A prosecutor said Boston Marathon bomber Dzhokhar Tsarnaev wrote defiant notes while he lay injured in a hospital bed after his capture.
The revelation by Assistant U.S. Attorney William Weinreb came Wednesday during a sidebar discussion with Judge George O'Toole Jr. and Tsarnaev's lawyers. The group was discussing the testimony of an assistant U.S. marshal who was asked by Tsarnaev's lawyers about his conduct after his arrest.
Defense attorney Miriam Conrad said she wanted to show that Tsarnaev, in his interactions with the marshal, "was never defiant, hostile or uncooperative." Weinreb protested, saying Tsarnaev wrote "one defiant note after another" in his hospital bed.
Tsarnaev had been shot in the face and had a jaw injury that left him unable to speak.
Weinreb didn't reveal the contents of Tsarnaev's notes.
Earlier, a prosecutor grilled a prison consultant testifying for the defense to try to rebut his description of the strict conditions Tsarnaev might face behind bars.
Mark Bezy acknowledged Thursday on cross-examination that special communication restrictions can be eased over time. He says inmates in a special unit of the Supermax federal prison in Florence, Colorado, can have five visits each month and can write and receive an unlimited number of letters from people on an approved list.
Bezy had said Wednesday that Tsarnaev's communications would be severely restricted under a procedure known as Special Administrative Measures.
A jury will soon decide whether Tsarnaev will be sent to prison for the rest of his life or face execution. A recent poll showed a majority of Bostonians are against Tsarnaev paying with his life.
On Wednesday, Tsarnaev's former brother-in-law testified that Tsarnaev was close to his brother and followed his older sibling's lead.