"..

stATE,O"J1~0RIl!>a"
DEPAAltMEN'r;(ihrt:o~crIONS
.' .... ,..
.

..'-

.....

OFFICE OF TREINSPEeTt>ll GENERAL

MEMO

To:

Gerald Abdul-Wasi
Inspector General

FROM:

Daryl J. McCasland

DATE:'

01/15/04

SUBJECT:

Administrative Investigation at Charlotte Correctional
Institution

Case Summary:
On 06/11/03, at approximately 10:00 p.m., the interior perimeters fence alarm
sounded at Charlotte Correctional Institution. Sergeant Pate observed a ladder
against the interior fence along with an inmate betWeen the 2 security fences.
He further observed 2 other inmates at the (interior) fence.
During the
recapturing efforts, it was discovered that inA dorm, an officer was found dead
along with 2 additional inmates who had serious injuries. On this date, I was
assigned as the lead inspector in this case. ,The Florida Department of Law
Enforcement (FDLE) was contacted and responded. They assumed the criminal
investigation (FDLE case numberFM-Ol-0014) under the current Memorandum
of Understanding (MOD).
On 06/18/03, I was advised to address any
administrative issues that might be found in relation tqthe events of
06/11/03.
. It should be noted that this investigation's primary focus is on the 3 rd shift (the
incident occurred on this shift) and its relationship to A dorm, which began
renovation on or about 04/19/03. The time frame of this investigation is from
a meeting that took place on 03/27/03 (explained in a following paragraph) and
06/11/03 (the night of the incident). In addition. testimony indicates that A
~orm was being..§.upervised in the same manner as all of the previous dorms
'. that were renovated.
' .

---

At the time of this incident, Charlotte Correctional Institution was undergoing
major renovations of several dorms in order to house additional close

management inmates. During renovations the dorms under construction,
including A dorm, were not operated as a secure housing unit.
On 03/27/03, a meeting was held at the Institution and attended by Director
Dugger, Bureau Chief Cain, Assistant Warden Anglin, Correctional Security
Consultant Howdeshell (who became Colonel at Charlotte on or about 04/14/03)
of Central Office, Regional Director Villacorta, Maintenance and Construction _R.~/6A-1}LOfficer Rogers, Construction Project Consultant Shidler of· Region 4 and
~~jUnM
Warden Cornell, Assistant Wardens Boyett and White and Colonel Jordan (who
left Charlotte on or about. 04/ 1 0/03) of Charlotte Correctional Institution. The
purpose of the meeting was to address the construction needs of the facility,
locating inmate tradesmen; time schedules for the completion of the project
and special inmate work c9nsiderations. Because of the increase of activity
inside the construction dorms, Shidler requested to have 2 security staff
present in construction dorms during construction hours. Central Office staff
approved the request without giving any specific directives and so it was l<;ft to
Warden Cornell and the Charlotte staff to implement the request. During
weekly status reports forwarded to Central Office, Cornell indicated that 2
officers were being assigned to each of the construction dorms while inmates
were working in the dorm. However, no evidence was found during this
investigation to indicate that there were ever 2 officers working in this area
during evening hours, or that this requirement was effectively communicated to
the shift supervisor(s). ~rther information found that shift supervisors never
questioned the ambiguity 01 a memorandum put out by AsststtffitWarcren
~~ett that indicated conflicting instructions as to how the construction dorm ,
was to e
pervised, in-that on the one bana there was to be 2 officerssupervising the inmates and on the other hand, there would be no less than 1
officer in each of the dorms.
It should be noted that shortly after the meeting on March 27, 2004, pre-

arrpngedpersonnel changes were made at Charlotte. Assistant Warden White
left during the first week of April. Colonel Jordan (who took a position as Major)
left on or about 04/10/03. Colonel Howdeshell arnved as the new Colonel on
or about 04/14/03. Mr. Cannon (former Colonel at Santa Rosa Correctional
Institution) arrived as As~istan,t Warden of OPerations on or ~bout 04/28/03.
It should also be noted that Mr. Boyett moved from Assistant Warden of
Dperations to Assistant Warden of Programs just prior to Cannon's arrival.
This investigation also found several administrative concerns. These include
the following. No one from Charlotte's administration appeared to monitor the
construction project beyond the normal duty hours to ensure that manpower
was being utilized properly. No one from the administration recognized or
enforced the policy requiring all staff entering the institution be required to
wear a body alarm. Inmates were riot placed in restraints during movement
after Master Roster Count pursuant to policy requirements. Key control was

