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Caash: 220 OCKBP AEN DunumentS Aiitel1001E201 Pateyé dfof 4 Page 4 of them, there may be a need for multiple such hearings. The Court must then adjudicate the motion before trial starts or during trial. There is no reason to impose the defense’s cramped schedule on the Court or the parties, particularly where the motion concerns such sensitive issues. For these reasons, the Government respectfully submits that the Court should maintain the October 18, 2021 in limine deadline as the deadline for the defense to file a motion under Rule 412, or order that any Rule 412 motion be made, at the latest, by October 25, 2021. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: ___s/ Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) DOJ-OGR-00005249