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STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2 ARGUMENT 4 EFTA00106018 TABLE OF AUTHORITIES Page(s) Cases Duren v. Missouri, 439 U.S. 357 (1979) 5, 7 Holland v. Illinois, 493 U.S. 474 (1990) 1 Taylor v. Louisiana, 419 U.S. 522 (1975) 4 United States v
stematic underrepresentation of Black and Hispanic persons from the jury selection process, in violation of Ms. Maxwell's Sixth Amendment right. In Duren v. Missouri, the Supreme Court set forth the three elements that must be shown to establish a prima facie violation of the fair cross-section requir
d. As a result of the COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master Wheel and to indict Ms. Maxwell using a White Plains grand jury. B. This District's Jun Plan The Jury Selection and Service Act of 1968 mandates that each federal district court "devise and place in
STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2 ARGUMENT 4 EFTA00077250 TABLE OF AUTHORITIES Page(s) Cases Duren v. Missouri, 439 U.S. 357 (1979) 5, 7 Holland v. Illinois, 493 U.S. 474 (1990) 1 Taylor v. Louisiana, 419 U.S. 522 (1975) 4 United States v
stematic underrepresentation of Black and Hispanic persons from the jury selection process, in violation of Ms. Maxwell's Sixth Amendment right. In Duren v. Missouri, the Supreme Court set forth the three elements that must be shown to establish a prima facie violation of the fair cross-section requir
d. As a result of the COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master Wheel and to indict Ms. Maxwell using a White Plains grand jury. B. This District's Jun Plan The Jury Selection and Service Act of 1968 mandates that each federal district court "devise and place in
STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2 ARGUMENT 4 EFTA00099511 TABLE OF AUTHORITIES Page(s) Cases Duren v. Missouri, 439 U.S. 357 (1979) 5, 7 Holland v. Illinois, 493 U.S. 474 (1990) 1 Taylor v. Louisiana, 419 U.S. 522 (1975) 4 United States v
stematic underrepresentation of Black and Hispanic persons from the jury selection process, in violation of Ms. Maxwell's Sixth Amendment right. In Duren v. Missouri, the Supreme Court set forth the three elements that must be shown to establish a prima facie violation of the fair cross-section requir
d. As a result of the COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master Wheel and to indict Ms. Maxwell using a White Plains grand jury. B. This District's Jun Plan The Jury Selection and Service Act of 1968 mandates that each federal district court "devise and place in
(S.D. Fla. 2019) 14 Doe No. 1. v. United States, 749 F.3d 999 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 234 Falter v. Uni
ess 194 2. The SDNY Jury Plan 195 B. Applicable Law 197 C. Discussion 198 1. The Defendant Was Properly Indicted by a Grand Jury Sitting in White Plains 198 2. The Defendant's Fair Cross-Section Claim Is Meritless 205 a. The Defendant Has Not Established that Blacks or Hispanics Are Unfairly Repres
Entities connected to both Duren and White Plains

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
George W. Bush
PERSON
United States
LOCATION
Donald Trump
PERSON
Lesley Groff
PERSON
Nassau
LOCATION
Newark
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSON
Westchester
LOCATIONEmmy Taylor
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
Supreme Court
ORGANIZATION
Colorado
LOCATION