DOJ-OGR-00010585.jpg

Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page50of55 staff conduct flashlight checks every 30 minutes for inmates housed in the Special Housing Unit and conduct flashlight checks of inmates in the general population multiple times each night at irregular intervals, but at an average of at least once per hour. The defendant’s repeated claims about jail food and her weight should be rejected out of hand as a basis for a downward variance. Legal counsel for the MDC has informed the Government that when the defendant was housed outside of the general population, her meals arrived in containers that were both microwavable and oven safe, and her meals were heated in a thermal oven as of at least April 6, 2021. As the Government previously informed the Court in response to the defendant’s complaints about her weight, during her time at the MDC, the defendant’s weight has fluctuated between the 130s and the 140s. Medical records reflect that the defendant weighed 146 pounds when she was arrested, and she weighed 144.5 pounds when she was last weighed in April 2022. In short, the defendant’s claims of extreme weight loss are not true. At bottom, the defendant’s complaints about jail seem to come down to the vast gulf between the conditions of her confinement and the defendant’s lived experience up until her arrest and detention on July 2, 2020. Until July 2020, the defendant spent her entire life living in extraordinary luxury. Her childhood and adolescence were filled with wealth and privilege. That access to wealth continued into adulthood when the defendant found a benefactor in Epstein, who provided her with millions of dollars and invited her to share in his luxurious lifestyle of mansions, house staff, private chefs, and private planes. After leaving that relationship, the defendant remained exceptionally wealthy, residing in palatial estates and owning multiple homes. It is no wonder, then, that she found jail jarring. Going from being waited on hand and foot to incarceration is undoubtedly a shocking and unpleasant experience. The massive difference 48 DOJ-OGR-00010585