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Case 21-58, Document 89-1, 05/17/2021, 3102450, Page? of 14 2. Government misrepresentation to this Court during oral argument when asked if shining lights in Ms. Maxwell’s face every fifteen minutes during the night was routine: “My understanding, Your Honor, is that that is a routine; it is routine by BOP officials.” But then in a letter to the district court, the government admitted that Ms. Maxwell is the only inmate who receives these targeted flashlight checks every 15 minutes. Doc. 270 (“MDC staff conduct flashlight checks every fifteen minutes [only for Ms. Maxwell] because the defendant, while not on suicide watch, is on an enhanced security schedule.”). In a response that would make Orwell’s Ministry of Truth proud, the government tries to spin this and argue that other inmates are also periodically checked throughout the night. Doc. 270 (stating — without an affidavit or other actual sworn testimony — that in general population, checks are usually done about once an hour). But try as it might, the government cannot escape the bottom line that Ms. Maxwell is the only person who is treated this way and wakened every 15 minutes while in solitary confinement. In fact, the government then tries to justify the treatment by saying — again without support or an affidavit — that even though Ms. Maxwell is not suicidal, she should DOJ-OGR- 00020331