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


File Size: 385.3 kB
Pages: 4
Date: December 31, 1969
File Format: PDF
State: Delaware
Category: District Court of Delaware
Author: unknown
Word Count: 1,789 Words, 12,771 Characters
Page Size: Letter (8 1/2" x 11")
URL

https://www.findforms.com/pdf_files/ded/7529/40-2.pdf

Download Motion for Summary Judgment - District Court of Delaware ( 385.3 kB)


Preview Motion for Summary Judgment - District Court of Delaware
State of ]D`<£1$®a`réO4Si2t$slt)t£21`bZZ&$il1-J3 T1 - D<§fa?H|r1QgtQ1?/égftgctiolgage 1 gage 1 of 4
l
·. T ~ it T ‘‘°° ‘ i t tt t t
ttt t t .. .. tttt t t . ·.tt
.· · r·» ·- , s r ~ . rfrizii )t”‘‘t“"ttt””" mirrrfzi »==- irT~?T·‘ ··:’i·K*t’t»‘V· 7 · 1; ‘t·* 't·t tri
, i.}-iétiigi litzetl, The Qtticittl Wcbszrc tar tl¢icrr}~"1rstrii,Ststcs _Ett ·‘° ·_ , ,g,}~ .’x= r,1l;§i,li,l?g l
V,'. g · , ( ‘ tt‘t ·V;!_((.($t..t=t,..t . .t.tt_ tt‘·t, sa `#.<,=i.i·mi
—·.,.t - ‘ Visit the Governcrl General Assembly] Courts) Other Elected Officialsl Federal, State &l. §
State Direcionrl rlalpl Search Delaware} citizen ssivisssi Business sslvasssi ~ I
` $..'J;‘Z;1"““"”""°"””.....,.M.,.....',"."'”'“,..”"Z."'”'.s ”“;”"""""”"..,.,.... '””"""””"““ . ..,.,,,,.,.... ,..., Q. ,.-,.......,,,,,,,,,_*‘°"‘ ··*····*·**‘······r·r···r··~·~···
Department of Correction (DOC)
Home Substance Abuse Treatment J
siznvices
lNFORll/IATION The State of Delaware—Department of Correction recognizes the vital importance of
Bids/RFPs/Solicitations Substance abuse treatment within the inmate/offender population. Currently, 80-
g°*é"§'::_Ol} C°"‘·’°l'0“ percent of the state's offender population are substance abusers. Without intervention
Dgath Rgfct and treatment, recidivism rates can top 70-percent. DeIaware's internationally-
Exgcutms acclaimed, 3-step substance abuse treatment program is proven to be successful in
F ,3,] t rehabilitating drug offenders. This treatment program is called: KEY, Crest,
H?S(iOr·y 99 Aftercare. Treatment follows the offender from incarceration to work release and
Egggpgg Listing finally, to full·time status in the community. Delaware is the first state in the nation to
Facts and Figures fully implement such an aggressive offender substance abuse program. l
Prison Arts
Prison Industries . {
Religious Services Program Datalls i
Youth/Young Offenders (
The KEY Program
• The KEY is the first component of Delaware's substance abuse treatment
regimen for offenders with a history of substance abuse. KEY is a prison- ,
i based therapeutic community for men and women - a total treatment
4 environment that is discipline—based, intense and isolated from the rest of the
prison population. Today, the KEY program can accommodate approximately
420 participants a year throughout the prison system.
• The primary goal of KEY is to change negative patterns of behavior, thinking
and feelings that predispose one toward drug abuse.
• The KEY program started at the Howard R. Young Correctional Institution
_ (then the Multi Purpose Criminal Justice Facility) (Gander Hill) on July 21, (
1988 with 20 inmates. KEY South at the Sussex Correctional institution started
November 1997.
• The treatment perspective of the KEY programs is that drug abuse is a
disorder of the whole person; addiction is the symptom, not the essence of the
disorder. The primary goal is to change negative patterns of behavior, thinking
and feeling that predispose one toward drug abuse.
• inmates typically become involved in the KEY program during the last 12-18
months of incarceration. This allows material learned in the program to stay in
the forefront ofthe offender's mind as he/she moves to the next stage of
substance abuse treatment.
• The program provides a disciplined, regimented routine for inmates. They do
not have access to television or telephones during the day. Free time can be
taken away as a consequence of inappropriate behavior.
• KEY participants are called "family" members. Undertaking responsibility is
http://www.statedc.us/correct/Programs/treatmcntprograms.shtml 1/30/2006

