Free Motion for Summary Judgment - District Court of Delaware - Delaware

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1 mms/-00177-SLR Document 40-6 Filed O2/O3/2006 Page 1 of Qggygg
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
EDDIE TAYLOR : NO. 04-177-SLR (
Plaintiff : I
2 {
CIVIGENICS : 4 {
Defendant :
I i
DECLARATION OF FRANK COSTON i
Frank Coston being duly sworn according; to lsw, deposes and says,
1. I sm currently employed by Civigenics, Inc. as s Supervisor of the Key North
Progsm. .
2. I have hold this position since Civigenics began administrating the Key North {
Program in July of 2003.
3. Prior to July 2003, I was employed by Spectrum Behavior Services as s
Supervisor with the Key North Program.
4. At no time did Civigenies employ humiliation or intimidation tactics.
' S. No Resident has the authority to discipline mother Resident.
6. No Resident hss supervisory or administrative authority over other Residents.
7. No Resident has the authority to instruct another Resident to "stsnd tight". I
8. _ All infractions of the Progmnrs rules are investigated by thc Program Ststii It is
the Program StaEPs decision to impose sanctions, if any.
9. Program Staii who are ¤on·resider¤ts, assign Residents to positions within the
Program. Residents do not have the authority to assign other Residents to positions within the
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Case 1 :04-cv—OO177-SLR Document 40-6 Filed O2/O3/2006 Page 2 of 2
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_ 10. stnfmd counselors are available no Residual: at all time during A
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Case 1:04-cv-00177-SLR

Document 40-6

Filed 02/03/2006

Page 1 of 2

Case 1:04-cv-00177-SLR

Document 40-6

Filed 02/03/2006

Page 2 of 2