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is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
eks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XL The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29,2020, amidst a global pandemic that suspendedgrand juries across the country, the Government sought
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
nse 199 EFTA00095291 occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Aviyulallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298 United States v. Barlow, 732 F. Supp. 2d I (E.D.N.Y. 2010) 300
Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied 185 XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper 193 A. Background 194 1. The SDNY and Local Rules for the Division of Business 194 2. The SDNY Any Plan 19
Entities connected to both Bahna and The Use of a Grand Jury Siting
Blaszczak
PERSONBortnovsky
PERSONMahabub
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Bill Richardson
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John F. Kennedy
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United States
LOCATIONMandell
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Audrey Strauss
PERSONTracy
PERSONGuzman
PERSONthe Second Circuit's
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PERSONYonkers Contracting Co., Inc.
ORGANIZATIONZicarelli
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Ghislaine Maxwell
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Cynthia Nixon
PERSONCollins
PERSONWalsh
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