Case 1:12-cv-01326-RBJ-KLM Document 118 Filed 12/26/13 USDC Colorado Page 1 of 36

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 12-cv-01326-RBJ-KLM JAMES SARDAKOWSKI, Plaintiff, v. TOM CLEMENTS, et al., Defendants.

DECLARATION OF JAMES SARDAKOWSKI

I, James Sardakowski, pursuant to 28 U.S.C. 1746, declare under penalty of perjury as follows: 1. Im a prisoner at Centennial Correctional Facility. 2. I am 28 years old. 3. Ive been in solitary confinement since December 2009. Pre-Incarceration 4. I lived with my biological mother and father until about 1998 when they subsequently got divorced when I was 11 or 12. 5. I grew up all over the Denver Metro Area. I never was homeless as a kid, but my family moved a lot from one place to another, as soon as we got a notice that we were evicted. 6. In school, I was primarily in special education. I couldnt be regular ed due to some topics confounded me, e.g. history class. I didnt understand most of it. Also, the big numbers of kids in the rooms were very distracting. 1
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7. I experienced physical abuse since I could remember from my biological dad. He drank a lot, i.e. beers, to be drunk. My dad had a job at Coors brewery for twenty years but got fired for drinking on the job. As far back as I can remember he was a drunk. 8. I experienced sexual abuse from my older brother from age four or five until I was seven or eight. He was convicted as a juvenile for raping me. Yet I felt he cared about me more than others did in my family. 9. My mom was a poor care giver all around, in my opinion. I feel that my moms got some form of mental illness, unknown of what kind she suffers from. 10. I also have an older sister. I dont have any contact wither her. 11. Ive been bilaterally hearing impaired since birth. Ive had serious ear problems in childhood. I grew up in a unique setting, where it was a lot of yelling, etc. On one hand its abusive, albeit on the other hand I learned to read lips real well. 12. I started receiving mental health care in 1993, or when I was eight years old. I think it was because of the trauma I got from fraternal rape, but Im not positive due to I was too young to remember what prompted such matters. 13. I first started hearing voices at age 9 or so. 14. I think at age 9 is when I started to take psychotropic medicine. 15. I worried about my safety, when my biological father was physically abusive and would beat me. My biological mother was emotionally abusive. I got used to it so I never think about it unless dad or mom really went nuts. 16. My granddad (my biological fathers father) bought us a trailer in 1996/1997, right before he blew his head off as an act of suicide. The rent for the space where the trailer was paid for a 2
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while by my biological father, and he subsequently stopped paying the rent for the space and we were forced to move. 17. After my parents got divorced, I lived with my biological mother and step father from 1997 until 1998 or so (when I was placed in the mental hospital). My stepdad gave me verbal abuse and physical abuse. 18. My first suicide attempt I can recall was in 1998. I just wanted to die. I took 30 Clonidines (blood pressure pills) on a Saturday night and I lay down in a cross position and fell asleep. I woke up the next morning sadder. This is a time in my juvenile life that a lot of things started to occur. My mom and dad were divorced, and I was living with a new man as a new father in my life, etc. so all these new stresses drove me there. It wasnt a single idea. 19. In 1998 I was having medication issues and therefore subsequently I threatened to blow a kids head off at the last period of school, because he kept harassing me due to he was going to kick my ass after school, which he had been saying to me for weeks. I threatened him to get him to leave me alone. I was sent to the mental hospital called Colorado Mental Health Institute at Fort Logan (Fort Logan). 20. I went to Fort Logan in 1998 and was there for a nearly two linear years, until 2000. 21. I liked Fort Logan a lot. It was a stable environment. I was not being abused in any way, and I was getting my medications regularly. I feared, which I can admit to, of going back to an unstable, abusive environment. 22. On my release I went home to my stepdad and my biological mother. I received care at a transient day care/school center from 2000 to 2002 to get used to being free again. This daycare/ school center was very small in number and they assisted people with mental illnesses and 3
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people like me, released from the nut house to get stabilized, to the streets. In that program I excelled in mathematics. I was starting algebra II, meaning late high school mathematics. 23. When I went back to regular high school in 2002 or so I couldnt focus in class for it was too big and thus I was placed in special ed. And my math teacher Mr. Johnson put me into basic math, i.e. what is 2+2? This was very insulting. I admit I needed special education for reading and writing, and I might needed special assistance not special education in mathematics. 24. In 2002 I started weekly visits to a therapist at outreach community until 2004. I had a stable therapist for almost the whole time. He left in mid-2004 and I decompensated and didnt really meet my new therapist at all. 25. I worked at Chuck-E-Cheese from about 2002 or so until February or so of 2004. This is my sole job Ive had, ever. I was the mouse that did rounds. I also cleaned the sky tubes. Sky tubes are those tubes you see at McDonalds play rooms at some restaurants that got them. I could maneuver well due to my great flexibility I got. I cleaned those tubes due to for example kids will pee in them, or vomit. I also did busing the tables too. I did many simple things like these aforesaid jobs. I can do manual work when Im properly medicated, something with linear steps. 26. In 2002 I was placed on my own. I was forced to leave the nest due to my stepdad and biological mom wanted me to start paying the 1/3 of the bills. 27. I went to live with a guy named Julian. He said I only got to pay $200 a month for rent. This was what I could of afforded due to my job at Chuck-E-Cheese. But this wasnt what occurred. He was extremely in debt. I gave him all of my paycheck, about $300 a month, but it still wasnt enough. Within 5 months we were evicted from the trailer park. Then I became homeless. 4
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28. I lived on streets for a few weeks. Then I went to live with my grandfather for a little bit. I felt uncomfortable to be bumming off him. I was cleaning, etc., but still felt guilty. I went back and forth between my grandfather, sister, etc. I was having major medication issues at this time. When I got kicked out of mom and stepdads house, I got kicked off their insurance, too, so I wasnt getting meds regularly. It was a very struggling time for me. All I had was my clothes and my backpack. 29. During that one year or so of becoming homeless I applied for SSI, HUD, etc. which was subsequently granted. 30. I left school in 2003 in 11th grade. I left school due to (1) Mr. Johnson insulted my mathematic intellect; (2) I needed to try to find more pay for the overdue rent, which I failed; and (3) I had medication issues, which I attempting to remedy through store bought drugs, such as Robitussin to get me sleep and to equate to the feeling of what my antipsychotic meds did. I was trying to imagine the equivalent of what my psych meds were doing, but all I knew was what the side effects were so thats all I could mimic. It didnt help, and the voices never left me alone. 31. I got brave and asked my Grandpa Tom if I can live with him. He agreed. He never charged me for rent, my only duty was to clean for rent. 32. My Grandpa Tom was my adopted grandpa via my moms side. I only knew him for 3 years (2001-2004). He died in August of 2004 by cancer. I took care of his apartment and in return I lived with him for free for a year or so (2003-2004). In the time I knew him I got close to him. 33. His parents came here to America from Poland. He had a strong will when he wanted to. He quit drinking and smoking on his own. He was an all right cook. He aimed to please me. On 5
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my 17th birthday he bought a pack of hot dogs and a crazy octopus hot dog cutter. I think it was a prank and it was. He is a goof ball. I came home one day on fathers day and I bought a huge toy a remote control car and he respectfully declined it so I kept it. He feared that if he was caught playing with it the neighbors would think he lost his mind. 34. Theres so much small stuff I learnt from him, like using toilet paper efficiently. I didnt know how to do it until age 17. He taught me how to electrically wire a battery charger to a battery which the battery led to a light bulb inside a magnifying glass. He taught me how to clean a house. I didnt know how to take care of myself. He pretty much showed me the ropes. 35. I loved my Grandpa Tom. He was brave. Grandpa Tomas Sardakowski will always be alive to me despite he is now dead, and never was a biological link to me. 36. During this time my community outreach treatment center offered me to go live in an assistant living center in Arvada and it was all women, I would have been the only man there. I declined it because: (1) It was all women which Im shy of the opposite sex; (2) I dont like basements, which is where my living quarters would have been; (3) all but 50 dollars would have been taken from my SSI; and (4) I would have been too far away from my Grandpa. Three buses away trip. I cant recall the address of this place, I just recall how alone I would have been. It was five buses away from my biological mother and stepfather. 37. Grandpa Tom died on August 24, 2004. I lived on my own for only 2 or so months before I was arrested. At the time I had my own apartment, I was not working. I was receiving SSI, HUD, discounted bus fares, etc. 38. I was receiving mental health care, yet I didnt get my weekly meetings due to: (1) I was in mourning because Grandpa Tom died and (2) I didnt want to leave my apartment for this 6
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reason. I was also placed on 72 hour mental health watches during this time too, because of feeling depressed. I dont recall the name of the hospitals I got placed on mental health watches at. 39. I was on Risperdal and Depakote on the streets. I had a care provider who come to see me weekly. I had this machine that acted as an alarm clock/ med dispenser which she had to come and fill weekly. This med machine helped out for me to be on medication a regular basis. I didnt pay much heed to it due my extreme sadness of the passing away of Grandpa Tom. 40. The last time I saw my dad face to face was prior to being arrested in 2004, and I got only one letter from him in 2009 when I sent him a letter first. I subsequently sent him stamps, selfaddressed prepaid envelopes, and paper without reply to this very day. 41. The last time I physically saw my mom without talking to her was in medical at the county jail when I was on mental health watch. (She got arrested after I got arrested.) I could see her from a distance I dont know if she didnt hear me but she didnt talk to me. I talked to her on 10/7/04 for the very last time. I got a card on December of 2013 as of this date I am writing. She lies when she writes me and says Ill write more later, and doesnt until next Christmas, saying nothing but Ill write you more later, etc. 42. My Great Aunt Sally and Uncle Jim are my only family I communicate with on a regular basis since my incarceration in 2004. I know them only via my Grandpa Tom in 2002-2004. They have been with me for a long time. They were there when every court date occurred in 2004 to 2006. They are the only ones Ive ever seen in a visit while incarcerated in 2004. Since their visit in 2004 Ive not had another visit by my family since.

