Manhattan Division

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DOJ-OGR-00002330(1).jpg

This legal document, filed on January 25, 2021, argues that the jury selection process in the White Plains Division systematically excludes Black and Hispanic jurors. It relies on a statistical analysis by Mr. Martin, which found that the demographic makeup of the jury wheel deviates by more than three standard deviations from comparison populations, suggesting the discrepancy is inherent to the process and not a result of chance.

Legal document
2025-11-20

DOJ-OGR-00002329(1).jpg

This legal document, filed on January 25, 2021, presents an analysis by a 'Mr. Martin' concerning the underrepresentation of Black and Hispanic jurors. The analysis compares the demographic composition of the 'White Plains qualified wheel' (juror pool) to the eligible juror populations of the Manhattan Division and the entire Southern District of New York, finding significant disparities. This argument is being made in the context of a case involving 'Epstein's New York residence,' which is located in the Manhattan Division.

Legal document
2025-11-20

DOJ-OGR-00002325.jpg

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.

Legal filing / court motion (statement of facts)
2025-11-20

DOJ-OGR-00002325(1).jpg

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.

Legal filing / court motion (statement of facts)
2025-11-20

DOJ-OGR-00002324.jpg

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.

Legal document
2025-11-20

DOJ-OGR-00002324(1).jpg

This document is a preliminary statement from a legal motion filed on January 25, 2021, in the case of United States v. Ghislaine Maxwell. The defense argues that the government violated Maxwell's Sixth Amendment rights by using a grand jury from the White Plains Division rather than the Manhattan Division, allegedly to rush the indictment to coincide with the July 2 anniversary of Jeffrey Epstein's indictment. The defense claims this excluded a fair cross-section of the community, specifically underrepresenting Black and Hispanic residents, despite a Manhattan grand jury being available as early as June 25, 2020.

Legal filing (preliminary statement/motion)
2025-11-20
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