DOJ-OGR-00019939.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page80 of 200 k7e2MaxC kjc 1 the court's approval, assumes there will be no substantive 2 superseding indictment. If there is one, which the government 3 has advised us they don't believe is imminent or I assume not 4 at all, we might have to come back to the court to address not 5 just trial schedule but other schedule as well. 6 And I am assuming -- we take your Honor's points about 7 the issues on discovery, and we agree with them, particularly 8 as to electronic discovery; and I am assuming that, as this 9 unfolds, if we spot an issue we think needs further attention, 10 we will be able to bring it to the court's attention. 11 Those are my points. 12 THE COURT: Thank you, Mr. Cohen. 13 Let me go ahead and ask, Ms. Moe, Mr. Cohen has made a 14 representation but I will ask if you do anticipate at this time 15 filing any further superseding indictments adding either 16 defendants or additional charges? 17 MS. MOE: Your Honor, our investigation remains 18 ongoing, but at this point we do not currently anticipate 19 seeking a superseding indictment. 20 THE COURT: All right. So with that -- and also let 21 me ask, Ms. Moe, just because it is next on my list, what 22 processes the government has put in place to notify alleged 23 victims of events and court dates pursuant to the Crime Victims 24 Rights Act. 25 MS. MOE: Yes, your Honor. I am happy to give the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019939