DOJ-OGR-00020332.pdf

Case 21-58, Document 89-1, 05/17/2021, 3102450, Page8 of 14 be singled out in this way because she is alone, the nature of the charges, and that this is high profile case. But those reasons, individually or collectively, do not justify torturing someone by depriving them of sleep. Nevertheless, the district judge did not conduct a hearing or otherwise question BOP. It simply allowed the government to file a letter saying that this is what was relayed to the government from the jail lawyer from the jail guards. Even if that hearsay was true (which should be questioned based on other representations made by BOP to the government to the court), it is not at all sufficient for this type of treatment. 3. Government misrepresentation to the district court: Ms. Maxwell “caused [her] cell to smell” by not flushing the toilet. Doc. 196, n.2 (April 6, 2021, gov’t letter to district court). This claim is absurd, of course, and was again made without any sworn statement. Ms. Maxwell responded and explained that the smell of sewage was caused by the conditions in MDC and not by her. This was recently corroborated by another MDC inmate, Tiffany Days, who explained to Judge McMahon the sorts of conditions that are present at MDC: “I also survived the disgusting feces flood that we were 6 DOJ-OGR-00020332