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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),
the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Z
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),
the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Z
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),
the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulino, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Z
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),
the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Za
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),
the defendant's bad character, or unless it is overly prejudicial under Fed. R. Evid. 403 or not relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Za
Entities connected to both Falso and Pascarella

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Eric Schmidt
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
David Boies
PERSONColleen McMahon
PERSONConcepcion
PERSONSweet
PERSON
Southern District of New York
ORGANIZATIONBenussi
PERSONJane Doe
PERSONSalinas
PERSONMartindell
PERSON
Figueroa
PERSONthe Southern District
LOCATIONMartin Weinberg
PERSONSliker
PERSONHuddleston
PERSON