Epstein Secrets

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N. Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initi

grand jury that had issued a alliena for the production of documents as parl'of an ongoing ation5). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

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

ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

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

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

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

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

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

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

Parties' reliance."). 79 EFTA00100046 cau PPIal (Id. washy a granrad issulaubeaurnalMI an In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martind ell, reversed the district court's decision granting the state Attorney General's motion to intervene to

her the protective order was improvidently granted or whether the government had made a showing of exceptionalcircumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification o fprotective orders where district court did not make an "express finding" of improvidenc

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