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Case 1:20-cr-00330-PAE Document 235 Filed 04/22/21 Page6of10 Page 6 particular to the time period covered by the S2 Indictment, especially with the guidance provided by the Government regarding key documents relevant to Minor Victim-4. Given that the largest portion of the discovery in this case is text searchable, the defense will also be able to tailor any re-review of those materials through relevant search terms. The combination of having already possessed the relevant discovery for months and receiving a list of key documents should meaningfully assist the defense in preparing for trial as scheduled. The Government has also committed to providing further disclosures well in advance of trial and far earlier than such productions would ordinarily be made in this District. The Government has already begun producing materials relating to witnesses whom it does not intend to call at trial to the defense, more than three months in advance of trial. The bulk of those materials were produced on April 13, 2021, and the Government intends to make additional productions on a rolling basis as it continues to review its files for such materials. In this vein, the Government has produced materials, including prior witness statements, for approximately 225 individuals relevant to the Government’s investigation into Jeffrey Epstein, the defendant, and others. While the Government made this production with an expansive eye toward its pretrial disclosures, as it has adopted throughout the pendency of this matter, it bears noting that a significant majority of those individuals never mentioned or knew the defendant. Indeed, the number of non-testifying witnesses who mentioned the defendant makes up a small portion of the overall production. That is unsurprising, given that the Government conducted a broad investigation into Jeffrey Epstein’s crimes, including crimes that did not involve this defendant. Accordingly, to the extent the defense claims it now needs to investigate or interview all, or even the majority of these witnesses, it is unclear how that testimony would be relevant or admissible DOJ-OGR- 00003948