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623 KB
Extraction Summary
3
People
4
Organizations
2
Locations
4
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing / legal memorandum
File Size:
623 KB
Summary
This document is Page 2 of a Government filing (Case 1:20-cr-00330-PAE, filed 10/15/21) addressing defense complaints regarding legal mail delays at the MDC. The Government argues that a request for 1-day mail turnaround is burdensome given the facility houses 1,700 inmates. It details the timeline of a specific hard drive delivery: sent Oct 11, received Oct 12, delayed Oct 13 due to an 'institutional emergency,' and personally delivered to the defendant by MDC legal counsel on Oct 14, 2021.
People (3)
| Name | Role | Context |
|---|---|---|
| The Defendant | Inmate/Accused |
Subject of the legal mail delivery dispute; housed at MDC. (Case 1:20-cr-00330-PAE corresponds to United States v. Gh...
|
| Legal counsel at the MDC | MDC Staff/Attorney |
Explained protocols to the Government; personally delivered hard drive to the defendant.
|
| Defense counsel | Attorney |
Lawyers representing the defendant who requested expedited mail delivery.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Facility housing approximately 1,700 inmates including the defendant.
|
|
| The Government |
Filing the document; coordinating with MDC regarding discovery delivery.
|
|
| FedEx |
Used to ship the hard drive containing disclosures.
|
|
| Court |
Issued orders regarding disclosures.
|
Timeline (4 events)
2021-10-11
2021-10-14
MDC legal counsel personally delivered the hard drive to the defendant.
MDC
MDC Legal Counsel
The Defendant
Locations (2)
| Location | Context |
|---|---|
|
Location of the defendant and the 'institutional emergency'.
|
|
|
Located at the MDC; origin point for internal mail distribution.
|
Relationships (2)
Government conferred with MDC counsel regarding mail delivery protocols and specific delivery of the hard drive.
Defendant is an inmate at the MDC.
Key Quotes (4)
"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"Source
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Quote #1
"The Government respectfully submits that there are no circumstances that merit special expedited delivery for this defendant"Source
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Quote #2
"institutional emergency impacting the safety and security of the MDC on October 13, 2021"Source
DOJ-OGR-00005235.jpg
Quote #3
"legal counsel at the MDC personally delivered the hard drive to the defendant."Source
DOJ-OGR-00005235.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,763 characters)
Case 1:20-cr-00330-PAE Document 350 Filed 10/15/21 Page 2 of 3
Page 2
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.
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.
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.
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-00005235
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