{
  "document_metadata": {
    "page_number": "5",
    "document_number": "41",
    "date": "August 13, 2020",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 5 of 5\n\nHonorable Alison J. Nathan\nAugust 13, 2020\nPage 5\ncontinue to evaluate where the defendant should be housed within the facility and that the defendant will be placed into the general population if and when BOP is assured that such placement would not pose a threat to the orderly operation of the institution. The defendant identifies no basis for the Court to disturb that determination by the BOP, particularly given that, as detailed below, her housing assignment will not negatively affect her ability to review discovery in this case.\n\nRegarding the defendant's request in connection with access to discovery, the Government understands from BOP that the defendant had not even yet received her copy of the Government's first discovery production at the time the Defense Letter was filed—she received the materials on Tuesday, August 11. While it is correct that BOP's initial plan was to provide three hours per day of access to the discovery—the same access that is granted to every other pretrial inmate, including those with trial dates scheduled for far earlier than July 2021—as of earlier this week, and given the volume of expected discovery, BOP informed the defendant that she will have the opportunity to access to her discovery from 7:00 a.m. to 8:00 p.m. every day of the week. Although this arrangement will be subject to continued evaluation on an ongoing and individualized basis, and is subject to ordinary considerations of prison operations, BOP intends to provide that access on an ongoing basis to the extent it remains reasonably practicable to do so. Accordingly, this application should be denied as moot.\n\nC. Conclusion\n\nFor the reasons set forth above, the defendants' requests, as set forth in the Defense Letter, should be denied.\n\nRespectfully submitted,\n\nAUDREY STRAUSS\nActing United States Attorney\nBy: _______________________\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2415\n\nCc: All counsel of record, via ECF\n\nDOJ-OGR-00001723",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 5 of 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nAugust 13, 2020\nPage 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "continue to evaluate where the defendant should be housed within the facility and that the defendant will be placed into the general population if and when BOP is assured that such placement would not pose a threat to the orderly operation of the institution. The defendant identifies no basis for the Court to disturb that determination by the BOP, particularly given that, as detailed below, her housing assignment will not negatively affect her ability to review discovery in this case.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Regarding the defendant's request in connection with access to discovery, the Government understands from BOP that the defendant had not even yet received her copy of the Government's first discovery production at the time the Defense Letter was filed—she received the materials on Tuesday, August 11. While it is correct that BOP's initial plan was to provide three hours per day of access to the discovery—the same access that is granted to every other pretrial inmate, including those with trial dates scheduled for far earlier than July 2021—as of earlier this week, and given the volume of expected discovery, BOP informed the defendant that she will have the opportunity to access to her discovery from 7:00 a.m. to 8:00 p.m. every day of the week. Although this arrangement will be subject to continued evaluation on an ongoing and individualized basis, and is subject to ordinary considerations of prison operations, BOP intends to provide that access on an ongoing basis to the extent it remains reasonably practicable to do so. Accordingly, this application should be denied as moot.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "C. Conclusion",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For the reasons set forth above, the defendants' requests, as set forth in the Defense Letter, should be denied.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "AUDREY STRAUSS\nActing United States Attorney",
      "position": "body"
    },
    {
      "type": "signature",
      "content": "By: _______________________",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Alex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2415",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Cc: All counsel of record, via ECF",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001723",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Audrey Strauss",
      "Alex Rossmiller",
      "Alison Moe",
      "Maurene Comey"
    ],
    "organizations": [
      "BOP",
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "August 13, 2020",
      "August 11",
      "July 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 41",
      "DOJ-OGR-00001723"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
}