When Reason Fails – An Example

This December 16 letter to the Minister of Public Safety belongs in the two assigned categories. When our government panders to its voter base in the face of common sense, it deserves to be throttled as much for its stupidity as it does for the corruption it creates in the administration of justice.

December 16, 2014

The Honourable Steven Blaney,
Minister of Public Safety,
Ste. 306, Justice Building,
House of Commons,
Ottawa, ON K1A 0A6

Re: Solitary confinement/segregation in our federal prisons

Minister Blaney:

House of Commons, Monday, December 8 (reported in the Globe and Mail, Tuesday, December 9)……Canada’s prison practices are “fully aligned with Western countries’ modern practices and we fully trust our correctional services to do the appropriate thing.”

House of Commons, Wednesday, December 10 (reported in the Toronto Star, Friday, December 12)….regarding segregation, “This is a procedure that is applied with a lot of common sense by our correctional officers.”

Really? Assuming the newspapers quoted you accurately, the fingers of both hands must have been crossed behind your back.

Only the uninformed or anyone with an agenda that skirts the truth would believe this, and there are tens of thousands of us in the community who are embarrassed on your behalf. Imagine. A Minister of the Crown giving voice to such nonsense! One wonders what causes an intelligent person to support such counterproductive measures. Thankfully for you, this is a country where armchair activism wins over street protests.

There will come a time when you are no longer in public life, and an opportunity to have you reflect upon your present positions from that perspective would be welcomed by many.

Yours truly,

Charles H. Klassen
cc turnoverarocktoday.com
system.

Supreme Court of Canada – Police rights to Search Cellphones

On December 11, 2014, Canada’s Supreme Court ruled that police can conduct limited searches of suspects’ cellphones without a search warrant….but, they must follow strict rules. The search must be directly related to the circumstances of an arrest, and detailed records of the search must be kept.
The Court’s 4 to 3 ruling is a margin so narrow one wonders how much sway tipped the decision one way or the other.
This writer is ambivalent on the subject, but there’s a tendency to agree with the Court. The problem though, and the issue I have with the SCC’s ruling, is best articulated in Heather Mallick’s December 15 Toronto Star column, “Court ruling on cellphones ravages people’s privacy.” It questions the Court’s belief that the police can regulate themselves, and will follow the rules. There can be information on a cellphone subject to broad interpretation, stored for personal but non-relevant purposes, and in some cases outdated and awaiting deletion. Check out this column on the Star’s web site. In any case, we can foretell legal challenges are to come.
One important question Ms. Mallick asks in her column is, can a suspect refuse to provide a phone’s password to the police. I was able to email her the answer. No, suspects are not required to provide passwords, BUT the police know that most people don’t know that and they will press for the information. The message……be informed….and inform. And, choose passwords wisely.

Were we really expecting something different?

For the week ahead of Correctional Service of Canada’s scheduled December 11 response to the 104 recommendations that came out of the 2013 inquest into the death of Ashley Smith, the Globe and Mail ran daily articles on the subject of solitary confinement in our federal prisons. In its 28 page response to the inquiry’s findings, CSC hardly did better than to acknowledge that there had been an inquiry and it was expected to say something……anything….but it wasn’t about to make any substantive changes.

December 15, 2014
David Walmsley, Editor-In-Chief,
The Globe and Mail,
444 Front Street West,
Toronto, ON M5V 2S9

Re: Solitary confinement in Canada’s federal prisons

Dear Mr. Walmsley:
I’m a Correctional Service of Canada “specialist”. I’ve spent more than twenty years in research and observation of this institution.

If I give ground to Steven Blaney and his staffers at Public Safety, or Don Head and others at CSC’s National Headquarters, it’s for their lack of accurate information of how federal prisons operate in the trenches where thousands of inmates and CSC employees live and work. But I surrender only a few millimetres because I’m convinced Mr. Blaney and Mr. Head, et al, would prefer not to know. It’s like the old Victorian adage, “I don’t care what you do, as long as you don’t do it in the streets and frighten the horses.”

It doesn’t take much research/observation, or the expertise of the proverbial rocket scientist, to support my long-held view that Correctional Service of Canada is dishonest, abusive, morally and ethically corrupt, and a blot on the landscape of this country. So many have become frustrated with the organization’s absence of accountability and transparency, and its refusal to comply with the law, international treaties, best practices, and a plethora of calls for change. When I was recently given an opportunity to help underwrite a legal action against CSC on behalf of an inmate, I ran headlong to get involved.

