Where there is a First and Fourth Amendment and common law right to discovery of search warrant materials, Supplemental Rule G also provides for it for forfeiture. Here, however, the government shows in camera that disclosure now would jeopardize an ongoing investigation. United States v. 2015 Dodge Ram 3500 Truck, 2018 U.S. Dist. LEXIS 211065 (D. Neb. Dec. 14, 2018).
A motion to reopen a Franks hearing is subject to the abuse of discretion standard, and it wasn’t met here. The fact there were minor credibility findings as to whether and how one person was frisked doesn’t undermine the totality of the testimony of the witness as a matter of law. United States v. Aldissi, 2018 U.S. App. LEXIS 35014 (11th Cir. Dec. 13, 2018).*