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Case 1:20-cr-00330-PAE Document 204-12 Filed 04/16/21 Page 12 of 30 because the voter list demographics are as of a specific point in time, while the community estimate is over a five-year period of time (2014-2018). 3) The community may differ from the randomly selected master jury wheel because of chance in selection from the voter registration lists. Randomly Selected Master Jury Wheel vs Actual Master Jury Wheel 4) The actual master jury wheel may differ from a randomly drawn master jury wheel because the sample selection underweights the probability of selection from the counties feeding both the White Plains and Manhattan master jury wheels. This is referred to as the “prorating” issue. 5) The actual master jury wheel may differ from a randomly drawn master jury wheel because, in five of the six counties, the voter registration lists did not include inactive voters. This is referred to as the “sample frame” issue. Qualified Jury Wheel vs Master Jury Wheel 6) The qualified jury wheel may differ from the master jury wheel because of clerical errors in transferring the mailing (alternative) address to the master jury wheel, which potentially results in not being able to properly reach some potential jurors on the master jury wheel to determine if they should be placed on the qualified jury wheel. 7) The qualified jury wheel may differ from the master jury wheel because being sent a questionnaire, returning the questionnaire, and being found to be qualified as a juror and not excused are different by race or ethnicity. 8) The qualified jury wheel may differ from the master jury wheel by chance resulting from the random selection of those on the master jury wheel who will be sent a questionnaire. 12 DOJ-OGR- 00003632