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Case 21-770, Document 20-1, 04/01/2021, 3068530, Page6 of 31 ISSUES PRESENTED 1. Whether Ms. Maxwell can effectively prepare her defense where she is being subjected to horrific conditions of detention during a global pandemic, including: e not being able to regularly see her lawyers in person to prepare for trial; e being kept awake all night to make sure she does not commit suicide even though nothing suggests she is a suicide risk; e having her every movement videotaped on multiple cameras focused on her every move; e being stuck in de facto solitary confinement without safe, in person visitation; e being forced to review millions of pages of documents on a stripped down computer without adequate hardware or software such that Ms. Maxwell cannot open tens of thousands of pages of discovery and for those she can open, only has the ability to review them one page at a time and cannot search, edit, copy, or print; e having no writing surface in her solitary cell; and e not consistently provided edible food or drinkable water. 2. Whether the trial court erred by relying on the government’s proffer — which was comprised of nothing but extremely old, anonymous, unconfronted, hearsay accusations — to refuse to set reasonable bail. DOJ-OGR-00000916