Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:78-cv-00014-SLR Document 253-6 Filed O2/14/2006 Paget of3
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
NORTH EMERSON-WEST, et al. )
Plaintiffs, l
) C.A. N0. 78-14 SLR
v. )
)
WALTER REDMAN, et al. )
Defendants, l
AFFIDAVIT OF PAUL HOWARD
PAUL HOWARD, having been duly sworn according to law, deposes and
states as follows:
1. I am currently employed by the State of Delaware, Department of
Correction as the Chief of Bureau of Prisons. I have held that position since 1996. I
have been employed by the Department of Correction since 1973. My current
responsibilities include supervising the operations and management personnel (including
wardens) of all the prisons in the State of Delaware. These responsibilities include
security, classification, transportation, human resources, treatment, and basic logistics
(such as feeding). -
2. The Department of Correction (DCC) Code of Penal Discipline mandated
by the Consent Order has caused multiple serious problems for the Department of
Correction. It has the following results that are harmful to the orderly operation of the
Delaware prisons: (1) it creates inconsistent standards between prisons, as all other
institutions have one Code of Penal Discipline and DCC has another, different one———
depriving the Department of the ability to promulgate uniform rules of conduct

Case 1:78-cv-00014-SLR

Document 253-6

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