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Case 1:20-cr-00330-PAE Document 326 Filed 08/23/21 Page2of3 Page 2 On or about August 12, 2021, MDC IT staff assigned the defendant such a BOP-generated VTC virtual room for her to use with her attorneys. Due to an oversight by MDC IT staff, however, that same VTC virtual room had also been assigned for a different group’s use at the same time as the defendant’s VTC appointment. As a result of the inadvertent double-booking of the virtual room, the participants in both VTC meetings were logged into the room at the same time. In order to ensure that such an issue does not occur again, MDC and BOP staff spent several days working to set up a unique VTC virtual room for the defendant’s exclusive use on the BOP’s system. That process was completed last week, and the defendant’s VTC meetings with counsel resumed on or about August 20, 2021 using a unique VTC virtual room. MDC staff assess that this VTC virtual room on the BOP’s system is more secure than a WebEx link generated by defense counsel and will be exclusively for the defendant’s use, such that no other meeting will overlap with the defendant within the virtual room. Now that this unique VTC virtual room is ready for use, the defendant’s regularly scheduled VTCs with counsel have resumed for five hours every weekday. Even during the temporary unavailability of VTCs, however, the defendant still had regular access to counsel both over the phone and through in-person meetings at the MDC, during which the defendant and counsel may review documents together. As noted in MDC legal counsel’s August 14, 2021 email to defense counsel, (see Dkt. No. 319 at 2), such phone calls and in-person visits with counsel are available every weekday. ! During VTCs with her attorneys, the defendant is currently permitted to bring any legal ' The defense letter references certain discovery materials that the defendant has recently had difficulty accessing. Defense counsel has not informed the Government which discovery materials are the source of this issue, but the Government remains available to address any specific issues the defendant may have reviewing her discovery should the defense wish to seek assistance from the undersigned. Otherwise, the Government understands that the defendant has worked with her attorneys and MDC IT staff to address technical issues with discovery materials as needed. DOJ-OGR-00005012