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Extraction Summary

10
People
4
Organizations
1
Locations
7
Events
6
Relationships
6
Quotes

Document Information

Type: Legal document
File Size: 727 KB
Summary

This legal document, a page from a court filing dated April 16, 2021, discusses the legal standard for challenging an affidavit based on alleged omissions of fact. It cites numerous precedents, primarily from the Second Circuit and the Southern District of New York, to argue that a motion to suppress evidence should be denied unless the omissions were intentional, deliberate, or made with reckless disregard for the truth. The document emphasizes that this is a high standard to meet, as courts recognize that all affidavits will inevitably omit some facts that may seem significant in retrospect.

People (10)

Name Role Context
Martin Party in a legal case
Mentioned in the case citation 'United States v. Martin, 426 F.3d 68, 74 (2d Cir. 2005)'.
Lambus Party in a legal case
Mentioned in the case citation 'Lambus, 897 F.3d at 399'.
Rivera Party in a legal case
Mentioned in the case citation 'Rivera v. United States, 928 F.2d 592, 604 (2d Cir. 1991)'.
Franks Party in a legal case
Mentioned in reference to the 'intent prong of Franks' and a 'Franks challenge', which refers to the legal precedent ...
Awadallah Party in a legal case
Mentioned in the case citation 'Awadallah, 349 F.3d at 68'.
Lahey Party in a legal case
Mentioned in the case citation 'United States v. Lahey, 967 F. Supp. 2d 698, 708 (S.D.N.Y. 2013)'.
Vilar Party in a legal case
Mentioned in the case citation 'United States v. Vilar, No. 05 Cr. 621 (KMK), 2007 WL 1075041, at *27 (S.D.N.Y. Apr. ...
DeFilippo Party in a legal case
Mentioned in the case citation 'United States v. DeFilippo, No. 17 Cr. 585 (WHP), 2018 WL 740727, at *2 (S.D.N.Y. Jan...
Falso Party in a legal case
Mentioned in the case citation 'Falso, 544 F.3d at 125'.
Pizarro Party in a legal case
Mentioned in the case citation 'United States v. Pizarro, No. 17 Cr. 151 (AJN), 2018 WL 1737236, at *10 (S.D.N.Y. Apr...

Organizations (4)

Name Type Context
United States government agency
Appears as a party in multiple legal cases, such as 'United States v. Martin' and 'Rivera v. United States'.
2d Cir. court
Referenced in case citations, indicating the United States Court of Appeals for the Second Circuit.
S.D.N.Y. court
Referenced in case citations, indicating the United States District Court for the Southern District of New York.
DOJ government agency
Appears in the footer as 'DOJ-OGR-00003075', likely standing for Department of Justice.

Timeline (7 events)

1991
Legal case: Rivera v. United States, 928 F.2d 592.
2d Cir.
2005
Legal case: United States v. Martin, 426 F.3d 68.
2d Cir.
2007-04-04
Legal case: United States v. Vilar, No. 05 Cr. 621 (KMK).
S.D.N.Y.
2013
Legal case: United States v. Lahey, 967 F. Supp. 2d 698.
S.D.N.Y.
2018-01-31
Legal case: United States v. DeFilippo, No. 17 Cr. 585 (WHP).
S.D.N.Y.
2018-04-10
Legal case: United States v. Pizarro, No. 17 Cr. 151 (AJN).
S.D.N.Y.
2021-04-16
Document 204 was filed in case 1:20-cr-00330-PAE.

Locations (1)

Location Context
Mentioned in several case citations as the location of the court (Southern District of New York).

Relationships (6)

United States legal/adversarial Martin
The document cites the case 'United States v. Martin', indicating a legal proceeding between the two parties.
Rivera legal/adversarial United States
The document cites the case 'Rivera v. United States', indicating a legal proceeding between the two parties.
United States legal/adversarial Lahey
The document cites the case 'United States v. Lahey', indicating a legal proceeding between the two parties.
United States legal/adversarial Vilar
The document cites the case 'United States v. Vilar', indicating a legal proceeding between the two parties.
United States legal/adversarial DeFilippo
The document cites the case 'United States v. DeFilippo', indicating a legal proceeding between the two parties.
United States legal/adversarial Pizarro
The document cites the case 'United States v. Pizarro', indicating a legal proceeding between the two parties.

Key Quotes (6)

"there remains a residue of independent and lawful information sufficient to support probable cause."
Source
— United States v. Martin (Describing the 'ultimate inquiry' after correcting alleged errors or omissions in an affidavit.)
DOJ-OGR-00003075.jpg
Quote #1
"[E]ven if the misrepresented or omitted information was material, a motion to suppress is to be denied unless the misrepresentations or omissions were intentional or deliberate, or were made in reckless disregard for the truth."
Source
— Lambus (Stating the standard for suppressing evidence based on misrepresentations or omissions.)
DOJ-OGR-00003075.jpg
Quote #2
"Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead."
Source
— Awadallah (Explaining the intent prong of a Franks challenge with respect to omissions.)
DOJ-OGR-00003075.jpg
Quote #3
"‘[a]ll storytelling involves an element of selectivity,’ and it is therefore not necessarily constitutionally significant that an affidavit ‘omit[s] facts which, in retrospect, seem significant.’"
Source
— United States v. Lahey (quoting United States v. Vilar) (Justifying the inherent nature of omissions in affidavits.)
DOJ-OGR-00003075.jpg
Quote #4
"As courts in this Circuit have recognized, it is not shocking that every affidavit will omit facts which, in retrospect, seem significant."
Source
— United States v. DeFilippo (Reinforcing the idea that omissions in affidavits are common and not necessarily problematic.)
DOJ-OGR-00003075.jpg
Quote #5
"[C]onclusory allegations cannot support a Franks challenge as a matter of law."
Source
— United States v. Pizarro (Stating that mere allegations without substance are insufficient for a Franks challenge.)
DOJ-OGR-00003075.jpg
Quote #6

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