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Case 21-770, Document 70-1, 05/17/2021, 3102450, Page4 of 14 of sleep would alleviate her stress instead of exacerbate it. Ms. Maxwell replied. Ex. E, Doc. 272. The district court then issued an order saying that it would not tell the Bureau of Prisons what to do but “admonishe[d] the MDC and the Government to continue to ensure that Maxwell is subjected to only those security protocols that BOP determines are necessary for her safety and security, based upon neutral and applicable factors, and consistent with the treatment of similarly situated pre-trial detainees.” Ex. B, Doc. 282. But Ms. Maxwell is not being treated like any other detainee. And the horrific conditions make it impossible to prepare for trial. Accordingly, we renew our motion for bond and seek relief from this Court. Ms. Maxwell simply wants a fair opportunity to fight the charges against her at trial. Currently, she (1) can’t sleep because the guards wake her every 15 minutes; (2) oftentimes can’t drink the water because it is brown and contains particles; (3) can’t meet in person with her lawyers because the guards use a handheld camera to video and audio tape record the meetings; (4) can’t manage the smell of overflowing sewage that comes up from the drain in her unit; (5) can’t keep the guards from seizing and DOJ-OGR-00001410