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Case 1:20-cr-00330-PAE Document 229 _ Filed 04/21/21 Page3of5 Page 3 in this District, will provide the defense with ample time to review these materials, prepare for trial, and consider and brief any in limine motions. This deadline will also allow the Government adequate time in the coming weeks to finalize its witness list for trial, review its files for all Giglio and Jencks Act materials, and prepare those materials for production. e The Government is prepared to provide the defense with notice pursuant to Federal Rule of Evidence 404(b) by May 28, 2021, or 45 days in advance of trial. Consistent with the motion in limine schedule set forth above, this proposed deadline will provide the defense with adequate time to review the disclosure and file any appropriate motions. This deadline will also allow the Government adequate time to finalize its determination of what evidence it will seek to introduce at trial pursuant to Federal Rule of Evidence 404(b). e The Government is prepared to provide the defense with its proposed exhibit list and marked exhibits by June 11, 2021, or one month in advance of trial. This deadline will allow the defense adequate time to review and raise objections to any Government exhibits. This deadline will also allow the Government adequate time to finalize its determination of what exhibits it will seek to introduce at trial. e The Government would propose that the defense be required to provide expert witness disclosures pursuant to Federal Rule of Criminal Procedure 16(b)(1)(C) by May 14, 2021. This deadline, which is three weeks after the Government has agreed to provide expert notice, will give the defendant ample time to determine what, if any, expert testimony she may seek to offer. This deadline will also allow the Government sufficient time to brief the admissibility of any such proposed DOJ-OGR-00003924