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be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 21-770, Document 20-2, 04/01/2021, 3068530, Page129 of 200 66 k7e2MaxC kjc MR example, verificati . COHEN: 'm sorry. the proceeding open on information, the court has concerns about the number of for a week and allow us If the court desires to leave to come back, if suretors, for information about financial issues, we think th a little bi the court's consideration. We came package we could put at, now that w hav som ability to breathe t, that we should be able to pull this together for who was arrested, held in custody, the MDC held in, term of sol Lu. tary co like administrative now. forward with the best together on a limited notice with a client has been since she came to [ will call it, the equivalent of the layman's nfinement. There is probably a BOP word, seg., or some other word they have for it We have had a client who has been kept alone in a room with the lights on all the time, is not us in the jail ata had her legal mater given back. answer quest So wor tions ab Fficult, is very di ll, wasn't allowed ials taken away king with that, t allowed to speak with to shower for 72 hours, from her, only recently we have been trying to out financial situation and others, but it your Honor, under circumstances that are of the government's creation, of the government's creation, and we —-- THI! think that's for clarity, GI COURT: So I do want to understand that point. the "by design" point that you are making. Just [ understand that there was consent to detention SOUTH BRN DISTRICT RE PORT ERS, (212) 805-0300 P a Gs DOJ-OGR-00001070