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Case 1:20-cr-00330-PAE Document517_ Filed 11/30/21 Page4of4 Accordingly, the defense should be precluded from offering further exhibits that have not been turned over to the Government absent (a) a showing of cause for the delayed disclosure, or (b) an articulation of a theory by which they are admissible impeachment notwithstanding Rule 608 and the collateral-matter bar. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: ___s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by ECF) DOJ-OGR-00008193