Your recent series on the use of solitary confinement/administrative segregation in the federal prison system is a welcome insight into practices which are entirely unacceptable. You and all the contributors to this project are to be commended for making this effort to bring about change. Sadly, we see how intransigent some of our public servants can be. Strange, given the meaning of “servant” is not abstruse.

Yours truly,

Charles H. Klassen

cc Steven Blaney/Don Head/turnoverarocktoday.com

Lawsuits against the Toronto Police Services

There are hundreds of complaints filed against the Toronto Police Services every year, plus many more incidents where citizens believe a complaint is warranted but not worth the effort. Many are dismissed summarily, whether or not they have merit. And, we don’t have any figures because no government body is required to oversee and issue the statistics. It’s up us to research the material.
In additional, where there is a financial resolution to a dispute, we are not entitled to know the details, even though tax dollars are involved, either directly or indirectly as liability insurance premiums.
TPS is quick to deflect criticism, and Mark Pugash is adept at the work he does. That’s why it’s important to take him to task when the opportunities arise, even if there’s a delay is getting to it.

December 9, 2014

Mark Pugash, Director,
Unit Commander, Corporate Communications,
Toronto Police Services,
40 College Street,
Toronto, ON M5G 2J3

Re: Man reeling from arrest seeks closure in court
Toronto Star, September 24, 2014

Dear Director Pugash:
“It’s important to note that it is not at all unusual for lawsuit claims to fail in court. Unfortunately, the Toronto Star provides a platform for unproved claims but rarely, if ever, lets its readers know when the claims it prints are judged to be baseless.” This is part of your response when Wendy Gillis asked about Tyrone Sparks’ multi-claim suit against the Toronto Police Services as printed in the above article.

You’re right. Outcomes rarely appear in print. In an email exchange I had with the Star’s Jim Rankin in June of 2013 on just this subject, he admitted they could do a better follow-up job but noted that neither party to an action is prone to report any outcome. As well, he agreed with my assessment that a resolution, particularly where gag orders prevent the disclosure of details, is generally not newsworthy.

I have a lengthy list of newspaper items of legal actions launched against the police where nothing further appears. More pertinent though is “Mayor calls for review of police litigation” from the Globe and Mail’s Tuesday March 15, 2005 edition, where David Miller “was responding to a CBC Radio report that the city spent more than $30-million on more than 8,000 lawsuits against the police since 1998.” The figures stagger! Consider also the additional number of people who may believe they had grounds for a complaint but just didn’t bother filing. Then too, how do the last ten years stack up?

Here’s a suggestion. Given your position with the Toronto Police Services, the resources you have and your access to the media, plus the sense that you feel the TPS is ill-served by the press, why don’t you publish the outcomes of these varied and many actions?

Yours truly,

Charles H. Klassen
cc Wendy Gillis, Toronto Star
turnoverarocktoday.com

Our duty to assist – for change!

“Information is the lifeblood of a democracy. Without adequate access to key information about government policies and programs, citizens and parliamentarians cannot make informed decisions, and incompetent or corrupt governments can be hidden under a cloak of secrecy.”
Stephen Harper
Montreal Gazette, 2005

Stephen Harper was commenting on the Liberal government of the day. This is the same Stephen Harper who became Prime Minister not long after, and soon began closing doors, shuttering windows, and building a guard post at the gate to control all and sundry comings and goings. His fellow caucus members in the Conservative/Reform Party are complicit in cutting off “the lifeblood of a democracy.” If for no other reason, this government deserves to fall.
There are a number of tools Mr. Harper, et al, is using to keep Canadians uninformed. One of the more effective is budget cuts. The Access to Information and Privacy divisions of government ministries, departments, and institutions, for example, are legislated to adhere to the provisions of two Acts, plus applicable departmental directives. Using Correctional Service of Canada as a sample familiar to me, when an information request is received at CSC, it returns an acknowledgement that includes this attachment:-

