DOJ-OGR-00005244.jpg

631 KB

Extraction Summary

3
People
5
Organizations
2
Locations
4
Events
3
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 631 KB
Summary

This legal document, filed by the Government, responds to a request from defense counsel for expedited delivery of legal mail to a defendant held at the MDC. The Government argues against the request, citing the burden on the MDC's legal department, and details a timeline of events where a hard drive delivery was delayed by one day due to an 'institutional emergency' at the facility on October 13, 2021.

People (3)

Name Role Context
defense counsel Legal representative for the defendant
Mentioned as having requested that the MDC provide the defendant with legal mail within one day of receipt.
the defendant Defendant
The intended recipient of a hard drive containing Court-ordered disclosures.
Legal counsel at the MDC Legal counsel
Explained the burden of the defense's request, informed the Government of an institutional emergency, and personally ...

Organizations (5)

Name Type Context
MDC Correctional facility
A facility housing approximately 1,700 inmates, including the defendant. The document discusses its procedures for ha...
MDC's legal department Government agency department
Responsible for legal issues relating to the approximately 1,700 inmates at the MDC.
The Government Government agency
The party that sent the hard drive to the defendant and is submitting this document to the Court.
FedEx Company
The courier service used by the Government to send a hard drive to the defendant.
the Court Government agency
The judicial body that ordered the disclosures and to whom this document is addressed.

Timeline (4 events)

2021-10-11
The Government sent a hard drive containing Court-ordered disclosures to the defendant via FedEx.
2021-10-12
The hard drive sent by the Government was received by the MDC.
MDC
2021-10-13
An institutional emergency impacting safety and security occurred at the MDC, preventing any inmate from receiving legal mail from the warehouse.
MDC
2021-10-14
Legal counsel at the MDC personally delivered the hard drive to the defendant.
MDC

Locations (2)

Location Context
MDC
The location where the defendant is an inmate and where the events surrounding the mail delivery took place.
The location from which legal mail is distributed to the MDC; delivery was halted from here due to an emergency.

Relationships (3)

The Government Adversarial (legal) the defendant
The Government is providing 'Court-ordered disclosures' to the defendant as part of a legal case (Case: 2:20-cr-00333-ABN).
defense counsel Professional (lawyer-client) the defendant
Defense counsel made a request on behalf of the defendant regarding the delivery of legal mail.
Legal counsel at the MDC communicated with the Government regarding the status of the mail delivery and an institutional emergency.

Full Extracted Text

Complete text extracted from the document (1,765 characters)

Case: 2:20-cr-00333-ABN Document 353 Filed 10/15/21 Page 2 of 3
Page 2
standard procedures for legal mail, and these protocols apply to each one of the approximately 1,700 inmates at the MDC. Legal counsel at the MDC has further explained that defense counsel's request that the MDC be ordered to provide the defendant with all legal mail within one day of receipt by the MDC would be extremely burdensome and is not practicable in light of the various responsibilities of the MDC's legal department, which is responsible for issues relating to the approximately 1,700 inmates at the MDC. The Government respectfully submits that there are no circumstances that merit special expedited delivery for this defendant, and that the delivery of the defendant's mail should not receive priority over the services the legal department's staff provides to other inmates.
As noted in the defense's letter, the Government sent a hard drive containing Court-ordered disclosures to the defendant via FedEx on October 11, 2021. The hard drive was received by the MDC on October 12, 2021. Legal counsel at the MDC informed the Government that there was an institutional emergency impacting the safety and security of the MDC on October 13, 2021, such that no inmate at the MDC received any legal mail from the warehouse that day. On the morning of October 14, 2021, legal counsel at the MDC personally delivered the hard drive to the defendant.
The Government has made best efforts to obtain accurate information and respond to the Court's Order within a short time frame. Should the Court have any questions or require any additional details regarding this topic, the Government will confer with legal counsel at the MDC and provide additional information.
DOJ-OGR-00005244

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