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Case 1:20-cr-00330-AJN Document 5 Filed 07/05/20 Page 2 of 2 Honorable Alison J. Nathan United States District Judge July 5, 2020 Page 2 also intends to use the time until any initial appearance before Your Honor to discuss the terms of a protective order with defense counsel. Such a protective order will be necessary to facilitate the production of discovery while also protecting, among other things, the privacy and identity of third parties, including victims of the conduct charged in the Indictment. Accordingly, the Government respectfully requests that the Court exclude time both for the transportation of the defendant from another district, see 18 U.S.C. § 3161(h)(1)(F), and to allow the parties to engage in discussions regarding a protective order, which will serve the interests of justice by facilitating the timely production of discovery in a manner protective of the rights of third parties, including potential victims. See 18 U.S.C. § 3161(h)(7). The Government has consulted with defense counsel, who consents to this request. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 Ce: — Christian Everdell, Esq. (by email) Mark Cohen, Esq. (by email) DOJ-OGR-00001498