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Case 1:20-cr-00330-PAE Document 235 Filed 04/22/21 Page8of10 Page 8 that its investigation of the witnesses referenced in these materials will take months, it fails to explain in any detail what specific steps it needs to take, why those steps are material to preparing a defense, or how those steps would be particularly expected to lead to admissible evidence at trial. Additionally, the Government has agreed to provide the defense with expert notice by April 23, 2021 and the names of the victims referenced in the S2 Indictment by May 17, 2021. The Government has also agreed to provide notice pursuant to Federal Rule of Evidence 404(b), a proposed witness list, Jencks Act material, and Giglio material 45 days in advance of trial. As a result, the defense will receive many of these disclosures weeks in advance of when is typical for criminal defendants in this District, thereby further ensuring ample time to prepare for trial. To the extent the defense claims that it will need to retain additional experts to review electronic evidence, it appears that would be true regardless of the S2 Indictment because the electronic discovery materials referenced in the defense’s most recent letter were already part of the discovery in this case before the S2 Indictment was returned. In any event, the defense will receive the Government’s expert disclosure tomorrow, thereby providing more than two months for the defense to consider whether it wishes to offer any responsive expert(s). Further, the defense’s suggestion that it has insufficient time to file additional motions is undercut by the proposed schedule agreed upon by the parties, which allows the defense to file its supplemental pretrial motions more than five weeks after the return of the S2 Indictment and its motions in /imine more than eight weeks from today and eleven weeks from the return of the S2 Indictment. Although the defense claims that its trial preparation will be hampered by the COVID-19 pandemic, the availability of vaccines to all adults in the United States should enable the defense team to conduct any necessary investigation far more expeditiously than was possible a few months ago. Further, the defense’s concerns that jury selection will be lengthy or cumbersome in DOJ-OGR-00003950