DOJ-OGR-00004759.pdf

--- Page 1 --- **Document Header** * Case 1:20-cr-00330-PAE * Document 300 * Filed 06/15/21 * Page 16 of 32 **Case Number and Document Information** * Case Number: 1:20-cr-00330-PAE * Document Number: 300 * Filing Date: 06/15/21 * Page Number: 16 of 32 **Transcribed Text** 1. point home, Ms. Days -- although she's never had a single 2. ticket since she's been locked up in MCC or MDC, and I would be 3. remiss if I didn't say that's been difficult and challenging 4. because the inmates, the officers, everyone is frustrated and 5. their frustrations breeds hostility and breeds, you know, people just coming at each other. 6. She has resisted any of that and has not had any 7. tickets. In fact, she's tried to help people instead of get 8. tickets, but nonetheless, she spent 75 days in the SHU. Now, the SHU is normally reserved for persons who get tickets. It's a disciplinary action. And I think society, we know that, is now moving away from the isolation because we know that it causes significant mental hardship. It's debilitating. It causes future mental hardship once you get released from the SHU. 9. Ms. Days has spent 75 days in the SHU. That is absolutely, positively incredible, in my opinion, because I've not had a client do that who has not had a ticket. So because of that, because of the other reasons I've articulated, I firmly believe that Ms. Days has been specifically deterred. I don't like to talk about general deterrence because I don't think that works. I think it's -- well, that's my own issues, but I do think she's been specifically deterred. I think that she has been really punished. I think the five years will be significantly more than time she's spent before. **Footer Information** * Southern District Reporters, P.C. * (212) 805-0300 * DOJ-OGR-00004759