court filing: Case 1:17-cr-00330-AJN Document 101002 Filed 03/13/20 Page 30 of 36

The Government is responding to the defendant's argument that they cannot prepare for trial while housed at the MDC, citing the various measures taken to facilitate their access to legal counsel and discovery materials. The defendant has access to hard drives, discs, and hard copy documents containing discovery materials, and has been provided with a laptop for their exclusive use. The Government argues that these measures demonstrate that the defendant is able to prepare for trial despite being housed at the MDC.