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43. I do feel and think My Auntie and Uncle Jim are mine, and I do feel they think Im their nephew. Theyve been emotionally supportive by being in chronic contact since my incarcerated situation. I get a letter every 2 to 4 months by them. They send me pictures, that is to say my Auntie does, of every holiday. So I dont feel lonely due to them. 44. They have bought me subscriptions to magazines. I got one now called Wired they bought me. I read it from cover to cover. I admit some things in it I dont comprehend, like this one article talking about a super virus. They got technical and I got lost in wonderland. I read it all the same to show thanks for it. 45. My Uncle Jim is of ill health and can die soon. It could be years or minutes. He has heart issues, knee replacement, Parkinsons disease, visual issues, etc. Adams County Jail 46. I was in Adams County Jail from 2004 to 2006 waiting to be found competent to stand trial. 47. During this time, I went to the Colorado Mental Health Institute at Pueblo (CMHIP) for testing for a not guilty by reason of insanity plea, and for four or so competency exams. The treatment there was a whole lot better than at the jail. 48. One of the doctors that evaluated me found that I was insane at the time of the crime. 49. When I first arrived at Adams County Jail, I was on mental health watch for two weeks, and periodically after this initial watch occurred. It was all in the county jail infirmary cells. 50. I spent some of my time in the minimum dormitories so I can be watched for selfharming actions more easily than closed celled houses. The dormitories had no closed cells, the walls are halved and segregated that way. If I wasnt in the minimum center or medical then I 8
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was in A unit which has maximum and punitive rooms. Theyre all closed up cells, unlike anything of the minimum center is. 51. If I was in the punitive segregation cells for more than 3 days then I would tell the cops I need to go to medical on mental health watch due to I felt suicidal. The main reason was the voices in my head caused this feeling of suicidal I didnt tell the cops this for a host of reasons, e.g. because they make fun of me when I do hurt myself, etc. 52. I attempted suicide many times by hanging. I had to be four-pointed to the floor many times. I had to be shot with psychotropic medications for an emergency care to calm me down. These things were a result of a lack of proper care on medication management. The medication schedule was irregular, e.g., medicine will look like this: 11:00 am, 1:00 pm, 10:00 am, 4:30 pm, for a 48 hour period. Extend this for months and youll see why I acted out. 53. The only treatment I got was medication, as aforesaid, it was very inadequate. I got no other treatment there. 54. After two years I couldnt take it in the jail anymore so I pled guilty. San Carlos Correctional Facility (SCCF) 55. When I arrived in CDOC I was assigned to San Carlos Correctional Facility. I was there twice. The first time was from November 2006 to October 2007. 56. I lived on 2 left, which was the DD Unit. It was a housing unit for people that had severe needs and couldnt make it in general population (GP). 57. The staff there are verbally abusive and the cops are not good in treating the mentally ill, i.e. they lack training or care towards treating the mentally ill inmates.

