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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page132 of 200 k7e2MaxC kjc 1 And in response to that, the government said, well, 2 too bad, COVID crisis, too bad, Ms. Maxwell, we are not going 3 to let you out. We are not going to let you out because you 4 might get infected, we are not going to let you out because, 5 you know, because it will be tough preparing your trial. And 6 they cite to your Honor, in reply, two pages of cases, very 7 limited parentheticals. If you actually read those cases, they 8 are totally different from our situation, your Honor. The 9 cases they cite on health risks in the prison environment, they 10 cite 14 cases, 12 of them are dangerousness cases, people who 11 are convicted of multiple felonies, including weapons felonies. 12 The courts in those cases determined the COVID factors do not 13 outweigh that analysis. They cite nine cases on the 14 preparation and access to counsel. Several of them are 15 dangerousness cases, and the other ones that have some 16 discussion of flight risk are so extremely different from our 17 case as to not be relevant. 18 Judge, I don't know how we could possibly prepare this 19 case, getting four months of discovery, including electronic 20 discovery, and in over 25 years of conduct, with a client who 21 is in custody, who we can't meet with in person. And I'm not 22 Faulting the BOP. I understand why they have to do what they 23 have to do, and your Honor has made the same point, but it is 24 just we have to be in the real world here. We have to 25 THE COURT: Whether defendants are detained because of 69 SOUTH BRN DISTRICT REP ORTERS, PiaG. (212) 805- 0300 DOJ-OGR-00001073