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Case 21-770, Document 70-1, 05/17/2021, 3102450, Paged of 14 going through her attorney-client materials; and (6) can’t search, print, highlight, or sort the discovery because the “computer” she was given was stripped down and does not have the proper software or hardware capabilities. The truth is that Ms. Maxwell is not being treated in a humane fashion and cannot prepare for trial under these horrific conditions. She has been in solitary confinement with no sleep for almost a year. The presumption of innocence has been turned on its head. This Court should either order her temporary release under 18 U.S.C. 3142) or remand this matter and order the trial court to conduct an evidentiary hearing on the conditions of her confinement. It is important to underscore that the government has made a number of representations to the trial court and to this Court about the conditions of Ms. Maxwell’s detention that have proven to be false. 1. Government misrepresentation to the district court: “The defendant wears an eye mask when she sleeps, limiting the disturbance caused by the flashlight [every fifteen minutes].” Doc. 196 (April 6, 2021, gov't letter to district court). But the truth is that she has no “eye mask” and the government has now admitted that eye masks are “contraband” in the jail and that she cannot have one. Doc. 270 (May 5, 2021, gov’t DOJ-OGR-00001411