Drug Testing of Prisoners in Michigan 1970s
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UNTIED COURT OF APPEALS STATES POR THE SIXTH CIRCUIT NO 711170 FRANK WALTER ROGERS BILLY LEE GEORGE MILLS LEE BOYT SLAGI3R PIITISR ORDELL LEE WALKER CLEMONT DIIDEAUX WILLIAM CLEARY 1IERBISRT VILI3LJRN BENNY SPELLS FRED LIOLNACEL WILLIAMS ORCEAN RAYMOND BAILEY KENNETH INMAN JERRY MACK BOYD KELTON THOMAS CALVIN ALLEN WILLIAMS RICHARD SIMS DAVIS SAWICKI LORD RALPH WATSON CHESTER RALPH VERNON MEVIS PI4ILLTP MCGIIHE PAUL ROSS KENNEDY WARNER RONALD NORMAN PAUL MTLIER HERNAN HEAD GERALD LONNIE PAYNE ROBERT THOMAS MULLIGAN KENNETH AND ESPICLI MASON GAYLORD MARSHALL PLAINTIFFS APPELLANTS CO CORPORATION MICHIGAN PARKE DAVIS CORPORATIOLL DELAWARE THE UPJOHN CO STATE OF DEPARTMENT OP CORRECTIONS OF THE JAMES WADSWORTH ELEANOR HUTZEL MICHIGAN PARLEY ERNEST BROOKS MAX BIBER VATERS FLORENCE JOHN IV RICH DUANE ROBERT COTTON AND GROSS CRANE JOSEPH GUS HARRISON NOFENDANTSAPPELLEES COURT OF THE UNITED STATES FOR APPEAL FROM THU DISTRICT SOUTHERN DIVISION OP MICHIGAN THE EASTERN DISTRICT APPENDIX FOR PLAINTIFFSAPPELLANTS LEITSON DEAN DEAN SEGAR HART SEGAR ROBERT 1616 GONESCE TOWERS 48302 FLINT MICHIGAN PLAINTIFFSAPPELIANTS FOR ATTORNCYS BY PC OF APPENDFX OP CONTENTS TABLE PAGE IN DOCKET UNTRICS 4A COMPLAINT ANSWER OF PARK EAVIS ANSWER OF THE PLAINTIFFS THE ACTION CLASS COMPANY TO 34A SIMS SHALL SUPPORT IN CO NOT BE OF SOA SUMMARY JUDGMENT FOR MOTION UPJOHN 49W SUMMARY JUDGMENT FOR MOTION OF CALVIN BY 24A CO UPJOHN INTERROGATFLRLES PLAINTIFFS MOTION THE PARK DAVIS PLAINTIFFS PLAINTIFFS TO BY INTERROGATORIES AFFIDAVIT 19A CO UPJOHN ANSWERS AND OBJECTIONS ANSWERS OF 14A COMPANY MA PLAINTIFFS THAT AS SZA ACTION MOTION BY THE UPJOHN FFS OF PLAINTI CO TO DISMISS COUNT TI 53A CONIPLAIRIT COMPANY TO ANSWER OF PARK DAVIS PMINTIFFS 54A INTERROGATORIES ADDITIONAL SSA AMENDED COMPLAINT ANSWER OF MEMBERS OF DENT TO AMENDED LAWOFF LEITSON DEAN DEAN SECAR HART RE STNTAETOWR CNE INST PUNT TVBCII 45 SSSST OF RALPH AFFIDAVIT OF WARDEN AFFIDAVIT OF AFFFIDNVIT PLAINTIFFS 6TH WILLY GEORGE BOYD SLAGER OF CORRECTIONS COMPLAINT AFFIDAVIT PLAINTIFFS OF MOTION CHESTER MOTION IN FOR 77A KROPP SUPPORT OF 90A SUMMARY JUDGMENT SAWICKI FOR 72A ADMINISTRATOR IN SUPPORT SUMMARY JUDGMENT OF 93A PAGE DEDEALIX OF CLEMENT AFFIDAVIT PLAINTIFFS ANSWERS OF THE FOR MOTION CO UPJOHN IN SUPPORT OF 95FL SUMMARY JUDGMCNT PLAINTIFFS TO C4 ADDITIONAL MOTION DEFEADANTS COUNT 97A INTERROGATORIES FOR ON SUMMARY JUDGMENT 10TH OF COMPLAINT DEFENDANTS MOTION FOR ON SUMMARY JUDGMENT 104A III COUNT DEFENDANTS MOTION FOR ON SUMMARY JUDGMENT 106A COUNTLV AFFIDAVIT ATTACHED MEMORANDUM RO PRISON CLASSIFICATION OF AFFIDAVIT OF COMMITTEE DEFENDANTS MOTION OF RALPH DEFENDANTS LIST MOTION PLAINTIFFS HAFLT HAL ONE FLINT OENESEE WIRT L1ICH OWVRS 5T DETAIL EXHIBIT LETTER FROM UPJ EXHIBIT INVOICE TO THE EXHIBIT SHIPPERS EXHIBIT P4 G4 JOB IN ADIULNISTRATOR UPJOHN CO 14TH 14TH 14TH RECEIPT MATERIALS TO LETTER RELATING TO LSOA CLINIC AND MEMORANDA RE INNATE LSSA EXPENSES DESCRIPTION RESEARCH CLINIC 4S50A 3FLFLS II 14TH FOR UPJOHN SUBSIDIARIES OF PAY EL OBRI LSZA FLOCUMENTS EXPENSES LISTING EXHIBIT 12TH 127A INMATE EXHIBIT LQSA OF SUMMARY JUDGMENT FOR A7 DEAN PC SUPPORT IN EXHIBIT EXHIBIT SUPPORT EXHIBITS ADDITION DEAN IN FOR SUMMARY JUDGMENT WILLY CLINIC LEITSON KRUPP WITH OF WARDEN CTHORGE STAFF PHYSICIAN 166A PAGE LETTER EXHIBIT RE DENT IUIT MEMO TO INMATE EXHIBIT CLINICS IN EXPENSES HEATING EMPLOYEES RE L69 ABSENTEEISM MEMO RE UPJOHN EXHIBIT LETTER DATED UPJOHN ADTANISTRATOR 22266 170A S5 PROTOCOL EXHIBIT FROM 171A MEMO RE MISCELLAFLCOUS TNTERCCFICE EXHIBIT 17TH MATTERS PROTOCOL EXHIBIT UZ1 OF AFFIDAVIT GAYLORD MEMORANDUM OPINION ORDER GRANTING CLASS FOR LAW OFRICES DEAN DRAN SEGAFL HART PC DLL OINESFE ONE FLINT TTWERS FIR5RSTTEL MICH 03 4L OF IF AND TO PERTAINING FOR TO 173A LINCOSIN PERTAINING 96 ESPICH IN TO SUPPORT ORINASE 178A SUMNARY JUDGMENT L0S MOTTON PERTAINING DISMISS DENYING SUMMARY JUDGMENT 174A OF COURT DEFENDANTS ACTION JUDGMENT LEE MOTION PLAINTIFFS GG ZSLP PROTOCOL EXHIBIT 168A AND FOR PLAINTIFFS TO SUMMARY MOTION 223A ZEV1NT DOCXEP ENTRIES LII 1968 APR 23 FILED COMPLAINT ADD PARTIES TO MAY MOTION MAY ORDER TO ADD PARTIES AND ENTERED TILED PLAINTIFF FILED APPEARANCE OF TJPIOHN COMPANY FILED JUNE 17 APPEARANCE OF PARKE DAVIS JUNE 26 ANSWER OF PARKE ANSWER OF THE CO FILED COMPANY FILED FLAVIS UPJOHN 21 ROTH 16 JULY RULE TO PURSUANT PLAINTIFF MAY CO PROOF OF SERVICE WITH FILED AND ORDER TO ADD PARTY MOTION JULY 17 AUG 14 INTERROGATORIES AUG 14 INTERROGATOR SEPT 30 MOTION OCT 14 PTT FILED AND ENTERED 21 14 AS TO TO DEFT UPJOHN CO DAVIS TO FILED COMPANY FILED FRCP ANSWERS OF PARKE CO DEFT PARKE DAVIS AND ORDER TO ADD PARTY PTF FILED AND ENTERED PURSUANT TO RULE WITH INTARROGATORIES FILED EXHIBIT OCT 21 TO RULE PURSUANT TO PTFS INTERROGATORIES ANSWERS AND OBJECTIONS AND PROOF OF SERVICE UPJOHN CO WITH EXHIBIT BY FILED 1969 LAW NOTICE OF PRETRIAL MAY NOTICE OF REVISED SECAR HART DRRNOLR RTRZA MFCH 4S FOR MAY PRETRIAL FOR MAY FILED 2669 SEPT 2969 TO DEFENDANT FILED 26 PROTRIAL JULY 16 ADDITIONAL JULY 16 AND REQLNRANC MOTION FOR ORDER OF THE COURT DIRECTING UNDER OATH DEFENDANTS ANSWER INTERROGATORIES WITH TO DEFENDANT THE UPJOHN INTERROGATORIES FLIED NRG ON AUG 1169 PROOF OF SERVICE CO HAD AND ADJ 1269 MAY TO INTERROGATORIES FILED PARKE DAVIS CO QF OEATT FLINT MAY SEPT 29 PRETRIAL OCT 30 MOTION FOR HAD ORDER OF THE AND RDQNIRIN COURT DIRECTING UNDER OATH WITH DEFTS TO ANSWER INTETROGATORIES FILED EXHIBITS OCT 30 MOTION WITH OCT 30 MOTION 21 OCT 30 FTFS ST FOR TRIAL SUPPORTING DEFT ADD TO FRCP PARTIES WITH BRIEF MOTION TO DISMISS COUNT RANDUMN AND CERTIFICATE CO 12 M6TION OF PTFS TO ADD PARTIES 12 MOTION OF PTFS TO ADD PARTY EXHIBIT NOV 18 ORDER TO ADA PARTIES FREEMAN NOV MEMO OF IT OF COMPLAINT WITH FILED FOR SERVICE PTF FILED NOV AND MOTION OF UPJOHN CO FOR ORDER THAT PTFS ACTION SHALL NOT BE MAINTMNED AS CLASS ACTION WITH FILED BRIEF AND CERTZFCATE OF SERVICE NOV NOV 20 SUMMARY JUDGMENT PURSUANT TO RULE AND BRIEF WITH AFFIDAVIT OXHIBIT MOTION UPJOHN TO RULES PURSUANT FILED FOR FRCP FILED NOV 39B TORULE JURY PURSUANT AFFIDAVIT FILED 18 ORDER TO ADD PARTIES PTF EXHIBIT WITH FILED CWITH PTF FILED AND ENTERED PTF FILED AND ENTERED FREEMAN NOV 24 NOTICE OF HEARING ON PENDING MOTIOHS FOR FOB FILED DEC 16 CO ANSWERS OF PARKE DAVIS ROGATORIES AND AFFIDAVIT 970 INTER TO ADDITIONAL RILED 1970 JAN 21 AMENDED FEB 10 ANSWER OF INDIVIDUALS 12 AFFIDAVIT IN JUDGMENT FEB 16 AFFIDAVITS SUPPORT OF JUNE SUPPORT OF OA 24 FOR WITH CO TO ADDITIONAL FOR SUMMARY SUMMARY INTORROGATORIES AFFIDAVIT FRCP OF HEARING FOR SEPT 1470 ON PENDING TO MOTIONS FILED DEAN SEGAR HART EG RUNT MICH NOTICE MOTION PTFS MOTION LAW OFFICES JULY AND PROOF OF AND ORDER TO ADD PARTIES PTF PURSUANT FILCD AND ENTERED 21 T4OTION RULE LFITSON ETHIBIT PTFS FILED ANSWERS OR UPJOHN FILED WITH ISSUED FILED IN JUDGMENT MAR SUINMONS FILED SERVICE FEB FILED COMPLAINT AUG 17 MOTION OF UPJOHN JUDGMENT WITH FILED AND PARKE AFFIDAVITS DAVIS CC AND SUPPORTING ROT SUMMARY BRIEFS SEPT 10 SEPT 11 NOV NOV DCC HAD MENT TO DISMISS FILED DATED FOR NOV 970 NOTICE OF HEARING FILED HEARING NOV OF MICHIGAN MOLTEN OF STATE PORTING BRIEF ON PENDING MOTIONS WITH MAR 2670 ON PENDING TAKEN SUP MOLIONS UNDER ADVISE FREEMAN AFFIDAVIT OF CAYLORD LEE ESPICH IN SNPPORT OF PTFS MOTION FOR SUMMARY JUDGMENT AND PTFS ANSWER TO DEFTS MOTIONS FOR SUMMARY UDGRNENT FILED 12 28 COS PARKE DAVIS PERTAINING AFFIDAVIT FILED WITH RESPECT TO MOTIONS POSITION FILED DAUNT II AND TO CLASS ACTION TO OF WARDEN GEORGE REC JAN 2170 KROPP ND EXHIBITS 1971 DRAN DEAN SESAR HART PC 604 RLINT DFTROFR STREET MICII A503 FREEMAN MEMORANDUM OPINION FEB TO CLASS ORDER GRANTING DEFTS MOTIONS PERTAINING ACTION TD DISMISS AND FOR SUMMARY JUDGMENT AND DENYING PTFS MOTION FOR SUMMARY JUDGMCNT FILED AND ENTERED FREEMAN FEB PTFS MAR FOR DISTRICT STIPULATION PURSUANT TO RUIC 11F OF THE RECORD TO RETAIN COURT PARTS MAR NOTICE MAR LAW OJCES AND ENTERED JAN 15 NOTICE TILED OF APPEAL OF MAILING ACKNOWLEDGMENT FILE FILED FILED TO CCA FILED COMPLAINT 42368 FILED APR2 TCFL UNITED CO FOR THE STATES DISTRICT COURT WTT 11 JOUR FL OF MICHIGAN EASTERN DISTRICT SOUTHERN DIVISION FRANK RICHARD ALLEN WALTER BILLY LEE WILLIAMS ROGERS LEE BOYD SLAGERI PETER GEORGE MILLS LEE WALKER CLEMONT DEDEAUX WILLIAM CIJEARY OPDELL VITJSURK FRED HOLNAGEL HERBERT WILLIAMS KENNENI INMAN BENNY SPELLS ORCEAN DAVIS RAYMO1 IT BAILEY JERRY MACK AND BOYD KELTON CALVIN E4T SIMS CASE NO JUDGE COMPLAINT PLAINTIFFS IS CO MICHIGAN PARKE DAVIS AND TILE UPJOHN CORPORATION DELAWARE CORPORATION CO DEFENDANTS PLAINTIFFS OF DEFENDANTS COMPLAIN AS FOLLOWS COUNTI OF THIS JURISDICTION TITLE 29 216 STANDARDS COURT IS UNITED STATES SEC II ACT 16 GROUNDED UPON CODE ANNOTAEED THE FAIR LABOR SEC OF OF 1938 AS AMENDED STATES CODE ANNOTATED THE DISTRICT COURT SEC GIVING CIVIL ACTION OF ANY JURISDICTION ORIGINAL AT ACT UNDER OR PROCEEDINGS ARISING ANY COMMERCE WITHOUT REGARD CONGRESS REGULATING IN AMOUNT OR OF THE PARTIES TO CITIZENSHIP TITLE 28 UNITED 1337 IT CONTROVERSY LEFL DEAN TITLE 28 UNITED STATES CODE ANNOTATED SEC13 TITLE 42 UNITED STATES CODE ANNOTATED SOCJ9E33 DEART SEOARHART ATTQ P04 FLINT AR LAW R7 ZUER MICII AOOQS THIRTZECNTH AMENDMENT CONSTITUTION TO THE UNITED STATES THIS TO SEC OF THE FAIR 16 USCAI ACTION SEC 201219 LABOR COURT COSTS AND PLAINTIFFS PRISON IS MICHIGAN FOR CORPORATION DEFENDANTS ARE PROFIT PRIVATE BEEN JACKSON AFTER INMATES CIVIL IT IS CLINICS CORPORATIONS CURRENTLY DSAN ABRAM SEGAR ATTO Q4 HART AT TP FLNT MCII CEDAJB5E IN OTHER THINGS AND PRODUCED INTERTTATE THE STATE THE DRUG OF MICHIGAN 1963 OF ALL JOIN CLINXCS THE THE INCLUDE WELL FOR SOLD AS OF OF THE THIS RULES FEDERAL THE AS PLAINTIFFS OF SAID SAID AR AND CLINICS AMONG OF DRUGS NOT PRESENTLY TESTING OF OF THE RESEARCH MICHIGAN CONTINUOUSLY IN ACTIVITIES WITHIN ERECTED PURPOSES HAVE BEEN TESTING THE NAMED CLASS AT JACKSON MAKIHG TRANSPORTED AND THE SUCH PEOPLE WHOSE NUMBER MAKE SAID CLINICAL AT HEREIN AS SUCH UNNAMED PEOPLE 23 ARE SOUTHERN MICHIGAN THE NAMED DEFENDANTS PROFIT PRIVATE SAID WHO EITHER NAMED PLAINTIFFS TO RULE REPRESENT OPERATION ON THE MARKETAS CO BOTH ENGAGED SAME CAUSE OF ACTION OF SOUTHERN MICHIGAN FOR THE DELAWARE REPRESENT TO HAVETHEM IN L5ITSOND PART OF PURSUAHT ADEQUATELY PRISON TIMES DAVIS COMPANY IS STATE TIXE ALL ENGAGED IN PRISON STATE THE PROCEDUREON BEHAAF PLAINTIFFS STATE IN ADEQUATELY BROUGHT IMPZACTICAL OF PROFIT ARE NUMEROUS OTHER PEOPLE FORTH ON THE NAMED PLAINTIFFS ACTION AT PARKE THROUGHOUT THE WHO HAVE THE MICHIGAN SET INMATES COMMERCE THERE OR HAVE AMOUNTS DAMAGES MICHIGAN SIMILARLY BUSINESS DOING INTERSTATE AND IN TH ON SAID FEE DEFENDANT RIVATE 29 UNPAID LIQIDATED HAVE BEEN AT JACKSON FOR CORPORATION AND DEFENDANT INDUSTRY OR CAUSE OF ACTICA THIS TO RELEVANT ARE SOUTHERN MICHIGAN OF ATTORNEYS PURSUAN 1938 OF INTEREST AMOUNT AS REASONABLE ACT FROM DEFENDANTS CCMPENSATIOZK DUE AN EQUAL ADDITIONAL SINCE COUNT PART STANDARDS TO RECOVER WAGES AND OVERTIME MINIMUM BROUGHL IN IS DRUGS CURRENTLY SHIPPED COMMERCE THROUGHOUT THE UNITED AND DELIVERED STATES BEING IN THE TJSCA OF 29 MEANING CERTAIN BY SAID SAID EMPLOYEES HUNDRED INMATES WORK ON 112 TWELVE NONPRISION PAID NT FI IS IS EXACTLY PERSONNEL COSTS OF RUNNING DEFENDANTS SUCH AS POWER TO ONE DOLLAR HEAT CHIEF IN CLASSIFIED AREAS CHIEFOLERK B04 IF AND OF THE WAGES 125 25100 CLINIC ARE PAID PER BY OF THE INMATES EACH CLASSIFICATIONR ARCAS TECHNICIAN CLERKS KITCHEN TRAINEES NURSE SUPERVISOR POT AND PAN MAN HEAD PORTER OF THE STOCKHOLDERS STATE BY PLAINTIFFS ACTAVITY OF DEFENDANTS NOT ACCOMPLISHED ACCOMPIN SHED BY CIVILIAN FEDERAL CLASSIFIED ASSISBANT COOK KITCHEN AND IN TECHNICIAN ALL AND REQUIRED CAPACITIES CLASSIFICATIONS TECHNICIAN OF THE ONE AND WATER TRAINED WORK WHICH HART SEGAR ANORNEYSATLAW JOB THE FOLLOWING BENEFIT MUCH AS ON BY TH9 NAMED PLAINTIFFS ARC THE ALL DEAN DEANASRAM UP TO AS TO EACH WORKEC RANGE FROM OTHER MAN AND REPRESENTATIVES COMPARABLE DEFENDANTS AMONG THE LEITSON IN WORKING DAY AND ALL MAINTENANCE THE THE SOLE ON UNDER SAME WORK THAT WOULD HE THE 035 CHIEF TO BE COMMISSION HOURS PER WEEK CENTS NURSE WITH RESEARCH CLINICS REGNLAR BASIS BY THE RESPECTIVE ALL INCLUDING CONJUNCTION CARRIED THIRTYRIVE IN PRISON CORRECTIONS THE WORK CARRIED OTHER INMATES IN OF DEFENDANTS AND SUPERVISION DIRECTION SAID THE AFORESAID AT EMPLOYED BY DEFENDANTS WORK THEREIN OF INMATES OF THE MICHIGAN REPRESENTATIVES WITHIN COMRNCRCTI SEC 203 BY DEFENDANTS WCRE PICKED PLAINTIFFS INTERSTATE ENGAGED IN ARE ONTERPRISES NEFEADAUTS HELP BY SAID PAID IN MARES CORPORATIONS INMATES AND WOULD HAVE ACCORDANCE WITH TO THE INVOLV TO BE APPLICABLE LAWS DETRNT FUNT MJCN 4C503 10 WITHIN THE MCANIN9 PLAINTIFFS OF THE IFAIR WERE AND LABOR ARE EMPLOYEES STANDARDS ACT OF DEFENDANTS OF 1938 AS AMENDED USCA 2S MINIMUM THE TO BE PAID SEC 11 PLAINTIFFS BETWEEN AND THE MINIMUM DAMAGES LIQUIDATED AMOUNT AS ATTORNEYS FEE THEY WERE DUE AS WELL 12 AN ADDITIONAL EQUAL REASONABLE BACK WAGES SINCE ON SAID OF OVERTIME AMOUNT THE ACTUALLY THE AMOUNTS AS ALL PAID THE KNOWLEDGE OF THE DEFENDANTS WITHIN RECORDS WHICH THROUGH THE WELL AS LAW BY SAID COURT COSTS AND DISC BY EACH AMOUNTS RECEIVED NUMBER OF HOURS AND THE IS DUE INTEREST AS WORKED BY EACH PLAINTIFF TOCACH PLAINTIFF MAY BE FROM TO RECOVER WAGE GUARANTEED THAT COMPENSATION OVERTIME THE ACT SAID TN ENTITLED ARE ARE ENTITLED WERE AND AND FOR WAGES PROVIDED THE DIFFERENCE DEFENDANTS SEQ EL 201 THEY KEEP PLAINTIFFS REGARDING EMPLOYMENT SEEK WHEREFORE PLAINTIFFS OF I000OO0O0 ONE MILLION POLLARS IN JUDGMENT THE COSTS AND INTEREST PLUS AMOUNI FEE ATTORNEYS CDUNTR II AS INCORPORATE THROUGH TWELVE THE ALLEGED PUBLIC THE DEAN OSANASNAM LSITSON 5ECAH ARFO 604 BSTROT LAWS AFORESAID ACTS OF 1964 EMPLOYMENT OF THE STALE WAGE LAW OF 1964 MINIMUM OF THE STATE HEREIN 12 THE ALLEGATIONS OF COURT NUNTHER OF MICHIGAN BEING HEREOF BY DEFENDANTS OF ACT SHOULD 154 OF CON KNOWN AS OF THE SEC 408381 OF 1938 ACT EMPLOYERS HEREIN AS THE COMPILED THIS COURT DETERMINE THAT THE FAIR STN SLANDRADS HEREB OF MICHIGAN HART 14W BY SUCH REFERENCE OF VIOLATION IN IS AM REPEATED THOUGH EXPRESSLY ONE OF PARAGRAPHS TO RCFER PLAINTIFFS AS CEDAR THEN THE AMENDED DOES NOT MINIMUM APPLY TO DEFENDANT WAGE LAW OF THE STATE OF LABOR MICHIGAN ACLION IS BASED IN RECOVERY OF THE PART OUT UPON AMOUNT AS SEC ARE OF SAID MIMIMURN THE IN SEEKS AND TO PLAINTIFFS WAGE LAW AND FOR FEE EMPLOYERS PLAINTIFFS AND EMPLOYCS WAG LAW SEEK JUDGMENT AGAINST AMOUNT OF ONE MILLION COSTS AND INTEREST PLUS THIS AND DAMAGES TOGETHER WITH ATTORNEYS WHEREFORE PLAINTIFFS DEFENDANTS ACT MINIMUM LIQUIDATED FLEFENDANTS WITNN THE MEANING THORROF 14 OF SAID 13 BY SAID REASONAHL COSTS AND SCC IN BOTWEON THE AMOUATS PAID WAGE PROVIDED AN EQUAL ADDITIONAL INTEREST SET DUFTERONCO THE MINIMUM AND AS APPLY DOLLARS FEE AFRTORNEYS COULQT PLAINTIFFS INCORPORATE PARAGRAPHS HEREIN AS EXPRESSLY PARTICULARLY CONTRARY BY SUCH REFERENCE REPEATED 12 OF COURT THROUGH TWELVE ONE TO AND THOUGH EXPRESSLY THE IS REFER APPOINTMENT TO THE SEC 800305 OF OF SAID LAW OF THE CL48 THE HEREOF INMATES STATE WHICH ALLEGATIONS BY DEFENDANTS OF MICHIGAN PROVIDES IN PERTINENT PART NOR LABOR OF PRISONERS SOLD CONTRACTED FOR OR HIRED LEASED LOANED OTHERWISE USED FOR PRIVATE OR CORPORALE OR FOR ANY OTHER PURPOSE THAN THE PROFIT CONSTRUCTION MAINTENANCE OR OPERATION OF PUBLIC WORKS WAYST OR PROPERTY AS DIRECTED BY AND FL SECAF LEFTCON OEAT4 A5F ARROSNFY AT LAW FLETNDIT FLINT TNT MICW CZTAN SHALL THE CL SEC 800310 IT THIS IS THE GOVERNOR 48 WHICH PROVIDOS HEREBY DECLARED IN PERTINENT TO BE THE INTENT PART OF ACT TO PROVIDE ADEQUATE REGULAR DIVERSIFIED SUITABLE EMPLOYMENT FOR PRISONORS OF THE STATE CONSISLENT WITH PROPER PENAL PURPOSES AND AND THE LABOR OF PRISONERS TO UTILIZC AND FOR SELF MAINTENANCE FOR EXCLUSIVELY OF STATE FOR EXPENSES LNCORRED REIMBURSEMENT CRIMES AND IMPRISONMENT BY REASON OF THEIR RELATIONSHIPS PRODUCTS AND ALL COMPETITIVE TO ELIMINATE LABOR OR PRISON BETWECN PRISONER INDUSTRY FREE LABOR OR PRIVATE AND DTSBURSE TO AFFECT THE REQUISITIONING AND DIRECTLY LABOR PRODUCTS PRISON MENT OF PRISON WITH NO AUTHORITIES STALE THROUGH ESTABLISHED AND THEREFRQM PROFITS OF PRIVATO POSSIBILITY FINANCIAL OF INTERMEDIATING WITH THE MINIMUM OR EXPENDITURES CONSIDERATIONS DEFENDANTS FOR IN RESULTED AND FLEFENDANTS IN IS THE THE PLAINTIFFS WITH AND UNJUSTLY BENEFITING BY THE REARON THE IS AT WAGE LAWS OF THE THE AND OF MICHIGAN STAT THE BETWEEN VALUE OF THEIR SERVICES WOULD BE DUE THEM UNDER THE MINIMUM THE AMOUNT WHICH LEAST OF VALUE TO THEY ARE RL SERVICES OF BEING IS DIFTEREN THE REASONABLE AND VALUE AND KNOWLEDGE THAT FULL ILLEGALLY TO PLAINTIFFS AMOUNT PAID HAS BEEN OF PLAINTIFFS LABOR OF BY DEFENDANTS AMOUNT PAID THE INTERESTHAS AND REASONABLE THE OF LABOR AND ENRICHMENT THE UNJUST IN EXCEEDS SCRVIC PROFIT PRIVATE AMOUNT BY WHICH BY DEFENDANTS UTILIZED OWFL RESULTING SERVICES PLAINTIFFS OF THE UTILIZATION THE UNITED STATES BEEN UNJUSTLY OF AMERICA HAVE PLAINTIFFS LABOR OF THEIR OF THC LFLTSON FLE DEAN AE3KAM SEGARSHART ATTQRNIYS OF MICHIGAN AND IN HEREINBEFORE CONTRACTS THE DEFENDANTS AS THEREOF EM BETWEEN DEFENDANTS AND ANY BECAUSE OF VIOLATION OF THE STATUTES SET REGARDING PRISON LABOR ALREADY SET FORTH DEPRIVE LAWS FORTH BETWEEN PLAINTIFFS OTHER PARTY OF THE MICFL 4SS03 OF THE VIOLATION AT LAW FLB4DETR FLINT STATE FRUITS THE AND THEREFORE STATE ND ARE V6ID OF MICHLGAFL FROM DEFENDANTS OF THE AMOUNT DUE TO THEM UNDER ARC ENTITLED FOR SAME INTEREST TO EXCESS IN SERVICES DATES FROM THE THIS FEOUNT ON THE AMOUNTS SAID DUE WHEREFORE PLAINTIFFS IN DEFENDANTS PLUS OT THEIR TO PLAINTIFFS BY DEFENDANTS AMOUNTS PAID PLAINTIFFS WERE VALUE REASONABLE THE TO RCCOVA CNTTTLED ARC THEREFORE PLAINTIFFS TH INTEREST AMOUNT COSTS AND SEEK OF ONE MILLION AGAINST JUDGMENT 100000000 BOLLARS FEE ATTCRNEYS COUNT IV REFER TO AND BY SUCH REFERENCE PLAINTIFFS HEREIN INCORPORATE TWELVE 12 THE LLEGATIONS THE WITH THE THAN THOSE REQUIRED DUE PROCESS OF LAW AND THE HOLDING OF MICHIGAN AMENDMENT DEALING DEAN AAHAM HART ARFQ AT LAW DETROCY STHECT MJCH AS WITH FEDERAL RESULT OF SAID WAGES LESS IN RESULTING PLAINTIFF WITHOUT FOURTSEENTH AMENDMENT AND RESULTING IS SERVITUDE CONTRARY CONSTITUTION UNDER COLOR OF THE SUPERVISION OF OF LAWS OF THE PRISONERS CONDUCTS PLAINTIFFS FLEAN SEGAR RLINT TO THE IS RESULTED INVOLUNTARY CONDUCTS IS ALSO LEITSON IN OF OF THE CONDUCT HAS ALSO SAID STATE VIOLATION IN OF PLAINTIFFS TO THE THIRTEENTH PROPERTY AND BY DEPARTMENTS OF NOMINAL BY DEFENDANTS AND LIBERTY SAID IN THROUGH PLAINTIFFS THE MICHIGAN BY LAW HAS RESULTED OF THE OF COOPERATION DEPRIVA OF EMPLOYMENT ILLEGAL THE PAYMENT AND CORRECLIONS ONE HEREOF OF COUNT DEFENDANTS OF PARAGRAPHS HAVE BEEN FOURTEENTH DENIED EQUAL 7MENDMCNT PROTECTION IN THAT OF THE PLAINTUIFFS JAWS GUARANTEED HAVE BEEN AND BY THE ARE BEING 40E0 ARBITRARILY DISCRIMINATED AGAINST IN THE AMOUNT OF WAGES PAID LO THEM FOR THEIR ENTITLED TO LABOR COLLECT SINCE SEC 1983 OF RRITLE 42 AND SAME WORK WOULD BE WAGE THEREFOR REASONABLE JURISDICTION LII THE OTHERS DOING UNDER THIS SEC 1343 COUNT TITLE 28 IS GROUNDED UPON OF UNITED STATES CODE ANNOTATED THE ACTIONS CAUSED DAMAGES TO PLAINTIFFS COMPLAINED IN THE OF HAVE PROXIMATELY AMOUNT OF ONE MILLION LOOOOOOOO DOLLARS WHEREFORE PLAINTIFFS DEFENDANTS PLUS IN INTEREST HE SEEK LOOOOOOOC DOLLARS AMOUNT OF ONE MILLION COSTS AND ATTORNEYS UDGMENT AGAINST FEE LETTSONDEANDEANAERAMSBOAR ATTORNEYS FOR PLAINTIFFS BY ROBERT DATEPT DEAN DE ABRAM HART ARRO AS LAW AOC FLINT NVT IWLT MC OJ1 APRIL 1963 LSEGAR HART CON TO UNDER TITLE EACH OF THE PARTY NAX THE PURSUANT REQUIRED BY SECTION 29 LABOR 216 COMMENCILLBNT OF LADOR THNDARDS US SEC TILED COMPLAINT STANDARDS ACT STIXI ACT 216 HEREBY UNDERSIGNED ATT FAIR TO THC FATFL CONSENTS TO BE TO RECOVER BACK WAGES AND PARTICA2 AS CTA THEREOF JAJJWUZ 1T2A M6 YLQ PZ INS IY 1I XI V1 LERVSCN BEAN DEAN ABRAM SEGAR AFTOFINEYS 804 RLINR HART AT JAV NRNOIY MICL 40ZO DL 49 CQNSEVT TO COMMENCEMENRP OR LABOR STANDARDS FAIR UNDEIT TITLE EACH PARTY NAMED IN DEAN OEAN ABRAM WZCAR HART ATTORNEYS AT LAW QA FLINT VZTHROIT MICH CO OF THO THE PURSUANT TO THE REQUIRED BY SECTION 29 UND ATTACHED FAIR LABOR 216 USCA CC COMPLAINT STANDARDS THEREOF SUN ACT 216 HEREBY CONSENTS FILED TO BE TO RECOVER BACK ACT AND PARTICULARLY C7 AS WAGES ANSJER OF PARKE COMPANY FILED DAVIS 62668 UNITED STATES OF AMERICA COURT OF THE UNITED STATES THE EASTERN SISTRICT OF MIQIICAN SOUTHERN DIVISION TW DISTRICT EOFL CALVIN SIMS RICHARD ALLEN FRANK ROGERS BILLY LEE WALTER LEE FLOYD WILLIAMS SLAGER PETER GEORGE MILLS LEE WALKER CLEMONT DEDEAUX ORDELL VILBURN WILLIAM CLEARY HERBERT FRED HOLNAGEL WILLIAMS BENNY SPELLS KENNETH INMAW RAYMOND BAILEY ORCEAN DAVIS JERRY MACK AND BOYD KELTON PLAINTIFFS CIVIL NO ACTION 31172 PARKE DAVIS COMPANY MICHIGAN CORPORATION AND THE UPJOHN DELAWARE CORPORATION CO DEFENDANTS ANSWER HI COUNT NOW COMES PARKE DAVIS CORPORATION ONE STONE ITS OF THE DEFENDANTS ATTORNEYS HEREIN BY MILLER AND IN ANSWER TO PLAINTIFFRL ANSWERING PARAGRAPH HONORABLE COURT HAS JURISDICTION FURTHER ANSWERING THE REMAINING COMPANY THIS DEFENDANT ADMITS DEFENDANT NDTHER CONTAINED THEREIN PADDOCK AND SAYS OVER THE SUBJACT MATTER IN THIS SAID PARAGRAPH ALLEGATIONS CANFIELD COMPLAINT THIS MICHIGAN BUT LEAVES ADNIITRI THAT CAUAE NOR DENIES THE PLAINTIFFS TO THEIR PROOFS ANSWERING PARAGRANH DEFENDANT SPECILICALLY CKNLES ANY LIABILITY OF PLAINTIFFS CORNPLAII2T WHATSOEV ON TH THIS PART OF THIS IARKE DAVIS ADMITS THE NOR DENIES TO THEIR PLAINTIFFS REMAINING PROOFS THE OF PLAINTIFFS NOR DENIES ADMITS CONTAINED TLMREMN WHICH ALLEGATIONS AUE THE REMAINING DEFENDANT DENIES OF BRINGING THE PROPRIETY RURTHER ANSV THIS SAID PARAGRAPH CAUSE AS PARPORTED DEFENDANT NEITHER THIS REMAINING ALLEGATIONS CONTAINED THEREIN THE COMPLAINT OF PLAINTIFFS THIS CLASS ADMITS NOR BUT LEAVES THE PLAINTIFFS DENIES DEFENDANT SPECIFICALLY 1963 THIS DEFENDANT ADMITS GRAPH WHICH PERTAIN TO THIS DEFENDANT NEITHER ADMITS THEREIN THE ALLEGATION NOR DENIES THIS PARAGRAPH TO THE REMAINING TO THEIR DCFRN TINT ADNIITS SAID PARAGRAPH NHIEGATIONS WERE ERECTED CLINICS CONTAINED IN SAID PARA SAID PARAGRAPH THIS CONTAINED ALLEGATIONS PROOFS AETENNANT AENIEN CCRNA WE AETTLONS ANSWERING PARAGRAPH THIS THIS COMPLAINT OF PLAINTIFFS DEFENDANT SPECIFICALLY RESEARCH FURTHER ANSWERING DEFENDANT BUT LEAVES THE PLAINTIFFS THAT OTHER ALLEGATIONS ALL COMPLAINT OF PLAINTIFFS ANSWERING PARAGRAPH ING BUT LEAVES THE PROOFS THCI IN FAR DEFENDANT NEITHER CONTAINEDIHOREIN ANSWERING PARAGRAPH DENIES RELATE TO THIS TO THEIR PROOFS PLAINTIFFS ACTION COMPLAINT THIS ANSWERING SAID PARAGRAPH FURTHER COMPANY DAVIS BUT LEAVTS THE CONTAINUD THEREIN ALLEGATIONS ANSWERING PARAGRAPH DEFENDANT ADMITS DEFENDANT NEUTER THIS FURTHER ANSWERING SAID PARAGRAPH COMPANY DENIES THAT THAT PN THIS IT IT PAID FOR OF PLAINTIFFS COMPLAINT ANY WAGES TO ANY PRISON POWER THE PU4NT INNATE FURTHER ANSWER HEAT AND SWATER DEFUNCHAT NEITHER ADMITS NOR DENIES CODTABOD THEREHM BUT LEAVES THIS TO THEIR THE REMAINING PROOFS THAT THERE DEFENDANT ADNAITE RATTIER INMATES C1A ANSWERING SAID PARAGRAPH FOR THE PRISON DEFENDANT THIN NEITHER ADMITS BUT LEAVES REMAINING ALLEGATIONS CONTAINED THEREIN THE DENIES WERE VARIOUS THIS COMPLAINT OF PLAINTIFFS ANSWERING PARAGRAPH TO THE PLAINTIFFS PROOFS THEIR CONTAINED PARAGRAPH IN NOR DENIES DEFENDANT NEITHER ADMITS THIS OF PLAINTIFFS COMPLAINT BUT LEAVES THE THE ALLEGATIONS TO PLAINTIFFS PROOFS THEIR THIS DEFENDANT DENIES 10 GRAPH 10 OF PLAINTIFFS GRAPH 11 OF PLAINTIFFS 1Z GRAPH THE ALLEGATIONS CONTAINED IN PNN THE ALLEGATIONS CONTAINED IN PAN THE ALLEGATIONS CONTAINED IN PARA COMPLAINT THIS DEFENDANT DENIES 11 COMPLAINT DEFENDANT DENIES THIS COMPLAINT OF PLAINTIFFS COUNT THIS ANSWERS TO PARAGRAPHS IT DEFENDANT INCORPORATES HEREIN BY REFERENCE AS THOUGH THE THROUGH 12 OF COUNT ITS SANE WERE FULLY SET FORTH HEREIN DEFENDANT DENIES THIS THE ALLEGATIONS CONTAINED OF PLAINTIFFS CONWLAINT IN BE PARAGRAPH COMPLAINT OF PLAINTIFFS ANSWERING PARAGRAPH DEFENDANT ADM ITS FEDERAL FAIR SAID NOR THAT IT IS SUBJECT LABOR STANDARDE ACT PARAGRAPH THIS DEFENDANT TO OF DENIES THE MINIMUM 1958 AS WAGE PROVISIONS AMENDED THE REMAINING THIS OF THE RURTHER ANSWERING ALLEGATIONS CONTAINED THEREIN THK PARAGRAPH OF PLAIMAFFS DEFENDANT DENIES COMPLAINT THE ALLCGATIOIS CONTAINED IN COUNT DEFENDANT INCORPORATC HEREIN THIS ANSWERS TO PARZ GRAPHS NET FORTH HEREIN THEIR VI THROLIGH OF PLAINTIFFS PARAGRAPH ITS SNME WORE NOR DENIES THE FULLY ALLEGATIONS TO BUT LEAVES THE PLAINTIFFS COMPLAINT PROOFS OF PLAINTIFFS PARAGRR CONTAINED IN DENIES THE ALLEGATIONS CONTAINED IN CONTAINED IN DEFENDANT CENTES THE ALLEGATIONS CONTAINED IN DEFENDANT COMPLAINT OF PLEINTIFFS DEFENDANT DENIES THIS DEFENDANT DENIES THIS COUNT PARAGRAPHS SET FORTH HEREIN THROUGH 12 OF COUNT ANSWERING PARAGRAPH DEFENDANT ADMITS THAT AS PRISON LIBERTY FUWTHER ANSWERING LUG A11EGATIOIAR CORT2TILWD IV DEFENDANT INCORPORATES THIS TO CONTAINED IN THE ALLEGATIUNS COMPKINT OF PLAINTTFFE ANSWERS A1LEGAT COMPLAINT OF PLAINTIFFS PARAGRAPH THE COMPLAINT OF PLAINTIFFS THIS PARAGRAPH THE ALLEGATIONS DEFENDANT DENIES THIS PARAGRAPH IN COMPLAINT OF PLNINTIFFS PARAGRAPH CONTAINED COMPLMNT THIS PARAGRAPH THE ALLEGATIONS DEFENDANT DENIES THIS THIS BY REFERENCE AS THOUGH THE COUNT DFENDANT NEITHER ADMITS THIS CONTAINED IN ILL THERCIN IRNUATOS PARAGRAPH AS HEROIN THOUGH THE OF SAID PLAINTIFIS THIS BY REFERENCE ITS SAME WERE PLAINTIFFS FULLY COMPLAINT AXE DEPRIVED DEFENDANT DENIES OF THE THEIR REMAIN THIS THIS OF PLAINTIFFS PARAGRAPH IN THE ALLEGATIONS CONTAINED IN THE ALLEGATIONS DEFENDANT DENIES COMPLAINT DEFENDANT NEIVH ER ADMITS THIS THEFR CONTAINED ALLEGATIONS COMPLAINT OF PBINTIFFS CONTAINED IN IN THE DEFENDANT DENIES THIS PARAGRAPH COR DENIES COMPLAINT OF PLAINTIFFS PARAGRAPH DEFENDANT PARAGRAPH OF PLAINTIFFS COMPLAINT NOR DENIES THE ALLEGATIONS BUT LEAVES THE PLAINTIFFS TO PROOFS THIS OF PLAINTIFFS PARAGRAPH DEFENDANT DENIES IN FURTHER ANSWER AND BY STATES BY REASON OF THE THAT ALLEGATIONS CONTAINED IN CONIPLAINT DEWENSE AFFIRMATIVE DEFENDANT THE SOME APPLICABLE OR ALL OF MFIRIRATIVE WAY FROM BRINGING OF LIRNITATION WHEREFORE DEFENDANT PARKE MICHIGAN CORPORATION PREJUDICE AND THAT PLAINTIFFS PRAYS THAT PLAINTIFFS THIS ARC BATRED IN WHOLE OR IN PART OF PLAINTIFFS STATUTE DEFENSE BE ORDERED TO PAY ALL COMPANY DAVIS COMPLAINT ACTION THIS BE DISMISSED WITH COSTS AND REASONABLE ATTORNEY FEES SO WRONGFULLY SUSTAINED MILLER CANFIELD PADDOCK AND STONE WOLFGANG HOPPE BY WOLFGANG FLOPPE ATTORNEYS FOR DEFENDANT PARKE DAVIS COMPANY 2500 DETROIT BANK DETROIT DATED JUNE …D 1958 TRUST BUILDING 36420 MICHIGAN 48226 ANSI OP C4 SW IXOZTUX FLZJ2LAM 7268 QW2 MC 2A2TPZ RON CATVXS UPJOHN TUB FILED CODIPANY A5… D2TZR CV XZY 3OUT CIXD OTZA MTURZ 2XLT LOLAC7 CLI VA AZTIC CIVIX NO DAVE C02TXIY CCRPBRZTKCN NND ZFL CO WPJO2M XS CORVOR DOFCNTA AWTHTHR C0UY TH NOW TH PEFQND CF 3T WPJEJ TH ICR AVN JOZI SDT QS C2NBNJ T4R ZCS2JAININ P1QAAWLFL2 TC ZDR BY DYCZ W1VN AN ANI CITTORNCYA COUN BAA CO UPJOCI ALL THIA V2 IN OOFEZTHNT MTTONTJ CCFLTZDWVA TB ORIB BTZ 1C PCOC4S CA CI T72D2 23CINT RC7ISR T2 19A CC 2FL TTHC UT RMFCC TSTZ RW VVCR TBA PZRA IRR TO PLA5NTTCZZR TBIS ZA CC R3PCNC IA1 A2 BI T1X ASS RMITZ WH TTHJCZ CC2 TH 1A NT ACM RXIR THI IN LEIVN TH P1AZ AR CTTB CFLM2S IN AN TTN TH TO TM PRN 1C ALL TC RECTARC CONTTXIRD DT RC ETWR TMS THTS THQRHIN E1XSQATIO CTP7PLATNT OF UC TH IUS RNTC PU EU AJ HNT9TSLT TTRST THAT IER OF T3 ALL LTIT PXCC 7FLITN FL PV TH5A PORTNIN IOTONRA TXTR YS2 TT G2 CO FLC RAC ALL NIWCZING CVZPLAINT PI NILC PARZ TFT ZT OF THIS UVTD P1AANTI VATT TO TBCDX THE COCTND IN LII RC VISO LHIS JT4 T2T THE THICH TET TO P1A IR4NGTT ANSW DE4 TRZT CF 7A XIOTMCR THRZN TB PLCTNTTS TH PXOPCIC FNRTB TDWT CO NIC5 P2RA ANSWANY ACTAON CITATI CCNT FC C2TVYRFLY DCS IZ ND THI PIJTH XP 3AS TVLMRH9 TO THIN P1 CA THIS CEZPFLTNT HC DC T‰21R PZNGZI TH 2JR OF C1 1NN CIXIB‰… TTVSI 3M IN TBLS TO ANY LT PCDC ANY IT CONTINTD ND H5J ROR PCRV CCNTN‰CD SN TH BUT TIFFS OF 10 DI PFLINTZT THDA LIT CCTTPZSITIT RC TO TBQIR LII 2RCFT 1ITNTZI3Z OF A11 TH CCNTAIZ IN CONPLNINTW DMTHRC A1K TWZ TTAINCD IN 11 OF PZCDNT2ZS ARNGIRAPH DN 12 PTZ 12 AILE THE CONTAINCD AS IIZDTFLIFFFS COWPT THUT CT LNZON INCCRPOZATN TO OF THROUGH 12 CORS ITS THOUGH TB FOTH H2S OZ DC T5NT AZI THAT THS WCD43TL 5AHER TKDR CUY4I PARA IT LZ OF OF THC 193S DFCNDA TH FLCCM7 PINTIT PZ OF STZMSIAR 1C THIS CST THT EN AT DEZ THO CR A2 17Y TI THE HRRNN ST CDNTCDNR UBJCCZ TO T‰ RILNEIM IS AAFLM ZCZ A1I ‰NATQ TYB OZ IC TH2TV THIS CCNT AFLAGATIEN TO EC THIS THIS AX DEF OF PLAINTITFS TH4R PNA OF PAR2VTAPH DAFE P1 THIS DENI TBO AL1C CANTAILWD IN THA 11EQATTONS IN AX1 CONTAINT IN THE 8LLEGATIOZFL CONTAINCI IN THE AI1T CCATAMRTL IN HCRE BY XOTHZONCO TIV CAIP DOFENMT DGFONDANT PAAGRAPH WRE TIST FCRTH ADNITR PARAGNI THAT AO AI OF CONNT UTTHEE FLCFC N5A THOU3H TN PLI THZ3 IT AOAII ANMVERIFLG THE STILL THEI TN PA CCATALNCD THNRR NTTHGATKN COZ O11C CC CCSPXTTNT NS2AX TKNCT CORPLANT P1OINTAFF AJIOGATTQN D1TNI CZ P2ATTTIZLZ OF PRI TH WHT 1DII INCORRCR4TC HEROIN THAR LTBTNRTY SL XV THROWH ANS THTSI IN DC2CNDANT CNSW TQ OF COMTAT COMPT THIS DCFCNDANT FLLCG5TIONA DC COTET UTI THE COT OF FULLY PTOZ CVNPTHTNT PLATNTSSFO THIZ TH DCFENDANT OF PLAINTIFFS CA DCNLC TH OF CC CA PLAINTFFS OF PARARAPB NOR RARAS ITT TN P1ANTUF THIN NCIT DCFR4T1A XT DU THIS A11 CO3TSLTN 82 P2AINTCT PSNQRAPH TH3 A11 BUT TM DONIA TATHER ADMITS NOR CONTAINF2D IN THIS TO THATR COVLAINT PROOFS TN PEFTINDANT OF PLAINTIFTO PARAGRAPH OF PLA4NTIFFS PARAGRAPH 1ERZE TH PLAINTIFFS THS VAR AIZEGATI0S IN COWPLAINT AVPIFL FL OX FRO ZN FIRTBCR ST PAFL THAT UT AND BY AT ALL TJDA CP 4OT AFTLN PTHINTIFFS THE APPLICABXO BY REASON BTN OF ORE BARRCD STETUTS IN TM3 WHO OF LINITATIONA ACTION VZ TW3O WRETRORS DCFONDANT THAT P1AINTI THAT ATTOZV BE FEES SO CO OR COMPANY NONG2T DIT BE TO PAY DAIIAZTRE 08 CCST CWZTEDNCD TJYK2MA TILAT 3Y RTLZT C0OD FOR D2F TTEN UPJOHN CO 2700 PENO FEZ THE DETROIT 963C 2260 WTH 040 P4R FLI INDIVIOUAILY TH0 FLUILDING 4FLO TRICC FILED CO FOR OCT 14 1968 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTIIERN DIVISION TUFL CALVIN FRANK SIMS RICTIARD ALLEN WALTER ROGERS HILLY LEE WILLIANS LEE BOYD SLAGER PETER GEORGE MILLS LEE WALXER CLEMONT DEDEAUX ORDELL VILSURN WILLIAM CLEARY HERSERT WILLIAMS FRED HOLNAGEL BENNY SPELLS KENNETH INMAN RAYMOND ORCEAN DAVIS JERRY MACK BAILEY BOYD KELTON THOMAS LORD RALPH WATSON CHESTER PHILLIP SAWICKI MCGHEE AND VERNON MEVIS PLAINTIFFS NO VS CO 31172 PARKE DAVIS MICHIGAN CORPORATION AND THE UPJOHN DELAWARE CORPORATION CO DEFENDANTS TUE UPJOHN CONPANY ANSWERS AND OBJECTIONS TO PLAZNTIFFS INTERROGATORIES THE UPJOHN COMPANY ASSEXTS TO GENERAL OBJECTION THE FORM OF QUESTIONS SET FORTH IN P1AINTITFS INTERROGATORIES THE UPJOHN COMPANY DOES NOT ADMIT THAT IT UTILIZES INNATE LABOR CMPLOYS INMATES OR THAT INMATES WORK FOR OR PERFORM JOB FOR THE UPJOHN COMPANY OR WORK THE UPJOHN PROGRWT ALL INMATE PLAINTIFFS WHO WERE OR ARE ASSOCIATED WITH THE UPJOHN CLINIC WERE ASSIGNED THERETO BY PRISON UTHORITIES NOW COMES DEFENDANT TO PLAINTIFFS INTERROGATORIES THE UPJOHN COMPANY AND IN STATES AS FOLLOWS STATE WHETHER OR NOT OF PRISON REGARD TO YOUR UTILIZATION OF SOUTHERN MICHIGAN FL WRITTEN CONTRACT EXISTS WITH LABOR IN THE STATE PRISON STATE WHO THE CONTRACT IS WITH STATE THE DATE THEREOF WHO ARE THE FORMAL PARTIES AS DESIGNATED THEREIN ATTACH OF SAID CONTRACT TO YOUR ANSWERS TO COPY THESE INTERROGATORIES STATE OR IN THE ALTERNATIVE WORD FOR WORD THE CONTENT OF SUCH CONTRACT ANSWER LABOR UTILIZED RESPONSE NO SUCH CONTRACT STATE IN C9NPLETE DETAIL BY YOU AT SAID PRISON EXISTS THE METHOD PAYMENT STATE THE CLASSIFICATION OR TYPE OF EACH JOB PERFORMED TY THE PRISONERS STATE THE RATE OF COMPENSATION FOR EACH SUCH STATE TO WHOM SUCH MONEY IS PAID STATE IN WHAT FORM SUCH MONEY IS PAID FOR JOB DESCRIBE THE CLASSIFICATION WORK INVOLVED IN EACH JOB OR TYPE YOU HAVE NAMED ABOVE ANSWER THE UPJOHN COMPANY MAKES PORIODIC PAYMENTS STATE OF MICHIGAN TO INMATES WHICH INCLUDE AMOUNTS RELATING THE PRISON AUTHORITIES TO THE UPJOHN CLINIC ASSIGNED TO THE WHICH UPJOHN CLINIC ASSIGNMENT CLASSIFICATIONS HAVE EXISTED AND MOST RECENT PER DIEM CHARGES BY STATE OF MICHIGAN ARE AS FOLXOWS 76 50 35 75 40 50 30 55 40 25 35 40 25 CHIEF TECHNICIAN TECHNICIAN TECHNICIAN TRAINEE CHIEF CLERK CLERK NURSE SUPERVISCR NURSE CHIEF COOK KITCHEN PAN KITCHEN POT MAINTENANCE MAN HEAD PORTER THE STATE 125 75 50 125 75 100 50 80 55 40 60 60 40 OF MICHIGAN COMPANY CHECK CHIEF TECHNICIAN TECHNICIAN TECHNICIAN TRAINEE ORDINARILY PERFORMS SPECIFIC TASKS SUCH AS OPERATION OF EEC MACHINE CHIEF CLERK CLERK CLERICAL NURSE SUPERVISOR NURSE ACTS CHIEF COOK COOKS AND SERVES WITH COOK KITCHEN KITCHSZF POT MAINTENANCE ASSISTS MAN ANSWER AUTHORITIES FIRST IN FOOD KITCHEN MAINTENANCE AND MINOR JANITORIAL STATE THE DATE ON WHICH LABOR OF SAID PRISONERS BY PRISON NURSE IN CONNECTION CLINICAL TESTS AS PAN HEAD PORTER PORTER THE TASKS INMATE REPAIR TASKS YOU FIRST BEGAN TO UTILIZE WAS ASSIGNED AMONG PLAINTIFFS ON APRIL 1964 TO UPJOHN CLINIC INK STATE WHETHER OR NOT YOU HAVE SIMILAR WORK PROGRAMS AT ANY OTHER PLACE OF IN THE UNITED STATES STATE WHETHER OR NOT YOU UTILIZE THE LABOR IN IN ANY COUNTRY OR PLACE PLACE OF INCARCERATION OTHER THAR THE UNITED ST4TES ANSWER BEEN UTILIZED NONE WITHIN OR WITHOUT THE UNITED STATES STATE THE NAME OF EVERY PRISONER WHOSE LABOR HAS OF THE PROGRAM BY YOU SINCE THE BEGINNING 25A STATE THE NUMBER OF HOURS EVERY SUCH PRISONER HAS WORKED STATE THE AMOUNT OF MONEY EACH SUCH PRISONER HAS BEEN PAID OR HAS BEEN PAID FOR SUCH PRISONER STATE THE YEARS DURING WHICH SUCH UTILIZATION OF LABOR IN THE CASE OF EACH PRISONER HAS TAKEN PLACE STATE THE TOTAL NUMBER OF PRISONERS WHOSE LABOR IS BEING UTILIZED AT THE PRESENT TIME STATE THEIR NAMES AND JOB CLASSIFICATIONS IS AS ANSWER FOLLOWS INFORMATION FRANK ROGERS TRAINED TECHNICIAN SOU9HT WITH 8555 RESPECT TO PLAINTIF 1965 1966 45620 1965 1966 TECHNICIAN 63760 1966 1967 1968 CLEMONT DEDEAUX CHIEF TECHHICIAN 64425 1965 1966 1967 ORDELL CLERK 29880 1966 1967 51875 1965 1966 29250 2965 1966 RALPH WATSPN COOK 19865 1964 1965 CHESTER COOK 33575 1966 1967 44240 1966 1967 1968 107710 1964 1965 1966 WALTER LEE NURSE SUPERVISOR LEE CHIEF WA1 VILBURN FRED HOLNAGEL CHIEF TECHNICIAN KENNETH TRAINED TEC INJNAN SAWICKI VERNON MEVIS NURSE SUPERVISOR BOYD SLAGER CHIEF CLERK 1967 HOURS FOR ABOVE PERSONS UNKNQWN PEFENDANT IN OBJECTS STATE IN DETAIL THE PROGRAM AT THE PRISON TO BALANCE OF QUESTION HOW INMATES ARE SELECTED TO WORK WHAT PART DO YOU PLAY IN SELECTING THE INMATES DO THE INNATES HAVE ANY FREEDOM TO REFUSE TO WORK IN THE PROGRAM IS THE METHOD OF SELECTIDN OF INMATES FOR WORK IN YOUR PROGRAMS ESSENTIALLY SIMILAR TO SELECTION OF INMATES FOR WORK IN OTHET PRISON INDUSTRIES WHAT EXIST REGARD TO THE SELECTION OFIRMIATES WORK IN Y6UR PROGRAMS AND THE SELECTION BF INMATES FOR WORK IN OTHER PRISON DIEFE INDUSTRIES WHAT SANCTIONS ARE APPLIED AGAINST REFUSES TO WORK IN YOUR PROGRAM PRISONER WHO ANSWER TO WORK AT UPJOHN INMATES ARE CLINIC ASSIGNED BY PRISON AUTHORITIES THE UPJOHN CLINIC PLAYS NO PART IN THE SELECTION INMATES TO BE ASSIGNED TO IT EXCEPT THAT OCCASIONALLY REQUEST FOR SPECIFIC INMATE HAS BEEN MADE OF UNKNOWN ASSIGNRNENTOF IS ESSENTIALLY UNKNOWN UPON INFORMATION AND BELIEF THE INMATES BYTHE PRISON AUTHORITY TO THE TJPJOHN CLINIC THE SANE AS THE ASSIGNMENT TO OTHER PRISON PROGRAMS UNKNOWN UNKNOWN PROGRAMS IR DO YOU KNOQ OF ANY OTHER DRUG COMPANY WITH THE UNITED STATEST SIMILAR IF SO WHAT METHOD OF PAYMENT IS FOLLOWED BY THAT DRUG COMPANY IF YOU KNOW IN ITS PROGRAMS NAME THE DTUQ COMPANY OR COMPANIES AND THE PLACE OR PLACES WHERE SUCH PROYTAMS ARE CARRIED ON ANSWER UPON INFORMATION AND BELIEF PARKE DAVIS AND COMPANY AT THE 7STATE PRISON FOR SOUTHERN HAS MICHIGAN AN ESSENTIALLY WHICH OPERATES IN THE SAME MANNER AS THE UPJOHN CLINIC LOCATED AT THAT PRISON IDENTICAL WHAT STATUTES OF THE STATE OF MICHIGAN WILL YOU RELY ON AT THE TRIAL OF THIS CAUSE TO 4UTHORIZE YOUR USE OF PRISON LABOR ANSWER THE STATE DEFENDANT OBJECTS TO QUESTION WHAT MEMBERS OF THE DEPARTMENT OF CORRECTIONS OF MICHIGAN OWIA STOCK IN YBUR CCZHPANY FOR NAME THEM GIVE THE AMOUNT OF STOCK OR EACH PERSON GIVE THE SAME INFORMATION FOR ANY PAST MEMBER OF THE DEPARTMENT OF CORRECTIONS SINCE YOUR PROGRAM WENT INTO EFFECT ANSWERZ 10 IX DEFENDANT ARE YOU PROFIT OBJECTS MAKING TO QUESTION ORGANIZATION DO YOU MARKET DRUGS IN INTERSTATE COMMERCE DO YOU MARKET DRUGS WHICH ARE TESTED AT THE STATE PRISON OF SOUTHERN MICHIGAN IN INTERSTATE COMMERCE DO YOU SELL SUCH DRUGS FOR PROFIT ARE DRUGS USED IN TESTING AT THE PRISON SHIPPED IN INTERSTATE COMMERCE STATE YOURPROFIT FOR YOUR LAST COMPLETE FISCAL YEAR ANSWER 10 DEFENDANT OBJECTS TO QUESTION 10 DEFENDANT ANSWER PARAGRAPH ADEQUATELY PROVIDES NEEDED INFORMATION 41 FOR EACH JOB CLASSIFICATION AT THE STATE PRISON OF SOUTHERN MICHIGAN CIVILIAN FOR PERFORMING THE OVERTIME RATES OF PAY WOULD ANSWER RESULT 11 UNKNOWN FROM PURE CONJECTURE WHICH INM4TES PERFORNR GIVE THE RATE OF PAY JOB FOR YOU INCLUDING ANY ANSWER TO QUESTION 11 WOULD THE BENEFIT HOW ARE THE AMOUNTS PAID TO OR FOR MICHIGAN OF SOUTHERN AT THE STATE PRISON OF THE PRISONERS REFLECTCD IN YOUR FEDERAL INCOME TAX RETURN 12 ANSWER THE SAME QUESTION FOR YOUR STATE RETURN FOR ANSWER THE SAME QUESTION IN FILE IF FACT RETURN YOU FOR ARE ANY AMOUNTS WITHHELD AT ANY LEVET ARE ANY AMOUNTS WITHHELD FOR FL INCOME INCOME YOUR CITY TAX TAX ONE INCOME TAX SOCIAL SECURITY PURPOSES BENEFITS AMOUNTS PAID BY THE PPJOHN COMPANY TO FOR CHARGES WITH RESPECT TO INMATE THE STATE OF MICHIGAN ON FEDERAL AND STATE TAX RETURNS AS ARE REFLECTED ASSIGNMENTS AND LABORATORY RESEARCH EXPENSE OUTSIDE CLINICAL ANSWER 12 NO 12 14O 13 FOR 12 WHO DETERMINES THE NUMBER OF HOURS AN INMATE WORKS YOU HAVE YOU EVER REJECTED AN INMATE CONSIDERED BY YOU FOR WORK IN YOUR CLINIC HAVE YOU EVER SOUGHT REPLACEMENT OF AN INMATE CONDUCT BECAUSE OF UNSATISFACTORY AS FAR AS YOU ARE ABLE GIVE THE NAMES AND DETAILS FOR THE PRIOR TWO QUESTIONS ANSWER AUTHORITY THERE 13 ARE HOURS ARE REGULATED BY PRISON ASSIGNMENT NO SET HOURS FOR ACTUAL PERFORMANCE OF TASKS 13A NO 13 NO 13 INAPPLICABLE 14 ON WHAT FACTS PROPER CLASS TBIS LAWSUIT ACTION ANSWER 14 IN DO YOU RELY IN DENYING YOUR ANSWER TO PLAINTIFFS DEFENDANT OBJECTS 15 OPERATIONS WHO CONSTRUCTED THE BUILDING ARE CARRIED ON AT THE PRISON THAT THIS COMPLAINT TO QUESTION IN WHICH IS IN 14 YOUR THE BUILDING WHO BUILT WHAT WAS THE COST NOW WHO OWNS THE BUILDING FROM THE ORIGINAL IF THE PRESENT OWNER IS DIFFERENT TRANSFERRED HOW WAS TITLE OWNER TREATED BY YOU FOR FEDERAL FLOW WAS THE TRANSACTION INCOME TAX PURPOSES ATTACH COPIES OF ALL DOCUMENTS INVOLVED IN THE TITL TRANSFER OR STATE THEM WORD FOR WORD AS PART OF THE ANSWER TO THIS