…………………………..Duty to Assist………………………….
The Federal Accountability Act and Treasury Board Secretariat directives apply to the Access to Information Act, and require that all government institutions “make every reasonable effort to assist” individuals making a request for records, regardless of who the requester is. The Correctional Service of Canada is committed to ensuring that we:
• Process your request without regard to your identity.
• Offer reasonable assistance throughout the request process
• Provide information on the Access to Information Act, including information on the processing of your request and your right to complain to the Information Commissioner of Canada.
• Inform you as appropriate and without undue delay when your request needs to be clarified.
• Make every reasonable effort to locate and retrieve the requested records under our purview.
• Apply limited and specific exemptions to the request records.
• Provide accurate and complete responses.
• Provide timely access to the requested information.
• Provide records in the format and official language requested, as appropriate.
• Provide an appropriate location within the government institution to examine the requested information
When applicable, requesters will be given the option of having their request processed informally. However, the requester should know that only formal requests are subject to the provision of the Act, including the right to complain.
For additional information, please refer to the Treasure Board Secretariat’s Directive on the Administration of The Access to Information Act, Frequently Asked Questions on the ATIP page of CSC’s internet site and/or contact the analyst responsible for processing your request.

 

The Act stipulates there is a 30 day time limit to respond to requests, but a provision permits the head of a government institution to invoke an extension of an additional 30 days under specified circumstances. A “requester” is entitled to complain to the Privacy Commissioner of Canada and/or the Information Commissioner of Canada if the process or response doesn’t satisfy. My experience with CSC’s ATIP division has generally been positive, and even when answers to my requests linger beyond the permitted legislated time limits, I know the delays are most likely caused by the information source.
So, what happens when an office, or institution, or department does not follow through on what they are mandated to do, regardless of the reasons? Why, a requester files a complaint with the Commissioner, of course. But, budget cuts to that office means a complaint will wait about six months before an investigator can be assigned. In the meantime, the offending information source knows repercussions are far off, if at all, and the requester may have abandoned the enquiry to boot.
Here’s a suggestion. Reread the paragraph at the top of this post, and the next time you see a television spot in which our federal government is spending tax dollars to promote itself, give it a raspberry……and, remember where the “x” belongs in the 2015 election. Now, that’s not so hard, is it?

Carding…why are we still putting up with it?

November 26, 2014

Bill Blair, Chief,
Toronto Police Service,
40 College Street,
Toronto, ON M5G 2T3

Re: Blair opens up to students at rights symposium
 Toronto Star, Thursday, November 20, 2014

Chief Blair:

“You’ve got your own agenda….” is how the Toronto Star’s Patty Winsa quoted the beginning of your response to a question from the paper around the police practice of carding at a Know Your Rights meeting for youth at the Toronto Police College on Wednesday, November 19.
If by “agenda” you mean the Toronto Star’s ongoing efforts to make our police service transparent and accountable, then I would assume your comment was complimentary. As it is, the November 26 Police Board meeting to which you referred has been delayed, and that stalls the release of “Community Assessment of Police Practices”, a survey that would be of considerable interest to many.
It’s problematic understanding why there is any difficulty in implementing the Police Board’s policy on carding. You are an executive, authorized to issue directives and orders, supported by compliance staffers to ensure the measures are carried out, and with further resources to iron out what wrinkles may arise in the process.
“Carding” is an abhorrent infringement by the public service on the sovereignty of the citizenry. It’s a fishing expedition coupled with a reverse onus stipulation. Taken to an extreme, it could be likened to putting everyone in jail until each individual provides surety for good behaviour. Odd, given that those people in jail are the very ones who determine what good behaviour is required of us all.
Yours truly,

Charles H. Klassen

cc John Tory, Office of the Mayor
Patty Winsa, The Toronto Star
turnoverarocktoday.com

Tough on crime? Smart on crime?

