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fe NO Ww ws Oo OY ~] oO Ke) a oO a fe No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:19-cr-00490-RMB Document 53 J8RSEPSL MR. WEINBERG: Judge, if THE COURT: Absolutely. MR. WEINBERG: sir. Thank you, as an out-of-town lawye Thank you, to appear in front of you, your Honor. THE COURT: It's my pleasure. MR. WEINBERG: as to the co First, th the your Honor trusted Bure government, keep our client safe and keep him in civil government will again ask, as to other defe detained at the MCC, some subset of unit. ion I've called it It is a horrif the There is wet from the vermin on floor. no sunlight. There is limited exercis Filed 09/03/19 vr for the p nations, Priso au of ized conditions. ndants, tha them will end up in medieval. plumbing. It is simply conditions that no pretrial detainee -- and I as a criminal defense lawyer -- no United §S should be subjected to. taken views of Certain judges hav would urge your Honor, the government about transparency, to see what kind of con would go Page 20 of 86 20 can just supplement? rivilege we think ns, to The t they be the SHU There's There is farther tates defendant the condit ditions within 50 or 100 yards of one of the great district courts. Second, in terms, ions. We talks about and we talk there exist United States we have a profound problem with the conclusions of the medical examiner. There are for three SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000658