UNITED STATES V. MOHAMUD 33 Cromitie further claimed that the government had violated due process because a government informant had exploited his relationship with Cromitie to “manipulate Cromitie into agreeing to the planned attacks”; the court cited our precedent indicating that “the ‘illusory cultivation of emotional intimacy’ does not exceed due process limits.” Id. at 220 (quoting United States v. Simpson, 813 F.2d 1462, 1467 (9th Cir. 1987)). Even considering certain monetary benefits offered by the government informant—including $250,000 cash, a barbershop valued at $70,000, a new BMW, and a two-week vacation—the court held that the overall operation did not rise to the level of a due process violation. Id. Although Mohamud may have been more vulnerable than Cromitie, the government’s questionable actions in that case far exceeded anything here. In light of the extremely high standard set out in Black, we hold that the government’s conduct here did not violate due process. C. Late Notice Of § 702-Derived Evidence FISA requires the government to “notify the aggrieved person and the court” prior to trial when it intends to use at trial evidence “obtained or derived from electronic surveillance” pursuant to FISA. 50 U.S.C. § 1806(c); see also 50 U.S.C. § 1881e(a) (stating that information acquired under § 702 is subject to the notice requirement in § 1806(c)). The government provided a supplemental notice regarding evidence derived under § 702 after the trial concluded. Mohamud argues that this late disclosure mandates suppression, or at a minimum, discovery and an evidentiary hearing to explore the tardy disclosure.

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