This memorandum supports Ghislaine Maxwell's motion to dismiss the superseding indictment on the grounds that it was obtained in violation of the Sixth Amendment. The argument centers on the claim that the grand jury was improperly drawn from the White Plains Division, which underrepresented Black and Hispanic communities, rather than the Manhattan Division where the alleged offenses occurred. The memorandum argues that this violated Maxwell's right to a fair cross-section of the community.
documents/EFTA00099510.pdf
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