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58. I was on C-Level a lot, which was the lowest level where all privileges were taken away. I was in a single cell, with no TV, no radio, nothing. I couldnt take it anymore after awhile. 59. I felt stressed, hearing voices, depressed, suicidal thoughts. I felt suicidal, but no suicidal attempts. I didnt go on mental health watch. I was afraid that if I told mental health about my symptoms I would never get off of lockdown. 60. I was in the SCCF shelter workshop. I folded the napkins for the food trays. And another group in the shelter workshop does sewing and repairing clothing, and making safety smocks and safety blankets for people on mental health watch. This is what I did, i.e. sewing and repairing clothes and making safety clothes. It got me out of the cell and away from the cell so I liked it. 61. I was in the DD Unit for about 8 months before I went to Territorial and was placed in the DD Program there. Colorado Territorial Correctional Facility (CTCF) 62. I was in CTCF from October 2007 to October 2008. 63. I was in the DD Program. We talked about any issues one has got, if any. And if not, we will talk about something, like anger management, that a lot of people got in CDOC. Or we will go around and talk about how all are doing today, etc. There was no set standard on what we were going to do. 64. DD Program wasnt really for mental health treatment. It was for inmates with developmental disabilities and mental retardation. It was an informal group check in on a weekly basis at CTCF. 65. I finished my GED at CTCF. It didnt come overnight. It took nearly 3 years to complete of hard work. (I was working on it at Adams County Jail and San Carlos, too.) I had to learn to 10
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read and write in a new way due to my reading handicap. I now see words in pictographs and I read slow so I found a way to mine the important facts of a sentence, and subsequently the paragraph, then the whole document. I can read most things, but I sometimes say Im illiterate because its embarrassing for me to read out loud. Its hard for me to read out loud if its something I see the first time. 66. When I write I attempt to place short words that are akin to each other, i.e. ergo for word therefore. I dont try to sound smart when I write, I write words that get my point across and be as concise as possible. Lastly, after taking so many pretests, some stories you read are in the final tests, so I got two stories in my final test that I already knew the answers to. 67. I was on medication when I studied for my GED and when I took the test. I was off meds for a week or so when I got the results. 68. I did not harm myself at CTCF. I think the main reason I was not harming myself is due to the openness of CTCF. Youre not locked down at all. All inmates have their own keys to their own cell. You get to come out to use the toilet even, so if I need to get up due to feeling stressed out, etc., then I can take a slow walk to the toilet to calm down. Youre never confined to an 8 square foot room and can pretty much do whatever you want that does not violate the relaxed rules. Moreover you can cell visit, so if my cellmate is driving me nuts, then I can to Joe Blows cell and clear my mind by talking about nothing important. 69. I felt extremely well at CTCF to the point I thought my meds were useless and I stop them. I decompensated badly. I felt paranoid and had suicidal thoughts. I was placed on mental health watch once to be watched to see if Im not suicidal. I had to be replaced at San Carlos due to these issues and to be restabilized on medication. 11
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Return to San Carlos Correctional Facility (SCCF) 70. I was at San Carlos the second time from October 2008 to March 2009. 71. I lived on 4 right, 4 left, and 3 right. 72. I was in 22 to 23-hour lockdown, on average. I came out with other inmates for dayhall for about an hour each day, and we could go to a small yard a couple times a week. I left my cell for showers, medical, etc. The rest of the time I was alone in my cell. I was also on punitive seg sometimes. 73. I was feeling stressed and agitated from being in lockdown. I was feeling suicidal, paranoid, angry, hearing voices, depressed, manic. I felt like killing myself. No attempts, just suicide watches. 74. I was put on Seroquel and I was stabilized after a few months. But I was still feeling stressed and agitated due to the chronic lockdown. 75. In March 2009, I went to Ft. Lyon Correctional Facility for four weeks, and then I was sent to Sterling. Sterling Correctional Facility (SCF) 76. I was at Sterling from April to December of 2009, except when I went to DRDC for a few weeks in November. 77. This was my second new facility in two months. Transfers between facilities were stressful. Its like being forced to move into an unknown neighborhood. What will it be like here? is what I think to myself. I dont know my roommate at all. So, being force to talk to new faces isnt easy for me. I dislike to mingle with others very much. I dont know beforehand where Im going. This is another stressor to me. 12
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78. In GP at SCF I was doing okay until medication issues started. Then I started to have loss of reality, and stressed, which lead to anger, and I couldnt sleep well because I was paranoid my cell mate was going to kill me which the voices said to me. I felt moody, i.e. depressed for weeks, then manic for weeks. My mind is going somewhere, and my body is going somewhere else. Im all over the place, and I cant control it. My words would get tripped up on themselves. Some people would just give me a confused type look. 79. At Sterling theres a bunch of gangbangers there. Im unaffiliated with any gangs. I dont comprehend their mentality due to I didnt grow up in their environment. People in Sterling without being in a gang are picked out and targeted at for victimization. Thus, due to medication problems I became unstable. This correlated to about the time I was singled out for victimhood. 80. Im not gang banger, and got a bad crime. A few saw this and wanted to gain from these issues of mine. So I was approached by gang members who say I know your crime, give me this and that, or I will hurt you or get you moved to ad seg. 81. Id plenty of thoughts of suicide yet no attempts here, that I can recall. I was on mental health watches, I couldnt guess to venture how many. For the reasons of (1) needed sleep, (2) felt anxious, (3) stressed out; (4) voices harassing me, and (5) trying to seek help due to medication issues and wanting to go back to San Carlos to get stabilized. 82. On mental health watch I had to talk to mental health staff through the cell door with others around to hear it. They just talked to me about contracting for safety.1