INTERROGATORY OF SAID FOR THE MAINTENANCE WHO IS RESPONSIBLE BUILDING WHO DOES THE MAINTENANCE WORK ANSWER 15 15 BANTA APPROXIMATELY BROOKS COMPANY 31739000 LANSING MICHIGAR 15 15 FL 15 30 ST THE OF MICHIGAN INAPPLICABLE DEPRECIATION OF LAASEHOLD 15 INAPPLICABLE 15 THE STTE OF MICHIGAN 15 OF SOUTHERN LABOR EMPLOYED AND INMATES MICHIGAN 16 FOR OVER IZNPROVEFFIEFLTS YEAR PERIOD YOU IF THERE IS THE AND COMPANY UPJOHN OUTSIDE OF THE STATE PRISON ASSIGNED BY PRISON AUTHORITY PRISONER TO CONTINUE WORKING YOU DO NOT WANT ANY REQUIREMENT THAT YOU KEEP THEM ANYWAY ARISWER 16 17 THERE ARE YES ANY CUSTODIAL EMPLOYEES FROM THE PRISON AT YOUR BUILDING ANSWER 17 YES 18 ARE THE SAME JOB CLASSIFICATIONS CIVILIANS EMPLOYED BY YOUR COMPANY IN THE AS THE PRISONERS MEMBERS OF ANY NNTOP STATE THE UNION COLLECTIVE ATTACH COPY OF ANY APPLICABLE BARGAINING AGREEMENT BUT NOT LIMITED ALL FRINGE BENEFITS LIST INCLUDING TO VACATION PAY PENSION PLAN ETC ANSWER UPJOHN 18 COMPANY WORKING 19 CIVILIAN EMPLOYEES OF THE UNION ARE MEMBERS OF IN DETAIL THE HISTORY THE WALLS OF JACKSON STATE WITHIN OF THE CLINICS NONE OF THE AT THE CLINIC OF THE PRISON COMMENCEMENT BY YOUR COMPANY AND AGENTS STATE THE NAMES OF YOUR REPRESENTATIVES ON THE NEGOTIATIONS WHO CARRIED THE STATE THE NAMES OF THE PERSONS REPRESENTING OF CORRECTIONS WHO CARRIED ON DEPARTMENT FOR THE STATE OF MICHIGAN NEGOTIATIONS AND INTERCOMPA OF ALL CORRESPONDENCE ATTACH COPIES MEMORANDA RELATING TO THE AFORESAID NEGOTIATIONS AND THE CONTRACT SIGNED BETWEEN YOU AND THE PRISON IF ONE WAS IN FACT SIGNED ANSWER AND INCORPORATED BALANCE OF QUESTION 20 TO THE 19 SEE ATTACHED AGREEMENT MARKED AS EXHIBIT DEFENDANT OBJECTS TO HEREIN BY REFERENCE 19 STATE WHETHER OR NOT YOU SOUGHT LEGAL OF THE CLINICS UNDER MICHIGAN LAW LEGALITY ATTACH COPY OF ANY LEGAL OPINXON RECEIVED IN CONNECTION WITH SAID ATTACH ALL CORRESPONDENCE RELATING SUCH LEGAL OPINION ADVICE AS YOU HAVE QUEST ANSWER 21 JOH ASSIGNMENTS 20 DEFENDANT OBJECTS TO GIVE THE NAMES OF ANY INMATES FOR YOUR COMPANY ANSWER 21 UNKNOWN TO ANY QU WHO HAVE 20 FUSED 22 UPON THEIR HAVE ANY INMATES WHO WORKED FOR YOU IN RELEASE GONE TO WORK FOR YOU THE STATE AR 22 NAMES OF ALL PRISON SUCH PRISONERS NONE 23 OUTLINE THE CHAIN OF CORMNAND OR ADMINISTRATION WITHIN THE PRISON WALLS OF YOUR EMPLOYEES IN THE CLINIC STATE STATE EACH ADMINISTRATIVE THE DUTIES INVOLVED POSITION IN CARRYING OUT EACH POSITION 23 SCHWECM STAFF PHYSICIAN DR II FOR PROTOCOLS AND CLINICAL RESPONSIBTH OF CLINIC WITHIN RULES AND REGULATIONS OF STUDIES OPERATION STATE PRISON FOR SOUTHERN MICHIGAN RALPH WILLY SUPERVISOR OF RESEARCH AFFAIRS FOREXECUTION OF PROTOCOLS RESPONSIBLE AT CLINIC AND FOR ROUTINE MATTERS RELATING TO THE OPERATION OF OPERATIONAL OF THE CLINIC WILLIAM IIOSSLCR SUPERVISOR OF BUILDING AND EQUIPMENT AFFAIRS FOR MAINTENANCE RESPONSIBLE AND ROUTINE MATTERS RELATING TO OPERATXON GENERAL SUPERVISION OF THE CLINIC ANSWER JACKSON ESCARCH CLINIC 24 HAVE YOU EVER WRITTEN LETTER OF RECOMMENDATION TO AID FOR ANY INMATE WHO WORKED FOR YOU IN THE PRISON CLINIC IN ANOTHER HIS RELEASE HIM OBTAINING JOB UPON 24 ANSWER YES 2K GIVE THE COMPLETE NAME AND COURT CASE NUMBER OF OTHER SUITS INVOLVING IN THIS SUIT IN ANY OF THE QUESTIONS WHICH YOU ARE NAMED DEFENDANT ALL ATTACH COPY OF THE COMPLAINT AND ANSWER IN EACH SUCH SUIT ATTACH COPY OF ANY MOTION TO DISXNISSFILED YOU AND ANY ANSWER THEREOF 25 ANSWER DEFENDANT OBJECTS TO QUESTION BY 25 26 LIAVE THERE EVER BEEN DISCUSSIONS BETWEEN YOUR OR AGENTS AND AGENTS OR REPRESENTATIVES OF THE REPRESENTATIVES THE PAYMENT OF WAGES TO DEPARTMENT OF CORRECTIONS INVOLVING INMATES FOR WORK DONE IN THE CLINICS IN ACCORDANCE WITH THE OF THE FEDERAL MINIMUM PROVISIONS WAGE LAW OR THE STATE MINIMUM WAGE LAW GIVE ANSWER PA THE 26 DETAILS OF ANY SUCH DISCUSSIONS DEFENDANT OBJECTS TO QUESTION 26 27 IN CONNECTION WITH YOUR PROGRAM HAVE YOU PAID OR ANY MONEY TO ANY MEMBERS OF THE DEPARTMENT OF CORRECTIONS EMPLOYEES OF THE DEPARTMENT OF CORRECTIONS FOR ANY REASON IF ANSWER SO STATE 27 NO THE DETAILS OF ANY SUCH TRANSACTION ANY DYJCEI4A WHEAT SPENCER GOODNOW XI TH T7 VU BY TIMOTHY CARROLL 2700 PENOBSOCT BUILDING 48226 DETROIT MICHIGAN C4 LII 9636040 ATTORNEYS UPJOHN DATED OCTOBER 14 1968 FOR DEFENDANT COMPNY THE TRIG ACR THE FOLLOWING OWNERSHIP OF 4ICHIGAFL COVERS THE MCTHOD OF CONSTRUCTION AT THE STATE RESEARCH NUILDING CLINICAL AGRERIFLCNT THE ‰CRATION FRISON OF AND SOUTHERN AT CS OF AN ARCHITECT THE SERVICES THE UPJOHN CONPANY WILL RETAIN RESEARCH O19 CLINICAL END WILL CONTRACT FOR THE CONSTRUCTION MICHIGAN AT THE STATE PRISON OF SOUTHERN ZDLDINS THE THE UPJOHN COMPANY WILL PAY CONSTRUCTING THE BUILDINS ENTIRE EXPENSE OF PLANNING AND RESEARCH BUILDING FOR THE CLINICAL THE PLANS END SPECIFICATIOTI AND THE CORRECTIONS OF RNU BE APPROVED BY BOTH THE DEPARTMENT UPJOHN COMPANY PUR ALL NECESSARY EQUIPMENT FCC THE UPJOHN COMPANY WILL WILL REMAIN AND THE PORTABTE RESEARCH EQUIPMENT THE BUILDING THE PROPERTY OF THE COMPANY OF OF THE COMPLETED PROJECT BY THE DEPARTMENT UPON ACCEPTANCE BECOME THE AND FIXED EQUIPMENT SHALL THE BUILDING CORRECTIONS OF ANY INSURANCE THE PROCEES OF MICHGAN PROPERTY OF THE STATE SHALL BE OR CONTENTS AGAINST DAMAGE ON THE BUILDING PRBTECTIOII SHALL BE PROVIDED SUCH INSURANCE USED TO RESTORE THE FACILITY BY THE UPJOHN COMPANY COMPLETED PROJECT PARTIALLY EVENT OF ABANDONMENT OF SHALL BECOME SITE CONSTRUCTION THE AT AND EQUIPMENT ANY MATERIALS OF CORRECTIONS THE PROPERTY OF THE DEPARTMENT IN THE WZ THE MEINTAIN ADMINISTER THE UPJOHN COMPANY WILL BEAT LIGHT AT ITS OWN EXPENSE AND PROVIDE NECESSARY SUPERVISION BUILDING OF BE THE WILL RESPONSIBILITY HOWEVER CUSTODY AND SECURITY BE DEPARTMENT OF CORRECTIONS T1 WILL HAVE THE THE UPJOHN COMPANY AND ONLY THE UPJOHN COMPANY RESEARCH SO LONG AS FOR CLINICAL RIGHT TO USE THE BUILDING OR CORPORA RESEARCH IS CONDUCTED BY ANY ORGSNIZATLOFL CLINICAL TION AT THE STATE PRISON OF SOUTHERN MICHIGAN FOR THE CONDUCT OF THE THE UPJOHN COMPANY WILL BE RESPONSIBLE THEY WILL RESEARCH FLUILDING RESEARCH IN EHE CLINICAL CLINICAL OF THE DEPARTMENT OF CORRECTIONS AND THE ABIDE BY THE POLICIES LAWS OF MICHIGAN AND THE UNITED STATES EXHIENY 10 MC DEPNRTRNEDT FACILITATE THE THE DEPARTMCFLT TO PARTICIPATE OF CORRECTIONS WILL CONDUCT OF CLINICAL OF CORRECTIONS WILL AS SUBJECTS IN THE TAKE ALL TO RESEARCH CLINICAL MEDICAL ADVISBRY DEPARTMEHT OF CORRECTIONS WILL APPOINT FROM OF SEVERAL QUALIFIED COMMITTEE COMPOSED ON THE WHICH WILL REVIEW OPERATIONS MICHIGAN MEDICAL SCHOOLS WILL EITHER APPROVE OR SUGGEST CHANGES THE CORRNIITTEE YEARLY BASIS 11 THE IT IN 12 RNEI THE 13 PROCEDURES USED IN THE RESEARCH CLINICAL FOR THE STATE OF MICHIGAN THE UPJOHN COMPANY AGREES TO INDEMNIFY INMATE SUFFERING INCURRED VOLUNTEER BY EXPENDITURES ANY ADDITIONAL FROM DRTG INCUTRED ILLNESS OR DISABILITY THE UPJOHN COMPANY AGREES TO TONTINUE PROJECTS WITH THE DEPARTMENT OF TO CLEAR ALL OF ITS RESEARCH THEM BEFORE INITIDTING CORR AT THE PRISON CONRANY LLLI DSTE REASONABLE STEPS RESEARCH BY THE UPJOHN COMPANY PERMIT PRISONERS TO O1URILEER NOVEMBER 15 1963 BY VICE SEBREIBER PRESIDENT TNT MICHIGAN DEPARTMENT OF CORRECTIONS JR DY DATE DIRECTOR CC FT OCT 14 FILED 1968 AM STATES OF COURT OF THE UNITED STATES DSTRICT MCFLIO UNT3YIJ THE DISTPICT FOR THE EAST SMS CALVIN ALLEN RICHAFLFL FRANK ROGEXTS FILLY LEZ WALTER LTE WILLIAMS BOYD STAGER GEORGE MILLS LE WAUCER CLEMONT DEDZAUX CIDZLL V1LDUNN PI I7ILLIA4 CLYXATTYU HERI3ERT WILLIM4S RREFL ICITNAGEL BZN17 SZLTS KENIWTIT INYAAN IAYMOWD BAILEY DAVIS JERRY ICACK POWCFLLTON RFLQ ACTION CIVIL NO 3117Z TORI RALPH WATSON STYVICXI FHIL4AP CHE5TFI CGHEZ AND VERNON PINTITFS THXNAR C0Z DAVYS MICHTGNN CORPORATION TTIE UPJOHN CO DELAWARE CORPOR3TION DVFCNDANTN IF ANSWERS OF PARKE DAVIS COMPANY RO TRRRESZNOAARONIRS NOW COMES PA1E DAVE AND AN PLAINTIFFS INTRODUCTORY NOTS MADE UNLESS OTHERWISE DAVI CIINLC MICHIGAN LACATED PARKE DVIN LABOR PA AT ININRTTCA IRWI EWNER VOIUATCER TNTEZROCATORICS PAN ITH FOR OF ALL NOTED NIL MICHIGAN ANSWON AUSWER COMPANY D0E5 OR TIAC TTHTT OR REK SOCALKD TO THE NOT NDNAT THAT WORKFOR INNIATES WORK IN PATIKO DAVIS RCGCARCH TTV CORPORATION SAYS THE STATE PRISON OF SOUTHERN MICHISNA CON2P PWLS COMPANY THE CLINIC PARL FARKE IAEON INRAATN IT OR PCRFCRM MVK JOB PRRYJI AIX HSRCNRTOR CLINSC OR HZVE BOEA ASKR TO THE CHI INTERFLFLGATORY NO OR NOT STATE CONTRACT CXI WITH REGARD TO YOUR TIU ON INBOR IN THE STATE PRIOOU OF SOUTHCRN MICHIGAN OF PRISON C4 WRITTEN ANSVYERTO NO NO INRRRRCGATORY NO ST SAID COMPLETE AETAU IN THE METHOD OF PA FOR LABOR UTILIZCDBY YOU AT PRI STATE THE CKSSTFLCATLOM OR TYPE OF EACH JOB PERFONNOD BY THE PRISONORS STATE THE RATE OF COMPENSATION FOR EACH SNEB JOB STATE TO WHOZN ENCH RNCMCY STATC IN VH PAID IS FARM SUCH MOXWY IN PAID DESCRIBE THE WORKIRWOLVED IN EACH JOB CLASSIFICATION OR TYPE YOU HTVE NNMED ABOVE AMWT TO NO STPLTC MICHIGAN WHICH INCLUDE AN OF BY THE PRISON THE CLINIC BY THY AS STTE DCPARTMENL CHIEF RE1ATH C1ASSIFIC GORRECTIONN 125 CERKZ 75 CLERK CHICF COOK NO UEAD OZGER MMNTCNANCE MANZ PORTOR SND NURSE SUPERVUORR 13 SEE ANSWER TO SEE ANUWER TO SEC TO TO THE IMNATES ASSIGNED TO AUTHORITIES PRESENT CLFNTC EHARSES PAYMENTS BY CHECK CCNNPANY MAKES PARKE DWIS ABOVE 6O 100 AND RELATED DAILY CHIEF PR CLERKT ND VOLUNTEER AND CALL SLIPS PAYROLL DOUBLE CHECKS LABETH CLERK AND RNES 1LEAD PORTCRZ JANITOR MAINTENANCE MANTE AND NIGHT JANITOR AND PORTER LNTY STATE COOKING AND OTHER KITCHEN DUUES COOK CHIEF DE OF PRISON REPAIRS AM NNRZE NO THE DATE ON WHICH YEA FIRST BC TO UTI1I THE LABOR OF SAID PRISONC AM3WER TO ND PRWON AUTNORAIE MICHIGAN AT ASSIGNED COMPANY REOEACCH PROJECTS NOMETTME IN INMATES TO PARKE DAVIS 1934 ZWTRE CRY TI WHETHER OR YOU HAVE SIMILAR IN THE UNITED INCAZCERNTION WORK PROGRANIS AT ANY OTHER PLACE OF STATES WHETHER OR STATE IN NOT YOU UTILIZED THE LABOR IN ANY CCWXTRY OR PLACE OTHER THAN THE UNITED ANSWER TO NO PLACE OF INCARCERATION STACS 4C INTERROGATORYNO5 STATE THE NA THE BEGINNING OF OF THE STATE THE STATE BEEN TID FOR EVERY PRISONER WHOSE LABOR HAN BAEN TE UTILI BY YOU SINCE PROGRARI NUNTOR OF AN CL INOIAY NCH PRISOI HOURS EVCRY CUCH PRISONER EACH RUCH PRISONER HAS WORKED BOS BEEN PAD OR STRAC THO NRIAANOR OF DURING WHICH SUCH OF THBOR IN THE BSS TAKEN PLACT STTC THE NUMBER TCTSL WBO LABOR EF UTFLI BCIN IS TIME THE PRESENT STETE THEIR AND JOB CTHSIFIC ANSW TO TO PARKE DAVIS DOLTS NOT 193 WITH RESPECT TO THE RERLOD 1934 SSLT TO THE CLINIC 13 STTECHR OF VU2TT PARKE SP FOR THE TY IMNATOS IZ DWIS 64 TO CON DO NOT TOT 1142 REQUAST JA TABUL IS OBJOCTC4D PERFORMAN THE THC LNFORSNATI IRDORNWUON ELNCE IO ALL BLOW NUSRBER OF HOURS C12 SEC THE TZI PRE 12 NIVNT IXI ARE SS4NERI TO THE CLINIC BY PRFRON SEE RXZIUIE INTRR KT SUDE FL HOW ARE SELICTCD TO WHAT PAT DO YOU PLAY IN SELTCTTA DO 13 TE VS THE THE SINA1 PHGT IN INAATE YC DIF HAVC ANY FROEDOM OF TO THE SELCCTILCN CF ELCCTIQN OF RENCE C71T PROR 235T AU IT UVRL THE IN FTC RTTSE TO WORK PR REG TO THE PRO PRO TH IN IN ICR ICXK OF THE RNNATES IMNATG N2CXR PRO SEKCTICN NN4 TCS 4HER OF PRI IR IRA TAR OTHOR PRA EN WHAT IN NNVTI ARE APP LIED NGDNST WHO REFURIEE PRISONER WORK TO PROGRAM YONR ANSVFR TO NO CLASSIIIC THE PRISON UU THE CORNNATTEE THAT NONE UP TO THE STRICTLY TO ALL ALL ASSIGAVATNTS ASSIGNMENT CLINIC OF CLINIC TO THE CLINIC IS OATZETIONS MADE BY ARE CANPANY IS PRESUMABLY ISSL THE PRISON NOT QURILIFIED IS TO CLASILHICATION ANWZER INMATES FOR REFUSAL APPLIED UP TO TBE PRISON OTRIETLY HAS REQUESTED TO THE TO REFUSE PROCESS FOR PARKE DAVIS ANY IS GIVEN BE CLINIC TO THE OTHER ASSIGNMENTS FOR INMATES SINCE COMINITT PARKE DAVIS OCCASION INSNATE INMATES COMA SELECTION TDENTICA ON SPECIFIC ANY FREEDOM COMMITTEE ASSIGNS THIS QUECTION OF ANSIGAWCN IN THE COMMITTEE INTTRTTOGATOIVF T0 DO YEA KNOW OF ANY OTHER DRUZ COMPANY WITH SHNIHR PRO UNITED STATES IF CC WHAT METHOD YOU KNOU IN ITS NAME OF IS FOLLOWED BY THAT DRUG COMPANY IF PROGRAMS THE DRUG AND THE PLACE OR PLACES WHERE COMPANY OR COMPANIES OUCH PROGRAMS ARE ON AN3WRR RO NO YES PRESUN LNERMRSTION WITH THE TC UPJ THE NANIC TO OTHCR CO IN CON FOLLOWCD BY THE UPJOLZA IE NOT KNOWN BY PARKE SONTHCRN AICB1GNN PRISON OTHERS URC CO NO I2TZRRCCATC1Y TINT CAI TO AIFLHCRLZO NO THIS QACSTTAA INRLANOGATCBPS RELY CM AT TH TXI OF TBIO LABOR PRFRON ST CBJCCTE4 IS DQ 9T HNT TNCTNBERS OF THE IN YI VAU ICIILGNN WE CI YOUR ANSVIRR TO OWN ETOCK OF OF THE ST4TE STATUTCA YOUR CF CORRECTIONS FOR THE STSTO OF MICHIGAN CON NAME THEN IT OF STOCK FOR EACH GIVE THE RNNCWT GIN THE SANTE LNFORRNATION FOR COWRCDTRSINCE NY PR YOUR PEWSON IN PAST RNEMB OF THE DCPNRTRNEMT EFFECT ANSWT TO NO TIIIT BE IS ZNTE1WE ARE YOA PROFIT DO MICHI IN RNAKIN TO YOA ARC FT OR MARKET DRUZS IN INTER DR WMCHRO YCUR IN TEETISM AT THE LOR YEAR 135T PZOFIT ANSWRFL TO YCS CCNRNCRCC TESTOD AT THE STETE TRIEON OF SOUTHAN EACH DSUGRA FOR PROFIT DRU NV STATE INTCR COXN2 XSTATE ETLI TO IN DO YOU NATKET 33 OBJ NO TO RND PRI OBIPPED COAIPKTE IN TNTET COMMERCE YCTTR LO ANWVCR TO PARAGRAPH OF CONPLALNT RENA1N OF QUESTION TO IS NT2RT EACH OB THO IT C1A WHICH LA GIVE T2C RTTE CF ZW PCVFORA CVILTNN THE STNTE PRIAC W0Z21 RCCIVC FOR NF PER TO THIS ARE IHE IN AN FACT FILE NO 12 NRNOUNTS PATD TO OR FOR THE BENEFIT PFL SON OF SOUTHERN 33 OBJECTED TO QUESTION IN TNTRTU NOW II MTCBQ REFLECTED SAME QUESTION THO SANE QUESTION FOR YOUR CITY FOR YOUR AT THE STNTE FEDERAL INCCYNE TAX RETURN ST THE TNCOMNE TNX RETURN INCOSNE TAX RETURN IF RU ONE WITBH ARE ANY AMOUNTS FOR INCOME TAT PURPOSES AT ANY LEVEL RNOUNTN WITHHELD FOR SODNI SECURITY BENEFITS ARE TO NO 12 AZISWER AMOW4E REFERRED RCSC YEA IN OF THE PRISONERS TO IN UNWER TO CXPCNTW IN FEDERAL INCOME 1T TA NO ARE SHOWA RETURN ABOVE SANIE RA SAME AS ABOVE XC NO 13 INTRTUROCATOFLY WBO DETERMINES OF HOURS AN INMATE WORKS FOR NIZNBCR THE WAVE YOU EVER REJCCTED INMATE CON YOU BY YOU FOR WORK IN YOUR DLITILE HAVE YOU EVE SOLXZHT OF AN INZNATC REPBCEMTNN BECAUSE OF UNSATIS FZ COI 0INC THE NAMC RIND CCTNIIA AC ITT AS YOU ORE ABLE FOR THE PRIOR TWO QUESTIONS TH TO ASS IAFN ET IC 12 ECURO OI RC LIN PEN BY PI4 N2HFLCC CF FLY TTS THERC IS FL9T ANJ NO 13 LOW ERCEPT IT CBAN ICR ATSIGNNTCNT TU TFLT SLI TAR IRVTT AT THE RCQUCST OF THE TNNNITE CR JFLIVIS DTVI TEE THE IZMIATE LII MNB1 OR WVAIUING TO PERFORM THE DUTIES MR HIR3 TA AESIGNED AFLE FL SR MR FL1O MR FOWKR MR MACK MR 5STCARNA NO TNTI2UTOGATCT ONV ACTS IT DO YOU RELY IN DSNYIN COR TO LALRITTFFS YOUR THAT THIS IZ THIS IS PROPCR LA CI CTON IN ANSWER TO NO 14 LPE4CRAL CKUTS NCTON THIS RULES PROE OF CIVIL INTW VBO NO TH CONRSTRUCTED PRIVO WHO BUFLT THE WHAT WAC FFIE WHO EWRA THE T1O ATTRELI TNER2 WOTS THO KIH IS BUS IDIW THE OP AWE OR THE ON ST THE COST NOW DI IS TR COPLE OF FOR EITHER BY TATCTE BU PRW OWNER AA VHICH YOUR II THE THSLTDLAZ TR THE NOT ATITHORLED IS ALL OF THE RTPQNZATLE LOZ 11 RLTCNR THE ORIGINAL INVCLVSD ANRWA THE RCT TVOI IS IN THE TTTLE CDS OF OWNERS HOW WAS FEOER HCO2 TREAWD BY 70Q OR OCUMCTTS WER AS FROM TRANDER OR INTR SIA PURPOSUS STATE ANSWER TO NO 15 THT AVCL4TECT AE CT COA DANTA 73ROOLW Z3 APPRO4NI 13 000 00 STATE OF MICTULZAFL NOT APPLICABLE ECPEN NET APPLICABLE ARID STETE OF MICHIGAN XM RLZON INZNATO 11 IC YNA NOT TIE WANT RCCVARCNT THAT AN1 16 PARW CC YOU KEEP TLXEN AAYWAY OF INMC4E CONMPAAY EMPLOYEES FLNVLS PRI3OFLCR TO AS UU COXNPRNY PARKE DAVIS WOX1N TO CLINIC FOR YEN ARE WITHIN THE HE AT IS OW THERE CAY TO OX PITS IN ARC TWE NY CUNTA AN CCFLIOROA TORN PRISON YOUR BUILDING TO 17 YES ARC THE TBE CIVI1L PN ST ERNPLOYOD BY YEAR COMPANY IN YNCRTHC THE CI JOB CLA UNIOA THE 4TL NGRECZRCFL CC1KETTV FRIR4 BENITS LAC1ICI1M BUT OL 1IMIT TO TO NCZW ARE ANTON PARI OF STATE IN DETATI ST ON TH 2RT OF WL2DA TTBE THE CIJAICS YCT RTPZESERT CARRTCD AND AGENTS NCZETLTOR OF THE CONECTTO BO RDNTTNG 3ERSONS REPRCSERTLTR ON NCGATIMION CO ATTNCB OF NIL CORREEPQHDEFLCC THE ANS ONC CO5Y UR WNC IN FACT INA1NDEW CI THIS NO AICBT ATTACH FLEPARTRC IA CO OF IC1 AHP RNETNOUANDA BCTWCEA VOLT CIT DATED NOVOTNBCR 13 AND OF THE DUO STION IS OBJECTED J3 NCWCMBCR LEI TO 20 NC YOA OTATE WHETHER OR THE FOR TIW TO THE RFORCONZD AAD THE PRISON TIAJER CLIUTC CCCPI BY YOUR NAMES THE CORNRNCNCEN OF OF TITO THA HISTORY TC THE FLTFLC IN NT LHC WORZIN NOI JACKSON OF CONIP 1ZAV MEN INRTTRRQCIATORY WTGE FLZI OOUZHT 1E ADVICE OF TO THE LEGRIITY TH CLINICS LAW COPY OF ANY 1C OPINION YOU HAVE ROCCIVED IN COAAECTIAN WITH SATD QUESTION ATTACH CORRCPON RC1ATIN 1E TO AN5WER TO NC THIS CI UI CBJCCTCD NO N3YN0T4 ANY TN 29 INR VN BAVO RCFRSCD FLY 10 JC JR FOR AIW DR DR IN CO NI ER TO KNOWNTO HAVE IU NC ROFN TO THE CLINIC CORR IN PARKE DAVIS NZ HAVE NY INN TO XVERK THR WBC VORKOD FOR YOU IN PRT RELC UPON THEIR GOX YOU AWWEROFL NO OUTUNE THE EHRLN OF COGNT OR DZNIAIS OF YOUR CRRPLOYCC TZ THE PRT EINSC WITHIN THE ANSWER CO JOLIN TO THE AC ATINI TO PCTA EVER WWFTTC WO FOR YOTT IN NONHL NCC UIC THE CLINIC AND TO CONDUCT RCCONRNCATIO LETTER PRITON DRINISTRATIVO CTNC TO AID HIM IN NSE TUTLC FOR ANY INMATE WHO NOTHER JOB OBTAINING ROCA AN TO 24 YC WWLPONARCTNYNO GIVE ANY OF TTACH 33 NGN THE ATT CTY COAT LMS NIT LWSTIONRI COPY MIWL TH CO IN CASE NUABER WNCH OT YU4ION TUSLSS IL IUIT KVOLVING 2RC NAMED AXW NOIT4 AR NFL OTHER LA TIICJ CULT BY YOU ARBI OC NNSTER AN3WFFL TO TW DI 20 IKVE EVA THCR OR RCIPRESONTFLTVCS GIVE COW WORK DCNO TBE IN THE DCTZAILN RCPRCNENTATIVC OR CORR2ETIO INVQ1V1 THE PAYMENT TT NCCORDNNCEWITH THE CIKICE FEDER NGALNJUM WAGE OF THE PROVISLOAS OF OF THE BSN TO OF BCTWCCN YOI LEEN OR THE 6TATE NIAINAANA WAZE LAW IECUSOINN OF ANY SACH TO FL 26 QTZC THIS INTETWCGATQFL IN TO R4 THE DEPARTN FOR OF HWE YEN PDD CARCCTIOT OR RUQ NC TTTE THE TFILT3 IF TO 27 YOUR PROSRAN IVITB CORCTION OBJECTED OF ZRONEY TO EMP1OY CI THE NY DEPAFLN OF ENY YVE DUVIE NENB TO NDN INFSTER OCCMSTONAFLY CONTRACTED WITH ROSTRICTAL DURTN MEDICATION MILLER NOR4NTY CAE KID OIFFY ATTORNCVA 2500 TITCD CC 14 L2 HOUM LP CO TR 43 MI DZ TN1F PADDOCK AND STONE FOR FLCKNT2N DETROIT DETRC PTI DAVIS 1MD1DTN DUJFLQJ LINT BY OF OF 12 CORETINS 1968 DCHARGES EPARTMN SEPTMBER 7345 TOTAL STATE AS THE PERIODS 102 16 12 6 OF 30 589 12 6 124167 95190 46560 15130 3 090 51395 32530 1868 6295 4268 L2 2 49395 43960 3165 42 05 ON STIL 916 6 7286 8176 1 267 AS IGN 16 7 STILONAG STILON AS IGN 8246 1 56 12167 Z 167 72 6 71565 4296 1 2067 93065 STILONAG STILONAG STILONAG STILONAG APROXIMATE ASIGNMET 4286 316 4 1368 AND BAILEY CLEARY CCO DAVIS MAN HONAGEL MAN LNMAN KELTON LORD MACK MCGHE COOK SIMS SPEL S WIL AMS WIL AMS CHIEF TECHNIA TECHNIA TECHNIA CHIEF TRAINED HEAD RUN ER CHIEF COOK C L E R K CLERK TRAINED CHIEF MAINTE C CHIEF TRAINED TRAINE CHIEF P O R T E R PORTER T R A I N E T E C H N I A A S I T A N S U N E R V I S O CHIEF CLASIFTON PORTER SQPERVISO CCOOKHIEF TRAINE TRAINE N U R S E K I T C H E N T E C H N I A CHIEF T E C H N I A T E C H N I A A S I T A N T E C H N I A N U R S E S U P E R V I S O CLERK AS I TAN TECHNI A COOK AS I TAN T E C H N I A ASIGNMET PORTER COOKTECHNIA TECHNIA CHIEF KITCHEN TRAINED TRAINED NURSE TECHNIA CLERK CHIEF MAINTE C PORTER TRAINED CHIEF KITCHEN CLERK TECHNIA COCK KITCHEN PORTER NAME AL EN RMNTMCT AGREENEUT THE METHOD OF CONSTTUCTIOFL FOLLOWING AGREEMENT COVERS RESEARCH DUILDING CLINICAL OF OPERATION AND THE OWNERSHIP AT JACKSOIT OF SOUTHERN MICHIGAN THE STATE PRISON THE THE AT OF AN ARCHI THE SERVICES COMPANY WILL RETAIN CLINICAL OF THE CONSTRMCTION CECT AND WILL CONTRACT FOR AR THE STATE PRISON OF SOUTHERN MICHIGAN RESEARCH BUILDING THE ARKEDAV IS COMPANY WILL PAY THE THE PARKEDAVIS THE BUILDING NING AND CONSTRUCTING THE FOR PLANS AND SPECIFICATIONS BOTH THE MUST BE APPROVED BY ING AND THE THE PARKEDAVIS FARKEFLAVIS THE ENTIRE CLINICAL DEPAR OF RESEARCH BUILD OF CORRECTIONS COMPANY PURCHASE ELI NECESSARY COXNPANY WILL AND THE PORTABLE RESEARCH EQUIPMENT FOR THE BUILDING REMAIN THE PROPERTY PLAN OF THE EQUIPMENT WILL COMPANY OF OF THE COMPLETED PROJECT BY THE DEPARTMENT BECOME AND FIXED EQUIPMENT SHALL CORRECTIONS THE BUILDING THE PROCEEDS OF ANY THE PROPERTY OF THE STATE OF MICHIGAN DAM CONLENTS AGAINST OR ON THE BUILDING INSURANCE PROTECTION SUCH INSURANCE RESTORE THE FACILITY AGE SHALL BE USED TO COMPANY SHALL BE PROVIDED BY THE PARKEFLAVIS UPON ACCEPTANCE EVENT OF ABANDONMENT AND EQUIPMENT ANY MATERIALS BECOME THE PROPERTY OF THE IN THE COMPLETED PROJECT PARTIALLY SHALL SITE CONSTRUCTION DEPARTRN OF CORRECTIONS OF AT THE MAINTAIN ADMINISTER COMPANY WILL HEAT LIGHT ITS OIIN AT AND PROVIDE NECESSARY SUPERVISION TH BUILDIN THE BE RESPONSI WILL EXPENSE HOWEVER CUSTODY AND SECURITY CORRECTIONS OF OF THE THG PARKEDAVIS BULLY DEPART COMPANY WILL COMPANY AND ONLY THE RARKEDAVIS RESEARCH SO FOR CLINICAL HAVE THE RIGHT TO USE THE BUILDING OR RESEARCH IS CONDUCTED BY ANY ORGANIZATION LONG AS CLINICAL PRISON OF SOUTLWRFL MICHIGAN CORPORATION AT THE STATE THE PARKEDAVIS FOR THE CONDUCT OF THE PARKEDAVIS COMPANY WILL BE RESPONSIBLE THEY RESEARCH BUILDING RESEARCH IN THE CLINICAL THE CLINICAL CORRECTI OF OF THE DAPARHASNT WILL ABIDE BY THE POLICIES STATES THE UNITED AND OF THE LAWS FLICHIGAN AND 4A CDNTRACT NB REASONABLE STEPS OF CORRECTIONS WILL TA1 ALL DEPARTMENT RESEARCH BY THE VARKE THE CONDUCT OF CLINICAL TO FACILITATE WILL PERMIT THE DEPARTMENT OF CORRECJOFLS DAVIS IN THE SUBJECTS AS VOLUNTEER TO PARTICIPATE PRISONERS TO 10 THE CO CLINICAL 11 12 RESEARCH CO MEDICAL ADVISORY WILL APPOINT OF CORRECTIONS TRAM MATTERS FACULTY OF SEVERAL QUALIFIED CCNIPOSED THE OPERATIOFLSIFL SCHOOLS WHICH WILL REVIEW IJICHIGAN EITHER WILL APPROVE OR SUGGEST THC YEARLY BASIS RESEARCH CLINICAL USED IN THE CHANGES IN THE PROCEDURES THE STATE OF CMPANY AGREES TO INDEMNIFY THE FARKE4THVIS RESULT INCURRED AS FOR ANY ADDITIONAL MICHIGAN ILLNESS FROI DRUG INCURRED VOLUNTECR INMATE SUFFERING OF THE DEPARTMENT CORN OR DISABILITY 13 OF CONTINUE TO CLEAR ALL COMPANY AGREES TO CORRECTIONS OF PROJECTS WITH THE DEPARTMENT THE ARKED3AVIS ITS RESEARCH INITIATING BEFORE THEM AT THE PRISON PARKE DAVIS COMPANY 7IOV DATE PRESI4SNT MICRICAN DEARRN1 71 DATE DIRECTOR 48A OF CORRECTIONS II TH FOR DISIRICT EASTERN O2 RTC FRANK WALCER BILLY LEE PEYER GEORCE MTLLS LEE BOYD SLACISII LEE WALKTHR CLEMONT DLDEAUX CLEAYY ORDELL VTLBURN WILLIAM SIMS ROC TTERBERT MICHSIQAFL DIVISION SOUTHCRI CALVTN COTJRC DISTRT22 STATWS TJNI2D WILLIAMS FFLED UOINA IKFNNBTTT INMAN RFNNV SPELLS ORCEAN DAVIS RAYMOND BAILEY MACH BOYD KELTON THOMAS LORD RALPH WATSON OFLESTER KTCCHBE VERNON SAWTCKT PHILLIF AND RALPH WARNER MEVIS UMBE CIVIL CASE JUDCE FREEMAN 31172 MOTION FOR SUMTJJRV JUDGMENT BY PLAINTF PURSUANT TO RULE 55 OF THE EDEBATA RULES OF CTVL PROCEDURE PLAINTIFF VS II PARKE DAVIS CORPORATIONS DELAWARE CO AND THE MICHIGAN UPJOHN CORROM CO DOFENOANRS PLAINTIFFS THRCUQH COUNSEL RESMACT2U MOVE TL2 COURT PROCEDURE RULU OF CIVIL PURSUANT LA RULE SS OF THE PODERAL ARNCNC COMOLAI III OF PAINTIFFS TO ENTER JUDGMENT UNDER COUNT OF PLAINLIFH AND IN FAVOR DEFENDANTS ONLY AGAINST AS TO LIABILITY HACHED ANSWERS ON THE GROUNDS THAT IT APPEARS FTAM DEFERIDFLBS TAT DEFENDANTS ANSWERS TO INTCRROGATOE5 HERETO AS RMTBIT OF CALVIN AND THE AFFIDAVIT ATLACHED HERETO AS ETHIBIT THERE IS NO GENULNE THAT EXHIBIB SIMS ABTACHED HERETO AS ENTITLED FLAINTIFFS ARC AND THAT MATERIAL FACT ISSUE AS TO AN OF PLAINTIFFS ITT AS MATBER OF LAW TO JUDGMENT UNDER COUNT OR AS TO LIABILITY COMPLAINT COUNSEL THE CONCURRENCE OF OPPOSING HAS BEAN CTHNICJ CEBOBER 24 1969 PLAINTIFFS TORIES 01 WRITTEN THE DATE HE HEREBY REQUEST ADTJUSIONS GIC GT LEVSON DEAN DEAN SECAR DER2ND IV T30N DTHNBEANSEOAR TOR 14 IJ TO INUUNRORL 4V03 DATHD SOUGHT THAT ANY ANSWERS TO INLE SUBSEQUENT NC RTA YLINRTUC THE RELIEF FLDUE LB HA2TRC IN LER RN LAINTF KARTPC FILED OCT UNITED FOR THE 30 DISI STATE5 EASTERN 1969 COIIR2 MICH LISTRICT SONTHERN II II CALVIN OTRS LEE LEE SIMS RTCHARE FRXN7 ALLEN ARULTLIISVALTJR ETER MILLS BOYD STACILR WALKEM CLEMONT VILBURN WILLIAM NTLTVVMS FRED DEDEAEIX CLEARY CASE NUMBBR 21172 TCOLNAGEL BENNY SPELLS XENNET INIAAN RAYMOND BATTJ2Y ORCEAN DAVIS JERRY MACK BOYD KENTON TMAS LCR0 RALPE WATSON CHESPIR PHITLIP SANICET MCCUEE VTRNON NEVIS RALTH WARNER JUDGE FREEMAN AFETDAVTC IN SUOPORT OF FLAINTYIPFS MOTION FOR STE4MLARY JUDCERT P1 XS ARE CO DAVTS CNORA DELAWARE AND THE MICHTHGAN UPJONN COROORAT ON CO DEFENDANTS STATE COUNTY OF MICETOAN OF GENV II STS CALVIN SAYS AS FOLLOWS PER AFFIANB BEING FIRST THIS AFFIDAVIT IS MACAC AFFIANT OF THE CORMOETENE TO TESTIFY TO THE KNOW DOS IS DULY SWORN DEPOSES URO THE BASIS OF FOILOWIIIQ MATTERS AND HE 3R0 TATCE NERC ATFIART ONE OF TI NAMED PJAINTIFFS NEREIN AND HA WORKED IN THE DRUG CLINIC IUITHING CONSUCTED BY PARKE DAVIS CO AT THE STATA PRISON OF SOUTHERN MHICAN FURTHER HE IS FAMILIAR WITH THE RENAMING NAMED PLAINTI AND OTHER INMATES OF SAID RICISON WHO WORKCD THE SAID CLINIC AS WELL AS IN THE CLINIC CONSTRUCTED BY THE UPJOHN COMPANY THE HOURS WHICH HE WORKCD WERE COMOARABLO TO THOSE WHICH WOULD HO WORKECI BY ANYONE ON REGULAR CIVILIAN JOO AND IN FACT SOME TIMES TE2 WORKCA SEVEN DEAVS THE WEEK TIME UNKED EACH JAY FROM HOURS ON TO SAXTUON 15 VAR RN7 MAJ PC TFLTUR ILJNV MJD2I Z22424 CCRIOD NO OT CIVILIAN ANCL OTHERS WCRXER FIHE CRUO CWLOB OF O1REO CON UNDER THE SUNERV AENO IN DM105 THE LU THE WORK WHICH EXA INCLUDE O1 LC4IN FLH BLOOD SARM1E CONTRIFUGE TO EOE DRATIING ACCURAWLY AND CAKING FL TYP WJBEL RR TE ANNIYTV TAKING TR THOSE PERSONS ARNINISTCRING WAS RIRUINC THEM THROUAH OLASMA JRORI RED CR2IS ROR URINE VIALS SAMPLES AND BLOOD PRESSURE RA USED IN DRUC TESTS CC MOARDIOGRAMS AND OF IMUORTANT OF ELCCTROENCORH KEEROING RECORDS BODILY FUNCTIONS HE AND OTHERS WORKING AT THE CLINICS DID SO BECAUSE THEY WANC ORDERED TO DO SO BY RENRESCNTATIVES OF THE DEPARTMENT OF CORRECTIONS JU BE ORDERED TO THEY WOUJ ZN ANY OTTER TISOFL ANCA RERUSAL TO WORK AS IRIDUSTOY WOULD HAVE RESULTED IN NENALTIES DIRECTLY ISO THEM AND SUCH COERCION AND THREAT WAS UNDER THE CLREUMSTANCES CLEARLY AMPLIED IF NOT EXPRESSLY STATED ARE ES OF THE DRAGS TESTED SAID IN CLINICS DILANTIN HJORCGQYCETJN PANS WI SENADR ALBUSNCIN ZXMBCCHYL CALVIAR4S SUBSCRIBED 1969 AN E04 ILINT 3CTH DAY OF CATCHER CONESEE COUNTY MY CONMISS IE LAWO7R DEAN AND SWORN TO BEFORE ME THIS 5C PC EHI J42V DZRI IRTSO II CYAN RES 1971 FILED NOV UNITED 1969 STATES EAST1 LII COURT OF MICHIGAN DIVISION SOUTHERN CALVIN DISTRICT ET AL SIMS VS NO CASE 31172 PARKE DAVIS AND COMPANY AND THE UPJOHN COMPANY MOTION ACTION SHALL NOT BE MAINTAINED AS CLASS NOW COMES DEFENDANT DYKEMA WHEAT ATTORNEYS RESPECTFULLY MOVES THAT ACTION NOT BE SHALL THIS FED CIV SPENCER IS BY ABOVE MOTION THE BE MAINTAINED THIS AS DAY SERVED CLASS ACTION CLASS ROBERT CL BRIEF ATTACHED SPENCER PLAINTIFFS WITH MAIL SEGAR 804PETROITSTREET FLINT CC 23 COONOW TRIOG COMPANY THAT ONE COPY HEREBY CERTIFY ORDER THAT BY FIRST TO RULE OF SERVICE CARROLL FOR ACTION AR011 TIMOTHY FOR THE UPJOHN ATTORNEYS 2700 PENOBSCOT BUILDING CBRTTFTCATE OF ORDER THAT PLAINTIFFS SUPPORTED BY THO II AND TTIGQ ITS CLASS AS DYKEMA TIMOTHY GOODNOW MADE PNRSTTHNT PROCEDURE AND COMPANY BY ITS UPJOHN COURT ENTER THE IS ACTION THE MAINTAINED MOTION PLAINTIFFS FOR ORDER THAT ACTION SUPPORTING SHALL NOT WAS BRIEF UPON RN ESQ MICHIGAR KXRRRI4 CARROLL FLMOTTY SUBSCRIBED ME THIS DAY 1969 OF 6NV NOTARY AND SWORN TO BEFORE PUBLIC TVTTC WAYNE COUNTY MICH MY CORN EXP 7… 94 ‰T FILED NOV UNITED 1969 STATES EASTERN DISTRICT DISTRTCT COURT OF MICHTAN LII SOUTHERN DIVISION CALVIN ET AL STHS VS CASE NO 31172 PARKE DAVIS AND COMPANY AND THE UPJOHN COMANY MOTIOIQ TO DISIATSS TI COUR1X OF COMPLAINT NOW CONES ATTORNEYS DYKEMA WHEAT RESPECTFULLY MOVES THAT BE DISMISSED IN CLAIM ITS UPON WHICH THIS CIV DEFONDANT THE UPJOHN COMPANY BY COUNT TI CAN NOTION IS IS COUNT TI AND TRIGG PLAINTIFFS OF AS ENTIRETY RELIEF PROCEDURE AND GOEDNOW SPENCER COMPLAINT FAILS TO STATE BE GRANTED MADE PURSUANT TO RULE BY THE ATTACHOD SUPPORTED DYKEMA WHEAT 12 CERTIFICATE OF THE BE ABOVE MOTION MAINTAINED THIS DAY AS SPZC SERVED FOR ORDER THAT CLASS HEREBY CERTIFY PLAINTIFFS WITH ACTION BY FIRST TRIGO COMPANY SERVICE CARROLL CLASS 1ED MEMORANDUM OOBTL TIMOTHY ATTORNEYS FOR THE UPJOHN 2700 PENOBSOOT FLUILDING TIMOTHY ITS MAIL THAT ONE COPY ACTION SUPPORTING BRIEF SHALL NOT WAS TIPON ROBERT SEGAR ESQ 804 DETROIT STREET FLINT MICHIGAN A4 CARROLL TIMOTHY AND SWORN TO BEORE SUBSCRIBCD OF JRVFATTCT 1969 IWIL NOTARY PUBLIC MY COMMISSION WAYNE COUNTY EXPIRES MICHIGAN KATC 5TH TO THIS STATES DISTHICT COURT IFLCHIGAU FOR THE EA2ERII DISTRICT OF OUMMT DIVISXCU CAVIN UOCE LEE SIMS LEE BILLY WALRR VIL3U3N HERBERT WILLIFL43 CZ0R0 MILLS PETEII DEDEAUX WILLLQ FP SPZLLS BETIR GLEAFLLY HOLRAGEL ETHAU EAYWOIID ORCEAU DAVIS THO4AS BOYD ICELTON BAILEY WATSON FPAFL WATTS WFLL1A2T5 CL BOYD SLASER LEE ALLEN RICUAFCD JE SA CTLESTER MCCBE AND VERNON TOP MACK RALPH PHILLIP MEVIS PLAINTIFFS VA EARRE DAVIS CIVIL 31172 MICB COIIPATTY UPJOHN CORPORATION DELAWARE CORPORATION AIRS ACTION COMPANY DEFENDANTS PAM A1QS1 OF TO ADDTTIORIAL NOWCOMES PAR AND ANSWERING PLAINTIFFS TNTETFLCATORY ITO AT THE OF THIS TRIAL ANSWER TO THE BEEN INTEIWOGTORV NO STALE IN THE THE STBJECT PRECEDING INT COT2ANY OF EVERY WITNESS MICHIGAN WHO YOU CORPORATION SAYS RELY ON CAUSE UO WITNC HAVE NOT YTT DAVIS ADDITIONAL THE NAME AND ADDRESS LIST DAVIS COMANY INTERROGATORIZS DAVIS MAY CALL AT TH2 TESTIMONY OF EACH ITNESS WHOA PARKE TRIAL DETERMINED MATTER QUCSTION OF THE XAMED ANSWER TO STO THE WITNESSES TH LAICWLEDGE NOT HE WILL NANE AT MATTER OF THE PROPOSED TCSTTHCNY MOWN UNTIL THEIR IS IDENTITY OF TRIAL ESTABLISHED NO INTHTROGATOAY LIST SUBJECT AND ADDRESS OF CACH OF YOUR THE ICORKINGS AND PROCEDURES WHO HAVE OF YOUR PRISON CLINIC 7O A3YTSWER TO PARKA FLAVIS COMPANY DOES NOT 1A ALL THOSE WHO MAY HAVE SOME KNOWLEDGE OF THE WORKTHGS AND PROCEDURES OF THEIR CLINIC AT JACKSON PROBABLY WITH THE BUT KNSWZ AT TO BCST ACQUAINTED PRISON CLINIC COMPANY DOES NOT KNOTI ALL OF THE ORIGTNAL CLINIC ON BEHALF OF PARKE LOYND 610 NEFF ERISON OF OPERATION DAVIS THOSE WHO NEGOTIATIONS AT JACKSON THE COTNENCENONT HARRY TO THE ESTABLISH THE PRISON OF THEIR AGREEMENT PRECEDING LEADING NO KAOWLEDGS THE ESTABLIDMIENT PRESIDENT THE WOOD IS OF EACH OF YOUR EMPLOYEES WHO HAVE NEGOTIATIONS PARKE DAVIS EXECUTED WHO IS GEORGE NO WENT OF YOUR CLINIC VFLS EMPLOYEE OF LOOWLEDGA OF THE ORIGINAL SORB NR AND THE NAME AND ADDRESS MAY HAVE AT PRESENT PARKE DAVIS THE WORKINGS INTERROGATORY LIST ONE PRISON LEADING BUT OF THE CONPENY BY ITS ROAD CROSSE OINTE TO THE CIMNIC THEN NOW RETIRED INTEWIOCATORY LIST TH RIME WHO YOU HAVE NO AND ADDRESS OF ANY PERSON OTHER THAI TO IN FTVO HAS SUCH KNOULEDGE REASON YOUR ER YO ANSWER TO CCRN PARKE DAVIS HAVE ESTABLISHWENT PRECEDING EXECUTED ITS OF THE ORIGINAL SOME KNOWLEDG2 THE OF DIRECTOR THIERROCATOTTY OF OPERATION COMENCECNANT OF THE ON BEHALF MR T4CHIGAN PRISON OF THE LEADING BUT THE TO THE AGREO CLIN CORRECTIONS DEPARTMENT AY BY GUS HARRISON NO THE NAME AND ADDRESS STATE NEGOTIATIONS AT JACKSON CLINIC THEIR THOSE 7HO DOES NOT KNOW ALL OF THE PERSON IN CHARGE OF PERSONNEL FOR YOUR COMPANY 70 AFLSWER NO DIRECTOR MATHENS 1563 EDMONTON CROSSE POINZE INTE QHAT IS PRISON OF PERSONNEL MICHIGAN NO THE PAY SCALE FRINGE BENEFITS THE OVERTIME WHAT IS THE AFLSWER THIS BY YOU OUTSIDE AVAILABLE RATE MC TO SUCH EMPLOYEES OF PAY FOR SUCH EMPLOYCES FOR SUCH STANDARD OF ANY APLOYEES UNION 20 QUESTION THE DRUG TESTING WHAT IS ARE THEY ER FOR CIVILIANS VHO ARE ENGAGED IN STATE ALL RELATIONS IS OBJECTED TO PAMCE DAVIS CO7TPANY XJOHN BRADSBS ASSISTANT SECRETARY STATE OF 2TCHIGAN 35 COUNTY OF WAYNE JOHN BRADSHA7 BEING FIRST DULY SWORN ON OA DEPOSES AND SAYS AS FOLLOWS THAT PARKE DAVIS HE IS ASSISTANT COMPANY THAT INTERROGATORES MICHIGAN HE HAS READ BY DEFENDANT THE PARKE SECRETAQ OF DCFENDANT CORPORATION FOREGOING DAVIS ANSWERS ARE TRUE AND CORRECT TO THE BEST INFORMATION AND AND ANSWERS TO IN CCRNRANY AND SUCH AT HIS CR JOHN ASSISTANT SUBSCRIBED THIS TTT AND SWORN TO BEFORE DAY OF 1969 RA COUNTY NOTARYUBLIC MY COMMISSION ME EXNIIES MICHIGAN 70 BRADSBAV SECRETARY JAN FILED UNITED FOR THE 21 1970 COURP STHTES OF MICHIGAN DISTRICT EASTERN DIVISION SOUTHERN FRANK STMS RICHARD ALLEN LEE WIELTAMS WALTER ROGERS BILLY LEE BOYD SLAGEE PETER GEORGE MILLS LEE WALKER CLEMENT DEDTAUX WILLIAM CLEARY OFLDBLL VILBURN HERBERT W1LLTAMS FRED HOLNAGELI KENNETH INMAN BENNY SPELLS ORCEAN DAVIS RAYMOND BAILEY JERRY MACK BOYD KELTON THOMAS LORD RALPH WATSON CHESTER PHILLIF MOGHEE VERNON SAWICKI RALPH WARNER MEVIS CALVIN CASE NUMBER JUDGE A1 3117 FREEMAN COMPLAINT PLAINTIFFS VS CO MICHZGAN PARKE DAVIS CORPORATION AND THE UPJOHN DELAWARE COROORATION ELEANOR HUPZBL BROOKS WADSWORTH ERNEST JAMES RICE JOHN FABLE MAX ETBER WATERS FLORENCE CRANE JOSEPH DUANE ROBERT COTTON AND GROSS GUS CO HARRISON DEFCZVLFLU5 PLAINTIFFS COMPLAINT OF DEFENDANTS AS FOLLOWS COUNT JURISDICTTOFL TITLE9 UNITED 2166 GROUNDED UPON STATES CODE ANNOTAUCD 16B OF THE FAIR LABOR SEC OF THIS SEA COURT IS STATES CODE ANNO BATED 2S UNITED COURT THE DISAICT 1337 SEC GIVING ACTION OF ANY CIVIL ORIGINAL JURISDICTION OF UNDER CT ANY OR NROCEOD NGS R15IFL9 WITHOUT REATRA COMMERCE CONGRESS REGULATING OR AMOUNT IN OF THE PARTIES TO CITIZENSHIP TITLE WOF CONTROVERSY LEITSON ECAR DEAN HART WOE NCRAO FLINT MICA PC TITLE 28 UNITED STATES CODE ANNOTATED SEC 1343 TITLE 42 UNITED STATES CODE ANNOTATCD SEC 1933 FOURTEENTH T7 AMENDMENT TO THE AMENDMENT TO THE UNITED CON LUTION STATES CONSTITUTION II ACTION THIS TO SEC USCA FAIR THE 15 201219 SEC IS PRISON FOR FORMED BY AND PURSUANT PUBLIC OF ACTS GENERAL DEPARTMENT OF CORRECTIONS OR HAVE BEEN JACKSON FTEZ SET INMATES MICHIGAN OF AN THE WHO HAVE FORTH ON THE PART STATE THE OF TH DRUG BOTH DEFENDAFLR AND IN IS CORRECTIONS OF THE 232 SUPERVISING PENAL INSTITUTIONS THE BEEN MEMBERS OF SAID PLAINTIFFS RELEVANT PRISON SAME HE PARTICULAR IN THE DIRECTOR IS CO DAVIS ACT WITH SAID OF ARE NUMEROUS OTHER PEOPLE THERE DAN OF NUMBER AND INDUSTRIES AT TIMES HARRISON TIMES OF MICHIGAN ADMINISTRATION NAMED ATE OR HAVE DEFENDANT LAWOFSIC THE ALL ENGAGED TO ACT CHARGED BY LABOR AND PRISON MEMBERS ACTION AND IS AND MANAGING INDIVIDUAL OF FLINT 1953 AT PARKE DEPARTMENT CORPORATION IN ZC DEFENDANT STATE DELAWARE STATE COMMERCE THE COMPANY IS THE THROUGHOUT OF ENGAGED IN SIMILARLY PROFIT INMATES PROFIT PRIVATE UPJOHN DAMAGES LIQUIDATED DEFENDANT INTERSTATE CONTROLLING HART PRIVATE BUSINESS ARE DOING DEAN THE AND DEFENDANT CORPORALION FOR CORPORATION MICHIGAN INOUSURY CAUSE OF ACTION THIS RELEVANT AMOUNTS ON SAID MICHIGAN AT JACKSON SOUTHERN MICHIGAN OF UNPAID INTEREST HAVE BEEN OR 29 OF 1933 FEE ATTORNEYS ARE PLAINTIFFS ACT FROM FLEFENDANT AMOUNT AS PURSUANT COUNT PART COMPENSATION RCASONABE COURT COSTS AND IN STANDARDS TO RECOVER DUE AN EQUAL ADDITIONAL SINCE IS LABOR WAGES AND OVERTIME MINIMUM BROUGHT OF CSU SAID CAUSE DEPARTMENT WHO EITHER ARE SOUTHERN MICH OF ACTION NAMED PLAINTIFFS AS GASI AT HEREIN AND THE ON ICIVIL IT AD QTGELY CC UPJOTFL PROFIT RAKING SAID IN ACTIVITIES THROUGHOUT INTASTATE IN THE THE WELL FOR SOLD COMMERCE INTERSTATE DEFENDANTS COMMERCE WITHIN THE MEANING OF USCA 29 2Q3 IN WITH CONJUNCTION UPJOHN THEREIN CO AT UP LE LAAV THE RRRAO MLC 4SZO OTHE AND REPRESCNTTIVC PARKE SAID UUVTA LAS PAID IS CI WORK CARRIED EXACTLY PERSONAE BY THE EMPLOYEES RESPECTIVE THE CO PARKE DAVL5 THE IN ANA SOLE DIRECTION WORK ON THE UPJBHN REGULAR ER BASIS WEEK NAMED PLAINTIZES PRIVATE CAPACITIC2S COLFIPCKRAJ CORPOT LE OF THE WORK CO2S AND HOURS CO AND BE RCCU1YCC SAME WERK THAT WOULD THE WOR BY 112 BLAINR DEPSRTTFLQ THE MICHIGAN DAVIS SEC AND THE UPJOHN ON UNDER ONE HUNDRED TWELVE AS MUCH NFLNPRLSON OF CARRIED IS O1FICZS OSAN CO INCLUDING RESEARCH CLINICS AFORESAID OF DERENDANTS THE OSAN SEGA HART PC FLINT TO DAVIS REPRESENTATIVES INMATES BY SAID AND SUPERVISION COS PRISON TO HE EMPLOYED BY DEFENDANTS CORRECTIONS THE PARKE BY DEFENDANTS WERE PICKED SAID OF INMATES CERTAIN ENGAGEC ARE ENTERPRISES STATES UNILED THE CLINICS INCLUDE PRODUCED BEING IN PRIVATE ON THE MARKET PRESENTLY DELIVERED AND SHIPPED TRANSPORTED THE COERATIOFI IN OTHC THINGS AMONG DRUGS CURRENTLY OF TESTING THE CLINICS FOR AND SAID CORPORATIONS ARE CURRENTLY OF DRUGS NET TESTING CLINICAL OF SAID AND COATINFLO HAVE BEEN AS PURPOACS AND OF SOUTHERN CLINICS RESEARCH CO ONVIS PARKE PYISOFL STATE THE PHE NARTED CLASS SAID MICHIGAN WHOSE RUR4HCY RAKE PLAINTIFFS NAMED DEFENDANTS THE ERECTED WITHIN AT JACKSON MICHIGAN AS JOIN RU‰T THE OF SUCH PEOPLE REPRESENT TN 1962 THE CC ALL TO HAVE THEA IBIPRACTLMLI PLAIFLB14S HCH 23 TO RULE NURSUANT BREUCHT IS ACTION THIS SUCH UNNAMED PEOPLE REPRESENT AICGUAT PLAINUFFS 1522C1 DEFENDANTS THE TO CJKC2 07 WA IL II 125 25100 IIL AMONG THE ARE IN IN TECHNICIAN TRAINED CLASSIFIED ALL COCK CHIEF NURSE ALL OF KILCHERT ASSISTANT OF ACCOMPLISHED APPLICABLE TEDERAL 10 FAIR 201 CO BY CIVILIAN COMPLAINED AND THE IN SAID THE FACT OR THE PRISON LABOR UNITED STALES FOR PRIVATE REGULATING INCH CRRZZR CO AS TO BE 29 STAKE SEC ACTIONS ANN BY THE AGREERENT PLAINTIFFS FURTHER AND THE SAID EVADE AVOID REGARDING THE TO MICHIGAN THE MINIMUM THE THE MNTIMUM ACTS AND OF DEFENDANTS OF OF BOTH CORNORATE AND INDIVIDUAL IATILIZ PROFIT THE WOULD USCA PAID OF THE LAWS OF MICHIGAN WAGE TO BE PAID ARE ENTITLED BETWEEN AND OF DEFENDANTS THE MEANING AMENDEI LAW AN ATTEMPT IN TO THE ACCORDANCE WITH IN PAID WITHIN ALL DEFENDANTS 11 DIFFERENCE INMATES SAID BY WERE ACCOMPLISHED ILLEGAL LAWS OF THE VIOLATE ACT OF ALL TO THE BENEFIT CONSTITUTED RROI7 1938 OF ACT PLAINTIFFS OF ALL NAMED HEREIN FLINT NAN CORPORATIONS WERE AND ARE EMPLOYEES AND THE UPJOHN FOR IN OF BY COOPERATION THE PAN INURES PRIVATE HELP SEQ AND WERE AND ATE ENTITLED WAGES PROVIDED BEAN OBAN SEGAB HART PC AND POT SUPERVISOR LAWS STATE AND STANDARDS LABOR INURED KITCHEN ACCORA PLAINTIFFS DAVIS ET NURSE CLERKS DEFENDANT OF NOT TIFF HAVE TO BE PARKE TRAINEES TECHNICIAN BY PLAINTIFFS ACTIVITY THE STOCKHOLDERS THE WORK WHICH INVOLVES CLERK OBJET THE INMATES OF AROAS AREAS CLINIC EACH CLASSIFICATION IN CLASSIFIED ALL THQ POWER HEAT AND WATOR CLAS TECHN ANC MAN HEAD PORTER MAINTENANCE BENEFIT SUCH AS JOB CHIEF FOLLOWING THE TO ONE DOLLAR OTHER COSTS OF RUNNING AND ALL DOFONDANTS BY SAID ARE PAID DA PCR 035 CENTS WORKER RANGE FRAN THITTYFIVO TO AMOUNTS RECEIVED RECOVER BY FOR FROM LABOR ACTIONS AND MSE OR AND THE LABOR DO ENNANTS EACH PLAINTIFF II AND THE MINIMUM TBA PENSATION DUE BE IFLAY AS WELL INTEREST DUE ON SAID 12 NUMBER OT HOURS AND THE THE TO THEY KEEP WHICH RECORDS THROUGH THE ACTUALLY KNOWLEDGE OF THE THE WITHIN IS EACH PLAINTIFT AMOUNT OF OVERTIME THE AMOUNTS AS FOE DUE THEY WERE BACK WAGES SINCE WELL AS WORKED BY EACH PLAINTIFF AUTORREYS REASONABLE AND DAMAGES COURTS COSTS CORN AMOUNT AS ADDITIONAL EQUAL LIQUIDATED AS NRR 11 IQ BY WAGE GUARAFLT30C PAID DEFENDANTS PLAINTIFFS REGARDING EMPLOYMENT IN THE PLAINTIFFS AS INCORPORATE PUBLIC IT REFER TO AND EMPLOYMENT IS AFORESAID TH OF ACTS OF 1964 STATE THE MINIMUM WAGE LAW OF 1964 LAWS OF THE STATE OF STANDARDS ACT EMPLOYERS HEREIN II IAVJOFLC LEFT DCAN SEGAR HARV ULVRQI FLINT S7FL MCH 4S