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Case 1:20-cr-00330-PAE Document 384 _ Filed 10/29/21 Page10of12 willfully violated the Order and has refused to produce statements that it obviously (1) is aware of and (2) could be easily identified by referring to a discovery page number or simply providing the statement. Ms. Maxwell had a very narrow window of time to review and consider any alleged co- conspirator statements which has expired. Counsel for Ms. Maxwell are concurrently preparing multiple motions in limine, reviewing thousands of pages of newly provided discovery material, addressing other pretrial deadlines, and preparing for trial. At this stage the failure of the government to address a very simple disclosure requirement has prejudiced Ms. Maxwell’s ability to prepare for trial and impacts her statutory and constitutional rights to a fair and speedy trial, due process, and effective assistance of counsel. The appropriate remedy is preclusion of the purported statements. Dated: October 18, 2021 DOJ-OGR-00005604