DOJ-OGR-00002196(1).jpg
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Extraction Summary
5
People
3
Organizations
5
Locations
4
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
728 KB
Summary
This legal document, filed by the Government, argues against a defendant's release from the Metropolitan Detention Center (MDC). It asserts that the MDC provides adequate care, including meals and medical checks, and that the security searches she complains about are standard procedure. The document also dismisses COVID-19 concerns, noting the defendant was quarantined and tested negative after a potential exposure and has no underlying health conditions, making her release unwarranted.
People (5)
| Name | Role | Context |
|---|---|---|
| defendant | Inmate |
The subject of the legal filing, whose complaints about diet, searches, and COVID-19 risks are being addressed.
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| psychology and medical staff | Healthcare Staff |
Mentioned as checking on the defendant daily at the MDC.
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| MDC legal staff | Legal Staff |
Described as being highly attuned to the defendant's complaints.
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| searching staff member | Security Staff |
Conducts visual inspections of the defendant's mouth while wearing a mask.
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| MDC legal counsel | Legal Counsel |
Assured the Government that staff does not monitor privileged communications and that extra security steps are necess...
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| MDC | Detention facility |
The institution where the defendant is incarcerated. The document details its procedures regarding the defendant's ca...
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| The Government | Government agency |
The party arguing against the defendant's release, presenting the MDC's actions as appropriate and sufficient.
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| The Court | Judicial body |
The entity that previously found the defendant had no underlying health conditions and is being asked to reject her r...
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Timeline (4 events)
The defendant is subjected to searches after every visit, searches of her cell, and pat downs, which are standard procedures for all inmates.
MDC
Locations (5)
| Location | Context |
|---|---|
|
The location where the defendant is incarcerated and where the events described take place.
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Mentioned in passing as a location for other inmates.
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The defendant has access to it to supplement her diet.
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One of the locations that is searched.
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Where the defendant was placed after potential exposure to COVID-19.
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Relationships (3)
The document describes the MDC's provision of care (meals, medical checks) and security measures (searches) applied to the defendant.
MDC legal counsel has provided assurances to the Government regarding the necessity of security measures and the privacy of the defendant's legal communications.
The document mentions the defendant's calls and visits with legal counsel, which are stated to be unmonitored by MDC staff.
Full Extracted Text
Complete text extracted from the document (2,147 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 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-00002196
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