TION IS RC TAC BASED OF THCI MINAMUM BEING ALLEGATIONS HEREOF OF COUNT BY DEFENDANTS ACT NUMBER OF HEREBY OF 154 AS THE COMMONLY KNOWN AS MICHIGAN SEC 40S381 THE COMNILED OF MICHIGAN AS THEN THE IN PART COURT DCTERM4 THAT AMENDED DOES NOT APPLY 1938 WOULD APPLY MTCHIAN 12 OF THE HEREIN OF PLAINTIFFS VIOLATION IN SHOULD THIS IT INTERE PLUS BY SUCH REFERENCE REPEATED THROUGH TWELVE THE ALLEGED COUI41 THOUGH EXPRESSLY ONE OF PARAGRAPHS DOLLARS FEE COSTS AND ATTORNEYS II LQOOODOOO AMOUNT OF ONE MILLION DEFENDANTS JUDGMENT AGAINST SEEK WEERPFORE PLAINTIFFS MINIMUM SET OUT IN UPON IFFCRCFLCE SEC BETWEEN WAGE PROVICED WAGE LAW OF SEC 13 OF 14 THE FAIR TO DEFENDANT THE STATE THEREOF SAID ACT NIN ARID OT TINS AND SEEKS THE AMOUNTS RAID BY SAID LABOR TO PLAINTIFFS WAGE LAW AND FOR II EQFL AN INTEREST THE WHERRT COSTS AND RARAGRAPHS ITT PLAINTIFFS REFER TO AS THOUGH ETPRCSE REPEATED 12 OF THE CZONTTARY IS MICHIGAFLAND PARTICULARLY IN PART PERTINENT DEFENDANTS AGAFLST JNDGTFIEFLT DOLLARS INTEREST PLUS EREOF LABOR OF SAID AW INMATES OF THE STATE CL OF OR ALLEGATIONS THE OF COUNT TO THE 300335 SEC MOOR AND BY BUCH REFERENCE THROUGH TWELVE THE UTILIZATION DEFENDANTS CNPTHWE LAW 1ODO300QO COUNT ONE FIAIN FEE ATTORNEYS PORATE HEREIN SEEK PLAMNTIFFS MILLION THE AMOUNT OF ONE IN WAGE MINIMUIFT TQITH TEE AND ARC EMPLOYERS SAID OF MEANTRIG DAMAGOQ WQETHCC ATTORNEYS REASONABLE COSTS AND DOFENDAFIBS WITHIN 1IQU AMO ADATTIOFLAL 43 WHICH OF PROVIDES OR BE SOLD CONTRACTED FOR OR LEASED HIRED OR CORPORATE OTHRW1SC USED FOR PRIVATE THAN THE OR FAR ANY OUHER PURPO5C OF PROFIT OPERATION OR CONSTRUCTION MAINTENANCE DIRECTED W0RC5 WAYS OR PROPERTY PUBLIC BY THE COVERNORI NOR 11‰ AND SEC 9QO310 SHALL CI THE LOANED WHICH 48 HEREBY THIS LABOR OF IN PROVIDES DECLARED TO BE PERTINENT THE ACT INTENT PART OF DIVERS3 TO PROVIDE ADEQUATE REGULAR OF THE FOR PRISONERS EMPLOYMENT AND SUITABLE WITH PROPER PETAL PURPOE5 STATE CONSISTENT II LABOR OF PRIOFLERS AND FOR MAINTENANCE STATE FOR THEIR CRINES AND MDRISOFLMCNT TO UTILIZC FOR CLUSIVELY LAW SELF NER WCC LCITSOW OSAN DSAN 5EGAR RELATIONSHLMS PRODUCTS AND AND DISBURSC TO AFLOAT THE PRODUCLETDIRCCT MERIT OF MCLEAN LABOR AND PRISON WTTH NO STATE AUTHORITIES EUTABLISIXED THROUGH HART FC T04 THE ALL COMPETITI TO ELIMINATE LABOR BETWEEN PRI MNDUSTXU FREE LABOR OR PRIVATE CD RR TA FUN II BY IF INTEYMT THE AIRII CONSIDORATIFLNS CU IT AND IS IN AMOUNT BY WHICH THE IN PEFONDANTS HAS BEEN AND IS THEY ARE IL II AID AMOUNT REASONABLE AND THE TO TO BEING VALUE THE BCTWEOFL BY THE DIFFERENCE AND IJLEGAJLY UNJUSTLY BENEFITING OF BY DEFCFLDANTS KNOWLEDGE THAT FULL WITH BY DEFENDANT HAS OF VALUE REASONABLE THR OF PLAINTIFFS LABOR THE PLAINTIFFS ENR3CHRN EXCOEDS THO AMOUNT PAID SERVICES PLAINTIFFS AND LABOR OF AND INTEREST PCOFIT UN THE IN IF OR THO CRVICOS OF OWN PRIVATC FOR FLEFONDANTS PLAINTIFFS UTILIZED OF APPROPRIATIONS TIJIZATI THE ATC IM2Y0L1LBIL DROR1R RIVAIE OF OF THCIR SERVICES CC IE DAVIS CC ANDTBE II THE AT LEASU THE LAWQ EAN II UPJOHN STATE MIC ZR CO WHICH OF AS AS BY ALLEGED COECIOFL ORDEROD OF SERVICES PLAINTIFFS THE WOULD BE DUE THEM UNDER MICHIGAP AND AND THE UNITED STATES MINILTUM OT AMERICA PTHINTIFI OAR TAR O4 ZTJTOT COSJ NOT WORK FOR PARKE THEY DID IF REASON ARRTOUFLT WAGE LAWS OF THE WHOSE AND CONSENT AND UNDER RETRIBUTION OF THREAT COST WHICH CLINIC THE LABOR WAS UTILIZED PLAINTIFFS WITHOUT IMPLIED IS HOUSING OT TODAY PLAINTIFFS DEFENDANTS JABOR BY THE SOUTHERN MICHIGAN TO CONSTRUCT 30000000 BE FARGREATET OF PRISON AND ENRICHED UNJLLTL OF PIAINTIFFS USE STRUCTURE THE ANUROXIMATELY WOULD STATE THE FOR ACQUISITION HAVC BEE4 ILLEGAL FROM THE NENEFITED BILIDING GO THE UPJOHN AND DAVIS OTHER THAN PARKE NEFCPDANTS TN ADDITION THEIR 45 OF ABOR AND THE STATE OF THO HAVE UIT AS THEREFORE THEREOF IN HAREINBEFORE BEEN UNJUSTLY VIOLATIEN SET FORTH OF THE DEPRIVCCZ LAWS II EEF AND BETWEEN DEFENDANTS LABOR PRISON REGARDING OF THE ON THE INTEYE5C DATES COUNT FROM THE THIS TO THEM UNDER SAIME AMOUNTS SAID DUO WORE SEEK WHLRBFQRT PLAINTIFFS IN TO ARE ENTITISCI 10 AMOUNT DUE ZOR TO PLAINTIFFS BY ‰FONDANTS PAID RROLLFLTS CNCGSS SERVICES EF THEIR VALUE TO RECOVER CNTITJED ARE THEREFORE RECI THE FROM DEFENDANTS OF MICHICAFL STALE OF THE FORTH SOT ALREADY PLAINTIFFS II AND STATUTES THE VIOLA ECAUS BETWC M1AINT TWA AR VOL ANY OTHER PARTY EXISTING US THC CONTRAC COST5 INTEREST DEFENDANTS PLN DOLLARS 100000000 AMOUNTOF ONE MILLION THE AGAI JWDRIIFLEFLT FEE AND ATTORNEYS COUNT TV THE HEREIN PORATE 12 TWELVE OF COUNT LABOR BY ALL CO THAN DUE PROCESS OF LAW AND IN HOLDING TO THE THIRTEENTH IN PIAINTIFFS AMENDMENT SAID LAW QFCX OSAN OSAN SEGAR OF THE VIOLATION CONDUCT HAS SAID IN TO HAF FLNT TUC OF THE STATE DR1SONEZ OF NOMINAL AND OF GICHIQAN WAGES LESS IN IS WITHOUT IFL THE FOURTEENTH OF ALSO RESULTED NVOLUNTARY AND IS RESULTING SERVITUDE CONTRARY CONSTITUTIOS THE DEA BY PLAINTIFFS CONDUEB WAS CARRIED LEITSON LAWS CO AND PROPEUY LIBERTY DO CT THE PAYMENT AND DEFENDANT BY LAW HAS RESULTED OF THE THROUGH ONE AND UTILIZATION AND THE UPJOHN THOSE REQUIRED DCPRIVAT PARAGRAPHS HEREOF ILLEGAL THE PARKE DAVIS OF ALLEGATIOFL5 LXCOT BY SUCH REFERENCE TO AN REFER ING OUT UNDER WITH THE COLOR SUPERVJ OF ROSULT ALSO DC AMENDMENT FOURTEENTH ANY SERVICE ENTITLED LABOR THEIR FOR 1983 OF TITLE 42 XE BEING AMOUNT OF WAGES PAID TO THE SAME WORK OR PERFORMIRWJ CORPORATIONS WOUD BE WAGE THEREFOR UNDER THIS 1343 AND HAVE BY THE HAVE BEEN AND THE IN MAKING REASONABLE TO COLICET LAWS GUARANTEED OTHERS DOING PROFIT JURISDICTION SEC THO AGAINST SINCE PRIVALE OF THAT PLAINTIFFS IN DISCRIMINATED ARBITRARILY THEM FOR EQUAL PROTECTION CONDUCT RLIINTITHTS SAID OF COURT IS OZ TITLE 23 GROUNDED UMON OF UNITED S4ATES CODE ANNOTATED RITE CAUSEAAAMJH ACTIONS TO PLAINTIFFS IN WHEREFORE PLAINTIFFS DEFENDANTS PLUS HI IN INTEREST THE OF CORAPLAINTED THE HAVE PROXIMATELY AMOUNT OF ONE MILLION SACK JUDGMENT AMOUNT OF ONE MILLION COSTS AND ATTORNEYS AGAZNSC 1OQOOOOOO DOLAT FEE LBTTSONDBAN PLAINTIFFS ATTORNEYS BY 71 KOBDRT DATED CI LAW DIAN DEAN HART PC LESITBON T3 FLINR RECT MIOB ITHO II 3CR 1969 FOR SOGAR WXRTFC UNITED OR THE DISTJ STATES OP MICHIGAN DISTRICT EASTEYIRN SOUI CCITT DIVISION FRANK RICHARD ALLEN CALVIN SIMS WALTER THE BOYD SLAGER BELLY THE WILLIAMS THE 19 WALKER CLEMENT PETER GEORGE MILLS DEDEA ORDELI VILBURN WILLIAM CLEARY FRED HQLRAGEI BARMY SPELLS HERBERT WILLIAMS CRCEAN DAVIS KENNETH INMJRM RAYMOND IL BAIJEY THOMAS II KCLTCN LORD JERRY MACK BOYD CHESTER SAWICKI PHILLIP DIOGHEE WATSON RALPH VERNON 19 MEVIS WARNER RALPH PLAINTIFFS CIVIL NO VS BROOKS DUANE GROSS FILE CO CORPORATION AND MICHIGAN DELAWARE CORPORATION HUT2C JAMES WADSWORTH ERNEST MAX BIBER FANCY JOHN VI RICE FLORENCE CRANE JOSEPH WATERS ROBERT COTTON AND GUS HRURISON PARKE DAVIS THE UPJOH MEANER ACTION 31172 CO DEFENDANTS ANSWER TC CCMPLATWT COUNT NOW COME ELEANOR ROBERT COTTON CROSS JOSEPH KELLEY FTANK BIERCAFELD ASSISTANT TUTTOIMA WERO LAWFULLY SERVING PRISON GENERAL ATTORNEY ATTORNEY TO TIM PROVISIONS CONVICTED TORUS IN THEY HAVE NOT BEEN OF ERIN JAEKSI DENIED AND GUS OF THE AND ANSWER AS OR THE STATE JACC500 OF ANY CONSTI THAI ONA STATUTES AND PLAINTIFFS OF MICHIGAN MICHIGAN OR ATTORNEY 1OLLOWS ACTION CAIJEE AGAINST PRISON THE OF CRANE BY SOLOMON OR MICHIGAN APPLICABILITY ALLE BY THEIR HARRISON STATE BROOKS FLORENCE WATERS DUANE GENERAL DENY THE DEFENDANTS CONGTI RICE JOHN FARLEY MAX BIBER WADSWORTH ERNEST JAMES ILUTZEL STATUTORY AND ARC THEREFORE RIGHTS DEFENDANTS DENY DEFENDANTS ADNILT ANIT PRISON JACKSON THAT COMPANY ARE ENGAGED IN DENY THAT IT THE THE MEMBERS OF THE MICHIGAN STATE AND HAVE AT OFFICERS OFFICERS THEREBY DEPARTMENT PROCEDURE IS ACTIONS IN FEDERAL DENY THAT COURT FOR THE FILE ACTION FOR THE MINK EASTERN US OF JR BY COLERIDGE ET MLCHLGAN O17 SUCH RULES TAYLOR SOUTHERN RE JR STATES UNITED FILED STATES DIVISION MASON OF SIMILAR UNITED CX SAID OFFICERS STATE SAME OR AT ARE STATE AS OF THE OF AMERICA AL OF 1963 HAVE PREVIOUSLY ET PA 1965 380 FEDERAL SOUTHERN MICHIGAN OF CORREOTIONS URICT INMATES STATES OF THAT DEFENDANTS UNDER OF THE CHASE PAUL UNITED THE MASON FLCPARTMENT MICHIGAN OTHER ASTERN DISTRICT COLERIDGE RULE 23 DEFENDANTS CAPACITY IMMUNITY COURT BASED UPON THE DISTRICT NO 3I480 THEIR BY IMMUNITY PROTECTED UPJOHN THE CONSTITUTION THE DIRECTOR IS MID BY ACT NAMED AS IN WITH HARRISON GUS APPLICABLE FAR CIRCUMSTANCES ACTED THEMSELVES SIMILARLY DEFENDANTS CIVIL TIMES OF AND STATE CORPORATION OF THE MICHIGAN INMATES PROFIT ESTABLISHED OF MICHIGAN ALL PROTECTING AND IS IS CORRECTIFLFLSCOTIRNISSFTON DEFENDANT CIRCUMSTANCES FOR PRIVATE DRUG INDUSTRY SECTION TO ARTICLE PURSUANT CO DAVIS PARKE DEFENDANTS STATE HAVE BEEN P2AINTLFTS OF CORRECTIONS DEPARTMENT AN AGENCY OF THE THAT DIVISION DISTRICT CIVIL FOR THE DISTRICT CIVIL COURT ACTION NO 29260 DEFENDANTS ADMIT DEFENDANTS DENY AND WILLY AND GEORGE 99260 REFERRED WHICH DAVIS INMATES KROPP TO IN PURAGRAPH PARTICLP2TE CO AND TLIE RILED UPJOBN IN IN 14 ATTACH HERETO AFFIDAVITS CONJUNCTION ABOVE WITH STATING THE WORK ASSIGNMENTS CO TAD TIES THE CIVIL OF RALPH ACTION CIRCUMSTANCES RELATING TO THE NO UNDER PARKE DENY FLEFENC2ANTS TO THEIR ADMIT NEITHCSR NOR DENY BUT LEAVE PLALNTXFFS PROOT C4 NOT AND THE UPJOHN APPLLCAB2S OTHER THAN PARKE TO DEFENDANTS DAVIS CO CO 10 DEFENDANTS DENY 11 DEFENDANTS DENY 12 DEFENDANTS DENY COUNT II DEFENDANTS OR THE TO ACTIVITIES TO AND BY SUCH REFERENCE THROUGH 12 ANSWERS TO PARAGRAPH OF 1935 REFER DEFENDANTS DENY FLEFENDANTS DENY THAT MINIMUM CARRIED WAGE LAW DEFENDANTS THE AIR LABOR ORTHE STATE OF MICHIGAN ON BY INMATES OF INCORPORATE HEREOF OF COUNT EITHER HEREBY STATE STANDARDS ACT ARE APPLICABLE PRISON DENY COUWJ III DEFENDANTS ANSWERS TO PARAGRAPHS REFER TO AND BY THROUGH 12 DEFENDANTS DENY DEFENDANTS DENY DEFENDANTS DENY DSFEFLDTNTS DENY SUCH REFERENCE OF COUNT HEREOF HEREBY INCORPORATE 30 DNIEMANTS DCNY DEFENDANTS DENY DEFENDANTS DENY DEFENDANTS DENY DEFENDANTS DCNY COUNT IV RETER DEFENDANTS THROUGH 12 ANSWERS TO PARAGRAPHS CONSTITUTION TO AND BY SUCH TCFERENCE DEFENDANTS DENY DEFENDANTS DENY OF COUNT THE HEREBY HERCOF AMENDMENT TO THE 13TH INCORPORATE FEDERAL PROVIDES DUY ANY EXCEPT AS SERVITUDE SLAVERY NOR INVOLUNTARY SHALHHWVETHEOFL FOR CRIME VZHEREOT THE PUNISHMENT SHALL EX4 WITHIN THE UNITED STATES OF SUBJECT TO THEIR JURISDICTION ITNEITHER HAVE AS PLAINTIFFS THE STATE BEEN OF LAICHIGAN DULY THEY CONVICTED OF CRIMES AGAINST OF THE PEOPLE OF THE 13TH ARE NOT SUBJECT TO THE PROTECTION THAT WERE CONVICTEDL OF CRIMES AMENDMENT TO THE PURSUANT JACKSON TO THE LAWS PRISON CONTROLLED OF THE AS OF THE PUNISHMENT ACTIVITIES LAWS OF THE EXTENT WITHIN STATE STATE PLAINTIFFS OF MICHIGAN FOR THE COMMISSION THE PRISON OF MICHIGAN DEFENDANTS DENY DEFENDANTS DCNY AND ARE INCARCERATED IN OF SUCH CRIMES THEIR OUT UNDER COLOR WERE CARRIED DEFENDANTS WHEREFORE DISMISSED WITH DENY DERENDANTS PREJUDICE ASK THAT PLAINTIFFS AND WITH COMPLAINT BE COSTS LII ELEANOR ERNEST JAMES WADSWORTH HUTZEL BROOKS MAX FIBER JOHN RICE DUANE GROSS WATERS FLORENCE CRANE JOSOPH AND ONS HARRISON ROBERT COTTON FANCY BY KELLEY FRANK LOMON BIENENFELD ATTORNEY SSISTFLT ATTORNEY GENERAL ATTORNEY ROR BEFENDAFLTS STORY OFFICE OTTAWA MIEHTGFL LANSING SEVEN BUILDING 525 TELEPHONE DATED FEBRUARY 1970 517 373ILYB GENERAL SCIIV UJZT2C T312 1AR21114 MIT R8137U VTAV2S CV P1 IR C0L37V CIVIL ACATION NO CC RP70 TC CT GJY G20R17 P2L R3R02 RCC2 1LIQAT2KIAJC DIN J0R1 E8 RR 2R DSITSVID IFS NO CCC2UY 5CR ETC TT D7I7 12 A3SYPT OT ZC CCGSCRI COUUTY ILT1 IHC CF TLM YTL TJPJ OH 11C FACSLT J2 KY CZ TX IC BRLVVJ 2HS JQ CT2Y VV2 UPJOHN FL IX XP II TWX 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RECORD OFFICE AND TO INMATE ACCOUNTING DEPUTY WARDENS OFFICE OFICE SUCH OTHER DEPARTMENTS REUESTS BY SUPERVISORS TO THE FOMNIS PROVIDED AS ARC DESIGNATED REMOVE AND ARE SUBIOCT INMATES TO THE TRAIN BY THEIR APPROVAL THE DIRECTOR ASSIGNMENT OF THE DIRECTOR OF TREATMENT WILL OF BE MADE ON TREATMENT 5100 RN THC FLR MEN WARDEN DHDPLNARY FOR TRUSTY VRY LIME REMOVE FRAN OF WE LABOR REASONS BY SO NOTIFYING OR CUSTODICIL CLASSICATIOIJ DIVISION CIY OR HIS REPRESONICRILVE INMATES IRANSFERRED THE TO ASSIGN CR1 PQQI DIVISION TRUSTY WI C4 BE SCREENED AMMEDIALCY FRETS DISC THAT WORK TO RET MEN 16 CLASSFICATION OF ASSIGNMENT TJOTE THE TRUSTY CHANCES DIVISION FROM ANY ASSIGNMENT REOSONS WHET RECLASSIFFRALION TO THIS FAR TO ACTION TAKEN THE THE IS AS WARDEN IHENT DISTRIBUTION FRONT BY FICO LION THE NOTIFYING THE BE TADE BY SHALL OR 7157 BY THE TRUSTY THE TRUSTY DIVISION TO DISTRIBUTIOH OR RETURN MORE SUITABLE BE PREPARED WILL HI MAIN USED BY INMATES 5200 DEPUTY INSIDE REPRESENTATIVE AFFECTED ASSIGNMENT PR THE DIVISION KROPP CLASSIF WORDCN LABOR POOL MAY REMOVE MEN PRISON FOR DISCIPLINARY WARDEN 123163 SI COMMITTEE REFARAL ASSTGNMENT TRUSTY GEORGE REVISED CIA NEEDS DISTRIBUTION DEPVTY IS COMMITTEE THEY HOVE THE INITIA THE QUIP DIRECTOR MASTER OLD SUCH BLOCK HALL MAY MAKE UPPER PENINSULA FOR IHROU CHANNELLED RECLCSSFICAHIORL DIRECTOR AND SRAVIDOD ICCTICNI OKO BE SECURIHY TO HOWL DSOI UT GIL FOR CLASZIFKOHORI IJIVISTON TRUSTY POOL OF HH REPLACEMENT OF CANDIDATES LIST 110 MUST COMMITTEE CLASSIRICAFION MSNNUM COD MEDIUM FOR TO LIDS WISHING THE TRUSTY DIVISION DAILY THESE RILE TABOR TRUSLY DIYISION SELECTION UNSWTVD RECLASSIFICORON SUPERVISOR THE IF ANY KNIOLE RETIRN OF THESE OTHER OR PLACEMENT BY THE TRUSTY DIVISON SHOULD BE OR CUSTODIAL REFERRED FOR FEB FILED UNITED 12 STATES FOR 1970 DISTRICT COURT THS OF MICHIGAN EASTERN DISTRICT SOUTHERN DIVISION SIM CALVIN ROGERS LEE FRANK WALTER GEORGE MILLS RICHARD ALLEN LEE WILLIAMS BILLY SLAGER PETER WALKER CLEMONT DEDEAUX BOYD LEE WILLIAM CLEARY ORDELL VILBURN FRED WILLIAMS HOLNAGEL HERBERT KENNETH INMAN BENNY SPELLS ORCEAN DAVIS BAILEY RAYMOND JERRY MACK BOYD KELTON THOMAS LORD RALPH WATSON CHESTER MCGHEE VERNON PHILLIP SAWICICI RALPH WARNER AND MEVIS CASE JUDGE P1EINTFF NO FREEMAN AFFIDAVIT OF 31172 IN PLAINTIFFS FOR SUMMARY VS CO SUPPORT MOTION JUDCMENT MICHIGAN PARKE DAVIS AND THE UPJOHN CORPORATION DELAWARE CORPORATION CO DAFANDANTS STATE COUNTY MICHIGAN OF AS OF JACKSON HOYD SLAGER BEING FIRST DULY SWORN DEPOSES AND SAYS AS FOLLOWS OF THE IS MADE UPON THE BASIS AFFIDAVIT MATTERS AND EFFIANT OF THE FOLLOWING OF TO THE MATTERS STATED HEREIN TO TESTIFY THIS KNOWLEDGE COMPETENT PERSONAL IS HEREIN AND HAS IS ONE OF THE NAMED PLAINTIFFS AFFIANT EHC CONSTRUCTED UPJOHN BY BUILDING WORKED IN THE DRUG CLINIC FAMILIAR HA IS FURTHER SOUTHERN MICHIGAN OF STATE PRISON THE AT OF SAID AND OTHER INMATES PLAINTIFFS NAMED WITH THE REMAINING THE CLINIC CLINIC AS SELL AS IN IN THE SAID WORKED WHO PRISON CO CONSTRUCTED BY THE PARKE DAVIS CA OL THE HOURS HOURS WHICH HE WORKED WERE IN EXCESS THE DETAIL IN FACT JOB AND EGULAR CIVILIAN WORKED BY ANYONE ON AND ALLOWED TO HIS CELL FROM TO BE RELEASED UPON WHICH HE WASABLE AND 4T4SARN TILL FROM 1030PM REMEIN IN THE CLINIC PROPER READ SEVEN DAYS PER WEEK HOURS WERE EFFECTIVE THAT SEID DETAILED THE INCLUDING HOLIDAYS OF UNDER THE SUPERVISION OTHERS WORKED DIRECTLY THAT HE AND PERSONALLY EMPLOYEES OF THE DRUG COMPANIES CIVILIAN OF THE CIVILIAN EMPLOYEES WHOS SUPERVISION WAS UNDOR THE DIRECT HESSIAR WILL AND WILLIAM HE AND IN THE REPRBEEFLTATIVS INCLUDE THE CXINIA UXEMP‰S FOLLOWING DRAWING BLOOD SAMPLES TO SEPARATE CENTRIFUGE ACCURATELY AND TAKING TYPING OF RUNNING THEM THROUGH PHSMA FROM RED CELLS ARID FCR VIALS THB LABELS ANALYZING WORK WHICH WAS DONE THE SAMPLES URINE AND BLOOD PRESSURE TAKING THE TEMPERETURE USED IN DRUG TESTS PERSONS BEING SND ADMINISTERING ELECTROENCEPHALOYRSMS KEEPING RECORDS OF IMPORTANT DISPENSING THE OF THOSE BODILY FUNCTIONS TESTED DRUGS TO BE FROM AUGUST 1964 WORKED IN THE UPJOHN CLINIC OF THE FUNCTION DURING WHICH TIME HE PERFORMED UNTIL JULY 1967 DR LLOYD UF UNDER THE DIRECT SUPERVISION ACTING PHARMACIST AND THE DOCTORS WHO HESSIER WILLIAM WILLY LEZOTTE RALPH THE VARIOUS PROTOCOLS STUDIES TO SUPERVISE CAME TO THE CLINIC MONITORS OF WHICH THEY WERE THE AFFISFLT THE FOREGOING SPAN CONTAINED IN THAT DURING THE TIME IT WAS OF PHARMACIST THE IN CAPACITY PARAGRAPH AND WHILE ACTING RECORDS IN ACCURATE MAINTAIN MEDICATIONS TO DISPENSE HIS DUTIES KEEP ACCURATE OF THE MEDICATIONS THE DISPENSING CONJUNCTION WITH MEDITATIONS AND ACNDTNG OF RECORDS CONCERNING THE RECEIVING AND ELSA END THE PRISON CLINIC IN KALAMAZOO BETWEEN THE COMPANY FOR USED EMERGENCYS OF THE RESTRICTED DRUGS TO KEEP AN INVENTORY SET FORTH IN THAT DURING THE TIME PERIOD OF THE CIVIL SOMETIMES IN THE PRESENCE AFFIANTI ABSENCE NUMBER SI IN THEIR OF THE DRUG COMPANY BUT GENERALLY OF IAN ACCORDING TO THE REQUIREFLEFLTS THE DID DISPENSE THE VARIOUS DRUGS OF LISTING PARTIAL AND THOT THE STUDY BEING CONDUCTED FOLLOW SO DISPENSEDIS2S DRUGS MEDICATIONS PARAI EMPJ MEESURIN METOPIRONE SYNALAR TPPICEL MACITO ACSTATS TOPICAL NEOMSDROL ACETATE TOPICAL THORAZINE PHENO LIBRIURFI CI EQUANIL DARVON 65 HEPARIRI FLILANTIN CAFERGFLT TOTRACYCLFLFLFLE HENEDRYL DEXADRINE LINCOCIN PANALBA ELRINASE PAMINE AFFIANT WAS ABOVE DESIGNATED MEDICATIONS THE TO ADDITION THE UPJOHN THAT IN DRUGS THAT WERE KNOWN ONLY BY TO DISPENSE REQUITED ALSO U22020 ETC COMPANYS OF WORK BY IN THE CO NAME EG PLACED IN AFFIANT MOTHOD FOLLOWING THE JUNE OF 1964 STATE PRISON OF WHILE THE UPJOHN WORKING IN SOUTHERN MICHIGAN AS THE CLINIC FOR MAIN HALL PURPOSES OFFICE THE COUNT CLERK ON OF AUGHT SHIFT AFFIART WAS OFFERED IN MEDICAL RASEARCH CLINIC THE UPJOHN OF THE PRISON AND REQUESTED TEAS WAS TAKEN THAT RALPH PRISON THE TH BEFORE AFTER JOHN OUTZ WITH CLASSIFICATION AND THE IN FORE AD INTERVIEW MR DIRECTOR PART OF JULY COMMITTEE NO OBJECTION HAD THEN CLINIC THE THAT PRISON CLASSIFICATION OFFICIALS AWARE OF AN OPENING LOCATED INSIDE THE WALLS CLERK WILLY MADE TO THE NOW RETIRED SCHRNEIGS INMATE WAS GRANTED AN INTERVIEW MR MINISTRATOR REQUEST BY THE THON MADE OR AND TO THE IT 1964 WAS DECIDED TRANSFER AND IT APPRNVAD PROVIDED THAT STAYED ON TO HELP BREAK ANOTHER INMATEIN ON THE MAIN HAITI OFFICE JOB THIS WAS DONE AND IN AUGUST OF 1964 GL GO TO WORK AT AT THE JULY 1967 THE CLINIC CHANGE ORDER WAS SIGNED ASSIGNMENT LIRECTOR HANSEN WORK AN OF TREATMENT INDICATING UN AUGUST 19 UPJOHN CLINIC ON FULL TIME BASIS THAT BY MR WAS TO 1964 WHICH CONTXNUED STARTED UNTILL 10 THAT UNTILL JULY 1967 WAS UNDER THE IMPRESSION THAT SHOULD WITHOUT REQUESTING THAT QUIT MY JOB AT THE CLINIC BE ALLOWED TO DOXFZOM THA PRISON OFFICIALS WOULD BE PLACED IN AT THAT TIME SOLITARY WAS INFORMED TO THE CONTRARY END IMMEDIATELY QUIT 19 FEB SUBSCRIBED 1970 AND SWORN TO BEFORE ME THIS DAY OF IN AND THE TARY FT6LIC COUNTY OF JACKSON MICHIGAN MY COMMISSION PAUL EXPIRES LADOW NOTARY PUBLIC MY COMMISSION JACKSON EXPIRES COUNTY MICH MMCH 10 19TH FILED FEB UNITED 16 1970 DIST STATES FOR THE COURT EASTERN DTSTMCT OF MICHIGAN SOUTHERN DIVISION SIMS RICHARD ALLEN FRANK LEE WILLIAMS ROGERS BILLY WALTER LEE BOYD SLAGER PETER GEORGE MILLS LEE WALKER CLEMONT DEDEAUX ORDELL VILI3URN WILLIAM CLEARY 1IERJ3ERT FRED UOLNAGETJ WILLIAMS BENNY SPELLS KENNETH INMAN RAYMOND ORCEAN DAVIS BAILEY JERRY MACX BOYD KELTON THOMAS CASE NO 31172 LORD RAL WATSON CHESTER PHILLIP SAWICKI MOGHEE VERNON JUDGE FREEMAN MEVIS AND RALPH WARNER PLAINTIFFS AFFIDAVIT IN SUPPORT OF PLAINTIFFS MOTION FOR CALVIN VS SUW4ARYJUDGMENT CO PARKE DAVIS MICHIGAN CORPORATION AND THE UPJOHN DELAWARE CORPORATION CO DEFENDANTS STATE OF MICHIGAN JACKSON COUNTY OF ZN CHESTER SAWICKQ SAYS AS FOLLOWS BEING THIS AFFIDAVIT PERSONAL KNOWLEDGE OF AFFIANT AFFIANT ISCOMPETENT TO TESTIFY FIRST DULY SWORN DEPOSES AND IS MADE UPON THE BASIS OF THE OF THE FOLLOWING MATTERS AND TO THE MATTERS STATED HEREIN AFFIANT IS ONE OF THE NAMED PLAINTIFFS HEREIN AND HAS WORKED IN THE DRUG CLINIC CONSTRUCTED BY THE UPJOHN BUILDING CC AT THE STATE PRISON OF SOUTHERN MICHIGAN FURTHER HE IS FAMILIAR NTH THE REMAINING NAMED PLAINTIFFS AND OTHER INMATES OF SAID PRISON WHO WORKED IN THE SAID CLINIC AS WELL AS IN THE CLINIC CONSTRUCTED BY THE PARKE DAVIS CO THE HOURS WHICH HE WORKED WERE COMPARABLE TO WOULD BE WORKED BY ANYONE ON REGULAR CIVILIANJOB AND IN FACT SOMETIMES HE WORKED SEVEN WEEK THE DAYS TIME WORKED EAQH DAYVARIOD FROM FEW HOURS UP TO SIXTEEN 16 HOURO IN HOUR PORIOD TWENTYFOUR THOSE WHICH 24 OZCSS LEITSON CEAN SEGAR HART PC ISIS OHIR FLINT OF CIVILIAN CRT TQWLTH RSY I4ICH STREKT 48502 FL TLAE II LIE AND OTHERS WORKED DIRECTLY EMPLOYEES OF THE DRUG COMPANIES UNDER THE SUPERVISION DONE IN THE REPRESENTATIVE EXAMPLES OF THE WORK WHICH THE CLINICS INCLUDE FOLLOWING WAS DRAWING BLOOD SAMPLES AND RUNNING THEM THROUGH TO SEPARATE PLASMA FROM RED CELLS CENTRIFUGE ACCURATELY TAKING LABELS TYPING AND ANALYZING FOR URINE VIALS SAMPLES AND BLOOD PRESSURE USED IN DRUG TESTS THE TAKING THOSE PERSONS BEING ADMINISTERING ELECTROCARDIOGRAMS OF AND ELECTROENCEPHALOGRAMS XEEPING RECORDS OF IMPORTANT BODILY FUNCTIONS DID SO HE AND OTHERS WORKING AT THE CLINICS OF THE ORDERED DO TO SO BY REPRESENTATIVES BECAUSE THEY WERE ORDERED TO WOULD BE OF CORRECTIONS JUST THEY DEPARTNLENT REFUSAL TO WORK AS WORK IN ANY OTHER PRISON INDUSTRY AND SUCH TO THETA WOULD HAVE RESULTED IN PENALTIES DIRECTLY UNDER THE CIRCUMSTANCES CLEARLY WAS COERCION AND THREAT MPLIED IF NOT EXPRESSLY STATED EXAMPLES OF THE DRUG TESTED IN CLINICS SAID ARE LB DILAHTIFL CHIOROMYCETIN PONSTEL BENADRYL ALBUSPAN ZIXNBODRYL FEB SUBSCRIBED LAW ORFIC EITSON DEAN DEAN HART DRRAOIT LTNR PC ANESY MICIT4J3 61970 DAY OF AND SWORN TO BEFORE ME THIS NOTARY GENESEE COUNTY MICHIGAN MY COMMISSION EXPIRES PAUL LADOW NOTARY PUBLIC MY CCMMISSIPN JACKSON COUNTY MKH EXPIRES MARCH 10 ISIS PUBLIC FEB FILED 16 1970 COURT DTSTRICT FOR THE OR MICHIGAN EASTERN DTSTRIC SOUTHERN XVXSION UNFLYED CALVIN STATTHS ALLEN OJ44 WALTER LEE WILLIAMS ROGERS BILLY PETER GEORGE MILLS BOYD SLACER LEE REMONT DEDEAUX LEE WATV77TH WILLVAT4 CL2ATRY ORDELL VUSUFLN FRED HOLNAGEL HERBERT WILLIAMS KENNETH INMAN BENNY SPELLS RAYMOND ORCEAN DAVIS DAILEY THOMAS JERRY MACK BOYD KELTON LORD RALPH WATSON CFESTER PHILLIP MOGHEE VERNON SAWICKI NEVIS AND RALPH II WARNER PLAINTIFFS VS NO CASE JUDGE 31172 FREEMAN SUPPORT OF MOTION FOR SUMMARYJUDGMENT IN AFFIDAVIT PLAINTIFFS CO PARKE DAVIS MICHIGAN CORPORATION AND THE UPJOHNCO DELAWARE CORPORATION DEFENDANTS OF MICHIGAN JACKSON COUNTY OF STATE CLEMONT SS DEDEAUX BEING FIRST SWORN DEPOSES DULY AND SAYS AS AFFIDAVIT THIS OF AFFIANT PERSONAL KNOWLEDGE TO AFFIANT TESTIFY ISCONIPETENT IS MADE UPON THE BASIS OF THE OF THE FOLLOWING MATTERS AND TO THE MATTERS STATED HEREIN HEREIN AND IS AFFIANT ONE OF THE NARNOD PLAINTIFFS THE UPJOHN CLINIC CONSTRUCTED WORKED IN THE BUILDING BY HAS DRUG HE IS OF FURTHER THE STATE PRISON SOUTHERN MICHIGAN AT CO AND OTHER INMATES WITH THE REMAINING NAMED PLAINTIFFS FAMILIAR AS WELL AS IN THE OF SAID PRISON WHO WORKED IN THE SAID CLINIC CLINIC CONSTRUCTED BY THE PARKE DAVIS CO THE HOURS WHICH HO WORKED WERE COMPARABLETO OB REGULAR CIVILIAN THOSE WHICH WOULD BE WORKED BY ANYONE ON WEEK THE SOMETIMES HE WORKED SEVEN DAYS AND IN FACT FROM LEW TO SIXTEEN TIME WORJWD CACH HOUR HOURB IN PERIOD TWENTYTOUR 24 LAW OFFWES LEITEON AN HARTPC OF CIVILIAN HOUR HE AND OTHERS WORKED DIRECTLY EMPLOYEES OF THE DRUG COMPANIES UNDER 16 THE SUPERVISION ROWRB FLINT MI SL1EC3I 44 DONE IN REPRESENTATIVE EXAMPLES OF THE WORK WHICH THE CLINICS INCLUDE THE FOLLOWING AND RUNNING THEM THROUGH PLASMA FROM RED CELLS DRAWING BLOOD SAMPLES TO SEPARATE CENTRIFUGE ACCURATELY TAKING WAS TYPING LABELS FOR URINE AND ANALYZING VIALS SAMPLES AND BLOOD PRESSURE USED IN DRUG TESTS TAKING THE THOSE PERSONS BEING ADMINISTERING CLECTROCARDIOGRANIS OF AND ELECTROENCEPHALOGRAMS KEEPING RECORDS OF IMPORTANT FUNCTIONS BODILY DID SO HE AND OTHERS WORKING AT THE CLINICS OF THE BECAUSE THEY WERE ORDERED TO DO SO BY REPRESENTATIVES ORDERED TO WOULD BE OF CORRECTIONS JUST THEY DEPARTMENT REFUSAL TO WORK AS WORK IN ANY OTHER PRISON INDUSTRY AND TO THEM AND SUCH WOULD HAVE RESULTED IN PENALTIES DIRECTLY WAS UNDER THE CIRCUMSTANCES CLEARLY COERCION AND THREAT STATED IF NOTEXPRESSLY IMPLIED ARE EXAMPLES IN OF THEDRUGSTESTED CLINICS SAID FLILANTIN CHOROMYCETIN PONSTEL BENADRYL ALBUSPAN KNBODRYL RI1 AIJ4A FID2N FEB AND SWORN TO BEFORE II II FLTST2F SUBSCRIBED J1 FI JR FLI 1910 DAY OF ME THIS NOTARY LAWQFFJC LEIT5ON DEAN DEAN SEGAS HAWV SC BTTAOIY COUNTY EXPIRES MY COMMISSION PAUL LADOW NOTA PUBLIC BFLQCCT COMMISSION VUNT 1DEC11 AFLFL COUNTY MICH EXPIWS MAWH 10 1973 PUBLIC UNITED STATES OF AMERICA THE DISTRICT COURT OF THE UNITED STATES FOR THE EASTERN DISTRICT CF MICHIGAN SOUTHEHN DIVISION RICHARD ALLEN CALVIN SIMS LEE FRANK ROGERS BILLY WALTER LEE WILLIAMS BOYD STAGER PETER GEORGE LEE WALKER CLEMONT MILLS DEDEAUX ORDELL VILBURN WILLIAM CLEARY HERBERT WILLIAMS FRED HOLNAGEL BENNY SPELLS KENNETH INMAN OIWEAN RAYMOND BAILEY JERRY MACK BOYD KELTON DAVIS THOMAS LORD RALPH WATSON PHILLIP CHESTER SAWICKI MAGHEE AND VERNON MEVIS CASE NO 31172 PLAINTIFFS VS DAVIS COMPANY MICHIGAN CORPORATION AND DELAWARE THE UPJOHN PARKE CO CORPORATION DEFENDANTS ANSWERS OF TUE UPJOHN COMPANY TO ADDITIONAL INTERROGATOFLIES NOW COMES THE AND ANSWERING AS L‰T THE NAME AND ADDRESS TRIAL THE STATES TRIAL IS INTERROGATORY STATE THE THE OF EVERY WITNESS WHO YOU MAY RELY ON CAUSE OF THIS NO THE THE WITNESSES IN INTERROGATORIESL NO ANSWER TO IF ADDITIONAL FOLLOWS INTERROGATORY AT PLAINTIFFS DELAWARE CORPCRATION COMPANY UPJOHN UPJOHN COMPANY MAY CALL AT TRIAL HELD HAVE NOT BEEN DETERMINED NO SUBJECT PRECEDING MATTER OF THE TESTIMONY OF EACH WITNESS NAMED QUESTION ANSWER TO NO THE GENCRAL SUBJECT MATTER OF TESTIMONY WHICH THE UPJOHN AND PROCEDURES THE OF THE JACKSON KNOWLEDGE CLINIC WORKINGS OPERATED BY NO NAME AND ADDRESS THE PRISON BE THE COMPANY UPJOHN INTERIIOGATORY LIST WOULD PROBABLY COMPANY WOULD PRESENT OF THE WORKINGS ANSWER TO UPJOHN OF EACH OF YOUR EMPLOYEES AND PROCEDURES WHO HAVE OF YOUR PRISON CLINIC NO PERSONNEL MOST FAMILIAR WITH WORKINQSAND PROCEDURES MD AB HERBERT SCHWEEM 1703 POOLE DRIVE 49201 JACKSON MICHIGAN RALPH WILLY 5895 SOUTH JACKSON JACKSON MICHIGAN THE NAME AND ADDRESS KNOWLEDGE OF THE ORIGINAL MENT OF OUR CLINIC ANSWER TO HV 00936 MD DEMISSIANOS LITTLE DRIVE APT 302A 49007 KALAMAZOO MICHIGAN AT THE NEGOTIATIONS LEADING WHO HAVE TO THE ESTABLISH PRISON NO GERARD THOMAS 7000 PORTAGE ROAD KALAMAZOO MICHIGAN RT ROAD 49203 CARL SCHLAGEL 301 HENRIETTA STREET KALAMAZOO MICHIGAN PARFET PORTAGE ROAD KALAMAZOO MICHIGAN 7000 DALE CHODOS PORTAGE ROAD KALAMAZOO MICHIGAN 7000 RS SCHRCIBCR PORGAGE ROAD KALAMAZOO MICHIGAN LEZOTTE ROMA CIL EXT VILLA CAPARRA CUAYNABC PUERTO RICO LLOYD CALLE 7000 00936 NO THE NAME AND ADDRESS WHO YOU HAVE MD 1230 OF EACH OF YOUR EMPLOYEES RALPH WILLY 5895 SOUTH JACKSON JACKSON MICHIGAN LIST LEZOTTE ROMA CIL EXT VILLA CAPARRA GUAYFLABO PUERTO RICO 49081 HAROLD UPJOHN 7000 PORTAGE ROAD KALAMAZOO MICHIGAN INTERROGATORY LLOYD CALLE NO INTERROGATORY LIST MD TREEHAVEN DRIVE KALAMAZOO MICHIGAN ROAD 49203 WILLIAM HESSLER 1112 WOODVIEW PORTAGE MICHIGAN VARLEY 2146 REASON OF TO BELIEVE ANY PERSON OTHER THAN YOUR EMPLOYEE HAS SUCH KNOWLEDGE ANSWER TO NO GUS HARRISON DIRECTOR OF CORRECTIONS LANSING MICHIGAN HAROLD JACKSON OSTER MICHIGAN DEAN WILLIAM HUBBARD OF MICHIGAN UNIVERSITY ANN ARBOR MICHIGAN INTERROGATORY STATE FOR THE MEDICAL SCHOOL NO NAME AND ADDRESS OF THE PERSON IN CHARGE OF PERSONNEL YOUR COMPANY ANSWER TO NO TURBEVILLE PORTAGE ROAD KALAMAZOO MICHIGAN 7000 INTERROGATORY WHAT IS PRISON THE NO PAY SCALE FOR CIVILIANS WHO ARE ENGAGED ANSWER TO DEFENDANT IN EMPLOYED BY YOU OUTSIDE THE DRUG TESTING NO THE UPJOHN COMPANY OBJECTS TO NO THE BY UPJOHN COMPANY INTERROGATORY STATE OF MICHIGAN 55 COUNTY OF KALAMAZOO GERARD THOMAS DEPOSES THE AND UPJOHN STATES AS FOLLOWS THAT HE IS COMPANY THAT INTERROGATORAES TO THE BEST AND OF HIS THE HE HAS READ THE FOREGOING SUCH ANSWERS ARE ANSWERS DAY ME OF 1970 NOTARY PUBLICTCLYN MY COMMISSION EXPIREST MICHIGAN 397 TO TRUE AND CORRECT KNOWLEDGE AND BELIEF AND SWORN TO BEFORE THIS SWORNJ CORPORATION 14 SUBSCRIBED DULY VICE PRCSIDENT SECRETARY AND GENERAL COUNSEL OF DEFENDANT DELAWARE THAT FIRST BEING UNITED STATES OF ADVRNRICA STATES OF THE UNITED DISTRICT COURT THE OF MICHIGAN FOR THE EASTERN DISTRICT SOUTHERN DIVISION LII RICHARD ALLEN CALVIN SIMS LEE FRANK ROGERS HILLY WALTER LEE WILLIAMS PETER GSORGE BOYD LEE WALKER CJ2EMONT MILTS DEPEAUX ORDELL VTLBEJRN CLRARY HERBERT WILLIAM FRED HOLNAGEL WILTIAMS KENNETH INMAN BENNY SPELLS ORCEAN BAILEY RAYMOND BOYD KELTON JERRY MACK DAVIS THOMAS LORD RALPH WATSON PIIELLIP CUESTER SAWICKI MEVIS MEGHEE AND VERNON SLAG CASE 4O S1172 PLAINTIFFS DAVIS COMPANY MICHIGAN CORPORATION AND DEAWARE THE UPJOHN PARKE CO CORPORATION DEFENDANTS AFFIDAVIT THE UPJOHN STATE IN SUPPORT OF ANSWERS OF COMPANY TO INTERROGATORIES OF MICHIGAN COUNTY 55 OF KALAMAZOO AND SAYS AS SWORN DEPOSES THAT UPJOHN COMPANY THAT HE IS DELAWARE HE COMPANY TO PLAINTIFFS OCTOBER 14 HAS FOLLOWS VICE PRESIDENT THE RETARY FIRST BEING GERARD THOMAS AND GENERAL DULY COUNSEL OF THE CORPORATION REVIEWED THE INTERROGATORIE ANSWERS OF THE WHICH UPJOHN ANSWERS ARE DATED 1968 THAT SUCH ANSWERS WERE AT THE TIME OF SUCH FILING TRUE TO THE BEST SUBSCRIBED AND INFORMATION PUBLIC MY COMMISSION 1970 7Z COUNTY EXPIRES KNOWLEDGE AND BELIEF SWORN TO BEFORE ME DAY OF II THIS NOTARY OF HIS MICHIGAN 97 81770 FILED STATES DISTRICT JURT FOR THE EASTEEN THIS TRICT OF MICIJI CAN SOUPHEIIN ORVISFON UNITED CALVIN SIMS ELI AL PLAINTIFFS CIVIL ACTION 31172 NO CO PARKE DAVIS AND THE UPJOHN COMPANY DEFENDANTS DEWENDANTS MOTION JUDGMENT OU COUNT NOW COME DEFENDANTS DAVIS WHEAT AND COMPANY BY THEIR SPENCER ND STONE OF THE IN GROUND THAT THEIR THIS AFFIDAVITS MOVE THIS ARE MOTION IS OF ISSUC AS BASED KROPP MOTION FOR TO RULE 56 PURSUANT SUMMARY ON THE COMPLAINT TQ MATERIAL ANY MR FACT OF LAW MATTER AND THE PLEADINGS AND PADDOCK CANFIELD AS UPON THE PARKE DYKEMA TO ENTER THE TO JUDGMCNT OF WARDEN GEORGE SUPPORT OF OEFENDANTS COURT PROCEDURE NO GENUINE ENTITLED ATTORNEYS MILLER AND FAVOR ON COUNT THERE IS AND DEFENDANTS RESPOCTIVE RULES OF CIVIL COMPANY AND UPJOHN TIIC TRIGC RESPECTFULLY FEDERAL JUDGMENT COODNOW FOR SUMMARY OF COTLATNT RALPH WILLY IN SUMMARY JUDGMENT DYKEMA WHEAT FLY SPENCER OTINOW TRIGG CAROL1 TIMOTHY FOR THE FINN AND INDIVIDUALLY 2700 PCNOBOT BUILDING 48226 DETROIT MICHIGAN 9636040 ATTORNEYS FOR THE DEFENDANT THE UPJOHN COMPANY MTTTER 2500 DATED TJU CANFI DO LIOI 96364 103A BANK HVHIGAN ATTORNEY THE PADDOCK DAV FOI THE AND STONE PRUNT 48226 BUILDING DEFENDANT CMPANY FI1EC STATES EAS ITHUTED FOT TIJ SOUTUTXN CO DISTAICT CQUTT AICNITAN DISTAICT DIVISION ALUFN FAANX STHS RICIJAAD RALTE BILLY LET WILLIAMS OGELSJ PETEJA GEOAGE MILLS LEE BOYD LEE WALKE4 CLEMONT ODELL VILBU4N WILLIAM CLSAH ITEKFLE47 WILLIAMS IOLFLAGEL BRENT SPELU ZENNEFLI INMAN SAYMOND MACK DAILEY O4CRAN FLAWS BOYD KELTON TO2VTAS II LOAD SAWICKI PUILLIP WATSOT CITESTEA CALVFLT D1 LAGI JSY MCCF ANO V32ANON MEVT PLMNTIFFS ACTION CLVII COMPANY DAVLS CORPOR DUICTV MICN 31172 AN UPJQBN COMPANY TIU AND HO COVPORATLON DEFCNDANT DEFENDANTS MOTZON FLIT UMMA SUDG TO COUNT 1K MENT 17ITU NOW COME DCTANNT FARVO UPJOHN AD CONIRANY BY THEIR STENO AND DYKEINA MOVE OR SUMRNAZY COMPLAINT 1YH JUDG SPENCER MILLER GOODN CANFLELD PADDOCK TRI AND RESPECTFLDLY WITH RESPECT TO COUNT UT OF PLAINTIFFS ON THE GROUNDS THAT THERE AND THAT 4EFCNCLANTS ATTQ RESPECTIVE COMPANY AND THE DAVIS ARC CNTLTTED IS NO TO JUDGRNCNT LSS AMENDED AS TO ANY MATERIAL OF LAW FACT THIS TILED IN TBIS MOTION ON THE IS AND OTHEE DOCUNIONTS PHADING CAUSE MILLER DY CANFIELD 4LPRANN ATTORNEYS PADDOCK AND STONE VOPPC FOR DEFENDANT PARKE DAVIS COMPAAY 2500 THTRCIT DETOIT FLANK MICHIGAN AND TRUST BUILDING 43226 9636420 DYKEINA WHEAT SPENCER GOODNSW TIMC4TY FIR THY UPJOHN COMPANY 2700 PENOBSCCT T3ULLDLTNZ DETROIT MICHI 48226 9636040 ATT DATECL AUGUST 1970 TRIGG STATES DISTRICT COURT ROR THE EASTERN DISTRICT OF MICI4IGAN UNITED SOUTHERN DIVISION TMS RICHARD ALLEN ROGERS BILLY LEE WILLTAMS CALVIN FRANK WALTER EOYDSLAGER MILLS LEE WALKER GLEMONT DEDEAUX ORDELL VITJBURN WILLIAM CLEARLY PETER LEE Y4ERBER FRED IIOLNAGEL WILLIAMS BEENY SPELLS KENNETH INMAN RAYMOND ORCEAN DAVIS JERRY MACK BAILEY BOYD KELT ON THOMAS LORD RALPH WATSON CHESTER SAWICKI P1FILLIP MCGIIEE AND MEWS VERNON PLAINTIFFS ACTION CIVIL COMPANY PARKE DAVIS CORPORATION AND NO 31172 MICHIGAN THE UPJOHN COMPANY DELAWARE CORPORATION DEFENDANTS DEFENDANTS MOTION FOR SUMMARY JUDG MENT WITH RESPECT TO COUNT IV NOWCOME UPJOHN COMPANY THY THEIR AND STONE AND DYKERNA MOVE FOR SUMMARY COMPLAINT ON THE DEFENDANTS PARKE AND THAT DEFENDANTS WHEAT SPENCER JUDGVNENT WITH RESPECT ARE ENLITLED TO COMPANY ATTORNEYS MILLER RESPECTIVE GROUNDS THAT THERE DAVIS IS GOODNOW TO GAUNT IV TRIGG MATTER AS OF PADDOCK AND RESPECTFULLY OF PLAINTIFFS NO GENUINE ISSUE JUDGMENT AS CANFIELD AND THE TO ANY LAW AMENDED MATERIAL FACT THIS FILED IN THIS MOTION IS BASED ON THE PLEADINGS AND OTHER DOCUMENTS CAUSE MILLER GANFIELD 77 BY ATTORNEYS PADDOCK AND STDNE FOR DEFENDANT PARKE DAVIS GONIPANY 2500 DETROIT DETROIT BANK AND TRUST BUILDING MICHIGAN 48226 9636420 DYKEMA WHEAT SPENCER BY GOODNOW TIMOTHY TC CARROLL ATTORNEYS FOR THE UPJOHN COMPANY 2700 PENOBSEOT BUILDING DETROIT MICHIGAN 9636040 DATED AUGUST 1970 48226 TRIGG 81770 FI1ED EA STATGS USTAICT DIST2ICT UNITED ROD TTTE OUTICXU SI7 CALVIPI V7 4ICHADD ALT PT LLY OOH1T COU4T ZFLC1YIGA DIVISION TIC FZA ECYL SIACED PETE GEO2G MILLS LEE WAUF4 DEDEAUX PR IS VNNUAT VZILLTAM CLRA ZX TEI BED PA ED FLOLTHTAC2TI VILLIAMS CL22 ENN1TH ITAAN SINUS NT TAXTJ2Y DOYD OAGYTAN DAVIS AAYMOND ST DY MACI TTOMAS II IJOAD RALPH SAWICTN PHILLI WATSON CFESTE M3 AND VI2ANON PLAINTIFFS VS CIVIL DAVFL COMPANY UPJOHN ANC DELAWARE CORPFLRATION PAZUCIZ FL COVORTTTION NO ACTION 31172 MICBIGAN COMPA2Y DCFENDANTS AFFIDAVIT GEO OF X7AFLDEN K2SJ2 STATE OF MICHIGAN SA COUNTY 07 JACISON RROPP GEORGE AFTER FIRST BEING DULY SWORN AND CLEPOAES SAYS AS FOLLOWS THAT HE L4ICIGAN HI CKSON FEBRUARY THAT YEA 1Q64 17 RLEN WARDEN OF THE STATE 4000 COOPR PRISON HAS BEEN WARDEN SINCE IS MT FOR SOUTBORRI MIDIGAR AN THAT 1963 ST II PRISON NARIE THIS AFFIDAVTT APPLY TO THE THAT WITHIN THE PRISON AND NA HEAD OF IS THAT HE HAS VARIOUS PRISON OF TREATMENT MENT AND DIRECTION ALL THE CHIEF IS IRSTTTUTION TFLNTITUTIORAL OFFICERS ONE SUCH OFFICER IS OFFICER IN THEIR WITHIN RESPONSIBLE EMPLOYED IN AND HAS THE DAY TO DAY RAPONAIBLLITY INTNATES OFFICER OPERATIONS OTHER INSTITUTIONAL AU OF HE AS THE CHIEF THAT DIRECTOR WARDEN RESPECTIVE HIM DIRECTLY TO THE POSITION OF TASKS THE OF PROPER ASSIGN STUDY AND RECREATION THAT ASSISTANCE OF OF ININATC TO THEIR THE PRISON RESEARCH CLASS IFICATIO XCSPCETIVC ACTING WITH THE CONMILTTEE MAKES EACH AND EVERY ASS TANKS WITHIN THE PRISON LAUNDRY THE PRLNON HOSPITAL THS ANN SUCH AS ASSIGNMENTS TO PARKE DAVL AND UPJOHN CLINICS THAT DIRECTOR TRCATN OF THE DIRECTOR OF ZNMISTRATIVE TREATMENT IS OR CUSTODIAL IN BINDING MAKING SUCH ASSIZNMENVS THE DECISION IN ALL INSTANCES REASONS SUCH DECISION UNLESS IS FOR OF THE AD SECVRITY RESCINDED BY THE INSIDE DEPUTY WARDEN THAT THE PRISON NO SUPERVISOR OR HEAD OF ANY HAS THE POWER OR AUTHORITY TO HAVE AN INMATE WITHIN PLACED ON HIS ASS TGNHNENT THAT SER OR DIRECTORS CLAGSIFICATJO COMMITTEE 10 PARKE C4IHERS DAVIS LA AND BOEN RCQUCOVS FOR PARTICULAR OF THE ASS IGNNIENT OR THE BIRECTOR DO FROM ARE FREQUENTLY RECEIVED OF TRC THAT SUCH REQUESTS HTIVE UPJOHN RESEARCH CLINICS INMATES AND BEEN RECEIVED SOME HAVE BEEN THE BY VARIOU THE FRON THE GRANTED AND II THAT THE DKECTOR AUTHORITY TO PLACE THE PARLCC LNNIATA AR DAVIS OR SUPERVISOR IZ RIND OF ASSURING RWPONSIBILLTY CONFLNES OF THE OF APFJ THE INSIDE OR THE WITHOUT THO APPROVAL ASSIGNMENT INVOLVED DEPUTY WARDEN HAS THE DAY TO DAY PROPER SECURITY TH THAT ASSISTANT THE AND CUSTODY OF INMATES WITHIN THE TASK AN INMATO DUTY TO DISAPPROVE CERTAIN DEPUTY WARDEN ACTING WITH THE INSIDE DEPUTY WARDEN HAS THE THE HOURS WORKED BY INMATES PARTKUJAR SSAI LNCLNCIING PRI 13 ASSISTANCE ASSIGNME ON PARTICULAR UPJOHN RESCAROB CLINIC OF THE DIRECTOR TH POWER AND OF TRCATRNENT AND AUTHORITY NRNO ON ANY ASS PERFORMS ON ASSIGNMENT HOURS TASKS ANDOR ITSELF IE1I AS THE AND THAT ASSI IN TO DIS IT IS HIS PROPER SITUATIOTNS THAT THE INSIDE APPROVED CERTAIN HOURS FOR LMNATES RESEARCH CITNIEN AND CERTAIN DEPUTY WARDEN HAS OY OCCASION TO THE ASSIGNED PARKE DAVIS DI AND UPJOHN TASKS TO BE PERFORZNCD BY LNRNATESON THESE ASSLGNTNONTS 15 CLINIC THAT WHILE ON THE PARKE AN INMATE ASSIGNMENT IS FLAVIS OR UPJOHN RCSCARCH SUBJECT TO CALL AT ANYTIME BY ANY INSTITUTIONAL ELK TAT 16 DAVIS CALLS THAT THE ADMINISTRATORS AND UPJOHN RESEARCH CLINIC AND RELCASC THE PCXRTICNLAR ASS IGNK2XENTS INMATE OR DIRECTORS OF THE MUST COMPLY WITH TO THE INSTITUTIONAL ALL PARKE SUCH OFFICIAL SUCH CALL 17 POWER TO RECLASSIFY ASSH THAT THO DIRECTOR AN INMATE AND RTACIN HIM TLLERCLQ CQ ANOTHER OF TREATMENT HAS THE AUTHORIT RCMOVIN HIM IRONI PARTICULAR 13 THAT THE DITECTOR MAKE SUCH RECASSIFICATLO AUTHORITY TO IIL VISOR OZ DTRECTOR OF THE PARTICULAR ASS OF TREATMENT HAS THE POWER AND OF THE WITHONT THE APPROVAL IG FROM WHICH THE SUPER INMATE IS RERNOV2D 19 FROM PARTICULAR VISOR OR DITECTOR SUPERVISOR THAT THE ASSIGNMENT WITHOUT THD KNOWLECLGE OR APPROVAL OF SUCH ASS AND UPJOHN APPROVAL TESOARCH PAIKE OF THE SUPER OF THE DAVIS DAVIS PARKE ASS IGNNTCNTS WITHOUT THE PRIOR KNOWLEDGE OR CLINIC OR UPJOHN PERNONNCL THAT THE SUPERVISORS PARKE REMOVED FROM OR DIRECTORS AND UPJOHN RESEARCH CL1N1CS AN ASSIGNMENT OF IN TRAY EQTCET THAT AN BE REMOVED INMATE 22 OF AND EVEN AGAINST TBE WISHES THAT INMATC HAVE BEEN 21 CHIDING OF THE OR 4IRECTOR 20 DAVIS DEPUTY WARDCN MAY REMOVE AN INMATE TREATMENT THAT ALL SUCH REQUASTS NIUST WHERE THEY NIAY BE GRANTED DENIED DIRECTED TO THE DIRECTOR OR RETURNED FOR FURTHER CLARIFTC4ION 23 THAT THERE ARE MATES ADOPTED BY THE CORRCCTLCNS PRISON THDNSTRIES TO THE 25 JLGINTIFS BY THE IN EJTHCT THE SCHEDULES PARKE THAT THE CORRECTIONS PA IU AT TLE COMMISSION PNRSUANT OF TO PAYMENT IJ OF THE TO IN FORMER ACT 24 TO AASIGNNINNT SCHEDULES EFFECT IN DAVIS SO ADOPTED INCLUDE DAILY RATES AND UPJOHN THE AND UPJOIN PARHEULAR TINC RENOAR CLINICS CROLITCD COMZAIS RESEARCH APPLIC TO THE ACCOIRAS WHILE PLAINT CLINICS WERE OF THE WEO ON BA ON THE SCHEDULES TB 26 PARKCUAVIS THE DAILY AND AND FLINT RESEARCH UPJOHN WITH 0T ARE WORKING CONDITIONS CLINTCS ACE SUPERIOR BECAUSE NEW AND TMCI1ITIE CLINICS TO THE THAN FOR ANPARABLE RZITES OTHER PCTSON TIVC C38SI NOTTEWHAT HIE RATES FCC DAILY RESEARCH UPJOHN 27 DAVIS TH ININTES BETTER TH PECSONN1 HSRE PATKE COINPNED AS HAVE URE RRETEC OT4B THE IN SPECIAZ AND ZECRCATICN NORE CONTACT NON ON WITH RC RETH RESCNRCH FACILITIES ASSIGNN ON CLIIIC TIR NENPRISRT THE AT OTHER PRISON SSAGNRTRNTN TH UPJ0HN HIGHLY CILNIEFI ARE DCS 29 IN THE TTNT TRKO TO BE AND TO THE REGARDED BY MOST MFLNY 1IN5C UPJOHN PARKE INR AS OF THE PCCAIC TDNTLTIEAOI DAVIS AS AND BEING CLTTSITICRT CONS OPORTUNITLES IONS CNRED BY THE 9N CORRECT SQ REQUEST