DOJ-OGR-00000614.pdf

--- Page 1 --- The extracted text is: **Case 1:19-cv-00490-RMB** **Document 42** **Filed 08/06/19** **Page 3 of 10** **j7v2espC kjc** For discovery-related motions, we would propose that the defense file any motions that they are aware of relating to discovery, to include motions relating to the nonprosecution agreement, by September 13 -- THE COURT: By when? MS. MOE: September 13, your Honor. -- that the government be permitted to respond by October 4; with any reply due on October 11, as necessary. Of course we understand that if the defense comes to have additional motions related to discovery based on the ongoing discovery process that we will confer and propose an additional briefing schedule beyond that, as necessary. But with respect to motions that the defense is already aware of, including the NPA, that is the schedule that we would propose at this time. Regarding pretrial motions, your Honor, we would propose that the defense file their motions by January 10, that the government be permitted to respond by February 10, and that any replies be due on or before February 24. THE COURT: Got it. MS. MOE: And finally, your Honor, we are prepared to discuss a trial date in this case. The government is asking the court to set a trial date in this matter. We would propose that the court schedule this matter for trial in June of next year, and we estimate that the trial would take approximately **SOUTHERN DISTRICT REPORTERS, P.C.** **(212) 805-0300** **DOJ-OGR-00000614**