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Extraction Summary
3
People
4
Organizations
4
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court motion (statement of facts)
File Size:
705 KB
Summary
This document is page 5 of a legal filing (Statement of Facts) dated January 25, 2021, arguing that Ghislaine Maxwell's indictment should be dismissed due to Sixth Amendment violations. The defense contends that while the alleged crimes occurred at Epstein's Manhattan residence, the government improperly used a grand jury from White Plains due to COVID-19 protocols, deviating from established practice.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the indictment; arguing rights violation regarding jury selection location.
|
| Epstein | Associate/Co-conspirator |
Mentioned regarding his residence on the Upper East Side where alleged illegal acts occurred.
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| Minor Victim-1 | Victim |
Alleged victim intended to engage in unlawful sexual activity with Epstein.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The government |
Filed the indictment and selected the grand jury location.
|
|
| Manhattan Division of this Court |
Where the indictment was filed.
|
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| White Plains Division |
Where the grand jury was seated.
|
|
| United States District Court |
Court with the jury plan.
|
Timeline (2 events)
2020-06-29
The government filed a sealed indictment of Ms. Maxwell.
Manhattan Division
Locations (4)
| Location | Context |
|---|---|
|
Jurisdiction where the case was filed.
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Jurisdiction where the grand jury was seated.
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Specific location of alleged unlawful conduct.
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Location of the grand jury.
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Relationships (2)
Maxwell allegedly intended for Minor Victim-1 to engage in unlawful sexual activity with Epstein at his residence.
Maxwell allegedly intended for Minor Victim-1 to engage in unlawful sexual activity.
Key Quotes (4)
"Its failure to do so mandates dismissal of the indictment."Source
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Quote #1
"The government has conceded that Ms. Maxwell’s indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division."Source
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Quote #2
"the only specific location within this District that is referenced in the indictment is Epstein’s residence on the Upper East Side of Manhattan"Source
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Quote #3
"As a result of the COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master Wheel and to indict Ms. Maxwell using a White Plains grand jury."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,013 characters)
Case 1:20-cr-00330-AJN Document 126 Filed 01/25/21 Page 5 of 13
impact. But the government would have avoided violating Ms. Maxwell’s Sixth Amendment
right. Its failure to do so mandates dismissal of the indictment.
right. Its failure to do so mandates dismissal of the indictment.
STATEMENT OF FACTS
A. Procedural History
On June 29, 2020, the government filed a sealed indictment of Ms. Maxwell in the
Manhattan Division of this Court. The government has conceded that Ms. Maxwell’s indictment
was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively
from the White Plains Division. At no point, however, has the government alleged that Ms.
Maxwell engaged in any unlawful conduct in the White Plains Division, or that any overt act in
furtherance of the alleged conspiracies occurred in the White Plains Division. To the contrary,
the only specific location within this District that is referenced in the indictment is Epstein’s
residence on the Upper East Side of Manhattan, the location at which Ms. Maxwell allegedly
intended for Minor Victim-1 to engage in unlawful sexual activity with Epstein. Sealed
Indictment (“Indictment”), Dkt. No. 1 (filed Jun. 29, 2020), at ¶¶ 6a, 11b, 17b.
Manhattan Division of this Court. The government has conceded that Ms. Maxwell’s indictment
was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively
from the White Plains Division. At no point, however, has the government alleged that Ms.
Maxwell engaged in any unlawful conduct in the White Plains Division, or that any overt act in
furtherance of the alleged conspiracies occurred in the White Plains Division. To the contrary,
the only specific location within this District that is referenced in the indictment is Epstein’s
residence on the Upper East Side of Manhattan, the location at which Ms. Maxwell allegedly
intended for Minor Victim-1 to engage in unlawful sexual activity with Epstein. Sealed
Indictment (“Indictment”), Dkt. No. 1 (filed Jun. 29, 2020), at ¶¶ 6a, 11b, 17b.
The indictment of Ms. Maxwell, and apparently others in the wake of the COVID-19
pandemic, was a deviation from the established practice of indicting defendants in the division
where the offense is alleged to have occurred and where the case will be tried. As a result of the
COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master
Wheel and to indict Ms. Maxwell using a White Plains grand jury.
pandemic, was a deviation from the established practice of indicting defendants in the division
where the offense is alleged to have occurred and where the case will be tried. As a result of the
COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master
Wheel and to indict Ms. Maxwell using a White Plains grand jury.
B. This District’s Jury Plan
The Jury Selection and Service Act of 1968 mandates that each federal district court
“devise and place into operation a written plan for random selection of grand and petit jurors.”
28 U.S.C. § 1863(a). This District’s current plan was adopted in 2009. See Amended Plan for
the Random Selection of Grand and Petit Jurors in the United States District Court for the
“devise and place into operation a written plan for random selection of grand and petit jurors.”
28 U.S.C. § 1863(a). This District’s current plan was adopted in 2009. See Amended Plan for
the Random Selection of Grand and Petit Jurors in the United States District Court for the
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