DOJ-OGR-00001436.jpg

Casest:20-cr/00Bat AGA B6ermMent 2202 Filedoos/95/PagPage2asf 2 Page 2 because MDC has identified a number of factors that raise heightened safety and security concerns with respect to this defendant, including: (1) the nature of the charges, (2) the potential stress for inmates that can arise in high-profile cases, and (3) the need to ensure the defendant’s safety while she is incarcerated in a cell by herself—a housing determination made by MDC staff based on various factors, including the defendant’s expressed concern for her safety if she were to be housed in the general population.! As to the Court’s question whether the defendant can be provided with “appropriate eye covering,” MDC legal counsel has informed the Government that the defendant cannot be provided with an eye mask. Eye masks are not available for purchase in commissary and are not issued to inmates and, therefore, are considered contraband. The defendant is permitted, however, to use non-contraband items to cover her eyes at night. Should the Court have any questions or require any additional details regarding this topic, the Government will promptly confer with legal counsel at MDC and provide additional information. Respectfully submitted, AUDREY STRAUSS United States Attorney By: ___s/ Maurene Comey / Alison Moe / Lara Pomerantz Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) ' The MDC has determined the defendant’s current housing assignment based, in part, on her concerns about being housed in the general population and as an alternative to her being housed in the SHU. By contrast, in the SHU, most inmates have a cellmate which provides an additional check should something go wrong or should an inmate need medical attention in the middle of the night. DOJ-OGR-00001436