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r of a grand jury drawn from a community in which Black and Hispanic residents are significantly underre
allegedly committed the offenses with which she is charged, and in which she will be tried, in favor of a grand jury drawn from a community in which Black and Hispanic residents are significantly underrepresented by comparison. The government thus violated Ms. Maxwell's Sixth Amendment right to be indic
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.
r of a grand jury drawn from a community in which Black and Hispanic residents are significantly underre
allegedly committed the offenses with which she is charged, and in which she will be tried, in favor of a grand jury drawn from a community in which Black and Hispanic residents are significantly underrepresented by comparison. The government thus violated Ms. Maxwell's Sixth Amendment right to be indic
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.
r of a grand jury drawn from a community in which Black and Hispanic residents are significantly underre
allegedly committed the offenses with which she is charged, and in which she will be tried, in favor of a grand jury drawn from a community in which Black and Hispanic residents are significantly underrepresented by comparison. The government thus violated Ms. Maxwell's Sixth Amendment right to be indic
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 Leon Black and Martin Decl

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
Scarlett Johansson
PERSONSouthern District
LOCATION
Colorado
LOCATIONEmmy Taylor
PERSON
Denver
LOCATION
Louisiana
LOCATION
the United States District Court
ORGANIZATIONPutnam
LOCATIONSullivan
PERSONthe Upper East Side
LOCATIONReyes
PERSON
Bronx
LOCATIONJeffrey Pagliuca
PERSON
Jackman
PERSON
White Plains
LOCATION
Westchester
LOCATION