Manning's lawyer David Coombs was
quoted: "'Manning was awoken at 0500 hours and required to remain awake in his cell from 0500 to 2200 hours,' Coombs claims in the motion, adding that he 'was not permitted to lie down on his rack during the duty day. Nor was Manning permitted to lean his back against the cell wall; he had to sit upright on his rack without any back support'.
The motion further states that Manning was only allowed 20 minutes of 'sunshine call' a day. In addition, he was permitted by guards to take no more than five minutes in the shower. On the rare occasions that he was allowed out of his cell, Manning was forced to wear shackles with metal hand and leg restraints. At least two guards accompanied him at all times.
Manning was handed a pair of running shoes without laces for his trips outside, but they would fall off when he attempted to walk. As a result he 'elected to wear boots instead', the document alleges."