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bstitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.'" Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
irectly rebutting the defendant's allegations, there is no material issue of fact sufficient to justify an evidentiary hearing. The defendant cites Franks v. Delaware, 438 U.S. 154 (1978), to suggest that a hearing is somehow warranted, but her motion falls far short of the Franks standard to obtain a hearing. "W
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
Entities connected to both Ming He and Franks v. Delaware

Jeffrey Epstein
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Julie K. Brown
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United States
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Ghislaine Maxwell
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David Boies
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Bradley Edwards
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Eric Schmidt
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Stephen Hawking
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