Stop abuse in SCI Smithfield's Behavior Management Unit

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Pursuant to the 1st and 8th Amendment of the US Constitution:

We are people of the law who understand the law and respect the law and the courts. We have read civil action number 1:18-CV-270 filed in the Middle District of Pennsylvania by plaintiffs Damont Hagan, Thomas Davis, and Raphael Spearman. We have also read the declarations in support of their allegations.

The plaintiffs have established a prima facie case that they, and other inmates in the Behavior Management Unit ("BMU") are being subjected to:

  1. Bright lights while they are trying to sleep;
  2. Sexual harassment by way of strip searches that malicious correction offices are permitted to do under pretext per policy;
  3. Sexual harassment by way of pat searches that policy does not authorize;
  4. Being placed into feces-infested cells;
  5. Having their property taken from them arbitrarily; and
  6. Receiving false misconducts for reasons to subject inmates to strict procedures.

Furthermore, the plaintiffs have established a prima facie case showing that supervisor staff at all levels of administration have participated personally in the violations in one way or another.

With the understanding that plaintiffs have exhausted their administrative remedies, and that the declarations in support create issues of material fact, we are calling on defendant John Wetzel to save all parties and the courts precious time by doing the following:

  1. Remove plaintiffs Damont Hagan, Thomas Davis, and Raphael Spearman from SCI Smithfield's BMU immediately;
  2. Reinvestigate Damont Hagan, Thomas Davis, and Raphael Spearman's allegations mentioned in the complaint in a way wher all the evidence is looked at evenly instead of completely tilted in staff's favor; and
  3. Make the necessary corrections to SCI Smithfield's BMU so that the problem does not occur again.

Lastly, we request that you note that we will continue to follow civil action number 1:18-CV-270 throughout the entire course of the litigation, and will offer assistance to the plaintiffs when necessary.



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