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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 18 of 19 at *1 (S.D.N.Y. Apr. 20, 2020) (“Gonzalez fails to demonstrate that temporary release is ‘necessary’ for the preparation of his defense because, among other things, his trial is not scheduled for another five months.”); United States v. Eley, No. 20 Cr. 78 (AT), 2020 WL 1689773, at *1 (S.D.N.Y. Apr. 7, 2020) (“Defendant’s request for release is not compelled under the Sixth Amendment; with trial scheduled for nine months from now, this case is distinguishable from other instances in which an imminent evidentiary hearing may support a defendant’s temporary release.”). In fact, the defendant’s own motion makes clear that the MDC has been responsive to defense counsel’s concerns and has ensured that they have access to their client. As their motion notes, the MDC provided defense counsel with access to their client within three hours of a request earlier this week, despite having zero notice and receiving the request after close of business in the evening. See Opposition Memorandum at 12. For non-emergencies, defense counsel can avail themselves of the scheduling system that has been instituted at the MDC to request regular calls with their client and will be able to coordinate with MDC legal counsel should an urgent need arise. 17 DOJ-OGR-00001628