{
  "document_metadata": {
    "page_number": "2",
    "document_number": "350",
    "date": "10/15/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 350 Filed 10/15/21 Page 2 of 3\nPage 2\nstandard procedures for legal mail, and these protocols apply to each one of the approximately\n1,700 inmates at the MDC. Legal counsel at the MDC has further explained that defense counsel's\nrequest that the MDC be ordered to provide the defendant with all legal mail within one day of\nreceipt by the MDC would be extremely burdensome and is not practicable in light of the various\nresponsibilities of the MDC's legal department, which is responsible for issues relating to the\napproximately 1,700 inmates at the MDC. The Government respectfully submits that there are no\ncircumstances that merit special expedited delivery for this defendant, and that the delivery of the\ndefendant's mail should not receive priority over the services the legal department's staff provides\nto other inmates.\nAs noted in the defense's letter, the Government sent a hard drive containing Court-ordered\ndisclosures to the defendant via FedEx on October 11, 2021. The hard drive was received by the\nMDC on October 12, 2021. Legal counsel at the MDC informed the Government that there was\nan institutional emergency impacting the safety and security of the MDC on October 13, 2021,\nsuch that no inmate at the MDC received any legal mail from the warehouse that day. On the\nmorning of October 14, 2021, legal counsel at the MDC personally delivered the hard drive to the\ndefendant.\nThe Government has made best efforts to obtain accurate information and respond to the\nCourt's Order within a short time frame. Should the Court have any questions or require any\nadditional details regarding this topic, the Government will confer with legal counsel at the MDC\nand provide additional information.\nDOJ-OGR-00005235",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 350 Filed 10/15/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "standard procedures for legal mail, and these protocols apply to each one of the approximately\n1,700 inmates at the MDC. Legal counsel at the MDC has further explained that defense counsel's\nrequest that the MDC be ordered to provide the defendant with all legal mail within one day of\nreceipt by the MDC would be extremely burdensome and is not practicable in light of the various\nresponsibilities of the MDC's legal department, which is responsible for issues relating to the\napproximately 1,700 inmates at the MDC. The Government respectfully submits that there are no\ncircumstances that merit special expedited delivery for this defendant, and that the delivery of the\ndefendant's mail should not receive priority over the services the legal department's staff provides\nto other inmates.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "As noted in the defense's letter, the Government sent a hard drive containing Court-ordered\ndisclosures to the defendant via FedEx on October 11, 2021. The hard drive was received by the\nMDC on October 12, 2021. Legal counsel at the MDC informed the Government that there was\nan institutional emergency impacting the safety and security of the MDC on October 13, 2021,\nsuch that no inmate at the MDC received any legal mail from the warehouse that day. On the\nmorning of October 14, 2021, legal counsel at the MDC personally delivered the hard drive to the\ndefendant.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government has made best efforts to obtain accurate information and respond to the\nCourt's Order within a short time frame. Should the Court have any questions or require any\nadditional details regarding this topic, the Government will confer with legal counsel at the MDC\nand provide additional information.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005235",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "defendant"
    ],
    "organizations": [
      "MDC",
      "FedEx",
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "October 11, 2021",
      "October 12, 2021",
      "October 13, 2021",
      "October 14, 2021",
      "10/15/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 350",
      "DOJ-OGR-00005235"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the delivery of legal mail to a defendant at the MDC. The text is clear and legible, with no visible redactions or damage."
}