The memorandum argues that the government's use of a White Plains Division grand jury to indict Ghis...

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.