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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 221 of 239 premises, and at any rate fail to meet the elements of a claim under the Sixth Amendment. Therefore, the defendant’s motion must be denied. A. Background 1. The SDNY and Local Rules for the Division of Business The defendant’s brief repeatedly uses the term “Division” to describe a “White Plains Division” and a “Manhattan Division.” (See, e.g., Def. Mot. 9 at 2 (“On June 29, 2020, the government filed a sealed indictment of Ms. Maxwell in the Manhattan Division of this Court. The government has conceded that Ms. Maxwell’s indictment was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively from the White Plains Division.”)). Her use of the term “division” is imprecise and attributes legal significance where there is none. Understanding how that is so requires some background. District courts in each state in the United States are prescribed by statute. United States district courts in New York State are divided between four districts: Northern, Southern, Eastern and Western. 28 U.S.C. § 112. While certain districts in other states are further divided into “divisions” by statute, see, e.g., id. § 81 (dividing Alabama into three “districts” and multiple “divisions” within each district), the federal districts in New York State are not so divided. That is, in the Southern District, no “divisions” have been created by statute. /d. § 112(b). The statute provides only that “Court for the Southern District shall be held at New York, White Plains, and in the Middletown-Wallkill area of Orange County or such nearby location as may be deemed appropriate.” Id. In the Southern District, the only authority determining whether particular cases are heard in the Manhattan or White Plains courthouse is the SDNY Business Division Rules. These rules 99 begin with an important preface: they “shall not be deemed to vest any rights in litigants... . 194 DOJ-OGR-00003155