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be NO Ww ws Oo OY ~] oO Ke} a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:19-cr-00830-AT Document 26 k1lu2NoeC kjc approximately two weeks. It's going Filed 02/10/20 Page 5 of 15 5 I think there to take -- was at least 25 witness st atements th at we not only need to ollow up and maybe contact le who were incarcerated, review, but then we need to try and f those witnesses. There are some peop may have been released. There are nu done in terms of that our clients the It took are demanding that we do in their def federal government merous things that must be at least us tracking down specific details ns 90 days to investigate this case and to come up with an indictment. Accordingly, a law firm with one or two attorneys, without the resources of all the federal agencies, it is going to take us more than 90 days to do the same amount of work. So I don't think that it is an unreasonable request. Not to mention, I believe that if the court were not to grant some type of an adjournment, ourselves back here again, but the de we are going to find fense will just be ina better position to give you more specifics as to why we need more time 4 la maybe we can't track down spoke to this witness and now we have to Ther are numerous things about, court a bird's eye view of that early on, delay -- or avoid having those additional requests. and that's why we would this witness or we find another one. like that t try an hat think would come d suggest to give the so that maybe we can to come back repeatedly just to make I do believe that there is a Additionally, your Honor, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00022008