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Case 1:20-cr-00330-PAE Document 300 _ Filed 06/15/21 Page 3 of 32 LAW OFFICES OF BOBBI C. STERNHEIA\ During a recent sentencing in which defense counsel described deplorable conditions at the MCC, Judge McMahon acknowledged that the defendant had been subjected to conditions as “disgusting, inhuman as anything I’ve heard about any Colombian prison, but more so because we’re supposed to be better than that.” United States v. Tiffany Days, 19 Cr. 619 (CM), Sentencing Transcript at 19 (annexed as Exhibit A.) Addressing both the MCC and the MDC, Judge McMahon boldly stated: [T]here is no excuse for the conditions in those two institutions. . .. [Detainees] shouldn’t suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau of Prisons. I will do what I can to bring your situation to the people who, if they give a damn, might do something. Exhibit A at 20. Numerous complaints have been brought to the Court’s attention regarding recurring problematic conditions at the MDC and over-management of Ms. Maxwell. Little if anything has been done to improve Ms. Maxwell’s conditions; and the government’s updates to the Court embolden the MDC to maintain the status quo. The ever-changing rules are negatively impacting Ms. Maxwell’s ability to prepare for trial and are interfering with privileged attorney-client communication. The hyper-surveillance of Ms. Maxwell and counsel during legal visits is highly inappropriate and invasive. At a minimum, this should not be sanctioned by the Court. Very truly yours, BOBBI C. STERNHEIM cc: Counsel for both parties DOJ-OGR-00004746