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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),
nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n
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),
nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n
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),
nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n
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),
nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n
Entities connected to both Falso and Rolan-Zapata

Jeffrey Epstein
PERSON
Bradley Edwards
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Eric Schmidt
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Julie K. Brown
PERSONJane Doe
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Ghislaine Maxwell
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David Boies
PERSONColleen McMahon
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United States
LOCATIONMartindell
PERSONthe Southern District
LOCATIONSweet
PERSON
Martinez
PERSONMartin Weinberg
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Colorado
LOCATIONRaymonda
LOCATIONLoera
LOCATIONAshburn
LOCATIONBryson v. United States
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Kendall Coffey
PERSON