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Case 1:20-cr-00330-PAE Document 302 Filed 06/16/21 Page 2 of 3
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also permitted outdoor recreation every day, although she has the option of declining such recreation time if she wishes.

The defendant also continues to receive as much, if not more, time as any other MDC inmate to communicate with her attorneys. Currently, the defendant receives five hours of video-teleconference (“VTC”) calls with her counsel every weekday, for a total of 25 hours of attorney VTC calls per week. All of these VTC calls take place in a room where the defendant is alone and where no MDC staff can hear her communications with counsel. During these VTC calls, MDC staff place a camera approximately 30 feet away from the door to the room where the defendant conducts the VTC calls. The camera has a full view of the door to the VTC room, but the camera does not capture any sound from the defendant’s VTC calls with her attorneys. The defendant is also permitted to use the phone in the day room to place phone calls to her attorneys as needed.

In addition, the defendant receives in-person visits from her attorneys as needed on weekends. These meetings take place in a room where the defendant is alone with her counsel and where no MDC staff can hear the defendant’s communications with counsel. During these visits, MDC staff place a camera approximately 30 feet away from the door to the attorney visit room. The camera has a full view of the door to the attorney visit room, but the camera does not capture any sound from the defendant’s meetings with her counsel.

Like any other inmate, the defendant is patted down by MDC staff whenever she is moved to a different part of the facility. As part of every pat-down search, the defendant is required to open her mouth briefly so that MDC staff can confirm she has not hidden contraband in her mouth. These pat-down and mouth searches continue to be consistent with MDC’s policy that all inmates be searched whenever they move to a different location within the jail facility. Also like all other inmates, after each in-person visit she receives, the defendant is strip searched.

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