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Case 1:20-cr-00330-PAE Document199_ Filed 04/09/21 Page5of8 Page 5 defense will be fully prepared to proceed to trial on July 12, 2021. As noted in its March 29, 2021 letter to the Court, the Government has already produced to the defense all material of which it is aware that constitutes Rule 16 discovery related to the new allegations in the S2 Indictment. This includes material that was already in the files of the FBI, which the Government produced during its Fall 2020 productions, and new material obtained during the Government’s investigation, which the Government has produced on a rolling basis as it has received such material. Additionally, the Government provided the defendant with a list of Bates ranges within the past discovery productions that relate specifically to Minor Victim-4, which should substantially assist the defense in re-reviewing relevant materials and preparing for trial. In other words, this is not a superseding indictment that requires a huge production of new discovery that the defense will need time to review. To the contrary, the defense already had in its possession Rule 16 discovery relevant to the S2 Indictment for months. The Government plans to begin producing non-testifying witness statements on April 12, 2021. With these productions, the defense will have access to statements of witnesses whom the Government does not intend to call at trial, thereby providing the defense multiple months during which it can decide whether it wishes to call any of these individuals. Further, the Government plans to produce Jencks Act and Giglio material for testifying witnesses six weeks in advance of trial, which will provide the defense with far more time than is typical in this District for review of such material. Given that the defense has had discovery in this case for months, will have months with non-testifying witness statements, and will have more than one month with Jencks Act and Giglio material, there is every reason to believe that the defense will provide excellent representation to the defendant at trial as scheduled beginning July 12, 2021. In light of the ample time that remains before trial and the steps the Government has DOJ-OGR-00002917