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Case 1:20-cr-00330-AJN Document 60 Filed 10/06/20 Page 3 of 3

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Government as part of its ongoing investigation, well in advance of any trial in this matter.
Premature disclosure of these witnesses’ identities and sensitive information about those witnesses risks jeopardizing the Government’s ongoing investigation in at least two respects. First, disclosure would tend to reveal to the defendant the scope of and evidence gathered during the Government’s ongoing investigation, the details of which are not currently public or known to the defendant. Second, an order requiring the immediate production of these Materials would risk deterring other victims from coming forward to be interviewed and from providing evidence to the Government. Victims who may be considering cooperating with the Government’s investigation may decline to do so if they believe that the information they provide—even information outside the period charged in the Indictment—must be immediately disclosed to the defense in this case. Given the sensitivity of the Materials, the need to protect the Government’s ongoing investigation, and the minimal (if any) relevance of the Materials to the offenses charged in the Indictment, the Government respectfully submits that good cause exists pursuant to Rule 16(d) to delay their disclosure.

Accordingly, the Government respectfully requests that the Court approve the Government’s request to delay disclosure of these Materials.

Respectfully submitted,

AUDREY STRAUSS
Acting United States Attorney

By: [Signature]
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324

Cc: All Counsel of Record (By ECF)

DOJ-OGR-00001781