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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),
or sexual massages .. . you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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),
ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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),
ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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),
nt. 124 EFTA00095216 you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
Entities connected to both Falso and Cl Triumph Capital Grp.

Eric Schmidt
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Bradley Edwards
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Jeffrey Epstein
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Julie K. Brown
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David Boies
PERSONJeffrey Pagliuca
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Ghislaine Maxwell
PERSONJane Doe
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Stephen Hawking
PERSONLoretta A. Preska
PERSONPayner
PERSONColleen McMahon
PERSON
United States
LOCATIONthe Southern District
LOCATIONStephen Rex Brown
PERSONMing He
PERSONMartindell
PERSONSweet
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Colorado
LOCATION
Martinez
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