DOJ-OGR-00000658.pdf

Case 1:19-cr-00490-RMB Document 53 Filed 09/03/19 Page 20 of 86 J8RsEPS1 1 MR. WEINBERG: Judge, if I can just supplement? 2 THE COURT: Absolutely. 3 MR. WEINBERG: Thank you, sir. 4 Thank you, as an out-of-town lawyer for the privilege 5 to appear in front of you, your Honor. 6 THE COURT: It's my pleasure. 7 MR. WEINBERG: First, as to the conditions, we think 8 your Honor trusted the government, the Bureau of Prisons, to 9 keep our client safe and keep him in civilized conditions. The 10 government will again ask, as to other defendants, that they be 11 detained at the MCC, some subset of them will end up in the SHU 12 unit. 13 It is a horrific. I've called it medieval. There's 14 vermin on the floor. There is wet from the plumbing. There is 15 no sunlight. There is limited exercise. It is simply 16 conditions that no pretrial detainee -- and I would go farther 17 as a criminal defense lawyer -- no United States defendant 18 should be subjected to. 19 Certain judges have taken views of the conditions. We 20 would urge your Honor, the government talks about and we talk 21 about transparency, to see what kind of conditions there exist 22 within 50 or 100 yards of one of the great United States 23 district courts. 24 Second, in terms, we have a profound problem with the 25 conclusions of the medical examiner. There are for three SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000658