Sm Of1P:‘?駑é”if?o2t$’¤E‘i*??i5ti°i°?v°¢§tt§ T“i5t§%ttiiiEiltg&t31°é · Dtntéafeaiof/§ses¤i1¤Page 2 Seas 2 ef 4
essential to treatment at the KEY. For example, some "family" members are
part of the media crew, which develops motivational signs and displays
appropriate news articles. V
• Programming is scheduled seven days a week with KEY staff members' l
oversight. Inmates have access to staff counselors daily should they need to
discuss issues related to their treatment. l
• inmates must meet twice a week with their caseload group (several other l
inmate members) to discuss issues important to their own recovery. I
• inmates who have been part of the KEY program for several months are l
required to present "peer seminars" to other inmate members regarding issues
important to their own recovery.
• KEY is located at: ‘
Women's Facilities:
..,. in New Castle
Called: KEY Baylor or The Village
5 Opened January 1994
J 96 beds
12 month program — designed specifically for the needs of female offenders
l Men's Facilities:
F2. Yeiing ..,. Q e.rreetiena.l ..... lr1st.i.t.u.t.ien..(Gender Hill) in Wilmington
Called; KEY North
Opened July 1988
200 beds
12 month program
Sussex C_oi@g.;t@rtal Institution in Georgetown i
Called: KEY South
Opened November 1997
120 beds 1
12 month program
The Crest Program
• Crest is the second component of Delaware's substance abuse treatment
program for offenders. Crest Outreach Centers are residential centers for both
J men and women. The Crest program allows recovering substance abusers to
continue their treatment as they transition to the community. Offenders must
display pro—social behaviors such as honesty, responsibility and accountability
prior to being hired for jobs in the community. Typically, offenders work during ,
; the day and return to their assigned Center at night for therapy, counseling or
treatment.
• The Crest program is 6 months in duration. The first three months are spent
entirely at the Crest Center with the offender engaged full-time in substance
abuse treatment. In the second three months in the program, offenders
become involved in the work release portion of the program. Offenders job
i seek or work during the day then return to the Crest Center at night for l
continued substance abuse therapy and to sleep.
• Offenders go through several phases of treatment during their time in the Crest
program: l
l
http://www.state.de.us/correct/Programs/treatmentprograms.shtml 1/3 0/2006 S

l
smc °f]B?%3’“f??>2i*$’étl?St$t>‘t°Ff?*§lif$ T“l§B‘&?iifiEfHg!le¤§ · DF¥i §ede¢ti¤Page s emo 3 of 4 J
y l
o Entry, evaluation and orientation: Offenders become acclimated to life
outside of prison.
o Primary; Counselors and offenders explore the challenges and issues
faced by individual offenders and prepare appropriate responses to
minimize the likelihood of relapse.
o Jobseeking: Offenders develop job seeking and interview skills. . l
o Work Release: Offenders maintain residence at Crest while working in i
the community.
• Crest is located at: (
.Q.en.ttal-.l/ioation E..ro.bat.i.o.r1 near Smyrna
Called: Crest Primary
250 total facility beds
125 beds dedicated to Crest
6 month program l
y Serves a male population only
il/lotr.i.s...Qoi·n.m unity...Qo.rreoti_o.n.s i.,u in Dover
Called: Crest Central
150 total facility beds
150 beds dedicated to Crest
6 month program
Serves a male and female population _
.. Called: Crest North
240 total facility beds
if 140 beds dedicated to Crest
{ 6 month program
Serves a male and female population
Sussex Cerrwunity Corrections Center—Work Release Unit in Georgetown
Called: Crest South
240 total facility beds A
100 beds dedicated to Crest
6 month program
Serves a male and female population
The Aftercare Program
• Aftercare is the third and final component of substance abuse treatment that
takes place once an offender has completed Crest and is on probation.
Offenders taking part in the Aftercare are living full—time in the community. In
Aftercare, offenders return weekly to an assigned center for group sessions
i and counseling. Offenders also participate in random, mandatory drug testing.
• Aftercare offenders typically live in "host houses" where host families must 1
meet certain requirements to participate. r l
• Aftercare is located at: ;
Central Violation of Probation Center near Smyrna
Plummer Community Corrections Center in Wilmington `
Sussex Violation of Probation Center in Georgetown
http://www.state.de.us/correct/Programs/trcatmentprograms.shtml 1/3 0/2006 l
l

