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Case 1:20-cr-00330-PAE Document 663 _ Filed 06/15/22 Page 37 of 77 ended. In fact, she has been involved in two committed, long-term, loving relationships with men who had young children. She is not a danger to the community and there is no concern about recidivism. In imposing an appropriate sentence, we urge the Court to credit a number of factors: =» Ms. Maxwell is being sentenced for non-violent offenses which occurred decades ago (1994 to 2004). = Ms. Maxwell is over 60 years old. = Ms. Maxwell is not a danger to the community in any way. = Ms. Maxwell has no prior criminal history or prior bad acts. = Ms. Maxwell has served the entirely of pre-sentence detention during the COVID pandemic. = Ms. Maxwell served 22 months of pre-sentence detention under extraordinarily abnormal and restrictive conditions of solitary confinement as a non-violent defendant who posed no danger to herself or others. =" Ms. Maxwell is being sentenced solely for reasons of punishment. = Ms. Maxwell is not being sentenced for rehabilitation. = Ms. Maxwell poses no risk of recidivism. In addition, Ms. Maxwell’s personal characteristics and history of lawful behavior pre- and and post-dating the offense conduct further distinguishes her situation and warrants sentencing consideration. Probation recognizes that a downward variance is warranted in this case. However, noticeably absent from Probation’s justification is any mention of detention served during the pandemic and under harsh conditions of solitary confinement. A poll taken of the CJA Panel and Federal Defenders of the Southern and Eastern Districts of New York has resulted in no cases where Probation has referenced conditions of confinement or COVID, despite requests by defense 36 DOJ-OGR-00010483