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Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 9 of 34 notes. On January 30, 2020,°? the Government reproduced video surveillance footage with timestamps, and on March 16, 2020, the Government produced forensic reports for three electronic devices and a photograph of a text message. B. Defense Requests for Additional Discovery Materials The defendants have made a number of requests for additional discovery materials, in response to which the Government has provided information in its possession as consistent with Rule 16 and its other disclosure obligations, as described below. At the initial pretrial conference on November 11, 2019, Thomas, through counsel, raised the issue of an “ongoing . . . report” by the Office of the Inspector General and requested the “status” of the report and when it would be completed.* (Conf. Tr., Nov. 25, 2019, at 3-4, 7-9). In response, the Government explained that “to the extent counsel’s asking for a summary of the results of the criminal investigation, obviously we’ll be turning over in discovery all of the underlying results of the criminal investigation. . . . I don’t have a time frame on the [I]nspector [G]eneral report, but the [G]overnment will produce to the defense all of the relevant discovery materials in this matter, which includes the Rule 16 materials relevant to the criminal charges that have been brought against the defendants.” (/d. at 7-8). As there was no pending issue to resolve, the Court declined to rule at that time. On January 29, 2020, Thomas and Noel each submitted discovery requests to the Government. Thomas’s letter reiterated his prior request for “any and all reports, memorandums, 3 The January 30, 2020 production was made to Noel’s counsel on January 24, 2020, while the Government was still waiting for an additional hard drive from Thomas’s counsel. * Based on conversations with attorneys at DOJ-OIG tasked with preparing this report, the Government understands that the report will likely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 DOJ-OGR- 00022071