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Case 1:20-cr-00330-AJN Document 159 Filed 02/16/21 Page 3 of 3 LAW OFFICES OF BOBBI C. STERNHEIA\ It is impossible to overstate the deleterious effect of the conditions under which Ms. Maxwell is detained. Upon arrival at the MDC seven months ago, she was placed on suicide watch though no competent medical professional deemed her in any manner suicidal, nor has any psychologist or medical staffer ever found her to be suicidal at any time during her detention. For weeks she was deprived of legal material, the ability to use a telephone to make personal calls, and the opportunity to exercise and shower. Clearly, this was an effort to avoid a recurrence of the BOP’s negligence regarding Jeffrey Epstein’s death. Contrary to the way she is hyper-monitored, Ms. Maxwell is classified with the standard CC1-Mh designation: inmate with no significant mental health care. The overall conditions of detention have had a detrimental impact on Ms. Maxwell’s health and overall well-being; and she is withering to a shell of her former self — losing weight, losing hair, and losing her ability to concentrate. In addition to the many difficulties impacting her review of electronic discovery materials, the over-management and stress are impacting her stamina and effectiveness in preparing her defense and conferring with counsel. Having been incarcerated in de facto solitary confinement for 225 days and monitored by two to six guards 24 hours a day with a handheld camera dedicated to capturing her every move, except when it would record improper conduct on the part of the guards, it is not surprising that Ms. Maxwell feels she is detained under the control of the Bureau of “Pretrial Punishment.’ Very truly yours, BOBBI C. STERNHEIM cc: All counsel DOJ-OGR- 00002731