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Case 1:20-cr-00330-PAE Document663_ Filed 06/15/22 Page 36 of 77 supermax detention - involved imprisonment within imprisonment. It was so different from conventional conditions of pretrial detention as to constitute a different form of hardship and tantamount to a different form of punishment. Typically, a defendant receives time-served credit for each day incarcerated prior to sentencing. Pretrial detainees have received and continue to receive credit beyond time served for detention during COVID. See, e.g., Gonzalez; Brissett, supra. Ms. Maxwell should receive a hardship credit in addition to a COVID credit due to the restrictive and harsh conditions of her pretrial detention. CONCLUSION Ghislaine Maxwell is not an heiress, villain, or vapid socialite. She has worked hard her entire life. She has energy, drive, commitment, a strong work ethic, and desire to do good in the world. She has supported friends and family through tough times and personal crisis and currently is assisting women in her unit at the MDC. She has endeavored to contribute to society (e.g., by becoming an EMT, developing a platform so that people in remote areas could receive quality medical assistance, helping launch the Clinton Global Initiative, creating TerraMar, providing GED tutoring for inmates in her unit) and will continue to do so throughout her sentence and when she rejoins the community beyond prison walls. She has also tried to protect the people around her (Ted Waitt’s children, her stepchildren, the people at TerraMar) from the onslaught of press and public vilification that come with having been associated with her. She had a difficult, traumatic childhood with an overbearing, narcissistic, and demanding father. It made her vulnerable to Epstein, whom she met right after her father’s death. It is the biggest mistake she made in her life and one that she has not and never will repeat. She has never been accused of anything untoward in the over-15-year period since her relationship with Epstein 35 DOJ-OGR-00010482