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Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page6of13 The Hon. Alison J. Nathan April 22, 2021 Page 6 are minimal. See United States v. Rojas-Contreras, 474 U.S. 231, 234 (1985) (no prejudice to superseding indictment which changed the date of offense by ten days); United States v. Stringer, 730 F.3d 120, 128 (2d Cir. 2013) (not an abuse of discretion to deny continuance for a superseding indictment that extended the conspiracy range by one month). In this case, the changes to the indictment were anything but minimal. The conspiracy was expanded from four years (without any specific actual dates within that range) to eleven years (again, without any specificity), an additional seven years, and two new counts were added. These were significant and substantial changes that require a continuance. The need to research Ms. Maxwell’s whereabouts during a full eleven year period, not to mention comb the millions of pages of discovery including travel records, phone records, bank records, photographs, diaries, message pads, credit card records, and countless other records for the eleven-year versus four year period, will take hundreds, if not thousands, of attorney and staff hours. C. The new, and old, discovery require review (and re-review) and analysis. The government, on April 13, 2021, produced more than 20,000 pages of “new” discovery. Although the government represented that this production is related to “non-testifying witnesses,” it is more accurately described as exculpatory Brady material. Notably, the government has possessed most of this information for years (in some cases, more than a decade) and has resisted disclosure until after the filing of the second superseding indictment and on the eve of trial.2, Many of the reports recently produced stem from the years 2006-2008. ? Consistent with the updated Fed. R. Crim. P. 5(f) and the Due Process Protections Act, Pub. L. No 116-182, 134 Stat. 894 (Oct. 21, 2020), this Court on November 5, 2020, ordered that “The Government shall disclose [Brady] information to the defense promptly after its existence becomes known to the Government so that the defense may make effective use of the information in the preparation of its case. See Dkt. 68 (emphasis supplied). The Government has not explained why key witnesses statements, made to the government in 2019 and 2020, that Ms. DOJ-OGR-00003993