Court Filing - Memorandum in Support of Motion to Dismiss: 126
The memorandum argues that the government's use of a White Plains Division grand jury to indict Ghislaine Maxwell was unconstitutional because it did not represent a fair cross-section of the community where the alleged crimes took place. The document highlights that the Manhattan Division grand jury was available but not used, and that the White Plains Division jury pool underrepresented Black and Hispanic residents.
Summary
The memorandum argues that the government's use of a White Plains Division grand jury to indict Ghislaine Maxwell was unconstitutional because it did not represent a fair cross-section of the community where the alleged crimes took place. The document highlights that the Manhattan Division grand jury was available but not used, and that the White Plains Division jury pool underrepresented Black and Hispanic residents.
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GRAND JURY [EFTA00008998]
GRAND JURY EXHIBIT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA SUPERSEDING INDICTMENT GHISLAINE MAXWELL, Defendant. S1 20 Cr. 330 (AJN) COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW The char...
Invoice Number: 4.013-86582
DOJ EFTA Data Set 10 document EFTA01313161
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reached in this case, and other information in the possession of the victims, it is also possible that
reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: a) involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein; b) Attorney liklimenvolvement in and/or awareness of the Government's interest."( witness, subject, or target of the Epstein investigation, including Sarah Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, [REDACTED - Survivor], Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs and telephone billing statements) made by or received by m Jeffrey Epstein, the Florida Science
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