riot adhered to or monitored. Sensitive tools were not secured as policy
dictates. In addition, required security checks were not made or monitored to
ensure compliance with policy.
The above mentioned administrative concerns are evidenced by the following.
On the day of the attempted escape and murders, there was an optimum level
of security staff on duty (41 officers were on duty, while only 32 officers were
necessary to fill all essential posts), but only one officer assigned, to supervise
the work crew in the construction dorm. Security records do not properly
reflect any staff being assigned to or actually working inside A dorm during the
3 rd shift. Testimony indicates that staff were not consistent in their issuance or
wearing of personal body alarms and that security records and evidence
indicate that Officer Lathrem was not found _to have checked out or to be
wearing a personal body'alarm at the time of the incident (although she was in
possession of a radio that may have had at1Janic button" on it. The status ofthe
radio cannot be detennined at this time because it has been held as evidence
with the Florida Department of Law Enforcement). Testimony indicates that
inmates working inside A dorm after Master Roster Count were not placed in
restraints while being escorted back to their assigned dorms. Security records
and testimony indicates there was a lack of accountability as to key control as
it relates to A dorm.- Testimony and a lack of records indicate that sensitive
tools were not removed and stored in an area located outside the secure
perimeter when not·in use..Security records and testimony indicates that little
if any security checks were completed on A dorm dUring the nighttime
construction detail.
SUPPORTING EvIDENCE:

Finding(s) #1:
F.A.C. 33-208.001, (4)(a) (Administration and enforcement of rules),

Stafffailed to enSure that 2 officers were present when construction was
taking place in dormitories. This is evidenced by the following:
Evidence:
• Director Dugger indicated that during a . . meeting (held on03/27/03) Charlotte staff requested to have 2 correctional officers
in each (construction) dorm. It was approved to have 2 correctional
officers working in the dorm at all times. However, there was no
discussion of an after hours work detail that was welding
footlockers after Master Roster Count.
• Regional Director Villacorta indicated that a determination was
made during the meeting to have 2 security officers on duty at
each work site and that it would be a IO-hour workday. There was
no mention about an after hour work detail.

_',

. l "..~"'.lt

I

•

Maintenance and Construction Officer Rogers indicated that
during the meeting, Mr. Shidler requested to have 2 (correctional)
officers in each (construction) dorm during working hours. The
request was based on additional inmates being needed to
accelerate the project.
The wardens (warden and assistants)
agreed. There was no mention of an after hour work detail.
• Construction Project Consultant Shidler indicated that during the
meeting it was discussed that due to the acceleration of the
project, additional inmates would be brought in to assist. Because
of this, he suggested to have 2 security officers inside the dorms
during construction hours. The request was granted. There was
no mention of an after hour work detail.
• A review of weekly status r~ports from Warden Cornell to Director
Dugger indicates Cornell advising Dugger that there· are 2 officers
assigned to each dorm during renovation work hours. In addition,
more recent status reports indicated Cprnell advised Dugger that
officers were supervising small numbers of painters and welders
after hours in G and A dorms.
• A review of a memorandum dated 04/02/03, to shift supervisors
from Assistant Warden Boyett indicates that "Two Officers will be
assigned to work in each dormitory under construction: One from
'lAM t03PM. One from9AM to 5PM (At least one Officer must be
in the dormitory at all times, no exception)."
• Officers Millard, Giddens, Claudio, George, Behrens, Ciofani and
Sergeant Sharkey, from the 3 rd shift, indicated that when they
worked A dorm, they did so alone and without any assistance.
• Warden Cornell indicated that during the meeting, Mr. Shidler and
Mr. Rogers requested to have 2 (correctional) officers per dorm to
provide security. He agreed and it was decided that they would
"assign 2 officers to each construction donn during conStruction
hours. " The decision was to have 2 officers for whatever hours they
were working in whatever dorm no matter what shift.. «After· hourJ}
to him meant whenever the inmates worked past the 5:00 p.m.
count and that OPS staff had left for the day and on work done on
Sundays. He was not aware that only 1 officer was supervising
inmates during· the 3 rd shift.
Cornell indicated that the
responsibility to initiate the 2-officer directive fell with Colonel
Jordan who· was also present at the meeting. Cornell indicated
that he did not have any further discussion with Jordan about this
because he was at the meeting and heard the same thing as he
did. As for his weekly status reports, he was told that they were in
compliance with having 2 officers present in the dorms however, he
cannot recall who advised him of this. The reports were shared
with Mr. Boyett, Mr. White, Mr. Cannon, and Colonels Jordan and
Howdeshell. Cornell indicated that he assumed word of the 2-