BY ESSIGNRENTA PATTICULAR TRNIATCUI THAT ATY A8SI SI COT IN INSTTN 4NNR VOIUNT RECUENT REQTC AND TO THE CCS PARKT AVLS TRE UPJOHN MADE RESEARCH CLINICS 31 IS APE FOR TIONS UZISNN PUBLICATION OF THE SO THNT WHICH DE NENORANDUA TARKED EXHIBIT HE TITLDN FUNCTION THE AND ST PRISON IICHIU0 JJR3TIR NAYS ATTACHED CLAS CON THAT TFLICA THE IN EATTH1ISH HE TTACHCD CNORANDUN NARKCA PTLITTICFLTIOFL TCFCCT VS ANI HNS TH PARLE BEEN FLAV IN EFPECT GND AT UPJOHN ALL IR INCO CLLRUCS THE ACCUZIFLE TO NY BEST PACTS STATED IN THIS NFFFTDAVLT AXE TRUE AR TNCW1CD ST SIBSCRIB RFTP TO FLD OF BEFQ ILCHIZAN ME THIS DAY OF 59 UATY MY COUIIIISTIOA LIFRCENE GALJT NOTARY PUBLIC MY COMMISS FLE EXPIRES COUNTY MAY 27 MCH 1973 INITIAL INSIDE CLASS IFICATION SPSM CO RN IFJYI IT THE OF INW CT CORSIIT TO THE VAIOUS LE RS 12STJB OR CLASSIFICATION FLIR THE DIRECTION OF THE PREPARATION AND EXECUTION OF THE WORK INSTITUTIOI SSII RSS SHALL 1E TR OF THIS IN PROGRWZS ISTTIALCL THE DIRECTOR LOT TH2 ASSLGXUUENT UNDAR FOR THE COORDINATION COM OF THE CLASSIFICATION NITTEE NIL INITIAL THE DIRECTOR DLLSSJFICATION CLASSIFIC OF BAR OX THE CUSTODIAL WARDEN FROM LIST TO ALL RO IF TEE ARE IN THE TONI DECISIONS THA CHIAF CHJRR OR INDUSTRIAL NGINEER THEMSELVES BEARING STAFFS CLASSIVICATION CI COMMIT TREAT ASSIGRUNCNT COMMITTEE BELW SUBJECTS T5SIAL TAC2T AND INDNSTRIES OF RECONWNENDATION TO THE DIRECTOR FOR ONE BY THE DEPUTY PROVIDED THE ILJNTENNOE BY CLASSIFICATION FINEDTO BCT AS OF PLACEMENT BY THE WHO HDS THE RESDONSLBI2ITY DISCUSSION 4L1 CWROER TO BE PROVIDED MANAGER ALL WHO STAFF AND ONE NERNBER SHALL BE CORANSED OF SHALL SAD B2AR IN THE THRNATE ON HIS DIRECTLY TB MIND SHALL BE THE CON IRISTITUTIONAIPRO GRAM SHALL IT BE CLEARLY FROM THE INNATE JEET 6I OUTSIDE DISCUSSIEN SPECIAL ORDER TO CEIVE C6NTIDENTLAL NSNX INTORRNATION AND UILL STAFF INTHRM ATTCRTON THAT SBXJL TALL BE TTET SUB NERSONNEL OVERHEARINCTHER WORDS BE SO TREATED PAID TKTS LEARNED NOT BE N3DE THRATCS OR INSTITUTIONAL TGHERE THE CLASSIFICATION CONFIDENTIAL IN IS UNDTR5TOOD TO REMDIVISTIC INMATES OF OFFENDER DOES NOT BOCAUSJ HE IS STITUTION LL5A KNO IN THE RE NI FL REEORZT WHENSV LADE ROCERBION THE OFF TO 5OLOSE ATTENTION EITHER OR PHYSICAL DOUBT C1E ASSOCI ARRAR SIMLI OR TO THE PAID I1THESS BE OBTILNEI CLINIC TM RE IS LATOR DATE TOR SUCH AT ALSO SHSLL IT COUNSELOR AND THE RECLASSIT5I EIT OR CE IZIGNOSBIC BLELI BO INITIFTI CATION COTSN3TTE MERIT HC BY THIS SPONSIBILITY UT SHSJA EDICALNRJUESTS AND IN FRONT ALL CASES OF THE I4EDICAL DEPART PRO BECORE ESTABLISHIN FOR THE INMATE THE DECISION VDU WILL ALSO THE PLANS SIFEATION SOCIATE MDC THE OFF THE CLASSIFICATION COCMNITTCE ATH PER RE OUUINE FUTURE ORONW CLAS OF THE RESRONSTBILITY ENTAILS THE SAME MEMBERSHIP ONE ADDITIONS THAT BEING THE AS COUNSELOR ASSOCIATE SPEAKING REFER CASO FRO RECLASSIFICATION SENTING THEIR WRITTEN AS NATED MEETING DATES AND REPRESENT THE IANITES THE WRITTEN CCTCT TRE WILL BE AS CONWNITTEE TO THE THE MAY AT ANY SO NIERNBERS CERTAIN TKE REPRE DES4 EACH COUNSELOR CAN APPEAR EASE LOAD RECLASSIFIO TO COUNSELOR COUNSELORS SHALL AVTEAD SCHEDULED ON HIS RRD COUNSOLOR WILL THE RART CCTTNTTT DIRECTOR GENERALLY FOR HIS CLASSIFTC OL TIE WWSN POSSIBLE RECORDING IS THE RECIASSIFICATION AS THE INITIAL FINCUN BE RECORDED AND CORDTHEY IN AND R4ATTORSI PROGRAN 116A REFEIRAL FROM THRATES TREATN2RT OF CH THE ASSOCIATE COUNSELRW CS3 TO 13 THE SSIRICATION CORNITTEE SHLFL TJ ZV TH OLLOUNG OBJECTIVES PROVTH UNITY MUST SUPERVISE WHETHER BY THE IECPTION TO AHD EFFORT OF VARIOUS AIM INN THE TO DETEZNJNC WHETHER OR CHANGE IS INDIC RESTRICTIVE P2ISBNENT OUTSIEE TO JOBS OF TYPES AND WHO IN MZY BE RES THE BISIS UAOTI1ED CEORAPLISHEL OR BY LOSS TO OF THEIR TCNT INDLYIDUIL OANB ACCOU TAVORITIS OR COIISIDERATION FOR THE LAICREASS OR PROGRAM SUGGESTED BY EDI OR FINDINGS THAT INFORMATION RECEIVED ERALUATJCN CENTER AND THE INITIAL BY ABOUT INMATES SUB TH ECEPTION DIAG CLASSIFICATION CORNRAITTEES BE EMPHASIS TO RELATE MORE CLOSELY WITH I1IM TOHTTFLTHESS OEQUEAT TO THE ORIGINAL POPER THIS NEGATIVE TO RECOMMEND CHANGESIN GIVEN RECOU FOLLOWED AND OR BEING MVE TO RDCOIPA DECREASE OF CUSTCDIAL NOSTIC IS REWARD FOR WORK OF RECEIVE PT RAKE SPECIFIC TO INSURE CI BY INSURING INFLUANCE PSYCHIATRIC OR SELFCONTROL IRIMTES RGRAM AS TED ME JUDGED BY SOME OBJECTIVE ASSIGNING CENTER RECOGNITION DEGREE OF LIFE THE ORIGINAL DIAGNOSTIC PROVIDE OR IN ILY PERSONNEL WHO THE COIMSELORS THE INRNTES INSTITUTIONAL TREATMENT OBJECTIVES PROGRAM III IT IS SU3GESTED TODL CFFIC THE DISCIP1IN TAINTENANCE RECTOR BE DISCUSS INMATE TO IF OR HIS THAT THE CUS TH OBSERVATION OF INDUSTRIES OR EACH ASABER OF THE USES HIS DI ELEMENTS OF THE ALL SYNTHISIZE AEASURE OF SUCCESS OBTAINED NE4IRWS THE OCCUDTIONAL ADJUSTMENT AND THE COUNSELOR ATTEUIPT THE PROBLESI TALL THE ARFD OF THE ADJASTAENT NERNBER THB COWATTEA THE GIVE CTHSSITIC THAT DURING CP COAFLITTEE OWN PROFESSIONAL KNOULEDGE AND SKIFL SINCE SURE THE SAFE KEEPING IT GRAM MAKING OF AN IRRATE IDIL RECEIVE THE EXPRESSION IT IS THAT INPLIED AND ACTIVITIES AND WILT WHICH PROVIDE AY HE ASSIGNED FOR ELIGIBLE TO AN CORNITTEES BE USED ONLY WHEN LIVE THE NEST SECURE IN ONLY FOR ASSIGNSRANT CONSTANT SUPERVISION BE USED WHEN IT IS BELIEVED ORDINARY HOUSING FACILITIES AND REGULAR ASSIGNMENTS ACTIVITIES THE AND IS WHICH PZO CONSTANT SUPERMTSICN NEDIUN ASSGNCD AND MINIMUM TO CENTER MAY THE SUPERVISION TRANSRER NEW XNTZATES TIHICH TOR PLAC HOWEVER THE CORWILT THE THAT TO RAY SUU ALSO REVIE LLRA BE DIAGNOSTIC THAT UNIT THROUGH THE OUTSIDE OPERATES UNDER THE OFFICE LE THE INAATE NECEPTION DIRECTLY BE SCREENED MENT COMNITTEE OUTSIDE THPLIES TRUSTY DIVISION MAY ALSO AND GENERALLY MEND OF RILL BE ELIGIBLE IN QUESTIONS C6NSTDERATION SUPERVISION 411 NECEESSARY TO TO ALL BASIC IRM THE CLOSE SUPERVISION INMATE IS FIRST RNAXIUN HOUSING FCILITIES RIDE SUUERV THE DEGREE OF CUSTODIAL ME PLACE OF THE DIREC THE CASES AND RECOIN IS IT CLASSIFICATION CORITTEE RECORNZN TLONS WITHIN THE SYSTEA BY THE FJEUTY DIRECTOR IV AZC CUSTODIFL ADDSPRY ARE REAEWED IN AN DIRECTOR HE SHALL PLANS AND SCHEDULES FINJ AND APPROVFL GIVEN ADMINISTRATION SHALL BE BY CLASSIFICATION IWRATES TO OTHER THSTITU CHANJE OF INSTITUTIONS CTSTSI RICTXUU ORDERLY BY THE OF TRANSFER OC INSTES THE CLASSIFICATION OF TH LMNCIERSTOOD FOR THE AND REOMESIRICATICN HAVE AUTHORITY NECCESSARY TO HELD RESPONSIBLE TO MAKE PROP2RLY ETHOIS SUCH CTRRY OUT HIS RESPONSI BILITIES HA FICATION SH BE RESPONSIBLE LABOR POOL FOR ASSISTED THE SUPERVISION BY THE CLASSIFICATION OF THE GLASSI AND SECRETART THE LABOR POOL CLARKE ASSIGNMENT OF ALL INRIATES WILL BR PROCESSED THROUGH IKE LABOR POOL OFFICE INRN ZIVERY POOL CARD THIS THE CARD WILL STATUS SIGNMCNT CATION WITHIN IT IS AND SECRETARY INSTITUTION SHALL HAVE LABOR RECORD LAS PRESENT AND PAST THE TESPONSIHIIITY LABOR FOOL CLERK OF THE TO AS CLASSIFI MAINTAIN THESE RECORDS THE LABOR FOOL OFFICE ANY INSTITUTIONAL ANY INMATE SIFICDTIOFL REPORTS STAFF CONFINED THE LABOR POOL ALSO PROUDE INFORMATION ERNPLO WITHIN STFF DIRECTOR AHD OTHER TILL AS TO THE WALLS AT THE ASSIGNMENTS THIS UNDER THE SUPERYISION WILL PERTINENT QUESTED LLSA ND RCPORTS TO OF INSTITUTMN OF THE CLAS PREPARE STATISTIC ROUTINELY OR AS RE C1A ERRED CON ICECEPTION STITUTIONS END SETRCTRY RRO ETC THIS ASSEN DI HE SHFLL IRAMTUTION CCNTER NATNTEIN ON INNTTES ROGRAA TRANS OTHER IRA RECORDS OF ALL TRANSFERS TO THCN2 XS ZO SILL 2Q LTO SEPTQUABER IT CT TN PR 1CO DATED SBNLL 2O1LOT4 OF CFMO‰NT IDONTIFICNTION TNE ICNT AND CRURU TRE ST IS HEREBY ESCI2DED DOTED C‰SSIFIC CFLRROC IP RAVELTRINT THO AND NN ZIXLNG GFLCI C1ASCIF2E OF AND TBA NSSIST THE INCLUDES TH CNNCERNING THE FO TO ARC PROCO IS DEVELOP THE OF RCNIISTC LRCOCO CI IE CC CO RG REP COL CA BT CO NVN CO SCI CJ CO HI FO TBE TJ EN RCCTOR THE RESNURCOS THC TT ZN ME OR TO ILL CHNT CTH TIVKIQN VU COUFLCEOR TTCEL ANTI 06 ALA MONTH THE TREAT OT 2REVIE DSTCN MD ADJUSTR PROGS CORAR4ITTOO TJURIIG IWL TTH SHCV IN CC DCCCR5ILNS CL OC JZ ZECLN CO TLKLO T VR TR POIL2T THE IF JR THE AC AFVIE 2A CC NNATE VIILI VZSC6 ICMX CLEAR CL RECOR TO RGCR CC PROFES NHAUIC 12‰ BN IN REPORTS REPORT IN BECOT IN TILE L2POFL THE ABOVE BZR SHOTLD BE ZDEUED PRCGRESN OR LACK OFF ONE FLAY IN THE TC RE TFLIT4TR TIONNI TA ME IRAYA INSTENCCT TO TO FOR OF CCCT OF YH SPECTRC TEAS CFFEN UN QHAFLTO SI OP INTER CU OF AN BE ELIGIBILITY AN TIILL CRXIOZ ND ONT IN PAROK ICW VO 20 VA SR TILL CIASSIFLCA ITH TH INRN TELPZOVE THE CFAL AFLST THE HJ IIZC WILL TO RC EVENTTMT SO TRCOTHONI OF THIS YEAR CHES DUE THE CORARILT NMFLTOS TR E2RT RMC FO CI INN UNA CFLCE CCS TE RHIC WIL ALL REVIEW SS5C BE SOCIAL OHC TTT ION FL ASSIGWIENTS TO VAIOTXS TSSIGN PROGZAI HASTORY NND OTHER INFORNA4 2FLTICIPSTED LENGTH OF STAY PRO ND SNSTITU SECURTTY FILCTOZT SONC STAFF FLUST GIVC DUE CON LNDIV RDC BY BE NS THE WIU CORNRUITTEC YJITT PRCGZNTL ITICH THIS TH NDIV S1DE BE TND CLSTRIDY AR PROCE LMRECTCN THE THE CTAZZNG3NG AP5IED EFECU7017 WILL RESPONSA CCMCEPTS TN FTINCTIERDNG ITMITED TO NO AOTC THAN NBOVO C‰RSAC WITH ASIFICA FOR HE SYSTERI TIE THE T1012 TW PCCE6URE6 SAFCTTION IUDICUITOD WHCIN GO 5104 2N1 OSCNDQSA TINC PY 5U04 SIFICNT CL TT ALT OI IN BC FT STRENRTHS NARI AND THE MEAK TI3E NCCUATELY EXHIBIT 13 AFLU RR2 2S5 02 I2CJ FL 2R 5409 440R II 1TE2AEL ASSTG TTHE LIST OZ SUC BY VC TSOR T411 TZC20 BEJ OFFFFICC BY 00 420V0 GEORGE DEPNTY WEVCCN 4IP GJ3 TZETH VATA SUP DII DC THU IECASCT KG FL PE 7E2 PSYCHBTSTC C1 DIV ZZ 49 DEV TT CUI OI THE RC FLCC FA SO WILL FR THE FLDUC SERVACE IV NPPROVTI TTH COOA TO CIZ TCROR ROOL ON VI 22YAN MS ETM SAGUM MRORA SUY3 RR AR TH OF ITYB BY 00 TPR NADE CE ANY TNC L3 RC CCT OF PIRCCTC RICJ DQPUT ACCRNIRTTOG BC ER CI3 TX 71 FNLLCUISG REQT ZT2OA ROO2 WC TSU CTH TT CI MI LLL TLI1 WUAS THE EASTERN DISTRICT CF MICHIGAN SOEJTIIERN DIVTSTON UREA FLD P0TH ETAL SIMS CALVIN PLAINTIFFS CIVIL ACTION 21172 NO CO PARKE DAVIS AND THE UPJOHN COMPANY DEFENDANTS AFFIDAVIT STATE OF MICHIGAN COUNTY AND SAYS SB TO THE FIRST BEING SWORN DEPOSES DULY AS FOLLOWS HE WAS EMPLOYED ABOVECAPTIONED ADMINISTRATOR THE OF CONFINES OF THE COOPER STREET PROCEEDING UPJOHN STATE JACKSON BY RESEARCH PRISON ALL DDRINQ THE UPJOHN COMPANY AS LOCATED CLINIC RELEVANT PERIODS WITHIN FOR SOUTHERN MICHIGAN MICHIGAN COMMENCING 4000 APPROXIMATELY 1964 FEBRUARY THAT INCLUDED GENERAL THAT OF THE PARKE AND THAT SAID DAVIS AS HE IS ADMINISTRATOR OF THE TECHNICAL WITH AND COMPANY CLINIC AND PROCEDURES NEITHER OF SAID CLINIC AND ADNILNISTRATIVE THEREIN FAMILIAR AND PROCEDURES THAT IN DUTIES CONDUCTED WORKINGS WORKINGS CONNECTED HIS SUPERVISION OF RESEARCH ASPECTS AFTER WILLY THAT TO THE WILLY OF RALPH THE OF RALPH OF THE THE LOCATED AT JACKSON ARE ESSENTIALLY UPJOHN WITH THE PRISON IDENTICAL DM56 HE NOR ANY OTHER UPJOHN ANY MANNER WHATSOEVER AND PROCCDURES WORKINGS REPRE RESEARCBF CLINIC IN JATKSON PRISON WORK IT THE HAD POWER OR AUTHORITY ANY TO INITIATE CLINIC THAT AN EXPRESSED TO ASSIGN INMATES INTEREST OF HIM TO THE IN HAD PRISON TIME TO TO WORK IN ASSIGNED BEING TIME THE CLINIC THAT INMATE HAD IN EXPRESSED THAT HE HAD REQUESTED THAT DIRECTOR WITHIN THE WHILE DENIED OTHERS HAVE BEEN COMMITTEE TO WORK IN KNOWLEDGE OR APPROVAL 10 SO ASSIGNED TO PERFORM THAT SPECIFIC THAT SO DESIGNATED INMATE TO THAT PARTIES ONLY WERE REQUESTS FILL WITHOUT CLINIC IN THE WHICH PRIOR IN INMATES CLASSIFICATION WERE COMMITTEE POSITIONS SPECIFIC TASKS SPECIFIC WERE OR THE CLASSIFICATION BY THE TO INMATES PERSONNEL SOME INSTANCES PERFORM THE OF WHICH THE INMATES AND TO TILL WERE SPECIFIC HAD NO NEED FOR SUCH ADDITIONAL PERSONNEL THAT INMATES OCCASION ON ONE SPECIFIC TO THE ASSIGNMENT CLINIC BE HE REQUESTED THAT AND RESCINDED SUCH REQUEST WAS DENIED 13 SERVICES AT THAT THE WAS PRCSRNT INSIDE DEPUTY 14 ONCE AN RESEARCH INMATE CLINIC IN THE WHICH IN SOME SUCH INSTANCES RESEARCH THE 12 CERTAIN OF ANY UPJOHN AND THE GRANTED RESEARCH CLINIC TASKS TO COMMITTEE AFOREMENTIONED THEY WERE DESIGNATED 11 POSITIONS IN CLINIC THE TO MAKE SUCH ASSIGNMENTS OF TREATMENT THE TO BE SO ASSIGNED ARE THERE WERE INSTANCES DIRECTOR PARTICULAR WERE DIRECTED WERE AND AUTHORITY SOME OF THE BY THE ASSIGNED INMATE OR THE CLASSIFICATION THAT THAT ASSIGNED SUCH REQUESTS HAVING PRISON BEING IN BELIEVES AFFIANT IN THE PARTICULAR ALL OF TREATMENT WHICH PRISON INTEREST AN WHICH CASES SOME OF THESE INMATE CLINIC AT THE WAS ASSIGNED THE CLINIC TO PERFORM HOURS DURING WERE FIRST WHICH APPROVED SUCH BY THE WARDEN THAT ONCE AN HE COULD BE GIVEN INMATE TIME OFF WAS ASSIGNED IN TO THE ACCORDANCE WITH RESEARCH PRISON RULES BY THE PRISON RECREATION STUDYING 15 THAT ALL SUBJECT TO APPROVAL SPECIFIC AND SECURITY BY UPJOHN THAT CLINIC BY THE OF SOME SPECIFIC THAT CLASSIFICATION THE INMATES THAT 19 20 COMMITTEE BY THAT AN INMATE THE 22 ASSIGNMENTS THAT 23 THAT TO THE OF RESEARCH TREATMENT WITHIN OR TIIC THE PRISOH THE TO DOUBLE WITHOUT PERSONNEL THE TO REASSIGN WERE IN HAS CONTINUED ON THE RESEARCH EXPRESS THE OR KNOWLEDGE CLASSIFICATION INMATES TO OTHER OCCASIONS WISHES PER DIEM IN THE DEPARTMENT BY THE PER OF FOR ALL ASSIGN INMATE CORRECTIONS STATE OF THE DIEM CLINIC DENIED PERSONNEL WAGE RATES RATES AND OR REJECT MAINTAINED RESEARCH CLINIC HE FOR THOSE INMATES WOULD BEDIRECTED THE SUCH SUGGESTION RECORDS THAT OF MICHIGAN CLINIC ANY SUCH REQUEST UPJOHN SOME INSTANCES OF UPJOHN AS ADMINISTRATOR WARDEN WHO WOULD ACCNPT 25 ASSIGNMENTS COULD OCCUR WITHOUT AUTHORITY OF TREATMENT TO THE RESEARCH THAT JOB AUTHORITY SUCH REQUESBS COULD SUGGEST CHANGES 24 PRISON WAGES WERE PAID THAT AND OTHER ASSIGNMENTS WERE REASSIGNED WERE SET BY THE SUCH PER DIEM ADMINISTRATIVE PERSONNEL ON VARIOUS MENT AGAINST WERE BARERY THE UPJOHN OR DIRECTOR 21 TO INMATES CELL THAT ASSIGNMENTS RESEARCH PERSONNEL OF UPJOHN APPROVAL BY THE DIRECTOR SUCH REASSIGNMENTS THAT TO INSTRUCTIONS WHO WERE ASSIGNED OR THE LAUNDRY OF UPJOHN BACK FOR AUTHORITY WERE VETOED BY THE PRISON COMMITTEE 18 APPROVAL TO THE BY UPJOHN PERSONNEL PRISON COULD BE REASSIGNED SUCH AS WAS ASSIGNED INSTRUCTIONS PERSONNEL 17 ASSIGNED MEETINGS REASONS 16 SO THAT ATTENDING OR OTHER REASONS WITH OUT APPTVAL ONCE AN INMATE CLINIC CT OF PURPOSES PERSONNEL UPJOHN 00 FOR AUTHORITY REFLECTING THE ASSIGNMENT 26 THAT SIMILAR FORMS OF INMATES DAYS TO THE RESEARCH SUCH RECORDS WERE KEPT TO THOSE UTILIZED CLINIC UPON STANDARD FOR INMATES PRISON ON OTHER PRISON ASSIGNMENTS 27 THAT FOR THE MICHIGAN TO THE RESEARCH COMPANY REIMBURSED UPJOHN DIEM PER CLINIC WAGES OF INMATES PURSUANT TO THE STATE OF WHO WERE ASSIGNED AGREEMENT WITH THE CCRRECTJONS DEPARTMENT 28 AT THE THE THAT THE PRISON RESEARCH UPJOHN GUARD TO PROVIDE ASSIGNED SECURITY CLINIC 29 THAT SUCH GUARDS WORE PAID 30 THAT THE BY THE STATE OF MICHIGAN UPJOHN COMPANY MICHIGAN FOR THE WAGES PAID RESEARCH CLINIC PURSUANT COMPANY AND THE THE STATE ANY SUCH GUARDS FOR DUTY TO AGREEMENT DEPARTMENT MAKE THIS REIMBURSED BETWEEN THE AT THE UPJOHN OF CORRECTIONS AFFIDAVIT ON THE BASIS OF MY OWN KNOWLEDGE 6ZOA LIALPH SUBSCRIBED AND SWORN TO BEFORE ME THIS FEB NOTARY 1970 PUBLIC MY COMMISSION COUNTY MICHIGAN EXPIRES PAUL OF UOWI NOTARY PUBLIC JACKSON COUIITY MARTH 10 MY COMMISSION EXPIRES MICH 1973 DAY OF FILED OCTOBER 1970 AND DTSCRIFIION OF EXHIBITS OR EACH DOCUMENT LIST EXHIBIT LETTER C4 ENTITLED INMAIE DETAIL REQUEST FOR APPROVAL OF ROUTINE EFFECTIVE DATE DECERNBCT 1966 THRU MONTHLY WORK DETAIL 1967 445 AA4 TO 2L0T00 SEVEN DAYS JANUARY 31 INCLUDED UPJOIW CLINIC THIS REQUEST PER WEEK HOLIDAYS 20112 SHALL APPLY TO THE FOLLOWING INMATE GLANCY 50593 UPJOHN HEAD BLOOD ROOM NURS TO ATTEND WEEKEND AND ORIGINATOR OR HOLIDAY MOVIES AS THE WORK LOAD PERMITS AND ADMINISTRATOR REOUESTT MR UPJOHN CLINIC WILLY WARDEN TUCKER DEPUTY APPROVED BY PM AI A2 SAME EXCEPT 104742 45412 MARLIN EEG TECHNICIAN ON 24 630 AM TO 1030 PM HOUR CALL DATE SAME EXCEPT EFFECTIVE UPJOHN CHIEF CLERK 104742 SEPT UPJOHN BY CLINIC HEAD CLERK OFFICER THIN NOV 30 1966 TBRU AUG 31 1966 45412 MARLIN A3 SAME A4 ENTITLED INMATE DETAIL REQUEST FOR APPROVAL OF SPECIAL DATE DECEMBER THIN EFFECTIVE WORK AND MOVEMCNT DETAIL 445 TO AAN DAILY UPJOHN DECEMBER 20 1966 TECHNICIAN HAS SPECIAL WORK CLINIC UPJOHN ORIGINATOR OF REQUEST PHARACOLOGY FOR FIFTEEN DAYS MR TUCKER DEPUTY WARDEN WILLY APPROVED EXCEPT EFFECTIVE EEC DATE JULY 6T AM HW A5 IJQTRAIJLPARTMENTAL OF HESSLER CORRESPONDENCE TO DATED CLASSIFICATION 81765 SUBJECT FOLLOWS FROM DESK 104742 PERTINENT PORTION READS AS TO THIS OFFICE FOR ABOVE NAMED INMATE HAS APPLIED EMPLOYMENT IN THE UPJOHN CLINIC THIS MAN AND FEEL HE WOULD MAKE HAVE INTERVIEWED THEREFORE IF IT GOOD MAN FOR THIS ASSIGNMENT AGREE ABLE IN YOUR OPINION AND THAT OF THE CLASSIFICATION COMMITTEE REQUEST THAT HE BE RECLASSIFIED RESPECTFULLY FOR THE 1011U MESSIER ASST ASSIGNMENT SIGNED UPJOHN CLINIC ADMINISTRATOR MARLIN THE WJ A6 MR THE CHANGE ORDER 104742 MARLIN ASSIGNMENT WILLY ABOVE INMATES HAVE BEEN PLACED ON THE 1011U ASSIGNMENT DATED 82765 HANSEN DIRECTOR OF TREATMENT SIGNED GL A7 THE JOB PAYT IAW ORFLCLS LEITSON FLEAN DEAN HART PC TUB CTRJ TOWERS ONE FREST STREET FLINT 48 2N UPJOHN CLERK 050 PERSONNEL ROSTER NAMEMARLIN DATE OF ASSIGNMENT 82666 MAXIMUM PAY CLINIC CHIEF 075 125 1104742 STARTING LETTER TO DEPUTY KIRCHER DATED JANUDRY 18 1965 AND SIGNED ADMINISTRATOR CLINIC MR WILLY UPJOHN PARAGRAPH BY TES GIVEN INMATE FIRST RESPONSINTLIT PAGE DISCUSSED EMPLOYEES AND ON PAGE THE FOLLOWING IS PARAGRAPH OF THE TAKEN VERBATIM IN ONE RESPECT THE RELATIONSHIP TO THE CLINIC IS CLINIC INMATE EMPLOYEES UPJOHN UNIQUETHE DEMANDS OF NECESSITY STANDARDS OF PERFORMANCE WHICH ARE TO THOSE MAINTAINED AT TNT UPJOHN COMPANY OUR WOR SIMILAR AT THE CLINIC WOULD HAVE LITTLE VALUE IF THIS CANNOT BE DOME ADMINISTRATOR SIGNED BY WILLY UPJOHN CLINIC CONTINUED PAGE EXB LB IT LETTER C4 INVOICENO 8485 INSTITUTIONAL MICHIGAN ADDRESS ATTEN MR WILLY ORIGINAL STATE PRISON OF SOUTHERN SOLD TO UPJOHN CLINIC 102766 JACKSON MICHIGAN XPENSES DUE STATE OF MICHIGAN AS PER THE ATTACHED STATEMENT PLEASE MAKO CHOCK PAYABLE LO STATE OF MICHIGAN 4000 COOPER STREET JACKSON MICHIGAN FORWARFLED TO KALAMAZOO FOR PAYMENT ON 11766 BY ASST ADMINISTRATOR FIESSLER UPJOHN CLINIC PAGE UPJOHN CLINIC BILLING SEPTEMT3 INNATE WAGES 1966 55775 FDRWARDED TO XALAMAZOO FOR PAYMENT BY FLESSLER ASST ADMINISTRATOR INMATE PAY UPJOHN CLINIC PAGE 1011UPJOHN ASSIGNMENT MONTHLY SUMMARYGRAND TOTAL OF LISTING 50593 GLANCY RECEIVED 55775 ITEM FOR 30 3150 DAY ITEM 26 OF LISTING PER DAYS ILO4742 MARLIN RECEIVED 3750 125 PER DAY FOR 30 CERTIFIED BY RFWILLY UPJOHN CLINIC ADMINISTRATOR DAYS WJ WJ 105 PAGES OF UPJOHN COMPANY KALAMAZOO PERSONAL TELEPHONE ALL SUBSIDIARIES 30 LISTING DIRECTORY LISTING OFFICES COUNTRIES AND 29 PHARMACEUTICAL SALES INFOREIGN OFFICES AND FLISTRIBUTION CENTERS WITH OFFICE ADDRESSES IN STATES OUTSIDE THE TERRITORIAL BOUNTIES OF THE STATE OF MICHIGAN F0RF LAKE CENTRAL AIRLINES FREIGHT DOMESTIC AIRBILT UPJOHN RESEARCH CLINIC INC INDIANAPOLIS NO 20YIP161993 4000 INDIANA AIR SHIPPER JACKSON COOPER STREET JAMES ODONNEL GASTRIC GENERAL LABORATORY CINCINNATI HOSPITAL CINCINNATI OHIO DESCRIPTION BOXES BLOOD SPECIMENS OF SNIPMENT PAID FREIGHT BILL 12566 WITH CHECK NO 226 TOTAL CHARGES MICHIGANTO CONSIGNEE DR 790 DATE NOVEMBER 1965 TO WARDEN GEORGE XROPP PRISON OF SOUTHERN MICHIGAN 4000 COOPER STREET JACKSON MICHIGAN SEE LAST PARAGRAPH THIS LETTER IS INTENDED TO SERVE FORMAL NOTICE OF OUR INTEREST IN SECURING AN CLINIC IN TBE TRUSTY FLIVI4ON AND TO WK THAT THE CORRECTIONS DEPARTMENT BE SO INFORMED THAT DECISION CAN BE MADE SIGNED BY RALPH CLINIC WILLY LETTER STATE OU ADMINISTRATOR FI FLOOR PLANS OF CELLS IN FOR REMODELING TEARING OUT AND REBUILDING 10BLOCK AND ENTITLED CELL BLOCX CLINIC DALED NOV 19 JACKSON MICHIGAN 1965 DWG NO OWINGS BY SKIDMORE MERRIIL ARCHITECTSENGINEERS SPSM CSK99 F2 LETTER STATE OF MICHIGAN DEPARTMENT OF CORRECTIONS 1966 MEMO TO JOHN CONLIN DIRECTOR JANUARY 14 PARKEDAVIS CLINIC AND RALPH WILLY DIRECTOR UPJOHN CLINIC CEMENTS IT HAS BEEN AGREED THAT YOUR COMPANIES WILL BE PERMITTED TO CONSTRUCT IN CLINIC FOR THE PURPOSE OF CONDUCTING SOME TYPES OF DRUG AND MEDICAL RESEARCH FROM THE DESK OF GEORGE KRDPP WARDEN DATED LAW OFFICES AN JLEITSON FLFAN SEGAR HART PC GENESES TOWERS ORJT FIRST STREER PUNT MIEN 48502 LO PAGE CONTIR CI EXHIBIT LETTER F3 INVOICE HUN3ERFORD CONSPRUCTION COMPANY GENERAL CONTRACTORS 1425 WOODWARD AVENUE BOX 5O7 JACKSON MICHIGAN INVOICE NO 6798K JOB NO 859 YOUR NO 341427 DATED OCTOBER TO DR LLOYD 1966 STATE LEZOTTE DIRECTOR UPJOHN RESEARCHCLINIC PRISON OF SOUTHERN MICHIGAN JACKSON MICHIGAN RORE 12 OF PAINTING CONTRACT REMOVE FIVE CELLS PO CONVERT F4 INTO CLINIC THE UPJOHN COMPANY JACKSON CLINIC 1966 JANUARY 20 PROPOSE FUFLNITURE AN EQUIPMENT NEEDS FOR THE TRUSTY DIVISION CLINIC ADMINISTRATOR SIGNED RALPH WILLY UPJOHN CLINIC JOB CLASSIFICATION WITH SUGGESTED PAY SCALE DATED JUNE 11 L965WHEREIN REFERENCE IS MADE TO HIRE INMATES SIGNED BY RALPH WILLY UPJOHN CLINIC AND JOHN CONLIN PARKEDAVIS CLINIC LETTER ATTACHED DATED JULY 15 ON DEPARTMENT OF CORRECTIONS LETTERHEAD ADDRESSED TO WARDEN GEORGE KROPP AND SIGNED BII GUS HARRISON WHEREIN MR HARRISON GIVES HIS APPROVAL TO NEW PAY SCALE SUGGESTED BY THE TWO CLINIC ADMINISTRATOR LETTER DEPARTMENT OF CORRECTIONS LETTERHEAD DATED MARCH ADDRESSED TO MR GUS HARRISON DIRCCLOR 26 1964 ATTENTION MR ROBERT BOASE RE INMAIE PAY CONFERENCE SIGNED GEORGE KROPP WARDEN CC MR CONLIN MR WILLY WHITE SWANSON AR G2 MEMOPANDUM DATED DCC 11 1965 TO MR ROBERT BOASE FINANCE OFFICER DEPARTMENT OF CORRECTIONS RE OPERATION OF UPJOHN PARKEDAVIS IABORATOTHIES AT SPSM SEE ITEM III FIRST PAGE INMATE WAGES REGULAR INMATE PAYROLL BILL DRUG FIRMS COLLECT AND DEPOSIT WITH STATE TREASURER FROM THE DESK OF FMMCLAURY DIRECTOR OF DIVISION ACCOUNTING 03 FOLLOWUP TO THE MEETING HELD IN THE PARKE DAVIS CLINIC AND IS ON MARCH 12 1964 INTENDED TO COVER MATTERS WHICH WERE UNDERSTOOD AT THE TIME OF THAT MEETING THE PARTICULAR IN THE MARCH 12MCETING WERE PARTICIPANTS DALE LANE FOR PARKE BOYLES JOHN CONLIN DR DAVIS COMPANY DR CARL SLAGLE AND RALPH WILLY FOR UPJOHN COMPANY GEORGE KROPP DR BARTHOLICAFL SWANSON AND JOHN WHITE FOR THE DEPARTMENT OF CORRECTIONS STATE PRISON OF SOUTHERN MICHIGAN GUS HARRISON AND RJI DBASE FOR THE DEPARTMENT OF CORRECTIONS ITEMS DISCUSSED WERE ITCM INMATE PAY FOR INMATES ASSIGNED TO THE CLINIC JOBS OTHER ITEMS DISCUSSED PERTAINING TO COMPANY EXPENSES FOR CUSTODIAL COVERAGE BUILDING MAINTENANCE LAUNDRY PROTOCOL COMMITTEE UTILITIES CHARCES SIGNED DY GUS HARRISON DIRECTOR DEPARTMENT OF CORRECTIONS NOTE STATE PAYS CUSTODIAL OFFICERS ASSIGNED TO CLINICS ON STRAIGHT AND COLLECTS ON STRAIGHT TIME AND HOURLY BASIS ONEHALF HOURLY BASIS FROM THE TWO COMPANIES TTHIMORANFLUMZ AZ FM LAW DEAN DEAN SEGAR HART PC MIS 7OWR EITSON NK UNT IFCST 141CM TRRRRR 4S CONTINUED PACE EXHIBITS LETTER G4 MEMORANDUM REPORT OF MEETING HELD IN THE OFFICE OF THE OF CORRECTIONS ON FEBRUARY 25 TO DISCUSS THE OPERATION OF THE MEDICAL RESEARCH CLINICS AT SOUTHERN MICHIGAN PRISON ITEMS DISCUSSCD CUSTODIAL COVCRAGE REIMBURSEMENT BY COMPANIES FOR SECURITY PERSONNEL PRQVIDE THE BY PRISON CIVIL SERVICE INMATES CLINICAL PERSCNNCL REIMBURSEMENT BY COMPANIES FOR INMAIE WAGES SEE ITEM THE PRISON COULD 5UPPLY ALL LINENS AND LAUNDRY SERVICE FOR LINENS AND LEVY REASONABLE CHARGE AGAINST THE COMPANIES HOWEVER IT MAY BE PREFERABLE FOR EACH COMPANY TO SUPPLY ITS OWN LINEN AND LAUNDRY SERVICE SEE ITEM INSURANCE THE DEPARTMENT OF CORRECTIONS WILL LIST THE BUILDINGS WITH THE STATE INSURANCE FUND TB COMPANIES WILL INSURE THE BUILDINGS AND CONTENTS WITH COMMERCIAL CARRIERS SIGNEDT GUS HARRISON DIRECTOR DEPARTMENT OF CORRECTIONS DEPARTRAENT ENTITLED JOB DESCRIPTION STAFF PHYSICIANJACKSCH PRISON RESEARCH CLINICT OBJECTIVEST THE PRIMARY OBJECTIVCS OF THE STAFF PHYSICIAN ASSIGNED TO THE JACKSON PRISON RESCARC CLINIC ARE SEE ITEM FOR HIRING PAGE AND RELEASING OF INMATE HELP LETTER DEPARTMENT OF CORRECTION LETTERHEAD DATED 1965 ADDRESSED TO MR MCTAURY DIRECTOR AEDOUNTING DIVISION DEPARTMENT OF ADMINISTRATION LANSING L4ICHIGAN ATTENTION NR DONALD POWERS SUBJECT HEATING CHARGES TO PAREDAVIS AND UPJOHN CLINICS LETLER COMMENCE WHEN ARRANGEMENTS WERE ORIGINALLY MADE IN MARCH 1964 FOR CHARGING THOSE DRUG FIRJ1S FOR HEAT FURNISHED THEIR CLINTC BUILDINGS SIGNED SWANSON BUSINESS MANAGER DECE AR MEMORANDUM DATED AUGUST 18 1965 TO INMATE EMPLOYEES RESEARCFL CLINXCS FFOCTIV DATE AUGUST 16 1965 ANY INMATE EMPLOYEE ARSIGNED TO THE UPJO OR PARKEDAVS CLINIC WHO IS OFF ASSIGNMENT FOR PERIOD EXCEEDING THREE DAYS SHALL NOT BE COMPENSATED AT HIS DAILY RATE OF SALARY STARTING WITH THE FIRST DAY OF THE ABSENTEEISM SIGNED RALPH WILLY UPJOHN CLINIC AND JOHN CONHIN PARKE DAVIS CLINIC MEMORANDUMS PROTOCOL OF THE CLINIC 56 LAW OFFICES LEIYSON DEAN NAAN SECAR HART PC US OTNESSE T6WTPG OFLE LINT FIRST STR MOH 4E1 255A031 TO 5LN12 BLOCKS SUBJECTZ UPJOHN CLINIC SEE SECOND PARAGRAPH AN TNMATI EMPLOYEE SIGNED ITS KIRCHER DEPUTY WARDEN LETTER HANSEN DATED FEBRUARY 22 1966 ADDRESSED TO MR GERALD DIRECTOR OF INMATE AFFAIRS SPSM WHEREIN MENTION IS MADE TO INNATES OF OUR AND SIGNED BY RALPH WILLY ADMINISTRATOR UPJOHN CLINIC EMPTOY PAGE CONTINUED C4 LII EXHIBITS LETTER AB INTEROFFICE MEMORANDTM4 TO LA LEZOTTIVROM VARLEY 1966 MEETING WITH GUS HARRISON SEPTEMBER 29 DATE OF OCTOBER 1966 HESSLERSEELLEXT COPIES TO WE SHOUL TO LAST PARAGRAPH WHEREIN REFERENCE IS MADE FILE HERE IN KALAMAZOO CONTAINING HAVE COPIES OF ALL LETTERS AND MEMOS WHICH ORIGINATE AT JACKSON AND WHICH PER TAM TO THE FUNCTION OF OUR UNIT AND LAST PARAGRAPH IN WONDER IF YOU WOULD BEGIN TO CONSIDER FULL TINALLY WHAT CIVILIAN PERSONNEL WE WOULD NEED TO RUN THE JACKSON UNIT EFFICIENTLY IF INMATE LABOR IS IN THE FUTURE DENIED AS RESULT OF TIW PGESENT FEDERAL MINIMUM WAGE LITIGATION IT IS MR HARRISONS OPINION THAT THEY COULD CONTINUE TO SUPPLY US WITH INMATE HELP FOR MAINTENANCE INASMUCH AS THE BUILDING IS THE PROPERTY OF THE STATE NOPE THIS MONTH PRIOR TO THE FILING OF CIVIL ACTION LETTER DATED SUBJECT WJ TO 29149 COPY OF 1121 PROTOCOL COPY OF PROTOCOL THE DRUG ORINASE LAW OFFICES LEPRSON DEAN SEGAR CC HART PC IO QRNE TOWEAS ONE RLINR 7ROT STREET MRCJ FLS455S1 488 JACKSON MICHIGAN PRETAINING TO 251FLINCOSIN 96 DAT MAY 23 1966 PERTAINING TO C4 1MM FDETAW REQUEST XXXIPS MONTHLY WORK DETAIL ROUTINE MONIBRY ODDHOUR DETAIL WORK KAVIN PRISON MOVEMENT 1966 FLLPJOIIN THIS DCZI TBRU JAN ATO REQUEST AHAN APPLY TO THE LOLLOWIG CLINIC NAME TO WEEK ATTEND 31 SEVEN71 FLAYS PER WEEIK HO LY TSYWC LU ED FLOLAIL DM51 PROPERTY EIECTIVO DEC ROUTINE SPECIAL I967 APPROVAL FOFI CI AND MCDIDAY AS THE LOCK WORK LOAD PERXNITS CC IZ BLOCK UPJOHN MEN TO IARHO BE OINCIOR CI RIQLT VRTLTIED DY APPROVD TK HY ANT 023 OF REJEA JLRDC AND RETURNED BY MR FLY JI WILLY ADMU4IWTWK2QR UFJONN CLINIC WCRDEN UPECDIC XCII ENDOR SPECIAL DEPUTY INALRUELLONH KIT WCRDCN SHALT BE ANT DOP NOTED WARDEN HCROON INSTITUTION CJ UIMATE DETAIL REQUEST FOR APPROVAL XXXI3 MONTHLY WORK DETAIL ROUTINE MONTHLY SPECIAL WORK ODDJKUR IDOVEMENT PTON LEAVING JJ EIFODFIV ROUTINE PROPERTY THIS NO DEC DETAIL REQUES DAYS PER INC LUDEDJ UPJOHN SHCDL APPLY NAME TO WEEK CLINIC THE FOLLOWING INJNATOS LOCK NA NAME LOCK 454I C1 UPJOHN HEAD ON TO HOUR 24 ATTEND ALL MY THE 9LINXCOFFICER WEEK END MOVIES AND HO IDAYMOVIES AS TB WORK LOAD PERMI CC BLOCK 12 UPJOHN MENLO BE ORI VERWED EN CBARQ OLBEQTAET VI RES AND RETURNED MR ARCH CLINIC BY WILLY ADMINISTRATOR 1K BRUP4O L1CL APPROVED WARDEIT NOTE ANY W3O2Q SPACILIC ANDOR 8I SPECIAL DEPUTY WARDEN ISLSTRUCTIONS 312 AMTOIO3 PM HOLIDAYS DETAIL THU JAN 1966 1967630 SEVEN7J DETAIL DALE AUST TSP WCRDCRT THOU BE NOTED HSRVON INSTITUTION CA CO JITHIATEDETATH OR APPROVAL RSQUEST 53 ROUTINE MONTHLY WORK ROUHFLE MONTHLY SPEDTXL WORKS MONRNONT LEAVING PRISON EFFOCILVO SCPLIAHRWNAV FLOTAIL ODDHOUR DOTAIL UPJOHN 1266 30 DETOIL ATN TO CIAINXC 1OFLCPM DA DETAIL PROPERTY FL INCLLUDCD THIS NO REQUEST SHALL APPLY TO THO LOLLOWINFLIINALOA NAME 104742 IXIZLXI ISSI NAME SISI 45412 MARLIN II THO LOVK XLXX XLXLXFXXM LOCK XIX LOWFLU UPJOHN CHIEF OFLFL TO ATTEND THE TORK LOAD MN ODGHATOR IN CHCZRG OL RUIUNI OF SW DAY AND AN OLIDA AND IPTURNED KFWILLY 47 VI APPRNND BY NOTE ANT IN WMDN PP THE PERM ANDOR YR DEPUTY WARDEN HTNICILON RVIQR SHALL AAT FLAP WARDEN BQ NOTED HEREON CKSTIKTION C4 TNMATE DETAIL REQUEST FOE APPROVAL EFFECTIVE DCC RVUUNE MONTHLY WC0K FLET ROUTINE MONTHLY ODDHOUR DETAIL EL XXXX WORK SPECIAL LEAVING PTI UPJOHN THE REQUEST SHALT APPLY TO ILI TEE TO TE OTIGLNEIOR IN CHORE OF XOQUI OF UPJPITXITHAIU FOLLOWING INMATEST NICLAN ABSVE HAS SPECIAL CONAC UTIVE DAYS BLOCK SEARCH UPJOHN MEN 1966 EEC OR RTITE 12 DEC 20 TO 630AM 45412 EEC CC DTITE DOUIL MARLIN 04742 AM DAXL DETAIL PROPERTY THIN 445 THIN AND RELURNOD MR IT BY WILLY FT VERIFIED DY APPROVD AS RTRR WARDEN I3O DOPUTY WARDEN TNR BO ANT DOP HE 020 EXHIBIT A3 WORD ROAN INSTITUTION CJ ILEQUEST FOR APPROVAL 4U1Y4 EFFECTIVE MONTHLY WORK DETAIL JFLOUTINE ROUTINE MONTHLY ODDFOUR DEBIT SPECIAL WORK MOVEMENT PRISON LEAVING PROPERLY DATE A966KAIPIOITHLCLIKIC DETAIL DETAIL INCITIDED THIS NO REQUEST SHALL NAME JJ53J APPLY TO THE FO1IVWINGJTHATES NO LOCK NAME LOCK MARLIN CIRIXXIXXXFX XLXLXFX IXIXIXI UPJOHN FLOAD GTE NT ATTERNL LOAD THE SRN PERMITS ON FLOUR RR UPJOHN MEN TO BE IA CHARGE OF OI4 ODGLNOTOR CI REQUEST RETURNED BY 44ASA411L VERILIEDJ APPROVED VOPUTYWORDRNQSSLDNNWTRAN WARDEN NOTE 1303020 6FI ANY SPCIFK ANDOR SPECIAL INSTRUCTIONS EJALZ HA NOTED BORCON IS INSTITUTION INYITADEPARTMENTAL CORRESPONDENCE DATE 81765 DEAK 1O4VQ MARLIN ABOVE NAMED INMATE BAA APPLIED TO TIAA IN THE UPJCIFL CLFLIC OFFICE TAR EZNPLAYNIENT AS INTERVIEWED THIS MAN AND TEE HE WOULD MAKE THERE FORE IF IT GOOD NN FOR THIS IS AGREEABLE IN YOUR OPLONTON AND THAT OZ THE RESPECTFULLY REQUEST CLASAIFICCTIOFL COTNITTEE ZOR THE 1011U THAT HE BE RUCLASSIFIED ASSIPUIENT MINE HAVE TALKED WITH MR AM YOUNG PERSONALY BE IS WIFLING TO RELEASE THIS MNEN LINNEDIATLY EMIL WJ AAST TTWL EASLER ADMINISTRATOR ASSIGNMENT ORDER REMARKS COLOR NAME NUMBER HANUZ 11 MR ON THE THE ABOVE INMATES WILLY 1011U HAVE BEEN PLACED ASSIGNMENT ASSIGNMENT DATE S276 19 CLERK APPROVED 59 HANSEN WRECTOR II N1KIO PVHLHL OF TREFTTMEFLT DUJFLQJ LINT NG II CLINC UPJ3HN THE 50593 NUMSE LOCK ASIGYNET CF DATE PAY ROOM 030 PEFISDN NURSWEADY CLANCY BLO D II ILI IF JANUQ 18 1965 DEPUTY LURCHER 11565 FRIDAY WHILE IN KALAMAZOO HAD TALK WITH VARLEY THE JACKSON CLINIC AT LENGTH AMONG THE PROBLEMS WE COVERED WAS THAT OF OUR RELATIONSHIP WITH INDICATED THAT CUSATODY HAVE EXPRESSED ON MANY OCCASIONS THE DESIRE TO COOPERATE COMPLETELY WITH THU DEPARTMENT VARLEY WAN OF THEOPINLON THAT TBIT INTEREST IN SHOULD BE FORMALIZED DR DISCUSTED DR YOU PARKEFLA THE FREE ENT SPECIPI AND UPJOHN CLINICS THE AREUNIQUE TO AHAHCONCE PROBLEM TOCTUTADY THE PRISON AND MYSELF ONLY WILH IN THE PROBLOMS ARISING CONCERN TO CUSTODY AND TO ZQ IN US THE OPERATION OF THE CLINIC WHICH ARE CAN BE DIVIDED INTO EVENL CATAGORIEA BUILDING DESIGN SECURITY OF SUPPLIES GIVEN ESPONNIBLLITCRJ RENPONSIIAIIIK BUILDING EFFICIENT DESIGN CLINICAL THE CONID BE HANDLED FROM NUMBER OF PROBLENIC STORAGE AREAS LIMITED SECURITY UPJOHN IN FACILITY WHICH VISION ES OFFICERO DESIGNED OF IN THE CLINIC PURELY AS AN RNEURCH PROBLEMS THE BUILDING PRELENTO WITH DOORS MANY LARGE AREAS OF THE BUILDING LARGE OR AE WIDE VARIETY CUETODIAL IE CLINIC ENI INNIATE CUSTODIAL STANDPOINT NUMBER OF RCON OF SUPPLIES THE NATURE OI OUR AT THE CLINIC INVOLVES EQUIPMENT AND DRUGS WHICH AR OFTEN CLASSIFIED AC HISH SECURITY BY CUSTODY SOME MAINTENANCE AND LAB EQUIPMENT IA ALOE OF CON THE USE OF ITEMS WE USE SPECIAL PROCEDURES FOR HANDLING OUR SAFEST FACULTIES FOR STORING THESE ITEMS SUCH ITEMS AND IVE TIEVERBEEN MADE AWARE OF THE LOSS OF ANY OF THE SPECIAL THE POTENTIAL IS ALWAYA PRESENT AND PERHAPS IT WOULD BE OF SOME TO EVERYONE IF PROCEDURES FACILITIES AND REPORTING SYSTEMS BE REVIEWED BY CUALTODY PERHAPS CXPIERVNCE GAINED IN THE PRISON HOSPITAL SHOULD BE TAKEN INTO CONNIDORATION MECURITY ITEMS RESPONS1NILIT1 GIVEN IN7AATE UPJOHN CLINIC LNVOLVEA NOT ONLY ALSO IT MUC OF LARGO OTAF TAO RM NU THE RNIANION LARGE OF ININATS NORK IS VERY INVOLVED WAR THL EASON LARGE UTA OF NURCES TECHNICIANS REQUIRE THE 99 II REF LTDTTAJC4A US TWA 14Q OF THE SUBJECTS BUT THE INRNNTE STAFF LIR DUPPORTING OREGJNAC NO STATE PRISON CE SOUTHERN MICHIGAN SOLD TO UPJOHN ADDRESS ATTN INSTRRURIONAL CLTHIC NE WILLY JACKSON ORDER STA EXPENSES DUE STATE PER THE ATTACHED MICHXGAFL FOR PAY MICHI 492 ARDED ML PO ENTO II LM4HUJUJHUJP HCNOWOOO TO 10 LII OI UTOTA WNW NO AN 6Q9 TW 102766 AS TO STATE PLEASE MAKE CHECK PAYABLE 4000 COOPER STREET JACKSON MICHIG UUOC 8485 WJ NT II TKTZ EXHLBTT TTFJOM CR BILLING 1966 SEPTEN2ER 7 SEPTEMBER WAGES INMATE SALARIES T9 UPJOHN 600 J16 3LB HOURS HOURS 300 OVERTIME TO AOVOR 005T YLUS AND TNNPLOYEE RETIREMENT 28…O0 T89600 2841 QLTBOO OF SERVCO CIVI 0976 ANDSERVI INSTALLATION UTILITIES ELECTRICITY2 WATER50625 COLD WATER33QS MISC 489 TJ510 SALT KWH PER TQ HEATI402 MILLION UH GAL 212 FUEL 0912 BTU PINS 402 MILLION COVER COST OF INCIDENTALS 750 PER 750 IJ92 32 GAL 32 GAL 1322 PER 4LG1 239 017 PER NM AL ZSEWE RAGESL4W4SO GAL 0912 11260 EXTENSION AT TELEPHONE 1085 HOT PP FOR SEPTEMBER POSTAGE IV ZC PERSONNEL WAGES OF CUSTODEAL 1966 FOR PERIOD OF SEPTEMBER 2023 750 GAL 483 PER MILLION 6237 PAR MTLLI6N AND OVERHEAD 1027 2317 TO CZL TOTAL ON ELECTRICITY CREDIT DUEUPJOHN CLINIC LIOTE SFSM BY FACTOR CORRECTION SUPPLIED DUE TO CHARGES THIN CONSUMERS ROWER COMPANY FOR PERIOD MARCH 1966 AUGUST 1966 TOTAL 42S378 PORWARDEDTOML MLNTON II TTB IF AAA DAY NAME AMOUNT PTP IT 5MG ZUNLOHN ASLJWNT MONTJIJJY NUMBER 301 TATH DAYFL GRAND TOTAL SUMMARY NU31IER NAME 48733 SAWTCK 15 00 50 30 107000 BAILEY 50593 GARICY 31 50 LOS 30 1071A3 52145 FLANIELSON 15 00 50 30 55191 MAY 22 50 75 61569 DAVIDNOU 1500 50 65238 LEE 66180 ANGERN 30 30 107254 1LATNAGEL 50 30 11078 BRACK 21 70 30 118886 MCFLARNARA 21 70 30 STAGER 3750 125 30 74593 MINK 1275 75 17 75606 DA1 1050 35 30 MOVIS 40 30 16 2250 75 30 KBARMS 80918 CRAIG 15 11111 87776 00 30 ODI 30 50 75 50 75 89513 CAIBREATH 89679 CRENFLLA 91018 WARD 1800 91681 PHLILIPN 1800 60 92690 SPANN 1800 60 30 93561 VILBORN 2250 75 30 96507 NAWRCCKL 1050 35 30 96773 BROWN 75 30 104247 MANCTI 22 30 90 22 50 60 30 50 MARLIN K01742 37 KRTRR RRTG OIL IUNSO UTL RO LI ONE LILT 15 50609 DEDEAUX 81245 IIRAE4 AOLOUUT 410 QUO FYA LIT FLATE 50 1ZS 80512 II 00 37S0 769Z9 AMOUNR II CITOCMNTHEE AAGENTINA LABORATORIOS UPJOHN ANODIA UPJOHN COMPANIA TSOA KFQUD POVINC VFLO5 AIRCI IEIIPA4ONE 6570202 6571955 CA8LT UPJOHN BURNO SAIL CC VI CNIIL DC BIJIMS SIN FICARDO CRNRE6 CNTRAL 1106 CHILE SAVTTIA YELP PHONC1 197718 CA8LT UPJOHN 5NIHTF ADIFRES CRR CIJS MS CLIII ARGEFLULLI IS 557 ICINBY PO BN 118 SBTIT AOLDO NEW PIRRIRNAIL AUSTRALIA WILTS SMITH BOGOTA SYD TELCPHONE RU JULIO POSTAL SAO PAULO FA MACOFLDAS SILGIDO 1554 NO I7 IJUECOL C0LOLIBI OGOTI COLOMBIA ENGLAND UPJOHN LILITTED FLIMBIG WAY ESIELEY ELEPN0NE ARTI 13 77I1454BD474914 CABLE FRIABLE PUURS DELTIULUL CILIA 1544 CUNDIRLHNQRCJ CABLE BEICIUM UPJOHN SA PUUS 2EIQIUNL BRAZL UPJOHN PRODUTOS NOI AEREN TELEPHONE 6780531 FRIABLE CABLE SA COUFLNIA UPJOHN PTV LIUIFLD SUSSEX ENGLAND TELEPHONE CREWITY 26011 FRIABLE CWLEY ENGLINDI CAEILE LYDA 24 1100 TRANCE TIRILIL UNION CHIMIQUE PLACE DESLICRINE TELTHONES 512115 110 2119 CABLE UQOBNAFA SAO PAULO BILLL ATLANTIQUE SA D0VE PJ QQ FRANCE TELEPHONE 7446159 FRIABLE PARS FRANCE CABLE BRANCH RE2EN 69 RIND LANEIRO LABORATOIPES OUNB PARIS BAZIF 520477 TELEPHONE 744659 CABLE RRIABLE PARIS PTAOCC RIO RIRI IELEPHONC CANAOA THE UPJOHN COIAPANY 865 YOGIS DON MILLS 11111 PLACE 90 OP CANADA 05 4TH VANCOUVER TEL GERRHANY TELEPHONE MONTREAL AVENUE BC AEGERIT CALSADA 375 LUCNTLIRL 555 PO EL 31112 AREA CODE FLEECE UPJOHN ITCCARTLRY SHEET ONTARIO ORANGEWLL CODE PLATELI COWANY LTD CANADA SIG LIEPPENHEIM 205715V59 OT252 CABLE UPJOHN HEPCNHCIIA CSFLSCC ZR TTLEPHONC BLVD MONTREAL QUEBEC CANADA AH HOWARD CHEMICAL 5ARL HH ONULO CANADA TELEPHONE AREA CODE 416 4444433 VT POTS 165 UPJOHN D0UTS CHIC FRANCE GERMANY UPJOHN CMBH VON CALCNSLAC 12 6148 QHRGSL4T ROAD VANCRNNER DC TI 9411030 PO LLC OMOSROLAS AUC 16 122 ALTER CRECCE 315766 TELEPHONE CABLE UPJOHN ATLIERS LCITECEI E7CB4B1T FL GTJATHIIALA PHILIPPINES UPJOHN CDMPARJIAARAACEUTICA SA M3O6 991 CU TTFIJIA CLO TRTEPHONE 2421 23245 GUWNIAL RCIOL IC IN FLIT MIII PO PO 200SF HONG KONG ONN COKIPAWV LUNG OF RRPUBLLC CUOTEMAH C0F CAMP RI MOKAIT POSTAL APARLADO LA HONG KONG 6RANCH 7TH QLIIDIRIG RO NORIB ICY 41I IIXEPIIONE 7OO2 CASLE UPJOHN HONG 29W FLUOR POINT INC UPJOHN FLOW TH PHLLLOPHTES 3029 MT24 TELEP8ON 874C CABLE UPJOHN KLANHFA PHIHIPPINTS PUERTO RICO UPJOHN INRERAMTAICAN RICO BRANCH PIJERTO VI CALLO BLOQIJE UIBALIIIACIO 12 TUSLO GUIYNIT PUCTO RICO TELERHONE THS3056 2A8LE UPJOHN KOII5 CORPORATION JVI 7661280 PURTO 7662281 RICOL RTATN SPA UPJOHN VTA DON OLONE MIV SOUTH AFRICA TUCO SPROPRIETARYI 10 TIM TELEPHONE 2892710 CABLE UPJOHN MILANO 2893834 HLTALYL TELEPHONE 239541 CAULET UPJOHN JOHANNESBYIG SOUTH AC1541 JAPAN JAPAN UPJOHN LIMT7EO 5TH IIO HLORIBJI TOYOTA NO 2CHTOI8 TOKYO JAPAN OUJIDING KUDOR CHLYODAKU TELEPHONE CAFILE MEXICO PPJOHN LA APAT TOKYO CV OE DE TIALPON LADORATORIOS UPJOHN MAMA TLURI 35 SPAIN 16 ST 2S TELEPHONT CABLE UPJOHN MADID SPAIN WJJTEO STATES UPJOHN INTERMACRICAN 2962 320 156 FRX ICO MEXICO SPAIN KLADULD 2658140 JAPAPJUPJOIIN LLMIT 255 PPC SICCT JOHANNESBUG SOIFIB AIICA PC BOX 7779 ICA PORTAGE CORPORATION SHEET KHICHI IAI2IA200 TELEPXON 493426 UOEUEX CABLET MCCS UPJOHN INTERNATIONAL 320 POITGC KAWAN IIEXICO LLIGXCL LA CONINENIAL ANGEL NO35 DF 19 MENICS INTERASERICAN VENEZUELA BRANCH MEXICO TELEPHONE 148140 CABKC MISSUKY LUEXICO COMPANY SO COLON ST APORTODO DCI COROCAS VENCRUCIA ESTE NQ 4752 TCLEPFIONE 345S9 3T37B1 34IS73 CABLE VOEVENE CAAE IVENEZUELA 536 FRET CORPORATION LOS LATCRALCIO EDIL OUNCE URBANIZACIEN LOS RUIC COLIC PANAMA UPJO MICHIGAN VENE UPJOHN PGTAT 31136 APARLADO INC STREET LTI OF PANACI COLON PCT ZONE 71960 UPJOHN COLON PANAMA RE5UBI IN TELEPHONE CABLE PERU UPJOHN INTERAMERICAN PERU BRANCH AVINIDO SALVERY NO 674 TOI 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AND ARE REQUESTED FOR OUW MUTUAL SECURITY NO FREQUENT INOPECTIANS IT COURTISLES ARE EXPECTED MIGHT BE HELPFUL IF SPECIAL OFFICER BE NEEDLES ETC THIS WOULD MAKE SUMMING REQUIRES HELP WILL IE OF INSPECTION OF TECHNICAL MATERIALS DRUGS THAT DOULD BE INTRODUCED OF CC TO OUR YATERN INVENTORY THE TASK ABSIGNED INSPECTION MUTUAL EATINFACTION TIP CLONE COOPERATION BE DONE PERHAPTI AND OFFICER MORE MEANINGFUL FOR THE ONERATION OF THE UPJOHN WOULD BE PROFITABLE UNRELATED TO THE DISCUSSION AO DR ASSISTANT WE UI ABOVE BUT AFFECTING AD THE OPERATION THAT IN ADDITION TO THE VARLEYS INFORMATION HAVE TWO MORE CIVILIAN LULL TIME AT VORKIN WITHIN AN AND LAB TECHNICIAN IT IS YEAR THESE CCRTAINHCIN MEN WILL BO HIRED AND INSTALLED THE JUNE 9I0 LAB TECHNICIAN IN SEPTEMBER CLINIC THANK CLINIC AND UNDERSTANDING ANYTHING WHICH WE CAN DO TO MEETING WITH SOME OF THE CAPTAINS INAPECTORN MD PHD 14 44 LIVE CLINIC LITTLE