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`UNITED STATES DISTRICT COURT
`DISTRICT OF MINNESOTA
`Criminal No. 23-160 (NEB/JFD)
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`v.
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`MONTEZ BROWN et al.,
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`Defendants.
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`)
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`)
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`JOINT PROPOSAL FOR THIRD
`PRETRIAL SCHEDULING
`ORDER
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`The United States of America, by and through its attorneys Andrew M. Luger,
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`United States Attorney for the District of Minnesota, and Justin A. Wesley and Samantha
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`H. Bates, Assistant United States Attorneys, and Brian W. Lynch, DOJ Trial Attorney,
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`moved to designate this case as complex (DCD 532) following the Superseding Indictment
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`in this case (DCD 450). The Court ordered deadlines for responses, a timeline for the
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`parties to meet and confer, and ordered a joint report to the Court on or before Friday,
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`December 15, 2023. (DCD 578). Since that Order, the defense filed various responses and
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`objections. DCD 586, 588, 593, 594, 596, 597, 598, 599, 600, 602, 603, 604, 606, 607,
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`608, 609, 611, and 612.
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`The government has met and conferred with the representatives for all of the
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`defendants in this matter, and all parties have agreed upon a proposed scheduling order
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`(with the exception of the highlighted portion in yellow) (Attached). The defense has
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`requested the highlighted portion in yellow to be included, and the government objects.
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`The parties would like to be heard on this issue.
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`
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`CASE 0:23-cr-00160-NEB-JFD Doc. 638 Filed 12/15/23 Page 2 of 2
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`Defendant Gregory Brown maintains his objection to the complex case designation.
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`However, should the Court designate this case as complex, Defendant Brown agrees to the
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`proposed scheduling order.
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`Please note the government has agreed to certain deadlines which are included in
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`the proposed order, including providing an initial round of exhibits 4 weeks prior to trial,
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`providing most non-cooperator Jencks materials pursuant to the protective order, and
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`providing all Jencks material two weeks prior to trial.
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`Finally, both parties respectfully propose a trial date of either October 21 or 28,
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`2024, with the understanding that Court dates are under complete control and availability
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`of the Court.
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`CONCLUSION
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`For the foregoing reasons, the parties respectfully request that the Court issue the
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`joint proposed Order.
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`Dated: December 15, 2023
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`Respectfully Submitted,
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`ANDREW M. LUGER
`United States Attorney
`s/ Justin A. Wesley
`BY: JUSTIN A. WESLEY
`Assistant U.S. Attorney
`Attorney ID No. 0389189
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`2
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