DOJ-OGR-00001177.jpg
738 KB
Extraction Summary
5
People
3
Organizations
1
Locations
3
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
738 KB
Summary
This legal document, filed by the Government, argues against the release of a defendant from the Metropolitan Detention Center (MDC). The filing asserts that the MDC has adequately addressed the defendant's complaints about her diet and security searches, and that precautionary measures taken after a potential COVID-19 exposure were effective. The Government concludes that because the defendant has no underlying health conditions, the pandemic does not warrant her release.
People (5)
| Name | Role | Context |
|---|---|---|
| the defendant | Inmate |
The subject of the legal filing, whose conditions of confinement, health, and potential release are being discussed.
|
| psychology and medical staff | Jail Staff |
Mentioned as checking on the defendant daily at the MDC.
|
| MDC legal staff | Legal Staff |
Described as being attuned to the defendant's complaints.
|
| searching staff member | Jail Staff |
Mentioned in the context of conducting visual inspections of the defendant's mouth.
|
| MDC legal counsel | Legal Counsel |
Stated to have assured the Government about the privacy of the defendant's communications and the necessity of securi...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| MDC | Government agency |
The detention facility where the defendant is incarcerated. The document details its procedures regarding the defenda...
|
| the Government | Government agency |
The party making the legal argument in this document, opposing the defendant's release.
|
| the Court | Government agency |
The judicial body being addressed in the filing, which previously made a finding at a bail hearing.
|
Timeline (3 events)
The defendant is incarcerated at the MDC, where she receives daily checks, meals, and is subject to security searches.
MDC
the defendant
MDC staff
The defendant was potentially exposed to COVID-19, placed in quarantine, remained asymptomatic, tested negative, and was subsequently released from quarantine.
MDC
An initial bail hearing was held where the Court found that the defendant had no underlying health conditions that would put her at greater risk from COVID-19.
Court
Locations (1)
| Location | Context |
|---|---|
|
The location where the defendant is incarcerated and where the events described (searches, quarantine, etc.) take place.
|
Relationships (3)
The document describes the interactions between the defendant and various MDC staff (medical, legal, searching staff) regarding her diet, health, security searches, and complaints.
The document mentions the defendant's privileged communications (calls and visits) with her legal counsel.
The Government is arguing against the defendant's release in this legal filing addressed to the Court.
Full Extracted Text
Complete text extracted from the document (2,149 characters)
Case 1:20-cr-00330-AJN Document 100-2 Filed 06/25/20 Page 35 of 36
other inmates in protective custody. Additionally, psychology and medical staff check on the defendant daily, MDC legal staff are highly attuned to any complaints the defendant has raised, and following initial complaints about the defendant’s diet early in her incarceration, the MDC has ensured that the defendant receives three full meals per day and has access to commissary from which she can supplement her diet.
The MDC has taken numerous steps to strike the balance between the security of the institution and providing the defendant with adequate time and resources to prepare her defense. In that vein, many of the searches the defendant complains of—such as searches after every visit, searches of her cell, pat downs when she is moved, and directing her to open her mouth for visual inspection (while the searching staff member is wearing a mask)—are the same searches to which every other inmate is subjected for the security of the institution. MDC legal counsel has assured the Government that MDC staff does not record or listen to the substance of the defendant’s calls and visits with legal counsel. To the extent MDC staff conducts additional searches or monitoring of the defendant, MDC legal counsel has indicated that those steps are necessary to maintain the security of the institution and the defendant.
With respect to the defense concerns regarding COVID-19, the Government recognizes, as it did in its initial bail briefing, that the virus presents a challenge at any jail facility. At least for this defendant, the MDC’s precautionary measures appear to have worked. When the defendant was potentially exposed to the virus, she was placed in quarantine, remained asymptomatic, tested negative, and then was released from quarantine. As the Court found at the initial bail hearing, the defendant has no underlying health conditions that would place her at greater risk of complications from COVID-19. (Tr. 89). For that same reason, the Court should again reject the suggestion that the pandemic warrants the defendant’s release.
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DOJ-OGR-00001177
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