UN MD PROBABLY BY FOR YOUR ATTENTION 44 THE OF THE SINCERELY UPJO CLINIC ADRNLNLNTRATOR 15 44 IN 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DATR FIRIRAOOFLO CO ST ON AVCRTIRN BADE PNY CNCTODINL ETSFF ON DILL BIN OTRFL CORRICO PPRT7REL LXI COD DCPCZ DTH STATO GREEN NLARTOO VIII QCAO FLO ABNRTRA WILL CC CAPND5TNRA TC44TOBJCCT N2DO 9CR OONTRBUTCN TOR EPWIOOR INNIRANOD 11111 TO DRN FIRTI FOR 9TA FOR I96544 AND 19C4I45 OF OF CIVIL TH5C FLORVIO AND COVER FITATOS TFLFLBO COFLCETCDDOPCVTTCD CAD CREDITED TO ROOOIP AOOOIINT TT OLT DN GTTT RE FIN ROTIRC 107113941 ADDITIENAL TDATTC UT BILL OOFLOOTOC VA FIRMN CM FULL TINS DRTT FIRT FOR AND OMNIFY OO HANDLE FOR O7ORTIN3AND TOW OPC0MORCD CPCNDITNN ORVSIT WTH4I444S VIII FLATOAPRCCEDURO FLETRILTY RATE2 AND LOPOOITTD ARE SHOWN BELCSG AND ORTYIS AND VIII RON ITFLI DNS TURN FO2 UT SN LNBORTTTOA BE THOOE RHARLCD BY CONUU TTTH THA STATE TREAEUROR RTORED ANPCIRATOLY PQ QAVC RY BNEOINIT 3PONIT TO CREDIT OF SPSM FLTNO AT TBO END OF TH FINTAL XCAR CPCNDITNS ARTD5T VIII BA ALLOVCD TOR THE ORNU TOTNL NOT TO 0RCC24 TBO 87SN IN CHRRGED IR ANRON THO AMWNL OF BY FCR 101 DOCTRINAL 12 ELERQ NTCZ COLD VONER CREDIT LX TIATOR SAC END THOI OT AR ONTTL TI FOR OBRTRGED BY THE CITY TO INOOLLONOONN YEYCN CCNUR MTOOVFLBOEO1DVATCRRATEP1 VR SXPOZ IRT1T RMO NOT ONDTT VTFL VOID HOT WATAR TIFL TROTAT CRE4IT FRR NSLT BE CREDITE4 TO NW NFL CONFTNITSTIT5 LTD OF BAIRS EIVE FL IAN OTFLRACO FRO2 RUB TRILL RCACN WTI H4T AE LGVA PERTTE THZFLDIN RNNIE DIVIBTON APCSTTURA ON ON WE TDARSTN TMT NRN AFTOR THU Y4VT OR THE TRE DTUU MC BTE TO DOT ETVO TTATERLA EN TAATANXI TND NTER OENV AEEOP AD AT AND TUN TCFLD LSJTO 1CR TOW FENTINA WN ANCEA OF FLEW JH FRG RELRMRZATA TB TR YOMO DIRSOTER A1 CT7CI TEELWR 8TA H1C DLV TFLP1H PC4 FIB UA TB II AI THDLDTNR TH THA US AEOCV ZYLVTCE OSI FOR CIH WONTED CUT WITH TO TO EAVTWC TER TORO PROTOCOL NO PAGE2 HYPOGIYCCT 96 ACTIVITY THREE DETERMINATIONS IN ADDITION VATS TO NSCECTA THAT THE LEVEL ON DAYS PRIOR TO TRCATNE PO WILL START FAST AT 400 IE INTCR YDS WILL BE PERFORMED AT WEEKLY 100 MG7 OF FASTING TRUE GLUCOSE OF FLAY IE FLAY DAY STATE THROUGH 400 ADMINISTRATION REMAIN IN THE FASTING BE DETERMINED AT 500 DAYS OF ON THE AI DAY FLAY DRUG 14 ALL AND SUBJECTS I5 ALL BLOOD PM SUBJECTS AN 1000 AM AM 600 CM 700 AM GLUCOSE WILL SINGLE BE ADMINISTTREAS IDLI AND 1200 NOON 200 PM AND 400 PM DRUG THERE FTSTING CONTINUE WILL DOSE OF FOUR TABLETS AT 600 AM AND SUBJECTS INTAKE OF WATER ALLOWED ONLY AFTER BEING THE OVERALL SCHEME OF THE STUDY MAY BEOUTL1 AS FOLLOWS DAY WEEK 2L BSXS RX EAST PM SOFT PTAI ESXB FAST PM 6AM END FAST MITRIBIN FAST PM SSXS RX 6AM 6AZM END FAST END FAST 4PM 4PM PM ALKALINE 15 14 PHOSPHATASE PRECAUTIONS HERE IS WITHIN THE RECOMMENDED ADMINISTRATION BE ANTTCI FELT THAT NOT ANY UNUSUAL REACTIORS NEED RANG FOR CLINICAL HOWEVER THE SUBJECTS SHOULD SINGLE DOSE EXPERIMENT ESSENTIALLY PATED IN TIIFS AS KNOWN FYRA BE CAREFULLY FOLLOWED AND ANY UNTOWARD REACTIONS REPORTED IT IS NOT 23 AT NAY AFTER PROLONGED ADMINISTRATION IS HEPATOTOXIC ZINATIDE THIS BE WILL II TINES ALONG THESE THAT ANY DIFFICULTIES SINCE THE DOSE OF ACT ERCTN ACUTE EXPERIMENT THE LIVER BATTERY AT INTERVALS PYRAZINARNIDE USE IT IS UNTIL ADVERSEEFFECT THEREISEVIDENG 1TVER HE END OF SHNUIBEPETFFLRMED IL ORMALY DEMIASIANOS OSTER IT TH LIVER TREAT MD MEDLAR HVTHB 5666 1613 MD MD THEN ANDREPEATED JT T77 THIS ROPERT C3 ON THO IN VTVC CRCH 12 1V6H THE TILC TIV NOVT WORE VOAYN CO II SLATLB RHE UPJOHN WILLY TORGO 12 PAXT UT PRAZLANA CARL TAN NCMOTING HELD IN THE PARKO FLAVIN INTONR2ED TO COVER MATTORO VLDCH OZ XLIAT IICOTIN THE PARHO 75W4V FLOYLOS JEHN TO ZAFLOWISP 12 CO IF TRCPP FLARTHOLC SN SOUT1I PRAOU IIUHIG L7H COHN OU IFARRICON IF THPARTMCNT OX CORRECTIONS FLAASO CW USTODIFLCOERARN FL TE COVERAGE LCCACTNU EN NN OVORTI ON NAY B4CIZ O2 GROSO ALARIAS 92 MD STRVCC IT IT AP1OYO COI OVCRTIRNO OVOR TO TO ACQUIRE STAT ON TATZ WOTID BE HANDLED THE ANTIC AS FOR EXCCPT THAT IT ROULD BE ALSO TO BUL THE OR OPONZORCD INUNZANCO AND ANY OTHER APPLCAB BASIO FRINGC COATS TMNIRN TOLANTCCRRI ATTACHED IS 2INOLUDNG COMPANIES DD NECE ROTIRORNE FLOOO SHOULD UL1T2NC BY ROGTDAR PRI5ON PERFLORMOL CHARGEC TO THC COAPANIOZ 411 BO TO WHAOH WFLL BO ADDED OF BI11IN TO COTOR THE STATES XNANCTNG OF CIVFL SCHEDULE THE TIILL CURRENTLY APPROVED RONCNRCH ACTTVITIOA FOR INNATE PARTICTPATON THC TO BE PAID PAY DRUCTLY INTO TSCONNTA THE APPROPRIATE INNATE ACCOUNT PAY THO LOLLORING RATES OF PAY HAVE ASNGNOD TO CLINIC JOBB PORTERS 200 CLERKS CHIEF OLE RC RRAINOEN NAN FLUROON ANNNNOD HA 75 3SF 2S 3O NOT TO TO TOCHNICIANR TOCHNICCTN CONK ILAINTONANCO BOON CATABLIAHED O1P TO TO 3O SS LOQ FOR INMATES CC TO TO TO SO STARTED AT THE RC TU TNG JQ OF OC CONTRCSL ERRS TIN ON RTTC VCBNS HELD RY OPT TN TH OFTTEE OF TO DINEUNS 11W THE RX ALE IT DOYLEO CONISI LEND VR PC CO DARIUS VORINY THOUPJOBN SOUTHAN I4REPP SW CA MLCH3I WI PRISON 39 FLRRTBOLIC GUA 11 BARINON 13OA3E FT DCPAFLMEI OF CORRUCTTONG CL CO AU CRT1EO PTRNONNC PXVVTTT SHOULD H3VE PEON VBFLC CTI THE TFTL BE WTY WS PILOCN NT8LNTI UND XXICW IT WAN DTN DVH V1T THY ONE OFFICAR THN TIOULD PPIY PT3RHDPS CORR NIL OT AND TO MVR SECURITY THAT EACH BUTLDT MOCNTGG NND AFTER BOTH CAN ON DAY TT BASI NACNFACTORY BE TBN BY ONC CUICAR AT OIG1IE DO COV TODLTL ZL IT UORK PLAN OF RHO VOMPNNTC CO ROTM OF CUD THIS SCHEDULE TNMNT C1IN OPT NEEDS BR THE OTART UTRE LNRNATVN FO TIRKE FLAVIS AM 15 TO 20 FOR UPJNHII BOTH HNRE TO COMPANIES THO TLTROU THU CLUNSLFICN TION SETH TAMPNNLUO S1I HELP RNTSCS3 THEIR TNTIATE NEEDS CML CDLICI THE 1JTPNRTM OF CORRCEUONS UND L1 FLE QUL COANT FORIN RRJIRNBURODMCNT HICH LIT PCY NCHOITA WILD WTTS OUT COMPANIVV3 OZ BY LLL RERK OUT AND WARHOBLE THO CORRECTIN FLU LN TNMETE PAYROILRI ATID CTIB TO THE BVQINENS OFFICE BT TRCDITED THEY UJIL TO THC INRA ACCOUNTS BE TPPRCPTTETC COPY OF THE SANE PAYTOILVLLL HUSINEO QFIICES TO SERVE AS THROUGH THE COMPONIEN THE BSSIO TOR THE INNTTTNTICN PI PROCC ZVFMB BE COMPILED THE HEALTHY AND THE P4NELN WILL REFLTCLCTOD THE RONTER OF HEATTHY INMATOS WILL VOLUNTAOICN WHO TDLL BE ON MEDG BY THU PRISON EEL T1Z VIII ONLY OUPPLIED BY THE HOUPITNI AT TH DOTT CCNIPNNLAC IIL DRAY R6OIR TNNNTOEI ONE CENTRAL O8TR OR PVC2 ALWAYO IF POSSIBLE VOLUNTCERTS IOCO RO CLC BS RO COR 19 ICLY 165A HI 4TH PHYELOIANT822NRNERRCH STAN CLINIC OBJECTIVES THE PRIMARY OBJECTIVES ARET RESEARCH CLINIC TO OF THE DIRECT CROUP INTO THIS DEVELOP THNRRNNCOTCGY STAFF ASSIGNED PHYSICIAN AUAA TE CAPABLE TIN TO THE JACKSON PRISON UNTT OF THESPJIGHFL NND EXPERIENCED TRAINED CLIN ELINICAL UNIT SUPERVISE THE TESTING AND EY1134SAOFL EXPEDITIOUSLY THFS INSTITUTION TO ATTIDYAT DRUGS APPROPRIATE TO TO NEW METHODS FOR CLINICAL DEVISE OF NEV UPJOHN PHARMACOLOGIC EVALUNTION OF NEW DRUG ENTITIES BETWEEN THE CLINICAL DEVELOP MUTUAL LIAISON AND THE CLINICAL RESEARCH CLINIC JACKSON PRISON MEDICAL CENTERS ONE OR MORE UNIVEROITY TO RESPONSTRILITIES TA PHARMACOLOGY UNIT AT THE OF PHARMACOLOGY UNITS RESEARCH CLINIC IS TO THE RESEARCH PROJECT AT THE PRIMARY RESPONSIBILITY AND MEANINGFUL AND WELL DESIGNED THAT PROTOCOLS ARE APPRVPRIATE TO ASSUIE MEET STANDARDS OF SAFETY AND ETHICS OF COMMUNITY RESPONS CLINICAL PHARMACOLOGY STAFFBOTH INMATE TRAINED TRXLEZPERT AND CIVILIAN ASSURE THAT CLINIC TO THE JACKSON PRISON ADRNJNISTRATIONTFL RESPONSIBILITY ADMINISTRATIVE POLICIES AND IS OPERATED ACCORDING TO SECURITY AND PERSONNEL OF THE JACKSON PRISON ADMINISTRATION TO DEVELOP NEW METHODS FOR EVALUATING AND SCREENING NEW DRUG CANDTDATES MEMBERS OF THE ACTUAL RUNNING OF STUDIES DESIGNED BYOTHER SUPERVISE STAFF TH MEDICAL THE UPJOHN MEDICAL STAFF AN REQUESTED BY TO REPRESCNT UPJOHN AT PROTOCOL EVIEW ADMINIATTFTTIVE RTWCTINGT TO TO DEVELOP AN ORIGINAL CLINICAL CONNITTEE MEETINGS AND AT PRISON RESEARCH PROGRAM AND MAKE ORIGINAL CONTRI BUTTONS AWPHORTNES PINSI UPJOHN TEVIEV TCHCDULING ALL OF ALL PROTOCOLS DTUDICFL RTTD AT PRINON CONDUCTED NT THE ZACKAON RISON RAA2I RESEARCH CLINIC ID MEDICAL JUDGMENTS DURING ATUDYFO STUDY FOR SAFETY OR OTHER REASON FOR TP H1XTNG REPRESENT RETHIMING THE CONMTTTEO VVN STOPPING DRUG OR DISCONTINUING OF INMWTE HELP TO PRISON ADMINTEE4TIB IF F1 BET IF ADVPKO 2865 16A THE PROTOEOL4TEVIEW OP STATE MICHIGAN OF CORRECTIONS PTV IT NICNIAAN COPCR JWN4 CQMUIUWIN CORPZCTIOF4B PRISON OV TTAFL TANNER VLOCI MCQFLA JOS SOAN CMAIAAR VICE CMASTS P100K CAME 0ON DUANE WAYPI CVI NAHHTGO DTNFL OKORWTROMNTLY TDCJJ IT DOOONBOR 1965 JI 4T IL HR 14 L4OLAURY ADNINIATRNTION DOPARTZNONT 10 DFRECTOR ATTENTION OCNTLCRWN XR SUBJECT PR POWERO FLONALD CHARGES TO PARKEDAVIA UPJOHN CLINICS FLOATING AND VFL 1964 XNADA IN LINROB ORRANGCMONTS WORN ORJTHALLY CHARGING THENO FOR HEAT FURNISHED IT WANE BASED ON BUILDINGS 01 OF DTU TAR CJTNIC AT NOCO AB ANO MOTORS HAW NOW BEEN INSTAFLOD AND WE HAVE THE BASIS TAR THE MONTH 02 OVENTCR WE WOULD TO HAVE YOU ODVISO AON AS PCSSIBLO TTCIT THO INTO OT CHSXRGO AHOUL4 AND HOW DISTRIBUTCD 013 TO ACCOVNTS DLVOION PORHAPA 1R RALPH SOELOY OF THO BUILDING CHRN BO EVIL ON THAT THORORORO ROADINGA 1V CON TI RNTNYON KT ADVLO US VERY OON TIC 0H1 PRZ2O OX RT IT YOURLJ SOUT2 TE ZT 3W UFL4TGA4 ANT ZRC LTR DOEASO MICHIGAN GZA2R KY AOL PONRITBIA H44ACLA N4IIBIT 77W LB 41 CA AUGAAT TOT LRUM4BO 4AETFRCTIVT3T ENPLOYOOS AU VHAFL 1965 AS AI NOT BE COMPCNAATED AT DAY OF THE FLINT IDA THE UPJPFR OR TO TSHOO OTT GOQGNMENT FOR THE 1965 NOOOARCN SA2PA ANY CINC 16 IS THRAN DNYN PETOD RATE DAIL PATKO PAVIE AT NN OTARTING ABAENTEOIARU JR ER EFFECTING CUSTODIAL QQD THIS POLICY ARC TJ DETENTION FROM AEAIGNNANT CUNSA CHCO7 STI 11 NNLHF FL WILLY AJP4OHN CLINIC ‰TT 17 OHNH IL IARKO DAVIS CLINIC TO IILUCS SUBJECT UY30FLN CLINIC 56 YHVOCOT THEN OR THE ABOVE BLACKS RECENTLY RECEIVED LETTER FROM AT WILLY NPJOHN CLINIC IAN REGARDING THE CERTAIN INRRNT IN TM BLACK THIN IS BNING DONE LITNINATE TRNFTIC AND LIZTT OI NNRLON AND AT TO BE MEDICATED IS ATTACHED HERATO PR NWN ST AN INMATE RRPLOYEO OF THE CLINIC WHO LOAKN IN THE BLOC HNE BOON DONIPNATEA TO DO THE TWDICATION AND DETAILO ROVERINP HIS AT TW PROPER TIA HCWO BOON FE WALL PICK THI AT TNI CLINIC AND RETURN TO THE BLOCK TO NEDI ENTO INTNTO MT DE SLA COMP1D 4180 9TJJ IN PIN NROSENT DETAIL UNLORK TO NRDICATO 5200 AD4 AND 30 PM 20HLA A9T79 CRIENIFLO 1ETAILS YUAVE LT 9A773 RETAILS IN HAVE BEEN RIEN AT L2 FL IN BEEN HIM EROL4N 5BLACK PNRMIT AN ITISU INSUED FOR FOR HIM THIS PROCEDURO WILL BEGIN AND CUSTODIAL PERSONNCL WILL AM MONDAY AT 5100 BE EXPECTED TO COOPERATE 1Q REPTY 00 CAPTAIN ATAN CAPTAIN MR JILLY CHAMBERLAIN JN PJOHN ALDVDN SHIFT 210 LUA CLINIC RILE 170A SHIFT WARDEN 211TH FULLY LII ZEBRUARY 22 1966 MR OCRALD HANCEN DIRECTORCF INMATE AFFAIRS MR DEAR HANSEN THE UPJOHA COMPANY IN PURE TILT OF PROGRAM TO THE OFFERING APECIAL TRAINHICC HRU TAR BARRY IN THE ENPOJM MR O7 CNRO1RCA HOME 2ICINAGOL ELECTRONICS THAUPJOHN OF COZNNS HAC J1 IT VI OUR PROGRAM OF FNRNNTE OF OUR T2IQ7ZS4 STUDY COURAC 11 AG II NO THE ENTIRE COFL SINCORCLY RALPH WILLY ADMNINLNTRATOR UPJOBN CLBDC CC DUO AND NTO QOLES TO LEZOTTE TO SPTCZIBC SUBJECT FROM IR MR AT TO THE ON TNCETINA REACHED 1966 29 WITH GUS THRRLSON THE SUBJECT OF GIFTS OF CORRECTIONS PERSONNEL WAS BROUGHT UP BY HARRISON WHILE AN SURE THAT THINK IT WOULD BE WORTH PRACTICET SIONS WTH XCETIN SCPT OEPART AND OCTOBER DATE VARLEY 1966 UARRISO GUS FRONI MR HARRISONS HAVE NO RCCRNPHASIZTNG BEEN GUILCY OF THIS AGAIN THE CONCLU COWRCNTS THERE SHALL BE NO GIFTS OF ANY KIND GIVEN TO EITHER IVWNARES OR STATE PERSONNEL FOR THEIR PARTICTHATION IN ANY MY WITH OUR RE SEARCH PROGRAM THIS INCLUDES CANDY AND CIGARS AT CHRISTMAS TIME THE STATE SENSIFJIVE ABOUT DISTRIBUTION PARTICULARLY AND EVEN POSSESSION OF CIGARETTES BY TTMATES WORKING IN OUR OR ON OUR RESEARCH STUDIES BUILDING THINK THAT WE SHOULD BE COGNIZANT OF THIS INASMUCH AS CIGARETTES ARE ME PARTICULARLY DIUN OF EXCHANGE WITHIN THE PRISON IS SUSPCE COFFEE TO INMATES ASSIGNED TO WORK IN OUR BUILDING IS PERMISSIBLE UNDERSTAND THAT IT IS PARKEFLAVIS POLICY NOT TO MAKE COFAE AVAILABLE TO OUTPATIENTS IN THE BUILDIN FOR STUDY PURPOSES ONLY AND BELIEVE IT WOULD BE WELL FOR US TO FOLLOW SIMILAR POLICY LUNCHES FOR STATE EMPLOYCAS IF CLEARLY IN THE LINE OF BUSINESS NOTE FREQUENT AND WHEN ARE PERMISSIBLE GATHER THAT PARKEDAVIS THROWS SOME KIND OF AN ANNUAL BANQUET THE STATE PERSONNEL WORKING OR INVOLVED WITH THEIR RESEARCH PROGRAM IF THIS CAN BE DONE IN LEGITRNATE WAY AS AN INFORIACTIONDISSEMINATING IT IS PERMISSIBLE IN HARRISON FUNCTION FOR SOME OF OPINION OUR DISCUSSION ALSO LED ME TO CONCLUDE THAT WE SHOULD HAVE FILE HERE IN KALAMAZOO CONTAINING COPIES EF ALL LETTERS AND MEMOS WINCH ORIGINATE AT JACKSON AND WHICH PERTIMIN FUNCTION OF OUR UNIT TO THE WOULD YOU AT RANGE TO HAVE COPY OF SUCH COCUINENTS CORWARDED TO AND HAVE MACGO SQL UP FILE SYSTEM SO WE CAN HAVE ALL COMPLETE RECORD TRANSACTIONG AND FRONT JACKSON KIA TB COTH WONDER IF YOU WOULD BEGI WE WOULD NEED TO RUN LIIC JACKSON UNIV THE FUTURE DCFTED US AS RESULT OT UR HARRISON ON2FL US WT LA HEN ROR FINALLY XALL ITJ 5V TO ONS WHAT V2 AN SENT PCDC TE ECU AS NU AC TO PKO PERSONNEL CICNTLY EXHIBIT TO UN CLINICAL PHARIACOLOGY STATE PRISON PROTOCOL U212517 OF SOUTHERN MICHIGAN NO 88 7CHIOROLIXICOMYCIN PHASE JACKSON MICHIGAN PROTOCOL HYDROCHLORIDE NO 002 SINGLE DOSE BLOOD LEVEL URINARY ESCRETION AND FEED EXCRETION STUDY DWW OSTER MEDLAR ND MD JAEKAON MICHIGAN NONITOR PHONE WAGNER PHD 616 EXT 3453571 7689 616 HOME RI 94689 PURPOSE TO COMPARE SRUM LEVELS URINARY EXCRETION AND FECAL EXCRETION FOLLOWINS 250 SIRGIE ORAL DOSES OF 7EBLOROLINCORNYCIN HYDROCHLORIDE AND 500 MG DOSES OF LIN6ORNYCIN SINGLE HYDROCHLORIDE IN DIFFEREPT SUBJECTS THAN EMPLOYED IN THE PREVIOUS PROTOCOL 001 SPSN PROTOCOL STUDY THIS DESIRABLE BEFORE PROCEEDING TO MULTIPLE STUDY IS DOSE STUDIES IN MAN WHICH WILL REQUIRE MORE EXTENSIVE ANIMAL TOXICOLOGY THAN PRESENTLY AVAILABLE AND 500 TNG ORAL NO71 INTRODUCTION THE PREVIOUS PROTOCOL 001 SF514 PROTOCOL NO 71 STUDY U21251F NS ADMINISTERED IN DOSES 5500 INCREASING TO THIRTYSIX NORMAL MALE VOLUN TEERS TO DETERMINE THE SINGLE DOSE TOLERANCE SERUM LEVELS URINARY EXCRETION AND FECAL EXCRETION MG TC NO CONSISTENT GROSS CHANGES IN VITAL SIGNS PULSE BLOOD PRESSURE AND RESPIRATION WERE OBSERVED AND NO STATISTICALLY DIFFERENCES SIGNIFICANT FROM LINCOMYCIN WERE FOUND HEADACHE OCCURRED IN NINE SUBJECTS SEVEN ON IJ21251F AND TWO ON PLACEBO FOUR SUBJECTS TREATED WITH SINGLE ORAL DOSE OF 500 TNG TWO ON U2I251F AND TWO ON LINCOMYCIN HYDROCHLORIDE WERE NOTED TO HAVE LOOSE STOOL ONE SUBJECT TREATED WITH SINGLE DOSE OF U21251F HAD MILD ABDOMINAL CRAMPS THIRTY MINUTES AFTER DRUG ADMINISTRATION NO OTHER EVIDENCE FOR TOXICITY OR UNTOWARD SIDE EFFECTS WERE OBSERVED THE SIGNIFICANTLY HIGHER PEAK SERUM LEVEL THE SIGNIFICANTLY RESPONSE GREATER URINARY EXCRETION OF BIONCTIVIRY CUD THE LOWER FECAL EXCRETION SIGNIFICANTLY OF BIOCETIVITY FOLLOWING IJ212SLF COMPARED WITH LINCOMYCIN HYDROCHLORIDE IN THE 001 STUDY UGGESRED THAT U21 251R SHOULD BE INVESTIGATED FURTHER 96 HP OR FLERNIASIANOS INVESTIGATOR RE HYPOGLYCEMIC ACTIVITY ORINASE PYRAZINAMIDE STATE PRISON OF SOUTHERN MICHIGAN 3ACKSON MICHIGAN THE PURPOSE OF THIS STUDYIS TO EVALUATE IN AN ACUTE EXPERIMENT THE POSSIBLE THIS DRUG IS CURRENTLY MARKETED FOR THE HYPOGLYCEMIC EFFECT OF PYRAZINAMNIDE WORK IN OUR LABORATORY SHOWS THAT IT TUBERCULOSIS TXPERIMENTAL TREATMENT OF THERE IN ANIMALS WE WOULD LIKE ACTTVTY HYPOSIYCEMIC AND FFIANA1CSUE IN MAN FORE TO KNOTI YRAZINAMIDE ITSELF SCTS PROD SIISIL SUBJECTS THE PRISON POPU HEALTHY ADULT VOLUNTEERS WILL BE SELECTED FROM AMONG SHOULD NOT BE DIABETIC THEY LATION OF THE STARE PRISON OF SOUTHERN MICHIGAN SHOULD BE IT FBS 100 MOREOVER DEMONSTRATE MUG7 AND SHOULD CONSISTENTLY TOTAL NORMAL LIVER FUNCTION TEATS THESE HAVE SCFTC35 SUBJECTS EMPHASIZED THAT WILL BE ASSIGNED TO SUBJECTS BILIRUBINL PHNSPHATASE12 MGLKALINE OF FBS THAT THE MEANS AND WILL BE MATCHED SO THREE EQUAL GROUPS OF TWELVE EACH AS ARE AS SIMILAR POSSIBLE LEVELS OF THE THREE GROUPS THIRTYSIX LA PLAN OR STUDY PLAN OF THE THE OVERALL AS FOLLOWS DAY OF RX I1 GROUP STUDY IS 271 PYRAZINACUIDE 914 ORINASE NIL PLACEBO NIL 15 GUI GRE GROUP GROUP III PLACEBO ORINASE NIL ORINASE PYRAZINAMIDE GIN PYRAAINAMIDE NIL GIN NIL PLACEBO GRIT THE MEDICATION WILL BE ADMINISTERED AS SINGLE TREATMENT DAY AND IN DOUBLE BLIND FASHION EXPERIMENTAL NIL GM DOSE OF FOUR CAPSULES ON EACH PROCEDURES SCREENING PRIOR FOR NORMAL LIVER ENTRY INTO FUNCTIONS TO THE STUDY SOPT ALKALINE ALL SUBJECTS WILL PHOSPHATASE BE SCREENED MD MD OSTER MEDLAR MD SUBJECTS OR RENAL TEEN NORMAL ADULT WALE VOLUNTEERS WITH NO KNOWN GASTROINTESTINAL OF AND BETWEEN THE 130200 WHO ARE NONOBESE WEIGHING AGES DISEASE 2140 WITH NORMAL VITAL SIGNS WILL BE SELECTED FIF LBS VITAL NORMAL RANGE SIGNS 1006 TEMPERATURE PULSE TSC 60100 UTV 9050 TO 14090 FOR 30 DAYS PRECEDING THE SUBJECTS SHOULD HAVE RECEIVED NO MEDICATION INTO NUMBERS TO 15 RANDOMLY AND DIVIDED NUDY SUBJECTS SHOULD BE ASSIGNED INITIAL 10 AND 11 TO 15 THE NUMBER TO TO PRISON GROUPS NAMELY BODY BUILD AND RACE OF EACH SUBJECT AND SURNAME BODY WEIGHT ASE HEIGHT SHOULD BE WRITTEN OPPOSITE THESE SUBJECT NTINTERS ON THE ATTACHED REPORT FORM ALL SUBJECT IS ABSENT FOR ANY COLLECTION INFORM WAGNER BY PHONE NOTE IRRU IF JAJ OR DROPS FROM THE STUDY MEDICATION HFC HFC HFC U21251 U21251 250 500 LINCOCIN 500 AS MG AS MG AS RAG THE HYDROCHLORIDE HYDROCHLORIDE THE HYDROCHLORIDE THE ONE ONE ONE CAPSULE CAPSULE CAPSULE DOSAGE SCHEDULE SUBJECTS IN GROUP WEEK WEEK II WEEK UT 12345 6789 1112 10 13 1415 STUDY CONDITIONS SUBJECTS WILL CATION FAST FASTING OF MEDI OVERNIGHT AND FOR FOUR HOURS POST ADMINISTRATION INCLUDES NOT ONLY THE ABSENCE OF FOOD BUT ALSO NO OTHER BEVERAGE THAN WATER ACH CAPSULE SHOULD BE THERE WILL OZ TAKEN ORALLY WITH BE ONE WEEK ELAPSED TIME OF WATER AT ZERO TIME BETWEEN TREATMENTS BE TAKEN AD LIB BUT ONLY ER UP TO ONE HOUR PRIOR TO DRUG INGESTION II OZ OF WATER TAKEN WITH THE CAPSULE SHOULD BE TAKEN PRESCRIBED FRON ONE HOUR PR LOT TO DRUG INGESTIOTI FROM TO ROUT HOURS POST DRUG INGESTION AND FOOD BE AD LIT BREAK HOURS POST DRUG ADMINISTR TAKEN BEVERAGES MAY IF FAST MAY BE PROVLDC AT RHO UPJOHN CLINIC NECESSARY 17 SMOKING IS PERMITTED SUBJECTS SHOULD BE IN THE COLLECTION PERIOD OF FECES IF THE UPJOHN RESEARCH CLINIC AT ALL WARDS DURING THE 4DAY POSSIBLE THE SUBJECTS SHOULD NOT ENGAGE IN ANY HAZARDOUS OR STRENUOUS OCCUPATIONS OR ATHLETIC ACTIVITIES DURING THE DAY OF OR ON LHE DAY FOLLOWING DRUG ADMINISTRA ON SAMPLING IT SO IS VITALLY IMPORTANT SHOULD BE IMMEDIATELY COLLECT ALL REPORTED TO TO SAMPLES SCHEDULED ANY FAILURE TO DO WAGNER BY PHONE 50 ML OF BLOOD SHOULD BE WITHDRAWN AT ZERO TIME IN EACH PHASE CROSSOVER FROM EACH SUBJECT IT IS ML VIRALLY IMPORTANT THAT 25 OF SERUM BE SHIPPED TO THE UPJOHN COMPANY FROM THIS ZERO TIME DRAWING FOR EACH SUBJECT FOR EACH TREATMENT TEN ML OF BLOOD IS TO HE TAKEN AT 10 12 AND 11 HOURS POST ADMINISTRATION SERUM IS TO BE HARVES TED FROM ALL BLOODS AND THE SERUM FROWN FROZEN SERUM SHOULD BE SHIPPED TO BELL FOR TRANSFER CHIDESTER BLOOD OF THE 34 112 10 412 URINE ZERO URINE AND RECORDED THE BLADDER MUST BE EMPTIED AT SHOULD BE DETERMFNED IMMEDIATELY COLTEETTONS MAY HE DISCARDED TIME THE OF THIS ZERO HOUR THEN THE URINE PH TWO 24HOUR URINES ARE TO BE COLLECTED 024 AND 2448 HOURS IN POLY OF TOLUENE ETHYLENE CONTAINERS CONTAINING ONE MILLILITER AS PRESERVATIVE THE BLADDER MUST BE EMPTIED AT 24 HOURS POSTDOSING AND THIS URINEADDED TO THE 024 HOUR COLLECTION THE BLADDER MUST BE EMPTIED AT 48 HOURS POST URINE ADDED TO THE 2448 HOUR COLLECTION DOSING AND THIS URINE SHOULD BE STORED IN THE REFRIGERATOR AT 400 NIFTIL THE FINAL VOLUME FOR EACH COLLECTION TS OBTAINED AT THE ND OF EACH COLLECTION PERIOD THE URINE COLLECTION SHOULD BE MIXED BY ROTATION OF THE CAPPED BOTTLE THE P14 AND VOTUNIE DETERMINED AND RECORDED ON THE ATTACHED REPORT FORM THERE IS ONE ILAGE FOR EACH WEEK 20 ML ALIQUOT OF EACH URINE COLLECTION SHOULD BE FROZEN AND SHIPPED TO BELL FOR TRANSFER TO CHIDESTER FOR BIOASSAY 783412 THE REMAINDER OF EACH URINE COLLECTION SHOULD BE FROZEN AND SHIPPED TO BELL FOR TRANSFER TO EBLE 711254 FOR POSSIBLE OF ATTEMPTED ISOLATION METABOLITES FECES SUBJECTS SHOULD BE ENCOURAGED TO HAVE BOWEL MOVEMENT IN THE MORNING PRIOR TO DOSING BUT NO LAXATIVES ARE TO BE EMPLOYED ALL STOOLS WILL THEN IE COLLECTED QANRITATIVELY FOR DAYS 96 HOURS POST DOSING STOOLS MUST BE COLLECTED IN PLASTIC BTGS AND THE STOOLS FROZEN IN THE BAGS THE STOOLS FOR EACH SUBJECT FOR EACH PERIOD 024 2448 4872 AND 7296 HOURS AND EACH TREATMENT SHOULD BE PACKED IN INDIVIDUAL CARDBOARD CONTAINERS FOR EXAMPLE IF SUBJCCT HAD BCNJEL MOVEMENTS DURING THE 024 HOUR AFTER PERIOD TRE TNENT ON WUEK THEN THESE TWO STOOLS SHOULD BE IN L76A BE FROZEN AND BUT BOTH OF THESE BEGS SHOULD SEPARATE POLYETHYLENE BASS SUBJECTS SHOULD BE CARDBOARD CONTAINER FOR SHIPMENT PLACED IN THE SANTE THE FOURTH DAY OF BOWEL MOVEMENT IN THE MORNING ENCOURAGED TO HAVE ARE TO BE LAXATIVES NO BUT AGAIN TIME 96 HOURS BEFORE THE TERMINATION EMPLOYED FOR TRANSFER TO BELL FROZEN FECAL SAMPTES SHOULD BE SHIPPED TO MOVEMENTS OF BOWEL THE TIME AND CHARACTER CHIDESTER FOR EACH IS 1P3 SEPARATE PAGE THERE SHOULD BE RECORDED ON REPORT FORM THE FORMS FORM 1K3 WITH WEEK SEE INSTRUCTIONS FOR COMPLETING REPORT ALL 783412 LA OF SANPT AND FECES SHOULD BE CLEARLY LABELED VITH OR III WEEK II OR TREATMENT THROUGH THAT ALL NUMBERS BE TAKEN CARE SHOULD PERIOD OF COLLECTION AND TIME OR TIME OF EACH ITEM LABELING AND ACCURACY OF THE ARE LEGIBLE AND THE LEGIBILITY TWO PEOPLE SHOULD BE CHECKED BY AT LEAST EACH CONTAINER OF NUMBER SIDE SERUM URINE 15 EFFECTS ADMIN QF MEDICA AND4 HOURS POST SUBJECTS SHOULD BE QUESTIONED AT THE MEDICATION THE TION TO DETERRD IF THERE ARE ANY SIDE EFFECTS OF OF THE MEDICATION HAVE YOU NOTICED AX EFFECTS QUESTION ASKED SHOULD BE OR ABSENCE OF SIDE EFFECTS ON THE ATTACHED SIDE EFFECTS THESE PLEASE REPORT REPORT FORM 1K4 SUPPLIES WAGNER CAPSULES THESE WILL BE AVAILABLE TO DR WILLY LEZOTTE ON OR BEFORE MARCH 16 1966 41 PHD YCPC JOHN BW 17TH AJ DATE II FILED NOV UNITED STATES FOR THE EASTETRN 1970 DTSTRTCP DISTRICT SOUTHERN CALVIN OF NICHIGAN DTVISION ETAL SIMS CIVIL PLAINTIFFS PARKE DAVIS COMPANY MICHIGAN CORPORATION AND THE UPJOHN COMPANY DELAWARE CORPORATION ET AT DEFENDANTS 31172 INDIANA OF COUNTY NO ACTION AFFIDAVIT OF GAYLORD LEE ESPICH IN SUPPORT OF LAIN TIFFS MOTION FOR SUMMARY JUDGMENT AND PLAINTIFFS ANSWER TO DEFENDANTS MOTIONS FOR SUMMARY JUDGMENT UNDER COUNTS III AND IV OF PLAINTIFFS COMPLAINT AND AMENDED COMPLAINT VS STATE COURT 0F6 GAYLORD TEE ESPICH FIRST BEING DULY SWORN DEPOSES AND SAYS AS FOLLOWS THIS PERSONAL AFFIANT AFFIDAVIT KNOWLEDGE OF AFFIANK IS COMPETENT ATFIANT HAS WORKED IN UPJOHN MORE IS THE COMPANY AT HE IS OTHER INMATES OF THE TO TESTIFY IS ONC OF THE DRUG CLINIC THE STATE FAMILIAR WITH OF SAID APPROVED TO THE MATTERS PRISON MAIN OF THE MATTERS STATED PLAINTIFFS AND HEREIN HEREIN CONSTRUCTED AND BY THE OF SOUTHERN MICHIGAN FURTHER SOME OF THE OTHER NAMED PLAINTIFFS PRISON ALL BASIS FOLLOWING BUILDINGS REPRESENTATIVES PERSONALLY MADE UPON THE WHO WORKED IN THE SAID OF DEFENDANT THE UPJOHN INMATES WHO WORKED AT THE AND CLINIC SAID COMPANY CLINIC LAW CRRITT TEAN DEAN SEGAR HART RC LRRRSOZY ISIS GPP4KSM 41011 INMATES TOWERS ONELFIRBTSTHRN FLINT PERSONS COULD NOT WORK THERE COMPANY CLINICS UNLESS THEY WERE SO APPROVED WHO WERE NOT WORKING AT ONE OF THE DRUG AND WHO WERE INVOLVED IN 4S502 WORK COULD MAKE MORE MONEY AT INMATES WORKING AT AND THOCLINICS SUCH JOB PRISON JOBS DOING THAN WAS EARNED PIECE BY THE INMATES SUCH THINGS WHO UTILIZED PAINTING AS PICTURES KEEP XLI THE MONEY REPRESENTING FURTHER THE PRICES ITEMS INMATES AD AFFIANT PRIOR TO BEING AND HIS UPJOHN THE UPJOHN EXPERIENCE PART OF THE WERE WORK RELEASE THOSE PRISONERS TIME AS AT WHO PRODUCED SAID OFIRICLE DEAN TEAN SEGAR HART PC TDI GENESES RNOY OW TRERR FUN MCH 4E502 ARTICLES ORDERED THE TO WORK IN AND ABILITY CLINIC FO WERE OF GREAT VALUE AFT LANT WAS MP1OYED EXISTENCE WHICH SUNS PAID TO IOVE COUNTY LEE THERE FAR MORE TO BY THOSE THE CLINICS TCC LIEN BY UPJOHN THEREON THAN CQULD BE EARNED THIS CITLC EXPIRES LAW OR HANDICRAFT PICTURES AND LABORATORY PROGRAMS IN PLACED WORKING PUBLIC LEITSON THEM AND ADVANCED EDUCATION SUBSCRIBED AND SWORN TO BEFORE NOTARY PUBLIC DAY OF 1970 4C FOR THE PROCCEDS FROM SUCH SALE 446 ME SKILLS COMPANY 11 PRISONERS INDIVIDUAL WERE ALLOWED TO SELL FOR SUCH ARTICLES WERE SET BY THE ENCE THEIR CH JAN FILED 71 STATES DISTUCT COURT DISTRICT OF MICHIGAN SOUTHERN DIVISION UNITED E4V EASTE ST T4ICIJ IF ZJ CALVIN SIMS LEE WILLIAMS RICHARD ALLEN FRANK SILLY ROGEFIS CLERK WALTER LEE BOYD SLAGE PETER GEORGE T4 MILES WALKER CLEMONT DEDEAIJX OFUJELL VILSTJFIN WILLIAM CLEARY IWRBERT WILLIAMS EFLED RIOLNAGEL BENNY SPELLS KENNETH INMAN RAYMOND BAILEY ORCEAIT DAVIS GERRY MACK BOYD KELTO THOMAS LORD RALPH WATSON CHESTER SAWICKI PHILLIP MEGL VERNON RALPH IT WARNER MEVIS RONALD KENNEDY PAUL ROSS HERMAN HEAD GERALD NORMAN PAUL MILLER THOMAS MULLIGAN IDNNIE PAYNE ROJ3ERT MASON AND KENNETH MARSHALL CIVIL WO PLAINTIFFS VS PARKE DAVIS C0R UPJOHN OF ACTION 31172 MICHIGAN CORPORATION THE DELAWARE CORPORATION DEPARTMENT OF THE STATE OF MICHIGAN ELEANOR HUTZEL JAMES MAX FIBER WAVERS FLORENCE WADSWORTH ERNEST BROOKS FAREY JOHN RICE DUANE CRANE JOSEPH GROSS ROBERT COTTON AND GUS HARRISON DEFENDANTS MEMORANDUM OPINION PLAINTIFFS OF MICHIGAN STATE AND ALC PRISON HEREAFTER WERE COLWIC LED REFERRED PARKE ARE PRIVATE CORPORATIONS THE DRUGS THIRD DAVIS OF MICHIGAN PENAL INSTITUTIONS MICH JAMES PRISON HAS COW LAWS 791204 WADSWORTH ERNEST THE TWO OF THE DEPARTMENT EXCLUSIVE PRISON THE LABOR AND BROOKS COMPANY RNANUFAC LURE OF CORRECTIONS JURISDICTION DEFENDANTS THE MICH‰AN THE INTERSTATE ENGAGED IN LAWS THE TERMS IN COMPANY AND THE UPJOHN DEFENDANT STALE SERVED UNDER AT JACKSON MICHIGAN TO AS JACKSON DEFENRIANTS OF OR HAVE SERVING OF SOUTHERN OF CRIMA INCIUS ELEANOR MAX BITER OF OVER URY RUTZEL FANCY RICE JOHN AND CORRECTIONS WHICH COMMISSION MICH CORRECTIONS JURISDICTION CORRECTIONS 2166 USC 28 TITLE ARE MICHIGAN NOT PURSUANT COMPANY RESEARCH ICHIGAN THE TO USE RIGHT WITH THE OWN EXPENSE PRISON STATE BECAME RESEARCH OF SOUTHERN AT THE STATE AND COMPLETED THE PROPERTY DRUG COMPANIES IS PARKE EACH DRUG OF THE RETAINING FOR CLINICAL THEY CONSTRUCTED BUILDINGS OR CORPORATION ORGANIZATION AT ITS THE DEFENDANT SO LONG AS CLINICAL RESEARCH DOFCNDANT WERE SUBSEQUENTLY TERMS OF THE CONTRACTS MICHIGAN OF BHE TWO SEPARATE THOSE AGREEN ENTS AT THE BUILDING BOTH BUILDINGS UNDER THE STATE TO INTO COMPANY AND TO CONSTRUCT COMPANY WAS PERMITTED CLINICAL UPJOHN THE PRESENT TO ENTERED 1983 42 NOVOMBOR OF 1963 IN DISPUTE DEFENDANT RISE GIVING TITLE AND OF USC 29 UPON TITLE 1343 OF CORRECTIONS DEPARTMENT AGREEMENTS WITH DAVIS IN 1337 FACTS THE BACKGROUND COMPLAINT BASED IS THE OF THE DEPARTMENT DIRECTOR IS OF DEPARTMENT 791201791203 CORN LAWS GUS HARRISON DEFENDANT THE SUPERVISES GROSS JOSEPH OF THE MICHIGAN INCMBERS ARE OR WERE ROBERT COTTON CRANE FLORENCE WATERS DTLANA CONDUCTED BY ANY PRISON OF SOULHERN ICHIGAN THE INVOLVES ULIDINGS JACKSON CLINICAL INMAT LAINTJFTS THE PLAINTIFFS WITH INSTEAD HOWEVER AND ON IN AMONG THE WERE NOT USED AS SUBJECTS OF THE UNDER THE CLINICS FOLLOWING JOB THOSE THE CLASS THEY PERFORMED VARIOUS THE OPERATION RRE OROUNED TOQETHER CARRIED PRESENTLY OF DRUGS ON VOLUNTEERS THE TESTING SEEK TO REPRESENT DRUG EXPC RIMENTS CONNECTION RESEARCH IN SERVICES THOSE SERVICES CLAS PARKE DAVIS COMPANY CLASSIFICATION CHIEF SERVICES CLERK PREPARATION DETAILS CLERK BAUBLE CHIEF COOK HEAD PORTER MAINTENANCE PERFORMED MAN OF PRISON CHECK LABELS COOKING DUTIES AND OTHER KITCHEN JANITOR AND MESSENGER MAINTENANCE AND MINOR REPAIRS PORTER AND NURSE SUPERVISOR THE RLPIOHN SERVICES TECHNICIAN CHIEF TRAINEE CLERK CLERK SAME AS ABOVE SAME AS ABOVE CLERICAL TASKS CLERICAL TASKS NURSE SUPERVISOR ACTS WITH NURSE SAME AS ABOVE CHIEF COOK COOKS AND SERVES SAME AS ABOVE KITCHEN ASSISTS IN KITCHEN ASSISTS IN KITCHCN POT AND MAINTENANCE HEAD PORTER PORTER MAN PAXI TASKS OF EEC AS NURSE IN CONNECTION CLINICAL TESTS COOK KITCHEN ATTENDANT PERFORMED PERFORMS SPECIFIC SUCH AS OPERATION MACHINE TECHNICIAN TECHNIESAN AND COMNASY CLASSIFICATION CHIEF JANITOR NIQHT MAINTENANCE REPALRS AND JANITORIAL TASKS JANITORIAL TASKS FOOD MINOR PLAINTIFFS WORE FORCED UPJOHN THAT ALLEGE DEFEND BY IN COMPANY ON HUNDRED WITH JACKSON TO WORK IN UP TO WEEK OF THE AS THOSE ONE AS ZRTUCH FROM AT WAGES RANGING 125 25100 AND TO ONEPOLLAR INMATES COMPANY AND THE REPRESENTATXVES BASIS HOURS PER 025 THIRTYFIVE PARKE DAVIS REGULAR 112 TWELVE OTHER AS OF CORRECTIONS DEPARTTMENT CLASSIFICATIONS WELL AS CONJUNCTION CO MICHIGAN THEY PER DAY ON THE IN TOF COUNT TO RECOVER BASIS THEIR OF THESE AMENDED COMPLAINT DEFENDANT FROM THE BETWEEN THE COMPENSATION MINIMUM WAGE PRESCRIBES FLSA 1938 OF THEIR LABOR AMENDED COMPLAINT STANDARDS ARE ENTITLED DIFFERENCE LABOR BETWEEN ILLEGAL RESULTED COMPANIES PLAINTIFFS THE WAGE AS OF THE SECTION THE IN IN THE DEFCNDANLS ENRICHMENT AMOUNT BY WHICH SERVICES PLAINTIFFS UNJUST EXCEEDS PLAINTIFFS OTHER THE THE THE FAI THEN PLAINTIF THE FOR THEIR ALLEGES THAT THE DRUG COMPANIES HAS OF DEFENDANTS REASONABLE AMOUNT PAID DAVIS IF DRUG COMPANIES LAWS AND ALSO CONTEND IN THAN PARKE COUNT II 408381 LABOR BY THE CORN OF BY THE MICHIGAN CORN LAWS MICH ACT THAT THEY RECEIVED AMENDED COMPLAINT 900305 THE AND SEQ IN CONTEND PRESCRIBED MICH OF THE PLAINTIFFS UNDER ET DEFENDANT THE COMPENSATION III LABOR STANDARDS 201 PLAINEIFFS FROM THE WAGE LAW OF 1964 UTILI USC THE DIFFERENCE FOUND TO BE INAPPLICABLE IS RECOVER TO COUNT TO ACT AND THE MINIMUM MINIMUM 29 LABOR ENTITLED THEY ARC THEIR FOR FAIR BY THE AMENDED AS THAT DRUG COMPANIES RECEIVED CONCLUD PLAINTIFFS ALLEGABIONS DRUG VALUE OF BY DEFENDANTS COUNL III COMPANY AND THAT IHE IS UPJOHN COMPANY HAVE BEEN ILLEGAL USE OF PLAINTIFFS STATE STRUCTURE THE HOUSING IV COUNT IN AND HAS RESULTED THIRTEENTH IN AMENDMENT THE DENIAL TO PLAINTIFFS GUARANTEED BY THE VIOLATIONS OF THEIR ONE MILLION JUDGMENT AS AND HAVE MAINTA3NE1 CORRECTIONS COMMISSION AS TO THEM CONTRARY TO AND OF LAWS AS FOR RIGHBS MOTION NOW FILED TH ALLEGED PLAIN SEEK IV CLAIM ACTION DIRECTOR HAVE ALSO FILED AND COMPANY AND MOTIOR FOR SUMMARY TO DISMISS MOTION UPON WHICH FOR SUMMARY UPJOHN FILED TURN IN III ITS OR THE CONSTITUTION THE DEFENDANTS CLASS ALL SCRVXTUDE AMENDMENT FOR AN ORDER THAT AS OF THE LAW DUE PROCESS OF OF EQUAL PROTECTION III TO STATE MOTION BY LAW DAMAGES FROM DEFENDANTS ON COUNTS FAILING THE UPJOHN DEPRIVATION TO THE FEDERAL COMPANY HAVE PARKE DAVIS IN AND DEFENDANTS THAN THOSE REQUIRED CONSTITUTIONAL DOLLARS ON COUNT THE ILLEGAL COMPANY AND DAVIS INVOLUNTARY FOURTEENTH PLAINTIFFS JUDGMENT PARKE WITHOUT OF PLAINTIFFS HOLDING LABOR BY ALL RESULTING IS THE THAT ALLEGE WAGES LESS OF PLAINTIFFS PROPERTY THE PLAINTIFFS OF NOMINAL IE BUILDING THE CLINIC BY DEFENDANTS THEPAYINENB COXNP OF OF PLAINTIFFS UTILIZATION FOR ACQUISITION LABOR BY THE OF SOUTHERN MICHIGAN PRISON FROM THE ENRICHED UNJUSTLY RELIEF COUNT IX CAN BE GRANTED CANNOT BE PLAINTIFFS ACTION DEFENDANT DEPARTMENT MOTION THCC NOTIONS CORRECTIONS MEMBERS OF THE THE TO DBIRNISS ATE THE NOW BEFORE OF COMPLAINT THE COURT DAVIS AND UPJOHNS FOR AN ORDER THAT BE NAINPAINED SUIT CAITN PARKT PLAINTIFFS CO THEIR IN ACTTON STATE PLAINTIFFS COMPLAINT CLASS AS NUMEROUS OTHER PEOPLE WHO EITHER ARE OR HAVE EEN INMATES IN THE STATE PRISON AT JACKSON MICHIGAN OF SOUTHERN MICHIGAN WHO HAVE THE SAME CAUSE OF ACTION AS HEREIN AFTER SET FORLH ON THE PART OF THE IIAMED AND THE NAMED PLAINTIFFS PLAINTIFFS ADEQUATELY REPRESENT SUCH UNNAMED PEOPLE ACTION IS BROUGHT PURSUANT TO RULE 23 THIS PROCEDURE OFL OF THE FEDERAL RULES OF CIVIL WHOSE NUMBER MAKE ALL SUCH BEHALF OF PEOPLE THERE ARE TO HAVE THEM JOIN AS PLAINTIF IMPRACTICAL THE NAMED PLAINTIFFS ADEQUATELY REPRESENT SAID IT CLASS DEFENDANT UPJOHN THAT ORDER DECLARING CLASS COMPANY HOWEVER ACTION UNDER THE PRESENT HAS AN FOR CASE CANNOT BE AIAINTAINED OF THE FEDERAL RULE 23 MOLION FILED RULES AS OF CKVIL PROCEDURE RULE 23 CLASS ALL WHO WISHES PLAINTIFF TO OVERCOME TWO HURDLES ACTION SATISFY REQUIRES CONDITIONS THE OF RULE FIRST 23A TO BRING HO MUST WHICH ARE THE CLASS IS SO NUMEROUS THAT JOINDER THERE OF ALL MEMBERS IS IMPRACTICABLE TO THE LAW FACT OF OR COMMON ARE QUESTIONS THE OF CLAIMS OR DEFENSES THE CLASS OF THE ARE TYPICAL PARTIES REPRESENTATIVE AND CLAIMS OR DEFENSES OF THE CLASS AND WILL FAIRLY THE REPRESENTATIVE PARTIES OF THE ADEQUATELY PROTECT THE INTERESTS CLASS AFTER OF RULE HIS 23A ACTION OF RULE IS 23B THE SATISFYING HAVE BEEN NTEL APPROPRIATE RULE 23B COURT THAT THE LITIGANT ALL THE CONDITIONS MUST ESTABLISH UNDER ONE OF THO THREE PROVIDES THAT THAT SUBDIVISIONS AN ACTION MAY BE MAINTAINOD AS CLASS ACTION IF THE PREREQUISITES OF SUBDIVISION AND IN ARE SATISFIED ADDITION THE PROSECUTION OF SEPARATE ACTIONS MEMBERS OF THE BY OR AGAINST INDIVIDUAL CLASS WOULD CREATE RISK OF INCONSISTENT OR VARYING ADJUDICATIONS WITH RESPECT TO INDIVIDUAL MEMBERS OF THE CLASS WHICH WOULD ESTABLISH INCOMPATIBLE STANDARDS OF CONDUCT FOR THE PARTY OPPOSING THE CLASS OR WITH RESPECT TO INDIVIDUAL ADJUDICATIONS MEMBERS OF THE CLASS WHICH WOULD AS MATTER BE DISPOSITIVE OF THE PRACTICAL INTERESTS OF THE OTHER MEMBERS NOT PARTIES TO THE ADJUDICATIONS OR SUBSTANTIALLY OR IMPEDE THEIR ABILITY TO PROTECT IMPAIR THEIR INTERESTS OR THE PARTY OPPOSING THE CLASS HAS ACLED OR REFUSED TO ACT ON QRONND GENERALLY TO THE CLASS APPLICABLE THEREBY MAKING FINAL RELIEF OR APPROPRIATE INJUNCTIVE CORRESPONDING DECLARATORY RELIEF WITH RESPECT TO THE CLASS AS WHOLE OR THE COURK FINDS THAT THE QUESTIONS OF LAW OR FACT CONVNON TO THE MEMBERS OF THE CLASS PREDOMINATE OVER ANY QUESTION AND AFFECTING ONLY INDIVIDUAL THAT CLASS ACTION IS SUPERIOR TO OTHER AVAILABLE METHODS FOR THE FAIR AND EFFICIENT OF THE CONTROVERSY ADJUDICATION THE MATTERS PERTINENT TO THE FINDINGS INCLUD2 THE INTEREST OF MEMBERS OF THE CLASS IN INDIVIDUALLY CONTROJLING THE PROSECUTION OR DEFENSE OF SEPARATE ACTAONS THE EXTENT AND NATURE OF ANY LITIGATION CONCERNING THE CONTROVERSY ALREADY COMMENCED BY OR AGAINST MEMBERS OF THE CLASS THE DESIRABILITY OR OF THE UNDESIRABILITY CONCENTRATING LITIGATION OF THE CLAIMS IN THE PARTICULAR FORUM THE DIFFICULTIES TO BE ENCOUNTERED IN LIKELY THE MANAGEMENT OF CLASS ACTION ME ONCE PLAINTIFF THE REQUIREMENTS NOT ONLY ON HIS HAS DEMONSTRATED OF RULE 22 OWN BEHALF THAT HE CAN BUT HIS SUIT THEN PURSUE ALSO ON BEHALF COMES WITHIN THE OF ACTION ALL OTHER PERSONS SIMILARLY PARTIES TO THE CLAIMS STANDARDS ACT SITUATED FOR MINIMUM LIMITS THE BINDING 23 RULE FLSA BECOME PARTJES WAGES UNDER THE FAIR HOWEVER CANNOT BE MAINTAINED UNDER THE LHOSE PERSONS ARE NOT IFTIGATION ACTION UNDER ALTHOUGH THAT EFFECTS IS OF BECAUSE CLASS AS USC 29 JUDGMENT TO PERSONS WHO HAVE LABOR 216B ADJUDICATING FILED WRITTEN RIGHTS CONSENT TO SUIT TO THE ANY EMPLOYER WHO VIOLATES EHE PROVISIONS OF SECTION 206 OR SECTION 207 OF THIS TIBLE SHALL BE LIABTH TO THE EMPLOYEE OR EMPLOYEES AFFECTZECL IN THE AMOUNT OF THEIR UNPAID MINIMUM WAGES OR THEIR UNPAID OVERTIME COMPENSATION AS THE CASE MAY BE AND IN AN ADDITIONAL EQUAL AMOUNT AS LIQUIDATED ACTION TO RECOVER SUCH LIABILITY DAMAGES IN MAY BE MAINTAINED ANY COURT OF COMPETENT JURISDICKION BY ANY ONE OR MORE EMPLOYEES FOR AND IN BEHALF OF HIMSELF OR THEMSELVES AND OTHER EMPLOYEES SIMILARLY SITUATED NO EMPLOYEE SHALL BE PLAINTJFF TO ANY SUCH ACTI ON UNLESS HE GIVES HIS CONSENB IN TO BECOME SUCH WRITING PARTY AND SUCH CONSENT IS FILED IRA THE COURT IN WHICH SUCH ACTION IS BROUGHT EMPHASIS ADDED 29 PAR USC HENCE PLAINTIFFS ALLEGES RULE CLAIM 23 NEITHER 216B CONCEDE UNDER THAT THE VLS1 AND THOSE INMATES NOT BENEFJT SINCE IT COUNT OFF THEIR COMPLAIN CANNOT BE MAINTAINED FILING WRITTEN UNDER CONSENTS FROM NOR BE BOUND BY ANY JUDGMENT CAN RENDERED ON COUNT NEVERTHELESS AND IV OF THEIR ACTION YET IS THE APPLICABLE COMPLAINT ASSUMING TO REQUIREFTIENTS PLAINTIFFS THE OF ARE RULE 23 REMAINING THAT CONTEND THAT MAINTAINABLE RATHER COUNTS USC PLAINTIFFS RULE HAVE NOT BEAN II RULE 23 AS THAN 29 AS COUNTS MET III CLASS 216B ARGUE THE FIRST SO NUMEROUS THAT CLASS 1NORACTICABILITY CONSTXTUTES CIRCUMSTANCES SURROUNDING 836 2ND AIR 845 TH ON CLASS FIDELI 170 IS 1968 ANACONDA BUT FACTOR PLAINTIFFS HAVE THE CLASS MERELY CONTAIN FAILED ATTORNEY DURING ORAL CLASS WOULD PROBABLY SINCE THIN LAUION MM 293 FRD COMYANY 43 TSTXMATE IT MUR THE ALLEGE THE CO IT BETWEEN CANNOT BE USED TO ESTABLISH 70 FOR SIZE PLEADINGS THERE ARE IMPRACTICABLE THIS TO HAVE COURT BY PLAINTIFFS COIRVNENTED AND 200 THOB THE PERSONS BY ANY MATERIALS BEFORE SPECUJATIVE ARID SPEED PROSPECTIVE CLASS THAT OF SAME CAUSE OF ACTION WAS SUPPLIED BE DEEMED THAT 1968 CASE THEIR INFORMATION ONLY WAS UNSUPPORTED EDA APPROXIMATE STATEMENT ARGUMENT WHEN HE CONTAIN 452 INSTEAD HAVE THE SIZE FSUPP 164 THE PRESENT IN OF CONSIDARED TO BE PHIIAD4PHIAELECTRIC WHO ON CLASS GIVEN COURT INDUSTRIE TO EVEN PLAINLIFFS HAS BEEN THE OF THE IMPRACTICABILITY WHOSE NUMBER MAKE AS F2D 3S0 OF PROSPECTIVE FACTOR CONCLUSIONARY NUMEROUS OTHER PEOPLE THEM JOIN EDENS NURR THE CANNOT BE THE AND TO GUIDELINE DEMARCO SEEK TO REPRESENT THEY AS THE SHOULD NOT BE COURTS SIGNIFICANT ACCORD BRASS THAT CASE HAND WHILE LITTON SDWY OF WHAT UPON ALL DEPEN6S NOT DETERMINATIVE IT JOINDER IS 1S68 OTHER MEMBERS IS IS MEMBERS RESOLUTION THE JOINDER OF THE PRACTICABILITY ACTION 23 OF ALL UPON MERE NUMBERS TO DEPEND AS RULE JOINDER 23A1 IMPRACTICABLE SO RIGID TO PREREQUISITE IS AS TO MAKC JOINDER SO NUMEROUS C4 SEYMOUR REV LUCAS REQUIRED SEACIRAVE GQ BECAUSE MORE THAN COURT FOR MET DOES NOT IS ESTABLISH CLASS 338 AS SPECULATION TO DETERMINE 64 IF THE DCONN 1953 75 1959 WITH TO CLASS MUST BE PRESENTED APPROXIMATE NUMBER OF CLASS COURT CAN DECIDE IF SIMPLY HAVE THOSE TO MEANS THAT CAN BC ASCERTAINED OF ALL JOINDER IS OF 23 FROM WHICH BY PLAINTIFFS MEMBERS SIZE REQUIREMENT IT PRECISION SEE DMINN 1967 348 MEAN HOWEVER THAT PLAINTIFFS SIZE 845 AT SUPRA 2ND CIR 365 FSUPP 277 INFORMATION THE FRD 23 F2D GROUNDS 270 OTHER OFI CC MDI DENS DEMARCO SURROUNDING CIRCUMSTANCES UNDER THE IMPRACTICABLE MEN SO TNC BEFORE WOULD HE IMPRACTICABLE SINCE MENT OF 23A HAS BEEN NOT MAINTAINABLE AS FOR AN ORDER DECLARING CLASS ACTION RULE THOSE COUNTS DEMONSTRATE 23AL THEIR MOTION COUNT CANNOT GRANTED FOR THE PROCEED AS RULE 23 REACONS PREVIOUSLY 10 III AND CANNOT BE PURSUED TO POSSIBLE THAT II THE REQUIRE THUS DEFENDANTS ACTION SUBJECT SHOW THAT TO COUNTS SATISFIED CLASS GRANTED IS LATER PLAINTIFFS HAVE FAILED PTHINTITFS SUIT FOR CLASS STATED TV MOLION AS REVISION IF COMPL5ES WITH SIMILAR ACTION ORDER THAL IS AR AJSO MOTION FOR SUNMARY JUDGMENT ON COUNT DY DNFENDANT DRUG COMPANIES FILED IN THAT ALLEGE THE COMPANIES THE IN LABOR LABOR ETSES DEFENDANT JUDGMENT ON THIS DRUG COMPANIES AND THE CLINICS BY THE PRESCRIBED AMENDED 29 USC 5201 HAVE MOVED FOR SUMMARY 56C RULE TO COUNU PURSUANT