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Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page11of13 The Hon. Alison J. Nathan April 22, 2021 Page 11 to evaluate the photographs for admissibility purposes, or even to decide which photographs she will want to introduce in her own defense, she will otherwise need to make an appointment to view these materials at a government office. Further, after the government discloses its testifying witness list, counsel will have to comb through the thousands of photos once again to determine which photographs she needs to use for impeachment purposes or for affirmative defense evidence. And, again, the images contain metadata that defense counsel must forensically analyze. Because defense counsel do not even have all of the images, this investigation cannot be accomplished in advance of the July 12, 2021 trial. F. The new charges and discovery require the assistance of defense experts In addition to locating, investigating, and perhaps interviewing a significant number of potential witnesses, counsel also anticipate that the defense may require the specialized knowledge of expert witnesses to analyze evidence that is now potentially relevant due to the expanded time frame of the allegations. Ms. Maxwell anticipates that the “highly confidential hard drives” will need to be forensically examined by a computer specialist to determine actual file creation dates, any alterations, and the original location of the data. Although the government has not identified any trial exhibits, it seems probable that the services of various forensic examiners may be necessary to analyze the exhibits. Ms. Maxwell will also need to receive and review the 20,000 pages of “new” material to provide that information to potential defense experts for consideration. None of this can happen in time to make appropriate disclosures in advance of trial. See United States v. Santos, No. S 91 CR. 724 (CSH), 1991 WL 248784 at *2 (S.D.N.Y. Nov. 25, 1991) (granting a continuance for 11 DOJ-OGR- 00003998