DOJ-OGR-00010472.jpg

Case 1:20-cr-00330-PAE Document663_ Filed 06/15/22 Page 26 of 77 effluvium (hair loss due to stress and poor nutrition). Complaints made during trial regarding her inadequate daily nutrition were received as a nuisance rather than cause for concern and attention. An extra blanket provided because of the cold temperature in her cell was removed on the claim it had not been approved by the warden, only to be returned when guards observed Ms. Maxwell shaking while asleep and became concerned that she might be having a seizure. She was given limited time to exercise in an area without sunlight or fresh air, then constructively denied the ability to exercise because she was not provided proper-fitting footwear. The treatment imposed on Ms. Maxwell was unnecessarily and intentionally degrading and threatening. While in isolation, a high-ranking prison guard told Ms. Maxwell that there was concern that she would be shot by sniper. Putting aside the reason and propriety of dispensing this alarming information, the diminution of security concerns resulting in her transfer to general population appears correlated to Ms. Maxwell having been sufficiently safeguarded to fill Epstein’s empty seat — satisfying the concerns of the government, DOJ, BOP, MDC, prosecutors, Court, and accusers. Deprived of sleep and adequate nutrition and subjected to such undignified and dehumanizing conditions of detention, Ms. Maxwell was considerably weakened psychologically and had great difficulty concentrating, thwarting her ability to participate in and prepare her defense. The impact of the pandemic coupled with the restrictive conditions of her confinement made preparation for trial involving multi-million pages of documents especially difficult. Despite being given a laptop, she encountered persistent technical issues reviewing electronic discovery, at times unreadable on both the laptop and prison PC, and could not search, highlight, annotate, save, or print. Further, delivery of her mail (legal and non-legal) was significantly delayed as were receipt of CorrLinks emails, which were prematurely deleted by the MDC. 25 DOJ-OGR-00010472