• - .',

rU.~v

rr

oJ

officer directive had filtered down to the shift supervisors because
when he walked the compound after 5:00 p.m. he always observed
more than 1 officer present in the dorms. Cornell indicated that he
was never informed of any concerns regarding a lack of security
during the construction project. Cornell acknowledged that there
should have been 2 officers inside A dorm during the 3 rd shift.
• Assistant Warden Boyett indicated that he was responsible for the
conversion project and that Colonel Jordan was aware of what was
going on. He established the after hour detail so that footlockers
could be welded to the bunks. I:Ie had Lieutenant Smich supervise
the detail; however he gave no direction or instructions on how the
detail was to operate. He was not aware that the detail was
working past the Master Roster Count nor did he authorize them
to' do so. During the March meeting, they received direction from
Central Office staff that there would be 2 officers present whenever
someone was working in the: dorm. It was his understanding that
there would be 2 officers present during both the 2 nd and 3 rd shifts
. whenever inmates were working in the dorms. After the meeting,
he i:s sure that Mr. Cornell had told him to take care of it; however
no one told him how to set it up. Even though he and Jordan
spoke about the scheduling of the 2 officers in the dorms, he
cannot recall what he specifically told Jordan. The purpose of his
memorandum to the shift supervisors was to let them know what
was going on in the dormitories as it related' to the CM. conversion
project and what steps were to be taken so that they finished the
project in a timely manner. He had scheduled the specific hours to
be worked and the reason for the 2-hour gap (where only 1 officer
was scheduled in the donn) in the beginning and .the end of the day
was so that no over-time would be accrued. The reason he put
that at no time would there be less than 1 officer, was because at
times an officer would have to go to food service and get trays to
bring back to the construction dorm. Boyett indicated he considers
the footlocker detail part of the construction project and there
should have been 2 officers present in the dorms while they were
working however, he forgot to address that particular detail in his
memorandum. Although not copied to Jordan, he sent the
memorandum by the computer. Also, when Colonel Howdeshell
arrived at Charlotte, he was advised of the memorandum. Boyett
could not be sure if he advised Howdeshell that he had an after
hour work detail that was addressing footlockers. Boyett indicated
that he did give a copy of his memorandum to Mr. Cannon. Boyett
indicated besides his memorandum to the shift supervisors,
Jordan had advised him that he had told the shift supervisors to
have 2 officers in the dorms anYtime work was being done, to
include the welders in A dorm. Boyett acknowledged that he did

not establish a procedure to monitor the 3 rd shift to make surv"
they were in compliance of having 2 officers in the dorm while the
detail was working on the lockers. He also indicated that he had
advised Cornell that they were in compliance of the 2-officer
directive so that Cornell could complete his weekly reports.
Although he did not advise Cornell each time a status report was
completed, he believes Cornell probably assumed they were in
compliance because of his (Boyett's memorandum).
• Lieutenant Orzechowski indicated he was never instructed to have
more than 1 officer" in the dorms (under construction) at night nor
does he recall seeing Mr. Boyett's memorandum.
• Captain Davis indicated he cannot recall ever being told by anyone,
including Colonel (Major) Jordan, to have 2· officers in the
construction dorms whenever inmates are working. There was. a
time in late March, early April, when he was under the impression
that he was to supply 2 officers to the dorms. He cannot recall
how he got that impression. He continued to supply the 2 officers
until he received the 04/02/03 memorandum from Mr. Boyett that
indicated he was responsible to supply 1 officer from 4:00 p.m. to
5:00 p.m. or to have 1 officer in the dorm at all times. He was not
given any guidelines or directions as to how to supervise the
inmates. When asked why he allowed the crew to work· past the
Master Roster Count, he indicated that no one had directed him to
, work past the Count, however a lot of information was passed on
between the officers (working in the donn) and not through him.
He feIt that the hours of operation were going the way it was
. suppose to. Davis admitted that he did not have a lot of control as
to what went on in the dorm. He indicated that he could have shut
the crew down if he wanted to but he did not h~ve a reason to do
so. He also indicated that he could have shortened the hours
worked in the dorm, however he did not see this as a red flag .
(warning sign) . .At no time did he check with the Adrninistration to
verify if the nighttime detail had been authorized; what they were
to be working on; how they were to be supervised; or how many
hours they were to be working. .He also indicated. that at no time
did Colonel (Major) Jordan advise him to have 2 officers pulled
from his shift and place 1 officer in one dorm and another officer in
another dorm.
Finding(s) #2:
The Personal Body Alarm Procedure, 602.023, indicates that all
Department personnel will be required to wear a personal body alarm'
device while inside the secure perimeter. This policy was not followed in

that the majority of 3 rd shift staff working in A dorm were not in
possession of body alarm devices. This is evidenced by the following: Evidence:
•
•
•
•

