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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 13 of 91 13 k7e2MaxC kjc 1 the entry of that protective order, as I noted, your Honor, the 2 government is prepared to make a substantial production of 3 discovery. 4 Your Honor, in advance of the conference, th 5 government and defense counsel proposed a joint schedule for 6 discovery, motion practice, and a proposed trial date, in 7 particular, the date selected in that schedule with an eye 8 towards assuring that there was sufficient time for the 9 government to do a careful and exhaustive and thorough review 10 of all of the materials that I just referenced to make sure 11 that the government is complying with its discovery obligations 12 in this case, which we take very seriously. We expect that the 13 bulk of the relevant materials will be produced in short order, 14 primarily by the end of this summer, with additional materials 15 to follow primarily in a category I mentioned before, your 16 Honor, of electronically stored information, which is subject 17 to an ongoing privilege review which we discussed and 18 communicated with defense counsel about. We have proposed a 19 scheduling order again to be very thorough in our review of 20 discovery and in files in various places where they may be 21 located and we are taking an expansive and thoughtful approach 22 to our obligations in this case, your Honor. 23 THE COURT: Let me just follow up specifically, since 24 you have r renced prior investigative files, to th xtent w 25 have seen in other matters issues with complete disclosure of SOUTHERN D STR CT RE PORTERS, P.C. (212) 805-0300 DOJ-OGR-00001890