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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 210 of 239 Cir. 1990). Thus, “‘[iJn the absence of a specific showing that disclosure [of a witness list] [is] both material to the preparation of [the] defense and reasonable in light of the circumstances surrounding [the] case,’ the request for a witness list should be denied.” United States v. Russo, 483 F. Supp. 2d 301, 309 (S.D.N.Y. 2007) (quoting Bejasa, 904 F.2d at 139-40). “Courts in the Second Circuit typically deny motions for the early disclosure of witness lists where, as here, Defendants have not made a specific showing of need.” United States v. Rivera, No. 16 Cr. 175 (LGS), 2017 WL 1843302, at *2 (S.D.N.Y. May 8, 2017). The claim that “given the complexity of the case, disclosure of the government witness list will level the playing field” amounts to an “abstract statement of need” that does not justify provision of a witness list. Russo, 483 F. Supp. 2d at 309. The Jencks Act, 18 U.S.C. § 3500, covers disclosure of statements or reports made by Government witnesses, and the rule mandates that such materials not be the subject of discovery or inspection “until said witness has testified on direct examination in the trial of the case.” 18 U.S.C. § 3500(a); see also United States v. Coppa, 267 F.3d 132, 145 (2d Cir. 2001) (“[T]he Jencks Act prohibits a District Court from ordering the pretrial disclosure of witness statements.”); United States v. Thompson, No. 13 Cr. 378 (AJN), 2013 WL 6246489, at *9 (S.D.N.Y. Dec. 3, 2013) (denying request for early production of Jencks Act material in light of Coppa). Typically in this District, and as is the case here, the Government confirms that it will produce 3500 material and Giglio (or impeachment) material reasonably in advance of trial, and will engage in good faith discussions with the defense regarding a schedule for pretrial disclosures. See United States v. Sergentakis, No. 05 Cr. 230 (JFK), 2005 WL 1994014, at *1-2 (S.D.N.Y. Aug. 17, 2005) (“18 U.S.C. § 3500(b) calls for production of Government witness statements after the witness ‘has testified on direct examination.’ The Government response . . . that ‘[c]onsistent 183 DOJ-OGR-00003144