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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),
68 F.2d 216, 222 (2d Cir. 1992) (citingLeon , 468 U.S. at 923). The good faith exception analysis applies in the context of court orders. See, e.g., Zodhiates, 901 F.3d at 143 (applying good faith analysis in Fourth Amendment challenge to cell phone location information obtained by subpoena issued pursuan
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),
68 F.2d 216, 222 (2d Cir. 1992) (citing Leon, 468 U.S. at 923). The good faith exception analysis applies in the context of court orders. See, e.g., Zodhiates, 901 F.3d at 143 (applying good faith analysis in Fourth Amendment challenge to cell phone location information obtained by subpoena issued pursuan
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),
68 F.2d 216, 222 (2d Cir. 1992) (citing Leon, 468 U.S. at 923). The good faith exception analysis applies in the context of court orders. See, e.g., Zodhiates, 901 F.3d at 143 (applying good faith analysis in Fourth Amendment challenge to cell phone location information obtained by subpoena issued pursuan
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),
68 F.2d 216, 222 (2d Cir. 1992) (citing Leon, 468 U.S. at 923). The good faith exception analysis applies in the context of court orders. See, e.g., Zodhiates, 901 F.3d at 143 (applying good faith analysis in Fourth Amendment challenge to cell phone location information obtained by subpoena issued pursuan
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),
68 F.2d 216, 222 (2d Cir. 1992) (citing Leon, 468 U.S. at 923). The good faith exception analysis applies in the context of court orders. See, e.g., Zodhiates, 901 F.3d at 143 (applying good faith analysis in Fourth Amendment challenge to cell phone location information obtained by subpoena issued pursuan
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Julie K. Brown
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