B. Discovery
Consistent with its long-standing policy, the government expects to provide discovery in excess of its obligations under Rule 16, Brady, and the Jencks Act. As a result, the document production in this case will be substantial, and is presently ongoing. The government has already produced to other defendants in this, and related cases, six (6) DVDs containing tens of thousands of pages of documents, and expects to produce in excess of 20,000 additional pages shortly. These totals do not include Jencks materials, which will be provided closer to trial. See Section II.C., infra. On or about July 23, 2009, the instant motions were entered on the docket. Those motions asserted the defendant's intention to proceed pro se in this matter. Prior to that time, the government was not aware whether the defendant had counsel and, accordingly, did not produce discovery materials to him directly. The government expects to begin the discovery process with the defendant once the parties have agreed to an appropriate proposed Protective Order governing certain discovery materials.
