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ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pen
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pend
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pend
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
igible for jury service); Rioux, 97 F.3d at 657 ("We conclude that the 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aft"), which was prepared for the defense in United States v. Balde, 20 Cr. 281 (KPF), where a similar motion is currently pending
ent has conceded that Ms. Maxwell's indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.")). Her use of the term "division" is imprecise and attributes legal significance where there is none. Understanding how that is so requires some
ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pen
Entities connected to both the White Plains Division and Jeffrey O'Neal

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONEmmy Taylor
PERSONCollins
PERSON
United States
LOCATION
Brady
PERSONRusso
PERSONThompson
PERSONBortnovsky
PERSON
Giglio
PERSONCoppa
PERSONWalker
PERSON
Scarlett Johansson
PERSONTracy
PERSONAnnabi
PERSON
Southern District of New York
ORGANIZATION
Bronx
LOCATIONLeon Black
PERSONthe White Plains
LOCATIONDutchess
LOCATION