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Case 1:20-cr-00330-AJN Document 88 Filed 12/07/20 Page 2 of 2

inmates are breathing and not in distress. Inmates in BOP custody are subject to searches, including
body scanners, and inmates may be searched prior to moving from one area of the facility to another.
The removal of Ms. Maxwell’s face mask complies with the BOP’s COVID-19 Pandemic Response Plan.

Since Ms. Maxwell’s arrival, she has been provided three (3) meals a day in accordance with BOP
policy and its National Menu. Food Service staff have addressed Ms. Maxwell’s requests. Ms. Maxwell is
served her breakfast upon entering the common area of the housing unit at 7:00 AM; at noon she is
served her lunch; and at 5:00 PM she is served dinner. Her medical records show that she currently
weighs 134 lbs., which fluctuates plus or minus 2 lbs. Health Services staff make regular rounds of her
housing unit and she has been instructed on how to request medical care through the sick call
procedures. Furthermore, while there has been a number of inmates whom have tested positive for
COVID-19, Ms. Maxwell remains in good health and is not in contact with those individuals. The BOP
staff assigned to Ms. Maxwell’s unit do not come in contact with the other individuals whom have
tested positive. Lastly, the temperature of Ms. Maxwell’s cell is checked three times daily to ensure it is
in compliance with national standards.

In accordance with the BOP’s COVID-19 Pandemic Response Plan, inmates are allotted 500
minutes per month of social telephone calls, which Ms. Maxwell has used throughout her time at MDC
Brooklyn. While Ms. Maxwell has received one legal video conference, she continues to have full access
to legal telephone calls and in person legal visits. Pursuant to the District Courts guidance, legal
telephone calls are scheduled through the Federal Defenders, who should be afforded an opportunity to
address any concerns Ms. Maxwell’s attorneys have with the legal calls.

I trust this has addressed your concerns.

Respectfully submitted,

/s/ Sophia Papapetru

Sophia Papapetru
Staff Attorney
MDC Brooklyn
Federal Bureau of Prisons

/s/ John Wallace

John Wallace
Staff Attorney
MDC Brooklyn
Federal Bureau of Prisons

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