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ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
ct believes the documents are responsive to the subpoena." In re Various Grand Jury Subpoenas, 924 F. Supp. 2d 549, 552 (S.D.N.Y. 2013), aff'd, 579 F. App's 37 (2d Cir. 2014); see also Fisher v. United States, 425 U.S. 391, 408 (1976). It follows that the privilege does not apply when "[t]he existence an
ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
ct believes the documents are responsive to the subpoena." In re Various Grand Jury Subpoenas, 924 F. Supp. 2d 549, 552 (S.D.N.Y. 2013), aff'd, 579 F. App's 37 (2d Cir. 2014); see also Fisher v. United States, 425 U.S. 391, 408 (1976). It follows that the privilege does not apply when "[t]he existence an
ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
ct believes the documents are responsive to the subpoena." In re Various Grand Jury Subpoenas, 924 F. Supp. 2d 549, 552 (S.D.N.Y. 2013), aff'd, 579 F. App's 37 (2d Cir. 2014); see also Fisher v. United States, 425 U.S. 391, 408 (1976). It follows that the privilege does not apply when "[t]he existence an
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