HomeMy WebLinkAboutACLU Lawsuit SettlementCARNEY
BADLEY
SPELLMAN
Jon A. Payne
September 16, 2003
David Goldsmith
Deputy County Administrator
JEFFERSON COUNTY
Jefferson County Courthouse
P.O. Box 1220
Port Townsend, WA 98368
Re: Orndorff v. Jefferson County
Settlement Agreement (Original)
Dear David:
LAW OFFICES
A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, SUITE 5800
SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 622-8020
DIRECT LINE (206) 607-4165
Email: payneCa�cameylaw.com
Enclosed please find the original Settlement Agreement, which includes the signatures of
Shawn Orndorff, Aaron Caplan and David Fathi. In order for the Agreement to be finalized, it also
requires the signatures of Sheriff Brasfield and Dan Titterness.
Please advise if you would like assistance in presenting or explaining this Settlement
Agreement to Mr. Titterness and/or the County Commissioners. Otherwise, please route the
Agreement for signature to Mr. Titterness and Sheriff Brasfield, and return the original document to
my attention for final execution.
As always, if you have any questions, please do no le itate to call.
Jon A. Payne
JAP:lc
Enclosure
cc: Ms. Susan Looker
Mr. David W. Silke
WCR001 0033 6170904
P.S.
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THE HONORABLE RONALD B. LEIGHTON
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT TACOMA
SHAWN ORNDORFF, on behalf of himself
and others similarly situated,
NO. 02-5096 (RJB) RBL
Plaintiff,
SETTLEMENT AGREEMENT
VS.
JEFFERSON COUNTY, PETER PICCINI,
CARLA SCHUCK, and STEVE
RICHMOND,
Defendants.
Plaintiff Shawn Omdorff, on behalf of himself and the class of individuals he represents,
through attorneys David C. Fathi and Aaron H. Caplan, and Defendants Jefferson County, Mike
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CARNEY LAW OFFICES
BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN SEATTLE, WA 9810450/7
FAX (206) 467-8215
TEL (206) 622-8020
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Brasfield and Steve Richmond,' through their attorneys David W. Silke and Jon A. Payne, based
upon consideration and the mutual promises contained herein, and as a mutual decision to
resolve the above -captioned matter without further litigation, hereby agree as follows:
1. The parties hereby agree that the attached Stipulation and Order of Dismissal
shall be entered, subject to the approval of the Court and notice to the class members.
2. The parties agree that this Settlement Agreement, together with the Stipulation
and Order of Dismissal to which it is attached, are entered to resolve and settle all claims for
declaratory relief, injunctive relief, attorneys' fees, and costs, that were set forth in the
Complaint that was filed February 25, 2002 under this cause number.
3. This Settlement Agreement shall not be construed as an admission by any party,
person, or entity regarding liability or violation of any law by defendants or any other person or
entity, and this Settlement Agreement may not be used as evidence in any proceeding other than
for the sole and limited purpose of enforcing this Settlement Agreement. The parties enter into
this Settlement Agreement for purposes of settling the disputed contentions and controversies
arising from this action. The parties stipulate, based upon the entire record, that the relief set forth
in this agreement is narrowly drawn, extends no further than necessary to correct violations of
federal rights, and is the least intrusive means necessary to correct violations of federal rights.
1 Current Sheriff Mike Brasfield and Jail Superintendent Steve Richmond did not hold these positions
at the time of the alleged acts contained in the Complaint.
CARNEY LAW OFFICES
SETTLEMENT AGREEMENT — 2 BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIF 11 AVENUE, #5800
CV02-5096 SPELLMAN SEAT -ME, WA 99104-5017
FAX (206) 467-8215
TEL(206)622-8020
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4. Definitions:
a. Defendants: Defendants are defined as Jefferson County, the Jefferson
County Jail ("Jail'), Mike Brasfield, Steve Richmond, and all of their successors, assigns,
commissioners, supervisors, officers, agents, employees, and insurers.
b. Plaintiffs: Plaintiffs are defined as Shawn Orndorff and the class of "all
persons who are now, or who will in the future be, incarcerated at the Jefferson County Jail," as
certified by United States District Court Judge Robert J. Bryan in the instant matter on
September 3, 2002.
c. Execution Date: The execution date of this Settlement Agreement, as
referred to below, shall be date on which the Court enters an order of final approval of the
settlement under Fed. R. Civ. P. 23(e).
