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Case 21-770, Document 73, 05/27/2021, 3109708, Page10 of 24 flashlight surveillance.” (Mot. Ex.C at2). That same day, Judge Nathan directed the Government to confer with MDC legal counsel and provide the District Court with an explanation of what flashlight surveillance the MDC conducts on Maxwell at night, the basis for such surveillance, and the availability of an appropriate eye covering for Maxwell’s use at night. (Dkt. 257). 19. On May 5, 2021, the Government submitted a letter to Judge Nathan conveying MDC legal counsel’s answers to the District Court’s questions. (Mot. Ex. D). First, the Government confirmed that all inmates at the MDC are subject to some form of flashlight checks throughout the night for their safety and security. In particular, MDC staff point a flashlight at the ceiling of each cell in order to illuminate the cell enough to confirm that each inmate “is present in the cell, breathing, and not in distress.” (/d. at 1). MDC staff conduct such checks every 30 minutes in the Special Housing Unit (“SHU”), and approximately once per hour for inmates housed in general population. (/d.). Because Maxwell is on an enhanced security schedule, MDC staff conduct these nighttime checks on her every 15 minutes. (/d.). Second, the Government conveyed that the MDC has determined that, although Maxwell is not on suicide watch, increased frequency of nighttime monitoring is warranted in her case due to several factors that “raise heightened safety and security concerns,” including the charges she faces, the 10 DOJ-OGR-00001450