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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
20 announcement of the indictment and arrest of Ghislaine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains Division. In doing so, the government procured Ms. Maxwell's indictment using a grand jury pool that excluded residents of the community in which Ms. Maxwel
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
20 announcement of the indictment and arrest of Ghislaine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains Division. In doing so, the government procured Ms. Maxwell's indictment using a grand jury pool that excluded residents of the community in which Ms. Maxwel
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
20 announcement of the indictment and arrest of Ghislaine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains Division. In doing so, the government procured Ms. Maxwell's indictment using a grand jury pool that excluded residents of the community in which Ms. Maxwel
Jury Wheel to the population of the Manhattan "Division"—the defendant fails to establish unfair underrepresentation under the second prong of the Duren test. Moreover, the defendant has not established that any disparity resulted from systemic exclusion of a particular group. Accordingly, the motion
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
antees a criminal defendant a jury selected from a fair cross section of the community." United States v. Rioux, 97 F.3d 648, 654 (2d Cir. 1996). In Duren v. Missouri, the Supreme Court articulated a three part test that defendants must meet in order to 197 EFTA00077829 establish a prima facie viol
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
antees a criminal defendant a jury selected from a fair cross section of the community." United States v. Rioux, 97 F.3d 648, 654 (2d Cir. 1996). In Duren v. Missouri, the Supreme Court articulated a three part test that defendants must meet in order to 197 EFTA00039644 establish a prima facie viol
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
antees a criminal defendant a jury selected from a fair cross section of the community." United States v. Rioux, 97 F.3d 648, 654 (2d Cir. 1996). In Duren v. Missouri, the Supreme Court articulated a three part test that defendants must meet in order to establish a prima facie violation of the fair cr
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
rantees a criminal defendant a jury selected from a fair cross section of the community." United States v. Rios, 97 F.3d 648, 654 (2d Cir. 1996). In Duren v. Missouri, the Supreme Court articulated a three part test that defendants must meet in order to 197 EFTA00103222 establish a prima facie viol
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
Entities connected to both Duren and the White Plains Division

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONEmmy Taylor
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONWalker
PERSONRusso
PERSONCollins
PERSONThompson
PERSONTracy
PERSON
Giglio
PERSONBortnovsky
PERSONAnnabi
PERSON
Brady
PERSON
Southern District of New York
ORGANIZATIONCoppa
PERSON
Bronx
LOCATIONFBI
ORGANIZATION
White Plains
LOCATION
Jackman
PERSON