Agreements by Defendants
5. a. Defendants agree to comply with the terms of this Settlement Agreement
for 36 months, beginning on the date of execution of this Settlement Agreement. At the
expiration of the 36 -month enforcement period, this Settlement Agreement shall automatically
terminate, unless extended under Paragraph 7(a).
b. On or before 6 months from the execution date of this Settlement
Agreement, Jefferson County shall have drafted, adopted and implemented the necessary policies
and procedures to ensure compliance with the requirements of this Settlement Agreement, as
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CARNEY LAW OFFICES
BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 622-8020
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provided in paragraphs 6(c)-Oj) below. Copies of policies will be provided to counsel for
plaintiffs upon adoption.
C. Jefferson County agrees to seek accreditation for the Jail's system for
delivery of medical services to inmates from the National Commission on Correctional Health
Care ("NCCHC") or other accrediting organization upon mutual agreement with the ACLU,
within 12 months of the execution date of this agreement. The Jail will adopt and implement
health care policies and procedures that would allow accreditation to be granted.
d. Jefferson County agrees to maintain a temperature in all inmate areas of
the Jail of between 60° and 80° Fahrenheit. For 36 months following the execution date of this
agreement, either the Jefferson County Health Department or a mutually agreed upon
independent contractor paid for by Jefferson County shall test the temperature within all inmate
areas of the Jail four times per year to verify that all temperatures are within the mandated range.
Temperature checks will be performed in the months of February, May, August, and November
on dates chosen without advance notice to jail staff. Defendants shall provide the results of the
tests to counsel for Plaintiffs.
e. Defendants will ensure that a sufficient supply of toilet paper and sanitary
napkins are maintained at the Jail. Such hygiene supplies will be delivered to inmates when
needed, even if the need arises sooner than, or in addition to, the Jail's ordinary distribution
schedule. Toilet paper and sanitary napkins will not be withheld as discipline for inmate
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CARNEY
LAW OFFICES
BADLEY
A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, X5800
SPELLMAN
SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 622-8020
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behavior. However, Defendants reserve the right to discipline inmates for stockpiling or abusing
toilet paper or sanitary napkins.
f. Inmates shall be offered a clean towel on a daily basis. Clean uniforms
will be offered twice per week. Permanently stained uniforms will be discarded.
g. Inmates in cells with exterior walls shall be entitled, upon request, to
receive up to two blankets in addition to the blankets that are issued when the inmate is booked
into the Jail.
h. Inmates may receive long underwear from outside retail vendors, provided
that the long underwear is sent directly to the inmate from the manufacturer or retailer in an
unopened, factory -sealed package.
i. The Jail will offer recreation to each inmate, other than those inmates in
the holding or crisis cells, for at least one hour per day, seven days per week, of which no less
than four days per week are outdoor recreation. The Jail reserves the right to withhold indoor or
outdoor recreation for safety or security purposes, documented by an incident report. "Safety or
security purposes" shall include, but not be limited to, withholding recreation from inmates who:
1) have previously committed infractions during indoor or outdoor recreation and have received,
after suitable procedures, a sanction of denial of recreation, which sanction may not exceed one
week of denial; or 2) pose an increased threat of harm to themselves, others, or property if they
are allowed to participate in indoor or outdoor recreation. A written record will be kept of the
recreation periods given in the Jail's general log book. Any instances where indoor or outdoor
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CARNEY LA W OFFICES
BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN SEATTLE, WA 981045017
FAX (206) 467-8215
TEL (206) 622-8020
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recreation is withheld shall be logged in the Jail's log book, which shall state the reason for
withholding the indoor or outdoor recreation.
