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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 216 of 239 aware, consistent with the Rule 5(f) Brady order previously issued by the Court in this case. See Fed. R. Crim. P. 5(f); Dkt. No. 68. The Government recognizes its continuing obligation to disclose any Brady material, and to make a diligent search for any relevant material that may be in the possession of the prosecution team, including investigating agents and officers. As the Government has already emphasized in this case, the Government takes its disclosure obligations very seriously and has committed to being transparent with the Court and the defense regarding its approach to obtaining and reviewing files, including other agency files, that may be relevant to this case. (See, e.g., Gov’t Letter dated October 7, 2020, Dkt. No. 63). Consistent with that commitment, the Government has completed an initial review of its files for Brady material and Rule 16 material and has produced more than 2.7 million pages of discovery as a result of that review. These productions have included specific disclosures of certain witness statements that may arguably be exculpatory. The Government also intends to produce all statements and potential impeachment material in its possession regarding any potential witness identified during its investigation, including those individuals whom the Government does not intend to call at trial. As discussed below, the Government is in the process of reviewing all files in its possession for potential impeachment material. The Government remains cognizant of its Brady obligations and will promptly produce any potentially exculpatory material if any is identified during that review. The Government is not currently aware of any undisclosed Brady material in its possession, but it will certainly provide timely disclosure of any additional Brady material if any such material comes to light. Courts in this Circuit routinely deny specific requests for Brady material where, as here, the Government has made a good-faith representation to the court and defense counsel that it recognizes and has complied with its disclosure obligations under Brady. See, e.g., Thompson, 2013 WL 6246489 at *9 (“In light of the Government's ‘good-faith representation to 189 DOJ-OGR-00003150