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mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v
t privilege is not concerned `with moral and psychological pressures to confess emanating from sources other than official coercion.'" Id. (quoting Elsiad, 470 U.S. at 305). For this reason, even "[t]he most outrageous 98 EFTA00077730 behavior by a private party seeking to secure evidence against a
mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v
t privilege is not concerned `with moral and psychological pressures to confess emanating from sources other than official coercion.'" Id. (quoting Elsiad, 470 U.S. at 305). For this reason, even "[t]he most outrageous 98 EFTA00039545 behavior by a private party seeking to secure evidence against a
mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v
t privilege is not concerned `with moral and psychological pressures to confess emanating from sources other than official coercion.'" Id. (quoting Elsiad, 470 U.S. at 305). For this reason, even "[t]he most outrageous 98 EFTA00095190 behavior by a private party seeking to secure evidence against a
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