For a description of contracting for safety, see paragraph 107. 13

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83. I saw in Dr. Lishs declaration that he said I was pretending to be asleep. At that time I didnt have hearing aids and it was hard to hear through the cell door. Sometimes people came to my cell door and I didnt know they were there because I couldnt hear them. 84. Leading up to ad seg, I had a loss of reality. I had trouble telling if I was asleep and in a dream or awake and not in a dream. I felt very sad, and subsequently while being in transit in DRDC, I attempted to commit suicide via hanging. 85. I believe that since treatment was not available, then I couldnt deal with a lot of stress that was building up. I thought that by going to ad seg, I would get some kind of treatment, i.e. anger management, etc. as I was told by the treating clinician. I would not have wanted to go to ad seg if I had been sent to a facility that had treatment, where it wasnt solely medication management. Denver Reception and Diagnostic Center (DRDC) 86. I was sent to DRDC in November 2009. I was there only a few weeks, then I went back to Sterling for a few weeks pending an ad seg hearing, then CSP for ad seg. 87. At DRDC I was in a segregated unit (solitary confinement). 88. I felt suicidal, stressed out, and hearing voices. 89. I tried to kill myself. I told them cops there I was going to do it and they didnt bother to care about me. So after a round I tore my boxers and hung myself. On count time they saw me hanging and ran in and brought me to medical. Smelling salt brought me around and I was placed in the womens medical unit next door, at DWCF for a few days, then returned back to DRDC butt naked for a full day. The mental health refused to give me anything.

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Ad Seg Classification 90. I was classified as ad seg in December 2009. 91. There is no set reason Im in ad seg. A case manager says too many COPD convictions, another case manager will say I was a threat to security and operation on how facility is ran, and a still another mental health worker said its due to self-injurious behavior issues. Colorado State Penitentiary (CSP) 92. I was at CSP from December 2009 to February 2013. 93. The cells in CSP were no bigger than 4 steps of mine, so from cell door to my bunk was close to 6 feet or so. Its always back and forth. The solid furniture consisted of either cement or steel. There was basic furniture one needs to have to live in it, i.e. a toilet, a bed, a desk, and a few storage areas. All cell walls are white, and the cell doors change color by what unit youre in. This is a picture of a cell at CSP:

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94. My cell was acutely unkempt. 95. Im allowed only two books and two magazines, which they need to swap out every time a new book or magazine has come in. 96. One of my two personal books was a dictionary, and the other one was a Bible. I read my dictionary so much that I wore it out. They confiscated it because it was so worn out and taped. I sent a letter to Miriam Webster to ask for a donation so I can have a dictionary. Its like losing a best friend. 97. My days are consisted on getting up between 4:30 am and5:30 am, and find something on TV, if I have one. If no TV, then Ill pick up a book or if I got legal stuff then I read that. I get breakfast around 6:30 am to 7:00 am, dependent on the day and unit youre in. Then I return the trays after about 30 to 45 minutes after delivery. Between the time Im done eating and lunch I go watch more TV, or read and study the law or read a book if no TV. After lunch trays are returned I go back to sleep. This will be around 11:30 am to noon. I sleep until 2:30 to 3:30, then I repeat the breakfast and lunch time routine until medline and dinner are done. Then I go to sleep around 7:30 pm. Then the next day starts and continues as the same. 98. When I was not in OMI (the Offenders with Mental Illness Program), the only time I was out of my cell was for showers. Once or twice a week, Ill take a shower for close to 30 minutes per time, so it was an hour a week out of my cell. I was hand cuffed every time. 99. When I was in OMI, I would go out for groups too. This was about one or two hours a week. 100. I would estimate I spoke to other people less than 2 hours a week. Due to my deafness its hard to yell through the doors and understand it. My hearing aids arent built for it. 16
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101. I had voices in my head, and I felt stressed out, depressed, suicidal. I started tying off a lot due to the aforesaid stress and depression. 102. When I tie off, I get string from any clothing I get in my cell, about 3 to 6 inches long. I wash my hands and string in warm water and soap. I get my testicles skin and loosen it up by gentle rubs, if it aint loose already. Then I take one testicle or two and I take the clean string then wrap it around my loosen testicle skin a few times tightly. I keep it on for a few hours or a few days. 103. I tied off my testicles nearly weekly. 104. When I tied off, sometimes I was put on mental health watch. 105. On mental health watch, you move to a suicide cell. All clothing and personal belongings are taken from you. Youre butt naked with only a blanket and smock thing that cant be worn with great ease due to they are heavy, and dont flex well. Also, its very cold in the suicide cells. So its like punishment. It makes me feel subhuman. 106. I have been on mental health watch more than fifteen times I would say, less than forty though or I hope that it is while in CDOC. 107. You get off mental health watch by contracting for safety, i.e. by saying I contract to not hurt myself or others, and this gets you off the watch. 108. After tying off, I would be put on mental health watch for 24 hours, and then I contracted for safety, and then was brought back to my cell. Thats all that ever happened. Mental health staff dont talk to me about the reason I was put on mental health watch. They dont offer any kind of advice about what led to the mental health watch.

