The following excerpt is from United States v. Sheikh, No. 2:18-cr-00119-WBS (E.D. Cal. 2020):
6. The court recognizes that other allegations in the warrant affidavit discuss potential immigration and financial harm, which could potentially support violation of the forced labor statute, 18 U.S.C. 1589, even if physical force, physical restraint, or physical harm, or threats of physical force, physical restraint, or physical harm were not used. See United States v. Dann, 652 F.3d 1160, 1171-72 (9th Cir. 2011). The court expresses no opinion as to whether there was in fact probable cause under Franks without the warrant application's allegations of physical force, restraint, or harm, or threats of physical force, restrain, or harm.
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