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Case 1:20-cr-00330-PAE Document199_ Filed 04/09/21 Page4of8 Page 4 Second, the Government does not expect the S2 Indictment to have a significant effect on the overall length of the trial, because the Government remains committed to a streamlined presentation of evidence that primarily focuses on the experiences of the specific minor victims referenced in the indictment. While the Government expects to call a number of additional witnesses as a result of the new allegations contained in the S2 Indictment, including, of course, Minor Victim-4, the Government’s overall estimation of the trial length has not significantly changed. In particular, at the July 14, 2020 conference, the Government estimated that “its case in chief would take no more than two weeks,” but “propose[d] blocking three weeks for trial” in total. (July 14, 2020 Tr. at 20). Given the need to call additional witnesses, the Government now estimates that its case-in-chief will now take up to three weeks.” Accordingly, the Government would propose reserving four weeks for trial in this matter. The Government further proposes that if the length of the trial is of concern, the Court may wish to conduct jury selection during the week of July 6, 2021 and/or make use of a jury questionnaire, so that a jury can be seated and the trial can proceed immediately on July 12, 2021. Such practices have been adopted in this District for other high-profile cases where jury selection is expected to take longer than usual. See, e.g., United States v. Skelos, 15 Cr. 317 (KMW) (making use of jury questionnaire provided to venire approximately one week in advance of trial to streamline jury selection); United States v. Percoco, 16 Cr. 776 (VEC) (same). Third, the Government has taken and will continue to take multiple steps to ensure that the > These estimates assume the defendant will agree to standard stipulations obviating the need for custodians of records and similar witnesses. Should she not, the length of the trial may be somewhat longer, although that of course would have been true even absent the obtaining of a superseding indictment. In addition, while the Government has tried to account for anticipated cross-examinations in its estimates, the length and scope of cross-examination is obviously not within the Government’s control. DOJ-OGR-00002916