PROCEDURE WHICH OF CIVIL AS DRUG AMOUNTS PLAINTIFFS RESEARCH OF 1958 ACT STANDARDS THE COMPENSATION WAGE PLUS OVERTIME MINIMUM RULES BETWEEN DIFFERENCE FROM DEFENDANT TO RECOVER ENTITLED ARE FOR THEIT RECEIVED FAIR THEY PLAINTIFFS AMENDED COMPLAINT OF THEIR COUNT OF THE FEDERAL PROVIDES JUDGMONT SOUGHT SHALL BE RENDERED DEPOSITIONS FORTHWITH IF THE PLEADINGS AND ADMISSIONS ANSWERS TO INTERROGAT IF AFFIDAVITS TOGETHER WITH THE ON FILE ISSUE AS ANY SHOW THAT THERE IS NO GENUINE FACT AND THAT THE MOVING TO ANY MATERIAL MATTER TO IS ENTITLED JUDGMENT AS PARTY OF THE LAW MATERIAL 56C PLAINTIFFS MAINTAIN FACT TO BE DECIDED DEFENDANTS THEY MOTION DEFENDANLS AND UNDISPUTED FACTS ARE IT IS SUMM JUDGMENT CONTOND THAT THEIR LAW ENTITLE5 THEY ARC IN ISSUES OF UNDER RULE MUST BE DENIED THE AFFIDAVITS ANSWERS TO DEFENDANTS THE PARTIES GENUINE AND THUS COUNT INTERROGATOTIES SUBMITTED BY SWOTNTESLIMOFLY APPLICABLE ALTHOUGH OF COUNB THERE MUST THEREFORE BE VIEWED PLAINTIFFS THE FOR AS WELL AS ARE UNCONTROVERTED FACTS IN OTHER HAND ON THE HAVE FILED THAT AS POSITION BY PRESENTING THAT ON THOSE THEM TO JUDGMENT DISAGREE ACCORD THAT THE ON THE ONLY FACLUAL QUESTION POSTURE OF LAW RAISCD BY THIS COUNT IS OF EITHER DEFENDANT STANDARDS ACT WHCTHER PLAINTIFFS WITHIN THAT ACT THE AS RNE ARNENDE6 ARE OF THE DEFINES EMPLOYEES FAIR LABOR EMPLOYEE AS LII ANY INDIVIDUAL EXCEPT THAT SUCH TERM PURPOSES OF SUBSECTION EMPLOYED BY AN EMPLOYER SHALL NOT FOR THE OF THIS SECTION INCLUDE ANY INDIVIDUAL EMPLOYED BY AN EMPLOYER IF SUCH INDIVIDUAL IS THE ENGAGED IN AGRICULTURE PARENT SPONSE CHILD OR OTHER MEMBER OF THE EMPLOYERS IMMEDIATE FAMILY OR WHO IS EMPLOYED BY AN EMPLOYER ANY INDIVIDUAL IF SUCH INDIVIDUAL IS ENGAGED IN AGRICULTURE HAND HARVEST LABORER AND IS PAID EMPLOYED AS ON IN AN OPERATION WHICH HAS PIECE RATE BASIS BCCN AND IS CUSTOMARILY AND GENERALLY RECOG NIZED AS HAVING BEEN PAID ON RATE PIECE BASIS IN THE REGION OF EMPLOYMENT COMMUTES FROM US RESIDENCE THE DAILY PERMANENT TO FARM ON WHICH HO IS SO EMPLOYED AND HAS BECN LESS THAN THIRTEEN EMPLOYED IN AGRICULTURE WEEKS DURING THE PRECEDING CALENDAR YEAR 29 USC AN EMPLOYER IS 203E DEFINED AS OR ANY PERSON ACTING DIRECTLY IN THE INTEREST OF AN EMPLOYER INDIREELLY IN RELATTHJI TO AN EMPLOYEE BUT SHALL NOT INCLUDE THE UNITED STATES OR ANY STATE OR SUBDIVISION OF STATE EXCEPT POLITICAL WITH RESPECT TO EMPLOYEES OF STATE OR SUBDIVISION POLITICAL THEREOF EMPLOYED IN HOSPITAL OR SCHOOL INSTITUTION REFERRED TO IN THE LAST SENTENCE OF SUBSECTION OF THIS SECTION OR IN THE OPERATION OF RAILWAY OR CARRIER REFERRED TO IN SUCH SENTENCE OR ANY LABOR ORGANIZATION OTHER TNAN WHEN ACTING AS AN OR EMPLOYER ANYONE ACTING IN THE OF OFF3CCR OR AGENT OF SUCH LABOR CAPACILY 29 ORGANT2ATLCTRL 203D TJ TO EMPLOY WORK 29 IN TURN USC MOANS TO SUFFER 203G 12 OR PENNIT TO LITERAL IN WOULD ACT THE AS 6TH CBS 1943 FOR THIS EXISTS RELATIONSHIP TO THE LIMITED HIS TECHNICAL LEGAL EMPLOYERS SERVANTS US 366 28 1960 33 THAT AND IS THIRD PERSONS US 333 SILK NOT TO AN PERTINENT CONCEPTS STATES TO WHITAKER RESPONSIBILITY UNITED FORCED FLSA OF THE THE MEANING 80 WHEN AN EMPLOYMENT TO DETERMINE REALITY INC HOUSE COOPERATIVE F2D 78 136 COURTS HAVE BEEN REASON WITHIN ONE OF ECONOMIC IS SANDERS TEST MORE MEANINGFUL DEVISE ENCOMPASS ALL NOTE PARTIES WALLING HUNANITY EMPLOYED TEST THE CONTAINED OF THOSE DEFINITIONS APPLICATION FOR 704 ACTS OF 713 1946 PLAINT ECONOMIC INSTEAD IS WHETHER EMPLOYMENT MASONCOMP JUDGMENT PROPER IF IN VERY UHAT NOTED 249 OR 334 ITS AT EXISTS DID OF FLSA SILAS KENNEDY VACATE WAS INVOLVED SUMMARY DISPOSAL SUMMARY UNDER THE 1948 ISSUE ANY THE QUESTION RAISING COURT IN COMPREHENSIVE 257 THAT SUPREME THE RECORD HAD PRESENTED FINDINGS TO CITE CONTENTION RELATIONSHIP OF SUMMARY JUDGMENT PRECLUDE CASES BUT CONSIDERATIONS HOWEVER HAVE FAILED US 334 WHERE THAT SPECIFICALLY WHICH STATES THE UNITED AND WHILE FACTS NATURE INAPPROPRIATE AN INVOLVES TEST TO SUPPORT THEIR AUTHORITY JUDGMENT THIS COMPLAINT OF THEIR TO COUNT THE OF THE APPLICABILITY NOT CONTEST PLAINTIFFS TREATMENT OF THAT FACTUAL PECIALIARLY LEGAL TEST REALITY ALLEGE DO SURTUNARY THO COURT WOULD HAVE BEEN MORE SOLID STATEMENT OF AGREED BASIS SUBSEQUENT DISTRICT FOR THE EASTERN UNDER THE FAIR LABOR ANTS WERE NOT THE KENNEDY TO OF TEXAS STANDARDS SUMMARILY ACT AFTER AFFIRMED FACTS BEFORE LOWER COURT WERE SUFFICIENT THE FIFTH GROUND THAT ON LHE THE FINDING COURT OF APPEALS COUR ADJUDICATED THE CONTRACTORS INDEPENDENT THE DISTRICT DECISION RIGHTS DOFOND CIRCUIT THE UNCONTROVERTS TO WARRANT ITS FINDNG ULTIMATE THAT APPELLEE CONTRACTOR WAS NOT AN INDEPENDENT REASONABLE INFERENCE DEDUCED FROM AN UNCONTROVERTED THE CXISTENCE NUMBER OF FACTS MAY ESTABLISH ENTITLES ONE OF THE OF AN ULTIMATE FACT THAT MATTER OF LAW TO JUDGMENT AS PARTIES DID THIS CASE WHEN THIS HAPPENED AS IT IN AND SUMMARY JUDGMENT IS SOUGHT RULE 56C SHALL BE REQUIRES THAT JUDGMENT RENDERED FORTHWITH CREEL LONE STAR 968 DEFENSE CORP 171 F26 964 5TH CIR FIRLY RCVD 1948 UNDER TO THAT IN CONTAIN FACTS TO THE IF FACTS THE IS CDNTRARICTORY DEFCNDANT PRESENT IF THEN THE OR IF COMPREHENSIVE OF THE DRUG COMPANIES WOULD BE RECORD CONTAINS THIS COURT CAN ARE NOT PLAINTIFFS REALITY US REASONING FROM WHICH ON THE OTHER HAND SUFFICIENTLY RELATIONSHIP JUDGMENT ECONOMIC AND DETENDANT SUMMARY JUDGMENT OF DEFENDANTS MATERIAL SUPRA UNCONTROVERTED SUFFICIENT CONCLUDE KENNEDY COURT OF APPEALS ENTITLED 339 1950 497 CIRCUIT ON OTHER GROUNDS EMPLOYCE5 SWORN TESTIMONY ON THE RECORD DOES NOT PICTURN DEFENDANTS OF PLAINTIFFS MOTION FOR SUMAR THE JAEKSO MUST BE DENIED IN DECIDING RESEARCH CLINICS DEFENDANTS WHETHER ARC IN BOTH PARTIES THE INMATES ECONOMIC AGREE THA 34 WORKING REALITY IS THE AT EMPLOYNER OF COURT MUAT CONSIDER THE EXTENT THOSE TO WHICH INMALES WALLING THAT OF DEFENDANTS THE THE TO SUPPORT AND CONTROL SUPRA IT ONLY LIMITED EXERCISE THE POSITION IS CONTROL OVER HAVE WARDEN OF THE STATE KROPP AND OVER HIRING DEFENDANTS CONTENTIONS OF GEORGE AFFIDAVIT TIRE HAVE NO AUTHORITY THEY THEIR HIRE CAN SANDERS XT THEY CAN AND THAT INMATES FIRING DEFENDANTS FILED PRISON OF SOUTHERN MICHIGAN INHIS TREATMENT OF PRISON DIRECTOR DETERMINES COMMITTEE CATION INCLUDING ASSIGNMENTS TREATMENT AND THE SIDER REQUESTS MATES RESEARCH THE OF INMATES THE DIRCCTORO CON FOR THE ASSIGNMENT OFFICIALS CAN PLACE IN OF THE DRUG OVER THE OBJECTIRNS CLINICS CLASSIFI HOWEVER WILL AND UPJOHN ALTHOUGH PRISON THE PRISON CLINICS CORMUITTAC FRC PARKEDAVIS AT WORK IN THE WORK ASSIGNMENT EVERY TO THE SWEARS THAT WITH ACTING CLASSIFICATION INMATES OF CERTAIN WARDEN KROPP AFFIDAVIT COMPANIES MOREOVER IS TREATMENT SIMILARLY DRUG COMPANIES INMALES PARTICULAR REQUESTS HIS DEPUTY THE THE REMOVED INMATES FROM THE WORK ASSIGNMENTS INMATES PARTICULAR OF TREATMENT RESEARCH CLINICS AND HAS ASSIGNED OF THAT THE CLIRIICS 15 HE DRUG REMOVE THOSE THAT SHE HOURS PERFORMED BY INMATES EXERCISED TO BUT FROM WARDEN KROPP MAINTAINS FINALLY TASKS THE OF ASSIGNMENTS DIRECTOR OF REMOVAL OF INMATES WARDEN HAS THE POWER TO DISAPPROVE WORKED AND THE CERTAIN THAT CAN BE DENIED THE DIRECTOR ROPP THE KNOWLEDGE OR APPROVAL THE CASE AS IN MAY REQUEST COMPANIES FOR HA AND WITHOUT ASSIGNMENTS TO WARDEN RESPONSIBLE WORK ASSIGNNIENTS FROM THEIR CLINIC ACCORDING POWER IN THE ON ALL CASE OF THE DEFENDANT INSTANODS BY THE ASSIGNED PERFORM SPECIFIC TASKS CLINIC HAD NO NEED TO THE UPJOHN PRISON WERE SOMETIMES REQUESTS THE BY UPJOHN OFF FILED SAME EFFECT INMATES FROM THEIR OF THEIR TASKS CLINIC WERE IN THE PURSUANT SUPER UPJOHN TO AUTHORITIES AND CLASSIFICATION THE WITH TO ASSIGNED BY UPJOHN PERSONNEL BY PRISON SOME COMMITTEE ALTHOUGH HELP APPROVAL VETOED TO REMOVE RMATES FROM THE CLINIC UPJOHN WERE IN INMATES UPJOHN INSTRUCTIONS SPECIFIC INMATES AT THE TO THE CLASSIFICATION PRISON TOOK TIME RULES WITHOUT VISOR THAT FOR ADDITIONAL CLINIC IS AFFIDAVIT STATOS AND AS WARDEN KROPPS TO WA AT JACKSON CLINIC OF THE ADMINISTRATOR WI1LY OF RALPH AFFIDAVIT THE ALSO INTRODUCED COMPANY HAS UPJOHN CONRNTITTECI SOME INSTAITEES DENIED THE ANSWERS TO INTERROGATORIES WHICH PARKEDAVIS FURTHER CEEDING BUTTRESS THE ACCORDING TO THOSE ANSWERS PERMITTED TO SELECT CLINIC CLINIC NO 16 CLINICS ANSWER THE COMPANIES FOR TO KEEP AN INMATE NO BY PRISON TO THE 16 RESEARCH AUTHORITIES WORKING IN ASSIGNED AUTHORITIES 13 KROPP THE INTERROGATORY ANSWER AND THC HOURS WORKED BY INMATES WERE REGULATED PRO DRUG COMPANY WAS EVER THE PRISON OVER DRUG COMPANY OBJECTIONS AND OF WILLY ASSIGNMENT NO AND SUMMARY JUDGMENT AFFIDAVITS NEITHER AN INMATE INTERROGATORY ANSWER COULD REQUIRE IN MAY BE EXAMINED OF BOTH UPJOHN TO THE INTERROGATORY PLAINTIFFS AFFIDAVITS DEFENR3ANTS CLINIC CONTROVERTED ARE SUMMARY JUDGMENT PROCEEDINGS FILED JUDGMENT MOTION THE AN EXAMINATION IN BY PLAINTIFFS FAILS ALLEGE CONTRADICTS UPJOHNS SWORN TESTATNONY SELECT THE INMATES TO WORK IN CLINIC AS UPJOHN BY THE COURT AFFIDAVITS TO THE STATES THAT HE IS THE IS THAT WERE NOT SO HIS AFFIDAVIT REVEAL OTHERWISE SUIWNARY JUDGMENT EXAMINATION THAT HE IS STATECB STATED AFFIANT THEREIN TO LESTIFY CLINIC AND APPROVED KNOWLEDGE OF THESE IN THE FACTS IS ESPICH COMNPEBENT AMERICAN HIS APPROVED COMPETENCY UNSUPPORTED ESPICH KNOWLEDGE ALL INMATES WHO HIS FACTS LACKS THE IT IMPORTANT IS CO AND FIRSTHAND BY ANYTHINQ NOT IN TO TESTIFY SCWFLRJY TO AFFIANT FROM PERSONAL HOW HE KNEW THESE OF AN AFFIANT AND PERSONS COULD NOT WORK THERE DOES PROCEDURE REQUIRES COMPETENT WHILE NOT CONSIDERED 56E RULE NOTES COMPANY PERSONALLY SAID CANNOT BE THAT COMPETENT THE WORKED IN CORRECTLY PLAINTIFFS DID THAT KNOWLEDGE MATTERS UPJOHN WHICH BE MADE ON PERSONAL SHOW AFFIRMALIVELY TESTIFY THE SUMMARY CONFLICT LEE ESPICH OF GAYLORD OF THE TO THE OPPOSITION SUCH TO REVEAL AFFIDAVIT SINCE CANNOT BE USED TO RESOLVE YET AMONG AFFIDAVITS MUST BE TRIED COUNT THAT WORK FORCE BY PLAINTIFFS SUBMITTED BY SWORN TESLIMONY CONCLUDE MATERIALS OF THE CLINIC DIRECTION THUS PLAINTIFFS CONFLICT ANSWERS CONCERNING AND INTERROGATORY AND THE ASSIGNMENTS TMT HOWEVER CONTENDS ATTORNEY AFFIDAVIL INASMUCH SAFEGUARD TO THE THAT TATTERS HAMILTON CONTAINOD OR AS OF CROSS IT BE SHOWN THEREIN GLASSCO 254 FSUPP 271 LIENSON IS 893894 F2D S89 1970 90 EDPA 1967 IT LABORATORY DIFFICULT IS FROM FIRSTHAND TO TESTIFY PERSONALLY THAT APPROVED RULE PLAINTIFF5 AFFIDAVIT ATTORNEY HAS INMATES BOYA SLAGER CHESTER SAWICKI AND CALVIN CLINICS PORTIONS OF DEFENDANTS AND THOSE WHO ARE TO REFERRING BE STRICKEN SUPPORT THE SELECTED CLE SIMS THAT FOUR FILED PARTIES AFFIDAVITS SWORN TESTIMONY DRUG COMPANIES CLIFLXC ITS IN FAILING AS 56E OF JACKSON RESEARCH THE UPJOHN WHO WOTKOD WILL OF INMATES UPJOHNS SLECTION ESPICH ON WHETHER UPJOHN KNOWLEDGE INMATES SINCE INDCCD HOW HE COUT9 BE COMPETENT TO SEE OF ESPICHS PORTION TO CONFORM WITFL ALL ACCORD GREEN WHO WORKED IN ONE OF THE INMATES SIMPLY HENCE AR 7TH DEFLEAUX WHO WORKED IN TO THE PRESENT RATHER PRISON INMATES OTHER AFFIDAVITS FOR THE SUIT THAN CONTRADICT AUTHORITIES WORK IN NOT THE THE RE5EARCH CLINICS AFFIDAVIT OF BOYD SLAQER WAS PLACED INTHE UPJOHN FOLLOWING PURPOSES OF WORK BY THE AFFIANT CLINIC FOR METHOD WHILE WORKING IN THE JUNE OF 1964 THE STATE PRISON OF OF MAIN HALL OFFICE COUNT CLERK ON THE AS SOUTHERN MICHIGAN WAS OFFERED OR MADE NIGHT SHIFT AWARE OF AN OPENING IN THE UPJOHN MCDICAJ THE WALLS LOCATED INSIDE RESEARCH CLINIC IN AFFI OF THE PRISON BY THE THEN INMATE CLERK THEN REQUESTED AND WAS GRANTED JOHN DUTZ ADMINISTRATOR THE CLINIC JITH AN INTERVIEW AFTER UHAT INTERVIEW WILLY RALPH PRISON CLASSIFICATION REQUEST WAS MADE TO T1 AND IN RETIRED MR SMCDGE NOW DIRECTOR WAS TAKEN BEFORE THE FORE PART OF JULY 1964 AND IT WAS COMMITTEE ON THE CLASSIFICATI HAD NO OFFICIALS DCCIDCD THAT THE PRISON AND IT WT APPROVED TO THE TRANSFER OBJECLION THAL STAYED ON TO HELP BREAK PROVIDED ANOTHER INMATE IN ON THE NAXN HALL OTFXCE THIS WAS DONE AND IN AUGUST OF 1964 JOB AN ASSIGNMENT CHANGE ORDER WAS SIGNED BY HANSEN DIRECTOR OF TREATMENT MR THAL WAS TO GO TO WORL AT THE INDICATING 1964 ON AUGUST 19 UPJOHN CLINIC CLINIC FULL TIME ON STARTED WORK AT THE UNTIL WHICH TONTINUED JULY 19672 BASIS OF CLEMENT FLEDEAUX AFFIDAVITS AND CALVIN SIMS SAWICKI CHESTER OTHERS WORKING AT THE CLINICS DID THEY WERE DRDERED TO DO SO BY OF THE DOPARTMENT OF CORREC REPRESENTATIVES TIONS JUST AS THEY WOULD BE ORDERED TO WORK AND REFUSAL IN ANY OTHER PRISON INDUSTRY RESULTED WOULD HAVE IN TO WOTK AS DIRECTLY AND COERCION TO THEM AND SUCH PENALTIES THREAT WAS UNDER THE CIRCUMSTANCES CLEARLY STATED IF NOT EXPRESSLY IMPLIED HE AND SO BECAUSE THE AFFIDAVITS ALSO SAY THAT VISION DEFENDANTS VISED CONCERNING OF CONTROL OVER INMATES HOWEVER ADMIT THE INMATES WORK DEFENDANTS THE ERIEF BY DEFENDANQS SUBMITTED RATHER IN THOSE AFFIDAVITS OVER INMATES SUPERVISION AUTHORITY OF PRISON AUTHORITY TO THE INDICATE CLINICS PARFORMANCC TO THE THAT WAS ALWAYS THE DRUG COMPANIES TO THE WHO FREQUENTLY DRUG COHIPANIES AFFIDAVITS CONTRARY DEFENDANTS SUBJECT SUPER OF CLINIC AND THE CLAIM SUPER CONTRADIC AGENTS DIRECTLY ON COUNT OFFICIALS DISAPPROVE THEIR DAYTODAY DO NOT THE COMPANIES TO THE ASSIGNED THAT UNDER THOSE STATEMENTS ATTORNEY SWORN TESTIMONY DR OF THE AND SLAYER SAWICKI DEFLEAUX WORKED DIRECTLY EMPLOYEES TO PLAINTIFFS DEFENDANTS SIMS AFFIANTS OF CIVILIAN ACCORDING LACK THE OF DAYTODAY OVERRIDING EXERCISED INSTRTTC LIONS THEIR TO INMATES THE IN SIMPLY IN ROUTINE COSIGNED DEFENDANTS CONTRADICTS TO SELECT INABILITY CI EXHIBIT THIS HIRING THE PRESENT FACTUAL HELP ONE PRESENTED HIRING IS NOTATION THAT OFTEN OF PROCEDURES VARIETY IN MUST PRODUCE DEFENDANTS MUST BE DIFFERENT AFFIANTS BUT SHORTHAND SXMPLY ATTAINMENT THE IN THE WORD TO CONNOTE ANY USED BY BUSINESSMEN RESULTING ON DISPUTE PROCEDURES BY WHICH DESCRIPTION ON PLAINTIFFS PLAINTIFFS BY DEFENDANTS FACTUAL IS OF PARKEDAVIS FACT AND SUCH DESCRIPTION FROM THE NOT MATERIAL MOTION CLINICS THE CLINICS CONLIN RN IS OF THE DESCRIPTION RESEARCH WE CANNOT AGREE WITH SUMMARY JUDGMENT INMATE ACQUIRE BY SIGNED AND ON THE DRUG COMPANIES WORK IN FUR THAT OFFICIALS THE SWORN TESTIMONY TO SHOW THERE POINT CONTROL ACTUALLY MAINTAINS AT OF INSUATES OF UPJOHN WILLY DEFENDANTS ATTORNEY INMATES LETTER COURT TO CONSIDER FOR THE AND PARKEDAVIS BY UPJOHN TO TNE BY DEFENDANTS CLINIC THE PLAINTIFFS FINALLY REFERRING IN WORKING TASKS FACT TO WHICH EXTENT 1NMCUC WERE SUPERVISED AWINIC OF THEIR PERFORMANCE THE THE INMATES AND THAT ANOTHER UNCONTROVERTED ANALYZING LETTER FR 1HE TENCE OF WORK FORCE MOREOVER IS HIRING ONLY THE ONE IN DRUG COMPANY PERSONNEL HAVE STIPULATED EXHIBIT OF THOSE FOR AN TO THE EXHIBIT FOR THE REFERENCE OF MANY LETTERS OUR COURTS THE PURPOSES LETTERS CONTAINING OR BY PRISON SUBMITTED HAVVU PLAINTIFFS LETTER OF THE EXAMMNAT PRESENT WHEN READ TOGCTHCI 20 BY DEFENDANTS OF THAT MOTION INDICATE SIGNED WHICH OFFICIALS CONSIDERATION TO ENTIRE THE CON LENT THAT EVEN THOUGH DEFENDANTS WAS DETERMINED THIS PARTIES COURT CONCLUDES ESTBLISHED ASSIGNED E9 G4 EXHIBIT WHEN INMATES OF THE WILL PRISON OFFICIALS THE TO THE APPROVAL OF PRISON CLINICS OFFICIALS MAY BE GIVEN THE THE DAYTODAY COMPANIES IN CLINICS FROM THESE THAT NEITHER OR FIRE BY PRISON INMATES INMATES OFFICIALS INMALES UPJOHN AND WORK PERFORMANCE OF THEIR THE NOR PARKEDAVIS TMT THE COMPANICQ AN OFFICIALS 21 ARE PER SUBJECT WORKING OF DEFENDANT FACTS UNEONLROVERTED THE TASKS BY DEFENDANT SUPERVISED PERFORMANCE WITHOUT TASKS BY PRISON OFF FROM THEIR ATE ASSIGNMENT MUST BE APPROVED BY HOURS WARKED BY INMATES OF THE DRUG PARTICUL THE CLINICS TIME HAVE BEEN SO REMOVED THE WHICH DRUG COMPANIES NOT THE THE CONSENT OR KNOWLEDGE WITHOUT COMPANIES IN WARKING DEC IDE DISAPPROVAL HAVE BEEN HAVC TESTIMONY REMOVED FROM THEIR BE BY BOTH FACTS FOLLOWING AND INMATES DRUG COMPANIES FORMED BY INMATES INMATES SUBMITTED SWAM THE DESPITE AND INMETRS TO THE CLINICS CONCLUDE ADMISSIBLE THE THE AUTHORITIES PRISON DETERININE HIRE CLINICS TO THE DRUG COMPANIES THE CLINXCS THE TO THE CLINICS CAMPIN APPROVAL NOT WARK IN WILL THAT BY UNCONTROVERTED OFFICIALS PRISON INMATES ALL REVIEWED CAREFULLY DOCUNWNTS AND INTERROGATORIES AFFIDAVITS THE SEE THE TO A5 HAVING BEEN OF INMATES ANTHORITIE BY PRISON REFER OCCASIONALLY MIGHT THE ASSIGNMENT OF INMATES HIRING AND PERSONNEL SNBJ ECT DRUG DRAG WORK AT THE COURT MUST HAD THE RIGHT SUPERVISION TO FINAL TO OF CONTROL FACT BUT THE CONTROL OR FINALLY OF THE DRUG COMPANIES ENTIRE FABRIC LII ARE EMPLOYEES OF WHETHER PLAINTIFFS ISSUE ON THE DETERMINATIVE UNDER THE ECONOMIC THE TEST REALITY TO THE COMPANIES RELATIONSHIP OF PLAINTIFFS NOT IS CLINICS THE IN WORKING INMATES FIRE HIRE COULD NOT DEFENDANTS THAT MUST BE CONSIDERED THE EXCLUDING DEFENDANTS KROPP ELEMENTS THAT SERVING PRISONCR5 PLAINTIFFS TO PERFORM SERVICES THE BY THE DEPARTMENT DEPARTMENT RNC5 FOR THE CASE BETVIEEN THE FAIR OF CORRECTIONS CLINIC IN STATE TO PAYMENTS NEVER AS JUST INDUSTRY WERE OPERATED BY OF MICHIGAN DRUG COMPANIES TO THE AT PER DIEM THE DRUG COMPANIES FOR ITS IN INMATES CONTRACTED RATES ESTABLISHED TURN REIMBURSED WORKING WITH THE AT THE CLI INMATES OF COMPENSATION INVOLVING PRISONERS LABOR AUTHORITIES DESCRIBED BEEN SERVICES FOR THEIR DRUG COMPANIES THE PAYMENT WALLS AND OWNED BY THE WERE PAID BY THE DEPARTMCNT THE PREVIOUSLY THE PRISON DRUG COMPANIES PLAINTIFFS HAVE AS PRISON ANY OTHER PRISON TO WORK IN CONVICTE WERE LAWFULLY DRUG COMPANIES FOR DEFENDANT WHICH INSIDE PERFORMED ADMISSIONS WERE ORDERED BY PRISON THEY WOULD BE ORDERED PHOSC SERVICES JACKSON IN SENTENCES CRIMINALS OF WARDEN PORTIONS OR ARE PLAINTIFFS BY PRESENTED JUDICIAL AND THE PARTIES AFFIDAVIT IS DISCUSSED ALREADY ANSWERS TO INTERRCGATORIES ESTABLISH THEY OF THAT RELATIONSHIP PICTURE COMPREHENSIVE AND ST AN ALMOST PRIVATE ACT IDENTICAL CORPORATION BY THE 22 REDERAL RELATIONSHIP WAS DECIDED DISTRICT UNDER COURT FOR THE WESTERN TH 1948 GUM ALSO HAD CLAIMING BE ENTITLED IN HUNTLEY CONTRACT STAMPING DEFENDANT PER DIEM THE REIMBURSED WHICH COMPENSATION THE STATE OF THE PRISONERS OF MICHIGAN WAS PAID ABOVE COMPLAINT TO THAT THE ACCORDING ALLEGED FOR THE BY THE STATE ALIOGATIONS UND THAT INMATES OF JUDGE MICHIGN STARR SAYING THE COMPLAINT IN THE PRESENT CASE FAILS TO ALLEGE FACTS SHOWING THAT PLAINTIFFS THE WERE EMPLOYEES OF THE DEFENDANT WITHIN THE WORDS AND OF EMPLOY EMPLOYEE MEANING THE ACT EFAIR LABOR STANDARDS ACT AS USED IN SHOWS THE COMPLAINT AFFIRMATIVELY IN FACT OF THE THAT THE PLAINTIFFS WERE EMPLOYEES AND NOT OF THE MICHIGAN PRISON INDUSTRIES CONCLUSION IT DEFENDANT IN VXEW OF THIS THE QUESTION OF TO DCTCRMINE UNNECESSARY THE VALIDITY OF THE CON BRACT BETWEEN THE DEFENDANT 79 FSNPP ATID AT PLAINTIFFS CASE FROM THE COMPANIES PRESENT EXERCISED THE PRISON INDUSTRIES 116 HOWEVER WOULD DISTINGUISH SUIT BECAUSE HERE THE DEGREE OF SUPERVISION 23 TO BY PRISON AND WHO WERE FURTHER PLAINTIFFS DIRECTION ON THE BASIS DISMISSED BY THE DEFENDANT WHO WERE PAID DEFENDANTS CASINGS WORK WAS SUPERVISED PLAINTIFFS COMPLAINT FORCE TO TO WORK IN ASSIGNED SHELL OF STATE LABOR PURSUANT CASINGS UPON THOSE PLANT CONVICT WITH DEFENDANT WITH THE WHEREBY WERE ALLEGEDLY PLAINTIFFS EMPLOYEES THE OF SHELL THE MICHIGAN CONTRACT CORPORATION DEFENDANT WOULD SUPPLY ASSEMBLY INTO THAT PLAINTIFF AS WAGE MINIMUM ALLEGED ENTERED COMMISSION WORK ON THE THE PLAINTIFFS WNMICH 110 PRISON OF JANLCSON FEDERAL TO THE MANU PRIVATE MICHIGAN INMATES CERTAIN FSUPP 79 CASE THAT 1948 IN COMPANY FURNITURE TO CORRECTIONS PRISON OF MICHIGAN DISTTITH THE HUNTLEV DEFENDANT DRUG OVER INMATES THE TO ASSIGNED EMPLOYEES DIRECTED THE ON THIS CASES IN THE THAT HUNT1C THEIR THE AND 112 THOSE STAMPING DIRECTION TO ASSUME THAT PLAINTIFFS IN THEIR ASSUMPTION CORRESPONDS THE ALLEGATION DEFCNDANT THE WORK AT TO THE THE INMATES SUPP AT 79 FOR COURT AGENTS SUPERVISED THAT PLANT STAMPING UNCONTROVERTED TRUE AS THE IJUNTLEY DEFENDANTS THE IN UNDER THE WERE TODISMISS ROUTINE TO DISTINGUISH HAD TO BE ACCEPTED ALLEGATIONS WAS REQUIRED PRISON WHO SUPERVISED PLANT OF THE OF THE MOTION ONLY WORK FORCE ETNPLOYEOS THE PURPOSES NOW BEFORE FACTS COURT THE IN ING OUR OPINION STARRS JUDGE THERE WERE NOT EMPLOYEES PRISONERS WITHIN THE MEANING OUR EASE WE BELIEVE CORPORATION SIMILARLY IN OF THE PRESENT REQUIRES OF THE THE CRIMINALS THAT ECONOMIC WORK ON THE THEY LBVE IS REALITY STATE IN BEEN AND PAID NORMAL RIGHTS THEIR ENTERPRISES THEIR FLSA THE MANUFACTUR WAS CORRECT ECONOMIC PLAINTIFFS REALITY FACTS ARE NOT LABOR OF THEIR THE STATE OFFICIALS BY PRISON PRIVATE PRIVATE NEED TO CORPORATIONS IN RETURN FOR THE CORPORATIONS HAVE TO DETERMINE WHEN ADDITIONAL WORK FORCE WORK FORCE MEMBERS WITH CONVICTED ARC PENITENTIARY BY THE STATE THEIR MEMBERS OF THE FOR RELINQUISHED THE DEFENDANT THAT PLAINTIFFS ASSIGNEE CONVICT SELECT OF THE THE DRUG COMPANIES USC OF THIS WHC THAT ON UNCONTROVERTED PENITENTIARY RATES ESTABLISHED DECISION THAT THE PRESENT DEFENDANT INCARCERATED PRISONERS BASED SITUATION FINDING EMPLOYEES AND HUNTLEY GROUND WOULD IGNORE THE SUPERVISION IN CONVICTS PRISON WORK IN SINCE WHILE CLINICS TO HELP TO REMOVE FROM WHOM THEY ARE DISSATISFIED AT CONTROL TO FIND TO RNATTERS THAT LABOR FORCE EXCEPT ON THOSE FACTS IN THAT THE MOST ROUTINE AN EMPLOYMENT RELATION CO SHIP IS EXISTS CONTRARY BETWEEN THE PRISONERS TO THE ECONOMIC MOREOVER WE FAIR THE SETTING OF WAGES MANY VARIABLES CRIMINALS IT GOVERNMENT IS THOSE VARIABLES DESIGNED FAIR 82 TO GIVE LABOR UNLIKELY AT THE 7298 1ST SEAS PP 34 MARKET 9260 1395 9265 AND MADE IT THE THAT WORKING CONSIDERATION SITUATION OF AND WHICH THAT ANY OF IT THE CONGRESS CONSIDERED GENERAL LEGISLATION ADOPTED RIGHT TO SUBSISTENCE 1505 SEE ALSO HAS HOWEVER 1507 7672 83 7885 CONG REC REP NO 1452 7STH CONG RECOGNIZED USED TO COMPETE WITH WAGE 1ST 75EH CONG BOSS THE POSSIBILITY THE FREE LABOR TO THOWINGLY TRANSPORT IN INTERSTATE ANY GOODS WARES OR MERCHANDISE PRODUCED OR MINED WHOLLY OR IN CONVICLS OR PRISONERS PARL BY EXCEPT CONVICTS OR PRISONERS ON PAROLE OR PROBATON OR IN ANY PENAL OR REFORMATORY INSTITUTLIR COMMERCE MANUFACTURED THIS CHAPTER SHALL NOT APPLY TO COMMODITIES MANUFACTURED IN FEDERAL DISTRICT OF COLUMBIA INSTITUTION STATE OR FOR BY THE FEDERAL GOVERNMENT OR BY THE DISTRIEL OF COLUMBIA OR BY ANY SFALE OR POLITICAI SUBDIVISION OF SLATE 18 USC 176L ON OF 1491 CRIME SITUATION POLKY ON REHABILITATION PEP NO 884 LABOR BEIIY PRISONERS REQUIRES TO INTENDED PRESENT CONG REC 7652 ACT STANDARDS CONGRESS OF CONVICT TIME EMPLOYEES CONG REC 1386 7283 OFFICIALS RELATIONSHIP THAT CONGRESS TO COVER THE WHICH ARE UNIQUE AFFECT DIRECTLY THINK INCARCERATED FOR BY PRISON ASSIGNMENT ACT CORPORATIONS OF THEIR REALITY DO NOT LABR STANDARDS THE AND PRIVATE NEVERTHELESS WHO IS PRISONER FOR PRIVATE BECAUSE FAIR PRISONER ACT ARE NOT PLAINTIFFS DEFENDANT DRUG COMPANIES DEFENDANTS HENCE OUTSIDE STATUS WE ONLY IN ECONOMIC AS THAT MOTION FOR THE COVERAGE OF THE ON THE PRESENT REALITY WORD IS OF EMPLOYEES DEFINED THE IN ACT ON COUNT JUDGMENT SUTNANARY WORK IS PREMISES THAT FIND ANY TO PERFORM ON THE PENITENTIARY CORPORATION OF HIS OFFICIALS BY PRISON ASSIGNED MALOR STANDARDS FACTS COURT DOES NOT NOW HOLD THAT THE IS GRANTED DEN IN IN ITS CLAIM INVOLVES CC UNITED FLEFENDANTS DISMISS RELIEF COUNB II THE MICHIGAN MINIMUM WAGE MICHIGAN LAW SECTION THE PROVISIONS AND US 383 TO STATE UNDER THE THE COURT UNDER OURSIER HAVE 408281 TO THOSE CONTAINED BEFORE GIBBS FILED CLAIM 289 US 715 1966 MOTION 26 238 TO UPON WHICH MINIMUM 14 NASHVILLE WAGE LAW PROVIDES OF THIS ACT SHALL NOT APPLY TO WHO EMPLOYER IS SUBJECT TO THE MINIMUM ANY OF CILIA WAGE PROVISIONS FEDERAL FAIR LABOR STANDARDS ACT OF 1928 OS AMENDED EXCEPT IN ANY CASE WHERE APPLICATION OF SUCH MINIMUM WOULD RESULT IN LOWER WAGE PROVISIONS MINIMUM WAGE THAN PROVIDED IN THIS ACT MSA II UNDER THE CORN LAWS LOUISVILLE AND PARKEDAVIS CAN BE GRANTED MICH COUNT CLAIM FORTH BURN WORKERS FOR FAILING TO DISMISS IDENTICAL SLIER 1909 175 MINE UPJOHN 1964 AND IS COMPLAINT US 213 SET ALLEGATIONS JURISDIDTION PENDENT MOTION PLAINTIFFS WAGE LAW OF OF THE COUNT 1923 TI COUNT MINIMUM NICHIGAN IHAT DRUG GGMPANTES WAGE LAW IS MINIMUM MICHIGAN BOTH BECAUSE 1932 WHICH LAW PLAINTIFFS ACT PROVIDES TO MEAN ONLY FEDERAL THAT THE OF THE SUBJECT JURISDICTIONALLY ENTERPRISE OF ITS NATURE WAGE RATE MINIMUM FEDERAL IN NEITHER PLAINTIFFS SUPPORT OF THEIR 14 SECTION IT DEFENDANTS ESCAPE THE MICHIGAN UNDER THE YET WHILE MINIMUM ACT BUT LAW WTHIN FEDERAL TO DUE RESPECLIVE THE INTERSTATE THEN THAT THE EMPLOYER LAW WAGE HAVE CITED ANY OF CONSTRUCTIONS HOWEVER THAT PUBLIC POLXCY THE NARROWER CONSTRUCTION POINT EMPLOYERS MICHIGAN MINIMUM SUCH OF FEDERAL WERE EMPLOYER FROM PAYING WERE EXCUSED MINIMUM TO THE WAGE RATE MICHIGAN NOR DEFENDANTS WAG THE THE FOR SOME REASON WAGE TO ALSO RESULT IS WHO ESCAPE PAYING NOT REQUIRED PREEMPTION COURT HOLDS THAT ARE JURISDICTIONALLY WCIGE EMPLOYECS FEDERAL NOT SUBJECT THE FLSA W6ULD PERMIT MINIMUM THE DOCTRINE COMPAN2ES ON THIS ADVOCATE PAYING TO TO PAY THE ARE IF RENCE WOULD SEEM FAVORS PLAINEIRFS REQUIRED FLSA TO THE MICHIGAN WOULD BE SUBJECT EASES WHO ARC THE TWO OF WAGES THAN THE MICHIGAN LAW PROVIDED WAGE ARE HAND WOULD CONSTRUE SECTION OTHER EMPLOYERS MINIMUM HIGHER THE ACT LABOR STANDARDS FOR HIGHER WAGE UNDER MIFLHLRILIFI MICHIGAN IS OXI THE FAIR TO SUBJECT SUIT MANUFACTURERS INTERSTATE AS THE LAN9UAGC TO THE PRESENT INAPPLICABLE DRUG COMPANIES JURISDICTIONALLY UNDER THIS CONTEND THAT DEFENDANTS SUBJECT DEFENDANT DRUG TO THE MICHIGAN IT FURTHER FINDS THE MEANING OF THAT WORD AS PLAINTIFFS ARE NOT DOFINED IN THE THE BETWEEN MEANS AN INDIVIDUAL OF 18 AND 65 BY AN EMPLOYED YEARS AGES THE OF THE PREMISES EMPLOYER ON FIXED SITE DESIGNATED BY THE OR AT EMPLOYEE MSA EMPLOYER IN WORK NSA THE MICHIGAN COMMON LAW TEST EMPLOYMENT IN FACTUAL TOTAL GOODAHULD REALITY 354 NNSKOVITZ TATE IF DECIDING MUST BE EXAMINED SHIP TO RELATIONSHIP EMPLOYED BY IS ACT RCIATIONSHLP AN EMPLOYMENT OF REMEDIAL SITUATION ERICKSON MICH THE RELATION 699 15 ECONOMIC OF MICH 375 695 EMPLOYMENTSECURITYS92 ONE LEGISLATION SOCIAL SURROUNDING IS THE TEST AND SUPREME COURT THE MICHIGAN INSTEAD FOR THE PURPOSE THE RULED IN WORKMENS COMPENSATION ACT SECURITY EXISTS SUPREME COURT HAS MASTERSERVANT OF STATEE THE THAT DIRECTED HAVE OF WHETHER ONE PERSON NOT DETERMINATIVE ANOTHER UNDER 1964 ENACTED THOSE DEFINITIONS NEVER BEEN CONSTRUED IS OR PERMIT 172552 ALTHOUGH THE ENGAGE SUFFER TO TURN MEANS EMPLOY THAT 172552B 289 19597 1965 293 FOSLERV 99401 MICH APP 96 1968 THE SINCE THE LEGISLATION THE EMPJ MINIMUM EQUALLY ACT WHETHER PJAINTI OF DOFENDANTS WAGE MINIMUM WAGE LAW IS OF THE MICHIGAN AND AS WELL RELATIONSHIP OF PLAINTIFFS EMPLOYEES REASONING SECURITY ACT WOULD APPJY DETERMINING MICHIGAN WITHIN SUPREME COURT UNDE THE WORKMENS COMPENSATINN TO IT AND TO DEFENDANTS FFS REMEDIAL ARC THE LAW JO IN THE FABRIC NMST BE EXAMINED CEOFLOLNIC MEANING EFIBIRE REALITY OF THE MICHIGAN IN BUT COUNT ND PARTIES THAT WITHIN THE CLAIM DEFENDANTS UNDER THE AS II COURT WILL ACT MINIMUM SINCE TO APPLICABLE MICHIGAN ENTITLED OF DEFCNDANT STANDARDS LABOR LIKEWISE IS THE SIMILARLY THUS COUNT DISMISS WHICH ARE II TEST REALITY PLAINTIFFS FAIR OF THE THE MEANING BY THE SUBMITTED AFFIDAVITS ARE NOT EMPLOYEES PLAINTIFFS ECONOMIC COUNT ON THE DCCIDED UNDER MADE SUCH AN EXAMINATION HAS ALREADY COURT THE WAGE LAW TO SUMMARY JUDGMENT TREAT DEFENDANTS ON MOTION UNDER RULE ONE FOR SUMMARY JUDGMENT TO 12C PROVIDES IF MOTION FOR JUDGMENT ON THE PLEADINGS ON THE PLEADINGS ARE PRESENTED TO MATTERS OUTSIDE AND NOT EXCLUDED BY THE COURT THE MOTION SHALL BE TREATED AS ONE FOR SUMMARY JUDGMENT AND IN RULE 56 DISPOSED OF AS PROVIDED RULE 12C FRCP MOTION FOR SUMMARY JUDGMENT ON COUNT III DEEENDANT DRUG COMPANIES CROSSMOTION FOR SUMMARY FILED FLY MOTION TO DISMISS JUDGMENT ON COUNT III DIRECTOR THE OF CORRECTIONST DEFENDANT DEPARTMENT OF L4EMBE CORRECTIONS AND OF THE DEPARTMENT OR THE CORRECTTONS COMMISSION PLAINTIFFS III COUNT OF THE FOR DAMAGES UNDER MICHIGAN SIMILAR ALLEGATIONS COUNT IV AND IS DICTION IN WERE UT3BZED LAW WHICH THE III PLAINTIFFS BY DOFENDANT AGREEM9FLTS BETWEEN THE DEPARTMENT OF CORRECTIONS FACTUAL INVOLVES COURT UNDER ITS STATE QUESTION PENDENT THAT THEIR DRUG COMPANXES PURSUANT DRUG COMPANIES WHICH 29 AND ARE ILLEGAL CLAIM ALLEGES FEDERAL TO THOSE RAISING BEFORE COUNT AMENDED COMPLAINT THE IN JURIS SERVICES TO MICHIGAN UNDER SECT4ON OF THE MICHIGAN PRISON ACT INDUSTRIES PA 210 1935 CORN 800305 LAWS 1948 NOR SHALL HIRED LEASED OF PRISONERS BE SOLD CONTRACTED FOR OR LABOR LOANED OTHERWISE USED FOR PRIVATE OR CORPORATE OTHER OR FOR ANY PROFIT PURPASE THAN THE OR OPERATION OF CONSTRUCTION MAINTENANCE AS DIRECTED PUBLIC WORKS WAYS OR PROPERTY 281525 BY THE GOVERNORT OF THE BECAUSE ALLEGED UNDER SECTION ACTION FOR THE REASONABLE DEFENDANT TIONS THE AND THE DIRECTOR EITHER THEY HAVE CAUSE OF TORT OR IMPLIED SERVICES DEFENDANT INDIVIDUAL AGAINST DEPARTMENT CONTRACT THE OF CORREC CORREC MEMBERS OF THE COMMISSION HAVE NOW PLAINTIFFS COUNT IN OF THEIR DRUG COMPANIES ITS TIONS LAW VALUE THAT CONCLUDE PLAINTIFFS UNDER MICHIGAN OF THOSE LABOR CONTRACTS ILLEGALITY ITT RNOTINN WHILE DEFENDANT DEPARTMENT HARRISON AND CORRECTIONS COUNT III CLAIM THE ENTITLING TO DISMISS INDIVIDUAL THE THEM TO RE1IEF ACCOMPANIED COURT WILL IN SINCE ADDITION DIRECTOR MOTION GROUND THAT PLAINTIFFS HAS BEEN WARDEN KROPP ITS ST AS GUS MICHIGAN TO DISMISS HAVE FAILED TO STATE HOWEVER THAT MOTION BY ANOTHER AFFIDAVIT TREAT CROSS HAVE FILED MEMBERS OF THE FILED ON SUMMARY JUDGMENT COUNT ON THIS OF CORRECTIONS CORMMISSAON HAVE ON THE FOR DRUG COMPANIES FOR SUMMARY JUDGMENT DEFENDANT IN OF ONE FOR SUMMARY SECT3ON OF THE MICHIGAN PRISON INDUSTRIES ACT 210 SECTION OF THE IS NOW P1‰ 1935 CAM LAWS 1948 800305 CORRECTIONAL INDUSTRIES CORN LAWS ACT 15 1968 MICHIGAN 80G PA 12C UNDER RULE JUDGMENT WHICH PROVIDES ON MOTION FOR JUDGMENT ON THE MATTERS OUTSIDE THE PLEADINGS ARE PRESENTED TO AND NOT EXCLUDED BY THE COURT THE MOTION SHALL BE TREATED AS ONE FOR SUNMTARY JUDGMENT AND DISPOSED OF AS PROVIDED IN RULE RULE 12C PLEADINGS 56 RC THE ON THE QUESTION RAISED BY THE UNCONTROVERTED FACTS AS ANY OF THE LAW MICHIGAN ARE ENTITLED PATTIES THOSE FACTS PLAINTIFFS JACKSON PURSUANT TURNS1 CLINICS STATE LABOR BUILT ORDERED BRIEF CLINIC CONTRACTS FACTS AS LEGALLY MATTER OF INCARCERATED IN ON ORAL OF CORRECTIONS DEPARTMENT IN ARGUMENTS BETWEEN DEFENDANT FOR USE MAE PRISON BRIEF ANMATES OF CORRECTIONS JUST THE LATTER THE RESEARCH BUT OWNED BY THE THE 30 1969 CLINICS BY THEY WOULD BE AS INDUSTRY PLAINTIFFS 1969 DRUG COMPANIES FOR THE LABOR OF THE PAID CERTAIN INMATOS PLAINLIFTS DEFENDANTS BRIEF MAINTAIN UNDER SECTION OF OCTOBER THAT EVEN SUMS ASSIGNED TO MONTHLY CHARGES MADE BY THE WERE ILLEGAL DRUG IN OF OCTOBER WORKED IN ANY OTHER PRISON 30 ACCORDING OF CORRECTIONS ON THOSE CONTRACTS PLAINTIFF TO WORK IN OF MICHIGAN COUNT TO JUDGMENT PLAINTIFFS DEFENDANT STATE TO THE DEPARTMENT OF OCTOBER IN TO THE DRUG COMPANIES OF MICHIGAN ORDER OF DISCUSSED ARE BY THE COMPANIES THE WHETHER STIPULATION AND DEFENDANT COMPANIES IS ALREADY ARE OR WERE PRISONPLAINTIFFS ABOVE MOTIONS 30 IF TO THE TO THE DEPARTMCNL 1969 THE OF THE MICHIGAN LABOR PRISON ACT INDUSFRIES AGAINST ANY OF THE THDR SERVICES LII TO JUDGMENT ACT RISE CREATE FOR THE DEFENDANTS OF MICHIGAN TO FOR BY DEFENDANTS WOULD CAUSE OF ACLION FOR INSTEAD PLAINTIFFS PROSECUTION AS THE ARE THEREFORE REMEDY FOR ENTITLED WHETHER INDUSTRIES PRISON DAMAGES WE BELIEVE THAT NOT FACTS ON THE PRESENT MONEY DAMAGES IN THAT ACT OF LAW OF THE MICHIGAN CLAIM VALUE REASONABLE COURT HAS EVER DECIDED NO MICHIGAN OF SECTION GIVES VIOLATION THAT MATTER AS ALTHOUGH VIOLATION DEFENAANTS AND CAUSE OF ACTION NOT HAVE DO PLAINTIFFS AUTHORIZES ITS WILLFUL SUCH FAVOR OF CRIMINAL VIOLATIOTIST VIOLATION OF SOC 14 WILFUL XTIOLATIONS OF THIS ACT AN OF THE BY PROVISIONS ANY OFFICER OF THE STATE OR OF ANY POLITICAL SUBDIVISION THEREOF OR BY ANY OFFICER OF INSTITUTION SHALL BE OF EITHER ANY REMOVAL FROM OFFICE SUFFICIENT CAUSE FOR SHALL ALSO BE SUBJECT TO AND SUCH OFFICER AS HEREINAFTEIT PROVIDED PROSECUTION NSA 2815342 PRISON SECTION 14 OF THE MICHIGAN 13 OF THE MICHIGAN CORRECTIONAL NOW SECLION WHICH PROVIDES INDUSTRIES INDUSTRIES OF ANY OF THE PROVISIONS WILFUL VIOLATIONS OF THIS ACT BY AN OFFICER OF THE STATE OR OF ANY POLITICAL SUBDIVISION THEREOF OR OFFICER OF INSTITUTION OF EITHER BY ANY ANY REMOVAL FROM SHALL BE SUFF5 CLEAT CAUSE FOR ANTI OFFICE SUBJECT SUCH OFFICER TO AS PROVIDED IN SECTION PROSECUTION CORN LAWS 28254013 800333 MSA 32 14 ACTIS ACT 15 SEC PENALTY FINN ANY PERSON OR VIOLATE ANY CORPORATION WHO SHALL WILFULLY OF THIS ACT SHALIBE OF THE OF MISDEMEANOR AND UPON DEEMED GDILTY CONVICTION THEREOF SHALL BE PUNISHED BY FINE OF NOT LESS THAN ONE HUNDRED 100 DOLL2RS NOR MORE THAN FIVE HUNDRED 500 IN THE COUNTY DOLLARS OR BY IMPRISONMENT FOR PERIOD OF NOT MORE THAN NINETY JAIL DAYS OR BY BOTH FINE AND IMFRISONMENT THE DISCRETION OF THE COURT AT PR6VI 90 281535 HLSA WHILE STATUTE THAT RECOGNIZED TO PROTECT US BEFORE 191 FOR PRIVATE OF THAT PRISONS FOR CO UNITED PRISON INDUSTRIES YANDOTTE IS LA PROTECTINMATES FROM BEING COMPELLED RATHER PROFIT CORPORATE SECTION DAMAGES ON ACTION CIVIL HE FALLS WAS INTENDED STATUTE CRIMINAL OF THE MICHIGAN HOWEVER WAS NEVER INTENDED MICHIGAN GENERALLY STATES 1967 202 SECTION IN IS DEMONSTRATE MUST FIRST HE CAN BASE LAW IT NEVERTHELESS PERSONS THE OF OF CRIMINAL VIOLATION 389 PLAINTIFF THE CLASS DOES NOT EXPRESSLY STATUTE DAMAGE SUIT CIVIL AUTHORIZE WITHIN THOUGH THAT EVEN CRIMINAL FROM FOR DAMAGES MAY BE INFERRED AN ACTION IN PERTINENT ACT INCARCERATED TO PERFORM THE PRIMARY SERVICES PURPOSE PART PRISON INDUSTRIES 15 OF THE L4ICHIQAN SECTION INDUSTRIES CORRECTIONAL 14 OF THE MICHIGAN NOW SECTION WHICH PROVIDES ANY PSIRSON FIRM OR CNRPORATION WHO WILLFULLY OF THIS ACT 15 VIOLATES ANY OF THE PROVISIONS CMI LAWS GUILTY OF MISDCM 800334 MSA 28A54014N 33 ACT IS ACT TO ELIMINATE 211 BETWEEN PRISONER SECTION SHIPS LABOR IN6USTRIES MSA IT PRISON INMATES IS THAT TO PROTECT BY THE PURSUE THE MICHIGAN EAACEMENT INTENDED THE NOT 10 AN ACTION AND FREE PRISON MICHIGAN 800310C LAWS THE WORK FORCE OUTSIDE HENCE ARE ACT 281530 RELATION COMPETITIVE LABOR THE PRISON SINCE OF SECTION PLAINTIFFS THEY CANNOT OF SECTION FOR DAMAGES BASED ON NOB WAS ATTEMPTING LEGISLATURE BENEFICIARIES WALLS VIOLATION OF THAT SECTION THERE RECOVER IS DAMAGES FROM DEFENDANTS BECAUSE DEFENDANTS LABOR PLAINTIFFS DID THEM OF ANY PROPERTY ON THE ILLEGAL ALLEGEDLY NOT AS TO WHICH OF THE MICHIGAN THRUST THE CANNOT SECOND REASON WHY PLAINTIFFS IS PLAINTIFFS PRESENT FACTS UTILIZATION CONTEND TNEY WERE ENTITLED PRISON INDUSTRIES ACT OF DEPRIVE INSTEAD IS PRISON INDUSTRIES SECTION 10 OF THE MICHIGAN INDUSTRIES 11 OF THE MICHIGAN CORRECTIONAL NOW SECTION 800331 LAWS COIN THE CORN LAWS CORRECTIONAL 800321325 IDENTICAL IN MSA 281540 THAT 11 PA THAT ACT IS ACT 1935 INDUSTRIES ACT 210 THE BEEN 800301319 HA5 REPEALED BY MICHIGAN CORN LAWS INDUSTRIES 196H ACT 15 THE 1968 ACT HOWEVER IS SUBSTANTIALLY CONTENT TO THE 1935 ACT MICHIGAN PRISON PA 34 THE OF INMATES LABOR AND WQRKING PENITENTIARIES BELONGS FEDERAL IN CONRB FOR DISTRICT NUNT1 IT OFFICIALS OF THE APPROVAL OF MICHIGAN DISTRICT THE WESTERN THIS INMATES THE RECEIVED MAFLUFAG CUNN ON ALMOST CONCLUDED THAN TO THE EARLIER OF THE ACT CONSTRUCTION MICHIGAN ON THE ORDER OF PRISON RATHER TO THE STATE IN INCARCERATED LAWFULLY WHEN JUDGE STARR SUPRA FACTS IDENTICAL THAT THE LABOR OF THE OF THE STATE AS INMATES PLAINTIFFS PRISON BELONGED TO THE STATE OF MICHIGAN 79 FSUPP AT 113 SINCE THE AT THEY NOW CHALLENGE ENTITLED THEY WERE ORDERED TIME TO RE COVER THE UNDER ANY THEORY OF ACTION ON OF THE MICHIGAN NMATE THE LABOR HAS BEEN INMATES ALREADY IN WAS TO PROTECT CRIMINALS PRISON INDUSTRIES ONLY REGULATING ACT OF THEIR FRUITS WITH INDUSTRY PRIVATE THE FREE LABOR MARKET REGARDING THE CASE SUGGESTING THE USES OF PRISON 35 ENACTMENT CONFERRING OF THE BUT AS OF SECTION NOT TO GIVE DISPOSITION THAT AS LABOR WHEN THAT USED THROUGH NO FAULT THE PURPOSE BEHIND ANY RIGHTS THE STATUTE ILLEGALLY THE LAW BY MICHIGAN RECOGNIZED TO THE RIGHT COMPETITION NOTED OF THOSE SERVICES HOWEVER WOULD HAVE THE COURB CONSTRUE PLAINTIFFS SECTION VALUE SERV2CES NOB ARE PLAINTIFFS REASONABLE THE TO PERFORM ILLEGAL AS BEING OR TO ITS OWN LABOR TO THEIR HAD AO RIGHT PLAINTIFFS FRUITS CLEAR IS INCARCERATE OF THEIR VIOLATION OF LABOR MAY CREATE LABOR STATE AN ACTION ALA SUPREME 656 PLAINTIFF CONTRACTY BUT SAID YET TORTIOUSQ SLOSS OF THE AS INMATES CONVICT TO PROTECT INTENDED HAVE NOT BEEN TO THEM UNDER MICHTGSFL THEIR TO THE LABOR JUDGM THEREFORE DEPRIVED THAT FOR DEFENDANTS 36 PRO INDUSTRIES AND SINCE PLAINTIFF5 BELONGFLG OF UTILIZATION DEFENDANTS ARE ENTITLED SUMMARY JUDGMENT CFL FOR 657 OF ANY PROPERTY FACTS 3TC LAW THE PRISON LAW BY DEFENDANTS STIPULATED ENTERED AT INMATES COURT CONCLUDES ON THE BE ALA 116 WAS LABOR WAS ENACTED OF THE MICHIGAN 5ECTION SINCE ACT WAS NOT COURE FOUND THAT LABOR BY PRISONERS SUNDAY THE BENEFIT THE IN ON SUNDAY FROM THE PRESENT DISTINGUISHABLE THERE BECAUSE SITUATION IS DAFENDANTS SUCH SUNDAY PROHIBITING FOR CLAIM THAT DICTA WORK FROM THE PRISONERS STATUTE OF VIOLATION THE ALABAMA PRISONERS IN HARVEY COMPANY SLOSS ILI THE EXTRACTING ACTS IN 2897 994 COURT DENIED RELIEF HIBITING SO 22 WHOSE LABOR WAS PRISONERS STEEL AND LOSS IRON USED IS UNLAWFULLY 116 FAVOR OF THE FOR DAMAGES IN COUNT III WILL FLE DRUG COMPANIES MOTCON FOR SUMR4ARY JUDGMENT ON COUNT IV AND MOTION TO DISMISS FILED BY DEPARTMENT OF CORRECTIONS ITS DIRECTOR AND THE MEMBEPS OF TIE MICHIGANCORRECTIONS COD4MISSIO DEWY COUNT IN IV MONEY DAMAGES UNDER OF THEIR USC 42 UTILIZATION ILLEGAL DEFENDDNTS LAW BY OF PLAINTIFFS PROPERTY FOURTEENTH HAS RESULTED WITHOUT SERVITUDE THE CONSTITUTION FEDERAL EQUAL PROTECTION MENT DEFENDANT ON THIS COUNT CORRECTIONS CORRECTIONS AS TO DISMISS ARE FACTS AN AFFIDAVIT INMATES RELEVANT FACTS TO AS DISCUSSED MICHIGAN TO ONE FOR RELIEF SUMMARY OF THE UNDER COUNT BY UNCONTROVERTED ACCORDING COUNT IV UNDER COUNT DETERMINATION THE OF TO DISMISS PLAINEIFFS ENUMERATED IN OF AMEND EOURTEENTH DEPARTMENT MOTION TREATED KROPP LTHOR TO ARNONDMANT TO PLAINTIFFS BY BHE ENTITLING ESTABLISHED OF WARDEN PERFORMING FILED BE IN HAVO MOVED FOR SUMMARY JUCIGMEN ALREADY THOSE PREVIOUSLY SOME ADDITIONAL IN WILL FOR THE REASONS THE MOTIONS CLAIM THAN OF PLAINTIFFS DENIAL THE THE MICHIGAN HAVE AND THE DEPRIVATION AND THE MEMBERS OF THE DIRECTOR COMMISSION THAT MOTION AND DRUG COMPANIES TO STATE FAILING JUDGMENT ITS IN THE THIRTEENTH TO CONTRARY ADDITION DAVIS WAGES LESS THE HOLDING OF LAWS AS REQUIRED IN PARKE THE DUE PROCESS OF LAW AS REQUIRED AMENDMENT INVOLUNTARY THE LABOR BY ALL CONPANY OF NOMINAL UPJOHN THAT ALLEGING BY DEFENDANTS PAYMENT THOSE REQUIRED BY THE 1923 ASK FOR PLAINTIFFS OF PLAINTIFFS AND THE COMPANY AND THE COMPLAINT PRESENT III AND STATEMENTS TO WARDEN RESEARCH CLINICS XII KROPP ARE PAID AND AT TIMES FACILITIES FACILITIES RECREATIONAL THE RESEARCH CLINICS AUTHORITIES THAN INDUSTRIES ON ARE ENTITLED