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Case 1:20-cr-00330-PAE Document 386-1 Filed 10/29/21 Page 4 of 4

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Additionally, the Government reiterates its August 5, 2020 request for reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of: (1) any books, papers, documents, data, photographs, tangible objects, buildings or places, or copies or portions thereof, which are in the defendant’s possession, custody or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental examinations and of scientific tests or experiments made in connection with this case, or copies thereof, which are in the defendant’s possession or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the defendant intends to call at trial.

The Government also reiterates its August 5, 2020 request that the defendant disclose prior statements of witnesses she will call to testify, including expert witnesses. See Fed. R. Crim. P. 26.2; United States v. Nobles, 422 U.S. 225 (1975). The Government requests that such material be provided on the same basis upon which the Government agrees to supply the defendant with 3500 material relating to Government witnesses.

Very truly yours,

AUDREY STRAUSS
United States Attorney

by: /s/
Alison Moe
Maurene Comey
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
(212) 637-2225

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