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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
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article") .36 The Article stated, among other things, that defense attorneys representing victims of Epstein and the defendant "urged" the
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
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
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
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
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
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
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
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
Entities connected to both Franks v. Delaware and the "Daily News Article

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Julie K. Brown
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSONColleen McMahon
PERSON
Southern District of New York
ORGANIZATIONMartindell
PERSON
Supreme Court
ORGANIZATIONJane Doe
PERSON
Valentine
PERSON
Eric Schmidt
PERSON
Bradley Edwards
PERSON
Chris Tucker
PERSONMason
ORGANIZATION
Adriana Ross
PERSON
Bill Richardson
PERSON
Michael Jackson
PERSONMartin Weinberg
PERSON