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Case 1:20-cr-00330-PAE Document 326 Page 3 Filed 08/23/21 Page 3 of 3 materials she can carry into the VTC room. Previously, the defendant was permitted to bring a cart full of legal materials into the VTC room for meetings with defense counsel; however, the defendant used that cart to barricade the door to the VTC room, thereby preventing MDC staff from being able to access the room. Because of the security threat posed by the use of the cart to barricade the door to the VTC room, the defendant is no longer permitted to bring the cart into the room. Instead, the defendant may bring whatever materials she can carry into the room, and if she needs other materials during a particular meeting with counsel, she may leave the VTC room, retrieve those materials by hand, and then return to her meeting with counsel. With respect to in- person meetings, as noted in MDC legal counsel’s August 14, 2021 email to defense counsel (see Dkt. No. 319 at 2), MDC staff have been instructed that the defendant and defense counsel should be allowed to pass documents to each other and review materials together during in-person visits. Should the Court have any questions or require any additional details regarding this topic, the Government will promptly provide additional information. Ce: All Counsel of Record (By ECF) Respectfully submitted, AUDREY STRAUSS United States Attorney Maurene Comey / Alison Moe Lara Pomerantz / Andrew Rohrbach Assistant United States Attorneys Southern District of New York Tel: (212) 637-2324 DOJ-OGR-00005013