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Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page 47 of 54 United States v. Castro, 813 F.2d 571, 575-76 (2d Cir. 1987)). But this doctrine “has never required the admission of portions of a statement that are neither explanatory of nor relevant to the admitted passages.” United States v. Williams, 930 F.3d 44, 58 (2d Cir. 2019) (internal quotation marks and alterations omitted); see id. at 61 (“[T]he rule of completeness does not require the admission of self-serving exculpatory statements in all circumstances.” (emphasis in original)). This rule is strictly applied, leading the Second Circuit to hold, for example, that a defendant could not introduce a portion of his confession relating “to the execution of [a] robbery,” where the portion introduced by the Government concerned only “plans to execute the robbery.” Johnson, 507 F.3d at 796 (emphasis in original). The Government expects to offer certain of the defendant’s written statements contained in her emails and oral statements through witness testimony. To the extent the defendant wishes to offer her own out-of-court statements, they are hearsay, whether in emails, deposition transcripts, or elsewhere. And unless they accomplish the narrow function of the rule of completeness, the Court should preclude them. Given the limited admissibility of such statements, and to avoid mid-trial delays, the Government requests that (a) to the extent the defense seeks to admit such evidence during the Government’s case-in-chief during cross- examination of witnesses, the defense preview with the Government and the Court prior to each trial day any statement of the defendant it intends to admit, so that any evidentiary issues can be addressed outside of the trial day; and (b) that the defendant be required to mark any such statements that she intends to offer during her case-in-chief at the time of her Rule 26.2 disclosures. 46 DOJ-OGR-00005440