DOJ-OGR-00020302.jpg

Case 21-58, Document 76, 04/19/2021, 3080288, Page12 of 30 Gov tEx. (April 6, 2021 letter, n.2). But as Ms. Maxwell explained, the Government’s narrative is total fiction — the unsanitary conditions are caused by other inmates and guards, not Ms. Maxwell. 9. The Government also makes much of Ms. Maxwell’s vaccination. Again this demonstrates a gross double standard. Imagine if the defense had publicly filed medical information about the accusers. There would be hell to pay. The Government insists on secrecy and redactions when discussing their witnesses, and will not even reveal their names. Yet it freely discloses private information in violation of HIPAA about Ms. Maxwell in public filings. In any event, whether Ms. Maxwell is vaccinated or not does not help her search documents on an ancient computer or give her access to a printer or allow her to meet with her lawyers (who would still need to come into the jail and interact with numerous other prisoners and guards who have not been vaccinated). Ms. Maxwell’s bail motion is not based on her risk of contracting COVID. Her vaccination status is irrelevant. DOJ-OGR- 00020302