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Case 1:20-cr-00330-AJN Document 74 Filed 11/23/20 Page 2 of 2

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seven days per week. Accordingly, the defendant is receiving the same amount of time to review
her discovery and the same amount of time to speak with her lawyers as she received before
entering quarantine. The defendant will not, however, be permitted to meet in person with her
lawyers until she tests out of quarantine.

After the defendant tests out of quarantine, she will resume the same schedule that the
MDC implemented approximately three months ago. Specifically, from 7am to 8pm every day,
the defendant will be permitted out of her isolation cell. During those thirteen hours, the defendant
will have access to a computer on which to review her discovery outside of her cell. Also during
the day, the defendant will be permitted to, among other things, make legal calls, make personal
calls, access CorrLinks, and shower. From 8pm to 7am, the defendant will remain in her isolation
cell. The defendant will also be permitted to have in-person visits with her attorneys up to three
days per week for multiple hours per visit. On days when the defendant does not have in-person
legal visits, she will have access to legal calls for up to three hours per day.

As was the case three months ago, the defendant continues to have more time to review her
discovery than any other inmate at the MDC, even while in quarantine. The defendant also has as
much, if not more, time as any other MDC inmate to communicate with her attorneys, even while
in quarantine.

As noted above, over the past three months, the Government has repeatedly communicated
both with MDC legal counsel and defense counsel regarding the defendant’s conditions of
confinement. Whenever the defense has raised a concern on this topic, the Government has
immediately contacted MDC legal counsel to inquire about and, where appropriate, to address the
concern. The Government will continue to keep those lines of communication open and will
remain responsive to any concerns raised by the defense regarding the defendant’s conditions of
confinement. Should the Court have any questions or require any additional details regarding this
topic, the Government will promptly provide additional information.

Respectfully submitted,

AUDREY STRAUSS
Acting United States Attorney

By: _______________________
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324

Cc: All Counsel of Record (By ECF)

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