j. Toilets, hot water faucets, and showers that are not functioning will be
evaluated by a representative of Jefferson County Department of Public Works within one
business day of jail staff receiving notification of the malfunction. Business days are Monday
through Friday. During any period of time when either the toilet or the hot water in an inmate's
cell is not functioning, the Jail will take the necessary steps to ensure that the affected innate has
access to a functioning toilet and hot water. Inmates will not be housed in cells with
malfunctioning toilets unless a cell with a functioning toilet is not available.
k. The Jail will adopt policies and procedures to ensure that the drainage
pipes in the Jail are kept moist to prevent odors in the Jail.
1. An inmate who has spent at least five consecutive days assigned to a
portable bunk (also referred to as a "boat') will be reassigned to a regular bed, unless the inmate
requests continued assignment to the portable bunk.
in. The Jail and/or the Jefferson County Department of Public Works will
develop and adhere to a preventative maintenance program for maintenance of the Jail's heating,
ventilation and air conditioning ("HVAC") system.
U. The Jail will provide some form of personal property storage unit for each
II inmate.
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CARNEY LAW OFFICES
BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 622-8020
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o. The Jail will prepare and maintain fire preparedness plans and will
implement and perform fire drills at least once per year.
P. The Jail's crisis cell will not be used as discipline for infractions or
misbehavior, unless both of the Jail's segregation cells are occupied, in which case an inmate
assigned to segregation may be assigned to the crisis cell for no more than 24 hours per 72 hour
period. The crisis cell may be used to house: 1) inmates who show evidence of being a risk of
harm to themselves, to others, or to Jail property in the form of property destruction or intentional
flooding; 2) inmates who require medical or psychiatric supervision; or 3) inmates who are
intoxicated.
q. The Jail will maintain a separate crisis cell log, which will document the
time of entry to and exit from the crisis cell for any reason, and a record of a corrections officer
directly observing the crisis cell occupant in person and not by video monitoring at least every 15
minutes during crisis placement. Further, during the entire course of an inmate's stay in the crisis
cell, the Jail will keep with the crisis cell log a sheet indicating the reasons for placing the inmate
in the crisis cell. Upon the inmate's transfer from the crisis cell, the sheets will be placed in a
central file of crisis log materials. The Jail may also place the sheets in the inmate's general
and/or medical file.
r. A corrections officer's decision to place an innate in the crisis cell must
be reviewed by a supervising officer by the end of the supervising officer's first shift following
the inmate's placement in the crisis cell. If the inmate is placed in the crisis cell by the Jail
CARNEY
LAW OFFICES
SETTLEMENT AGREEMENT -7 BADLEY
A PROFESSIONAL SERVICE CORPORATION
CVO2-5O96 SPELLMAN
700 FIFTH AVENUE, #5800
SEATTLE, WA 98104.5017
FAX (206) 467-8215
TEL (206) 622-8020
WCR001 0033 et064404 9/8/03
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superintendent, review will be by the undersheriff or sheriff. The Jail will develop and implement
a policy to determine when an inmate should be released from the crisis cell. The supervisor will
be notified when the inmate is released from the crisis cell.
S. Jefferson County Mental Health will be called at the time an inmate is
placed in the crisis cell for mental health reasons. The Jail's health care professional will be
called at the time an inmate is placed in the crisis cell for medical reasons. Inmates will not be
placed in the crisis cell in the nude. If a determination is made that the inmate's clothing should
be removed in order to protect the inmate's safety, to prevent property destruction, or to facilitate
clothing exchange, the inmate will be provided with a suicide smock or other suitable clothing.
t. Grievance forms, medical request forms, and regular request forms will
be made available in each cell block day room. The forms will be replenished as needed. The
medical request form will be amended to provide space for the inmates to describe their current
symptoms.