During the 1980s, we saw many news items out of the United States around judges dismissing criminal charges on the grounds of human and constitutional rights violations. Many of these cases before the courts involved serious charges carrying substantial penalties. The din grew louder as media attention focused on what seemed an increasing number of incidents where potentially guilty parties walked free. However, one retired American judge whose credentials I failed to note at the time pointed out that if all concerned with the pursuit of justice, in particular police officers and prosecuting attorneys, did their jobs properly then these circumstances would not arise as frequently.
Perhaps the American ‘tough on crime’ impetus into the 1990s was in part a backlash to what were often seen as miscarriages. Federal and state governments became intent on correcting flaws in a system that too often appeared to favour the guilty. Prison populations grew, new facilities were built, and some jurisdictions privatized their penal systems; California passed its three strikes law in 1994.
Eventually, the United States had the distinction of having 5% of the world’s population but 25% of the world’s prisoners.
With a new century came an awareness in the U.S. that this lock-em-up-and-throw-away-the-key mentality didn’t measure up, and was quite probably doing more harm than good. What was going to happen to all the ex-cons after their release back into the community? Doug Sanders’ January 24, 2004 article in Toronto’s Globe and Mail, “600,000 ex-cons add up to a U.S. headache”, referenced President George Bush’s January 20 State of the Union Address where he remarked on the challenges facing U.S. society by moving that many ex-offenders back onto the streets in just 2004.
With time, governments realized the mounting costs were not offset by measurable benefits. One spokesperson for a southern U.S. State suggested a few years ago that it might be confronting a choice between financing prisons and paying for schools. Still later, California began quietly releasing some prisoners to reduce crowding, and the financial liability on the public purse.
The Washington Post published statistics in September of this year referencing America’s emptying prisons, noting the U.S. federal prison population dropped this year – the first time in decades the number of people behind bars had shrunk. U.S. Attorney General Eric Holder highlighted the decline as a breakthrough for criminal justice reform.
The newspaper listed a number of indicators:
The cost of incarceration in the United States is 2010 was $80 billions of dollars.
Growth in the number of prisoners since 1980 was 800%, while the general U.S. population increased by about 33%.
The prison population had declined by 4800 at the end of fiscal 2014, to about 215,000 federal inmates.
The last decline in prison numbers was in 1980.
A further decline of 10,000 prisoners was expected in fiscal 2016, the equivalent of six full federal prisons.
Is it any wonder so many American law makers looked askance at Canada when the current federal government here launched its own tough on crime agenda. Why would we do something that had been tried and failed elsewhere? And not just from the United States are we hearing this. Legislators and law enforcement in Great Britain and Australia echoed the Americans. Others, like the Swedes, were more diplomatic when speaking of their own policies.
Canada’s prison population began to climb in 2007 in spite of falling crime rates. Why do intelligent men and women follow a course they know will meet with failure, and which will be costly to the fabric of our society, financially and socially? Further, these same intelligent men and women continue to ignore what they have before them, pushing forward a program contrary to good governance. Not only that, intent on squeezing budget surpluses out of limited revenue at the expense of programming and oversight, we can look forward to a surfeit of ex-offenders ill prepared to reintegrate successfully into our communities.
Why would intelligent men and women do this? Well, here’s a thought. This has nothing to do with safer communities, restorative justice, social order, or right and wrong. Rather, let’s look at this as pandering to an uninformed and mean-spirited support base by pillorying an easy target.
Thanks to Mssrs. Harper, et al, we’ll pay dearly for this.

