270 [DOJ-OGR-00004103—DOJ-OGR-00004104]

Case 1:20-cr-00330-PAE Document270 Filed 05/05/21 Page1of2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 May 5, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court’s Order dated April 29, 2021, which directed the Government to confer with legal counsel at the Metropolitan Detention Center (“MDC”) regarding the use of flashlights in security checks at MDC. (Dkt. No. 257). The Government has conferred with legal counsel at MDC in accordance with the Court’s Order, and legal counsel provided the information set forth herein. MDC staff conduct flashlight checks at night as a matter of course throughout the facility for the safety and security of the inmates at the institution. During these flashlight checks, MDC staff point a flashlight at the ceiling of each cell to illuminate the cell sufficiently to confirm that the inmate 1s present in the cell, breathing, and not in distress. MDC staff conduct flashlight checks every 30 minutes for inmates housed in the Special Housing Unit (the “SHU”) and conduct flashlight checks of inmates in the general population multiple times each night at irregular intervals, but at an average of at least once per hour. With respect to the defendant, MDC staff conduct flashlight checks every fifteen minutes because the defendant, while not on suicide watch, is on an enhanced security schedule. That is DOJ-OGR-00004103