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Case 1:20-cr-00330-PAE Document 358 _ Filed 10/18/21 Page3of4 The Honorable Alison J. Nathan October 18, 2021 Page 3 whether additional motions are required based on voluminous disclosures made less than one week ago.! By court order, the government produced Jencks Act and Giglio material and a list of government exhibits on the evening of October 11. New York counsel picked up the hard drives from the U.S. Attorney’s Office that evening. Colorado counsel received their hard drives via Federal Express on October 12 at approximately 6:30 p.m. The hard drives contained thousands of pages of disclosures: approximately 8,000 single-space typed and hand-written pages of testifying witness materials; approximately 6,000 pages on “non-testifying” witness materials, the bulk of which is exculpatory; and Excel spreadsheets identifying hundreds of government exhibits. Ms. Maxwell received her hard drive late morning on October 14 without inclusion of various .pdf disclosures, most significantly the government’s exhibit list, which counsel copied, hand-delivered, and deposited in the MDC legal mailbox on October 17. Counsel have been unable to thoroughly review and analyze this voluminous production in sufficient time to assess whether additional motions in /imine are required. Nor has Ms. ! This issue was discussed during the arraignment on April 23, 2021: MR. PAGLIUCA: [W]e don’t think it’s tenable to stick to the motion in limine schedule based on the government’s proposed disclosures. Dkt. 261 at 6. MS. COMEY: And as is typical with trials in this district, it is possible there may be supplemental motions in limine after the date that the parties have proposed for motions in limine in this case. Id. THE COURT: And to the extent that there is some additional supplementation after that date, we can consider that. Td. at 8. DOJ-OGR- 00005262