Health Care in Canada’s Federal Prisons

The Office of the Correctional Investigator is mandated under Part III of the Corrections and Conditional Release Act to serve as an Ombudsman for federal offenders. Perhaps as long as two years ago, the OCI reported that a prison term, particularly a lengthy prison term, could knock ten years off the life of an offender. CSC’s own resources tend to support this. Lifestyle plays a role of course, but so too does the availability and delivery of health care within federal institutions.
Referring again to the Corrections and Conditional Release Act, Chapter 86, Section (1), The Service shall provide every inmate with, (a) essential health care, and, (b) reasonable access to non-essential mental health care that will contribute to the inmate’s rehabilitation and successful reintegration into the community. Also, Section (2), The provision of health care under SubSection (1) shall conform to professionally accepted standards.
In addition, Correctional Service of Canada’s Commissioner’s Directive 800 – Health Services, provides specifics which on paper do meet CSC’s argument that federal inmates receive the same levels of care as the rest of us, although there are exceptions such as dental care where what’s approved matches services available to persons in the community living on social assistance. Two of the big BUT’s are that delivery is uneven and inconsistent across the Service, and inmates must access health care personnel via non-health care staff members.
To cite only a couple of examples from Brennan Guigue’s (Rahim) own experience, many years ago he put in a request to see the dentist at Kingston Penitentiary. This wasn’t an emergency but he had concerns that needed an examination. It was seven months until he was in that dentist’s chair. Later, at Cowansville Institution in Quebec, he was taken to the local hospital for an x-ray of a shoulder on January 9 of 2014. The x-ray had been ordered by a doctor at Port-Cartier Institution in September of 2012. That’s not a typo…..2012! The injury had occurred months earlier, but his complaints had been ignored. This is a typical response, perhaps systemic, and can be attributed to any number of reasons like liability issues, budget factors (health care is a budget line item subject to performance bonus considerations), or explanations best left to speculation.
In any case, and understandably, the results of that x-ray wouldn’t be available to him until he saw the Cowansville Institution’s doctor. He’d asked for an appointment when he first arrived there in December of 2013, but that appointment was set for April…..as long as he wasn’t transferred to yet another prison.
An inmate in western Canada with whom I’ve corresponded discovered a lump is his groin in the fall of 2012. He was in pain and his requests for help were ignored. By January of 2013, he had his lawyer call the director/warden of his institution to persuade the system to act. It was cancer, he had surgery, but the delay puts him at risk for further tumors. As well, he had to initiate a court action in order to get proper pain relief.
Yet another inmate I’ve had contact with was asking for counseling as part of his preparation for reintegration into the community. He was turned down in more than one institution. He was released on parole and sent to one of the CCC (Community Correctional Centre) half-way houses which are operated by CSC in a number of cities. While there, the staff suggested he needed counseling, and set up a date weeks down the road, but the parolee was returned to prison for a minor infraction before the process could begin. He asked again for counseling while in custody, and again was told he didn’t need it. When his parole was reinstated to the same CCC half-way house, the staff there once more set up a far off date for counseling because, according to them, it was a necessary part of his reintroduction to the community. Once more, he was sent back to prison for a minor parole infraction, and once more he was told that he didn’t need counseling.
So, how does something like this happen? Well, consider that this counseling is covered under the provincial health care system when the inmate is in the half-way house, but CSC pays when that same person is in an institution. Confusing? Well, yes, if someone is trying to get on the right course, and after all, CSC is charged under the CCRA with helping offenders reintegrate.
The pressure on the prison health care system is about to get considerably worse. A disproportionately high number of prisoners are HIV+ or are infected with Hep C, or both. As expensive as the HIV anti-retrovirals are, there are a number of effective new drugs either available or awaiting approval to treat Hep C, and these can cost many tens of thousands of dollars. CSC will be squeezed by requests for treatment on the one hand, and calls for fiscal restraint on the other.
The bottom line here is simple. The next time you hear about prison inmates being treated to free and extensive health care, don’t be too quick to sign up. It could cost you your life!

Body of complaint letter to Quebec College des medecins

October 31, 2014

Inquiries Division,
Collége des médecins du Québec,
2170 René-Lévesque Blvd. West,
Montreal, QC H3H 2T8

Re: Dr. David Lesage, Attending Physician,
Donnacona Institution, Quebec Region
Brennan Wayne Guigue. FPS104902C

Dear Inquiries Division:
Dr. David Lesage offered an uncaring, cursory, and unprofessional examination of Brennan Guigue at Donnacona Institution on Tuesday, August 19. Brennan Guigue and his family object to his treatment, and as his father, supporter, and champion, I’m appalled that a physician would accept tax dollars for a federal prison rotation and not provide the contracted services under the CCRA, and Commissioner’s Directive 800 Health Services.
Brennan Guigue was a temporary detainee at the Regional Reception Centre in Ste-Anne-des Plaines who suffered serious injury from an extraordinary and unjustified use-of-force incident there on July 22. A liquid chemical agent was sprayed on his naked body. Quite simply, guards at the RCC:
Ignored CSC policy, and engaged in prohibited activity.
Acted unlawfully under sections of the Criminal Code.
Violated provisions of the United Nations Standard Minimum Rules for the Treatment of Prisonsers, to which Canada is a signatory.
He was then surreptitiously transported to Donnacona the next day as an expedited substitution on a “load”, placed and held indefinitely in segregation there under what convenient justifications were available to prevent interaction with population and to limit contact with the outside, and further, put on ‘cuff status’ when a doubtful excuse arose. Miriam Gautier, the attending nurse in the health care unit at Donnacona on Saturday, July 26, refused to document Mr. Guigue’s injuries and condition. She gave him “Glaxo Base Cream” as a remedy, which was an unsatisfactory solution.
Brennan Guigue did not see Dr. Lesage until Tuesday, August 19, the escorting guard refused to remove the hand cuffs and the doctor did not insist they be taken off in order to facilitate a proper examination and documentation. In any case, Dr. David Lesage’s dismissive attitude excluded any substantive evaluation; he opined that Brennan had dry skin and walked away.
I can’t claim that the management of Donnacona asked Dr. Lesage not to look too closely at Brennan Guigue. What I can say is that Dr. Lesage did not provide adequate medical care, or address the concerns of a patient with obvious trauma.
Yours truly,

