Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:00-cv—00261-TPS Document 110-2 Filed 04/11/2006 Page 1 of 3
‘ UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT ‘
MICHAEL BRAHAM : CIVIL NO. 3 :00CV26l (AVC)(TPS)- I
JOHN ARMSTRONG, ET AL. : APRIL 5, 2006
AFFIDAVIT OF IVHCHAEL LEWIS
I, Michael Lewis, being duly sworn, state the following: - _
l. I am over 18 years of age and believe in the obligation of an oath.
2. I am employed by the State of Connecticut Department of Correction and have been so
employed since approximately December 1990.
3. My title with the Department of Correction is Correctional Counselor.
4. I am currently assigned to the CorriganfRadgowski Correctional Center, Radgowski
Building, as a Correctional Counselor. l
5. I was the Grievance Coordinator for Corrigan Correctional Institution trom on or about
September 200l to September 2004, and for Radgowski Correctional Institution from on or
about March 2005 to December 2005.
6. As Grievance Coordinator, my duties included the coordination, processing, review and
investigation of Level 1 Grievances filed by prisoners at the facility. .
7. A record is kept at the facility of all non—medical grievances filed at the facility, in that
the grievances are logged in a book kept for this purpose.
8. It was part of my job to maintain these books and tiles. _
9. On or about August 14, 2002, I signed an Affidavit in the above-entitled case. ‘

Case 3:00-cv-00261-TPS Document 1 10-2 Filed 04/1 1/2006 Page 2 of 3
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n 10. In that Affidavit, I stated that I reviewed those books and files for 1999 and 2000 and
located only one grievance filed by Michael Braham #231451. _
11. I stated in that Affidavit that this grievance pertained to the issue of a hard-cover book.
l That grievance was filed on or about November 26, 1999.
12. In March 2006 I was asked by the Attorney Genera1’s Office to locate a copy of the
- grievance logs for 1999 and 2000. l
13. I was unable to locate the log books for 1999-2000 as, by directive, these log books are
only kept for a specihed period of time. n
14. I discovered, however, that from 1996-2001, a prior grievance coordinator kept nnnlll
I computerized records of grievances.
15. I was able to locate these computengenerated logs.
. 16. While reviewing these logs, I discovered that Michael Braham #231451 had actuallyffiled
two grievances during these years.
‘ 17. In addition to the grievance filed by Mr. Braham on or about November 26, l-999,
regarding a hard-cover book, Mr. Braham filed a grievance on or about June 23, 1999, regarding
the temperature of his food.
18. I was unaware of the June 23, 1999, grievance at the time I signed my August 2002
Affidavit and, as such, it was not inc1uded in that Affidavit. It was not and is not my intention to
omit information from that Affidavit.

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Case 3:00-cv-00261-TPS Document 1 10-2 Filed 04/1 1/2006 Page 3 of 3

19. The remainder of my Affidavit dated August 13, 2002, made in good faith and signed on-
August 14, 2002, is correct. _
l have reviewed the foregoing and it is true and accurate to the best of my knowledge and
beiier. 2 A g
{ E
Michael Lewis
Subscribed and sworn to before me this day of April 2006.
Commissioner ofthe Superior Court} A
Notary Public