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Case 1:20-cr-00330-PAE Document199_ Filed 04/09/21 Page6éof8 Page 6 committed to taking to aid the defense in preparing for trial, the Government anticipates objecting to any request to adjourn trial, should one be made. The Government contacted defense counsel on March 29, 2021 to convey its availability for a call to discuss some of the issues above as well as a supplemental briefing schedule for certain of the defendant’s pending motions, among other issues. Although such a call has not yet taken place, the Government remains available to confer with the defense regarding these issues, as well as a schedule for trial-related filings such as motions in limine and requests to charge. Indeed, the Government and defense counsel have conferred extensively by email over the last several days regarding defense requests to review certain physical evidence and other defense inquiries regarding discovery in this case. As a result of this conferral, the Government has scheduled an evidence review session for the defendant and defense counsel to review physical evidence in the custody of the FBI relating to this case in the coming days. The Government will continue to be available to confer with defense counsel and is prepared to discuss scheduling matters whenever the defense would like. Finally, nothing about the S2 Indictment supports reconsideration of this Court’s three prior decisions ordering the defendant detained pending trial. If anything, the arguments in favor of detention are now stronger. The defendant now faces two additional charges, which increase the maximum penalty she faces to eighty years in prison. She also faces even more evidence, including a fourth victim, who 1s corroborated by independent evidence, including other witnesses and documents such as travel records, phone records, shipment records, and items recovered during the execution of a search warrant. Moreover, as the defense seems to implicitly recognize, the S2 Indictment undermines certain legal arguments the defense previously made in attacking the prior indictment in this case. (See Dkt. No. 192 at 2 (“The timing suggests that the decision to supersede was prompted by the filing of defense pretrial motions and government concern about DOJ-OGR-00002918