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Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 10 of 16 showing of need, and that comparable and customary disclosure deadlines for these materials are appropriate. (Opp. 184-85, 188-93). But Ms. Maxwell’s case is different—emphatically so— and the deadlines the government proposes are not sufficient to allow Ms. Maxwell, who is incarcerated, to adequately prepare her defense. Ms. Maxwell has made a specific showing that early disclosure of the identities of the government’s witnesses is “both material to the preparation of [her] defense and reasonable in light of the circumstances surrounding [her] case.” Cannone, 528 F.2d at 300-01. First, the allegations are over 25 years old and any documentary records that witnesses may direct us to, if they still exist, will be hard to retrieve and take time to collect. Second, the conduct relevant to the charged crimes allegedly took place in three different locations across the country (New York, Florida, and New Mexico) and in at least one foreign jurisdiction (London, England) over a four-year period. Hence, it will take time to investigate any witness statements pertaining to the alleged conduct, as well as to identify and interview other witnesses who may contradict the government’s witnesses. See United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *8-*9 (S.D.N.Y. Feb. 5, 2001) (disclosure ordered where evidence located in multiple locations and offenses spanned three-year “extended period of time”). In particular, international travel may be necessary to investigate statements by witnesses located in England or other foreign jurisdictions, as will depositions pursuant to Rule 15 of the Federal Rules of Criminal Procedure. See United States v. Savin, No. 00-CR-45 (RWS), 2001 WL 243533, *7-*9 (S.D.N.Y. Mar. 7, 2001) (disclosure ordered where offenses spanned “extended” six-year period and involved potential depositions of foreign witnesses). Third, for each witness identified, the defense will need to search through the over 2.7 million pages of discovery to identify any relevant documents for cross-examination. The task is extraordinarily difficult and time-consuming, as DOJ-OGR-00004237