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the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement
ts' claims of Government Franks violations. To obtain 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
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement
ts' claims of Government Franks violations. To obtain 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
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement
ts' claims of Government Franks violations. To obtain 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
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement
ts' claims of Government Franks violations. To obtain 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
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement
ts' claims of Government Franks violations. To obtain 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
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
RD A. LEBEDEKER MARK T. LUTEIER. PA- MICHAEL ). PIKE DAVID A. YAREMA if LOIUDA WARD CERTIFIED CIVIL TRIAL LAWYER 2nomirrao TO maw! IN FLORIDA AND COLORADO Roy Black, Esq. Black, Srebnick, Komspan & Ptumpf 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 33131 March 4, 2010 Martin G. Weinberg, Esq.
imposed minimum. Notwithstanding the above legal analysis, in the recent case of Individual Known to Defendant As 08MIST096.JPG and 08mist067.ipg Falso, 2009 WL 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York s Plaintiff has attempted to allege 6
Entities connected to both Colorado and Falso

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
United States
LOCATION
George W. Bush
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Julie K. Brown
PERSONJeffrey Pagliuca
PERSON
Michigan
LOCATION
Supreme Court
ORGANIZATION
Alexander Acosta
PERSON
Michael Jackson
PERSON
Scarlett Johansson
PERSON
Stephen Hawking
PERSON
Minnesota
LOCATIONFBI
ORGANIZATION
Oregon
LOCATION
North Carolina
LOCATION