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109. Sometimes I have declared a mental health emergency and mental health staff have never responded. Other times I have been put on mental health watch. When this occurs, sometimes Im placed in full restraints, i.e. the belly chain and leg irons, helmet, mitts, etc. until a mental health clinician comes in and sees me. Below is a depiction of the restraints used on mental health watch at CSP:

110. One time I asked to speak to mental health as an emergency and no one showed up. It never resulted in a suicide watch. I had been on loss of privileges (LOP) for months and needed human contact. LOP is like punitive seg in GP, except that LOP is indefinite. Youre already in segregation, but it takes away all your privileges that are basic. They take away TV, canteen, and phones. Thats all you got. If they take away that at CSP, all you got is a bunk and a toilet. I just needed someone to talk to. C.O. Smith did that for about of an hour. I try to do this with mental health, until they started to punish me these last few years for it by COPD charges, etc. 18
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111. In January 2012 they discontinued my medications. At that time I had been in solitary for 2 years. I couldnt deal with it. I told mental health staff that I was hearing voices, but they did nothing. Instead I got a COPD for covering up my window. 112. In March 2012 I was put on mental health watch for tying off. I was placed in belly chain, a chain with cuffs on it, and ankle cuffs. I was still hurting myself, so what comes next is the helmet and mitts. And after I was still hurting myself, then I was sent to CTCF infirmity, and placed in four points. 113. Four points is where you are put on a bed, and youre laid on your back. (Ankle cuffs and belly chain is placed onto you prior to this lying down). These ankle cuffs are tied down further with a nylon strap to the bed and an extra ankle cuff is affixed to each leg and those ankle cuffs are tied into the bed. Your hands are then hand cuffed to the bed, with belly chain still attached, then finally a nylon strap is placed across your chest in a smiling face configuration. As you can imagine, lying on a steel chain is very funny feeling, and whats worse you cant move at all for indefinite hours of the chain on your back. You are so tied down that every two hours staff must come in and pump your limbs. Its the greatest feeling in the whole world to move your limbs. You get cold sweats when you get close to the pumping time. This isnt exaggeration of mine 19
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of what it was like for me. All restraints above mentioned are all steel except when noting when theres a difference in the type. Above is a picture of the four-pointing bed at CTCF infirmary, with restraints, helmet, and diaper. 114. Four pointing makes me feel subhuman, like Im some type of wild animal that needs to be controlled and tamed. 115. During four pointing, mental health staff just talk to you about contracting for safety.2 They dont ask you about what led up to the incident. 116. I was in four points for three days. I was peeing a lot so they put me in walking restraints. I was in walking restraints for a few weeks. I felt suicidal, stress, and hearing voices. 117. I started requesting to be removed out of CSP. I said I cant deal with it anymore. I cant go back to CSP. A clinician came up with plan you dont act suicidal, you dont become aggressive for 60 days. She said then I could go to the DD Program. I contracted with her, Ill be good for 60 days. 118. After I was sent back to CSP, I was still tying off but wasnt calling medical. I didnt talk to nobody for 60 days. That 60 days it was very stressful. I was tying off but I couldnt get medical. I couldnt show physical injuries or I wouldnt be able to leave CSP. I couldnt tell anyone I was tying off due to it would destroy the contract. 119. 60 days go by, Im asking wheres my reclassification? Every time I ask, no response. I was sending letters to the warden. I started getting paranoid, thinking maybe theyre messing with my mail. I sent a letter to the warden that says Im gonna cut my nuts off.

For a description of contracting for safety, see paragraph 107.

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120. After that letter, a mental health clinician whose name is Alexander (who subsequently became my primary clinician in RTP) comes by and says they want to see you in mental health. I was scared. What are they planning? Last time I went to mental health they put the chains on me so tight I had bruises, and then I was four pointed. I told Alexander, talk to me here. He said no, youre gonna be sprayed [with pepper spray] or youre gonna come out. He said cuff up and I did. They put me in in the restraint chair and I was thinking: What are they going to do? Thats why I blew up. Thinking about what future would hold for me. A video of when they put me in the restraint chair and took me to mental health watch is attached to this declaration as Attachment A. 121. On mental health watch I tied off again. I was sent to CTCF infirmary and four pointed again. This was in May of 2012. 122. You get out of four points by contracting for safety. 3 They said I broke the contract by getting four pointed again, so they said they wouldnt reclassify me. . 123. At CSP I was put back on Seroquel again. I needed something to quiet my mind. I requested it I was out of my mind. Pretty much all of 2012 I was lied to by CDOC. Offenders with Mental Illness (OMI) Program 124. I was in and out of the OMI Program when I was at CSP. 125. The lower levels of OMI were akin to regular ad seg. The only difference was an additional few hours of groups. You were still restrained whenever you were out of cell. Level 5 or 6 and above had more privileges, but the lower levels had to be restrained. In groups I was

For a description of contracting for safety, see paragraph 107.

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restrained to tether tables. Below is a picture that depicts a tether table in the OMI Program at CSP.

