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Case 1:20-cr-00330-AJN Document 197 Filed 04/07/21 Page 4of5 LAW OFFICES OF BOBBI C. STERNHEIA\ taken seriously,” and just like the majority of complaints filed by inmates, the facility refuses to provide results of this and other inquiries. The mail and food issues persist. Even a Federal Express envelope from the government was not given to Ms. Maxwell until two weeks after it was sent, containing a discovery disc that was unreadable. In mid-March, she received a copy of the New York Times issued in October. Any claim that Ms. Maxwell deletes CorrLinks emails, which is disputed, does little to erase the fact that the MDC violated its own policy by prematurely deleting Ms. Maxwell’s legal emails. That her food is not heated in a thermal oven does little to explain why she was given a salad containing mold earlier this week. Ms. Maxwell does not have an eye mask; she’s not even provided a suitable face mask. She covers her eyes with a towel to shield them from glaring overhead lighting that she cannot turn off and from flashlights pointed into her cell every 15 minutes during the night. That Ms. Maxwell chooses not to respond to guards during the nighttime is no indication that she is engaged in restful sleep; rather, it’s a respite from having to engage with them. No amount of gloss put on Ms. Maxwell’s conditions of confinement can erase the fact that she remains in de facto solitary confinement, over-managed by multiple guards, and surveilled by multiple cameras 24 hours per day. The computer equipment provided remains inadequate to review the millions of pages of discovery under circumstances that are not conducive to preparing for trial. It is unreasonable to believe that not being able to search, mark, save, and print is sufficient to prepare this document-laden case for trial. The Court need only imagine how the government would respond if this was a 25-year-old document-driven fraud Case. DOJ-OGR-00002910