Trial Delay And Relocation Requests

SECOND MOTION TO CONTINUE TRIAL DATE

On December 15, the government provided a witness list (comprised of 590 “law enforcement personnel” and 142 “civilian witnesses”) and an exhibit list (naming 1,238 exhibits and an additional 413 “files contained on digital exhibits”). The government provided copies to the Court under seal.

Also on December 15, the government produced 5 disks and two hard drives (collectively, 166.87 gigabytes) containing witness-related Information and other discovery. The government did not include copies (or photographs) of actual listed exhibits, the materials were not Bates-numbered, and no index was provided.

On December 17, the government produced a single disk (2.41 gigabytes) containing what it described as “392 records” comprised of 2,623 individually Bates-stamped pages and other items, including more than 33 hours of audio recordings. No index was provided.

On December 18, the government produced a single disk (3.00 gigabytes) containing 16,825 individually Bates-stamped pages and other items. No index was provided. At least some of the material appears to duplicate the non-Bates-labeled materials producedon December 15, but the defense lacks ready means, other than ongoing manual comparison, to identify the overlap precisely.

NBC

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