DOJ-OGR-00006057.jpg

Case 1:20-cr-00330-PAE Document 408 _ Filed 11/03/21 Page2of7 LAW OFFICES OF BOBBI C. STERNHEIA\ openly hostile toward her and have mentioned having read the press and seen various television shows which amplify their hostility. There are cameras on her constantly, most are stationary, but one camera follows her as she moves throughout the facility, and is constantly surveilling her, even during confidential attorney-client conferences. Ms. Maxwell has reported to counsel and the BOP that she has been threatened by corrections officers that she will be subject to discipline if she is ever out of, or anything interferes with, the camera’s view. Ms. Maxwell is subject to numerous pat searches per day, despite being completely isolated, during which she alleges to have been touched in a sexually inappropriate manner by corrections officers on multiple occasions. She declines recreation time to avoid being searched, which has negatively impacted her physical health. She was denied an extra blanket in the winter, and, on more than one occasion, an officer took one of her blankets from her after her request for an extra blanket was granted. She was not provided a proper food regimen for the first few months she was incarcerated, wherein she was provided with small, inadequate portions or rotten food. She has lost at least 15 pounds since her incarceration and has experienced hair loss. Currently, she suffers from headaches and back pain and general physical weakness. Ms. Maxwell’s guards shine flashlights on the ceiling of her cell in 15-minute intervals and have done so every night since she has been incarcerated. As reported by the government, “MDC staff conduct flashlight checks every fifteen minutes because the defendant, while not on suicide watch, is on an enhanced security schedule because MDC has identified a number of factors that raise heightened safety and security concerns with respect to this defendant.” (Dkt. 270.) This response provides further support that Ms. Maxwell is overmanaged because of the intense criticism sustained by the Department of Justice over the Bureau of Prison’s blunders that resulted in the death of Jeffrey Epstein, an event that preceded the arrest and prosecution of Ms. DOJ-OGR-00006057