TO THE WITHOUT MERIT AFTER FOR CRIME THAT THEIR RH JAW OF FROM ITS PROHIBITIONS IS SERVITUDE MAY BE REQUITED NO FEDERALLY IS NOT TO WORK WHILE VIOLATES AMENDMENT WE AGREE THE RESEARCH WORK IN THIS F2D THAT THEY MAINTAIN THERE FOR 315 IN MOST OTHER PRISON CRIMINALS PRISONER WHICH SERVITUDE THE THIRTEENTH INDEED MATTER CONVICTION DR RIGHTS AS CONVICTED STATE OF RIGHT IN DEFENDANTS AUTHORITIES TO WORK BY PRISON WORKING MORE FREEDOM BY PRISON FORM OF INVOLUNTARY LAWFULLY INMATES TO PRISONERS INMATES WORKING FACTS CLAIM CONSTITUTES INVOLUNTARY FOOD AVAILABLE JUDGMENT CLINICS IMPRISONED AND THE ARE INMATES PLAINTIFFS PT6TECTCD ARC SUPERIOR ARE GIVEN RECREATIOFLA TO THE CLINICS JNDUSTRIE OTHER PRISON IN WORKING RESEARCH THE IN WORKING TO FOOD AVAILABLE THE PERFORMING THE INDUSTRIES OTHER PRISON IN LABOR SIMILAR INMATES THAN ARE RATES DAILY AT SOMEWHAT HIGHER IS THIRTEENTH 193 197 EXPRESSLY SORT OF NOT THE ATNENDAENT NINTH CIR EXCEPTS 1963 PUNISHMENT AGAINST SERVITUDE SERVITUDE SLAV NOR INVOLUNTARY FOR CRIME WHEREOF THE EGCEPT AS PUNISHMENT SHALL CONVICTED PARTY SHALL HAVE BEEN DULY STDTC5 OR ANY PLACE THE UNITED WITHIN EXIST SUBJECT TO THEIR JURISDICTION NEITHER SINCE PLAINTIFFS CONVICTED SNRVITFLDE THEIR BY DO NOT MAINTAIN CLAIM DEFEND THAT IS THEY THAT THEY WERE ILLEGALLY HAVE BEEN YROUNDLEFS HELD IN IIVOLUNTA3 THE THAT IV COUNT AND DUE PROCESS BASED ARE THE AS WE NOW UNDERSTAND IT VIOLATION THAT IS THE DEPRIVES PRISONERS YET NOT DOES IN CONCLUSION PRECISE FOLLOW RHA 315 9TH CIT MORE BROADLY QUESTION RAISC SUCH ESTABLISHED IT EVEN THEIR 1968 ON ERRONEOUS DECISION THE COURT AS FEDERAL HCINZE HUGHES TO 1963 CIR 9TH 8TH CIR 662 EVERY THE 1983 FOR CLAIM ITIUST PRISON DO NOT ATTORNEY 26 268 INDICATE OF DUE ALLEGATIONS IV 865 CONSTRUED ARE SUGGESTED ON ORAL PROCESS RIGHLS OR THAB PLAINTIFFS CONSTITUTIONAL CELLS COUNT CAUSE OF ACTION PRESENT THE DENIAL THOSC2 IN ALLEGATIONS THAN PLAINTIFFS OF SOME FUNDAMENTAL INTO FOR THE 1959 ARGUMENT THEY STILL USC 659 197 WAS THE WE ELECT TWO DCCXSXON WHICH F2D 193 DUE PROCESS THAT COURTS OF APPEAL WOULD COME BEFORC LAW MATTERS BUT 42 2D 404 RULE WERE OTHERWISE CONSTITUTIONAL 870 IN OF THE THOSE PFISONERS BYTHE CIRCUITS IOWRIE THE OF REACHED DRAPER SIGLER STATE NINTH AND EIGHTH IF RI LAW STATE APPLICABLE VIOLABION CONSTITUTE ITSEJF PROTECTION OR EQUAL THE TREATED HAVE OFFICIALS PENAL WITH AT VARIANCE PRISONERS TO THIS RIGHTS BECAUSE MERELY AUTOMATICALLY USED CONTRARY IS WHOSE LABOR IV COUNT PROHIBITING FREE LABOR AND FOURTEENTH OF THEIR MANDATE STATUTE OF THE MICHIGAN LABOR LABOR OF PLAINTIFFS ARGUMENT UNDERLYING LEGAL BY UNDER UNLAWFULNESS ALLEGED UTILIZATION PRISON COMPETITION STATE ON THE LAW OF DEFENDANTS MICHIGAN RAISED PRCTCCTICNC1EIA EQUAL WHOLLY INDICATED ATTORNEY ARGUMENT PLAINTIFFS ON ORAL THE FACTS HAVE BEEN RIGHT WHICH UNDER TO ALREADY DEPRIVED FOLLOWS THEM LAWFUL INCARCERATION NECESSARY WITHDRAWAL BRINGS ATHOUT THE OF OR LIMITATION PRIVILEGES AND RIGHTS WITHDRAWAL WHICH IS JUSTIFIED BY THE CONSIDERATIONS OUR PENAL SYSTEM NN6ERLYING TO ARGUE THAT THE INCARCERAFRED CAN PERSON ONLY BE INCARCERATED AND NOT BE DEPRIVED OF THE AVERAGE PERSON ORDINARY RIGHTS AS HE WOULD HAVE HAD EHEM IF THE PRISONER WERE NOT CONVICLED AND SENTENCED AND CONFINED MATTER OF COMMON ORDINARY LOGIC IS AS ABSURD IT IS OXIIY WHERE FUNDAMENTAL HUMANE AND NECESSARY RIGHTS ARC BREACHED THAT THE CONSTITUTIONAL PROTECTIONS BECOME INVOLVED COMMONWEALTH RAY OF PCNNSYLVARNA 263 FSUPP 630 631 ZN WD PA FAILURE CLINICS HOWEVER AT ITS FUNDAMENTAL AT 1967 TO PAY REASONABLE FOR THEIR PLAINTIFFS VALUE CONSTITUTIONAL IS NOT RIGHT DENIAL LABOR SUPRA 661 PLAINTIFFS DEFENDANTS OPPOSED MICHIGAN CRITNINATION THE EQUAL HAVE IS LABOR CONTRARY ACT INDUSTRIES NECESSARY PROTECTION FAILED CLAUSE TO THAT ELEMENT OF THE IN CONTEND THEM AGAINST THE SAME CLASS PRISONER USED PRISON PRISON LIKEWISE DISCRIMINATED PURPOSEFULLY TO OTHER ALLEGEDLY PURPOSEFUL PRESENT FOURTEENTH AS WHEN DEFENDANTS TO SECTION THE THAT OF THE DIS CASE UNDER AMENDMENT APPELLANT ASSERTS THAT HE IS BEING HELD IN THE STATE PENITENTIARY AND THAT IN ACCORDAN9E WITH STATE LAW HE SHOULD BE IN THE COUNTY JAIL NO DENIAL OF EQUAL PROTECTION IS SHOWN UNLESS THERE IS SHOWN INTCNTIONAL OR PURPOSEFUL DISCRIMINATION BETWEEN PERSONS OR CLASSES FLRAPCR TAOREOVER THAT THE OF SUCH LOWRIE SIGLER IN THE THE SUPRA AT UNCONTROVERTED EFFECTS OF THE FACTS ALLEGED 40 198 ALREADY VIOLATION DISCUSSED SHOW OF MICHIGAN JAW TO CONFER WHO RECEIVED ASSIGNMENTS CLINIC IN DID THAN DIFFERENT IN THE OF THE DEFENDANTS WHETHER SECTION OF THE MICHIGAN HOLD ONLY THAT CONTRARY EVEN UNDER 42 IF LAW IN IN MOTIONS IT FACT INDUSTRIES USC DEFENDANTSUSED LAW AND SO DOING EVEN IF IS VIOLATED ACT ORDERS MAY BE 1K HAVE FOR THIS JYY DETROIT MICHIGAN JANUARY RL973 41 WE LABOR ACTED UNDER SUFFERED REASON ON COUNT SUBMITTED FREEMAN RALPH CH EF BUDGE DATED TO ATHER DEFENDANTS GRANTED APPROPRIATE OR WHETHER PLAINTIFFS FOR SUMMARY JUCGMENT TO UNNECESSARY 1983 PLAINTIFFS PROTECTEDRIGHTED OF FEDERALLY DEFENDANTS WORK BUT UNDER COLOR OF LAW SUFFICIENT ACTED TO MICHIGAN COLOR OF STATE DENIDI HAS HAVE PRISON TO LIABILITY IT SUBJECT WORKING SIMILAR PERFORMING ABOVE FINDINGS DETERMINE EACH DEFENDANT HIGHER INDUSTR PRISON VIEW INMATES PLAINTIFFS FOR THEY RECEIVCD AND LABORED UNDER BETTER WAGES MORE FREEDOM CONDITIONS LIKE ON IMNATES BENEFITS TANGIBLE IV ARE NO APPEARANCES ROBERT SEGAR ESQ 804 DETROIT STREET FLINT 48503 MICHIGAN FLANNASCH RAPPTEYE 511 JACKSON STREET 49203 JACKSON MICHIGAN EQ VINCENT STAPLEY 464 COUNTY BUILDING 49203 JACKSON MICHIGAN WILLIAM GAGE ESQ 3030 GUARDIAN BUILDING 48226 FLETROIT MICHIGAN WOLFGANG HOPPE MILLER 2500 DETROIT DETROIT ESQ CANFIELD FLANK MICHIGAN PADDOCK STONE TRUST 48226 BUILDING CARROLL ESQ TIMOTHY FLYKEMA WHEAT SPCNCCR GOODNOW 2700 PENOBSEOT BUILDING 48226 DETROIT MICHIGAN SOLOMON BIENENTELD ASSISTANT ATTORNEY GENERAL 525 OTTAWA STREET LANSING MICHIGAN TRIGG FILED UNITED RET 1971 DISTRICT COUET OF MICHIGAN SOUTURNZN DIVISION STATES EASTERN DISTRICT CALVIN RICHARD ALLEN SIMS FRANK WALTER ROGERS BILLY LICE WILLIAMS LEE BOYD SLAGER PETER GEORGE WALKER CLEMONT MILLS LEE DEDEAUX ORDELL VILBURN WILLIAM FRED CLEARY HERBERT WITIJARVIS HOLNAGEL BENNY SPELLS KENNETH RAYMOND ORCEAN INMIAN BAILEY DAVIS JERRY MACK BOYD KELTON THOMAS LORD RALPH WATSON CHESTER VERNON RONALD PHILLIP RALPH IL SAWICKI MEWS MEGITEE CO WARNER KENNEDY PAUL ROSS HERMAN HEAD GERALD NORMAN PAUL MILLER THOMAS MULLIGAN LONNIE PAYNE ROBERT MASON AND KENNETH MARSHALL FREDERICK JJ6 J3HNSO PLAINTIFFS VS CIVIL PARKE DAVIS THE UPJOHN NO CO MICHIGAN CORPORATION GO DELAWARE CORPORATION ACTION 31172 DEPARTMENT OF CORRECTIONS OF THE OF MICHIGAN ELEANOR HUTZEL WADSWORTH ERNFSTC BROOKS MAX BIBER CJ FARLEY JOHN RICE DUANE WATERS FLORENCE CRANE JOSEPH GROSS ROBERT COTI ON AND STATE JAMES GUS HARRISON DEFENDANTS ORDER GRANTING DEFENDANTS MOTIONS PERTAINING TO CLASS ACTION TO DISMISS AND FOR SUMMARY JUDGMENT AND DENYING PLAINTIFFS MOTION FOR SUMMARY JUDGMENT AT SESSION OF SAID COURT HELD IN THE FEDERAL BUILDING D4ROIT MICHIGAN ON THE 01 1971 A2I PRESENT RALPH UNITED FREEMAN STATES DISTRICT JUDGE THE PARTIES HEROIN HAVING DESCRIBED VARIOUS MOTIONS FFTLCD BELOW AND CONSIDERED THE COURT HAVING EXTENSIVE BRIEFS SETTING OUT ITS TO SUCH AND ORAL ARGUMENTS PERTAINING THE COURT HAVING FINDINGS OF FACT THE COURT BEING NOW FILED HEREIN OPINION ITS AND CONCLUSIONS IN FN1L ADVISED THERE PORE IT IS OF THE AND 1971 AND PREMISES CO CLASS ACTION DEFENDANTSPARKE MOTIONS ON JANUARY LAW MOTION ROR ORDER THAT PLAINTIFFS AS CAUSE AND THE THIS HEREBY ORDERED AS FOLLOWS DEFENDANTS PARKE DAVIS MAINTAINED IN THE PLEADINGS DAVIS IS CO AND THE UPJOHN ACTION SHALL COMPANY NOT BE HEREBY GRANTED AND THE UPJOHN COMPANY OF COMPLAINT MOTION VAR SUMMARY JUDGMENT ON COUNT IS HEREBY GRANTED DEFENDANTS PARKE DAVIS CO MOTION TO DISMISS OF COMPLAINT MOTION FOR COUNT SUMMARY JUDGMENT IS AND THE UPJOHN COMPANY AS TREATED 1ZC PURSUANT TO RULE HEREBY GRANTED DEFENDANTS PARKE DAVIS GO AND THE UPJOHN COMPANY MOTION FOR SUMMARY JUDGMENT WITH RESPECT TO COUNT AND DEFENDANT OTHER UPJOHN THAN PARKE DAVIS COMPANY MOTION TO DISMISS COUNT MOTION FOR SUMMARY JUDGMENT PURSUANT ARE HEREBY CO ILL 113 AND THE TREATED TO RULE AS 12C GANTED DEFENDANTS PARKE DAVIS CO AND THE UPJOHN COMPANY MOTION FOR SUMMARY JUDGMENT WITH RESPECT TO COUNT IV AND DEFENDANTS OTHER THAN PARKE DAVIS 224 CO AND TH UPJOHN COMPANY MOTION TO DISMISS COUNT IV TREATED CO MOTION AS IT FOR SUMMARY JUDGMENT PURSUANT 56 PERTAINING CF THE REDERAL TO COUNT III IS RULES RALPH TO FORM ROBERT LEFTS 804 SEGAR ESQ ON DEAN DEAN ABRAM SEGAR DETROIT STREET 4S503 FLINT MICHIGAN ATTORNEYS FOR PLAINTI2S 2355631 HART PLAINTIFFS I2C OF CIVIL PURSUANT PROCEDURE HEREBY DENIED RALPH APPROVED AS RULE ARE HEREBY GRANTED THE MOTION FOR SUMMARY JUDGMENT RULE TO NI FREEMAN FREBMAN CHIEF JUDGE EXPEFU ENTS LEFIIND BA UZ DRUG COMPANIES AND PRISONERS CT WAFLR5FLFL ILOCIORS BY JESSICA CRIMINALS FCNILMUCH MATERIALAND MITFORD ARC FINE OUR IN RNA EXPERIMENTAL THAN CIII INPANZEE CHEAPER SOME GIVE NEW DRUG CAT BE MARKETED IN THE UNITED SLATES IT MUST AECORDI RIG TO FOOD AND IIUG ADA IN ISTRATION RULES BE TESTED EFORE JR HUMAN BEING ON EARLY BEEN TESTING DONE IN PISNU AT FRUSTRATED WOILD NI THE EFFORTS BY AMERICAN EDICAL SUBJECT CAPTIVE OF USE HAVE MEDICAL ASSOCIATION BEING PRISONERS CIS AS OF MICIETI BEEN THE 1961 THAT PROPOSED IN GROUPS SHOULD NOT BE USED THE RECOROMENDA EXPERIMENTS WAS 1963 SOCATION AM DISTURBED THAT THE WORLD IS NOW HEDGING ON ITS CLAUSE ERTNNALS IS INFLUENCE HAS ADDS WISTFULLY TATS PENITENT BEEN AT HI ARE MUCH CHEAPER THAN PANZECS DONT CUE 64 IT AT CAD FI CLI PSI SUSPENSION ITS AMERICAN THE NICEST TO SAY ABOUT TISING AMERICAN THE MATERIAL WOK ON OXTE OF KNOW WAS IA ILES IN EXPERI RI II IN 11 MATERIAL EXPERIMENTAL IMP IHTEES HOPE THE PEP IF AS MEDICAL THIS HE SCIEN HI FEDER VOLUNTEERS FBI WARDS RANGING FI IN CASH PIUS FR NAME PR ICPF 7OVERRNNENT WAS USING GESCALE RESEARCH DISPENYN ZN PACKAGE OF CIGA CITE CO RC 23 PRKONR ESTIMATED NEVER FORMALLY ADOPTED BECATOSE LARGELY OF AMERICAN DOCTORS OF THE OPPOSITION PERTINAX MEDICAL JOURNAL FOR JANUAY WRITES JO THE BRITISH TION CA OF THE SCOPE AND 963 TIME NLFLYIJLE AS EFFECTIVELY EXPERIXIENTERS THE EXPTRI1CI PRISON CS WELL SONERS MDI EXPETIMEN THAT IN OF SENTENCE TIMA WITH LIVE WERE INJECTETI LV CELLS AND WITH OD FROM IC UT CIII PATI EN DISEASES EOULD HI RB TERMINE WHETHOR THESE TI WERE GRVN NITIED AT RI NCZRS IN OKIAHON DRUG HAS HAVE BEEN THE EXOTIC IUIED WAL THE OF THE MUST YEARS EXPERHUCUTS OHILPIT TO TEIITPTED HUT THESE SUBJECTS AS RECENT MCRE AND INTERII SOME TIME FOR AVE IN OF OUR PRISONS OR OTHER MEDICAL SUBJECTS IT CFOP INVOLVED ALARMING OPENLY ABOUT THENI THE RCSS WITH STIFFICIEN REGULAR TALK TO THE JLY FEW ALTHOUGH LIKE OUR ATIT EHIM AND THIN IN CTION OK LB FF1 3004T3 YEAR EOMPKWS TO TEST ECUTICAL SAWE THAT TIE CR5 DOCTORS FROM RICA HARP JIPR VII IS OUT DEW IHUGS ON WERE PAYING PTIIFLC QUART FOR BLOOL WHICH THEY RETAILED UT ST WAITER RUGABER OF THE NESS IN JTLY 1969 REPORTED THAT THE FEDERAL GOVENFLTKCI WATCHED WITHOUT MTERFCRENCE WHILE NI TIN ERTED DD AND SONIC IN AN EXTENDED TIC BLOOD HA MAVE GRAMS DETERMINED THE STAKES AN WITH SEE II ICI PRESS 1967 BET TIC IN QRISON RESCAICH ARE OPERITTI CCCS5 PA9 ORTH TO PIG THE MD DI RON IS VI IT HTI IT PM FL OS FIUWTI II DI HI VICTIMS ILL VOLU IU IN OSLO COIJIPANICS 5L WITH BEEN STRICKEN ID TIE PLAA OPERATIONS DZRNAGE HAS BEE DONE IN THE PENITENT DREDS OF INMATES IN THREE STATES AND BURNT PM IS IT THE ARTICIPATING CASHES PHYSICIAN ON THE IN WAYS VARIOUS PROGRAMS IN C4 HUMAN SU BJECTS HEALTHY LIONS THAT ARE TIVIN TTICULT CII IN CONDI CONTROLLED NOT IMPOSSIBLE IF DU TO PH TIRE COMPANIES CAN BUY THAN ONETENTH ACCORDING OF WHAT THEY WOOID TO MANY MEDICJ ACT HON TIES STUDENTS HAVE TO PAY RNERLICA OR OTHER FREEWORLD CATE ELSTWLLETE ADDITION IN FRACTIONLESS THESE VOLUNTEERS THEY CAN CONDUCT EXPERIMENTS ON PRIS FOR STUDENT ONEIX THAT WONID NOT BE SX ICR ION CCI AT SULJECTS ANY PRICE HEEX USE OF THE DEGREE OF RISK AND MEN TA TION ARE EAST ED INVELY PAIN ES IN HY DISREGARDED BEHIND THE ARE STATICS FOR NOT THE SUBLICTC PRIVACY IF NIL OR VOLUNTEER BECOITIES SERIOUSLY HE IS RESULT OF THE PROCEDURES TO WHICH TH REPERCUSSIONS WILL LIKELY BE SNIM 11CR THIN WOULD OF PRNON AS THEY DUSRR VET TROUT WHEN ED THE HE ON THE TRYING TO VOLONLATY MU AS SIDE LACE DEATHS OTT THAT NIGHT FIA PROHIBITED BY LIKELY THE REGULATIONS BUT THE PRISONER IS IRI OF SIGNING THE PSYHOLOGICAI ETL KNOW THIS WAIVER ALONG WITH ONERS MAKE FOR TIE LAWSUITS PRISONER COMNY DRU MORE ONERO US VIEWED IN TF GENERAL HELPLESSNESS THE LIE PITTANCE AROUND GENERALLY ITS EXPERIRNE AN ORDINARY PNIS RARITY GETS SI FROM FOR DAY REPRESENTS RICHES 30 TERMS OF PRISON PAY SCALES MONTH HE WITH THE TO 10 IT COMPARED MAKE THE THE THE WHEN MONTH MIGHT JOB PRITTITI ROBERT BATTERMAN CLINICAL PHARMACOLOGIST ME THE NIL LIE PRISONERSUHJECT GETS VIRTUALLY CITED ANT ESTIMATE HIM FOR EXPENIRTIEC TI OG ON GIVEN MONTH FOR IN VACAVILIE LIFONRII4 15 PRISONERS MONTH THREE MONTHS TO HE LOWERT4 TO 1250 TOLD WE THE EXPERIMENT RUN FOR SIX MONTHS THE OTHER WAY AR ON ON WITH NORMALLY DO II FREEWORLD VOLUNTEERS WET GIVE THEN TUORE MONEY SHOULD WOOLD DI BATTERMAN TMNTGCR MAKES CONSIDETA TIE FROM USE OF STUDENTSUBJECTS SCHOOL FOR COMPARATIVELY NEARBY ILAPTIST DIVINITY WEEKLY UNDERNANDITIG CXPERIMENTNE REQOIRIRIG WITHDRAWAL OF BLOOD WOULD PAY STUDENT AT THE IF EXPERIMENT RAN HE LEASM 100 MONTH LIE II SAID HOWEVER THE PROBLEM AS AMER RCA TI MEDICAL OF THE THE THAT PRISONERSUBJECTS THEY MAY BE SEEN BY SONIC LEADERS PROFESSION ARE PAID PAID TEN TOO LITTLE MUCH PROBLEM TO THAT THE NREARTT KLUSINESS MR CRC II CHAIRMAN THE PRISONER PRISONER HART WAS TIN IS MUCH TOO STRONG VERY FROM PRESSURE NOT TO REPORT AND NOT TO WITHDRAW THE STUDY HERELORE BE WOULD DECLINE TO SAY THAT IS HAD FOR THE HE FELL ANY ADVERSE REACTIONS THIS US TING RESULT VALID BASIC RERNTTNERATIFLN IBIS MEDICAL FROM DAM AGE CLAIMS LII AT HELD LEGALLY III SUCH WAIVERS HAVE BTIR AND ARC SPECIFICALLY AS CONTRARY TO PUBLIC POLICY MAY THE ON SMALL CORTIMITTEE THE RESU THOSE RESPONSIBLE RELEASING SELECT PRISONER IN THAT IT EXPOSES HIM TO UNNECESSARY RISK IT IS BAD FOR OUR RECORDS III THAT IT DOES NOT PROVIDE TO THE AU PROVE CMBARRASSING HAVE HABIT OF CONVENIENTLY DISAPPEARING THOU ITTES RISK TINT SUTJ ECTS DISABLED BY THE CX HERE IS MINIMAL PENMEN TS WILL TRI RIG AWSU ITS AGAINST THE DING COIN WAIVER PANICS PRISONERS ARE NFL EN RERJLT RTID TO SIGN RECORDS PROT RUGAHER PRISON PROGRAMS WLI6T IS HAPPEN IS PRECISELY EXPRESSED BY SOME THUS PR HERBERT SPOKESMEN ION TILE HEY JR THEN COMRNRSSRONER OF THE FOOD ARID DRUG TESTIFIED IN 1969 HE ITRE THE SENATE ADMINISTRATION WILL EXPERI OTHER AGENCIES WALLS PRISON CARRIED UN II HEW AND ESLA TSIISHED LY WHEN JIJIDEL TO CAN BE SO STIPEND HEALTHY ADULT THE RE TRADIV AS TO INVALIDATE OVERWHELMINGLY IS SOT TS OF MEDICAL RESEARCH POSSIBILITY ONLY IN TIE TOPSYTURVY WORLD OF PRISONS YET THE FEAT THAT THIS LARADAY NOT IS BUT THAT HAT RATHER DOL FIR BR II II PRISONERS ATIORT DO INDEED FT IN LARGESSE 1969 AT VIEW OF SERIES THE SMALL SUMS PAID CONDOCTED AS INTERVIEWS CALIFORNIA VUCAVILLE ITT VFARTI BY PRISON OF CAL GRADUATE SI UDENT AT THE LJNIVERSITY FORN OF CRI UTINOLOGY SOME OF THE DEPARTMENT CONULIN OTED YEAH WUS ON RESEARCH PRISONERS HUT EOULDN LOST KEEP MY CHOW DOWN LIKE MILLER ABOUT POTINDS NRY FIRST YEAR IN SCARED HATED TO GIVE THIRTYFIVE SKIRTER SO CAUSE GETTING WAS IT AP TOPIT TEST GOOD PAY 30 MAKING MONTH KR DM50 THE THE IT JOINT UP BE HEY MAN IM THING CHRONIC KNOW DIMETHYLSULFO OF WHO COUPLE OF GUYS HAD TO GO IN THE HOSPITAL MD THE VERE ON IT AIRLS WERE SO BAD THEY HAD TO OFF IT FTMT WHILE FLIRT WHO GIVES TAKE EVERYONE FULL CANTEEN DRAW BAT MAN LIII RTY IS WISH THE THING WOULD GO ON FOR YEARSID HE LOST WITHOUT IT WAS ON DM80 LAST YEAR IT PAID REAL GOCD AND IT WAS BETTER THAN THAT PLAGUE VACCINE ITOTTIUNIZATION BUBONIC THING ALIOUT SIR IT AND PLA STUDY THAT BAD OF LOT WHY IT STAIR WRITER THRE FUEKED WITH GUYS INST YEAR THERE RES PAID THE YEARS EARLIER CURBED BY SEVERELY OUS ADVERSE WASHINGTON TILOTAN TESTING HAS FDA EFFECTS WAS GUESS THATS MORTON MINTZ POST HAD WRITTEN BUT DM50 OF GOOD SO FOR SO TO NOW BEEN SEN BECAUSE OF REPORTS OF LOST WASHINIGTOTI JULY 24 1966 THE PARTICIPATING GRAMS IN WITH THE VARIOUS PHYSICIAN WAYS IFE CASHES IN MAY MAKE ON THE PRO DIRECT DEAL OUT DRUG COMPANY TBR LINANCIAL BACKING OF WHICH HE PAYS THE EXPENSES OF RESEARCH AND RESCA REB POCKETS THE REST AS BTS FEE AN INILIVIRLUNT FROM 85000 TO MORE THAN 50000 GRANT MIGHT RIM CONTACTS TO 41 DOCTOR TH GOOD PRISON DOUBTE OR TRIPLE HIS REGULAR INCOME OR IF HE IS AS MEMBER IN TIEDICAL SCIT ONL FACULTY MANY ARE ENABLITIG 65 FLY IF AI AE HE THE ROUTE EN HA RICE IN TIE HI CI LVII OC FT MIPS TUJ CIBA ION IC 6I WORKING II SU SJEEIFICALLY 5UT WE CETS BJ OR YE ISSUE OF THE IN THE LSSOCIUTION LAW BY WNS PROCEDURE DR WRITES NOT WH HE II OX ENACTINER IF PRISONCRS FOR TALS LB ODIUM III ANTI HODGES HIS SOUGHT LAW EILIL ESEAREH AT SPECIFIC PA LB THUS THE COTISE WERE IN INC PING UNI XC DELIVERED COLLEAGUES AT THE HOSPI ESITY COLIVICTS DR TO RIVER BOSPI UNIVERSITY TALC LILDILOC II RIG UTEENUVES AND MOTIVES THAT TO VOLUNTEER FOR RESEARCH SLILDIES ON THE PRSONERS ID ARE SOMEWHAT UNPLEASANT TISTLILILY AND DI HODPES RISKS SURMISES THAT FOR SEINE IT PROBABLY REPRESENTS NEW EXPERIENCE WHICH TAKES THEM AWAY FERN TIRE MONOTONY 114 OPPRESSIVENESS OF PRISON ROUTINE FEW INSTANCS THE VARIETY DISTILICT MONOTONY THEY HAVE FROM RELIEF SWALLOWED DIETS STRANGE PEALED INVOLVE TUBES AND VENIPUNCTURES CL PHYSIOLOGICAL IOWA REDUCTION HIT II JIRISOLLEC ARE THE WARDEN LB THIS LETTER TLI IN EACH THAN FROM WJ DR HODES II CUSSIOLI OF EXPERILNEN TIRE 66 OUR TI ION THAN KYOU PLC IS MAY FOR DR THE LIT CO PANIUINS RECEIVE PO LETTER LODGES THE FACE PRISONERVOL ANT CC RS LIE CDXL INVESTI TATOLIE PHYSIOLOGIC ROBLEL OS THIS HAS BOTH ROR THE PHYSI IIIC STUDY AND MEDICA OF 1971 THE APRIL OF THIS VITAMIN IN II METABOLISM NUTRITION DELI UC THE SEVERE FOR THE DEFICIENCY OF EXPERIMENTALLY INDUCED SENIVY FIVE CORUPAN IONS IN RI ED CAL SCIENCE AND AD YEN TIRE WERE RECRUITED FROM THE IOWA TATE PEN ITE RID HEIR INFORRN ED CONCEIT WAS OH RY TA FOR PERIODS LALIGRIL FROM 84 TO DAYS WHICH SILLILY DIETALY CONSISTED RED WERE FED OF ASC III THEY FREE OF ITY THIS 1W STOMACH TO BE FORM LIQUID ACID BECAUSE OF THE UN PALATA BIL LOOK IT THRICE DAILY VIA FORMULA TIE INERT LUBE IHCY WERE EXPOSED IN CONTROL ROOM TO TEMPERATURE OF DEGREES FOR FOUR HOURS EACH DAY IHE VOLUME BLOOD DRAWN FOR LABORATORY PURPOSES WAS GA SINE POLYETHYLENE UOLDCIRNATE FILLY LARGE CAUSE TO ENOUGH RNEN MILD ANEMIA IN ALL THE DR HODGES OBSERVES THROWAWAY LINE THAT TIE MINERAL RTTPP NIENT RECOMMENDED BY THE NATIONAL RESEARCH COUICILJ WAS INADVERTENTLY OMITTED FROM THE DIETS DURING THE FIRST 34 DAYS OF IN THE DEPLETION PERIOD THE EXPERIMENT WAS GREAT SUCCESS IT WAS THE SEEND OF ITS KIND DR ILOJGES HAVING TRIED IT ONCE BEFORE WITH FAR LESS FAVORABLE RESULTS DESPITE SOMEWHAT SHORTER PTHOD OF DEPRIVATION IN THE SEE END SCURVY STUDY THE SUBJECTS IN THE SECOND INNATE SEVERE DEVELOPED DEGREE OF SCURVY THONAB CLONE OF TIE IN THE FIRST SUBJECTS STUDY DEVELOPED FOUR OUT OF FIX SCIENCE SET OIIUL IS AND DIS SADI SAYS AD UHO NIT UINT STUDY EVIDENT SKIN III EN DAYS OF HEN PETECLI HE COILED AND FIRST RES PECFLV II TICS APP ELY WAS PARTICIPATED AL SCURVY COMPLAINT IN IN THE SEE AID PA IN MADE BUT HAD NOT BEEN SWELLING EURVY III THU SUB THE GRADUAL OSS TRACED BY PR ITE FIRST SIN OF IS THIS ARTHRALGIA OBSERVED WAS AT NY THEMSELVES RESULTED II IN THAT REPORTS P15 INC RS AL MOST LYRICAL ITT AND TLI TEAL ASPECTS IN TO THAT FAVORABLY INLET INCENTIVES AND AD ICS ON BECOMES AURAL TO VOLUNLEERIMLG SD 11111K LILY SI LB FOR IT PRISRILER ETA SUPPOSED CLII TO STUDY GAIN MAY HE THE OILY ONE DOLL TURN SU ONCE THE PAROLE BOARD MOTIVES OF FESE IDLELA TRIORE NOT IN WIDE II TESTS OF SENTENCE OD GES ROU TILT YE TO IN PARTICIPATED FOR SEMITE PRISONERS MOHLEIILMY MILL LIVE LHOICGH INMATES ARE DAILY EATEN STIBUIITTED FOR CLINICAL OPPORTUNITY CLI WISH CLINICAL CI OH TO OF SPECULA CI MAN PR BUT OBTAINED THE USE OF OF 224 TOTAL CLEARED OF TUNE II RI PILYNI OIL JOURNAL HODGES HA TED WE PERINENTS THIS THE BURNING CURIOSITY ON THESE SACRED SUCH EXPERIENCE IS DESCRIBED BY DR HODGES OF HIS PAPERS CLINICAL MANUTESIATIONS OF ASCORBIC ACID LEHCIENCY IN IN THE ANERI CAN III THE HODGES DURINA OF HIS REWARDING EXPERIENCE AND FOR TILE SUBJECTI IS DEGREE DRRELIC WHICH ONE WAS IT SPECIFICAHY EVEN PROHIBITED CAME TO TIE ATTENTION OF EXPEAIMENTS IOWAS ATTAIN CY GENERAL IN HIS IT WAS UDGME NOT LEGAL FOR US TO ACCEPT PRISON VOLUNTEERS FOR NSEDIIA RESEARCH THERE FRI OWED TWO FALL OW YEARS IN WHO JLILRTIIACOLOGIE HEEI NEITHER TUALLY FI GIITORS CIA WHATEVER RIGHTS CAD PUT HAS PROVIDED HIS THIS SACRED EDGES WI THETA CLAHORAT IN CON CI IIDES VOLUNTARY PALL CI PA SYSTEM RN LY HA SED ON LEGAL AND ETHICAL STALL DARDS II LION IN SUBJECT II ALWAYS RIGH 15 COLLEAGUES RECCHCD GEMCOT WITH IOWA PNSNII KNEW THE FORLORU MUST CANVASS THE PTISON POPA WHO WE OLD SUBMIT TO PTO IN UN IVERSITY AS IC HOSPITALS TED PCRRNI APPEAR LIRE VENT TO LONGED HOPILALILALUIN SEARCH 197 RID AI LITIN OLUNTCCR FOR IL MCDI CAL THE IT AJCDILL1L HOD ES EABLI OFFICIALS LB VI IITCR NE HE DESCRI IRC LIE 1LODGES II JOURNAL OF 1H LATE FORTIES DI IC WILT 020 ITER IN HIS QUCST TOT BED LY LR ROBERT TO XPCR ESCA II IVE RSITY IGE DR JL II PROLESI OF THC VIC SSTUD PRISONERSUBJ RT LII AT SONIC SEARCHER HIS QU UCS COIL II IN SCURVY PA RTICIPATIRG SCURVY ILL THE FIVE PRISONERS WITH SOME ECITIL ISITISM IDGES ETS OF EK TO IN 10111 UD ICS IVY RRH AGE ENIRLRIB AGES IN THE VERE OBSERVED IN TWO OF THE ARED ILIE GUMS APPEN ID ON FIRST TILE EFINDE BE TWEERT THE 42ND AND 74T1T ABNORMALITIES 43RD AND 84TH S7 IF JF KNEW THIS SPCCIFICAUY PROCEDURE WAS NOT HIW BUT NEITHER WAS IT BY JCRFLHITICTJ PROHIBITED SPEDFICALLY AI DAYS OF DEPLETION ASCORBIC ACID PROGRESSED AFLER THE PLASMA IHE ONSET OF JOINT LEVELS FELL MONEY HUT WE WERENT COURSE MAN WE HAD OF THE IN IEGS THE RD III HO AD THE II DCGRCE OF SCURVY IRNE IT WAS ALL OVER VERE JO LAY THE TO CHALK SI TB FIVE SUL4ECTS SUFFERED LEGS DEUIT VUTTES AND CI EAR OF HAIR TIC RT IS ALL WHITES OF IN AND LEGS HEMORRHAGE THE ONSET LED SI GIT SCS RVY CC THOSE CIT II RI ALLY GAIN MEDICAL TO OTHER DOCTORS SENSELESS STUDY APPEARS AS VOL CIT TEDS ON THE FIVE DR POINTLESS ST II UT THE SOME ERA LIONS SEVERE EASE OF CRUELTY VISITED UTLY TO TALLY WITS EFFECTS HE MAY LISTS WELL YOUNG MAN WHO LAD THE MOST OF SCURVY MAY NEVER HAVE RECOVERED TO THO DEGREE OF COMPETENCE OF THESE SOEALLED RESEARCHERS THEY INADVERTENTLY OMITTED MINERAL FROM THE DIETS TB TIPPLENRENT NO DOUBT OTHER WEAKENED SIDE TFECTS AND SHOCK AMONG HERE EFKETS PULL LA TITN IT SUFLR TO OF THO MEN THE NI IF HI AND CA EXACERBATED SC CARDIAC SEVERE THE CC IT EXPERIMENT ID BE PERITIA C5 OF HA THE DR NETIT HA LU CART ASKED DR AT SCLTCTUI DITVIS TEST AT THE RAAOR WAS IN BLATTES ESVHA IOWA WEMUT ITS XL OF NTERXIA MEDICAL HE HAD PAID THE SCURVY WAS ONE DOLLAR OR MAYBE XXUUCH THINK DAY TWO DOLLARS SORIT HOW PROFESSOR OF ALI FORNIA UNIVERSITY VOLUNTEERS WHEN NOW LIODGES MEDIDNE IT HE AS REPLIED OVER THE OF CIGARETTES COST UP WE INCREASED CIII TO EMIL PAY THE YEARS AND PRISONERS AN NIOUN PAY OF DRUGS TO BE TESTED MARKETED ARE SOUND AND WAR II HUMBET CU GUIDING PRI IT AVE BEEN DEVELOPED AND CODES OF ETHICS TO BY THE MEDICAL PROFESSION GOVERN THE CONDUCT OF AN AXMER CAN MEDICIL ASSETEIS THIN EXPERIMENTS RESOLUTION OF 1946 ON HUMAN RESEARCH WAS IN TURN FOLLOWED BY FDA REGU ALIONS OF 1962 ANTI THE EL SINCE WORLD EPICS IT DEEHURATION OT 1966 THESE ARE REHETITIVE LARGELY MAN RNUS EXPERIMENTS TOCY WORK AND TESEARE OF GRAVE RESPONSIBILITY EXHORT TIM TO AVOID BASED ON ANIMALS 1972 US THE TIOTI AND WELFARE AND DETAILED OF THE IN ETC PRE VI TO REGULAT COD ON PC UNNECESSARY CORTSERT TUE XISLI LIOTECTICUIT RF WITH LIMITED PTISOJJCRS JOIN TO HI H1J MA XI PARTIEU HR CONCERN FOR CXPRCSSC GROUPS ETA THE SUBJECT AND AXE OF NO SCI TOED TITLED SIS 11W FT TATIOS EIITPTTASIZE 12DUCA PARLMENT OF ICALTH CI SET OF COMPREHENSIVE IS INCORPORATING PRINCIPLES PRAISEWORTHY SE LI TXU EM THE MATTER DROP DR INST 1W LABORA TCTRNUECL THE ITA THAT PRIOR TO HUMANS CR ST 19 LW AFFIRM ON OVESLIGATOR ABOVT PAIN AND RISK OF THE SUHJEET MUST HE IN ALL BE MENTS THAT VALUE OR THAT ENTIFTE RECORDED THE THE FDA TIM HUMAN EAPERITNEN TATIOI THEY SAY NECESSARY FLU FRAMEWORK OF STRINGENT MUST LIE COXTDSTCTED WITHIN MIES FOR THE PROTECTION OF THE HUMAN SUBJECT IN SUBJECTS THESE INCLUDE IN DISCUSSED REQUIRING BEFORE BEING HEXO DA MAGC RLBT IIN IC TED II HEUUORRHAGE INTO FEMORAL NERVE TEATHS THE LATTER IS XD COULD LEAD TO PERMANENT TERTIHLY PAIN FIIL NERVE DAMAGE CITED BTTMANS HAVE UNANIMOUSLY AGREE REGULATIONS ON SUBJECTS THE GUIDE TO GO INTO ABNORMAL TIES WHOM WITH MATTER THE CLUE THERES SIDE LIE TT BE IRREVERSIBLE FOR REALLY TO OCTORS SINKI CAUSE AND ETTRE OF SCURVY HAVE BEEN WELL KNOWN IN THE MEDICAL PROFESSION FOR GEN PTIBLIEATION EXTRA ORE DEFICIENCY OF THE CALIFBRITIA SAID OF DR HODGES HEALTH PUBLIC ACID PIECE WI KAHN FPHRAIM OF DEPANMENT ACCORTL COUNCIL RCSCARCH ASCORBIC THE OF TKITE II PI PLUS CONCLUSION ANTICLIMACTIC 1LODGES OUR HSEI WIT UMS AXE JII OF THE BRITISH DISEASE THY SHEATHSL PERIOD SUPER JOINTS DR NIORATION IN BIT GOT THE RAPID ONSET OF ARIBROPATHY PAINFUL TENT ORUL NE UMPOSED ON BILATERAL IN BOTH LARGE NERVES TO THE II IGHS NERVE TU PLEA5ARI NGS IF LUBE DOWN THEIR THROATS FOR SEV PUT ERAL HOURS OR TAKE OF THE SKIN THE SIZE OF THEM FEW DOLLARS PENCIL ERASER WED GIVE CR5 THE BE INTO HE PRISON LISTIORI SIT OF 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CORRECTION AT INSTITUTION AVON PARK CORRECTIONAL INSTITUTION CONNECT ICI REETIONA SYSTEM MONT INSTITUTION MEDICAL CALIFORNIA INS TIT GLADES PRISON RAIFINL LOWELL COR GIACTES STATE BELLE INSTITUTION TIOT LOWELL FARM PRISON ARGO PETERSHTRG ATLANTA FEDERAL PENITENTIARY GEORGIA ILLINOIS JOB PRISON INLET INDIANA INDIAN STATE PRISON MIEB IGIZI US COUNTY JAIL INDIANAPOLIS IOWA ANARNOSA STATE MCIIS REFORMATORY CITY IOWA CITY II PRISON NEW OR CANS HOUSE OF CORRECTION JESSIP CORRETTINAL MASSACHUSETTS IN LA MIS LEANS OU ISIA NIL MARYLAND MATYTAND MASSACHUSETTS NORFOLK SON SOUTHERN MICHIGAN PRISON JACK STATE HOUSE OF CORRECTIONS PLYMOUTH DETROIT MISSOURI MISSOURI STATE JEFFERSON PENITENTIARY CITY MONTANA MONTANA STATE PRISON DEER LODGE NEW JERSEY ESSEX COUNTY PRISON CAIDWELT NEW YURK ATTICA STATE PRISON ATTICA SING SING PRISON TARRY TOWN OHIO ITIRIRULI RECT TOO AT 051 OKIAHON PSYCIRI SCHOOL OF CRIMINOLOGY WHO HAVE LEGISLATORS THE CALIFORNIA TO STU DYING PMISOIT YEARS DI INTY AWARE OF THE EXISTENCE 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ABOUT ADVERSE SIDE EFFECTS CAUSED BY PUBLICATIOTI THE DISCLOSED RESULT OF ACH ULCERS AS DITION WITH STEROIDS SHVI PR 1972 THE IN II INDEPENDENT PHYSICIANS ETED DRUG WAS AD IIIIIIIST ON MM PWS CLAIM THAT THEJE HAVE ON CHECKING BEEN NO DEATHS OR SERROLTS SCCIO ELSE IS NOT EASY MAINTAINS IT IS TINDER SINCE SIMPI NOT REQUIRED THE CALIFORNIA PUBLIC RECORDS ACT TO DISCLOSE MCD ICAL OF VIIRIDASE OTRARNUSCULAR INJECTIONS FIBRINOLYTIC CD AS AN AN TIINFL AN 11 ATORY AGENT EVIDENCE ABORATORICS GIVET BY TCDCRLC PRODUCT CFL7VITITS DISCORFORT PAIN WITS FPSTEIRI IN NED WROTE IN EATS MIGHT IC AM FROM FEVER LOOKING CR TO HIS ER CLOSING ONE OF LIRE ENJOY HIS DESCRIPTION AND FOR CHILLS HE WAS SPONSORS AT RICIUGH SRI BJEETS WERE WHAT NOT DISAP HE EDE RLE COPY OF THE THOUGHT CO NI YOU OF THE SYRNPTOMATOLOGV WC IT FURLY DE AMONG WE TNJOYCD MEN EXPE AL THE OF WHAL RTPRESENTATIVE THE NENCID LEDEILE THAT IPTIONS BY TBE NINETEEN SUBJECTS GIVEN BY THE PLAINTIFF NOT STIC AND SUBPOENAED SWEATED PAN AS PART OF THE 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WAS TOLD ONE HAD TEEN SEVERED BY THE UNIVERSITY IN 1966 AND THE OTHER HAD DIED IN 1968 HE CAL FORNI OL CORRECTIONS DEPARTMENT PUB FISHES NII ANNUAT RUSEARELT REVIEW IN ONE SECTIOTI OF WHICH SONIC TLI ERAS FLY EXPERINI CONDUCRED VESTIGATORS CHAT HE USP ITES RU FL II SINCE IN THESE NIENLS ARE IS FOR ARE SET TBRTH CC AND TICOLOGY TRELTED NIC CHIC THE ST IN THE THE LANGUAGE OF CC OF ILLS OBSCURE PART DER PTC1 FORM IN THE TO PHAR EXPERT LAYMAN THE ART IS EXCEPTION AEDES MOSQUITO STUDY IN WIT ICH FRESH HY FED II RILE NIOSQ TR ITOES HI EAREFU PREPA RED BITITTG CAGES ATE APP TIED 10 THE TBREARNIS OF VOLTIC TEEM FOR PERIOD OF TEN MHI RE UTES WIT CAR TI LIE CC PR AT CON ORE PNI UICI EXPERINIERI FORNI TI SED STATE CIGE EON ITEL JOINS ECKING 1971 SCENTS EXPLICIT DANTE HON IS AT GH ELICIT ICR NA LION DESCRI DURES FOR BROTHER STUDIES IC ECS ON HEAT IN ITT IR IN ITIE NI TI ON ED NOTISIRIL TO FLU VOLU SEERS AS RGEN CC AD WITH FASCI TIO HE EXPERI NIE ITS TRA OSLO TED ME KILLS IT HE PROCE WOW OR 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THE TNES III BERG TO CC RRENTIY USE IM ML SAID CARDIAC ES TOXICITY ALL MI HI EREISE USE TIME MOST OF ERESLIOLD OF AS AND ND CON FREQUENTLY ITS PERFORMED IKE BARBARITY OF OLE EXPERI EARN INMATES ON IS ESE OF COURSE II RIPS RALLELED HUT THE NUREM BUN ESU BI ISH ED STANDARDS FOR II ED ICAL CX FREE IT IT RIGHTS WHEN ICIDES NISEEL ITS III PUNS ERGANIC DANGERO TOTAL LOS 1USTORY OF CAL PCI WOULD ECA ARE ENTER THEY THE DES OF CONFINE IEEDONI CREISING SITED FUNII SUBJECTED NEC CLIELTI OF BY EH TIT EDGE AND EN NSPRE HENSI ON UNDERS LAND BIG AT IN OF BLOOD FLOW RE THESE QUESTITMNUS IS CA WE MAT NTERS TIM TO VEAL TRUST OR CX THAT HIM ECISICMSS ATISWEM OF CAPABLE HEM INABLE TENED BE IS CII TO THEY KAIOWL TO MAKE ASK IBENI ALCHEMY ALL THE GOLD THAT EXISTS MEN ICANISIUIG BY WHO BROKE TOOK WAII TO USD AND AND II FOR IT TERL HAVE AND TO WHO FOUND THOSE BY CRUEL DISTINPUISHED JED AND SHOULD HAVE POWCR OF CHOICE OF THE DC KNOWLEDGE AND CONIPRELSENSIONI MENTS MF HC SU BJ ECT INN TEN NVOLVED AS TO ENA IIIS 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THERES TOE FOR OF WHICH INVOLVES CUT GET PA RT USD TIE II THEY TO SUITING WILL ESE TEN TLI HEN FLESH HORRIFIC III USEL MAKE THEM THEY THE EXPERTRUERUIZTION THE ORGANIC PHATES NO II PPENS TO SCM EN BE TOTALLY RISK BUT MAY RN BLOOD SAMPLE IRS THE III WOOID OF TOLD SUBMITTED FEM GO ITSELF IT UNIVERSITY CIPI WHO COLLECT OR CC BE 45 NE VER BE APPROVED FOR STUD CII NOR HAD IT YEN BEEN APP CV ED BY THE OF ALIFOXN MEDICAL CENTER COOT TJ IT CC COCKEYED PM TSE 13 BROUGH OF MUSCLC TISSUE HATS EXPERI STIBJ DL MARGEN TO ARM THE SWEAT EJACULATION AND JDDITION LERE WLI JET FOLLOWING 24 ML ITT IT CHANGE BURIED WE TLSEMUISELVES IT IT MCLIII FOR ITS NI OWL SAKE THAN TO THIESEE TO TLSER FOR THE II WAS TRANSAINTELL IT WAS EVIL CY DECLARED THAT TRANANIUTI RIG II INIPOSSIBL EVIL MERWIN 73 THE UNIVERSITY CF MICHIGAN COLLEGR OR PHARMACY WAGNER RHO JOHN PROF OF PHARMACY CA AMY 1401 IJT ANN FOR RAFL PHARNACY ST ANN ERVTCE ARSOR MICH 40104 OCTOBER MR 20 1972 ROBERT MANNING EDITORINCHIEF ATLANTIC MONTHLY STREET ARLINGTON BOSTON MASSACHUSETTS DEAR 02116 MR MANNING LETTER IS IN RESPONSE TO THE COPY OF LETTER FROM DR WILLIAM DIRECTED TO APPLE YOU CONCERNING USE OF PRISONERS AS SUBJECTS IN DRUG STUDIES SUGGEST YOU WRITE THE FOLLOWING ALAN VARLEY MEDICAL DIRECTOR PHARMACEUTICAL MARKETING THE UPJOHN COMPANY BUILDING 88 PORTAGE ROAD 49001 KALAMAZOO MICHIGAN THIS RECEIVED STEPHEN PRESTON CLINICAL FLIRECTOR CO PARKE DAVIS RESEARCH LABORATORIES 2500 PLYMOUTH ROAD ANN ARBOR MICHIGAN MD TNVESTIG DEPARTMENT 48105 CO HAVE BUILT UPJOHN COMPANY AND PARKE IJAVIS FACILITIES BEHIND THE WALLS OF JACKSON PRISON AND THE ABOVE TWO GENTLEMEN KNOW THE JACKSON MICHIGAN MOST ABOUT USE OF THESE FACILITIES SOTH THE HOSPITAL SINCERELY JOHN COPY CWAGNER PHD MD WILLIAM APPLE EXECUTIVE DIRECTOR AMERICAN PHARMACEUTICAL AVE 2215 CONSTITUTION ASSOCIATION NW 20037 THE RESEARCH IN 1964 ESTABLISHED FUNCTIONED INSIDE CLINIC THE AN FOR STATE OF MICHIGAN UNBIASED RESEARCH THE STATE POLICIES FOR AS STATE PRISON MICHIGAN THROUGH PROTOCOL DEPARTMENT OF CORRECTIONS COMMITTEE WHICH HAS ITS REVIEW CLINICAL WER REVIEW KNOWLEDGEABLE SCIENTIFICALLY HUMAN RESEARCH CONCERNING RESEARCH INVOLVING VOLUNTEERS COMMITTEE ADVISORY THE SOUTHERN IN AND THE PRISON POPULATION FROM THE PRISON POPULA STATE AGEN ESTABLISHED THE UNIQUE COOPERATION OF EXISTING AND THE MEDICAL COLLEGES PERMITTED THE FORMATION OF AN OVERALL ADVISORY OF COR COMMITTEE WHICH INCLUDED REPRESENTATIVES OF THE STATE DEPARTMENT MEDICAL THE HEALTH SLATE RECTIONS DEPARTMENT AND THE TWO MICHIGAN TION WERE FIRMLY CIES THE ESTABLISHMENT AND FUNCTIONING OF THE RESEARCH PROTOCOL RE COLLEGES PHASE VIEW COMMITTEE ARE DESCRIBED AFTER THE COMMITTEE WAS ESTABLISHED STUDIES WERE PERMITTED WITHIN THE PRISON POPULATION SINCE THE FORMATION THE RESEARCH PROTOCOL REVIEW COMMITTEE IN SEVERAL HUNDRED PHASE AND OTHER STUDIES NO SERIOUS ADVERSE REACTIOH HAS YET OCCURRED OF RESEARCH PROTOCOL REVIEW COMMITTEE FOR THE STATE OF MICHIGAN MD JACKSON TAYLOR ANN ARBOR ZARAFONETIS ANN ARBOR EDWARD CARR JR LAWRENCE DETROIT POWER ANN ARBOR PARK WILLIS ILL PHILIP JACKSON RILEY JR BY ROSS LENIS MD MD CHRIS JW FOOD AND DRUG ADMN USE OF DRUGS IN TH IS THE INISTRATIOUI OUN TRY IN NIT TIUCRICE LATE WHILE IIIIVE INWARDS RUED IRONS ICIIICAN DIE THE ACTUAL NO INTRODUCED TARE LAST MISSION VIITTHVLT STUDY AND IISTRAEN TO RHESC VOL 68 IN THE SUUECTS TILITAN ON 19 NOW FURTHER NEW YOIK STATE HAVE ESTABLISHED YEAR WOIJID ALL WITH NILNUL LV TO CONTROL SOME PROW MEDICINE DJ THIS CORN APPEARS THAT COMPLICATED BY KGISB STATE OR NATIONAL LEVEL LTGISIA IT BE MAY AT TIVE MICHIGAN KEIRI PHARMACCUTKD ND SATISFACTORY UNFORTUNATELY HAVE OF THE COMNIURUTY PRACTICING FUR THE MOST PART RRUDE EXELLENT HEW REGULATIONS MD MD NEW REGULATIONS RESOLVED XRADEMIC ILW PL1YSICI MD DURING THE PAST FE YEARS ED IN MARKED INCREASE IN RERNIN INDUSTRY IIGCS MEDICAL MEDICINE 12311128 IT LEGISLA CORN RCS3 IN STATE TIT WAS PROPOSED THA RESEA ITLI OF COIL SIST OCTOBER CTOBER III 1969 IS 1023 IT PROTOCOL RESEARCHJCONFINUCD BY THE GOVERNOR AND APPOINTED THE AD FURTHCR PROVIDED THAT NIOL OTHER IITENIBERS 1E THAN SIX OF LI USE 11 OTHER MEMBERS THALL OF THE INEDICIJI 411 TIMES BE TIONMEMBERS PROLES CLIDIRNIAN SION THE AND FANREACHING FOR SPONSIBLE WOULD NIS IN FFI WHO ALL IN HANDS RE ARE CLINICAL OF WOULD IT IRGR REVIEW ALCA OF LAL DIRECTORS OF ALL LHTULITY LIOSPI MEDICAL DEANS OF CREATED HAVE ALSO RES NIL AND 41 PTOLESSION THEIR AND HU WHETC AND THEIR INMATES CRCATC TO SITUATIONS IN PARTICIPATE SUCH WOULD RESULT SHOULD ALL SO STATES LAWS REGULATING RESEARCH ON 1W CHAOS STUDIES THOSE II BOARTIS VOLMIMUTEET DIFFERING NAN ON THE NATIONAL IN SCENE THE RECENT PROB NEW RODE TIMES MAY 31 THE ALABAMA THE FOR NECESSITY 1969 CONCERNING BOARD OF CORRETIONS THE DRUG IN TIE STATE CONDUCTED BEING PROGRAMS ADVERSE PUBLICITY IN WIDESPREAD PRISONS RESULTED AND RE AND EDITORIALS CORUCERNING DRUG TESTING TO HALT ORDER TO SCAICH THE 1969 ISSUE STATES ALA ASSOCIATION COMMISSIONER THE GAYLORD NELSON THE RESULT CRITICM LIMES MOST MONTGOMERY REPORT BY THE ALABAMA FDA JR WAS CALLED BE IRY OF SEN MONOPOLY SUBCENUNITTEE DR LEY TESTIFIED THAT FLWIS WOULD SEEK HAVE UN MNAXLRNUTN AS TICIPITING SUBJECTS HUMAN SRNIVER FOR TIME CENTERS AT THE PRESENT AND MOST HOSPITALS CENTERS UNEDICAL HUMAN ILEUNGS IS PER WHERE RESEARCH INVOLVING FORMED HAVE REVIEW COMNVTTCES ASSIGNED THIS XC OF BUT THERE REMAINS LARGE GROUP SPONSIBILITY OI CURIMIT LAT HOWEVER MUST AND TILE EXPERT THE WOULD LAITY OF STATE OVER FIVE FOR THROUGH THIS DESCRIPTION FOR OF THE II ITLT RT ITS OF EFFECTIVE THE USE THE II IS IN PUISON RESEARCH PROJECTS OF YEARS FOR WAS CI MEDICINE OCTOBER 1969 VOLUN OF IMNIXETAN LECAUSE IN THE II INCUS LRTGRALFL MEDICAL MICHIGAN COUUIMISSION STATE PIT AND RESE RTHTEIIIHEV MEDICAL MICHIGAN OF FOR IVITILDING LIE MD FLEARU SCHOOL THE THA IN STATE THE AUIEL OF THE MET WITH OF IOU IC GENERAL CONSTRSXC TION WIELTIMI SPIIEE LUOSPI OIL PJOHN FOR POSALS THE PROGRAMS MD JR LED 961 NE DI TO SERIOUS PRISOR HAROLD OUTLINED INTEREST THE RESCA RD LIXIMITED 961 OF RID OF AT HOPE THAT MEANS TLSC PRECEDING CORRECTINCUS CONDUCTED CORRECT UU HI PRISON HERE IM POPULATION SUGGESTION HAD BE SEARCH EXAMINING COMMITTEE AND FUNCTION OF HISTORY STATE PRISON AT ME SOUTHERM MITLIIGAN SUGGESTION BY THE TTPJOLIEN COMPANY IN BE CONSTRUE EEL INSIDE IESEA XCH FACILITY MXCIII TE G4 ROOMS SAFEGUARDS OF CORREC DEPARTMENT PROTOCOL REVIEW BACKGROUND TEVIETWERS LINIVERSITY MICHIGAN AND VISED ITS IVFLLTHMT 1024 LEL HELPFUL TO OTHERS SEARCHING FOR LEA HOG WITH THIS PROBLEM NEIVEUUIBER FOR II BE MAY EEULD STATE LIEU GSUIDANCE SEEM THE AOMWXTTCE MSPRESEIFLED IT PROBITNUS FACILITY LINT PROVIDED TUE HAS PROVIDED MIEHIGARM YEARS TIONS IA MICHIGAN RESCAICLI OF JULAEEMCNT INFORMED UN FOR WHISNI PH SONERS OFTEN TMNTEERS SUPERVISION ISUI SPECIAL PAR NEW IN IN NEED IT NIRDICIL UNIVERSITY ALL THAT SOUTHERN THOSE RESEARCHX MANY OTHER STATES THERE SOME MEANS BY WHICH APPEARS IN HUMANS CAN CEUNRMNUE WITH DRUG INVESLIGATION IDEQUATE SAFEGMNRDS FOR VOLUNTEER SUBJECTS OUTSIL BE TO TO THE THE BE CONSTRUED FOR PROTECTION IN ALABAMA AND YORK SEA LABORATORY ARID NOT TO THE NEW ASSURE TEEN FROM PART OF THE DOILL TO AUSPICES OF THE COMMON LCGISLMURE YORK WIDTH IS PROPERLY ATTEMPTING OF WEALTH OF TO WOULD II THAT BILL FDA 1HESF COMMENTS AS II HAS IN TIODUCED WORK SUCH 1L TN CENTEM UNDER FEDERAL CREMTE LEI XF TT SENATOR NELSON OF OF THE STATE HERBERT SENATE AGTFLC OF HAT REGULATION REQUIRING AND HOSPITALS BE SCREENED LAWYERS AITL OF PHYSICIANS PRISONS AMIGUAST AS YORK IN CRITICAL ARUD ADVERTISER MEDICAL THE IUAITLY STORIES BY HAT IMPRACTICAL IN NEW THE IN REHASH OF EARLIER LY THC 13 PAGE DISELOSUIRES RTTCFLT FORE WORLD NEWS MEDICAL 1969 NEWS AUGUST 25 NWN TIER NA BOIL THE THE MONITOR ISSUE SCSFLZMG FL PEER GROUPS BY RESTING TH ROUGLIOUT TO HE PTHSINED DRUG OF LEMS DISCLOSED INSTITTI OTHER AND MERICAN LHC AND PRISONS DTIIG WAS REPORTED THAT DR LEY IN QUESTIONING STATED SMALL BUSINESS SUBCOMMITTEE SETA IT FACULTIES THEIR COMMITTEES TO STUDY INCLUDING RESPECTIVE RESEARCH ME TUVESTIGATION CLIRMIAL INVOLVING AND WHICH FOLLOW GUIDELINES SET FORTI MILAN BEINGS ARID HEALTH SENICE PRISON CONS BY THE PUBLIC MISSIONERS IN WHICH MECHINSTN SCHOOLS AT PROTOCOLS TION CONDUCTING EVALUATIONS IT HAY NONINE ADMINI AN WOULD STAFFS TO COXIREM OF DEVELOPUTEVITS ARC LEGISLIIIION THERAPET THE NEW VOIK COLOGY POSS1 SUCH OF IRHPLICATIONS EX THE OF SOUTHERN PRISORM 1961 THE CORRECTIONS CORNIXISSIUN IN APPROVED COFLGRUCNON OF IN BE VOLUNTARY BI OF AND INCLUDE FROM COMMFLY POSSIBLE THE HIS SSOI ITED AN ANTI IN LILY PARTICIPA TI FL HAZARDS RATE OF IN NARY WI TI DRAWAL FOR COMPENSATION THE LATH ONI AND DIET SPECIAL COST OF ISIL OF PROFESSIONAL 1962 DI NET OR TO INFORM DEPARTMENT POSA1 AND WIT OF THE STATE THE JINX IJECT IE LI OF II IITG IN FOR THE MARCH ONE STAFF AND CUSTODIAL ASKED THE UPIOHN DIRECTOR TO VIM PLO CONSTRUCTION OF RESEARCH BR LDINGY THIN MIS ION REVIEWED THE