Case 4:19-cv-00212-MW-MAF Document 311-8 Filed 05/28/21 Page 1 of 265 EXHIBIT A PUTATIVE CLASS MEMBER DECLARATIONS A-1: Tracey Dean ………………………………………………………………....1 *Tracey Dean became a named plaintiff on May 27, 2021, see ECF 309. A-2: Derrick Grantley ……………………………………………………………16 A-3: Gary Seymour ……………………………………………………………....26 A-4: David Lee Moore ……………………………………………………………39 A-5: Norris Nelson ……………………………………………………………….55 A-6: Thomas P. Robinson ………………………………………………………..63 A-7: Michael Townson …………………………………………………………...75 A-8: Tyrone English ……………………………………………………………...84 A-9: John D. Ponder ……………………………………………………………...91 A-10: Dytrell Jones ……………………………………………………………..109 A-11: Larry Merritt ……………………………………………………………..116 A-12: Destini Matthews …………………………………………………………127 A-13: Demetrius Spires …………………………………………………………134 A-14: Michael Love ………………………………………………………….…141 A-15: Thomas Tingley ……………………………………………………….…147 A-16: Briana (Alex) Beasley ……………………………………………………156 A-17: Jamal Sessions ……………………………………………………………165 A-18: Ha Khelius Moore ………………………………………………………..170 A-19: Kiko Rogers ………………………………………………………………180 A-20: Randy Woullard ………………………………………………………….187 Case 4:19-cv-00212-MW-MAF Document 311-8 Filed 05/28/21 Page 2 of 265 A-21: Marcus Broadnax ………………………………………………………...194 A-22: Odell Lee …………………………………………………………………199 A-23: Kyle Himes ……………………………………………………………….206 A-24: John Gilday ………………………………………………………………214 A-25: Delonte Miller ……………………………………………………………224 A-26: Derrick Devon West Sr. ………………………………………………….232 A-27: Savannah Marie (Chad) Powell …………………………………………..238 A-28: Adarius Dale ……………………………………………………………...244 A-29: Valencia Simms ……………………………………………………….…249 A-30: Scott E. Barnes …………………………………………………………...254 A-31: David Anderson …………………………………………………………..260 Case 4:19-cv-00212-MW-MAF Document 311-8 Filed 05/28/21 Page 3 of 265 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION _________________________ ) JAC’QUANN (ADMIRE) ) HARVARD, et al., ) ) Plaintiffs, ) ) v. ) Case No.: 4:19-cv-00212-MW-MAF ) ) MARK S. INCH, et al., ) ) Defendants. ) _________________________ ) DECLARATION OF TRACEY DEAN I, TRACEY DEAN, declare under penalty of perjury: 1. I am 27-year-old woman who has been in and out of solitary confinement in the Florida Department of Corrections (FDC) since January of 2017. Right now, I am in an inpatient mental health unit at Florida Women’s Reception Center. I make this declaration based on my own personal knowledge. 2. FDC put me in Close Management (CM) at Lowell Correction Institution in August of 2018, and I have been stuck on CM ever since. I’m currently on level 3 of CM but my mental health got so bad that I had to go to the Transitional Care Unit (TCU), an inpatient mental health unit, in July of 2020. 1 Case 4:19-cv-00212-MW-MAF Document 311-8 Filed 05/28/21 Page 4 of 265 3. I have borderline personality disorder, post-traumatic stress disorder (PTSD), and bipolar disorder with depressive episodes. Throughout my childhood, I was in outpatient mental health services and was also hospitalized for my mental health at thirteen and fifteen-years-old. My PTSD gives me flashbacks and panic attacks. My PTSD comes from violence in my childhood and being a victim of domestic violence at the hands of my husband. I also get really bad mood swings from my bipolar disorder. For example, some days, I can’t sleep or eat. But then other days, I only sleep. Now that I’m in the TCU, I see a mental health counselor weekly in a private room for about an hour, plus group sessions, which really helps with controlling my depression, manic outbursts and flashbacks. But I’m very scared of going back to CM at Lowell because I don’t get this kind of counseling there. On CM, I get a “session” with a counselor maybe once a week for usually about 15 – 20 minutes. If I had to go back to CM at Lowell, I’m afraid that I would destabilize in CM at Lowell and end up trying to kill myself or cutting again because I know I won’t get the mental health care I need. 4. Since starting my current prison sentence on March 25, 2016, I’ve been in confinement over fifteen times. Everyone calls Administrative Confinement (AC), Disciplinary Confinement (DC), and CM “confinement” because in each we’re confined to our cells almost 24 hours a day. I’ve been in AC, including for being a victim of sexual abuse, DC, and all the CM levels (1, 2, and 3). I’ve been in 2 Case 4:19-cv-00212-MW-MAF Document 311-8 Filed 05/28/21 Page 5 of 265 confinement at Lowell, Lowell Annex, and Gadsen Correctional Institutions. But it doesn’t really matter what institution I’m in or what level on I’m, confinement is always a disaster for my mental health. 