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Case 1:20-cr-00330-AJN Document 197 Filed 04/07/21 Page 2 of5 LAW OFFICES OF BOBBI C. STERNHEIA\ regularly, I challenge the government to identify anyone that would risk their health by drinking the tap water. Even the guards resort to drinking bottled water. Blaming Ms. Maxwell for the filth of her severely restricted environment is utterly misplaced. To suggest she willingly lives in squalor is absurd. In an effort to wield power, the guards use cleaning as a punishment. The MDC - especially the East Building where Ms. Maxwell is held— is permeated with mold and vermin. Cockroaches and rodents are plentiful and glue tracks have been placed in Ms. Maxwell’s day area to help remediate the problem. While HEPA filters may improve the safety of the legal visiting rooms — characterized by an HVAC inspector as ‘“‘a death trap” — in-person visiting with Ms. Maxwell is uncomfortable and unproductive. Relegated to a small “fishbowl” where chairs abut glass walls and a table, with no room in between, Ms. Maxwell and counsel are forced to wedge their bodies into chairs. There is no opportunity to view electronic discovery or exchange documents; and speaking while wearing a face mask while crammed on either side of a plexiglass divider under surveillance of three guards and a handheld camera places a chill on any free exchange of confidential information. While video conferencing has facilitated on-going communication between Ms. Maxwell and counsel, her request for a legal call to confer with counsel regarding pretrial motions was denied. Ms. Maxwell’s health is deteriorating. She has not experienced sunshine and fresh air for the past eight months. Referring to an interior gated pen where Ms. Maxwell can exercise (and be subjected to even more searches) as the “outside” is a misnomer. Barely a breeze permeates that area. Medical staff monitor Ms. Maxwell’s health by recording her weight in her medical chart. Guards declined Ms. Maxwell’s request to know her weight, claiming they cannot look it DOJ-OGR- 00002908