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s "'an impermissible attempt to compel the Government to provide the 176 EFTA00100143 evidentiary details of its case"' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it
r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans
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
as "'an impermissible attempt to compel the Government to provide the 176 EFTA00077808 evidentiary details of its case' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it
r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans
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
as "'an impermissible attempt to compel the Government to provide the 176 EFTA00039623 evidentiary details of its case' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it
r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans
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
r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans
particulars request as "'an impermissible attempt to compel the Government to provide the evidentiary details of its case" (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it
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
as "'an impermissible attempt to compel the Government to provide the 176 EFTA00103201 evidentiary details of its case' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it
r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans
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
United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d
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 Biaggi and The Use of a Grand Jury Siting

Scarlett Johansson
PERSON
Cynthia Nixon
PERSON
United States
LOCATION
Jeffrey Epstein
PERSON
John F. Kennedy
PERSONthe Second Circuit's
ORGANIZATIONPerez
PERSONGallo
PERSONYonkers Contracting Co., Inc.
ORGANIZATIONZicarelli
PERSON
Ghislaine Maxwell
PERSONCollins
PERSONWalsh
PERSON
Louisiana
LOCATIONGibson
PERSONSoares
PERSONWalker
PERSONRusso
PERSONJimenez
PERSONThompson
PERSON