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Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page11of16 the vast majority of the discovery was produced as a “dump” of data from Epstein’s various electronic devices, which includes hundreds of thousands of photographs, videos, and other files that are not text searchable. See Rueb, 2001 WL 96177, at *8 (disclosure ordered where defendant needed to review voluminous documentary evidence to prepare cross-examination). Fourth, investigation of witness statements will face challenges and delays in light of the continuing travel restrictions imposed by the COVID-19 pandemic and the reluctance of witnesses to meet in person. By contrast, the “possible dangers accompanying disclosure (i.e. subornation of perjury, witness intimidation, and injury to witnesses)” are non-existent in this case. Cannone, 528 F.2d at 302. Indeed, the government does not even attempt to argue that Ms. Maxwell, who is currently incarcerated, will attempt to threaten or intimidate witnesses if she is given their names. Accordingly, early disclosure of the identities of the government’s witnesses is warranted. For these same reasons, the Court should order the government to provide early disclosure of any and all evidence of “other acts” that it intends to introduce under Rule 404(b). The allegations in the Indictment already include conduct that purportedly took place in locations all over the United States and in England. Moreover, the government just disclosed in its opposition that it intends to have Accuser-3 testify about PO Ls that are not alleged in the Indictment and that PO | | (Opp. 159). The government may seek to introduce evidence of “other acts” that took place in new locations and possibly other foreign countries. Ms. Maxwell will not have sufficient time to investigate these allegations if she is not given adequate notice and therefore must be given accelerated disclosure of all Rule 404(b) evidence. DOJ-OGR- 00004238