•
•
•
•

Officer's Millard, Giddens and George indicated they did not use a
body alarm when working in A dorm.
Officer Claudio and Sgt. Sharkey indicated they could not recall if
they were issued body alarms while working in A dorm.
Officer Behrens indicated she used a body alarm in A dorm
however; no one ever called to test· it.
, There is no indication that on 06/11/03, Officer Lathrem had been
assigned or was in possession of a personal body alaxm. There is
an indication she was in possession of a radio that had a "panic
button" on it.
Sergeant Meier, the control room supervisor for the 3 rd shift,
indicated that personal body alarms were not generally issued to
security staff with radios unless specifically requested.
Lieutenant Orzechowski, the "relief' shift supervisor for the 3 rd
shift, indicated that· he did not routinely follow up to see if
everyone h~d an alarm.
Captain Davis, the3rd shift supervisor, indicated he was aware the
policy was not being adhered to however; it was not an area he
"looked into".
Assistant Warden Boyett (Operations) indicated he has observed
staff not wearing personal body alarms and that when he observed
this he would address the non-compliance at once.

Finding(s) #3:
The Inmate Transportation and Movement Procedure, 602.024,
indicates that inmates assigned as Housing Levels H04 or HOS are
required. to have handcuffs behind the back, side cuffs or waist chain
with C&S handcuff cover during escorts conducted after Master Roster
Count. It was found that this procedure was not adhered to. This is
evidenced by the following:
Evidence:
• Warden Cornell stated that he knew inmates had been assigned to
the locker project during the evening hours (after 5:00 pm), but did
not know they were working past Master Roster Count.
• Assistant Warden Boyette said he was responsible for the
conversion project while working as the Assistant Warden at
Charlotte CI. He said that he started the evening project which
required inmates to weld lockers in A dorm, but he had no idea

•

•
•
•
•

•
•

•

they worked past the Master Roster Count. He said he did not
check with the Classification Department 'to verify the Housing
Classification for inmates assigned to this project.
Classification Supervisor Mount advised that the inmate and
transportation movement procedures were not considered for the
conversion/ renovation project because the inmates were supposed
to be working during day-light hours only.
Classification records indicate of the 5 inmates working in A dorm
on 06/11/03, (1) was classified as an HO-3, (2) were classified as
HO-4 and (1) was classified as a HO-S.
In reviewing 3 rd shift Control Room Logs it was found that the
Master Roster Count was conducted at 8:30 p.m.
In reviewing Formal Count Sheets for the period of 04/ 19/03 to
06/11/03, it was learned that inmates were working in A dorm
during and after the Master. Roster Count.
Officers Millard, Giddens, Claudio, George, Behrens and Ciofani
indicated after Master Roster Courit, they would escort the inmates
from A dorm-to their respected housing dorms without being
placed in restraints.
Sergeant Sharkey could not recall if he placed restraints on the
inmates when he escorted them from A dorm to their respected
housing dorms.
.
Lieutenant Orzechowski, the "relief' shift supervisor for" the"3rd"
shift, indicated that his understanding of the policy is that if
inmates are escorted by 2 officers, then they did not need to be
placed in restraints. It is his understanding that 2 officers were
involved in the escorts.
Captain Davis, the 3 rd shift supervisor, indicated that the only
reason he can give as to why the inmates from A dorm were not
placed in restraints was because it has always been the way the
escorts have been done.

