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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 212 of 239 to review the statements of testifying witnesses. The Government remains open to engaging in good faith discussions with the defense to mutually agree on a schedule for reciprocal pretrial disclosures.“ Accordingly, the motion for a witness list and early production of Jencks Act material should be denied. c. The Defendant’s Additional Requests for Disclosure Should Be Denied The defendant also makes a variety of motions seeking disclosures to which she is not entitled, all of which should be denied. PY which the defense attached to their motion as Exhibit B. (Def. Mot. 10 at 7-8). The defense assumes that because ee ee thereby, according to the defense, rendering any record of those interviews exculpatory. But that defense theory rests on a faulty premise. The Government confirmed that it incu/pates the defendant and contains nothing exculpatory. The Government has confirmed that it also inculpates the defendant. The Government has, however, identified a single line mM that could arguably be considered helpful to the defense. With the possible exception of that one line, there is nothing exculpatory contained 6 The Government has requested reciprocal discovery from the defendant and, to date, she has produced nothing. 65 Ty particular, 185 DOJ-OGR-00003146