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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 211 of 239 with the regular practice in this District, the Government intends to make Section 3500 material available to the defense at the same time as impeachment material, [and that] in order to avoid any delay in the trial, the Government will produce such material sufficiently in advance of each Government witness’s testimony’ . . . is more than adequate.”’); United States v. Gallo, No. 98 Cr. 338 (JGK), 1999 WL 9848, at *8 (S.D.N.Y. Jan. 11, 1999) (“[T]he Government has indicated that itis aware of its obligations under Giglio .. . and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness’s testimony to allow adequate time to prepare for cross- examination. These representations are sufficient.”’). 2s Discussion Trial is still more than four months away. The degree of complexity to this case, and the volume of discovery, is on par with other recent high-profile trials in this District, and in those cases witnesses have typically been disclosed approximately three to four weeks before trial. E.g., Gatto, 17 Cr. 686 (LAK); Blaszezak, 17 Cr. 357 (LAK); Skelos, 15 Cr. 317 (KMW),; Silver, 15 Cr. 93 (VEC); Ulbricht, 14 Cr. 68 (KBF). As the Government has noted for some time now, the Government intends to match or even go above and beyond that practice in this case. Specifically, the Government has offered repeatedly to provide non-testifying witness statements to the defense as much as eight weeks before trial, thereby allowing extra time for the defense to determine whether it wishes to call any of the witnesses the Government does not intend to present at trial, and to provide testifying witness statements and Giglio material as much as four weeks in advance of trial. Given that the defense has already been able to initiate its investigation of the charges, and given that the discovery makes clear who the three minor victims are, eight weeks should be ample time to review non-testifying witness statements, and four weeks is more than enough time 184 DOJ-OGR-00003145