Finding(s) *4:
The Key Control and Locking System Polley "and Pr9cedure
Directive, 3.09.09, indicates that the control room will document who
and when keys are issued and returned. Keys that are transferred
between shifts will "be documented.. This policy was not followed at
Charlotte Correctional Institution. This is evidenced by the following:

Evidence:
• A review of key control records indicate that entries in reference to
A dorm were ~naccurate in their description of the types of keys
were issued. "Active" keys were indica~ed as "24 hour pass-on"

keys and the plumbing keys wYcre entered as masonry keys. In
addition, the records indicate that inventories were not completed
at the end of the shifts to ensure an accurate accounting of A dorm
keys.
• A review of Control Room Logs indicate that the control room staff
checked on each dorm, infirmary and multi-service area for key
and equipment accountability with the exception of A dorm. In
fact, there are no notations on the Logs indicating A dorm in
anyway.
• A review of the latest Operational Review Report (07/16/02)
indicates a cite for standard 1.02;090. The standa,rd reads, "A
written sign-out system is used to check out ,keys. This shall be
documented on the Key Issue. Log, form' DC3-308." The cite
indicates, "Key #412 was located in medical and was not signed
out from the control room. (Corrected immediately). Several
confinement keys were in the key locker but were not signed back
in on the key log over a 2nd shift period. (Corrected immediately)." .
• Officers' Millard, Giddens, Claudio, George, Behrens, Ciofa.Ii.i and
Sergeant Sharkey indicate when they arrived at A, dorm to begin
their shift, they were handed a set of keys to the dorm from the
officer whom they were relieving.
• Officer Giddens indicated that he never signed anything to reflect
that he had the keys.
• Officer Claudio indicated there was no record of her receiving the
keys however; there was an occasion when the control room called
her to see if she had dorm keys.
• Sergeant Buendia, the control room supervisor for the2ud shift,
indicated that during the renovation of A donn, they did not
usually account for the exchanging of the keys between staff or
shifts because the dorm was not being utilized to house inmates.
This is why there is no notation on the control room logs for A
dorm as there is for the other dorms. She admitted it was an
oversight on their part for not contacting A dorm in the same
manner as the other dorms.
• Sergeant Meier, the control room supervisor· for the 3 00 shift,
indicated that during the renovation of A dorm, they did not
usually account for the keys. He cannot explain why there were
indications in the logs that the keys had not been returned. At the
end of the shift either he or the other officer in the control room
would take a cursory look at the key log and lor the hooks where
the keys were kept. He would be able to see if the A dorm keys
were missing; however on the A dorm' hook there was a 24 hour
pass tag on it. If you didn't know that A dorm was under
construction and that a key should be there, you would assume
that a key should not be there. Meier could not explain why the A

dorm keying system had not been changed to accurateiy reflect .
how the keys are belng used. There was no documentation to
reflect the exchanging of keys .between shifts.
Finding(s) #5:
The Tool and Sensitive Item Control Policy and Procedure Directive,
3.09~12, indicates that tools classified as AA shall be stored off the
compound at all times when not in use and stored in a locked storage
area located outside the secure perimeter. In addition, there is to be a
tool checkout log maintained for all tools issued. This policy was not
adhered to. This is evidenced by the following:
Evidence:
•

•
•

•

•

It was discovered that tools used on the fence project were brought·

to A dorm so the inmates could work on the footlockers at night.
The toolbox used contained some AA tools, such as dykes, needle
nose pliers and grinder blades. At the end of the evening~ the
toolbox was locked and secured in a locked room across from the
main control room..
No sign in/out logs (DC fonn DC6-293) could be located regarding
the welder's toolbox that was kept across from the main control
room.
Lieutenant Smich, who supervised the recreation fence crew,
indicated due to the tool room being closed after hour and that
some of the tools fAA) had to be taken off the compound when not
in use, Mr. Boyett advised him, verbally, that the tools could be
secured in the room across frOm the main controi room after the
welders (inmates) had completed their work in the evening.
Officer Filipowicz indicated that he supervised the fence crew until
he escorted them to A dorm for the night detail. The toolbox that
the inmates used at night contained some AA. classified tools.
When the inmates were finished for the night the tools were locked
back in the toolbox and then it was secured at the main control
room. . Each morning he would complete· an invento:ry of· the
toolbox. Nothing was ever missing however; he had concerns
about leaving the tools overnight because they were checked out in
his name.
Officer Pavao, the tools control officer, indicated that Lieutenant
Smich and Officer Filipowicz had advised· him that Mr. Boyett
authorized Class AA tools to be stored overnight in a room by the
control room.

