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Case 1:20-cr-00330-PAE Document275 Filed 05/10/21 Page3of5 Page 3 justice for trial to commence on November 29, 2021. See also 18 U.S.C. § 3161(h)(7)(B)(iv) (listing continuity of Government counsel as one factor to consider when evaluating a request for a continuance); see also United States v. Jones, 18-42-cr, 2021 WL 727837, at *2 (2d Cir. Feb. 25, 2021) (finding that the district court “considered the unavailability of the prosecutor when granting the continuance, as it was entitled to do under the Speedy Trial Act” and “reasonably conclud[ed] that a small delay was justified” in “balanc[ing] the need for a speedy trial with the efficiencies of continuity of counsel”). Given the complexities in this case, including a large volume of discovery, complex litigation history, years of investigation, and significant time invested with victim- witnesses, continuity of Government counsel at trial is a particularly compelling interest here. The Government respectfully submits that a trial before November 29, 2021 would be prejudicial to the Government and the interests of justice. The Government respectfully submits that the Government’s proposed trial date—which is only three weeks after the date requested by the defense—is reasonable in light of the interests described above and where defense counsel originally requested a continuance of trial to November 8, 2021 contingent upon the re-scheduling of a conflicting trial and alternatively requested a trial date of January 10, 2022.4 (Dkt. No. 246). Additionally, the Government respectfully proposes the following adjustment to the pre- trial schedule in place. The parties previously agreed, and the Court ordered, that the Government > The Government understands that the Court will request a trial commencement date from the Southern District of New York’s Assignment Committee. If the Committee were to assign a trial date prior to November 29, 2021, the Government respectfully proposes that jury selection through jury questionnaires be commenced on that date, but opening statements and the presentation of evidence not begin until November 29, 2021. * The Government notes that the difference between the two proposed dates is further minimized because the week of November 22, 2021 includes the Thanksgiving holiday and thus is a shortened week. DOJ-OGR-00004114