light of the distinctive circumstances described below, the People do not oppose a brief adjournment of up to 30 days to permit sufficient time for defendant to review the USAO productions. Yesterday afternoon, however, the USAO produced approximately 31,000 pages of additional records to both the People and the defense in response to defendant's subpoena, and also indicated that an additional production would follow by next week. We note that the timing of the current production of additional materials from the USAO is a function of defendant's own delay. In response, the USAO produced a subset of the materials we requested, which we timely and fully disclosed to defendant on June 8, 2023, more than nine months ago. Despite having access to those materials since June, defendant raised no concerns to the People about the sufficiency of our efforts to obtain materials from the USAO before last week; instead, defendant waited until January 18, 2

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