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

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) ni THE UNITED swnims DISTRICT COURT \
FOR THE DISTRICT OF DELAWARE
EDDIE TAYLOR : NO. 04-177-SLR ' \
|·|;|¤¤t!' : _ .
CIVIGENICS Q ‘ l
\ Defendant t " .
l DECLARATION Ol? JAY SYLVESTER i
Jay Sylvester being duly sworn aeeording to law, deposesand says, I l
1. I am presently employed with Civigenics, Inc. as Director ofthe Key North n
Program for the Delaware Department of Corrections. , , A
2. I have been with Civigenies for eight years and have held my current position · i
` since May, 2004.
3. ln the Administration of the Key North Program ("Program"), Civigenies does not
employ humiliationorintintidation tactics. O
4. No Resident has the authority to discipline another Resident. .
5. No Resident has supervisory or administrative authority over other Residents.
6. No Resident has the authority to insmuet another Resident to “sta¤d tig1t”.
7. A11 infractions ofthe Prog;mm’s rules are investigated by the Program Stafti It is
the Program Staffs decision to impose sanctions, if any.
8. Program Staff; who are non-residents, assin Residents to positions within the
1 ?1'¤gr¤m. Residents do not have the authority to assign other Residents to positions within the
E Program.

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9. Program sta;&'and counselors are available to llesidents at all time during
operating hours, which are hom 8:00 am. to 9:00 p.rn. X
10. Jobs available to Residents include janitorial tasks, maintaining attendance logs, /
settingup forfunctlons and leadingmeetings, with a Program advisorpresent.
11. While the Key Program, Civigenics has never required Residents to
utilize hand signals to request to perform certain functions. A
12. While enrolled in the Program, Rrsideuts must comply with all regulations,
policies and procedures of the Department of Corrections. ` G
13. While enrolled in the Program, Residents have the ability to Elo grievances with
the Department of Corrections.
14. The Grievance procedure for the Delaware Department ofCcrr¤:tions is as
tollows: an inmate may request a grievance form Erorn an oiiioer on duty. The inmate then K
forwards the grievance to me Grievance Chair. The Grievance Chair then reviews the grievance
and forwards it to the appropriate partyto investigate the complaint. In the instant matter, it
would be the Director ofthe Key Pmgarn. The Director would then investigate the complaint
which would include speaking with the inmate. Upon completion ofthe investigation, the j
4_ Director forwards the results ofthe investigation to the Grievance Chair notify him or her I
whether the matter could or could not bc resolved. The Grievance Chair would then notify the
inmate ofthe results of the investigation. The inmate would then have the ability to appeal the
decision. -
14. All positions within tire Prognm are supavised by a staff advisor.
W
N

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Pursuant to 28 U.S.C. § 1746, I declm cn this dau: under penalty ofpcrjuxy that the I
foregoing is tmc and correct based on my pusonul knowledge.
` 1 symm %°/b‘
TOTH. P. 5 5

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