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Case 1:20-cr-00330-PAE Document 204-12 Filed 04/16/21 Page 6 of 30 Plains community benchmark for African Americans increased from 1.25% to 3.69% and for Hispanics increased from 1.15% to 3.64%. 11. Mr. Martin also compared the qualified jury wheel for White Plains with the Manhattan community and for the overall Southern District community. The White Plains master jury wheel is designed to be representative of the White Plains community, not the Manhattan or Southern District community. The Manhattan and the Southern District communities are significantly more African American and Hispanic than the White Plains community. Thus, since the White Plains master jury wheel is designed to be representative of the White Plains community, by design it will not be representative of the Manhattan or the Southern District community with respect to the percent African American and Hispanic. IV. DATA RELIED UPON 12. The data I received and relied upon is listed in Appendix B of this declaration. V. FINDINGS A. Overview of Qualified Jury Wheel Selection Process. 13. The master jury wheel which forms the basis for the qualified jury wheel for the White Plains community of the Southern District of New York is supposed to be drawn via a simple? random sample from the voter lists from the six counties (Westchester, Putnam, Rockland, Orange, Sullivan and Dutchess) making up White Plains. The November 1, 2016 voter registration lists were used to construct the master jury wheel used in this matter. However, either by design or in error, the selection from the voter lists was not actually a simple ? A simple random sample is one where each person in the population has an equal probability of being selected. DOJ-OGR-00003626