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Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 4 of 20 keys while on duty. Within the SHU, inmates are assigned to Six separate tiers, each of which can be accessed only via a single locked door to which the correctional officers assigned to the SHU have keys while on duty. Each tier has eight celis, each of which can house either one or two prisoners, and each individual cell — which is made of cement and metal - is accessed only through a single locked door, to which only correctional officers assigned to the SHU have keys while on duty. 7. The BOP requires correctional officers assigned to guard inmates at the MCC to conduct institution-wide counts of inmates at regular, scheduled intervals to ensure that each inmate is alive and accounted for within the MCC (the “institutional count”). On weekdays, the MCC conducts five institutional counts at 4 p.m., 10 p.m., 12 a.m., 3 a.m., and 5S a.m. Performing an institutional count is one of the most basic and essential aspects of a correctional officer’s job, and the count is one of the most basic and essential functions of daily operation of the MCC. Two officers are required to perform the institutional count for each housing unit, including the SHU, and are further required to document their performance of the count on an official MCC form called a count slip. To perform the institutional count in the SHU, two officers must walk from tier to tier to observe and count each individual inmate. DOJ-OGR-00021911