DOJ-OGR-00020095.jpg
738 KB
Extraction Summary
5
People
3
Organizations
2
Locations
3
Events
4
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
738 KB
Summary
This legal document, part of a court filing, is the Government's argument against a defendant's release from the Metropolitan Detention Center (MDC). The Government contends that the MDC has adequately addressed the defendant's complaints regarding diet and security searches, and that its COVID-19 precautions were effective, as the defendant was quarantined and tested negative after a potential exposure. The filing concludes that since the defendant has no underlying health conditions, the pandemic does not warrant her release.
People (5)
| Name | Role | Context |
|---|---|---|
| defendant | defendant |
The subject of the legal filing, an inmate at the MDC whose complaints and health status are being discussed.
|
| psychology and medical staff | medical staff |
Mentioned as staff who check on the defendant daily at the MDC.
|
| MDC legal staff | legal staff |
Described as being highly attuned to any complaints the defendant has raised.
|
| searching staff member | security staff |
Mentioned as the individual conducting visual inspections of the defendant's mouth.
|
| MDC legal counsel | legal counsel |
Has provided assurances to the Government regarding MDC's policies on inmate monitoring and security.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| MDC | detention center |
The institution where the defendant is incarcerated. The document details its procedures regarding inmate care, secur...
|
| Government | government agency |
The prosecuting party in the legal case, arguing against the defendant's release.
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| The Court | government agency |
The judicial body that presided over the initial bail hearing and is being asked to reject the defendant's release.
|
Timeline (3 events)
The defendant is subjected to routine searches, including after visits, of her cell, pat downs when moved, and visual mouth inspections.
MDC
Locations (2)
| Location | Context |
|---|---|
|
The location where the defendant is incarcerated and where the events described (searches, quarantine) took place.
|
|
|
Mentioned generically as a type of location where the COVID-19 virus presents a challenge.
|
Relationships (4)
The Government is arguing against the defendant's release in a legal filing to the Court.
The defendant is an inmate at the MDC and is subject to its rules, security procedures, and care protocols.
MDC legal counsel has communicated with and provided assurances to the Government regarding the facility's policies.
The document mentions the defendant's privileged communications (calls and visits) with her legal counsel.
Full Extracted Text
Complete text extracted from the document (2,149 characters)
Case 1:20-cr-560880-AJN Document 1002 Filed 06/23/20 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-00020095
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