DOJ-OGR-00020349.pdf

Case 1:16-cv-03306-AJN-BCM Document 172562 Filed 04/29/20 Page 2 of 4 LAW OFFICES OF BOBBI C. STERNHEIM The MDC routinely places inmates in the SHU if they have engaged in physical altercation with other inmates or to protect inmates who are the subject of abuse. It would be ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since she has no contact with anyone but staff. As suggested by the Circuit, we ask the Court to address Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance. Very truly yours, Bobbi C. Sternheim BOBBI C. STERNHEIM Encs. cc: All counsel of record 2 DOJ-OGR-00020349