mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003769.json

{
  "document_metadata": {
    "page_number": "6",
    "document_number": "211",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 211 Filed 04/16/21 Page 6 of 11\nwhich effectuates the Sixth Amendment right to a fair cross-section, notes that the relevant \"community\" is \"the community in the district or division wherein the court convenes.\" 28 U.S.C. § 1861. Here, that is either the Manhattan Counties or the Southern District, as this Court is not \"convening\" in White Plains.\nEven United States v. Bahna, 68 F.3d 19 (2d Cir. 1995), on which the government heavily relies, recognizes this: \"Each [court] selects grand and petit juries pursuant to a plan . . . and, as a general rule, selections are made from the area surrounding the courthouse where the case is to be tried.\" Id. at 23 (emphases added). The government points to the Second Circuit's statement that \"[w]here a jury venire is drawn from a properly designated division, we look to that division to see whether there has been any unlawful or unconstitutional treatment of minorities.\" Opp. 201 (quoting Bahna, 68 F.3d at 24) (emphasis added by government). But the defendant in Bahna was tried on Long Island before a jury \"from the `Long Island Division' jury wheel.\" 68 F.3d at 23. He initially sought to have a jury \"culled only from Kings, Queens and Richmond Counties\"—i.e., from somewhere other than the place of trial. Id. at 26. Ms. Maxwell seeks precisely the opposite.\nThe government thus quotes the Second Circuit's statement in Bahna out of context, because Bahna was based on the very premise lacking here: a jury \"drawn from a properly designated division.\" Id. at 24. Unlike the Long Island Division in Bahna, White Plains was not \"properly designated\" to indict Ms. Maxwell.\nWhile the government claims that \"it is common for cases to be indicted by grand juries sitting in the White Plains courthouse and tried in the Manhattan courthouse\"—an assertion that has no bearing on the lawfulness of such a practice, particularly if not objected to—it cites just six such cases in the last 17 years. Opp. 195. The far more typical practice of using a grand jury",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 211 Filed 04/16/21 Page 6 of 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "which effectuates the Sixth Amendment right to a fair cross-section, notes that the relevant \"community\" is \"the community in the district or division wherein the court convenes.\" 28 U.S.C. § 1861. Here, that is either the Manhattan Counties or the Southern District, as this Court is not \"convening\" in White Plains.\nEven United States v. Bahna, 68 F.3d 19 (2d Cir. 1995), on which the government heavily relies, recognizes this: \"Each [court] selects grand and petit juries pursuant to a plan . . . and, as a general rule, selections are made from the area surrounding the courthouse where the case is to be tried.\" Id. at 23 (emphases added). The government points to the Second Circuit's statement that \"[w]here a jury venire is drawn from a properly designated division, we look to that division to see whether there has been any unlawful or unconstitutional treatment of minorities.\" Opp. 201 (quoting Bahna, 68 F.3d at 24) (emphasis added by government). But the defendant in Bahna was tried on Long Island before a jury \"from the `Long Island Division' jury wheel.\" 68 F.3d at 23. He initially sought to have a jury \"culled only from Kings, Queens and Richmond Counties\"—i.e., from somewhere other than the place of trial. Id. at 26. Ms. Maxwell seeks precisely the opposite.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "The government thus quotes the Second Circuit's statement in Bahna out of context, because Bahna was based on the very premise lacking here: a jury \"drawn from a properly designated division.\" Id. at 24. Unlike the Long Island Division in Bahna, White Plains was not \"properly designated\" to indict Ms. Maxwell.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "While the government claims that \"it is common for cases to be indicted by grand juries sitting in the White Plains courthouse and tried in the Manhattan courthouse\"—an assertion that has no bearing on the lawfulness of such a practice, particularly if not objected to—it cites just six such cases in the last 17 years. Opp. 195. The far more typical practice of using a grand jury",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003769",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "U.S.C.",
      "Second Circuit",
      "DOJ"
    ],
    "locations": [
      "Manhattan",
      "White Plains",
      "Long Island",
      "Kings",
      "Queens",
      "Richmond Counties"
    ],
    "dates": [
      "04/16/21",
      "1995"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 211",
      "28 U.S.C. § 1861",
      "68 F.3d 19",
      "Opp. 201",
      "Opp. 195",
      "DOJ-OGR-00003769"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Ms. Maxwell. The text discusses the selection of juries and the relevant community for the trial. The document is well-formatted and printed, with no visible handwriting or stamps."
}