DOJ-OGR-00001175.jpg

801 KB

Extraction Summary

5
People
2
Organizations
3
Locations
2
Events
3
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 801 KB
Summary

This legal document, filed by the Government, argues that the defendant housed at the Metropolitan Detention Center (MDC) has been given sufficient resources to prepare for trial, refuting a defense claim to the contrary. The filing details the defendant's access to discovery materials via hard drives, a dedicated laptop, and a desktop computer, as well as arrangements for regular video and phone calls with her legal counsel. It asserts that these accommodations, even with pandemic-related restrictions, are adequate for trial preparation.

People (5)

Name Role Context
the defendant Defendant
The subject of the legal filing, housed at the MDC, who needs to review discovery materials for her trial.
Defense counsel Legal Counsel
Represents the defendant, provides discovery materials, and schedules legal calls.
MDC legal counsel Legal Counsel
Legal representative for the MDC, arranging VTC calls and providing information on the defendant's access to resources.
MDC IT staff IT Support Staff
Was asked by the Government to assist the defendant in viewing her hard drives on the MDC computer.
MDC employees Staff
Employees who carry the key to the secure location where the laptop is kept, whose weekend schedules limit the defend...

Organizations (2)

Name Type Context
MDC Detention Center
The Metropolitan Detention Center where the defendant is housed.
The Government Government Agency
The prosecuting party in the legal case, which provided discovery materials and this legal filing.

Timeline (2 events)

The defendant reviews discovery materials provided by the Government and her defense counsel using hard drives, a laptop, and a desktop computer at the MDC.
MDC
The defendant was previously in quarantine, during which the MDC made an exception to allow her to use a laptop in her isolation cell on weekends.
isolation cell

Locations (3)

Location Context
MDC
The facility where the defendant is housed and reviewing discovery materials.
A cell within the MDC where the defendant was previously quarantined and given special permission to use a laptop on ...
A location within the MDC where the defendant's laptop is kept.

Relationships (3)

the defendant Professional / Client-Attorney Defense counsel
The document describes Defense counsel representing the defendant, providing discovery materials, and scheduling legal calls on her behalf.
The Government Adversarial / Legal the defendant
The Government is the prosecuting party, providing discovery to the defendant and arguing in this document against the defense's claims about her ability to prepare for trial.
MDC Custodial the defendant
The defendant is housed at the MDC, which controls her access to resources like computers, visitation, and phone calls as detailed in the document.

Full Extracted Text

Complete text extracted from the document (2,350 characters)

Case 1:20-cr-00330-AJN Document 1002 Filed 02/18/20 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-00001175

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