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Case 1:20-cr-00330-PAE Document 235 Filed 04/22/21 Page9of10 Page 9 this case would have been present whether or not the Government sought a superseding indictment, yet the defense never previously raised this issue as necessitating an adjournment. But more importantly, there is no reason to think that the S2 Indictment will increase the length of time required for jury selection in this case, and as noted above, the parties have agreed to the use of a jury questionnaire to expedite the selection process. Similarly, the defense’s complaint that it is difficult to estimate the length of a defense case before disclosure of Jencks Act material and Government exhibits would be true regardless of new charges. The defendant has five retained lawyers appearing on her behalf on the docket in this case, all of whom are experienced and skilled trial attorneys. Throughout the pendency of this case, the defense team has demonstrated its ability to litigate multiple complex issues on overlapping schedules while also carefully reviewing discovery and preparing for trial. In addition, the defendant has the benefit of even more attorneys who have appeared on her behalf to brief and argue appeals in this case before the Second Circuit, as well as staff such as paralegals and investigators assisting her attorneys. Given their skills and the resources at their disposal, there is every reason to believe that defense counsel will provide the defendant with exceptional representation at trial as scheduled. Third, the victims in this case would suffer additional harm were trial to be delayed. The longer this case remains pending, the longer the victims suffer the anxiety of anticipating their trial testimony and the uncertainty of awaiting a resolution. As a result, multiple victims oppose any adjournment of the trial date. In particular, Minor Victim-3 expressed feeling significant stress during the pendency of this case and a strong desire to have the case brought to a close through trial as soon as possible. Similarly, Minor Victim-2 also indicated that she has experienced an enormous amount of stress while this case has been pending, wishes to see the case brought to trial DOJ-OGR-00003951