U. The Jail will respond in writing to all written grievances within seven days
of receipt by Jail staff. Jail staff will not retaliate against or deny privileges to any inmate for
writing grievances, contacting counsel, or complaining to any person about Jail conditions based
solely on the fact that the inmate has complained about Jail conditions. However, this paragraph
does not limit the Jail's ability to discipline inmates for violations of the Jail's Policies and
Procedures.
SETTLEMENT AGREEMENT — 8
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CARNEY
LAW OFFICES
BADLEY
A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN
SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 622-8020
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V. The reasons for, and a description of, all disciplinary action will be
recorded in writing. Copies of documentation pertaining to the disciplinary action will be placed
in a central disciplinary file, in addition to any other file locations. The term "disciplinary action"
means denial of privileges, lockdown, infractions, or segregation in response to misbehavior, but
does not include verbal reprimands or instructions that are not accompanied by punishment or
loss of privileges.
system.
W. The Jail will develop and implement an objective inmate classification
X. All altercations between inmates involving the use or threat of violence of
which Jail staff are aware shall be documented. Inmates threatening fights with each other will be
separated, unless either the corrections officer or the inmates themselves are able to resolve the
issue between the inmates.
y. All use of force by Jail staff, including application of restraints, shall be
documented in an incident report. Copies of the incident report will be kept in a central incident
report file and in the individual inmate's file.
Z. The Jail shall keep accurate records of the good time credits applied for
and awarded pursuant to its written Policies and Procedures, and reports of good time credits shall
be made available to inmates weekly upon request. No good time credits will be revoked without
notice to the inmate and an opportunity for a hearing.
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CARNEY LAW OFFICES
BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN SEATTLE, WA 98104-5017
FAX(206)467-8215
TEL (206) 622-8020
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aa. The Jail will keep accurate computerized records of inmate commissary
accounts. Such records will be made available to the inmates weekly upon request.
bb. All current Jail staff will attend professionalism training from an outside
provider within one year of the execution date of this agreement. The content and provider of the
training will be of the Jail's choosing, so long as the training is offered by or approved by the
National Institute of Corrections, the American Correctional Association, the Washington
Association of Sheriffs and Police Chiefs, a similar nationally accredited corrections organization,
or as otherwise agreed between the parties to this Settlement Agreement. Thereafter, all new
hires will undergo the same training. A refresher course will be attended at least every five years
by staff with continuous service for five years.
cc. There will be a minimum of two correctional staff budgeted by the County
and scheduled by the Jail for duty at all times. County employees operating the dispatch desk are
not considered correctional officers for purposes of this paragraph.
dd. The Jail's ban on outside reading material shall be rescinded as of the
execution date of this agreement. It its place, the Jail may implement content -based prohibitions
with regard to literature received by inmates, so long as those policies do not infringe upon those
First Amendment rights retained by the relevant parry. Books may be limited to those shipped
directly from the publisher or retailer and received unopened at the Jail. The Jail will incur no
liability for failure to forward incoming mail, publications, or books to inmates who have been
released from the Jail.
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CARNEY LAW OFFICES
BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 622-8020
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ee. The Jail's ban on printouts from the Internet is rescinded. The Jail may
impose a limit on the number of pages of intemet printouts per day an inmate may receive by
mail, as long as the limit is not less than ten pages per inmate per day. Incoming Internet
materials shall be subject to review by Jail staff pursuant to the Jail's content -based restrictions,
and such documents may be withheld by the Jail on this basis, so long as those policies do not
infringe upon those First Amendment rights retained by the relevant party.
ff. Mail may not be withheld, delayed, or denied as a disciplinary device.
The Jail may withhold mail to prevent violation of a protective order, violation of a noncontact
order, or other criminal conduct. All deliverable mail shall be given to inmates within two
business days of receipt by the Jail.
gg. Upon request, inmates will be allowed to make confidential phone calls to
counsel on an unmonitored phone outside the hearing of Jail staff and other inmates. If requested,
inmates shall be afforded at least two attorney calls per day and may receive calls from their
attorney within two hours of requesting an opportunity to receive a call from their attorney.
hh. Jail staff will not read outbound or inbound legal mail. Incoming
envelopes marked "legal mail" may be opened by Jail staff and inspected for contraband only in
the presence of the recipient. Nothing contained in this paragraph, however, shall preclude the
Jail from taking the necessary steps to ascertain whether an item purporting to be legal mail is
actually legal mail.