126. We didnt do curriculum per se. We used an excerpt from DBT, anger management, etc. It wasnt a set curriculum. 127. OMI changed so much I couldnt remember exactly what occurred, levelwise. The only time you would find out that a change was happening was when it directly affected you. You wouldnt find out until it happened. 128. The highest level I reached was level 5. 129. One time I got my level decreased because while I was having issues with my irritable bowel syndrome (IBS) and I was on the toilet, a cellhouse sergeant told me to cuff up due to she needed to do a cell inspection. I requested a few extra minutes, she said now. So I was having severe cramps and I came to the door so I couldnt stand on my own and I was forced to stand by

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the guards pushing me against the door. I got chrons4 that resulted in a level drops. Thats all I did to get my level decreased. 130. I stopped going to groups because I was frustrated. It was so easy to get your level taken after so much hard work. You try for two months and then one little thing gets your level taken. 131. It was hard to progress because even if I said something wrong and got a chron, I wouldnt know. They wouldnt tell me at the time. Then later you get your level taken and you dont why. Its not the mental health staff that take your level, its correctional officers. Mental health isnt even involved. Theyre supposed to review it, but they probably wont give your level back.

A chron, or chronological report, is a report about an inmates behavior.

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Residential Treatment Program (RTP) at Centennial Correctional Facility (CCF) 132. I have been in RTP at CCF since February 2013. 133. No one told me why I was being put in RTP. 134. CCF RTP, in my experience, is just like ad seg, except Level 4s get one extra hour out if one chooses to go to the outdoor yard. Thats what Ive experienced. Everything, from attire to canteen, is all the same as ad seg, including my cell. Here is a picture of my cell:

135. RTP is identical to OMI in the lowest levels. Ive made it only to low RTP levels (level 4 and below) so the higher levels I cant say. Its the same pork chop with a different side order. 136. The highest level I reached in RTP is Level 4. 137. RTP Level 1 is exactly like loss-of-privileges (LOP)5 in CSP.

For a description of loss of privileges, see paragraph 110.

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138. On RTP Level 2, the only thing different from Level 1 is group and a TV. It is the same as lower levels of OMI at CSP. 139. Level 3 is exactly like Level 2. 140. Level 4 is exactly like level 2 except the addition of day hall with other offenders for one hour 5 times a week. One has to take a shower during this dayhall time. 141. I leave my cell on a weekly basis less than six hours, including groups. On Levels 1-3, I leave my cell for one hour five times a week to shower and go to the dog run (outdoor recreation). The only difference on Level 4 is that shower happens during day hall. This is if Im not on a facility lockdown, which happens regularly for many reasons, e.g. a cell extraction, or not enough staff, etc. When I go to court or attorney visits, this can increase my out of cell time. 142. On Levels 1-3 Im always restrained when I leave my cell. On Level 4 Im unrestrained when I go to the day hall or dog run - I go there unrestrained and then once there I get put into the fenced cages, i.e. dog runs, and locked in there. All other times Im restrained, e.g. going to attorney visits, medical, etc. To the right is a picture of the dog run. 143. Cuffing up hurts. Its hard for me to walk unrestrained already due to back pain, and cuffing up forces me to take smaller steps and thus its hurting my back due to its an unnatural walk to me. I wobble when I walk, i.e. nonlinear steps. This makes me feel like a dangerous animal that has no control, and that will attack

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anything that dares to glance at me. Which Im not. Im not sub human at all. 144. On Levels 1-3 Im served meals cell side. On Level 4 I go to the pod slider the door that separates the unit foyer and the pod itself and get served on the tray, which I take back to my cell. All meals are eaten in your assigned cell on Levels 1-4. 145. The main reasons they cancel out of cell activities are: (1) not enough staff; and (2) an inmate causing a facility disruption that forces cell house staff to go address it. 146. I leave my cell because I need showers, and I feel groups are sort of helpful to gain socialization skills. I just need to re-socialize for being locked up for nearly 3 years without human contact. Being without restraints on is something new to me. 147. My interactions with inmates is far and few between. I interact with other inmates only at groups and level 4 day hall. These aforesaid interactions happen at the kidney shape therapy tables, cell side, and level 4 at times face to face in the day hall. 148. Ive gotten so used to being alone that I got fears of having a cell mate for this will be a major change in my nearly four years of aloneness. 149. I have continued voices in my head. Im stressed out and depressed. I chronically think of offing myself. I dont attempt suicide here yet. 150. I tie off nearly weekly, same as CSP. 151. I have not been put on mental health watch here at CCF, yet. 152. Groups in RTP are like OMI. In OMI and RTP its curriculum, only, being taught. RTPs only difference is rec group, where you play card or board games. You dont talk about individual treatment plans in RTP groups, unless one shares it themselves.

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153. I think youre supposed to complete the curriculum before moving to the next level. But Robinson, right in the middle of Level 3 curriculum, put me and a few other inmates up for Level 4. So I moved to Level 4 without completing Level 3 curriculum (STEPPS). 154. No one from mental health talks about my individual treatment plan. Never have in CDOC that I can recollect. I dont even know if I got any goals. They never tell me how to achieve these goals, if I got any at all. How do I achieve something I dont know exists. 155. All levels, except Level 1, get groups as far as Im aware of. The groups happen in the dayhalls and Im restrained to the tether tables. This is true for all levels Ive been (levels 1-4). 156. Im supposed to have two normal groups a week and one rec group where you play board games/ card games. Theyre about an hour long each. Yet this does not happen. Groups are canceled because of lockdowns and for unknown reasons. And about once every two weeks they play card games during the curriculum groups. 157. I dont find out that a group has been canceled until the next group session or next day, whichever happens first. We are not told why they are canceled. They are not made up later, not in my personal experience. 158. I dont feel comfortable talking about some things in groups. I dont talk about childhood or tying off in groups. There are no opportunities to talk about these things in other settings. 159. I interact with mental health staff only at groups, records review, and the rare one-onones I get. In 2013, Ive only had 1 one-on-one, and it was not confidential.