Mr. Shidle~, the construction consultant, indicated that Mr. Boyett
suggested 'that Cla'ss AA tools be stored at the main control room
at the end of the day.
,
• Assistant Warden Boyett admitted to authorizing the securing of a
toolbox containing Class AA tools to be stored in a locked room
located inside the vestibule of the main control room. He considers
the vestibule as being off of the compound.
•

Finding(s) #6:
Post Order #3, (8) (Shift Supervisor) indicates that the shift supervisor
will conduct daily security inspections of all inmate activity areas. The
inspections will. be docum'ented daily on the "Control Room Log". This
was not being done as evi~enced by the following:
Evidence:
• A review of Control Room Logs for the d~tes listed above indicate
both the 2 nd and 3 rd shifts consistently checked on dorms, the.
inftrmary and multi-service areas for security checks. There is
however,' no indication that A dorm was ever contacted. In fact
there are no indications on the Logs related to A, dorm at all.
• Offtcers' Giddens, Claudio, Behrens, Ciofani and Sergeant Sharkey
indicated that at no time were security checks done while they
were in A dorm.
• Offtcer Millard indicated there were times while she was in A dorm
that someone would check on her. '
• Officer George indicated that the only time someone checked on
him was when the control room called him for count.
• Sergeant Buendia, the control room supervisor for the 2 nd , shift,
acknowledged that because A dorm was not being utilized to house
inmates, security checks were not documented. She admitted this
was an oversight. She further indicated the officers in the dorm
did call in however, the calls were not documented.
'
• Sergeant Meier, the control ,room superVisor for the Jrd shift,
acknowledged that it was common practice that they did not do
security checks on dorms that they considered closed. Closed
dorm to them meant that they did not house inmates.
• Lieutenant Orzechowski, the "relief' shift supervisor for the 3rd
shift, indicated that he did complete security checks in A dorm
while coristruction was going on.
• Captain Davis, the 3 rd shift supervisor, indicated he has on a few
occasions checked in A dorm but did not do so on a routine basis.
During the times he did check on A dorm, he would stop at the
gate when he saw an officer outside, usually on a smoke break.

On 1 or 2 oeca.siona he did step inside the dorm. Davis indicated
that he couldn't recall routinely contacting the officer in A dorm by
radio to check on them. His explanation as to why the control room
dId not call and cheek on A dorm is that they treated it as a work
site and not an established post. In reviewing the control room
logs, he never noticed that the, control room was not contacting A
dorm.
uestions or need additional information please advise.

IDeer Senior ~spector

see exhibit pages attached.

· . Page # 13

A.

EXHIBIT - attached
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21..
22.
23.
24.
25.
26.
27.
28.
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30.
31.
32.
33.
34.
35.
36.
37.
38.

Procedure 602.030 (Manpower Utilization)
3 rd Shift Daily Security Rosters
Formal Count Sheets
Formal Count Slips
Affidavit of Sergeant Meier (6/26/03)/
Transcribed sworn statementqf Lieutenant Orzechowski (7 /8/03)~
(refer to B-1)
Transcribed sworn statement of Captain Davis (6 /25/03) /
. Procedure 602.023 (personal Body Alarms)
Control Room Security Equipment Check Out/In Log (only tl].ose
that indicate Officer Lathrem) ;VtJT J"'" 0 J1.tH. .sa?
Affidavit of Officer Millard (8/15/03)1./'
Transcribed sworn statement of Officer Giddens (6/25/03)4Mfidavit of Officer Claudio (8/ 11/(3) v
Mfidavit of Officer George (8/15/03)V
Transcribed sworn statement of Officer Behrens (6/19/03) v
Mfidavit of Sergeant Sharkey (8/26/03)l../
.
Transcribed sworn statement of Officer Ciofani (6/ 19/03)£/
.
Transcribed sworn statement of Lieutenant Orzechowski (9/4/031..r-I17 /~
Procedure 602.024 {Inmate Transportation and Movement)tAffidavit of Offic;er Millard (6/26/03).....
Affidavit of Officer George (6/26/03) v
Affidavit of Officer Behrens (6/26/03) v
Policy and Procedure Directive 3.09.09 (Key Control and Locking VSystem)
Post Order # 8 {Control Room Sergeant)V'
Key Ring descriptionv
Mfidavit of Sergeant Kirkland v
Daily key ring sign out log (Key issue logs) v
2 nd and 3rd Shift Control Room Logs V
Operational Review Report l./'"
.
Affidavit of Officer Claudio (7/9/03)V
Transcribed sworn statement of Officer George (6/19/03) Y'
Transcribed sworn statement of Sergeant Buendia (8/26/03) V
Transcribed sworn statement of Sergeant Meier (7/8/03) v
Policy and Procedure Directive 3.09.12 (Tool and Sensitive Item
Control) fVC'lliV (}-n-et<.
Class AA Tool Receipt NOT /1v-t>J2f(J..
Affidavit of Lieutenant Smich (7/8/03) NO
Transcribed Sworn statement of Officer Filipowicz (6/19/03) tV!)
Transcribed sworn statement of Officer Filipowicz (6/25/03) tV 0
Mfidavit of Officer Filipowicz (7/8/03)/'-'"0

07Jo.t!?

