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Case 1:20-cr-00330-PAE Document663_ Filed 06/15/22 Page 23 of 77 out of range of the camera focused into the cell. During daytime hours she was isolated in a larger space. Atno time did she have contact with any other inmate. She was watched round-the-clock by a security detail dedicated exclusively to guard her as she was consistently monitored by video surveillance. Her security detail rotated every two weeks and consisted of high-level BOP staffers recruited from facilities outside New York who were instructed to guard a high-profile, high- security inmate on suicide watch.'* Ms. Maxwell was subject to constantly changing rules and whims. Her only source of information was from the guards who controlled her. They became the source of information regarding rules, regulations, and opportunities. If they chose not to dispense information or if they provided incorrect information, she had no basis to challenge them. She was instructed not to speak to them lest she face disciplinary sanction. Such is not the case in general population, where inmates assist other inmates and bear witness to and identify inconsistent and improper treatment. Unlike other inmates, Ms. Maxwell was subjected to various prohibitions and deprivations not common to other inmates. She was monitored 24 hours a day by stationary security cameras and by an additional hand-held camera that followed her while under the constant surveillance of several prison guards who scrutinized her every move, even when she was showering, and taking notes of her activities and recording them in various notebooks. The procedures in place deprived Ms. Maxwell of any privacy and prevented uninterrupted sleep. The constant illuminations during the night disrupted her sleep, leaving her sleep deprived and causing exhaustion that affected her ability to concentrate. Initially, she was denied adequate and restful sleep by bright lights left on in her cell for 24 hours a day coupled with a flashlight shining into her eyes or cell every 15 minutes '* The cost of her individualized detention should be of great concern to the taxpaying public and warrants an investigation into the propriety of this enormous expenditure for a single non-violent inmate. 22 DOJ-OGR-00010469