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Case 1:20-cr-00330-AJN Document 66 Filed 10/06/20 Page 3 of 3 Page 3 Government as part of its ongoing investigation, well in advance of any trial in this matter. Premature disclosure of these witnesses’ identities and sensitive information about those witnesses risks jeopardizing the Government’s ongoing investigation in at least two respects. First, disclosure would tend to reveal to the defendant the scope of and evidence gathered during the Government’s ongoing investigation, the details of which are not currently public or known to the defendant. Second, an order requiring the immediate production of these Materials would risk deterring other victims from coming forward to be interviewed and from providing evidence to the Government. Victims who may be considering cooperating with the Government’s investigation may decline to do so if they believe that the information they provide—even information outside the period charged in the Indictment—must be immediately disclosed to the defense in this case. Given the sensitivity of the Materials, the need to protect the Government’s ongoing investigation, and the minimal (if any) relevance of the Materials to the offenses charged in the Indictment, the Government respectfully submits that good cause exists pursuant to Rule 16(d) to delay their disclosure. Accordingly, the Government respectfully requests that the Court approve the Government’s request to delay disclosure of these Materials. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney Maurene Comey / Alison Moe / Lara Pomerantz Assistant United States Attorneys Southern District of New York Tel: (212) 637-2324 Ce: All Counsel of Record (By ECF) There is no dispute that the materials referenced in the Government's letter will be turned over to the defense. The Government has indicated that it will do so. The only dispute, then, relates to the timing of such disclosure. See Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some delay of ; disclosure, see Dkt. No. 65 at 4, the Court grants the Government’s hi ) si request to delay disclosure. However, the Government’s proposal to SO ORDERED. 11/18/20 delay disclosure until 8 weeks in advance of trial is insufficient. In order to ensure that the defense can adequately prepare for trial, the Government shall produce the referenced materials, which are not voluminous, to the defense by March 12, 2021. Disclosure of the materials will of course be subject to the protective order entered by the Court, see Dkt. No. 36. Alison J. Nathan, U.S.D,J. SO ORDERED. DOJ-OGR-00001834