Free Affidavit - District Court of Delaware - Delaware

_ Case1:05-cv—00823-SLR-LPS Document 270 Filed 06/30/2008 Page1of4
IN THE UNITED STATES DISTRICT COURT F I L E [) i
FOR THE DISTRICT OF DELAWARE I ? JUN 30 Hmg {
GEORGE A. JACKSON, et al., )
Flames, § gy ¤%§?¤%?E'?‘%EEE&f?.EE 3
v. ) C.A. No. 05-823-SLR
STANLEY TAYLOR, m;al., ) JURY TRIAL REQUESTED
Defendants. g
STATE OF DELAWARE)
AFFIDAVIT OF RIQUE REYNOLDS
COUNTY OF SUSSEX)
RIQUE1 REYNCHJDS, being duly sworn, deposes and says:
l. I am a plaintiff and witnesss in this case. I make this affidavit in
opposition to Defendants' Motion for Summary Judgment.
2. I was classified to work at the SCI Main kitchen between l2/27/Ol—
ll/26/O2. During all relevant times I was housed in the Merit Building with
minimum high/security. I had to work in the kitchen, or received a major prison
infraction (Class I). If found guilty, I would received penalty points and move
immediately to an higher security building such as Medium or P.I. Buildings. During
my time in the kitchen, inmate kitchen workers were constantly being threaten
to received a major write and move to a higher security building.
3. On information and belief, the above practice was approved by Food
Service Director Christopher Senato, and Treatment Administrator Patricia Ditto
who is also the supervisor of the classification staff.
4. During the time that I worked in the kitchen, I was trained by fellow
inmate kitchen workers to do whatevr job that was assigned to me. No DOC Food
Staff ever trained me to performed any dutie.
5. I witness only rare ocassion were DOC Food Staff would work side by
side with inmate kitchen workers in the preparation of meals.

_ Case 1:05-cv—00823-SLR-LPS Document 270 Filed 06/30/2008 Page 2 of 4
6. I personally observed and witness during the cold to freezing winter
months (especially the 3:00 am to 10:30 am shift), I was force to work under
extreme cold conditinn without the benefit of adequate winter clothing (DOC issued:
jackets, thermal wear, tobagans, ect.) But DOC Food Service Staff, would be permitted
to their DOC issued winter coats, ear muffs, gloves, thermal wear and hats when
they leaved the heated office to entered the cold work place.
7. I personally experience working under excessive heat and extreme humidity
conditions while in the dishroom area. The excessive heat and extreme humidity
in that area causes the floor and wall to constantly "sweat" while making the
walking conditions unsafe. I personally have fallen, and I've witness numerous
of other inmates fall and been hurt. I experience lack of oxygen due to extreme humidity.
8. When I was in the SCI kitchen, the ventilation system on the "old-side"
kitchen never worked. But the ventilation system in the "new-side" kitchen work
adequately no matter what the out doors temperature was.
9. During the shift, inmate kitchen workers remain in the excessive heat/
humidity and extreme cold during the entire shift, whereas the DOC Food Service
has the luxury of going into the air condition cool and heated office during those
extreme work condition.
10. I have made these statements based upon my personal knowledge and
experience while as an inmate kitchen worker.
@&@x,@,L(&2/
Rique Reynolds
SWORD AND SUBSCRIBED before me this :2 QQ-Ixdiiy of May, 2008.

~¤T.R¢%?H¥3"S'#k$EE$’%”E`hwA¤E
My Commtssion Expires August 28, 2009

Case 1 :05-cv—00823-SLR-LPS Document 270 Filed 06/30/2008 Page 3 of 4
B A CERTIFICATE OF SERVICE _'
. L . lg.1‘.QQ ea, g you l As , hereby certify that I have served 8 {N6 ¤¤d
correct copy of the attached cnf/3 { gf Q M Q f ........ “P°¤ th°
n following person/s below: A _ . l
» . . QAME §mE.B.';
I _ §Q¤e_·{;ggr>,‘¤; gr Zlrlz, ly IEE giyg j2@F,;~y;i; @<{i:¤r i 'C Z
· · 5 · [ • 1 E ? E Q S
_ · j _ By placing same in a sea.led,·—p0stage pre-paid envelope and depo$iii¤g S¤¤1¢
the United States Mill at Sussex Correctional Institution, P.O. Box 500, Georgetown,
° A Delaware 19947._ _
_ ‘ _ _ This ze dayof june; , -?~€?‘Z>$7· _

Case 1 :05-cv—00823-SLR-LPS Document 270 Filed 06/30/2008 Page 4 of 4
an rv ¤¤
5*; sv Q §
§ S K?
2 >< 2 a·
0 S 0 L
S ° E
g O `~..)
»-a_ ;
E E
(I
2 F i ,.,.
E "` l
z
z E
di
" E sa
0
2
I"!. N
Ig Z`;
ZT? i
H. E_
ai? f Pv
(H _ ‘”-
sf- ‘ _ "·\—
L!.}
2 —-’ V
F ><
? · { LQ;
Z: P" »»
EI 211 9*
im
= TY if;
2.. €`“

2-
*- ~ *1 § i ?
, i ,2 E
"r {2 Ear ’¥2a»;
E: fi/;_ _-_-• ;-