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nst him if this is 174 EFTA00100141 necessary to the preparation of his defense, and to avo id prejud icial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
uals selected from voter registration lists, the racial and ethnic makeup of the White Plains Master Jury Wheel can be estimated using geocoding and Bayesian Improved Surname Geocoding ("BISG").69 Taking into account those estimates, the White Plains Master Wheel is 11.20% Black or African-American and 12.97% His
ainst him if this is 174 EFTA00077806 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
uals selected from voter registration lists, the racial and ethnic makeup of the White Plains Master Jury Wheel can be estimated using geocoding and Bayesian Improved Surname Geocoding ("BISG").69 Taking into account those estimates, the White Plains Master Wheel is 11.20% Black or African-American and 12.97% His
ainst him if this is 174 EFTA00039621 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
uals selected from voter registration lists, the racial and ethnic makeup of the White Plains Master Jury Wheel can be estimated using geocoding and Bayesian Improved Surname Geocoding ("BISG").69 Taking into account those estimates, the White Plains Master Wheel is 11.20% Black or African-American and 12.97% His
h the defendant committed the crime charged, or a preview of the Government's evidence or legal theories." Mitlof, 165 F. Supp. 2d at 569; see also Torres, 901 F.2d at 234 ("Acquisition of evidentiary detail is not the function of the bill of particulars.' (quoting Hemphill v. United States, 392 F.2d 4
uals selected from voter registration lists, the racial and ethnic makeup of the White Plains Master Jury Wheel can be estimated using geocoding and Bayesian Improved Surname Geocoding ("BISG") 69 Taking into account those estimates, the White Plains Master Wheel is 11.20% Black or African-American and 12.97% His
ainst him if this is 174 EFTA00103199 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
uals selected from voter registration lists, the racial and ethnic makeup of the White Plains Master Jury Wheel can be estimated using geocoding and Bayesian Improved Surname Geocoding ("BISG").69 Taking into account those estimates, the White Plains Master Wheel is 11.20% Black or African-American and 12.97% His
Entities connected to both Torres and Bayesian Improved

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Ghislaine Maxwell
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Scarlett Johansson
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