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Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page9of13 Page 9 of the fact that some accusers have spoken publicly about this case. The government’s principal justification for withholding their identities until September 13 is that earlier disclosure would be inconsistent with the “practice” of the office. This is not a sufficient reason to withhold this information where any investigation of these accusers has to take place under the onerous conditions of COVID. Defendant's Proposal for Disclosure of Jencks Act/3500 and Giglio Material, Rule 404(b) Evidence and Notice, and Government Witness and Exhibit Lists The defense believes that shifting the deadlines up two weeks for motions in limine to be fully briefed four weeks prior to trial (Dkt. 277) necessitates a concomitant two week advancement of the dates for the government to produce Jencks Act/3500 and Giglio material, Rule 404(b) evidence and notice, and the government's witness and exhibit lists. The government’s proposal allows only one week for the defense to review thousands of pages of 3500 material before filing motions in /imine, and the government proposes disclosing its exhibit and witness lists one week after the in limine deadline. As discussed at the April 23d arraignment, the defense needs sufficient time in advance of the in limine deadline to review the materials and draft the appropriate motions.* The government's proposed process will frustrate the Court's aim of having in /imine issues briefed four weeks in advance of trial to the extent possible. The cases cited by the government in which disclosures were made closer to trial are wholly inapposite. In each of the cited cases, charges were filed nearly contemporaneously with the alleged crimes. Cole (indictment of 2 year conspiracy charged 4 years later); Dupigny “Tt bears repeating that two of Ms. Maxwell's counsel will be in other trials from September 13 through October 22, i.e., the entire time between disclosure of the Jencks Act material and the in limine filing deadlines, further hampering efforts to efficiently review and develop any legal briefing on issues presented by the materials. DOJ-OGR-00004259