court filing or legal brief: Case 2:17-cr-00354-JAK Document 1859 Filed 03/22/21 Page 10 of 20

The document analyzes the District's Jury Plan and its territorial division, referencing United States v. Gottfried and United States v. Bahna. It discusses the rationale behind dividing jury pools territorially and the implications for fair cross-section challenges. The Second Circuit's decision in Bahna is highlighted as framing the inquiry into whether a jury venire drawn from a properly designated division satisfies fair cross-section requirements.