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er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the firstFranks hurdle with a substantial preliminary showingof a false statement or om
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "'[a]ll storytelling involves an element of selectivity,' and it is therefore not necessarily co
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the first Franks hurdle with a substantial preliminary showing of a false statement or
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "la]ll storytelling involves an element of selectivity,' and it is therefore not necessarily con
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the first Franks hurdle with a substantial preliminary showing of a false statement or
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "la]ll storytelling involves an element of selectivity,' and it is therefore not necessarily con
Entities connected to both Palm Beach and Awadallah

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Eric Holder
PERSON
Marc Rich
PERSON
Lesley Groff
PERSONJane Doe
PERSON
Bradley Edwards
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
Bill Clinton
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Virginia Giuffre
PERSON
John F. Kennedy
PERSON
Alexander Acosta
PERSONDarren Indyke
PERSON
Sarah Kellen
PERSON