filed Nov. 9, 2020), Exhibit A ("Martin Decl.").
Because the jury wheels are emptied and refilled only every four years, following a presidential
election, and the defendant in Balde, like ... wheel—not only when compared to the eligible juror population
in the Manhattan counties (Martin Decl. ¶t 61-62, 69-70), but also when compared to the eligible
juror population ... eligible juror population of the Manhattan
Division is 20.92% Black and 28.06% Hispanic (Martin Decl. ¶ 20), while the White Plans
qualified wheel refilled in February 2017 (and thus in effect