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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 33 of 91 k7e2MaxC kjc information. So we were 33 first notified about the circumstances 2 the morning of the defendant's arrest, but I wanted to 3 personally confer with the agent who was involved in breaching 4 the door and verify that before including that information ina 5) brief before the court. That's the reason for the delay, your 6 Honor. 7 THE COURT: Okay. But the government has done that 8 confirmation process and is confident of the information 9 provided and the basic contention there is the basic 10 contention there is that she resisted opening the door in the 11 face of being informed that authorities wer king entry and 12 there is a suggestion of an effort to conceal location 13 monitoring of some type by placing a cell phone in foil of some 14 kind. 15 Could you explain what the government's understanding 16 factually is and what you think should derive from that? 17 MS. MOE: Yes, your Honor. 18 And, with apologies, we were very careful to make sure 19 that the specific language in our briefing was accurate in 20 consultation with the agents, so I don't want to add additional 21 facts or speak extemporaneously about that; but, in short, that 22 is correct that the defendant did not respond to law 23 enforcement announcing their presence and directing her to open 24 the door; that, instead, she left and went into a separate 25 room. SOUTHERN DISTRICT REPORTERS, P. (212) 805-0300 DOJ-OGR-00001910