To get a Franks hearing, it’s necessary to make an offer of proof, and defendant failed to do so. Defendant does not get a Franks hearing here because he also didn’t show that he’d have standing to make the challenge in the place searched to begin with. Defendant’s argument that police should have obtained an anticipatory warrant fails because there was no way to anticipate one here. United States v. Woodley, 2016 U.S. Dist. LEXIS 9479 (W.D.Pa. Jan. 27, 2016).
Codefendant had no standing to join in one defendant’s motion to suppress apartment search. United States v. Ford, 2016 U.S. Dist. LEXIS 10025 (D.D.C. Jan. 28, 2016).*