--. ,.page 1f

lLf

39. Affidavit of Officer Pavao (719 I 03) 4'()
40. Affidavit of Officer Shidler (7 18/03) IV 0
41. Transcribed sworn statement of Mr. Boyett (81 27 /03)bZ>
42. E-mail reference ladders N
43. Affidavit of Officer Giddens (7 19103) 11/tl
44.- Affidavit of Officer George (8/26/03).4'1>
45. Affidavit of Officer Ciofani (8 I 11 103) "" t?
46. Transcribed sworn statement of Mr. Shidler (6/19 103)~
47. Transcribed sworn statement of Mr. Shidler (6/26/03)&:'2I
48. Transcribed sworn ~tatement of Mr. Shidler (6/27/03)///;;
49. E-mail of Mr. Boyett approving ladders. .(.,~
50. Transcribed sworn statement of Mr. Boyett (6/25/03)",p
51. Transcribed sworn statement of Mr. Boyett (6/26/03)'" j)
52. Transcribed sworn statement of Mr. Teny (91 12/03) ~c)
53. Transcribed sworn statement of Ms. Villacorta (7/1/03) .....1
54. Transcribed sW9rn statement of Mr. Cornell (8/29 103)A tI .
55. . Transcribed sworn. statement of Mr. White (7/101 03) ~ iJ
56. Transcribed.sworn statement of Major Jordan (7/14/03/10/
57. E-mail from Mr. Boyett to Major Jordan ArD
58. Affidavit of Mr. Brandt /l'{)
59. Affidavit of Lieutenant Smich (8/26/03) A--P
60. Transcribed sworn statement ofMr. Cain (71 15/03)Av
61. Transcribed sworn statement of Mr. Rogers (7/8/03'y'Z-II
62. Transcribed sworn statement of Mr. Upchurch (7/15/03) Ai
63.
Documentation from Mr. Upchurch 40
64. Transcribed sworn statement of Mr. Upchurch (9/3/03)/t-;}
65. Post Order #3· (Shift Supervisor) ~
66. Affidavit of Officer Millard (8/28/03) t.--/
Affidavit of Officer Giddens (8/26/03) V
67.
68. Transcribed sworn statement of Sergeant Meier (8/26j03)t-69.
FAC 33-208.001,33-208.002,33·:-208.003 (Rules ofConduct)~
70. Transcribed sworn statement of Mr. Dugger (7/15/03)/2/)
71.
Affidavit of Mr. AnglinlVt1
72. E-mail from Mr. Rogersn--~
73. Transcribed sworn statement of Mr. Shidler(6/24/03)/t--)
74.
Status reports from Mr. Cornell 11/I
75. Memo from Mr. Boyett to Shift Supervisors ;..J
76.
Transcribed sworn statement of Mr. Boyett (918 I 03}~ :1
77. Affidavit of Officer Filipowicz (8/26/03) /f./J
78. Affidavit of Sergeant Spears tVi)
79.
Affidavit of Ms. Trudell Il/b
80. Transcribed sworn statement of Major Jordan (9/9/03) /'ViP
81. Post Order Change documentation Ii/l)
82. Transcribed sworn statement of Colonel Howdeshell(61 19/03) ~
83. Transcribed sworn statement of Colonel Howdeshell (9 I 4/03) -Lri'
84.
Affidavit of Col. Howdeshell (6/27/03) If /}