SETTLEMENT AGREEMENT — 11
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CARNEY LAW OFFICES
BADLEY A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, 85800
SPELLMAN SEATTLE, WA 98104-5017
FAX(206)467-8215
TEL (206) 622-8020
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ii. The Jail will not have scheduled daily lockdown periods during daytime
hours. The Jail may impose daytime lockdowns if necessary for security reasons, with any
security lockdowns documented in an incident report.
jj. Defendants will make payment to the "American Civil Liberties Union of
Washington Foundation" in the amount of $82,500.00 within ten days of the execution date of
this agreement. Such payment shall be in full settlement of any and all attorneys' fees and costs
incurred by plaintiff Shawn Omdorff and/or the class as of the execution date.
Settlement Agreement by Plaintiffs
6. Plaintiffs agree that, upon this Court's approval of the Settlement Agreement,
plaintiffs' Complaint under the above cause number shall be dismissed with prejudice pursuant to
the Stipulation and Order of Dismissal.
Mutual Settlement Agreement by Defendants and Plaintiffs
7. a. An independent monitor or monitors, mutually agreed upon by the parties
and paid for by the County, will make periodic visits to the Jail and shall have full access to
inmates, records, and facilities. The monitor will make the first of such visits on a date
approximately one year after the date of execution of this Settlement Agreement. Thereafter, the
monitor shall visit and evaluate the Jail's compliance with this agreement two times per year until
36 months have elapsed from the execution date of this agreement. Counsel for Plaintiffs and
Defendants shall use their best good -faith efforts to agree to a monitor or monitors at reasonable
cost to the County. In the event the parties are unable to agree on monitor(s), they will submit
SETTLEMENT AGREEMENT — 12
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CARNEY
LAW OFFICES
BARLEY
A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN
SEATTLE, WA 981045017
FAX (206) 467-8215
TEL (206) 622-8020
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their nominations in a motion to the federal court or to a mutually agreed upon outside arbiter.
The approximate schedule for monitoring shall be as follows:
Visit/Report Time
(1) 1 year after execution of the agreement;
(2) 1.5 years after execution of the agreement;
(3) 2 years after execution of the agreement;
(4) 2.5 years after execution of the agreement;
(5) 3 years after execution of the agreement.
The monitoring shall be broken down into two main categories, entitled "Facilities/Operations"
and "Medical." If the Jail is found to be in full compliance in either of these areas for two
consecutive monitoring periods, the monitoring for that category shall terminate. If the monitor
for either category does not report substantial compliance on the last monitor visit scheduled
above, the duration of the agreement will be extended and additional monitor visits scheduled on
six-month intervals, until such time as the monitor reports substantial compliance. Under no
circumstances will the agreement be extended more than an additional two years past the
originally scheduled termination date.
b. Plaintiffs must attempt to resolve any and all disputes concerning the
Defendants' continuing compliance with this Settlement Agreement through the following
dispute resolution process. Plaintiffs shall inform counsel for Defendants in writing of any
alleged substantial non-compliance. If the issues are not resolved at that stage, counsel for
SETTLEMENT AGREEMENT — 13
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CARNEY
LAW OFFICES
BADLEY
A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SPELLMAN
SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 6223020
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Plaintiffs and counsel for Defendants shall meet and confer in good faith to try to resolve any
differences. If the issues are not resolved at that stage, the parties and their counsel must attempt
to resolve the issues at mediation using a mutually acceptable mediator. If the dispute is not
resolved at mediation, Plaintiffs' counsel may file a motion in this Court. This Settlement
Agreement does not require Plaintiffs to exhaust the Jefferson County Jail's administrative
grievance process prior to attempting to resolve any disputes through the alternative dispute
resolution process described in this Settlement Agreement.
