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Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 19 of 23 location of witnesses, the ongoing global pandemic — justify the accelerated disclosure of Jencks Act material. The Court has already recognized that the defense will need substantial time to evaluate and investigate materials related to potential witnesses in this case. In response to the government request to delay production of certain Rule 16 materials related to non-testifying witnesses until eight weeks prior to trial, the Court ruled that such a time frame was “insufficient” and ordered the government to produce the materials by March 12, 2021 “to ensure that the defense can adequately prepare for trial.” (Dkt. 73). The defense has conferred with the government and proposed the same date—March 12, 2021—+to produce all Jencks Act material for both testifying and non-testifying witnesses. The government has denied that request. Accordingly, we ask the Court to order the government to disclose all Jencks Act material by that date, including, but not limited to the following: 1. Any and all rough notes of witness interviews taken or obtained in any investigation of Ms. Maxwell, including federal, state, local and other investigations whether or not the contents thereof have been incorporated in official reports; 2. Any notes or memoranda made by government counsel, staff, or law enforcement agents during the interview of any witness intended to be called by the government in its direct case; 3. Any emails, texts or voicemails (in original, transcribed and summary form) from the witness and from the witness’s counsel/law firm containing information derived from any witness intended to be called by the government in its direct case; and 4. Any emails, texts or voicemails (in original, transcribed and summary form) between and among government counsel and law enforcement officers containing information derived from any witness intended to be called by the government in its direct case. VI. Motion for a List of Government Witnesses In conjunction with Ms. Maxwell’s request for early disclosure of Jencks Act material, the defense also requests that the government provide a list of the witnesses it intends to call at trial. Although Rule 16 does not require the government to disclose its witness prior to trial, the 15 DOJ-OGR-00002712