DOJ-OGR-00021628.pdf

Case 22-1426, Document 78, 06/29/2023, 3536039, Page198 of 217 M6s2Max2 83 1 unusually harsh and punishing, she will remain in the shadow of 2 prison bars until she can return to the sunlight of liberty. 3 As I said before, she is over 60 years old. She has 4 no history of violence. She had no criminal history before or 5 after the crimes of conviction, which ended some 20 years ago, 6 and the Court needs to consider that there is an extensive 7 period that has elapsed from the end of the charged conduct. 8 She poses no danger to society or of recidivism. Her personal 9 circumstances include many accomplishments and good deeds. 10 As I said, she has been subjected to extensive 11 punishing conditions of presentence incarceration in solitary 12 confinement. When she was moved within the last two months to 13 general population, she began interacting with the inmates and 14 assisting them in many, many ways. She began conducting 15 English classes and GED tutoring, programs that were no longer 16 being offered in the MDC and certainly had been suspended as a 17 result of the ongoing pandemic. Her asset to the unit in 18 general population is recited in the unsolicited letter 19 submitted to the Court from one of her fellow unit inmates. 20 But I have also been contacted personally by counsel for other 21 inmates in Ms. Maxwell's unit, reporting to me that she is 22 providing needed educational assistance that has not been 23 ongoing for at least two years. 24 Ms. Maxwell is being sentenced for terrible conduct. 25 There is no denying that. But she has the ability and the SOUTHERN DISTRICT REPORTERS, P.C...(212) 805-0300 DOJ-OGR-00021628