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759 KB
Extraction Summary
3
People
2
Organizations
4
Locations
4
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
759 KB
Summary
This legal document is a preliminary statement arguing that Ghislaine Maxwell's Sixth Amendment rights were violated. The defense claims the government, rushing to meet a self-imposed July 2, 2020 deadline, improperly used a grand jury from the White Plains Division instead of the Manhattan Division, where the alleged crimes occurred. This resulted in a grand jury pool that significantly underrepresented Black and Hispanic residents, thus denying Maxwell her right to be indicted by a jury drawn from a fair cross-section of the community.
People (3)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein |
Mentioned in the context of the government's determination to mark the anniversary of his indictment with the announc...
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| Ghislaine Maxwell | Defendant |
The central figure of the document, referred to as Ms. Maxwell. The document argues that her Sixth Amendment rights w...
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| Balde | Defendant in a separate case |
Mentioned in a case citation (U.S. v. Balde) where a similar challenge to the government's grand jury practice was made.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| U.S. Government | Government agency |
Referred to as 'the government', it is the prosecuting body that sought and obtained the indictment against Ms. Maxwell.
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| S.D.N.Y. | Court |
Abbreviation for the Southern District of New York, the court district where the case is being heard, mentioned in a ...
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Timeline (4 events)
2020
The COVID-19 pandemic temporarily limited the availability of grand juries in the Manhattan courthouse.
Manhattan courthouse
2020-06-25
A Manhattan grand jury was seated, four days before Ms. Maxwell was indicted.
Manhattan
2020-07-02
The government's announcement of the indictment and arrest of Ghislaine Maxwell, timed to mark the anniversary of Jeffrey Epstein's indictment.
Indictment of Ghislaine Maxwell by a grand jury drawn from the White Plains Division.
White Plains Division
Locations (4)
| Location | Context |
|---|---|
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Location where the availability of grand juries was limited due to the COVID-19 pandemic.
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The division of the District from which a grand jury was not drawn, despite being the community where the alleged off...
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The division from which the grand jury that indicted Ms. Maxwell was drawn.
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Mentioned in the case citation 'Holland v. Illinois'.
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Relationships (2)
The document describes the government indicting Ms. Maxwell, and Ms. Maxwell's legal team challenging the validity of that indictment.
The document states the government timed the announcement of Maxwell's indictment to mark the anniversary of Jeffrey Epstein's indictment, implying a connection between their cases.
Key Quotes (1)
"[T]he Sixth Amendment entitles every defendant to object to a venire that is not designed to represent a fair cross section of the community, whether or not the systematically excluded groups are groups to which he himself belongs."Source
— Holland v. Illinois, 493 U.S. 474, 477 (1990)
(A quote from a Supreme Court case cited in a footnote to support the argument that Ms. Maxwell has standing to challenge the composition of the grand jury, even though she is not a member of the allegedly excluded groups (Black and Hispanic residents).)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,293 characters)
Case 1:20-cr-00330-AJN Document 126 Filed 01/25/21 Page 4 of 13
PRELIMINARY STATEMENT
When the COVID-19 pandemic temporarily limited the availability of grand juries in the Manhattan courthouse, the government responded with an extraordinary measure. Rather than wait a short time until residents of counties constituting the Manhattan Division of this District could appear for grand jury service, the government, in its apparent determination to mark the anniversary of its indictment of Jeffrey Epstein with a July 2, 2020 announcement of the indictment and arrest of Ghislaine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains Division. In doing so, the government procured Ms. Maxwell’s indictment using a grand jury pool that excluded residents of the community in which Ms. Maxwell 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 indicted by a grand jury drawn from a fair-cross section of the community.¹
It was unnecessary for the government to take this step. According to an email from a court official filed in connection with a similar challenge to the government’s practice, a Manhattan grand jury was seated as early as June 25, 2020—four days before Ms. Maxwell was indicted. See Exhibit A to Reply Memorandum in Support of Motion to Dismiss, U.S. v. Balde, No. 1:20-cr-00281-KPF (S.D.N.Y.), Dkt. No. 70-1 (filed Dec. 23, 2020). Had the government waited until that time, it might have been unable to meet its arbitrary July 2 deadline, and its press conference touting the indictment and arrest of Ms. Maxwell might have had slightly less
¹ The fact that Ms. Maxwell herself is neither Black nor Hispanic does not deprive of her of standing to raise this challenge. “[T]he Sixth Amendment entitles every defendant to object to a venire that is not designed to represent a fair cross section of the community, whether or not the systematically excluded groups are groups to which he himself belongs.” Holland v. Illinois, 493 U.S. 474, 477 (1990).
DOJ-OGR-00002324
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