5. In my experience, all the cells in AC, DC, and CM are small and terrible. They all make me feel claustrophobic. They are always filthy with general crud everywhere. I luck out if the toilet and sink aren’t banged up and work like they're supposed to. About half the time, the sinks will spray out on to the floor or there won’t be hot water. I’ve also been in cells with toilets that don’t flush or only flush halfway. One time, I was in a cell and the toilet wouldn’t flush at all. I told an officer like I’m supposed to and then they’re supposed to put me in a new cell. But instead, they kept me in there for three days with a non-flushing toilet before moving me. 6. There is hardly any natural light. If there is a window that faces the outdoors, it is covered or frosted so I can’t see outside. I also can’t open it even a crack to get fresh air. It’s hard to keep track of time, especially because I have no clock. Confinement cells are filled with bright lights from about 5AM to 9:45PM. Their intensity is magnified by the bright, plain white walls of the cells. For someone prone to headaches like me, the lights are excruciating. I only get a few headaches in general population but in confinement, I get at least two to three headaches a week. 3 Case 4:19-cv-00212-MW-MAF Document 311-8 Filed 05/28/21 Page 6 of 265 7. There’s not much to look at in confinement cells. There’s no view of the sky or outdoors through frosted windows. All I can usually see through the window in my cell door is the occasional person walking by and more prison walls. But when I try to look out my door because I’m bored or lonely, guards often yell at me. I can’t even look at myself because there is no mirror. I am not allowed to hang anything on my cell walls, not even pictures or letters from my family. In general population, I’d hang pictures of my kids and inspirational quotes to motivate me to keep moving forward and to stay positive. Something small like that can make all the difference to me to get strength to make it to the next day, but that is especially true when I'm all alone in a cell. Staring at the bare walls for hours every day makes me feel detached. It makes it feel like I’m sitting in a dungeon with nothing to look at but those four bright white walls. 8. Confinement denies me the basic dignity of good hygiene. In order to get tampons or pads, I have to ask an officer for them then wait for the officer to bring me them. A couple times, I’ve had to go several days waiting for the officers to bring me them while I was on my period. In general population, I automatically get a week’s worth of supplies every month without even asking for it. In general population, I could also shower basically every day if I wanted to. But in confinement, guards only offer showers maybe once or twice a week, even though it’s supposed to be three times a week. I mostly just stay in my bed when the guards 4 Case 4:19-cv-00212-MW-MAF Document 311-8 Filed 05/28/21 Page 7 of 265 offer showers because of the issues that can come with going. First, the guards have to put me in leg irons and handcuffs. Then, guards bring me to the shower, put me in it, close the door. I'm not allowed to talk to anyone during the whole process. 9. One time I went to the showers and the guards put on leg irons so tight that I kept tripping. The guards said I was fine and then made a joke about how instead of self-harming by cutting myself, I should use a razor for my legs. It was humiliating. People laughed at me. A guard then told me it was her job to make people laugh and I should go cut myself. Ever since then, I don’t feel like the showers are a safe place for me to be. 10. Other than the guards who I feel like hate me, I barely interact with anyone. Back in general population, I had regular contact with my mom and sister. In confinement, at most, even on CM3, I only get to make one call, about once a month. So basically, once a month, I have to choose between calling my sister or my mom. I need more calls with them because they reconnect me to the world which helps my mental health. 11. Until September of 2020, I didn’t have a tablet to email my family because I couldn’t afford one.