{
  "document_metadata": {
    "page_number": "225",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 225 of 239\restablish a prima facie violation of the fair cross-section requirement: (1) the excluded group is \"distinctive\"; (2) \"representation of this group in venires from which juries are selected is not fair and reasonable in relation to the number of such persons in the community;\" and (3) the \"underrepresentation is due to systematic exclusion of the group in the jury-selection process.\" 439 U.S. 357, 364 (1979).\n\nC. Discussion\nThe Government's decision to seek an indictment of the defendant from a grand jury sitting in White Plains was entirely appropriate and consistent with the Constitution, the JSSA, and the SDNY local rules. The defendant's claims to the contrary rest on a faulty premise: That a defendant who is likely to be tried in the Manhattan courthouse must be indicted by a grand jury sitting in that same courthouse. That is not the law. See Section XI.C.1, infra.\nThat foundational error is fatal to the defendant's fair cross-section claim. When the proper comparators are considered—the White Plains Master (or Qualified) Wheels to the voting age population of the counties from which juries in White Plains are drawn, rather than the defendant's apples-to-oranges comparison of the White Plains Qualified Jury Wheel to the population of the Manhattan \"Division\"—the defendant fails to establish unfair underrepresentation under the second prong of the Duren test. Moreover, the defendant has not established that any disparity resulted from systemic exclusion of a particular group. Accordingly, the motion should be denied.\n1. The Defendant Was Properly Indicted by a Grand Jury Sitting in White Plains\nAt the heart of the defendant's fair cross-section claim is her contention that the Government seeking an indictment from a grand jury sitting in White Plains—which was the only 198 DOJ-OGR-00003159",
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      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 225 of 239",
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    {
      "type": "printed",
      "content": "establish a prima facie violation of the fair cross-section requirement: (1) the excluded group is \"distinctive\"; (2) \"representation of this group in venires from which juries are selected is not fair and reasonable in relation to the number of such persons in the community;\" and (3) the \"underrepresentation is due to systematic exclusion of the group in the jury-selection process.\" 439 U.S. 357, 364 (1979).",
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      "type": "printed",
      "content": "C. Discussion",
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      "content": "The Government's decision to seek an indictment of the defendant from a grand jury sitting in White Plains was entirely appropriate and consistent with the Constitution, the JSSA, and the SDNY local rules. The defendant's claims to the contrary rest on a faulty premise: That a defendant who is likely to be tried in the Manhattan courthouse must be indicted by a grand jury sitting in that same courthouse. That is not the law. See Section XI.C.1, infra.",
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    {
      "type": "printed",
      "content": "That foundational error is fatal to the defendant's fair cross-section claim. When the proper comparators are considered—the White Plains Master (or Qualified) Wheels to the voting age population of the counties from which juries in White Plains are drawn, rather than the defendant's apples-to-oranges comparison of the White Plains Qualified Jury Wheel to the population of the Manhattan \"Division\"—the defendant fails to establish unfair underrepresentation under the second prong of the Duren test. Moreover, the defendant has not established that any disparity resulted from systemic exclusion of a particular group. Accordingly, the motion should be denied.",
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    {
      "type": "printed",
      "content": "1. The Defendant Was Properly Indicted by a Grand Jury Sitting in White Plains",
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    {
      "type": "printed",
      "content": "At the heart of the defendant's fair cross-section claim is her contention that the Government seeking an indictment from a grand jury sitting in White Plains—which was the only",
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      "content": "198",
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      "content": "DOJ-OGR-00003159",
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  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "JSSA",
      "SDNY"
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    "locations": [
      "White Plains",
      "Manhattan"
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    "dates": [
      "04/16/21"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003159"
    ]
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  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and easy to read."
}