DOJ-OGR-00004258.pdf

--- Page 1 --- The extracted text is: **Case 1:20-cr-00330-PAE** **Document 291** **Filed 05/21/21** **Page 8 of 13** Page 8 the identity of any unindicted co-conspirator. **Oct. 11 (7 weeks before trial) - government discloses exhibit list.** **Oct. 18 (6 weeks before trial) - simultaneous filing of motions in limine.** **Oct. 25 (5 weeks before trial; 3 weeks before jury selection) - simultaneous filing of proposed jury questionnaire and voir dire.** **Nov. 1 (4 weeks before trial) - responses to motions in limine.** **Nov. 1 (4 weeks before trial) - defense expert witness disclosure.** **Nov. 8 (3 weeks before trial) - simultaneous filing of requests to charge and verdict sheet.** At the close of the government's case-in-chief - defense discloses Rule 16(b)(1)(A) and 16(b)(1)(B) materials, defense witness list and Rule 26.2 statements. Ms. Maxwell hereby states, in accordance with the Court's directive (Dkt. 277), her points of disagreement with the government's proposed schedule. **Identities of Accusers** The government offers no justification for continuing to withhold defense counsel, subject to the protective order, the identities of the alleged victims in this case, so that the defense can adequately prepare for trial. The government has never argued that Ms. Maxwell presents a safety risk to these witnesses. Any privacy concerns are already diminished in light of the Jencks Act materials total in the "low thousands" of pages. In addition, the defense anticipates that many evidentiary issues cannot be decided prior to the presentation of evidence and will necessarily be raised in the context of a particular witness's testimony. **3** The defense reserves the right to file additional motions in limine at a later time after a thorough review of the Jencks Act material and the government's exhibits. The government previously has indicated to counsel that the Jencks Act materials total in the "low thousands" of pages. In addition, the defense anticipates that many evidentiary issues cannot be decided prior to the presentation of evidence and will necessarily be raised in the context of a particular witness's testimony.