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Case 1:20-cr-00330-PAE Document 350 Filed 10/15/21 Page2of3 Page 2 standard procedures for legal mail, and these protocols apply to each one of the approximately 1,700 inmates at the MDC. Legal counsel at the MDC has further explained that defense counsel’s request that the MDC be ordered to provide the defendant with all legal mail within one day of receipt by the MDC would be extremely burdensome and is not practicable in light of the various responsibilities of the MDC’s legal department, which is responsible for issues relating to the approximately 1,700 inmates at the MDC. The Government respectfully submits that there are no circumstances that merit special expedited delivery for this defendant, and that the delivery of the defendant’s mail should not receive priority over the services the legal department’s staff provides to other inmates. As noted in the defense’s letter, the Government sent a hard drive containing Court-ordered disclosures to the defendant via FedEx on October 11, 2021. The hard drive was received by the MDC on October 12, 2021. Legal counsel at the MDC informed the Government that there was an institutional emergency impacting the safety and security of the MDC on October 13, 2021, such that no inmate at the MDC received any legal mail from the warehouse that day. On the morning of October 14, 2021, legal counsel at the MDC personally delivered the hard drive to the defendant. The Government has made best efforts to obtain accurate information and respond to the Court’s Order within a short time frame. Should the Court have any questions or require any additional details regarding this topic, the Government will confer with legal counsel at the MDC and provide additional information. DOJ-OGR-00005235