 

Charles H. Klasssen

cc: Dr. David Lesage, Centre Méd. Hochelaga, Montreal
Elain Tousigmant, Deputy Commissioner, Regional Headquarters – Quebec
Marc Lamoie, Director/Warden, Donnaconna Institution, Donnacona
Blind copies

Material/evidence requested from CSC

Using the Access Act and the Privacy Act, Brennan Guigue has requested through his lawyer a list of material from Correctional Service of Canada related to the July 22. 2014, incident essayed in his July 23 summary in this file.
The lawyer advises CSC will refute/delay/resist/subvert/waver/obstruct in response, and exercise what resources it has to bury this inquiry.
What we have here then is only phase one of the process to obtain the relevant data.
Keep in mind these are our civil servants, living from our public purse, and acting under the auspices of men and women we have elected, appointed, and employed to represent our best interests.
INFORMATION REQUESTED BY BRENNAN GUIGUE 104902

THE VARIOUS MATERIALS LISTED BELOW BEAR ON AN INCEDENT THAT TOOK PLACE AT THE REGIONAL RECEPTION CENTRE AT STE-ANNE-DES-PLAINES ON JULY 22, 2014, AND IT’S AFTERMATH

* Security Management Protocol governing the case Brennan Guigue on July 22, 2014.

* Report of Security Intelligence Officer concerning the incident of July 22, 2014.

* All logs of the Security Intelligence Officer for a week beginning on July 22, 2014.

* All logs of the Associate Warden for Interventions for a week beginning on July 22, 2014.

* The morning shift briefing reports of July 23, 2014.

* Brennan Guigue’s security incidents on RADAR / OMS.

* Threat risk assessments about Brennan Guigue for a week beginning on July 22, 2014.

* The executive summaries of any grievances made by Brennan Guigue on July 22, 2014, or during the following two weeks (i.e. up to and including August 5).

* The executive summaries of all reports concerning the use of chemical spray on Brennan Guigue occurring on July 22, 2014.

* Reports of any data issuing from all institutional, regional, and national reviews of the use of force against Brennan Guigue on July 22, 2014.

* The names and photographs of all staff who participated in any events and movements involving Brennan Guigue on July 22, 2014 from the time he was placed in the dry cell in the early afternoon until his return from the nurse’s station to his cell in the evening. The term “staff” is intended to include nursing staff.

* All log book entries of any units holding Brennan Guigue for a week beginning on July 22, 2014.

* All log book entries of the Correctional Manager of any units holding Brenan Guigue for a week beginning on July 22, 2014.

* All Operations log book entries for a week beginning on July 22, 2014.

* All log book entries of the Security Intelligence for a week beginning on July 22, 2014.

* All log book entries of the Associate Warden for Inventions for a week beginning on July 22, 2014

* For the period beginning when Brennan Guigue was placed in the dry cell on July 22, 2014, to the end of July, 2014, all emails to or from:

the Institutional Director,
the Deputy Director,
the Associate Warden on Interventions,
the Assistant Director Operations,
the Security Intelligence Officer,
the Correctional Officer (CO II) in charge of the Dome,
the Correctional Manager in charge of detention,
any other Correctional Manager on Shift,
all Parole Officers assigned to Brennan Guigue during the time he spent in the Regional Reception Centre,
the Nursing Staff.

* Hand-held video camera recordings of all staff interactions with movements of Brennan Guigue on July 22, 2014 beginning with his placement in the dry cell in the early afternoon and ending in the evening after his return to his v=cell from the nursing station.

* Film from the fixed security cameras facing the dry cell on July 22, 2014, during the time it was occupied by Brennan Guigue.

*Film from the fixed security cameras facing the shower on July 22, 2014 during Brennan Guigue’s arrival at it and departure therefrom and during the time Brennan Guigue was in the shower.

* Film from the fixed security cameras facing the protocol cell used for decontamination of Brenan Guigue after the use of chemical spray on July 22, 2014. The requested period extends from Brennan Guigue’s arrival at the shower to his departure from it.

* Film from the fixed security cameras facing the nursing station to which Brennan Guigue was brought. The requested period covers the time during which Brennan Guigue was present there in the evening of July 22, 2014.

In short, we wish everything in the possession of CSC that sheds light on Brennan Guigue’s July 22, 2014 confrontation with staff and its aftermath.