DOJ-OGR-00019934.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page75 of 200 1 and federal law disclosure obligations. 2 Go ahead, Ms. Moe. 3 MS. MOE: Thank you, your Honor. 4 With respect to the items that the government anticipates will be included in discovery in this case, we 5 expect that those materials will include, among other items, search warrant returns, copies of search warrants, subpoena 6 returns, including business records, photographs, electronically stored information from searches conducted on 7 electronic devices. In addition, the materials with respect to the core of the case also include prior investigative files 8 from another investigation in the Southern District of Florida among other items. 9 With respect to the status of discovery, the government has begun preparing an initial production and are 10 prepared to produce a first batch of discovery as soon as a protective order is entered by the court. 11 With respect to the status of the proposed protective order, the government sent defense counsel a proposed 12 protective order last week. We have touched base about the status of that with defense counsel, and they conveyed that 13 they would like to continue reviewing and discussing it with the government, which we plan to do shortly after this 14 conference, with an eye towards submitting a proposed protective order to the court as soon as possible. Following SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019934