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Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 59 of 84 On September 3, 2021, the Court ordered the Government to “disclose to the Defendant the identities of all unnamed co-conspirators alleged in the S2 indictment to whom it will refer at trial.” (Order at 1, Dkt. No. 335). The Court further ordered the Government to “disclose all co- conspirator statements it intends to offer at trial no later than October 11, as consistent with this Court’s scheduling order.” (/d. at 2). Accordingly, on October 11, 2021, the Government produced its exhibit list and Jencks Act material to the defendant. The Jencks Act materials and exhibits contained the only co- conspirator statements in the Government’s possession that will be offered at trial. It also disclosed the identities of the individuals to whom it may refer at trial as co-conspirators and informed the defendant that it “has produced all co-conspirator statements which it intends to offer at trial ... in the Government’s production [that day] or in its previous productions.” (Def. Mot. 1 Ex. 1 at 1). The Government further noted that “[t]o the extent the Government learns of additional co- conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material.” (/d.). B. Discussion The Government has complied with its pre-trial disclosure obligations, consistent with the Court’s orders and on a schedule with deadlines well in advance of trial. As of October 11, the Government produced all co-conspirator statements in its possession that it intends to offer at trial. To the extent that the Government learns of additional co-conspirator statements as it prepares for trial—such as in a session preparing a witness for trial—it will produce those statements as part of its ongoing Jencks Act obligations. 58 DOJ-OGR-00006767