DOJ-OGR-00020093.jpg

802 KB

Extraction Summary

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

Document Information

Type: Legal document
File Size: 802 KB
Summary

This legal document, filed by the Government, refutes the defense's claim that the defendant cannot adequately prepare for trial while detained at the MDC. The Government outlines the measures taken to ensure access to discovery materials and legal counsel, including providing hard drives, a dedicated laptop, and arranging for daily video calls with her lawyer. The document argues that these provisions, despite pandemic-related restrictions, are sufficient for trial preparation.

People (5)

Name Role Context
Unnamed Defendant Defendant
The subject of the document, whose access to legal counsel and discovery materials while detained at the MDC is being...
Defense counsel Legal Counsel
Represents the defendant; their argument that the defendant cannot prepare for trial is being refuted.
MDC legal counsel Legal Counsel
Arranging for the defendant to receive VTC calls and providing information to the Government about the defendant's ac...
MDC IT staff IT Staff
Mentioned as having been asked to assist the defendant in viewing her hard drives on the MDC computer.
MDC employees Employees
Mentioned as employees who carry the key to the secure location where the laptop is kept, and who do not work regular...

Organizations (3)

Name Type Context
MDC Detention center
The facility where the defendant is housed. The document details the conditions and access provided to the defendant ...
The Government Government agency
The prosecuting party in the case, which provided discovery materials and is arguing against the defense's claims abo...
DOJ-OGR Government agency
Appears in the footer of the document (DOJ-OGR-00020093), likely indicating the Department of Justice office or recor...

Timeline (3 events)

A recently implemented lockdown at the MDC has made in-person visitation currently unavailable.
MDC
The defendant is reviewing discovery materials provided by the Government using hard drives, an MDC computer, and a dedicated laptop.
MDC
The defendant was previously in quarantine, during which the MDC made an exception for her to use a laptop in her isolation cell on weekends.
MDC isolation cell
Defendant

Locations (3)

Location Context
MDC
The location where the defendant is housed and where the events described are taking place.
A location within the MDC where the defendant was previously in quarantine and was allowed to use a laptop on weekends.
A location within the MDC where the laptop provided for the defendant is kept.

Relationships (2)

Unnamed Defendant Professional Defense counsel
The document details arrangements for the defendant to communicate with her defense counsel via VTC calls and weekend phone calls for the purpose of trial preparation.
The Government Adversarial (Legal) Unnamed Defendant
The Government is the prosecuting party, providing discovery to the defendant and arguing in this document against the defense's claims regarding her ability to prepare for trial.

Full Extracted Text

Complete text extracted from the document (2,349 characters)

Case 1:20-cr-560-AJN Document 1002 Filed 06/23/20 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-00020093

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