DOJ-OGR-00010583.jpg

Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 48 of 55 cell into a day room for thirteen hours per day, seven days per week. In the day room, the defendant had exclusive access to a telephone, a television, a desktop computer, a laptop computer, and a shower. The defendant had access to recreation time and programming, as well as multiple hours each day to meet with her attorneys. Those conditions are a far cry from the 23-hour-per-day lockdown experienced by inmates in SAMs, and indeed, a far cry from many inmates in general population during the COVID-19 pandemic, who were often locked in their cells for significant periods of time to prevent the spread of the virus. The defendant baselessly claims that her conditions of detention “thwart[ed] her ability to participate in and prepare her defense.” (Dkt. No. 663 at 25). The Court was actively involved in ensuring that the defendant’s conditions of confinement did not interfere with the ability to review her discovery materials and confer with her counsel in order to prepare for trial. (See, e.g., Dkt. Nos. 49, 92, 116, 131, 265, 268, 282). Indeed, the Court repeatedly found that the defendant has had sufficient time to confer with defense counsel and review her discovery. (See, e.g., Dkt. Nos. 49, 106). As the Government has repeatedly informed the Court throughout the pendency of this case, Maxwell received more time to review her discovery than any other inmate at the MDC. She was permitted to review her discovery thirteen hours per day, seven days per week. During her pretrial confinement, Maxwell had access to both a desktop computer provided by the MDC and a laptop computer provided by the Government in November 2020 on which to review discovery. Also during those thirteen hours per day, the defendant had access to the MDC desktop computer to send and receive emails with her attorneys. Maxwell also had as much, if not more, time as any other MDC inmate to communicate with her attorneys. She received five hours of VTC calls with her counsel every weekday, for a total of 25 hours of attorney VTC calls per week, and she had access to in-person visits with her attorneys. 46 DOJ-OGR-00010583