DOJ-OGR-00019938.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page79 of 200 16 k7e2MaxC kjc 1 include electronic materials, to be due by Monday, November 9 2 of this year, and following that we would propose the following 3 motion schedule: that defense motions be due by Monday, 4 December 21 of this year; that the government's response be due 5 on Friday, January 22, 2021; and that replies be due on Friday, 6 February 5, 2021. 7 8 THE COURT: All right. Mr. Cohen, based on the government's description of both the quantity and quality of 9 discovery, is that schedule that's been laid out sufficient from your perspective to do everything that you need to do? 10 11 MR. COHEN: Your Honor, just two points in that regard. I think counsel for the government did not mention in 12 the e-mail we had sent to your Honor's law clerk that August 21 would be the deadline for production of search warrant 13 applications and the subpoena returns. I think she just failed to mention it for the record. That would also be part of the 14 schedule. 15 16 THE COURT: Thank you. 17 Ms. Moe, do you agree? 18 19 MS. MOE: That's correct, your Honor. I apologize. We did include that in the e-mail to your Honor's chambers, and 20 that is correct. 21 22 And thank you, counsel, for clarifying that. 23 24 MR. COHEN: Two additional points, your Honor. The trial schedule that we are agreeing to, of course subject to 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019938