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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),
) is admitted with a limiting instruction to the July, if requested. See Huddleston v. United States, 485 U.S. 681, 691- 92 (1988); United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004). Here, evidence regarding the defendant's interactions with Minor Victim-3 is admissible to prove the defendant's
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),
) is admitted with a limiting instruction to the July, if requested. See Huddleston v. United States, 485 U.S. 681, 691- 92 (1988); United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004). Here, evidence regarding the defendant's interactions with Minor Victim-3 is admissible to prove the defendant's
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),
) is admitted with a limiting instruction to the jury, if requested. See Huddleston v. United States, 485 U.S. 681, 691- 92 (1988); United States v. LaFlam, 369 F.3d 153, 156 (2d Cir. 2004). Here, evidence regarding the defendant's interactions with Minor Victim-3 is admissible to prove the defendant's
Entities connected to both Falso and LaFlam

Jeffrey Epstein
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Bradley Edwards
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Ghislaine Maxwell
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United States
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Eric Schmidt
PERSONJane Doe
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Julie K. Brown
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David Boies
PERSONColleen McMahon
PERSONthe Southern District
LOCATIONWerner
PERSONSweet
PERSONMartindell
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Colorado
LOCATIONJeffrey Pagliuca
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Martinez
PERSONMartin Weinberg
PERSONTowne
LOCATIONRaymonda
LOCATIONLoera
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