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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 16 of 91 16 k7e2MaxC kjc 1 include electronic materials, to be due by Monday, November 9 2 of this year, and following that we would propose the following 3 motion schedule: that defense motions be due by Monday, 4 December 21 of this year; that the government's response be due 5 on Friday, January 22, 2021; and that replies be due on Friday, 6 February 5, 2021. 7 THE COURT: All right. Mr. Cohen, based on the 8 government's description of both the quantity and quality of 9 discovery, is that schedule that's been laid out sufficient 10 from your perspective to do everything that you need to do? 11 MR. COHEN: Your Honor, just two points in that 12 regard. [ think counsel for the government did not mention in 13 the e-mail we had sent to your Honor's law clerk that August 21 14 would be the deadline for production of search warrant 15 applications and the subpoena returns. I think she just failed 16 to mention it for the record. That would also be part of the 17 schedule. 18 THE COURT: Thank you. 19 Ms. Moe, do you agree? 20 MS. MOE: That's correct, your Honor. apologize. 21 We did include that in the e-mail to your Honor's chambers, and 22 that is correct. 23 And thank you, counsel, for clarifying that. 24 MR. COHEN: Two additional points, your Honor. The 25 trial schedule that we are agreeing to, of course subject to SOUTHERN D STRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001893