C. The prevailing party in any motion to enforce this agreement shall be
entitled to recover attorneys' fees and costs consistent with applicable law and the Prison
Litigation Reform Act. Otherwise, each party shall bear its own costs and attorneys' fees
regarding this Settlement Agreement. Nothing in this Settlement Agreement precludes the use of
any other type of alternative dispute resolution process that the parties agree to use to resolve
disputes.
d. This document is not a Consent Decree, but it is an agreement that is
enforceable through the remedies specified herein. None of the provisions contained in this
Settlement Agreement should be construed as creating or extinguishing any statutory rights or
federal constitutional interests. In the event a federal court rules it is without jurisdiction to
enforce this Agreement, the parties may seek enforcement, including specific performance, in
Washington state courts under applicable law.
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CARNEY
LAW OFFICES
BADLEY
A PROFESSIONAL SERVICE CORPORATION
SPELLMAN
700 FIFTH AVENUE, #5800
SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL(206)622-8020
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e. Class counsel will have full access to inmates, records, and facilities upon
24 hours notice to the Jail.
f. This Settlement Agreement constitutes the final written expression of all
of the terms of settlement and is a complete and exclusive statement of those terms. No other
agreements, oral or written, bind the parties.
g. This agreement may be modified at any time by a written and signed
document executed by mutual agreement of plaintiffs' and defendants' counsel. To give the
provisions contained herein an opportunity to be implemented and evaluated, the parties agree not
to challenge this agreement for a period of three years from the execution date.
h. The undersigned hereby acknowledge that the terms of this Settlement
Agreement have been completely read, wholly understood, and voluntarily accepted for the
purpose of making a full, final and binding compromise, adjustment and settlement of any and all
claims, disputed or otherwise, that are asserted in the Complaint.
i. This Settlement Agreement may be signed in counterpart originals and
may be delivered by facsimile with originals to follow. Defendant Jefferson County certifies that
Dan Tittemess has authority to bind the County to the terms of this Agreement.
For Defendants:
JEFFERSON COUNTY���
By:
Dan Titterness
Dated: lG-i- 2oo 3
SETTLEMENT AGREEMENT — 15
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CARNEY
LAW OFFICES
BADLEY
A PROFESSIONAL SERVICE CORPORATION
SPELL1.p,� ,� �T
700 FIFTH AVENUE, #5800
-ME,
AN
SEAT WA 98104-5017
FAX (206) 467-8215
TEL(206)622-8020
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2 By Ao���'
Sheriff ike Br d
3 Dated:
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5 For Plaintiffs:
6
7 NATIONAL PRISON
8 '47Y7
9 By Jo -
David C. Fathi
10 Attorney for laintiffs
Dated:
�Q
11
THE
12 I I AMERICAN CIVIL LIBERTIES UNION OF
WASHINGTON
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14 By
Aaron H. Caplan'
15 Attorneys for Platiffs
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Dated: T�q
17 For Plaintiffs:
18 By f` �✓ `
19 Shawn Orndorff
20 Dated: - - 03
21
CARNEY
SETTLEMENT AGREEMENT - 16 BADLEY
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WCRO01 0033 ef064404 8129/03
LAW OFFICES
A PROFESSIONAL SERVICE CORPORATION
700 FIFTH AVENUE, #5800
SEATTLE, WA 98104-5017
FAX (206) 467-8215
TEL (206) 622-8020
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Approved as to form:
CARNEY BADLEY SPELLMAN, P.S.
I BY
David W. Silke
Jon A. Payne
Attorneys for Defendants
Dated:
SETTLEMENT AGREEMENT — 17
CV02-5096
W CR001 0033 CR)64404 9/8/03
CARNEY
BADLEY
LAW OFFICES
A PROFESSIONAL SERVICE CORPORATION
SPELLMAN
700 FIFTH AVENUE, #5800
SEATTLE, WA 98104-5017
FAX(206)467-8215
TEL (206) 622-8020