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160. Ive not had the same mental health clinician consistently, its always been less than one year with the same person. CDOC gots a high turnover rate so I can see one person for a few months and see another person. 161. I dont got relationship with my clinicians. As aforesaid Im chronically changing to someone else. I dont trust them enough to build a relationship. I only talk to them when Im in need of something, like I do to the cops. I feel they dont care what my needs are. If its a personal issue I will never talk to them about this. I dont trust them one iota. I do my own therapy, i.e. tie off. 162. The only time I felt okay to talk to mental health staff in CDOC was the testing with Dr. Kaprivnikar at San Carlos. I feel she is honest. She cares and understands me as me. She is a super rare find in CDOC in whole. Ive not seen another person like her in CDOC. I believe she knew enough, not everything, about me to make adequate diagnoses. And youll note that the results are a mental illness, paranoia. Dr. Haney and Dr. Burns were akin to Dr. Kaprivnikar so I opened up to them. I wish I could have Dr. Koprivnikar back but I dont think thats even a remote possibility. She helped me a lot with medication issues. 163. My group clinician, Robinson, has a silent agreement with me that we will agree to disagree. Theres a strong dislike between me and her. Last week I didnt want to participate in group because Robinson wanted to sit me next to a sex offender. Because of my history (I was raped by my brother in my childhood), I dont feel safe around those people. I asked if I could sit in a different empty seat, but Robinson told me to sit there or go back to my assigned cell. I went back to my cell. Its not good for me to be around those people. It brings up issues for me.

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164. I meet with mental health staff one-on-one rarely. I had only one this whole year. It was with Robinson in the day hall, not confidential, because other inmates can hear you from their cells. The ones with Alexander were mainly records review. He talked with me on nothing important, non-mental health wise, like you would think of therapywise. The encounters were: how are you doing? got any issues by anyone picking on you? got medication issues? etc. Nothing that was like, e.g. Why do you tie off, type of questions. Its not therapy, just general review of my state of mind. Ive never had a true one-on-one (in private) with any clinician in RTP to talk about my issues. 165. Alexander was my primary clinician. Alexander and I had not gained a relationship in any form when he was here. He left around when I got my Level 4. I had no primary clinician for about 3 weeks or so. Now my clinician is Dr. Diaz, I think she is new to CDOC. I talked to her for about 10 minutes this week about records review. I asked her when I would see her for a true, confidential, one-on-one, and she said she might schedule it in the future. 166. I never see a psychiatrist. I see a physician assistant only (P.A. Waters). It has been like this ten months now. 167. Sometimes in CDOC you see psychiatrists on telepsych, sometimes its face to face. When its telepsych, this is on the TV, and you talk about medication issues, and general questions about how your state of mind is. Not in very much detail. 168. I have no input on the medications I get. I can say such and such works, yet the P.A. has sole authority to choose. 169. In my most recent med appointment P.A. Waters offered me Risperdal Consta injectable. 29
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170. Dr. Lish paraphrased that I should of requested Risperdal Consta on my own behalf. I wish to emphasize that Im not a practitioner of medicine and did not know Risperdal Consta existed until I saw the plaintiffs expert Dr. Burns who brought it to my attention. How can I ask for something I did not know that it was possible or available? 171. All meetings with mental health havent been confidential except P.A. Waters medicine review, and even then cops are right there. 172. I dont really know what the requirements are to progress in RTP. I can tell you what it took to get my Level 4. I had to fill out a sheet about how many groups I attended, why do I think Im ready to progress, etc. But I never filled out that sheet to progress to the other levels. It changes so much that I dont know if thats still the requirement. 173. Its hard for me to progress because the times are too far apart from level to level. I can comprehend two weeks, but beyond that it gets really stressful. I get too stressed out, trying to get the next level and stay out of trouble. The byproduct is my behavior, because of my stress. You say something wrong, you get your level taken. Its hard for me to control what I say. Im stuck in this rut. Im stressed about the timeframe and all the requirements. All these little stress factors build up to a volcano and I explode. I dont have nobody to talk to relieve my stress. The level system is too long for me to progress. 174. The staff says you go back to GP if you pass your Level 8. This is like saying to me: you will get released tomorrow and become the president tomorrow evening. Its not possible for me to get this notion. Its too long of a period for me to comprehend. I think I could get to higher levels if I had shorter term goals.

