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Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page10of13 Page 10 (2 year conspiracy charged the following year); Jones (1 year conspiracy charged the same year); Lebedev (2 year conspiracy charged in the second year); Corley (2 year conspiracy charged in January of the following year). None involved, as this one does, allegations of a 10-year conspiracy charged 25 years later. None involved accusers who were located in at least one foreign country, possibly more, for whom investigation will have to occur during the midst of pandemic. The cases do not involve the same "length" or complexity of this one. Co-Conspirator Identities and Statements Regarding co-conspirator identities and statements, the government backtracked on its previous representations to counsel and the Court. Ms. Maxwell sought early disclosure of both in her pretrial motions (Dkt. 148 at 13-14), and the government promised it would give "notice of any co-conspirator statements that the Government may seek to introduce through witness statements" sufficiently in advance of trial to permit objections by the defense. (Dkt. 204 at 192) The Court agreed. (Dkt. 207 at 30-31). During recent conferrals on the schedule, however, the government made clear its intent to imbed any co-conspirator statements in the bulk of its Jencks/3500 material rather than separately disclose either the identity of any purported unindicted co-conspirator or their anticipated testimony. The government also stated for the first time its intent to identify any unindicted co-conspirator documentary statements (e.g., emails between Epstein and any number of thousands of persons) only when it produces its exhibit list, one week after the in limine filing deadline. Neither government proposal will allow Ms. Maxwell to raise appropriate objections to the materials sufficiently in advance of trial, nor promote briefing during the in /imine motions. Indeed, the government fails to explain how Ms. Maxwell can object in limine to exhibits containing purported co- DOJ-OGR-00004260