Epstein Secrets

iness 193 2. The SDNY Jury Plan 194 B. Applicable Law 197 C. Discussion 197 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 204 a. The Defendant Has Not Established that Blacks or Hispanics Are Unfairly Repr

2d 418 (2d Cir. 1983) 78, 81, 103 United States v. DeFilippo, No. 17 Cr. 585 (WHP), 2018 WL 740727 (S.D.N.Y. Jan. 31, 2018) 114 United States v. Delacruz, 970 F. Supp. 2d 199 (S.D.N.Y. 2013) 53 United States v. DePahna, 461 F. Supp. 778 (S.D.N.Y. 1978) 159, 164 United States v. Dewar, 489 F. Sup

nt has intentionally used delay to gain unfair tactical advantage."); see also United States v. Delacruz, 970 F. Supp. 2d 199, 203 (S.D.N.Y. 2013) ("Delacruz's motion to dismiss would nevertheless fail for the independent reason that he has not made any showing that the preindictment delay was an intenti

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

2 F.2d 418 (2d Cir. 1983) passim United States v. DeFilippo, No. 17 Cr. 585 (WHP), 2018 WL 740727 (S.D.N.Y. Jan. 31, 2018) 169 United States v. Delacruz, 970 F. Supp. 2d 199 (S.D.N.Y. 2013) 77 United States v. DePalma, 461 F. Supp. 778 (S.D.N.Y. 1978) 241, 250 United States v. Dewar, 489 F. Sup

nt has intentionally used delay to gain unfair tactical advantage."); see also United States v. Delacruz, 970 F. Supp. 2d 199, 203 (S.D.N.Y. 2013) ("Delacruz's motion to dismiss would nevertheless fail for the independent reason that he has not made any showing that the preindictment delay was an intenti

cluding 404(b) notice, at your convenience. Requests 21 and 22 — Information about the Grand Jury that Indicted this Case: A grand jury sitting in White Plains, New York that was empaneled in November 2019 returned Indictment 20 Cr. 330 (AJN) and Superseding Indictment S 120 Cr. 330 (AJN). No grand jurors

broad and blind fishing expedition among items possessed by the Government on the chance that something impeaching might turn up." United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *1 (S.D.N.Y. May 12, 2015) (internal quotation marks omitted). If there are any specific anticipated def