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Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page2of13 Page 2 e The parties shall simultaneously file proposed jury questionnaires and proposed voir dire 3 weeks in advance of jury selection, or by October 25, 2021. e The parties shall simultaneously file requests to charge and proposed verdict sheets by November 8, 2021, or 3 weeks in advance of trial. The parties have been unable to reach agreement regarding the remaining pretrial dates. Government's Position For the reasons set forth below, the Government respectfully requests that the Court set the remaining schedule consistent with the Government’s proposals. In particular, the Government makes the following proposals: Identities of the Victims The Government will provide the defense with the identities of the victims referenced in the S2 Indictment by September 13, 2021, or 11 weeks in advance of trial. The Government understands that the defense requests that the Government disclose the identities of the victims immediately. The Government notes that the parties previously agreed, and the Court ordered, that the Government would provide the defense with the identities of the victims 8 weeks before trial, on May 17, 2021, assuming trial were to begin as scheduled on July 12, 2021. (Dkt. No. 229, 250). The Government’s proposal would provide the defense with the victims’ identities substantially in advance of trial. See, e.g., United States v. Kee, No. 98 Cr. 778 (DLC), 2000 WL 760096, at *1-*2 n.2 (S.D.N.Y. June 12, 2000) (requiring Government to disclose identities of victims approximately 45 days in advance of trial). The Government’s Proposed Witness List, Giglio Material, Jencks Act Material, and Rule 404(b) Notice The Government is prepared—consistent with the Court’s April 26, 2021 Order (Dkt. No. 250) to produce a proposed witness list, Giglio material, Jencks Act material, and notice pursuant DOJ-OGR-00004252