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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 1:19-cr-00830-AT Document 26 Filed 02/10/20 Page /7of15 7 k1lu2NoeC kjc THE COURT: will hear from the government. MS. LONERGAN: Yes, your Honor. As we put in our written submission to the court, we agree that a brief adjournment is appropriate, but we do not think that a six-month adjournment is necessary or warranted. First, the amount of discovery in this case is not particularly voluminous nor complex in light of the cases tried in this district; and, in addition, the further investigation, I want to focus the court on the facts that are going to be at issue in this trial occurred over a 14-hour period. It is true that, as part of our discovery, we provided information outside (e) requests that th But again, your indictment that is about hours. working conditions at the MCC, f£ that 14-hour period, anticipating many of the type s of e defense counsel has already begun to make. Honor, this isa A much larger investigation abou is going to be the issues on trial here. about the need t hav don Oo inter I want to also touch on something that pl view witnesses. court, w that we have provided witness sta discovery almost is aware, closer to trial. 8 som we typically provide wh four months in a thing that tements with our ini dvance of trial. As at we call 3500 mate So the need to review those witness OUTHERN DISTR CT PORT RE ERS, PC. (212) 805-0300 very focused, single-incident what happened over the period of 14 t, for example, the it is just not relevant to what aintiff said As we explained to the "s unusual here, which is tial the court rial much DOJ-OGR-00022010