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Case 1:20-cr-00330-AJN Document 91 Filed 12/07/20 Page 9 of 10 LAW OFFICES OF BOBBI C. STERNHEIA\ Deprivation of Communication with Family and Friends: The impact of Ms. Maxwell’s solitary confinement is aggravated by the deprivation of communication with friends and family. She was limited in the number of familial and social calls to a degree far less than any other detainee of which we are aware; and far less than even those who have been convicted of crimes and held in the same facility. Compromised Communication with Legal Counsel: As a consequence of COVID-19, restrictions have been placed on exercise of attorney-client relationship for all inmates but seemingly more so for Ms. Maxwell. Scheduled calls have been mishandled by the institution, resulting in missed legal calls. Despite numerous requests, only one video conference has been scheduled for Ms. Maxwell during the entirety of her detention. Recently, legal calls have been repeatedly denied even when confirmed by the Federal Defenders. All of Ms. Maxwell’s CorrLinks emails — all legal correspondence between Ms. Maxwell and counsel - have been deleted, well before the 180-day period in which they may be purged. During in-person legal conferences, Ms. Maxwell has not been permitted to physically handle and review legal documents provided by counsel. Rather, counsel must hold each page against the plastic partition requiring Ms. Maxwell to read these documents, at times from a distance of approximately four feet through a cloudy plastic shield. This method of discovery review in a case involving hundreds of thousands of documents consumes the majority of a time-limited legal conference. It is painstakingly slow and, often, impossible. Additionally, Ms. Maxwell is denied water or food and the use of toilet facilities during legal visits. She has been told that if she uses the toilet, the conference will be suspended while she is searched, returned to her unit, and then brought back to the visiting room. This process is time-consuming and limits the duration of the legal conference. In advance of each meeting, officers review her legal materials, slowly and deliberately, and appear to be reading content and breaching confidentiality of privileged information rather than conducting a routine security check. In addition to experiencing difficulty reviewing electronic discovery because files do not open, the officer delivering a hard drive last week appeared to intentionally let it fall to the ground, damaging to the device. While meeting with counsel, guards set up a tripod with a camera focused on Ms. Maxwell during the entirety of the legal conference. When counsel inquired why the conference was being recorded, the officer claimed the camera was not recording. When counsel inquired why the camera was being focused on the legal conference, the officer responded that Ms. Maxwell must be watched at all times. Conclusion These arbitrary and onerous restrictions imposed on Ms. Maxwell are contrary to prison rules and protocols, are not imposed on other inmates, and are utterly disproportionate to her detention. At no time has Ms. Maxwell been deemed a threat to herself or others or posed any disciplinary issues. Ironically, she has achieved two of the highest certifications offered at the MDC: suicide counselor and teacher/instructor. DOJ-OGR-00001874