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Case 1:20-cr-00330-PAE Document 229 _ Filed 04/21/21 Page2of5 Page 2 e The parties shall simultaneously file any motions in limine by June 14, 2021. The parties shall simultaneously file any responses to motions in limine by June 28, 2021. e The parties shall simultaneously file proposed jury questionnaires by June 18, 2021. Should the Court’s schedule permit, the parties would propose that the venire receive and complete the questionnaire during the week of June 28, 2021. e The parties shall simultaneously file requests to charge, proposed voir dire, and proposed verdict sheets by June 25, 2021. e The parties are available for a final pretrial conference on July 1, 2021. e The parties are available to appear for a conference on July 9, 2021 at which the parties would propose to present any for-cause challenges to prospective jurors based on the written questionnaires. The parties have been unable to reach agreement regarding the remaining pretrial dates. For the reasons set forth below, the Government respectfully requests that the Court set the remaining schedule consistent with the Government’s proposals. The Government notes that these proposed dates assume that trial will proceed as scheduled on July 12, 2021. Should trial be adjourned, the Government would propose that these dates be correspondingly adjourned. In particular, the Government makes the following proposals: e The Government is prepared to produce a proposed witness list, Giglio material, and Jencks Act material by May 28, 2021, or 45 days in advance of trial. These materials will include testifying witness statements, which themselves will also include any co-conspirator statements about which witnesses may testify at trial. This deadline, which is far in advance of when such disclosures are ordinarily made DOJ-OGR-00003923