i—l
State Of 8gl§eNgl¥0Zl§Lvl20t01i°7€7‘;0*é£)lEll§$: T1 l
r l
Effectiveness:
• A University of Delaware study ofthe DOC's drug treatment continuum found:
Of those completing the continuum, 76 percent remained drug~free and 71
percent remained arrest free after 18 months. ln a control group that did not {
receive the continuum, only 19 percent remained drug—free and 30 percent l
arrest—free after 18 months. {
• A study by the California Department of Alcohol and Drug Programs estimates {
that for every $1 spent on substance abuse treatment, $7 is saved in criminal ,
justice costs - making treatment a long—term, cost-effective approach toward {
reducing crime.
Fast Facts about the Delaware Department of Correction's substance abuse
treatment continuum:
• The Delaware Department of Correction immediately found that the KEY
section of the prison is the cleanest, safest, most troubIe—free section of the
facility.
• The KEY was established in 1988 by a Bureau of Justice Assistance grant. ln
1990, Delawares Department of Correction assumed funding of the program.
• ln February 1999, a delegation from Argentina visited the KEY Village program
at the Baylor Women's Correctional Institution. The delegation explored
bringing an intensive substance abuse treatment program to their region and
chose Delaware's model to study.
• ln April 1999, a delegation from Australia visited the KEY program at the
Howard R. Young Correctional Institution, (then i\/IPCJF), the KEY Village at
§ the Baylor Women's Correctional institution and the Crest program at the
Plummer Community Corrections Center. The delegation explored bringing an
intensive substance abuse treatment program to their region and chose
Delaware's model to study. ”
• ln June 1999, Department of Correction Commissioner Stan Taylor led a group
of DOC officials to Argentina to follow up with the delegation that visited in
February. Commissioner Taylor and his staff offered additional assistance to
the Argeritines in setting up a substance abuse treatment program.
• ln 1997, then U.S. Drug Czar, General Barry l\/lcCaffrey, visited the KEY ‘
program at the Howard R. Young Correctional institution (then l\/IPCJF), the
§ KEY Village program at the Baylor Women's Correctional Institution and the
Crest program at the Plummer Community Corrections Center. McCaffrey {
praised Delawares prison—based substance abuse programs as a role model I
for the ntion in turning around lives and reducing crime. {
W Last Updated: Monday, O5—De_c_;%5:23:28 {
M.“~”W"””M""Y.mZ“.mLM—`””"”"““..mMmm`mmiMmm.w. .... "`"""”"“ T
site map l about this site l contact us l translate l delawaregov
http://www.statc.de.us/correct/Pro grams/t1·eatmentpro g1rams.shtml 1/30/2006 {

Case 1:04-cv-00177-SLR

Document 40-2

Filed 02/03/2006

Page 1 of 4

Case 1:04-cv-00177-SLR

Document 40-2

Filed 02/03/2006

Page 2 of 4

Case 1:04-cv-00177-SLR

Document 40-2

Filed 02/03/2006

Page 3 of 4

Case 1:04-cv-00177-SLR

Document 40-2

Filed 02/03/2006

Page 4 of 4