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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),
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
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),
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
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),
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
Entities connected to both Falso and this stage.51 The Court

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