DOJ-OGR-00019935.json 4.3 KB

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  3. "page_number": "76",
  4. "document_number": "39-2",
  5. "date": "04/01/2021",
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  10. "full_text": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page76 of 200\nk7e2MaxC kjc\n1 the entry of that protective order, as I noted, your Honor, the government is prepared to make a substantial production of discovery.\n2\n3 Your Honor, in advance of the conference, the government and defense counsel proposed a joint schedule for\n4 discovery, motion practice, and a proposed trial date, in\n5 particular, the date selected in that schedule with an eye\n6 towards assuring that there was sufficient time for the\n7 government to do a careful and exhaustive and thorough review\n8 of all of the materials that I just referenced to make sure\n9 that the government is complying with its discovery obligations\n10 in this case, which we take very seriously. We expect that the\n11 bulk of the relevant materials will be produced in short order,\n12 primarily by the end of this summer, with additional materials\n13 to follow primarily in a category I mentioned before, your\n14 Honor, of electronically stored information, which is subject\n15 to an ongoing privilege review which we discussed and\n16 communicated with defense counsel about. We have proposed a\n17 scheduling order again to be very thorough in our review of\n18 discovery and in files in various places where they may be\n19 located and we are taking an expansive and thoughtful approach\n20 to our obligations in this case, your Honor.\n21\n22 THE COURT: Let me just follow up specifically, since\n23 you have referenced prior investigative files, to the extent we\n24 have seen in other matters issues with complete disclosure of\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00019935",
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  24. "content": "1 the entry of that protective order, as I noted, your Honor, the government is prepared to make a substantial production of discovery.\n2\n3 Your Honor, in advance of the conference, the government and defense counsel proposed a joint schedule for\n4 discovery, motion practice, and a proposed trial date, in\n5 particular, the date selected in that schedule with an eye\n6 towards assuring that there was sufficient time for the\n7 government to do a careful and exhaustive and thorough review\n8 of all of the materials that I just referenced to make sure\n9 that the government is complying with its discovery obligations\n10 in this case, which we take very seriously. We expect that the\n11 bulk of the relevant materials will be produced in short order,\n12 primarily by the end of this summer, with additional materials\n13 to follow primarily in a category I mentioned before, your\n14 Honor, of electronically stored information, which is subject\n15 to an ongoing privilege review which we discussed and\n16 communicated with defense counsel about. We have proposed a\n17 scheduling order again to be very thorough in our review of\n18 discovery and in files in various places where they may be\n19 located and we are taking an expansive and thoughtful approach\n20 to our obligations in this case, your Honor.\n21\n22 THE COURT: Let me just follow up specifically, since\n23 you have referenced prior investigative files, to the extent we\n24 have seen in other matters issues with complete disclosure of\n25",
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  44. "dates": [
  45. "04/01/2021"
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  48. "Case 21-58",
  49. "Document 39-2",
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  51. "DOJ-OGR-00019935"
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