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    "page_number": "119",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 119 of 127 119 LB15max4 MS. MOE: No, your Honor. We have not been asking to do that mindful of their obligations towards all of the other inmates at the facility but we appreciate the steps they have taken to be responsive to our alerts and about the defense's requests. For example, in some instances I think the defense has been e-mailing legal counsel noting certain tracking numbers and asking them to check at the particular warehouse. So that process seems to be working. I don't think we can create a system where the defendant is receiving, in jail, on a 24-hour basis, all disclosures. I don't think that is practical but I think especially because, in some instances, we may be uploading to the defense through a file sharing program certain disclosures on one day and they may be meeting with the defendant in person the very next day, they certainly have the ability to talk about those materials with the defendant, to provide her with paper copies if they wish, and I think that is more than sufficient. THE COURT: Well, you are not suggesting that instead of government sending the materials to the facility and working with the facility to facilitate timely movement of the materials to Ms. Maxwell, are you? MS. MOE: Of course, your Honor. Our view is in combination of the fact that, in the short-term, the defense has the opportunity to talk to the defendant immediately about it if they wish to, and in longer SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007170",
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      "content": "MS. MOE: No, your Honor. We have not been asking to do that mindful of their obligations towards all of the other inmates at the facility but we appreciate the steps they have taken to be responsive to our alerts and about the defense's requests. For example, in some instances I think the defense has been e-mailing legal counsel noting certain tracking numbers and asking them to check at the particular warehouse. So that process seems to be working. I don't think we can create a system where the defendant is receiving, in jail, on a 24-hour basis, all disclosures. I don't think that is practical but I think especially because, in some instances, we may be uploading to the defense through a file sharing program certain disclosures on one day and they may be meeting with the defendant in person the very next day, they certainly have the ability to talk about those materials with the defendant, to provide her with paper copies if they wish, and I think that is more than sufficient.",
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    {
      "type": "printed",
      "content": "THE COURT: Well, you are not suggesting that instead of government sending the materials to the facility and working with the facility to facilitate timely movement of the materials to Ms. Maxwell, are you?",
      "position": "main content"
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    {
      "type": "printed",
      "content": "MS. MOE: Of course, your Honor. Our view is in combination of the fact that, in the short-term, the defense has the opportunity to talk to the defendant immediately about it if they wish to, and in longer",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00007170",
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  "entities": {
    "people": [
      "MS. MOE",
      "MS. MAXWELL"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "11/15/21"
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      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007170"
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}