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Case 21-58, Document 39-2, 04/01/2021, 3068530, Page/5 of 200 k7e2MaxC kjc 12 1 and federal law disclosure obligations. 2 Go ahead, Ms. Moe. 3 MS. MOE: Thank you, your Honor. 4 With respect to the items that the government 5 anticipates will be included in discovery in this case, we 6 expect that those materials will include, among other items, 7 search warrant returns, copies of search warrants, subpoena 8 returns, including business records, photographs, 9 electronically stored information from searches conducted on 10 electronic devices. In addition, the materials with respect to 11 the core of the case also include prior investigative files 12 from another investigation in the Southern District of Florida 13 among other items. 14 With respect to the status of discovery, the 15 government has begun preparing an initial production and are 16 prepared to produce a first batch of discovery as soon as a 17 protective order is entered by the court. 18 With respect to the status of the proposed protective 19 order, the government sent defense counsel a proposed 20 protective order last week. We have touched base about the 21 status of that with defense counsel, and they conveyed that 22 they would like to continue reviewing and discussing it with 23 the government, which we plan to do shortly after this 24 conference, with an eye towards submitting a proposed 25 protective order to the court as soon as possible. Following SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00019934