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Case 1:20-cr-00330-PAE Document 229 _ Filed 04/21/21 Page4of5 Page 4 testimony in advance of the motion in limine deadline. The Government understands that the defense seeks to provide expert notice by June 14, 2021, but such a belated disclosure would not allow adequate time in advance of trial to brief any motions regarding the admissibility of such testimony. Additionally, the defense’s proposed disclosure date would not provide sufficient time for the Government to locate a rebuttal expert if appropriate and provide notice of that rebuttal expert to the defense. e The Government would propose that the defense provide a proposed witness list and witness statements, pursuant to Federal Rule of Criminal Procedure 26.2, by June 11,2021. This deadline will provide the defense with ample time to determine what, if any, defense witnesses may testify at trial. This deadline will also permit the Government adequate time to review these materials and raise any appropriate objections or motions in advance of trial. e The Government would propose that the defense be required to provide disclosures pursuant to Federal Rule of Criminal Procedure 16(b)(1)(A) and 16(b)(1)(B) by June 11, 2021, which is the same date by which the Government seeks to produce its proposed exhibit list and marked exhibits. Such reciprocal disclosure will ensure that the Government has adequate time to review the defense’s proposed trial exhibits and to raise any appropriate objections in advance of trial. In addition, the Government notes that it has already begun producing non-testifying witness statements, the bulk of which were produced on April 13, 2021. The Government will continue to produce any additional non-testifying witness statements on a rolling basis as it continues to review its files for such materials. DOJ-OGR-00003925