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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 209 of 239 apparent ability to understand who the three victims are from the productions, there is no real concern that the defense will waste efforts conducting any such investigation before receiving Jencks Act material.® Moreover, with respect to the perjury counts, to the extent there could plausibly be any remaining ambiguity about the nature of the charges, the Government has addressed and resolved such ambiguity in responding to the instant motions. In this memorandum, the Government has summarized how the defendant’s false statements during her deposition were material to the pending civil litigation. See Section V, supra. Perhaps more importantly, the defendant personally participated in that civil litigation, and she is undoubtedly quite familiar with it. Together, the discovery productions, briefing in which the Government has described aspects of its evidence and theory (see, e.g., Government Memorandum in Opposition to Renewed Bail Motion, Dec. 18, 2020, Dkt. No. 100, at 8-12), the contents of this memorandum, and the details contained in the Indictment more than adequately inform the defendant of the charges against her. This is simply not a case where the “relevance of key events [are] shrouded in mystery.” See Bortnovsky, 820 F.2d at 574. Accordingly, the Court should deny the motion for a bill of particulars. B. The Defendant’s Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 1. Applicable Law Federal Rule of Criminal Procedure 16 “does not require the Government to furnish the names and addresses of its witnesses in general.” United States v. Bejasa, 904 F.2d 137, 139 (2d 63 Although the victims’ identities are clear from the discovery, and the defendant’s motion makes clear that she strongly suspects their identities, there is no basis to require the Government to turn over the names of its witnesses, including its victim-witnesses in advance of its Jencks Act production, which is customary in this District. See Section X.B., infra. 182 DOJ-OGR-00003143