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m, Kristy: Attached for review please find a draft opposition to Maxwell's motion to dismiss the indictment on the ground that it was returned by a White Plains grand jury. Per Tom's request, I am including a redline with our office's briefing in Balde, so you can easily see any differences between the two.
ndictment on the ground that it was returned by a White Plains grand jury. Per Tom's request, I am including a redline with our office's briefing in Balde, so you can easily see any differences between the two. I've also attached Maxwell's motion for reference. Thanks, EFTA00106015
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
A ("Martin Decl."). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell's grand jury was presumably drawn from the same wheels Mr. Martin analyzed. Mr. Martin fo
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
A ("Martin Decl."). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell's grand jury was presumably drawn from the same wheels Mr. Martin analyzed. Mr. Martin fo
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
A ("Martin Decl."). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell's grand jury was presumably drawn from the same wheels Mr. Martin analyzed. Mr. Martin fo
Entities connected to both White Plains and Balde

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Prince Andrew
PERSON
Westchester
LOCATION
Denver
LOCATIONLeon Black
PERSON
Colorado
LOCATIONEmmy Taylor
PERSON
Scarlett Johansson
PERSON
Louisiana
LOCATIONthe White Plains Division
ORGANIZATIONthe Manhattan Division
ORGANIZATION
Bronx
LOCATION
Michael Cohen
PERSONReyes
PERSON
Christian Everdell
PERSONCohen & Gresser LLP
ORGANIZATIONKenny
PERSONJeffrey Pagliuca
PERSON