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be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 15 of 91 k7e2MaxC kjc THE bu COURT: Among other things, down specifically on that since that has be comparable circumstances in other matters, related to timely disclosures. MS. MOE: Yes, your Honor. Our te 15 t, yes, I'm drilling en, in somewhat issues the source of am met personally in Florida to make sure tha with the F.B. t we had the materials, and it was represented to us the F.B. provided in Florida were the that comprehensive set of the materials that materials. We will certainly have ongoing conversations to make sure that that we discover other m care, and we are pa in our review of is the case and if, aterials, we will handle that with great rticularly sensitive to that concern. THE COURT: just accepting of i And I xpect here, and in all matters, nitial representations made regarding disclosure, but tho questions and issue appropriate files. MS. MOE: THE COURT: With that, proposed schedule t [T will hear fr then files, not ughtful and critical pushing and pressing of Ss with respect to actively retrieving any Are we on the same page, Ms. Moe? Yes, your Honor. Very much so. All right. Thank you. why don't you go ahead and lay out the hat you have discussed with Mr. Cohen, and he has om Mr. Cohen if any concerns with that proposal. MS. MOE: Yes, your Honor. We would propose the completion of discovery, to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001892