{"id":"court_sdny_83_0","court":"SDNY","case_no":"23-cr-00118","doc_number":83,"sub_number":0,"doc_type":"ORDER","filed_date":"2023-06-05","title":"![](_page_0_Picture_1.jpeg) 147 WEST 25TH STREET, 12TH FLOOR","summary_zh":null,"summary_en":null,"body_en":"Priya Chaudhry\n        priya@chaudhrylaw.com\n212.785.5551\n\nJune 12, 2023\n\nVia ECF\n\nHon. Analisa Torres\nUnited States District Judge\nSouthern District of New York\n500 Pearl Street\nNew York, NY 10007\n\nRe:\nUnited States v. Yanping Wang, S1 1:23-cr-00118-AT\nRequest for Court Order for Access to a Government-Provided, Internet-\nDisabled Laptop Computer\n\nDear Hon. Judge Torres:\n\nAlong with Lipman Law PLLC, we represent Defendant Yanping Wang in the above-\nreferenced matter.  On June 6, 2023, the Court granted the request of Mr. Ho Wan Kwok, one of\nthe co-defendants, for access to a government-provided, internet-disabled laptop computer while\ndetained at the Metropolitan Detention Center (“MDC”) in Brooklyn to review the voluminous\nand complex discovery in this case.  (ECF No. 81).  During the June 6, 2023, status conference,\nYour Honor orally indicated that the grant of Mr. Kwok’s request applies to Ms. Wang as well.\nWith this letter, we respectfully request the Court to formalize its grant of laptop access for\nMs. Wang, ensuring that she has the necessary tools to participate in her defense effectively.\n\nAs explained in Mr. Kwok’s letter-motion to the Court, dated June 5, 2023, (ECF\nNo. 80), the MDC Legal Department maintains that limited access to a public desktop computer\nis sufficient for reviewing the discovery in this case.  This position is not justifiable because the\npublic computer is only available at certain times of the day, must be shared with Ms. Wang’s\nentire housing unit, and provides no privacy for reviewing confidential material.\n\nIn this case, the discovery is extensive, comprising at least six terabytes of data.  It\nincludes various document types such as PDFs, Excel files, emails, and videos.  In addition,\nMs. Wang requires the documents in English to be translated into Mandarin to comprehend and\nreview them thoroughly.  Given the size and complexity of the data, it is unreasonable to expect\nMs. Wang to review this discovery on a shared public desktop computer that has limited\navailability, lacks privacy, and does not meet her extensive computer access needs.  The public\ndesktop computer is available on weekdays from 7:00 a.m. to 7:00 p.m. and during modified\nhours on weekends, which is insufficient for adequate review of the voluminous discovery.\n\n---\n\nHon. Analisa Torres\nJune 12, 2023\n\nPriya Chaudhry\n        priya@chaudhrylaw.com\n212.785.5551\n\nFurthermore, the discovery is subject to a protective order issued by Your Honor on May\n4, 2023.  (ECF No. 63).  The protective order prohibits the disclosure of confidential discovery\nmaterial to individuals other than Ms. Wang, her counsel, and those retained by her counsel for\ndefense preparation.  Providing Ms. Wang access to a public desktop computer compromises the\nrequired privacy for reviewing confidential materials, as her screen and sensitive information\nwould be visible to everyone in the room.\n\nThe MDC has a policy of allowing access to a laptop only one month before trial in cases\ninvolving a large volume of 3500 material.  However, this policy fails to address Ms. Wang’s\nimmediate need for a timely and proper review of the voluminous and complex material in this\ncase.  Requesting an internet-disabled laptop is a reasonable accommodation, and we are willing\nto collaborate with the government and the MDC to ensure that any laptop provided meets the\nrequired specifications.\n\nIn conclusion, we respectfully request the Court to grant Ms. Wang’s request for access\nto a government-provided, internet-disabled laptop computer while detained at the MDC to\nreview the voluminous and complex discovery in this case.  As demonstrated above, Ms. Wang’s\nneed for laptop access is also critical for her to be able to assist in her defense, and she is in a\nsimilar position to Mr. Kwok.  For these reasons, during the June 6, 2023, status conference,\nYour Honor orally indicated that the grant of Mr. Kwok’s request applies to Ms. Wang as well.\nTherefore, we respectfully ask the Court to formalize its grant of laptop access for Ms. Wang,\nensuring that she has the necessary tools to participate in her defense effectively.\n\nRespectfully submitted,\n\n/s/\n\nPriya Chaudhry\n\nCc:\nAUSA Juliana N. Murray\nAUSA Micah Fergenson\nAUSA Ryan Finkel\nSO ORDERED.\n\n_________________________________\nHON. ANALISA TORRES, U.S.D.J.","body_zh":null,"key_entities":["Kwok","Torres","Yanping Wang","Analisa Torres","CIPA","Ho Wan Kwok","Je","Fergenson","Murray","Finkel"],"ecf_references":[{"doc_number":63,"court":"SDNY"},{"doc_number":80,"court":"SDNY"},{"doc_number":81,"court":"SDNY"}],"word_count":677,"status":"published","published_at":"2023-06-05 00:00:00","created_at":"2023-06-05","updated_at":"2026-07-06 20:57:23"}