DOJ-OGR-00019988.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page129 of 200 66 1 MR. COHEN: I'm sorry. If the court desires to leave 2 the proceeding open for a week and allow us to come back, if 3 the court has concerns about the number of suretors, for 4 example, verification information, information about financial 5 issues, we think that, now that we have some ability to breathe 6 a little bit, that we should be able to pull this together for 7 the court's consideration. We came forward with the best 8 package we could put together on a limited notice with a client 9 who was arrested, held in custody, has been since she came to 10 the MDC held in, I will call it, the equivalent of the layman's 11 term of solitary confinement. There is probably a BOP word, 12 like administrative seg., or some other word they have for it 13 now. 14 We have had a client who has been kept alone in a room 15 with the lights on all the time, is not allowed to speak with 16 us in the jail at all, wasn't allowed to shower for 72 hours, 17 had her legal materials taken away from her, only recently 18 given back. So working with that, we have been trying to 19 answer questions about financial situation and others, but it 20 is very difficult, your Honor, under circumstances that are of 21 the government's creation, of the government's creation, and 22 we -- 23 THE COURT: So I do want to understand that point. I 24 think that's the "by design" point that you are making. Just 25 for clarity, I understand that there was consent to detention SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019988