DOJ-OGR-00013852.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 759** **Filed 08/10/22** **Page 261 of 267** **LCAVMAX8** 1. Our concern is that the jury might feel we don't want to come back and would rush to judgment in a case that we know they were prepared to be here until the middle of January. And they are already getting some time off. They may be disinclined to want to come back. And that could inure to the disadvantage of both parties, I understand. 2. But I think we would not want to be in a position where the jury basically had one day prior to Christmas holiday, and I would ask the Court to be mindful of that, as I am sure you are. And that was one of the reasons why early on when we were hopeful that we could begin this case earlier because of our concern that it was going to bump up, now clearly we are way ahead of what the schedule is. But I would ask the Court to take into consideration that concern that we have. **THE COURT: Okay. Ms. Moe?** **MS. MOE:** Your Honor, with respect to the timing of deliberations, I think the request on the timing of deliberations is, I think, at best, premature because we don't know how long the defense case will be; and so I don't think the Court needs to reach that now. But as a preview, if we end up in a situation in which the defense rests during the week of the 20th, I think we should be respectful of the jury's time. There's no reason for the jury not to be permitted to deliberate. I think it would **SOUTHERN DISTRICT REPORTERS, P.C.** **(212) 805-0300** **DOJ-OGR-00013852**