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Case 1:20-cr-00330-PAE Document 188 Filed 03/29/21 Page 4 of 5

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today the Government provided the defense with a list of Bates ranges within the discovery materials produced to date that are particularly relevant to Minor Victim-4. Although that list is not exhaustive and does not include every document that may be relevant to Minor Victim-4, it identifies key pieces of evidence regarding this victim.

Additionally, in order to ensure that the defense has adequate time to prepare for trial, the Government intends to begin its production to the defense of non-testifying witness statements by April 12, 2021, approximately three months in advance of trial. This production will include the statements of more than 250 witnesses related to the investigation of Jeffrey Epstein and his associates in the Government’s possession whom the Government does not currently expect to call to testify at trial. The Government is continuing to review its files for witness statements and will produce any additional non-testifying witness statements that come to light on a rolling basis as promptly as possible in advance of trial.

Finally, given the expanded charges in the S2 Indictment, the Government is prepared to produce Jencks Act and Giglio material for witnesses it expects to call at trial six weeks, rather than four weeks, in advance of trial. These productions, together with the guidance provided to the defense today regarding discovery relating to Minor Victim-4, should provide ample time for the defense to prepare for trial and proceed as scheduled on July 12, 2021.

III. Motions

In light of the new allegations and charges contained in the S2 Indictment, the Government will meet and confer with defense counsel to discuss whether defense counsel wishes to bring additional motions (or supplement existing motions) based on the S2 Indictment and, if so, to discuss a proposed schedule for any additional briefing. Although the S2 Indictment should have

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