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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
ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the
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
ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the
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
ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the
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
as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo
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
as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo
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
as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo
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
as well as the appropriate method of statistical comparison. See RiOUX, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo
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
as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo
Entities connected to both Duren and the White Plains

Jeffrey Epstein
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Ghislaine Maxwell
PERSON
Bronx
LOCATION
Louisiana
LOCATIONKenny
PERSON
Jackman
PERSONLeon Black
PERSON
United States
LOCATION
Westchester
LOCATIONSullivan
PERSONJimenez
PERSON
Orange
LOCATIONthe White Plains Division
ORGANIZATIONDutchess
LOCATIONPerez
PERSONPutnam
LOCATIONWalker
PERSONRusso
PERSON