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Case 1:20-cr-00330-PAE Document 403 Filed 11/02/21 Page2of4 Page 2 office at 12 p.m. on Monday, but the mail room staff already picked up the mail for the day, the mail would not be retrieved by MDC mail room staff until Tuesday, at which point mail room staff would log the mail so it could then be delivered to the inmate by the unit manager. In connection with the questions raised at the November 1, 2021 conference about the delivery of materials sent by the Government to the defendant, the Government notes the following: The Government sent materials to the defendant on disks on October 27 and October 29, 2021. The Government sent those materials by disk directly to the defendant via certified mail in accordance with BOP policy. According to the USPS website, those disks were delivered on November 1 and November 2. Legal counsel at the MDC is following up on the status of the delivery of those disks. In any event, the Government also sent those materials via FedEx to legal counsel at the MDC on a hard drive on October 29, 2021, the same day the defense provided the drive to the Government.'! That same day, the Government informed legal counsel at the MDC that it had sent the hard drive.* According to the FedEx website, the Government understands that the hard drive was received by the MDC on November 1, 2021. Legal counsel at the MDC has informed the Government that it will hand deliver that hard drive to the defendant today. Legal counsel at the MDC informed the Government that it was not involved in the delivery of the legal mail sent to the defendant by her counsel as set forth in Exhibit A of the defendant’s October 29, 2021 letter. Legal counsel at the MDC looked into the tracking numbers provided by defense counsel in Exhibit A. According to legal counsel at the MDC, the package scheduled for delivery on Saturday, October 9, 2021 was delivered to the defendant on October 12, 2021 ' The Government has asked defense counsel to provide it with hard drives so it can produce additional materials on hard drives via FedEx rather than on disks via certified mail. ? According to legal counsel at the MDC, MDC staff picks up mail for delivery to inmates Monday through Friday. DOJ-OGR-00006033