DOJ-OGR-00006034.jpg

Case 1:20-cr-00330-PAE Document 403 Filed 11/02/21 Page3of4 Page 3 (Monday, October 11 was a federal holiday); the package scheduled for delivery on October 14, 2021 was delivered to the defendant on October 15, 2021; the package scheduled for delivery on Saturday, October 16, 2021 was delivered to the defendant on Monday, October 18, 2021; and the package scheduled for delivery on October 28, 2021 was delivered on October 29, 2021. Legal counsel at the MDC has explained to the Government that defense counsel’s request that the MDC be directed to retrieve the mail within one business day of receipt by the post office is burdensome and is not practicable in light of the procedures outlined above, which apply to the 1,700 inmates at the MDC. The MDC mail staff will continue to follow its standard procedures and retrieve mail from the post office every moming of the business week. As to the issues raised at the November 1, 2021 conference regarding the transportation of the defendant to the Southern District of New York courthouse for proceedings in this matter, according to legal counsel at the MDC, the procedures are similar to those used for other inmates, but the timing varies slightly. To the extent the Court requires specific details on the timing of transportation of the defendant as compared to other inmates, legal counsel at the MDC has expressed security concerns about putting such details in a publicly filed letter. To extent the Court needs that information, the Government would request permission to confer further with legal counsel at the MDC and authorization from the Court to provide such information under seal. The Government understands from the United States Marshals Service that the clothing and lunches provided to the defendant are provided by the Bureau of Prisons, and that the lunch does not usually require the use of utensils. This is the same for all defendants. 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- 00006034