EFTA00017026.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: 
To: 
Cc: 
Subject: RE: New mcc problems 
Date: Fri, 17 Jan 2020 16:27:31 +0000 
Bruce, 
Thanks for raising these issues with us in advance of the conference. We appreciate the o ortunit to t 
and 
address them with MCC in advance. Below are responses based on our conversation wi 
and 
we have copied all counsel because until Judge Karas instructs us otherwise, we intend to communicate with all 
counsel of record. 
1 — 
has advised us that allowing a tour of this kind is a security risk for the institution because, among 
other things, you have asked to tour areas where many inmates will be, and the institution cannot be locked down 
for purposes of an outside person taking a tour absent a very specific and pressing reason. 
also advised 
that were the Court to order such a tour, MCC would set very specific conditions and ask that the Government 
also be present. 
2 — 
has advised that she is working with SIS to get a date and time for the inspection of physical 
evidence, and hopefully will be reaching out today to schedule the inspection. 
3 — 
has advised that upon receiving your email, she had her staff speak with 
about the 
heat. The staff took heat reports in the unit and found the temperature was high. The staff made adjustments and 
there have not been complaints since. We have asked for another temperature reading to be taken in the unit 
before Wednesday's conference to ensure the temperature is at an acceptable level. 
4 — 
has advised that she asked you for additional information that she can discuss with the Warden in 
order to assess the request for a family visit, but has not heard back from you. As previously discussed, in order 
for the MCC to make an exception for your client, a social visit must be necessary for preparation of the defense. 
The Government is not trying to, nor does it want to be, in the middle of that assessment, but we understand 
from the MCC that your most recent request was conclusory and they need more detail to make a…
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