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175. I dont feel like I have control over my behavior. My behavior is randomly picked. If I feel upset then I act out behaviorally, i.e. tying off, etc. Its worse in ad seg, because I cant walk away from the situation to try to think rationally. You build up a lot of stress that you cant release. I implode, e.g. harm myself or explode, e.g. get sprayed with pepper spray, which affects the rest of the facility (they have to go on lockdown to deal with me). I never reached this level of self-harming tactics until I got to ad seg. In GP I could get to the point where I could think about my actions, but here, what do I have? I can stand at the door, then walk back to my bunk. 176. The reason I have been doing better is because my attorneys visit me on a regular basis, which helps reduce the everyday stress of being in my current confinement. Its confidential i.e. no other inmates around, and I can express openly what I do as self-harm, my crime Im in prison for, etc. Im not stuck in the cell thinking about the things that stress me out. Symptoms 177. I hear a voice all the time. From when I wake up to time I go to sleep. Sometimes one voice, sometimes more than one. They never stop. This happens even when Im around other people, in RTP groups, etc. 178. Medication helps me ignore the voices. Let me give an analogy: imagine you got a radio in your head. Now think about how you have no control over on how loud or silent it becomes, its always on to certain level. Without the external assistance its like death metal, front seat, concert loud that wont never quit and changes tune when you get used to it. Its equivalent to sleep deprivation tactics used at the infamous Gitmo terrorist prison in Cuba. Youre forced to be awake until you faint. This is nerve wracking. This is what its like when I am off medication. Now imagine this aforesaid allegoric statement going on for months or even years. On the flip 31
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side, imagine you are listing to soft music thats repetitive and annoying yet you can deal with it. This is what its like on medication for me. The voice will always be there and it can be managed. This is why I hate trying new meds. Its not the fact I hate trying something new, its the fear of self mental terrorism that no one can hear. 179. When Im off my meds, I feel everything the way one does when theyre sleep deprived, e.g. slow to comprehend, uncontrolled outburst of emotions, etc. My senses are lot stronger so food tastes funny, I will miss meals due to it. I get lost in my mind by the simple feel of a brick wall. I see messages in them walls too, etc. I cant sleep well, Im agitated. Dreams blend with reality and vice versa. Lost is the best word I can think of. When this happens I just do everything, e.g. watching TV, etc., until passes over. When I take medication those intense moments are less frequent and the duration shorter. 180. Since when I heard my first voice, age 9 or so, I havent obtained nothing to help me thus far besides meds. 181. The voices make it hard to sleep at times, when the meds are not working well. On a bad night I sleep an hour at best. I dont want to stand in the shower due to my tiredness. Standing and talking is tiresome. 182. I see things too. Mainly humanoid shapes. Its fortnightly on average on medication. Off dope I see them daily at a time, then they go away for a time and come back to harass me, then go away again, etc. On medication it lasts a few hours. Off meds it lasts a few days up to a week. This happens even when Im around other people. The worst was a two and a half week period off meds in 1997/98 when it was my humanoid grandpa, the one who killed himself.

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183. I wish to state that no doctor prior to my incarceration in 2004 never diagnosed me with a personality disorder such as conduct disorder, antisocial personality disorder, etc. Theres no record by my two year linear stay at Fort Logan, staffed 24/7 by mental health only, that ever said such a thing. 184. I feel stressed and anxious a lot due to my current confinement and my phobias. The government makes me anxious, and my aging family causes me to get stressed out because I dont know how theyre doing and I worry about them. 185. When I feel anxious, I feel like Im choking and my body feels itchy and unclean. 186. When this happens I clean my cell. This I really never do unless feeling a lot of worry. To clarify, cleaning my cell is a sign of anxiety and it does not help me. 187. I tie off if the anxiety is real bad. The anxiety causes stress and thats the reason I tie off. I also tie off in response to hearing voices. 188. I tie off one testie for stress management. I tie off for a few hours. It feels good when I break the string. Its like a runners high some get after a great run. 189. I tie off both testes when I feel I sinned greatly by lusting. Then I attempt castration. Those are the ER visits. The holy word of my God is telling me to be a eunich. I tie off for days, until I cant stand it no more. It becomes very painful. I cant bear days of it I lose spiritual strength and tap out. I almost succeeded once in 2012 by self-castration. That is when I almost lost them. 190. I tied off the most at CSP and here at CCF. 191. I tie off weekly. Rarely I will go a fortnight without tying off.

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192. Things I started doing after being ad segged in 2009 are head banging and biting holes, or attempting to, in my hands and lips. 193. In ad seg, I have gained a phobia of touching others, or the thought of such increases my heart rate. I dont like talking about it for my skin gets all wormy feeling. CDOC Response to Symptoms and Self-Harm 194. I told CDOC staff about the voices. They all appear to not take me serious. I believe P.A. Waters is the most disinterested about my claims. When I brought it up he was trying quickly to change the subject. At least the psychiatrists, most of them, would have asked is it bothering you, or akin to this question. Their tone of voice was like I heard this story before, repetitively, from many people. Like todays newspaper Ive already read so why would I read it again? Theyre just in a rush. The only one that ever seemed interested is Dr. Kaprivnikar at SCCF. She tries to get detailed. What are they saying to you? When do you hear them? She doesnt have that tone of I gotta go to lunch. Shes not in a rush to go nowhere. Albeit, I cant tell if she is genuine or a really good actor. 195. I told CDOC staff about seeing things but they didnt care. They respond to me like when I tell them about the voices. 196. I have told CDOC staff about tying off. They were at first caring then turned coldly. One nurse refused to care for it in January through March 2012 area and made me take the string off while the cops gave me staples, paper clips etc. Nothing sharp, so I had to pull the string around my testie. The cops watched me do it. This was all in my cell. The same nurse refused to do it in May 2012 and the cops did the procedure while she watched in medical.

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197. Sometimes when I tied off, I started to get Code of Penal Discipline charges of misuse of clinical services and advocating a facility disruption, as well as getting charged financially of thousands of dollars due to going to the ER. I can never pay it off while in prison. 198. I get into trouble for tying off now, so I tell no one now. But finally I decided to try to tell P.A. Waters. I told him in October 2013 that I am still tying off and how I dont tell mental health staff due to Im afraid of getting punished. He didnt say anything about it, didnt even write it down. 199. I feel telling CDOC staff about tying off would affect my RTP level. I can receive COPD charges. So if I say I need medical, I tied off weekly, I can get punished by having privileges taken way TV, canteen, etc. or by getting my level reduced. I dont want to jeopardize any more COPD, financial losses, etc. due to this self harm. 200. I dont know and never known whats in my treatment plan since I came into prison in 2006. Tying off has never been addressed in one-on-one sessions, so I will assume its not in any treatment plan, due to it would be brought up more often. 201. I have told CDOC staff about suicidal thoughts. They just hurry up and try to get me off suicide watch. They just try to get you to contract for safety, with nothing else in mind, i.e. do you still feeling like hurting yourself or others. If I say yes then they leave, if no, the same. I return back to my cell then, etc.

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Plaintiff's Exhibit 4