(ECF No. 66 at 27.) See, e.g., U.S. v. Behr, 2006 WL 1586563, *5 (S.D.N.Y. June 9, 2006) (sentencing court found that the 29 months served by pretrial detainee at the MCC under harsh conditions was sufficient punishment for his offenses and sentenced him to time served ). In contrast, movant is a post-conviction inmate, and harsh conditions are not a basis for reconsidering his 2013 sentence.