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ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
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
ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
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
ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
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
ment cannot provide "mountains of documents to defense counsel" as a substitute for a bill of particulars where one would otherwise be required, see Bortnovsky, 820 F.2d at 575, the provision of voluminous discovery in combination with some guidance about what is most relevant can vitiate a need for furthe
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
ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
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 Bortnovsky and Bayesian Improved

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Giglio
PERSONAnnabi
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Southern District of New York
ORGANIZATIONThompson
PERSONRusso
PERSONEmmy Taylor
PERSONWalker
PERSONTracy
PERSONCollins
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Brady
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Scarlett Johansson
PERSONCoppa
PERSONthe White Plains Division
ORGANIZATION
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PERSONMahabub
PERSONMandell
PERSONTrippe
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