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ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the
Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit 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.
ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the
Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit 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.
ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the
Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit 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.
Entities connected to both the White Plains and Martin Decl

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Louisiana
LOCATION
Jackman
PERSONSullivan
PERSON
Bronx
LOCATION
Orange
LOCATIONDuren
PERSON
Westchester
LOCATIONKenny
PERSON
Scarlett Johansson
PERSONDutchess
LOCATIONPutnam
LOCATIONthe White Plains Division
ORGANIZATIONEmmy Taylor
PERSONOsorio
PERSON
White Plains
LOCATIONJeffrey Martin
PERSONReyes
PERSON