iJ -

85. Transcribed sworn statement of Mr. Cannon (7/1/03)
86. Affidavit of Mr. Cannon (8/28/03)
87. Mfidavit of Mr.' Cannon (9/4/03)
88. . Mfidavit of Mr. Sapp
89. Affidavit of Major Reid (6/27/03)
90. Affidavit of Major Reid (7/9/03)
91. Transcribed sworn statement of Lieutenant Smich (6/19/03)
92. Affidavit of Lieutenant Smich (6/25/03)
93. Affidavit of Lieutenant Smich (9/4/03)
94. Mfidavit of Lieutenant Stewart
95.. AffidaVIt of Captain Hansen (6/26/03)
96. Affidavit of Captain Hansen (9/10/03)
97. Affidavit of Captain Licata
.
98. Transcribed sworn statement of Captain Davis (6/27/03)
99. Transcribed sworn statement of Captain Davis(9 /12/03)
100. Post Order #2 (Chief of Security)
101. Tra.ilscribed sworn statement of Col. Howdeshell (12/03/03)
102. Agendas (meetings) re: Shift Supervisors
103. Transcribed sworn statement of Mr. White (12/05/03)
104. Transcribed sworn statementof Mr. Boyett (12/05/03)
105. Transcribed sworn statement of Mr. Cannon (12/03/03)
106. Transcribed sworn statement of Mr. Mount (12;'03/03)
107. BlankJob Change form .
108. Job Change form for Inmate Beaston
109. Transcribed sworn statement of Lt. Orzechowski (12/11/03)
110. Incident Report by Lt. Orzechowski (04/17/03)
111. .Incident Report by Officer Henderson (04/17/03)
112. Transcribed sworn statement of Officer Henderson (12/15/03)

B

EXHIBIT - (not attached)
1.

Cassette tape. containing sworn statements of Lieutenant Orzechowski,
Mr. Rogers, and Sergeant Meier. (07/08/03)
2. Cassette tape containing sworn statement of Captain Davis
(06/25/03)
3. Cassette tape containing sworn statement of Officer Giddens
(06/25/03)
4. Cassette tape containing sworn statement of Officer Behrens
(06/19/03)
5. Cassette tape containing sworn statement of Officer Ciofani
(06/19/03)
6. Cassette tape containing sworn statements of Lieutenant Orzechowski,
Colonel Howdeshell (09/04/03)
7. Cassette tape containing sworn statement of Officer George
(06/19/03)
8. Cassette tape containing sworn statement ofSergeant Buendia

';:' ..

,

.L

""0"'"

II

.LV

(08/26/03)
9. Cassette tape containing sworn statement of Officer Filipowicz
(06/19/03)
10. Cassette tape containing sworn statement·ofOfficer Filipowicz
(06/25/03)
11. Cassette tape containing sworn statement of Mr. Boyett (08/27/03) .
12. Cassette tape containing sworn statement of Mr. Shidler, Colonel
Howdeshell (06/ 19/03)
13. Cassette tape containing· sworn statement of Mr. Shidler, Sergeant
Buendia (not used), Lieutenant Stewart (not used) (06/26/03)
14.' Cassette tape containing sworn statement of Mr. Shidler (06/27/03)
15. Cassette tape containing sworn statement of Mr. Boyett (06/25/03,
06/26/03)
.
16. Cassette tape containing sworn statement of Mr. Teny (09/12/03)
17. Cassette tape containing sworn statement of Ms. Villacorta, Mr.
Cannon (07/01/03)
. '18. Cassette tape containing sworn statement ofMr. Cornell (08/29/03)
19. Cassette tape containing sworn statement of Mr. White (07/10/03)
20. Cassette tape containing sworn statement of MajorJordan (tape 1)
(07/14/03)
21. Cassette tape containing sworn statement of Major Jordan (tape 2)
(07/14/03)
.
22. Cassette tape containing sworn statement of Mr. Dugger, Mr. Cain
(07/15/03)
23. Cassette tape containing sworn statement of Mr. Upchurch
(07/15/03)
24. Cassette tape containing sworn statement of Mr. Upchurch
(09/03/03)
25. Cassette tape containing sworn statement of Sergeant Meier
(08/26/03)
26. Cassette tape containing sworn statement of Mr. Shidler (06/24/03)
27. Cassette tape containing sworn statement ofMr. Boyett (09/08/03)
28. Cassette tape containing sworn statement of Major Jordan
(09/09/03)
29. Cassette tape containing sworn statement ofLieutenant Smich
(06/19/03)
30. Cassette tape containing sworn statement of Captain Davis
(06/27/03)
31. Cassette tape containing sworn statement of Captain Davis (tape 1)
(09/12/03)
32. Cassette tape containing sworn statement of Captain Davis (tape 2)
(09/12/03)
33. Cassette tape containing sworn statement of Col. Howdeshell
(12/03/03)
34. Cassette tape containing sworn statement of Mr. White (12/05/03)
35. Cassette tape containing sworn statement of Mr. Boyett (12/05/03)

TT • f

36. Cassette tape containing sworn statements of Mr. Mount and Mr.
Cannon (12/03/03)
,37. Cassette tape containing sworn statement of Lt. Orzechowski
- (12/11/03)
38. Cassette tape containing sworn statement of Officer Henderson
(12/15/03)