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Cétash: 2@20roCk RSP AON Dacunmentt2>6 AréeOeH229221 Patege afef 2 LAW OFFICES OF BOBBI C. STERNHEIAA The MDC routinely places inmates in the SHU if they have engaged in physical altercation with other inmates or to protect inmates who are the subject of abuse. It would be ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since she has no contact with anyone but staff. As suggested by the Circuit, we ask the Court to address Ms. Maxwell’s sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance. Encs. cc: All counsel of record 4/29/21 aN SO ORDERED. ALISON J. NATHAN, U.S.D,. Very truly yours, BOBBI C. STERNHEIM By May 5, 2021, the Government is ORDERED to confer with MDC legal counsel and provide the Court responses to the following questions: . Is Ms. Maxwell being subjected to flashlight surveillance every 15 minutes at night? Or any other atypical flashlight surveillance? . If so, what is the basis for doing so? . And if so, can she be provided with appropriate eye covering? The Government is further ORDERED to share its response with defense counsel before filing it on ECF so that defense counsel can indicate whether they believe any private medical information needs to be redacted before public filing. SO ORDERED. DOJ-OGR-00004059