Free Affidavit - District Court of Delaware - Delaware

Case 1:05-cv—OO823-SLR-LPS Document 278 Filed 07/O1/2008 Page1of2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
GEORGE A. JACKSON, et alu g
Plaintiffs, g
v, ) C.A. No. 05-823-SLR
STANLEY TAYLOR, et al., g JURY TRIAL REQU TELQ A "'
Defendants. ) "2
PLAINTIFF GEORGE A. JACKSON'S STATEMENT OF DIS'UT .&D§§&§bgw"
FACTUAL ISSUES •\TmCTOFDE‘Wki
Defendants have moved for summary judgment on the plaintiffs' claims cgi) Sfqf1nJ4/
of inadequate ventilation system on the "old—side" area of the SCI kitchen.
The Plaintiff submitts the following list of material fact that denial of
Defendants' Summary Judgment motion.
l. Whether the plaintiff were subjected to extreme temperatures on the
"old—side" kitchen area, whereas the "new-side" kitchen area did not subjected
inmate workers to the same extreme temperatures.
2. Whether the extreme temperature on the "old—side" area pose a serious
health risks to inmate kitchen workers and the prison population.
3. Whether the extreme temperature on the "old-side" area are the results
of an defective exhaust hood ventilation systems, or the sole result of the
summer heat wave.
4. Whether the working conditions at the "old-side" kitchen area are
"objectively, sufficiently serious."
5. Whether plaintiff were force to work under the defective condition ,
or whether plaintiff had any viable options.
6. Whether Plaintiff properly exhausted his administrative remedies
under the DOC grievance procedure 4.4.

Case 1:05-ov—OO823-SLR-LPS Document 278 Filed 07/O1/2008 Page 2 of 2

7. Whether plaintiff grievance gave prison officials "fair notice" of
his claims.
8. Whether the "old-side" ventilation system was maintained and operated as
to ensure the required protection by maintaining a volume and velocity of
exhaust air sufficient to gather dust, fumes, vapors, or gases from the said
commericial cooking equipment, and to covey them to suitable points of safe
disposal, thereby preventing their dispersion in harmful quantities into
the atomshere where inmate employees work.
9. Whether the constant exposure to the risk of heat stroke, lack of
air flow, dehydration, hazardous floor area, and limited use of toilet facility
subject plaintiff to cruel and unusual conditions at the work place.
lO. Whether one (l) toilet seat for 22—25 inmates to share is could
contribute to cruel and unusual punishment when inmates are order to drink
plenty of water when theres only one (1) toilet seat per 25 inmate workers.
ll. Whether there was pest infestation at the SCI kitchen.
DATED: 5,