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Case 1:20-cr-00330-PAE Document275 Filed 05/10/21 Page4of5 Page 4 would provide the defense with the identities of the victims eight weeks before trial, on May 17, 2021, assuming trial were to begin as scheduled on July 12, 2021. (Dkt. No. 229, 250). If the Court were to schedule trial to begin on November 29, 2021, in order to address the three-week adjournment that the Government is seeking, the Government would intend to provide the defense with the identities of the victims referenced in the S2 Indictment eleven weeks before trial. The Government understands that the defense objects to the Government’s proposal and requests that the information be provided on May 17, 2021, which would be approximately six months in advance of trial. Finally, the Government respectfully requests that the Court exclude time under the Speedy Trial Act through the date on which trial will proceed on Counts One through Six of Indictment S2 20 Cr. 330 (AJN). The exclusion of time is warranted for multiple reasons, including: to permit the defense to continue to review discovery and other materials in light of the superseding indictment, including materials related to non-testifying witnesses and the Government’s expert witness; to permit the parties to prepare and file motions in limine; to permit the parties to make and review additional pretrial disclosures, including proposed exhibits, proposed witness lists, and witness statements; and to allow adequate time for the parties to prepare for trial. Accordingly, the Government respectfully submits that the exclusion of time is in the interests of justice pursuant to 18 U.S.C. § 3161(h)(7). The Government has consulted with defense counsel, who consents to the exclusion of time, but only through November 8, 2021. In view of the defendant’s previous proposal ofa January 2022 trial date, however, the Government respectfully submits that exclusion of time through November 29, 2021 is warranted here and consistent with the factors set forth in the Speedy Trial Act. For the reasons noted above, the Government respectfully submits that the DOJ-OGR-O00004115