DOJ-OGR-00010582.jpg

Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 47 of55 Unlike the vast majority of inmates at the MDC, the defendant has been able to receive almost immediate attention from legal counsel at the MDC, the Court, and the Government when raising issues regarding her confinement. Her lawyers have not hesitated to alert the Court to issues requiring its attention, and the Court has ensured that the defendant was able to prepare for trial and participate in her defense. In addition, the defendant has filed numerous administrative complaints with the BOP, all of which have apparently been evaluated as unfounded. For example, the Government understands from legal counsel at the MDC that the BOP has investigated the defendant’s complaints of physical abuse and concluded that they are unfounded. Legal counsel at the MDC further informed the Government that all pat-down searches of the defendant that took place pretrial were, in fact, video recorded. Taken together with the defendant’s perjury in her civil deposition, her lies to Pretrial Services, and her blatant lies about her own weight while in BOP custody, the Court can fairly reject many of the defendant’s complaints about her conditions of confinement. Simply put, the defendant lies when it suits her. It apparently suits her to spread horror stories about her experiences in jail to the press in an attempt to garner public sympathy. See, e.g., Laurence Dollimore, Exclusive: Ghislaine Maxwell Speaks from Behind Bars for the First Time in the Mail on Sunday: Heiress Tells How ‘Creepy’ Guards Have Forced Her to Stop Taking Showers, Rats Live in Her Cell, and Why She Has No Hope of a Fair Trial, DAILY MAIL, Nov. 15, 2021 (available at https://www.dailymail.co.uk/news/article-10198309/Ghislaine-Maxwell-speaks-bars-time- Mail-Sunday.html) (last visited June 20, 2022). She is trying the same tactic now with the Court. The defense’s attempts to compare the defendant’s conditions of confinement to that of a defendant under Special Administrative Measures (“SAMs”) are stunningly off-base. As the Court is well aware, before she was placed in general population, the defendant was permitted out of her 45 DOJ-OGR-00010582