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Case 21-770, Document 57, 04/19/2021, 3080288, Page10 of 30 paradise,’ not one of the most notorious prisons in America. A “day room.” Two computers. Recreation. Eye masks. But the Government’s description of Ms. Maxwell’s conditions is not true. For example, she has no eye mask. The guards flash lights in her cell every 15 minutes for no reason so she tries as best as she can to shield her eyes with a towel that is not secured and not effective against the unwelcome beams. Even the Government does not dispute that Ms. Maxwell is in de facto solitary confinement. It does not dispute that she has no surface to write on in her isolation cell. It does not dispute that there is often cloudy, obviously unsanitary, water in the jail. It does not dispute that she is being forced to prepare for this trial with a computer that cannot do research and cannot search documents. Attached as Exhibit P, is a response to the latest Government letter, which outlines her actual conditions. It is inconceivable that the government lawyers or its witnesses could prepare for trial under these conditions. It is painfully apparent that the two sides are far apart on how Ms. Maxwell is being treated. The Government’s letters, however, are based on multiple layers of hearsay — prison guards to the prison lawyer to the prosecutor, which get summarized in an unsworn letter to the court. No DOJ-OGR-00001382