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Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page12of12 The Government has no objection to fact testimony from Lopez about the admitted exhibits. On December 13, however, defense counsel informed the Government that they may receive and produce financial records about which they would ask John Lopez to testify. Such records have not been produced to the Government as of the time of this letter. The Court should not permit the defense to produce and introduce additional financial records between now and Lopez’s testimony. The account statements showing the financial transactions that the Government proved at trial were all produced to the defense more than a year before trial. Production of new exhibits at this late date would violate Rule 16 and would likely prejudice the Government. VI. ‘Conclusion For the reasons set forth above, the Court should deny the defendant’s motion. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: ___s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by e-mail) {2 DOJ-OGR-00011264