DOJ-OGR-00002194.jpg
792 KB
Extraction Summary
5
People
2
Organizations
3
Locations
2
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
792 KB
Summary
This legal document, filed on December 18, 2020, is a response from the Government arguing that the defendant, housed at the MDC, has adequate resources to prepare for trial. It refutes the defense's claim to the contrary by detailing provisions such as daily VTC calls with counsel, access to discovery on hard drives, and the provision of a dedicated laptop. The document also explains how access to this equipment is managed within the MDC, including during a recent period of quarantine.
People (5)
| Name | Role | Context |
|---|---|---|
| defendant | defendant |
The subject of the document, who is housed at the MDC and whose access to legal counsel and discovery materials is be...
|
| MDC legal counsel | legal counsel |
Mentioned as arranging a VTC call for the defendant and as a source of information for the Government regarding the d...
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| Defense counsel | legal counsel |
Represents the defendant, can schedule legal calls, and provides discovery materials to the defendant.
|
| MDC IT staff | IT staff |
Were asked by the Government to assist the defendant in viewing her hard drives on the MDC computer.
|
| MDC employees who carry the key | employees |
Their limited weekend work schedule restricts the defendant's access to a laptop on weekends.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| MDC | detention center |
The facility where the defendant is housed. The document details the conditions and access to resources within the MDC.
|
| Government | government agency |
The prosecuting party in the case. The document outlines steps the Government has taken to ensure the defendant can r...
|
Timeline (2 events)
The Government details the provisions made for the defendant to review discovery materials and communicate with counsel, including providing hard drives, a dedicated laptop, and arranging VTC calls.
MDC
Locations (3)
| Location | Context |
|---|---|
|
The location where the defendant is housed and where the events described are taking place.
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|
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A location within the MDC where the defendant's laptop is stored, access to which is restricted.
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A location within the MDC where the defendant was previously held in quarantine and was allowed to use a laptop on we...
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Relationships (3)
Defense counsel represents the defendant, provides discovery materials, and schedules legal calls for her.
The Government is the prosecuting party in a legal case against the defendant, but is also taking steps to ensure she has access to discovery materials as required by law.
The Government is coordinating with the MDC (including its legal counsel and IT staff) to facilitate the defendant's access to legal resources.
Full Extracted Text
Complete text extracted from the document (2,350 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 33 of 36
counsel, and when visiting is available depending on pandemic-related conditions, the defendant has access to legal visits. Due to the recently implemented lockdown at the MDC, visitation is not currently available, but MDC legal counsel is arranging for the defendant to receive a VTC call with legal counsel three hours per day every weekday, starting this Friday. Defense counsel will also be able to schedule legal calls on weekends as needed. Given those facts, the defense argument essentially suggests that no defendant could prepare for trial while housed at the MDC— a patently incorrect claim.
The defendant is able to review her discovery using hard drives provided by the Government, discs that defense counsel can send containing any copies of discovery material defense counsel chooses within the confines of the protective order, or hard copy documents provided by defense counsel. The Government has taken multiple steps to address technical difficulties the defendant has encountered when reviewing her hard drives. These steps included modifying and reproducing productions in new formats, asking MDC IT staff to assist the defendant in viewing her hard drives on the MDC computer, and then purchasing and providing a laptop for the defendant’s exclusive use.¹⁰ Even when the defendant was temporarily unable to review some files from some hard drives, she was always able to review other portions of her discovery.
¹⁰ The Government understands from MDC legal counsel that the defendant has access to the laptop thirteen hours per day during weekdays and has access to the MDC desktop computer thirteen hours per day seven days per week. The use of the laptop is limited to weekdays because the MDC restricts the number of employees who carry the key to the secure location where the laptop is kept, and the employees with that key do not work regularly on weekends. The MDC previously accommodated an exception to this rule while the defendant was in quarantine and arranged for her to use the laptop in her isolation cell on weekends because otherwise she would not have had access to a computer during weekends while in quarantine. Now that she is out of quarantine, the defendant will have access to the MDC desktop computer on weekends.
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DOJ-OGR-00002194
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