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Case 1:20-cr-00330-PAE Document549 Filed 12/17/21 Page2of2 (11/01/21 Tr. at 16 (citing United States v. Saldarriaga, 204 F.3d 50 (2d Cir. 2000))), that the government “had an improper motive” (id. (citing United States v. Regan, 103 F.3d 1072 (2d Cir. 1997))), “affirmative evidence by the defense that goes to the thoroughness of the investigation” (id. at 17), “[t]he length of the investigation, the investigative techniques used, and the fact that the defendant was not initially a target of the investigation” (id. at 19 (quoting United States v. Duncan, No. 18 Cr. 289, 2019 WL 2210663 (S.D.N.Y. 2019)), and questions about “who [the case agents] talked to, what documents they subpoenaed, and when,” (id. at 20), among other lines of questioning. Without knowing details of the defense’s anticipated direct examination of the law enforcement witnesses, however, the Government does not seek relief at this time. 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- 00008394