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.

Regarding the 73,000 pages of records produced by the USAO as of the date of defendant’s motion, the People’s initial review indicated that those materials were largely irrelevant to the subject matter of this case, with the exception of approximately 172 pages of witness statements that defendant would have adequate time to review and address before trial. 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. The People diligently sought the full grand jury record related to Cohen’s campaign finance convictions from the USAO last year, including exculpatory material and (1) grand jury minutes and tapes; (2) witness lists and other documents identifying the names or identities of grand jury witnesses; (3) any grand jury subpoenas and documents returned pursuant to those subpoenas; (4) exhibits presented to the grand jury; (5) to the extent within the scope of Rule 6(e), summaries of witness interviews occurring outside the grand jury; and (6) to the extent within the scope of Rule 6(e), search warrant affidavits or other applications that contain evidence from the grand jury, and evidence seized pursuant to those warrants. 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,

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