RE LIE WARD IN THE HI TILL MORRIS FOR VOLUNTEERS AT INPATIENT PRISON RESEARCH STATION THE HE IN INNER FOR THE RESPORISIBI OF SAFETY THESE EVA NATE BE CONCLUC RED II DON IT RISDIC MAY 1961 NENT OF ALL OF STATE IE OF FOR TINY TIC LANE OSTER VARLEY THE COMPANY THE MMATE VOL LIII DE AND II THE PAR TTTETS PROJECTS 1LSEY RECOIN PROTOROL REVIEW CORN OF RESEARCH MI DC PARTINENT AN ADVISORY MD MD MD DISEUSS CLI OF IGA II TO PROJECTS WITHIN CORRECTION COMMISSION APPROVED LIAR OF SAFETY STAT MEDICAL LIE THE OF OF RESEARCH THE FORMATION UN OF YEN BE ERSTI REVIEW ULIBIASE WARDS OF TIC AS FOR AJI WELL PROJECT PRLQY TO INITIATION IBIS CONCERN OF THE UPJOHN CON COINCIDED WITH THAT OF THE DEPART RESPONSIBILITY TNIETIDED OLIN THE THAT THERE OF PRINT TRY FNSONIERT ICIPATING CONTROL DI PA CII OF COTIET TONS PA IKE DAY IS CORNPAU THAT BE IJIJ HAS THE SAFETY IMPROVE STUDIES AND ALSO THE LITE POJ CORRECTIONS OF WHICH LIE UN BIASED TO THEPROBLEM HSTNICE ANY OFFICERS STATE HSII CORRECTIONS COMMISSION THE LIE OF THE WITILIJI ATI RI MI MD 5163 OF OF WAS ON MARCH ALEXANDER 1911 EDWARD HAROLD HOLMES RUBEN MEDLAR MANN AND MR RAL PH WILLY MET TO IL WAS PROCEEDING WITH IN MAY ADVISED LIE LIE FJ TIUN PNWTANI HE OF FOR FIAT ERNIRERNIEUI ILTTSIRAHLE LESIRT ADVCRS III PIOJERTR AUGUST THE DIRECTOR REPORTED TO THE COMRNI ISSION TLI AT UITEETIUIGS AID BEEN HELD WITH THE ARCH IRCR TO IN CARE PLAN CEED RF 1ETO ION EMPLOYEES CONSTRLXETNON PO APRIL ITS JRNLT RESPONSIBILITIES TRSNLA RCLI PROPNTSC INR NENT IRLSIITANEE TIABILITY IN HIT DING VOL JJTEE AN AND LIAR INVESRIGATOR MD BECAME NCL MIX STES HAROLD 1964 1UECHAN1SM EW TT SONS PANY POLICY II THE COMMISSION IN NNNDISRRITNUINAIORY PARTICIPATION OF WAIVER ON IN UPJOHN THTHTY BASED RATE RC RT ONLY REVIEW OF RESEARCH PROINENIS RESEARCH DEPARTMENT OF THE GURIIPA IE VOLUNTEERS BE AND COMPANY RESEARCH OLD FAR ANY TIME AT THE CONSENT VOLUNTEER RIG RH COMPANY TO THE REQUEST BE APPROVED LHE UPJOHN ITIFOFLHLI OF TO VOL RIGHT STUDY STIPULATE EACH NATURE THE THE LLILCLING RCL EARLY BETWEEN PJOHN II RE LILA SEA OM CONSTRUCTION OF THE RECOMIREN DED TO THE DI FL THIRKC CORIJX STATED INSTANCES ALL THE UPJOHN HAL TIIDELINES UPON INFONNED AGREEMENT THE QUEST OF TFLUSU PARTICIPATION BE RELATIVE LICUII FACILITY INMATES OF PARTICIPATION THAT RCCOTIJITLELIL PRINCIPLE THE TN THE APPOINT COMMITTEE PROTOCOL REVIEW OF CNRRECNIONS HR RE ESEANCH OUT OIL VIEWING PROPOSALS TO BE CARRIED VOL MINTCRS UNDER RISTLICTIONI OF THE DEPARTMENT II SSISI IN TIIIT 4II PRII ITMILE MR OF CONECTIONS MICHIGAN MDICINE PARTRNEUT DI RECTOR RIISC INVITED FIVE OCTOBER TIE PHYSICIANS 1969 1025 PROTOCOL RFSEARCILLCORITIFLUED EDWARD MD JR MD GAZI RILEY PHILIP ZARAFONETIS AND CHRIS REVIEW PROTOCOL BETS OF CEPTED TLIO II KNOWLEDGE OF MAY LANE IN LA 1964 MD WITH TO TO IMPORTANCE CHAINUAN HAD AND SKILLS WAS ANTICI IT THE WORK OF THE MI ALEXANDEL VARLEY ALAN ZARITFONETIS MID CHRIS TO LIII MD DISCUSS EXPE THE COIN OF NEW DRUGS DEVELOPMENT AGREED TO VOLUNTEER PARTICIPATION THE MMSS ALL EXECUTIVE AS SERVE WHICH AREAS GOMMISSION THE MET WITH BECOME MENT TO CORNZUITTEE INCYNLWR EECH SPECIFIC WOULD BE COMMITTEE PATED MD TAYLOR APPOINTED TAYLOR WAS ASKED AND COMMITTEE SECRETARY OF DR AND MD MD PRESTOJI JOSEPH ROSS BY PRI NEW COMPOUNDS INVOLVING EXPERIMCNT WERE FULLY INFORMED IN NONSCIENTIFIZ IF THE INMATES AND WERE TENNS OF THE NATURE OF THE EXPERIMENT AT ANY TIWEP TO WITHDRAW GIVEN PERMISSION SOWN OF RECOIRUNENDED ADVISORY SPECIAL CO THE COTFLFLITTCC TO APPOINTMENT HIT OF POLICIES ASSIST IN DETENNINATION MAN RESEARCH THIS ADVISORY COMNUMITTEE WAS TO ROLL OF THE MICHIGAN DEPARTMENT SIST OF REPRESENTATIVES OF HEALTH OF CORRECTIONS MICHIGAN DEPARTMENT THEN THE UNIVERSITY SCHOOL OF MD OF AGREEUL TO TO OF DEPARTMENT COIN ADVISORY WAS WATERS THE MICHIGAN ON THIS SERVE DUANE COMMISSIONER APPOINTED REPRESENT THE MD COMMSSSON CONSTITUTION OF THE REVIEW COMMITTEE THE COMNPLETE SIATEMENT OF PURPOSE SMID FUNC TI6NS IN SOUTHERN PRI MICHIGAN STUDIES OF STUDIES STUDIES PIE APPROVED PREVIOUSLY REVIEWED DRUGS WITH ONLY MINOR PROTOCOL INVOLY DIAGNOSTIZ PROCEDURES OR STUDIES CLLARJGES OF VIOUSLY II NNMERCI LY AVAILALMIR TO DRUG OR TUGS MAY SUCH SNSTATES BE REVIEWED INFONNALLY BY LETTER III FOR APPROVAL DISAPPROVAL MAY REEOMTNENDATION TO THE DIRECTOR OF THE DEPART HE COMMUNICATED FONNAL COMMITTEE MENT OF CORRECTIONS WITHOUT THE PRRMWOIS INVOLVING DRUGS FLEW TO REVIEWED THE SHALL HE BY FORMALLY SYSUN MEETING PRISON ALL COXNNSISTEE IV STIPENDS STIPENDS AND EXPENSES TRAVEL TD USE OF CZNSUL TANTS ETC ALE PAID BY TIME FUND OPERATINE OF CORRECTIONS IRON PRO GENERAL DAVIS AND PARKE VIRIRIL EQUALLY LY SHE UPJOLIMM WAS CORNNSITTEE REVIEW THE UPROTOCOL OF ILL DUTIES TUE COMMITTEE SHALL MEET ONCE THE MONTHLY TO REVIEW ALL PROTOCOLS FORWARDED TO DIRECTOR OF THE DCPARTRRTEFLT OF CORRECTIONS BY SHE OF THE EXEC AT THE DISCIRTION INVOLVED ZZRAPANIES ILTIVE SECRETARY 1ROTOCOLS REPRESENTING REPETITION ING THE WAYITE WILLIAJIT COLLEGE OF MEDICINE DEAN OF THE UNIVERSITY OF MICHI AND ALBERT IL HEUSTIS MEDICINE DIRECTOR HEALTH ZMTTEE DEAN OF MD HUBBARD GALS PHD MEDICINE OF TWO SCHOOLS EXISTING GARDNER ERNEST STATE SON ROOM FOR SPECIAL IN THE COMMISSION ALSO AND MONITOR DEFIBRILLATOR ZOMISPANIES FOLLOWS LURPOSE TO REVIEW AND RENDER AN OPINION OF CORRECTMCFL5 OF THE DEPARTMENT OF RESEARCH PROTOCOLS ON THE SAFETY AND SUITABILITY OR TPJOHN COT SUBMITTED BY THE PARKE DAVIS IN THE SO BE CONDUCTED PRISON PANICS 0S STUDIES TO THE FLIREZTOR STATE OF MICHIGAN SYSTEM OF THE MEMBERS THE COMMITTEE WILL BE AP II OF POINTED BY THE DIRECTOR OF THE FLEPARTNMZENT AND WILL TO HIM CORRECTIONS SHALL REPORT DIRECTLY WITH OF THREE TO FIVE CONSIST PHYSICIANS AREA LOCATED IN SHE MICHIGAN RESEARCH EXPERIENCE ONE MENIBET OF THE COMMIT WE SHALL BE APPOINTED AND SHALL BE RESPONSIBLE FOR EXECUTIVE SECRETARY OPERATIONS OF THE PROTOCOL REVIEW COMMITTEE THE GENERAL PLAN FOR PROPOSAL REVIEW ARID IM ADMINISTRATION OF ALLEN REPRESCNR FOT TRNVIMTG WAYNE LOCTOR LAWRENCE PMMWCR PR WILL IS VACANCY CREATED MIMMOTLIER STATE 1026 HENNES JOI WHEN MICHIGAN UNTIMELY WAS ALIBI IW DR CI TIMED HE TO CUNMII OSEPLI CHIC TO FILL MMIUVCD ONE AND MC OCTOBER 1969 THE DIREC TOT OF THE DE IN TLTE COMMITTEE FOT DIRECTORS OFFICE EXECUTIVE SERIE DISTRIBI TI ENS TO COIN MOEMBERS WINCE OF RIME TE VIEWS CON MEDIC SAFETY AND THE BR PIOTCXOL ONE OR SUITABILITY OF TIE SPONSORING COMPANY REVIEW OF PINTO IMIVOLVING MEETINGS PRESENT OMIL PANY 4114 ROLS SUBTIM TED BY IHIA PROVIDE ANY INFONIM OIL NEEDED BY HE COMMIT TEE ADDITIONAL MORE II ITS ML MEDICINE FOLLOWS FORWARDED TO THE ARE OF TARY TO RELISAINS COPY COPIES REPNORTNMTAIMVES SHE LO AS OF PARTMEN THE DR DEATH OMIN ITTEE SEC PRESTON INFONNA TION ERRSSARY COMMITTEE FJNUMIONS HENNES WAS ADDED TO THE COMMITTEE TO SCHOOL MEDFRAT STATE UMIVERSITY II THE IS OR INDIVIRLUAL WISHING TO INITI FORWARDS AN APPROPRIATE ATE RESEARRLS PROLECT MUNMLRR OF COPIES OF SHE PROPOSED PROTOCOL WITH EVIDENCE DR PROTOCOLS THE COMPANY PREV THE TATMON OF PLENTEIT CONSIL HE IA DON OF LIE HE EXEELITI YE PROTOCOL FORWARDS THE SECRE MARY RECORNIN AP NENDATION OF DIRECTOR OF PROJUPUY AS THE RE ADVERTISEMENTS AFTER LETTER THE APPROVES OR DISAPPROVES TO THE PROTOCOL INDIVIDUAL WNUC FAR AS RE PRC WORKING TO BETWEEN NERSHIP MEAT THIS ASCERTAINED OF STATE SCPARATE UNITS GOVERN IS IDVANCETNENT OF RESEARCH THE WISDOM OF MICHIGAU FOR TO TILLIQILE OBVIOUS IS NERSHIP EACH OF BILITIES JTJ THE OF THE RESPONSI THE AGENCIES BE CONCENIED WITH IT MUST OF COT DEPARTMENT RECTIONS MUST BE ENTIRELY RESPONSIBLE FOR THE IM WARDS OF THE STATE AND THE MEDICAL PRISONED SCLCW LIST HE CON LIRI IJOSISI CORCENED VITHL OF MEDICAL RESEARELI AND EDUCATION ASPECTS OF SPERTS XIII JG THE LI TLW HEALTH PIHLI ONE OF THE PROTOCOL REVIEW MEETING FIRST CORN SINCE COMMITTEE AIR HAS IJIET TO REVIEW RESEARCH PROTOCOLS MONTHLY INTERVALS IS IL TN SHE RECOIL NM CVI IA TI MIS CC43 CERN ING CM TO THE OF CORRECTION PROTOCOLS ISAVE DEPARTMENT BEEN SUBMITTED PRIMARILY COMPIMO AND THE BY THE IN OF TWO TILE THE FIVE THE LTCT FINN FIRM IN BEETS PROTOCOLS HAVE TO UP OF THE OF PROTOCOLS III FOR THE SHOULD ALSO BIT CONS THE THE YEAR 1967 STUDIES 18 PHASE PERFORMED AN OF AS THE THE STUDLKS 174 III CLINIC UPJOHN OF THE AN EXAMPLE UPJOHN RESEARCH STUDIES TOTAL PHASE II LOGELDER OF 29751 II HESE MAN HAYS THE HISS PARKE DAVIS HAHI CLINIC SINCE VOLINRITEERS THE UPJOHN SOUTHERN MARCH PSRTICIPARC 1 IN 1961 STUDIES C0 TABLE RESEARCH MICHIGAN ACTIVITIES STATE PRISON NO NO YEAR STUDIES SUBJECTS 1954 1965 1955 1967 1565 41 33 1299 902 1216 27 BE 990 31 OR TO HE STUDY NOTED THAT 174 TNTSLS SESSION SUBTMCITREHL PARKE BY DAVIS SOUTHERN NOT OF OF OTHER TASLE RESEARCH MICHIGAN STATE CO ARE HAS IMIAE OF PP ROVA TUG RHENI IN THE IMPROVE SUBJECTS FROM YIELD WERE IN AT CLINIC 5296 REPRESENTATIVES CORN FLU FREE GESTIONS TAFT IN HERE SUBJECTS PH INVOI CLINIC FROMUI RICE REPRESENTATIVES TIN METRE FOX COMPANY COCTIPALL IE5 ENEQUEN TLY FOR MODIFYING 968 5296 STUDIES OR UPJOHN ISO COTMIC CLOSED PROTOCOLS ONE WITH DISCUSSED COURSE THROTTCTI OLVILI TABLE HISTYIITRI IN PARTICIPATION CLINIC BEEN ITI UNIVERSITY EACH PHARMACEUTICAL GROUP FOR GEN4TRAL DIS COMMITTEE AND THE FOR PARKE DAVIS THE HAVE DRUG STULICW HE REQUIREMENTS PARTICIPANI HE TNEDISAL MEETS ELIGIBLE MEN 18278 1964 AS POSSIBLE OF AS THEN ENRIPAC CONSIDERATION THAT HAS PROCEDURE TEPRESCTULTATIVES MEET TO CMSSZON OF EACH EITHER CONP MAKING SOCIETY INTNATE THEN IS ONE OF GENERAL APRIL SCREENED BASED USUAL ACID TO SINCE IN IS HOSPITAL HAVE PROTTXCLS STRONG LODE TRIBUTION DAVIS 1NST YEAM THE IT PARKE THE CCRN PHARMACEUTICAL COMPANIES MIND RED RID THIRTYEIOH 1381 PROTOCOLS TIC PA CHIT DAVIS CORN PD 71 FROM UPJOHN COMPANY WERE APPROVED IN LHE FIRST FRORMI FOR OF MAJORITY MICHIGAN ON III BY JPJOLITI SCHERER CORPORATION AND THE HENRY FORD MICHIGAN HE AS TI STUDIES AT OWN THEIR LOW JMVEL SO THMT JI CANNOT HE LPDNCETNENF 10 PARTICIPATION AL THOUGLVDYITICULT THE VOLUN LEERS AT EVALUATE CONCERNED THE HEALTH OF DEPARTMENT ONE CONSIDERS IF INITIATE IMIST BY EXCLUSIVELY PAFD5IV FOSPAROK OR TNT HE OHTAINED ARE BY SENDING IN REQUEST AS EXPLAINED IVTRTISETNENF TNMATE PARTICIPATION IN SUCH HAS NO INFLUENCE IN CONSIDERA THE VEWED CAN IEW IN PARTICIPATION PROPOSER DISCUSSION ASKED TO P4TTTICIPATC THE PRISON IS PLACED VOLUNTEERS SET AS INMATE ARE JAPERANJVQ1IINT TIFFS SNENDATIONS BY TARY BRIEF DIZECTOR OF THE DEPARTMENT OF COR REVIEW OF THE COMMITTEES RECOIN THE NO COMMITTEE FOR APPROVAL OR DIS EXPLANATORY NOTE TO THE OF CORRECTIVIS AS DCJX RTTNEIIT THE WITH ACTIVITIES PRISON NO NO STUDIES SUBJECTS 1964 1665 1666 FL 535 1925 FLAT 1967 1668 FL 34 714 1596 138 5841 PIN TOTALS PROTOCOL REVIEW COMMITTEE BY THE MICHIGAN DOES NOR IPSO FACTE ALLOW RESEARCH PROJECT TO BE TOCTYL INITIATED THE LIVEN RECOMMENDATION SUITABILITY TLE INN RID AFTER OF THE DIRECTOR LIII LW FILIAL OF BY THIS CFLRITUIITTEH AND COMMENTS ON SAFETY AND PPMRIVAL PROPOSED DII RESEARCH OF DHUNRIUCNTRIR APPMCWAL IS ARE TIME STUDY IRMITIATETL PARTICIPATION INVESTIGATIORMS WITHIN BY THE LIC PRISON PLISONERS IS ENTIRELY IN CLINICAL SOUTHERN TABLE RSSEAHCH ACTIVITIES MICHIGAN STATE PRISON TO CORRECTIONS BEFIMME REQUIRED GIVEN ALL THESE VOLUN NO NO YEAR SIUDIES SUBJECTS 1S64 1965 1666 73 1937 01 2431 55 1967 47 95 2420 1763 2386 312 10537 ISS TOTALS MICHIGAN MEDICINE OCTOBER 1969 1027 LI PARTICIPATING PROTOCOL RESEARCHCONTINUED TABLE DAVIS THERE 1201 31 FROM TEA HAVE FROM THE COINMITTCE SOME PII ARE THAT SOME TRUUS OF 10937 5IET HON TES TIFIC OF THE FRONI LY IN ING TIME GIVEN ANY PRTI SIIIESSFUL CORISNITLEE RESEARCH VIEW TO ESTABLISHMENT THE COMMITTEE TIRE AT CIT HOWEVER LIISCM THE TEE MAJORITY CEMED WITH PHASE OF FORMATION THE THE PN TESTS WITHOU IT PROBABLY 14AAPMY INROUR TIRE TEST IF TIRE HI FONMI ATTESTED RAN OVER FIVE MCLI TILE LISH TO RET TIGIL AD CTQUA AN THE ITS TE VOLUNTEER LINUHITES NERVE AS PTNOR RESEARCH SAFEGUARDS AGAINST COCMRLOIT CAREFUL IRISIT CRA TIT SIT OF THE OF THE SAFETY ARE PARTICULARLY NECESSARY AS WARDS OF THE WHENEVER STAIR FT NEW ING FIR OCCILITED MA OF WAS YET ESCA MIII PROTERIS THE PERMITS LIE HUMAN CON TINNING NECESSARY ARE PRISRATELS SIDED BY THE OF PRISECI ENTITLED EXISTENCE TIFI SCIER MX OF RA FLY THE PROTECTION TO STATI CUS REVIEWING INDIVIDUALS OF 1968 20 IF NEW YORK S4019A JO II IS LATIOII PIED II TIA RE FE RE TO AMEND LUTMA SEMITE THE AE ASSEMBLY LICAL US PUBLIC FEBRUARY OF MEETING OF THE STATE OF MICHIGURCI 961 ERRONT COMMISSION NEYTNIHER 12 PROTOCOL REVIEW COMMITTEE SI MICHIGAN OFFERED AS AN EXAURPLE SUCH IIIXLY REVICWII AID OPERA LIONS OF SUCH 1HE POLICIES REVIEWING IUCDV SHOTS ID BE ESTABLISHED MID NOMIITNNCI AN IRY GROUP OF REPTESEN GCSVERNMENTAL AND SCIENTIFIC LA ADVISORY UALIFICA CRSX PSACT LEE IN ICES STATE TIRE RE NIL PROTECTS AGAINST SELECTION OF FUSS DEPASTRSREMR OF PSIRTINENT TEA AND LILT CI OF ILTI TIUL CXL CLVISORY TA STATE SCHOOLS YES TIC AT THOSE 1028 MUIR OF TEA INS MINT OF AL ALE EVE EOMR CI TERN RI REID MICHIGAN STI RING TO YE IN RESEARCH CAREFUL MEDICINE MR GES ER CR TS AIMING PUBLIC TO INSURE PRISON EECCS TAN OCTOBER LA III 1969 VOL ITY TEA NICETI REEF III TES IONS ERTIRIG OF MEETITIG HO OF OF THE OF THE OF MICH COR IGASI ST CC 2OR 962 RORIESPTITDEAICE OF THE TINE COR OF MI CI 1963 SRI ASC MEETING OF HE COMMISSION MAY TIITG MICHIGAN 196 12 TITE PER TONSIL OF STATE OF MICLIIGAI AUGTIST CUR 196 STATE CITE MICHIGAN CON 1962 MAY 23 OF CONUN ISSION 67 STALE MAY 23 OF OF STALE TIRE DECEMBER CUSMISISSION MITT UTES OF ATEE REC ERG OMNMISSIDSSL ILOLME MITT TI UNTEEM CUIRRIISSION RECTROUSI MEDICINE TLS RECRSOISS IT IR DC MEETING CONISSSITSION OF COERE XE REJURESER OF REETROIRS USSURES POSSIBLE CCNIET LION TWO OF THE SIRES REVIEWING BJECTS TIRE SIR III OF CONS NISRION TOZIECRNCDL THI AGCTRSCIES TTSILERS TI THE YES OF RITE MICHIGAN II GROUP NSF TIRNLN TI MINUTES OF MEETING ICED RE LAW IN RCRRARRH MIITTRTES TIC THE 10 FAR AS MICHIGAN WHICH AND DRUGS TUIRTE IN SUBJECTS SITAILIES HUNT REIL SEVERAL HAVE MECHANISM ANTI PROPERLY DIRECTED RESEARCH CLINICAL EXPERIENCE RESPONSIBILITIES VOLZRIEERS SUMMARY ART THE SUCCESS IS IGAIR IN IN VOL FOR REACTITUNS ASCERTAINED LIR FIRST MITTS THAT AND IN DII IA TION TITITANS ADVERSE CAU FACT TIJI FREQUENTLY IUICLIES AUTHORITY ALREADY STNRTJRES ICIER LII LEGAL DEVISED IN III BY REVIEW CCXNM RRSEANH IG MOST STATES ACTION LEGISLATIVE EXISTING ADMINISTERED AS STIHJECTS POL ADVISOY ESTABLISH AL LEB IN IS NOTED NA EMMON ADVERSE DII SCI II BE REVIEW UNDER MICHIGAN OF AN SISAL IT AR NIL IHAT FUL SERIOUS FIT TIC UN PILED COST CON THE STATE BY COULD RESCA LICERS SHOULD FT TIN BEEN ENCORURI ICR HAS OF TOCOIS FLIRTHEL STTT4TE RE PROLTRIUL TIRE NEW COIFL POUNDS WAS LADY SOUTHERN MICHIGAN STATE SINCE IN OF EXIST OW PROGRAM PRIOR THE PINTCXXL OF OPERATION IN ESTABLISHED THERE RITE IS IT 1IVS GROUP OF REPRC YEN OF ESTABLISHED STALE AGENCIES AND IRTED CAL ICTILA STIDI SCHOOLS THAT THE MECHANISMS AS SUGGESTS IV NED IN THE NEW YOLK JUT ARE I1JTBZDCJ554 TIES SLI PAT MG CI FOUR TIMES OR DONE SXTORTO BONUS EXPTRICNCECL DERIVING INSTITUTIONS CL 4GCFLLWIT OF NOT THE 01 OF AN KIN DATE THC THE COTJI AND TOES INVCSTIG II III YORK AT CP ESTABLISHMENT THE GROUP NOT FLEW TALL WKJ ARRANGYRRIT FCATURCS IMPORTANT ITS RELEREIJEC HE NEW BY TIT PLIFTETI WH TVLI NILE IF ITS AR AJ IT CII TLETEDION THE AT MM VCA RICO 312 ICI PIOTOCOL REVIEW TED SCREENED THREE ARE PRCVICMNJLCITHWFL ABOUT 200 OH YTL VXCFLI IN LU PIUJXSA IE ENTIRELY DO NOT REQUIRE SCREENING AND USED IN MORE TAR ONE ST TIDY RCPG TB DAYS PATIENT TIONS STU ARE VOLUNTEERS YS 22102 THE YEAR INVOLVING IN KILT SR 1968 S1I1IIES IEERS CIA 1968 ILL RRCCPIIINR VOLTTNTEERS MIIHY TENT PARTICIPA TH NSUGLS VISIULL ORTIE TI RI SUBJECTS TABULATED BY CLINIC CAN BE SEEN IT LABLE STUDIES URIC 1966 IIIJERS STTBJETS STUDIES 31907 IN 1396 OF RCSCARCLI WERE SUBJECTS INVOLVING NUINBCR THE ISIS RC PATKE OF IGA COR 9B8 MICHIGAN COT 1964 SLATE 1718 OF MICHIGAN 1961 COT DUJFLQJ LINT NFL THE OR MANUFCTRES OOM TO AND OR AS 22 SO TO BE IF THE OR ET TO IS OF OF ET TO BETICT FOOD 682 DIS SOCAND ASCER EF CTS MEARU 5O HEALTH TORIES 832 FED RAL ANIMAL SRC AMENDE PR N HJERI DE MED ACT PABLIC 58STAT SEE ANDSTAT AND1031 THE DARCH191 FLRCG SIDE EXP RTS EXPRINCE EFOLVNES AS UME DOSARE SAMEPRE ARED STRUC RE PRO E TI S US4IFLCD T303 DRUGS DRUG ADMINSTROLKA MID OF THE IN AND THE OF ARID THIS IN THE IN BY ENY GT ANY AND TIE BY OF THE IRS AN NOT IS AND TO THE IT OF THE SAWARID IN ANY OF OR MAY USE OF MI IN 1965 20 24 INN OR SORT 302 THE OF USE IN DC PRCSLTONEX 101 1301 PR ON OF OR NEW IS CWO NIORESUBTAC 95 31 USE ICR OF OR AN OR BE IT IN THE DES EARTO SALTS THE THE II AND 551 ITS GRE N PLED SOB SACV 4E ICR ARD BR 10 THE END TO ORO S14O USE 21 HR FOR 41 C2 PSOS LB OF THE OF BY PBARMOCLGTI C O N T R A I D S OR AE REV BUT SO OR TO OF NEUDRGASCTIL SN ROCTION SUE FROM UN NOT HI IN OF 505 TO THE THE OF LAW IS SO RS ET 151 OR TO IN DIERTYJUS1LBAO AND OF ALE OF LAW THE BE OF TO US 21 USE OF OR IRS OR TBLS OR IN 26 ANT JSNE 537 OF 15 3 THE OF N7 NOT 505 AND 832 SDMINLTRA OR OR OF OF THE GLIB CODE IN NEW THE OT OR THE OR 82 7021 515 AS ASS 130 130 1051 PART STAT 353 FART THE EP 613 LOES 152 FR AT TB IS OR EVIDNCE ERDEAN DOCUMSNTA ACT OF OR 129 OR TIOR AL AS RSESI 303 NEW ECNAPDE IN AND NOT AND II EWAND 1312 SN DIN ORE OR IS FOR TO THIS IN NIDRY ALSO SECTION CON FROM OL WNS BE THE LL IF ACT THE OF NEW TO THE BEARS DRUG OF BE DRUGLIMTED AS OR ARE THE NOT FOR ACT PART ACTAND IN TO LAW STAT 52 201942 STA ES OR BY THE AD AND IN IN DAYS 31 OF EXMPTION BRUIT SIGNED TRIPLCATE BELOW THAN REC PT THE AND THE OF TOZ NEW HAS THE MED 21 WHO AN THE OR FOR II THE 321392 DEPARTWELFARE SECRTAY 21 EDUCATION MEANS ACT OF HE OF THE IS CAR FOR NEW SEC 1501 132S SOS FOR ROM NEW 3V2A ETC TO ROR ON AT 301 1305 TAO T507 130 OF 130S 13010 PR RO 12 AND 1301 130 13015 WBLCN SRV EN RIG ONIS OF PRO AL NOT AND EN SHOWN LES THEDATE THE BE AND OR MANUFETSLRCI4O NEW AND FOR PB AND 851 PERSON CORPATINS CONS MDIAM THE AND AND MEANSCOSMETIC USFL MEANS THE ANDWELFARE MEANSDRUGS IRSOLUDES THE FED 1040 ES ANY TO OR AND BE IN OF IRUHEPNASC ANSI AP L THIS IN THE AS SEQIB ET CON OF OF FOOD OF TOY OFL DI OR AR LET THE SECT TERM SAPENFO APLCTONR BESTROT CONSTAU G RSDER OTNERULS NOTES FLRNAE R ROAR126 46 APRO DEFINTOS DRUG SACS AMENDEDEPARTMNHEALTH SECROTASEDUCATION COMWIS NER TERMPARTNEHIPS AR ARTNE TEL 71IUT SP SUTHERWIC CROS SUBPARL 1 30 ASU ED FCFOODL AMENDE FLENTOF HEALTH MIS ONE VIDUALS EJSOCITN OF OS OR OF 37 201 SERUM NERD REI 055 LUG OR OR TO AS 42 OF OF IN ACT OF THE 124 BE IS OF USE OF THE NEW NOT IS ASI ROWOI NOD THE OXLAS SUB THE WE TO SALE TION BY AP LIRA WITHOUT AP ROVE AP ILCA IN FOR SIMLAR JOURNALS PRODUCTS PRODUCED UNDER BEIN EX MPT AS EB NEW ROOD RNVESCGATIO L DRUG ARTICLES EANLT W CHEMICAL INVESTGAO OTHER DRUGRELATED OPINO TRAING SAFETY PRUDENT 130 MAR NIOGIC CNIROL DRUGSHAL SENIOR UNDER JULY USCAVNIRIMUASL 1G13 SEDRUGACORDANCE ESED TOXIN DEMEDFEDRAL JUNE DRUGS HUMAN SHAL METLABEL CAUTIONUNITED USECLPAIEMRRSSGONWITH COMPLETD CLAIMED INFORMATIN FOLWING L I A B T Y L I S T E D L C E R U S E D F E T O OTHER SALTS INCLUDING OTHER 1 2 6 7 MARCH T TLE SERUMSTAT 7290 NEW RICM DRUG D E S I G N A T E D R E S V D L 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PRACTICE ESP ALBERT ELIGMAN ST BQC IFL FL UTTH SVT1 UR ALLAN AR LISSOCK TO 3C14 KEI MA FRANCES AC 30 1972 WHAT PRISONS HAVE DRUG NOMPANY TESTING WE KNOW OR CERTAIN PRISONS THROUGH AZPERIEFLCE THE WE FIND OUT LJ THEY ARE SUBMITTED TTLSTOUQBZNTHO WA TT PROBABLY CONRTDQNTLDLJDL9ITFFI0TLOFL IN THE 11W SUBTUISSIFLN MAKE SUGGEST YOU TO THE GENERAL ILL TAKS TAKE YR OR ‰RONNATTON ACT COULD DO IT DOUBT THERE ARE 20 PRISONS THAT WOULD BE VERY THAT INYOLVED PRISONERS NUMBERS YOU RURNISH TESTING HISTORY OF PHASE DIFFICULT PROBABLY UNAVAILABLE TESTING BEEN PHASE HERE ALWAYS USED SUBJECT AND TYPES FDA REGULS OF 1962 III ARISE OUT DTDNT TERM PHASE II ARE STUDENTS USED MUCH THEN IT UA FORMALIZED TIONS HOW ITS OERWHELMING2 DONE FEW ISOLETED EXAULPIES IN CONTIDOFLTI81 CONFIDENTIAPWHY HAT TSISNT IN PRISOTS ABOUT GUIDELINES ARE NRITING DITRT POSITION WERE IN SEFI ARE 1OT TH0T PURE THINGS INFORMATION XROCOS PTIBLIC INFORMATION ACT INFO UNDER FREEDOM OR ARE PUBLIC FTRM REQU MT CON US HERE YOU GET INFO 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INDUSTRY YOU BRING MONEY INTO WITHOUT DOING BE CONSULTANT CON ON PERSONAL BASIS YOU TO REVIEW BE ASKED FOR MIGHT RESEARCH EXAMPLE YOU ANY COULD BE COULD YEE IT DEPENDS FOR THE FDA BE JUST HOW DO DOCTORS 2000 RISE IN DRUG CO USE OF PRISONERS THERE BEEN THERES BETTER CONTROL GLOW ALWAYS USED PRISONERS WHEN HOST OF NEW DRVGS IN MIDTHIRTIES RUG STUDIES BEGAN THE LAW OF YOU HAD TO PROVE AFETY CAME INTO BEING NOT THE 1962 LAW 1998 APPLIES HAS THEYVE UK IS CONSEQUENCE IN DR HODGES XEHFL SCURVY STUDY CAN HAVE MINERAL SUPPLEMENT OF INADVERTENTLY OMITTING NJN WIN SUPPLEMENT SERIOUS TOXICITY OMITTTNG SUPPLEMENT BY THEY COULD HAVE SEVERE CARDIAC ABNORMALITIES CANS ALL MINERALS AFTER JII DAYS SURE RESULT OR GO INTO SHOCK ON THE DEPENDS PATIENT EPH USE PARTIAL HE THOUGHT DSMO WAS NEVER RELEASED FOR ORRECT NOT FOR GEN USE ONLY URXZFLTAT SAID USE GENNRAL FOR TORN 31 3RFLYE KENSINGTON BEVERL U1Y INTERVTEJ 1972 3O INMATES AT LEAST DSMO STUDY DONE VIA OR TWICE ONCE OF JELLY IN FORM MONTHS OR MORE FOR AN 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WHAT TONE DISCOMFORT BE TOLD POSSIBLY HO QU OK IS INFORMED IN RNANUFAOTURERES CRASH PROGRAM AT VAOAVILE HEN DRUG WAS TAKEN 12 DAYS ABBOTT LABS BOTTLES HIGH LEVEL TOXICITY HOROR 10 DAYS AYMEFLT OFF MARKET OF THE RESEARCH DO 85 EXPCRLMENT THEY CYCLAMATES I4ATBACH THE EXPERTTNEFLT SUPEVVISO INVESTIGATORS MAIBSOW TWO DAYS AT LEAST IN COMES EPSTEIN THE INMATE TO CONTROL IEEK EXPERIMENTERS GIVE UP DAY TAKES BLOOD ANALYSES RCSEARDHER WHO HANDS OUT MEDICATION IN CHARGE INVESTIGATORS BLOOD GIVES RESULT TO PHYSICI5FL TOXIC STATE THEY BELTEVA ARE IN SEE PATIENTS RESIDENT PHYSICIAN THE IS QWHAT IF SUBJECT GETS EXPERIMENTERS THE NOUF HELL TTHINK DIANGOSES AN TLUGSS WORE THAN CAUSED BY RESE CH LOT OF ILLNESS HIDE SYMPTOMS TO IVE SEEN LOTS GET ILL LOOK IS NECESSARY REVIEN THE TEST EXPERIMENTERS RROTOCOLS STAY ON PROGRAM TESTED BRING NEW STUFF TO BE FOR TOXIC LEVELS TES5 TO BE DONE ANT OF PAY ARE GENERAL NAME OT DRUG VAGUE MEDICAL JARGON MEAN NOONE REALLY KNOWS WHET PROTOCOLS OHOW DO CHIEF IL FU‰ INTERYTEW WITH DR GI CGASHFRWYETH COMPANY MU 14400 215 FLN MAIN POPULATIONS PHASE TESTING AT PRIS0NS FOR TELL ME THO REASON YOUR QUESTION IN WBJNB WHAT EXTENT DO YOU USE PRISONERS INVOLVED JUTSFUNDAMENTALLY NUMBERS OF VOLUNTEERS WHERE WE GEFITIIFLTHTINIOAL REASVN IS NRORNWTTON 00 UFIDENTIAL THERE TRADE SECRET AS WHAT WE RE 46 AS MUCH HAVE PIPELINE THRE MOU OOETTTORS ARE LNDUSTRTA JU9T THE NAME OR THE PRISONS WHAT WE ARE DEING VOLUNTEERS IF OF WE HAVE NUMBERS THE SECRET WNULD BE OUT AS MORE HAVE IT ITS 0TILL SECRET SECRET TWO NEOPLE HAVE WHERE …CLUNTEERS MIGHT SPILL BEANS ASSUME YOU ARE NOT GOING TO QUOTE ANY BDY TESTING DONE IN PHASE TIUUUZMM REASSURING HMMNIM IN THE ARTICLE OTHER TKXXUNFL IN THE US ITS UTLY MOSTI FLRJAQD DO BETTER COUNTRIES USE COUNTRIES THEY PHASE MEANS NORMAL HEALTHY VOLUNTEERS WITH PATIENTS THATS TRUE IN THE ITS ONLY DEFINITION EXCLUDES PATIENTS BY FOR EXAMPLE THAN PRISONERS STTUATION WE USE OTHER IN SPECIAL OTHER LARGESCALE POPULATIONS FLO USE YOU CANCER PATIENTS FOR PHASE OFFHAND ID SAY NO STUDENTS FOR INSTANCE EXPERIMENTS CUTENTLY BEING CONDUCTED COULD YOU TELL ME ABOUT OONF IDINT TAT AND WY 217213 NY 868 AT TAOALITTE PRISONT NA DRUGXIIL HID MEANS INVCSTIGATIOT1 TN THE INFORWATIOFL ITT FILED WITH FDA 1WOULDNT TELL MY OTT OTHER ABOUT IT THA YOLUNTEERS BIND OF CONFIDENTIALITY WHICH IS TN THE SANG MONTH COMPARED USUFLSRMSFLRFTDXXTTBFLFL UT GET FOR 217213 HE SAID BECAUSE ACCORDING TO MR IJRBINO WITH AV OF THE ABOUT DONT KNOW ANYTHING RISKER AND THE PRISONFLTX BETWEEN THE THATS PRISONER COMPENSATION YOURE ASKING ESSENTIALLY AGAINST WYETH ANY DOES ASSUME ANY RESPONSIBILITY WYETH INFORNATION CONFIDENTIAL ALL OUR PROTOCOLS ARE TO GUIDELINES FOR AHERING WE WORK HARD AT THIS KIND OF THING REVIEWED WITH THIS IN MIND THE MEDICAL MONITOR IN WYETH DOES WHO DOES IN WAIVER FROM AWARE THAT VAOAVTLLE EXACTS WOULD NEVER THE OF FFLA R16I WHAT IS THE NAME OF THE MEDICAL MONITOR PERMIT THAT WHERE AO YOU ITS T6 PATI SIDE LAV FDAT VIOL MEDA VOLUNT AR ON PROBLEM OR PRISONOR C4 NOT REPORTINR SIAE EFFECTS IS THAT THE THE BASIC PROBLEM HERE MR CHAIRMAN THIS MEANT THAT MUCH TO THE WAS TOO REMUNERATION PTISONER THE NOT TO REPORT AND NOT TO THE PRISONER HA VERY STRONG FROM THE STUDY THERERORE HE WOULD DECLINE TO SAY THAT ITIRAV BA FOR THE PRTEONER IN THIS IS HE FELT ANY SVERSE REACTIONS RISK IT IS BAD FOR OUR HIM TO UNNECESSARY THAT IT EXPOSES INFORMATION US FULL IT DOES NOT TIV3T PROVIDE RECORDS IN DR LEY PRE PRISON AFFORDS PROGRAMS IN CHANNEL ON OF BY PREY HUMANE AND FINANCIAL ORENORT THE PRESENCE OF DRUG TESTING ANOTHER MEANS OF REHAB WHICH THE PRISONERS CAN TO SOCIETY CONTRIBUTION SEN DOLE PRICE IN IN TESTING RATE WAS IN THROUGH THE NUACE SN BOTH THEIR FAMILIES CERTAIN ALSO UNDERSTAND THAT HE MADE REF TO MUCH FOR PARTICIPATION WHO PERHAPS WAS PD TOO WHAT THE GOING AM WONDERWITH WHAT HE WAS PAID AM ALA EN DAY THE TELLS ME THAT THE FEE VARIES DEPENDING ON OF NUMBER THE ON THE IS EASE SUSPECT AS USUALLY TEST AND ACROSS THE BUT EFL AV HAS TO BE BLED TIMES THE PRIS ABOVE DRUG HEARINGS DAY BOARD WOULD BE SORNWBERE THOUT DR LEY IT LISSOK HOW MUCH DID SCURVY TEST SUBJECTS NODGES THE PAY INCREASED AS THE COST OR DAY TO NKAXKFL PAY AN AMOUNT ITS UNETIIOAL CIGARETTES WENT UP OH WE HAD THE MONEY XEOOUTHD OF MBNEY THAT IS TOO ATTRACTIVE BEIFLA CHEAP BUT WE OF COURSE MUCH MORE HAVE PAID THE SITUATION OF THE ETHICS WE WERE CONDIDERING ON STUDENTS EZPERIMENTS BAVE YOU DONE SIMILAR TEST USED STUDENTSTO WEVE THE SAME ONE NOT THEIR MEALS THEY GET HOW COMPENSATED ARE THEY DIETS NEEDLE EACH TIME WE STICK EM WITH FREE AND IF THINGS UNPLEASANT FOR REALLY THE PRISONERS GOT HOURS WED FOR SEVERAL THEIR THROATS TUBE DOWN WE HAD TO PUT FOR BIOPSY OF THE SKIN THE FEW DOLLARS MORE RIVE THEN SIZE OF PENCIL ERASER NTERVIE GET PAID WITH DR OR NEW LABORATORIES TI LIII UPJOHN AND PARKEDAVIS STWID LCTWSEI PRZSN HCSPITAL OF SOUTHERN MIT GUT IN NI ICII AEKSOII OF AND TARE FILSOZI AT RESEARCH DRUG TESTS BEHIND UPJOHN AND PARKE DAVIS HAVE BROKEN PRECEDENT OWNLABS THEIR HUGE JACKSON IN RUN BETTER CLINICAL TESTS MICH BARS II BUILDING PRISON WHERE THEY CAN THAN EVER BEFORE ON NEW DRUGS PRISONERS YOU WANTED TO TEST IF OF HTI IS HAVE MUCH TLC SORT OF LIFT JRUL VITO FAN BE CONIIIIMMTMMMSLY SUPERVISED FOR MUON UT YEARS WHAT BETHR HA 11 CC TO 10K II PRISON FOR II ANY YEARS DO IG UNPAN IM ANTI THE NATO INSTITUTES OF IH ALUM HUT YE AD COOPT AT IVT AGREENLEN IS WITH PTRIPJ INSTITUTIONS ALL HE COTINTRY TC IVAL GENERALLY BRIG LABS MOUTH IS CHECLED TO HA SURE HE NEW DRUG OR II TRITEERS WHO IL RIG THEM TO RUN INMATES BUT THEY HA LT CLI BARRED FROM IN STAL PERT II ON AT THE LSTIIUITITN5 NOW UPJOHN 2O AND PARKE LA HAVE BROKEN IN IC PRISON IN MLII BIG WAY WITH HALF ON DOLLARS WORTH LAB FACILITICS PICTURES AT THE STALE PRISON OF SOLLRRN MICH THIS PI ISN AT JACKSON IS RAH AS II IC VORLDS LARGEST WALLED PCI 57 ACRES AN TENTIAUV TLICLCSING 41 IGARM PRISOUIIJS THE TIJUCENT TWO IULIPAFLITS TO PM PRISM SAUL II EVER LIHILT THE IN ITT SJ LRIILG TPPD INS IITSIDE COLUPALTITS WALLS PRISON OIWI FIRST LIMING LALLRATIRIT ARE HOSPITAL SUCH FACILITIES LUCY AT LABOR MD WERE EOII COST AND 266 226000 OF HR PA RLYJJAVIS TITLE VAS THEN ITRILL OVER TO THE STAT RESEARCH DREAM FROM HE OUTSIDE THE TWO LIIILDIFLGS CONNECTED BY COVERED WALK ARENT TOO IMPRESSIVE YET RESEARCH PEOPLE IN BUTT CORN 51 PTS1ARCH ONE INMITE TECHNICIAN TNHNTQUEA THUS GIVES WATDES ANOTHER COUNTING SKILL THEM CHANTS TO GIRN BLOOD MIACFNL CELK TNMATES LENIN WORLD LAB IN OUTSIDE BUSINESS WERK JUT 21 1944 LII SWALLOWED PU TRANQUILIZER FOR EXAMPLE CAN FETCH TWO PACKS OF CIGARETTES IF IT CAN BE SMUGGLED OUT TC THE YARD PP INMATE TECHNICIANS VOLUNTEERS IN DNIG TAKE TESIS HUSINOS WETK MINT 27 FLOOD SAMPLES FROM PRISONER GUARD CHECKS VOLVETEERS JOG INMATCS ROOMSEAT INTO THE WAITING IS MADE TO ROOM OF UMOHN LOOK PROLESSIONAL LAB THEERFUL FTESTARCH 59 TIIIGISI GUS HARRISON MICHIGANS DIRECTOR OF CORRECTIONS DREAM CONIC PAFLIS SAY THE SETUP IS TRUE IT WILL PERMIT FOR THE FIRST TINE WHAT THEY CALL UPTIMUM CONTROL TTSL ING OF NEW DRUGS THE COMPAR EXPECT TESTING AT NOT JUST THE ODD HOT EVERY PRECISIONMADE HAS ALL THE POTENTIAL ACKSRR TO PERMIT II USUIT BE DETUCTVD AFIFF DISCARDED ONE STAN ONE TO MONTHCOMN IRGIBAY TITLEI5T VCJITIQIWLZLIJ THE HOW INIGS COIN AFFECT THE GROUNDWORK THIS MAIN CONSISTENCY THE IS AMATEURS AND TOP TITLEIST MAJOR COMPETITION OTHER BALL NO ONE TO PLAY RERIJAULCABLE ZIG AND IS IN THAN ANY REMEMBER FOR RESULTS PARTLY DIFFICULT CREASINGLY VOLU RI TO IS ALSO IN FIND ENOUGH CI IN CAL THE FLOW DRUGS TCCRSNR EVEN ENOUGH TO INVESTIGATORS COMING OUT WITH THE TEST THE LABORATORY IN SPREAD OF MEDICAL VARDS IN HOSPITALS SURANCE CHARITY THESE WERE TRADI ARC DISAPPEARING FOR STU DIES AT AN OF NEW TIONALLY DRUGS AS WELL CUEDIEIL OF STILL FOR RISK TL TEACHING DENTS DRUG TESTS CAN MUCH RCORC CHEAPLY IN OF CORNPACII4 AD INAHJG OF THROI LENT AS BE RUN COON DES ROIL AND OF ROI2THIT ARE COMPE INVESTIGATORS TESTS CAN ALSO LIE RUN ON PATIENTS ALL DIVER THE SIOWER PROC COUNTRY THOUGH ITS ESS THAN WITH MASS VOLUNTEERS AND CUSHNET GOLF BALLS SOLD THHU GOLF COURSE PRO SHOPS ONLY MORE CONTACT WORK THERE SEVERE SHORTAGE TO RESEARCH ENS FOR ROUTINE TESTING JOBS THERE ARE LOT OF DOCTORS WHO IS ARE 60 REUARCI FULLCR SUPERB DOCTORS SAYS DR HAT STRICT AMEND COI 1963 TOCD DRUG ON ACCOUNTING FINDING CAL TEST DRUG TEST ALL AN ANSWER MANY CLINI NEW DRUG TURNS UP AN OF ABERRANT FINDING THAT LEAVES RCSCAZCHCRS EVER UNEASY DNZG HAS BEEN LICENSED IT FREAKISH GENUINE TECHNICIAN CARL REACTION EFFECT TO OF THE DRUG THE MIGHT BE AFTER CONIPOTIND THE DRUG SLOPPINESS NEVER ERASE DOUBT MINDS ITI OR OUR THE TERHRIIRIARC PRISMI IILR AREA STEP TOWARD CLII CCI NATING SUCH DOCHTS AT JAEKSON WITH LABORATORY FA CILITIES NOW AVAILS BLE FOR SUBSTANTIAL OF THE EXPANSION TESTING AND UPJOHN THIRLCEFLAVIS ROUID RIG NC UF LIT PROGRAM ARC TAP YE FOR ROUNDTHECOELC SUPERVISION ARE VOLIIN TEERIRI BY HUNDREDS FOR TISTING PURPOSES MANY WANT WILLING HELP MONEY XVH ICIC RANGES FION UNDER PRI9 OMIERS RRY TRT TUL ARC CLINICAL THE THE MG OWN MORE VITA TO ACT THAT EMPOWTR THE FOOD TO RCQUIRV DRUG AR1RIFINIT 5C MERSONNRV1NNMLIITR DRUGS ADEQUATELY MIST DRUG COMPANIES IRICTICS THE BE TEST TO SPOND MENTS ON INTYRNES CTIRE KNO TO PATIENTS WTIZJNN PAID TITLEIST FOR ON COUCH MORE POWER ACUL SO SPECIFICALLY FORMULATED FOR THEIR ASICK BUT THEIR OTENE IN CRIWEW SO DOES RISK CAUSE THEY ARC PLAY AND UPJOLUI UPJOHNS DIRECTOR OF RESEARVH BUT THEY DO NOT HAVE THE TIME 114 KRTVWLCDGC GIL THOUGH THEY DO NUT IT OR THE CLINICAL ALSO CORNZNON COLD OR FOR CANCER NIGHT WELL 10 LAID AT JACKSON IRUGS THESE DAYS ARE ACCOMPLISH REASON WHY MORE PROFESSIONALS IHEY MORE ACCURATE UNUINGS JAR RULES ALLOW AS LAB IDEA OLD YET THE II THE PRESSED TO AS SAVING WHEN MUCH TIP SDFLQLL DIFFERENCE AS 15 AS FOR THEIR BANKROLL IT DID THE THE EW DAX ON SOME PRICD CAN MEAN THE FOR PAROLE OE OR BE JOB PRISON FOTK47F OR FRIEND6ITSLJE SOME SEND MONEY TO THEIR FAMILIES TOO ING KWT JN PRISONERS ALSO GET VALUABLE FEEL ING OF SELTRESPCCT FOR SOME IT IS THE FIRST TIME THEY HAVE EVER DONE ANY THING TO BERNFIT SOCIETY 50110 EVEN BUSINESS WTTA JUNE 27 1984 CLEAR LEARN THE TRADE OF LAB TECHNICIAN WITH AIIYI IN WIN HELPING OTHER PEOPLE SAYS AND IVE ONE INMATE TECHNICIAN NEVER FELT JIKC THIS IN MY LIFE THE IDEAICSIING IF SELLING DRUGS CA 14 ILVODORE ROOSEVELT FOR THE FIRST F4OD 4711 IRN WY IOY XPEJLLELCC 1906 PRISONS WHEN PNS WAL CONTROLS WAR TI API4VTQ FLT JACKSON AGO DI YES THE LB RJSON OF COMPANY PRISON TO GUS THE DIRECTOR UP HAROLD IDEA OF THE HE CORRECTIONS IDEA MHTHIGI AND THE TO HAT EACH VOLUNTEER ABOUT HAIL GETS AJ CLIRNINAT VITH THE ARGWNENT THAT COULD BE CONSIDERED NEW IA IG MOUND THE DRI RUNNING LUG ILILLEAL 7TWFLEJT IN PRISON INVEST REBABILIRA RE ISSUOD RATE MICHIGAN INVITATIONS DRUG IN TICIPATE THE CNLIPAZJLCS 1I WORKS WTH IIICIIT LJRIDVR THE PANICSAXE ARVLN GENUINE RADIO WOOD CABINET WALNUT STEREO EXCELLENCE THE UITIRRAT LTIC ITRNJN ERIOY DIODES OIUI DESIQ DELI TO HR JVINR GOUND 15 TUBES SOLID TTTTC NLIRON REIIER GIVE ROVER TO STARE FUSIPUFL OUTPUT WITH TOODHOOK CURCULT BERGS TOO SEW CRYSTAL SOLULL TWO MGTLHINO WIVEL VOICE STEREO SPEALERC LIE ICI TICY LIP TO FWRII TORN IS STEREO EXCELLENCL TIST COULD LOLL TRON ARVIN ARVIN PRECISION TUNE IN YOJR AM BROODCOSTS TOO1110 MIS FAVORITE WITH CONTROL FM STORED VE FM OR SEPARATE PRECI STEREO BALANCE INCLIEDINO PLUS LASS SLID IRTI LORL IROIS RVIN VISA TUNE ION IEP LWI LIPS OLJ BOON IN RERFECT ORLSLGRAL LEOCYTIOLI AOTDM7TIC HOCKS HO FNI LKLGFLCY CONTROL FR IS R4LOD ITTICILT LEA CABINET HARDSOLRLEIV COIIRUITTEE SLIDE RULE DIAL TFE HALURSL RAD FLOOR OF SOLID WOCD CABINETRV ENHANCES TILE IILPTF NND DIMENSION SOUND TOR OCW ILR7O IN LJSLERLIN LIGHTED E5 RILILIL TESTS ARE THAT AIM 095 INCLUDES THE STATES INTD CAL SC LOUIS TWO CORNNAMES ARE IROAD RANGE ORD RUGS AT DEANS FLIGHT TES TI1L WITH THEIR NEW ABILI LY TO KCCP OIL TESTS LABORATORY CONTROLS WITH PRISONERS PIR DAVIS AND JOHN EXPECT SOON TO START TEST IRIG DRUGS TILAT HAVE NEVER BEEN TRIED ON CLOSE UP MALL SUBJECTS TEST IT LFLIG RATHER THAN ITS ICAC DOSES THEREAT 11000TH 50 MALTS THEY OF OUT ADJ ARE IS LI OF LTD THEN ARE AS LOW AS 5I THE LETHAL DOSE 100 LABORATORY ANT LIAN III HI NIT TEP WEIGHT GRADUALLY IN AID FASTER NUMBER AT JACKSON LARGE OF SART LC NINA PERSONS THROUGH THE EARLY STAGES OF TOXIS FLY TESTING REVEALING THE SPECIFIC REACTIONS THAT MUST BE NPLORED HI QUICKLY LARLY INTERESTED DRUGS XPITCL THE OF DEPTH STUDIES PRISONER ITGIVII IN REACTION OI7 REVEALING BASIC GUNCRULLY TIJIJOLIR 10BED MNETAHOL NEARABSOLUTE IT TITTER ULOUTHS AT ITS GS TWO STRESSING WARDS AT CONTROL LAST IN IS LAB FOR IN DRUG STUDIES OR FO IR DAYS OR TIME SLISM VIII THESE LII ALT ERRIJAT TO CHART BLOOD LEVEL ABSORPTION AND EXCRETION DRUGS OF LECTED ILL INIERIT TESTS AS WELL AT AS MEN HEALTHY IS IN TOXICITY THIS III ILISSINIG IS II THE SE DC ANY DRUG ELSEWHERE HOW CARE YOU TCLL WHEN YOU TEST WHOLE WARDS OF LIT TIE 011 LADIES WITH BROKEN HI LS IF THEIR REACTION TO TE TI EN 5FL1 IIE AS THAT 17YEAROLD GIRL ASKS FIR ALAN RESEARCH ICY MANAGER OF CLINICAL UPJOHN WITIL PRISONERS SET PRECISELY YOU THAI TILE OF AR FOR RESEARCHERS CAN IN IRU TESTS DCL DEVOTE YOUR ENTIRE ALTERS ALIFT SAYS VARLEY INFERS ABORT CONSIDERABLY CAN TO KARN SAFETY IN THE OUTS IDE WORLD LEST SR ILSJCET BALK DRUG RESEARCLERS AT EVER TURN ALBEIT UTE IRTTERETIRITIALLY PEOPLE ARE WHEN THEY ARE 451L TEE NOT RELIABLE TAKE MEDICINE DR UPJOHN SAYS ILL PRISON SETU THEY CAN BE CHECKED IN THZG PEOEAC14 TO DOWN PINNING STUDY DRUG THE MUCB OF GREAT BLOO DRUG VILI TINE LED DESI DIRECTOR ARCAS FOR FURDIER SINCE THE LAB OPENED PARKEDAVIS HAS ALNACLY ELI TIIISL ETI TWO RIE CHEMICALS DESIGNED TO REDUCE CHOLESH INI LEVEL DEEPER TOO DR UPJOHN IS PARLICTI SEVERAL ANTICOAGULANTS ANESTHETICS STEROIDS AND DE6DORANTI CAIRS CLINICAL IN NE AS AND ACCURACY THAT ANALGESICS TRAR IIIL IS FOR BY KARKEJAVIS YES IGAL ION IS FIN IJED DR HAILED NOW THE JACKSON INCLUDING RE JACKSRUI OF THE ACCERITEDBY TI ARVIN MODEL 32R98 WILRUT WISED LUUO BORI II ARVN BEAUTY FINEFURNITURE JD1RG WHICH DRUGS MAY HE TESTED AT LIW EACH CASE IS REVIEWED BY 111500 HOARD OF LIVE DOCTORS ART BLTWRIB ARVIN ARVIN FM STEREO TOLL SPCRIRUM OF RER RCSPCCTIVE HEADQUAR TERS FACILITIE5 PARKEI AVIS IN ANN ARBOR AND UPIOHN AT KALAMAZOO IHE BOARD OF CORRUCTIONS DECIDES TUBE IS JIAR THEIR IN FMAMFM ST TIMIR RAINING UT1ICR PFL TO OTHER PARKEDAVIS PROJECT ACCEPTUD HOW IT TO USINEFL WEEK 1964 RI IRI VK UCN 39 T9R CI 411 C7 66 CO DISCUSSION EDWARD DISCUSSION 1V1 ON WHICH MICHIGAN IHE HE OF IO FEW WITH TOIIIMITTEE CERTAIUI KEEP NBC TINGS IS HERE BY OMITTING INDIVIDUALS AND INVES TIAATORS NA RQS ALSO ILL CONFINE MYSELF TO CLASSES STUDENTS IN ALL OF COMPOUND RA CL CR TITAN GROUP DO NOT AS THESE INFRODACCS COMMITTEE CERTAIN AND ACTIONS THIS THESE DIFFICULTIES STU DENTS WHOM WE ARE EXPECTED TO TEACH HAVE STRONG DIVERSE OPINIONS IF WE GET ONE SPNDENT ON COMMITTCE IT TNAY BE GOOD FOR HIS BUT IT PNHFAL DOESNT STANDING WITH HIS FELLOWS TEACH THE VIOLE CLASS WISH THE WHOLE CLASS WERE INVOLVED DISCUSSIONS II US REGARDING WHICH WE WOULD DESTROY SO MUCH OF SITE TEACH IN NOT AVAILABLE DUO FIRST THESE CVIORNITTEE TO DIE CCII II HAVE WORKED THE COMMITTEE PRIRNIAN OF PHARMACOLOGY DEAL TO DO WITH CONHNITITTCE EN THE CONFIDENTIALITY TRIG ASPECT SO IMPORTANT DISCUSSIONS IN THAT IS COMPOUND HAS DECISINTIS AS TO DIN GREAT VHAT IS IN III PERMISSIBLE INVESTIGATIONS 047 THIS TYPE OF COMMITTEE BE CONSIDERED MIGHT THE GRANDFATHER OF THE PEER REVIEW MITTOES FLY 1952 TIRE ATOMIC ENERGY MISSION HAD FONNAL FOR ARRANGERLCTUTS JATIUG BEINGS THE ARID USC OF APES RADIATION POLICY IN CORN CON RCGRR HON LINT COTNIUITTEES 790 VT 77 RIVN STATES WITH OUR USE SUB CORLLMITTEC 952 PROBLEM MOST III THE OF PBITS IN ISNT GVNERAL IT VET HIGH DOW ON THE OTHER HAND ALONG CAME SU USE CONIGENER OF CY TARABINE BECAUSE STUDIES IN ANIMALS DIDNT APPLIE HOW THIS INVESTIGATE MICROCURIES XVHIDN 510115 20 DRUG LIBXV ESTIMATES INCREASED STANCE TRITIATED 3TI NOT IS IT IT LIP NITICH JIATTERIAL DIFFICULT TO EFFECTIVENESS DECIDED IT TO USE WOULD INCREASE FROM 15 BIOLOGIC WE VEX DOSE TO THE GENETIC RANGED PM PROB OTHER TRITIATED GENETIC IS THIS POSED LIKE THE FOR COUL CYTARABINE USED IN THE WAS NOT PROTOCOLS ILTE ESTINAE IN OF GENER THU OF IT DISPOSE HENS HUMAN THCING COMPANY VAI TUD TO HUMAN BEINGS USING 100 IIDICAT CLEARLY THE RADIATION THIDIOISOTOPE PIINCIPLE MONTH ONE WOULD TAKE WITH TTEE UNIVERDTICS HUMAN ON COMPOUNDS STUDENTS THE IN UP WITH AN ILK IF 100 DRUG USING TRI TIU NJ IUICRQC1JR OF HITIUA IS IN THE FORM GIVEN OF VAICR THE WHOLE BODY DOSES IS ONLY ABOI IT WHICH IS ABOUT THE CBS MILLJIADS FROM COSMIC AGE ONE GELS RNLIATIO IN UNITED PARTICIPATE KHIGAN IIG ABOUT OIICS SPECIFIC SET OF STARTED VHIGAN TABLE SHOWS YES INTIST WHICH CONFIDENTIALITY UNTHERSIEY CONRRIITTEES IN SPECIFLC SOLVED EASILY AFCDRCIC WERC UNIVERSITY THIS PRINCIPLES EXANLPLETS ANN ARBOR MICH THREE CQMIIIIITE THE AT PERHAPS SDMC LISLI ALCUT IS SERVE MD JR CARR TJLARNH7OK MID ITCNOL CF LUST MATERIAL 1000FOLD HIS IN COULD NOT IN BE DONE EXCEPT IN PEOPLE WHO COULD FOR SOME REASON EVENTUALLY BENEFIT BY IT THIS WAS AN ANTIVIRAL COMPOUND AND CERTAIN PEOPLE WITH MALIGNANT DISEASES WOULD IE IN SERIOUS TROUBLE IF THEY COTITRACTED VIRAL DISEASE THIS BE PASTICULAR VEIY HELPFUL COMPOUND TO MNIIGHT THEM PROVE THEREFORE TO IT 791 DISCTTSSION IA THOSE INSTANCUS IN JUSTIFLABIC TO III THIS FACT IN NOT MI STUDY HE DISCUSS JOITS AFTER ICTIGAN ALL TO SUB RESEARCH AS TIN THE CASE TABLE RED WORE PRINT OF AMDY ILUSI THAT WITH PROCEED ON THE BASIS BUT IN FROM THE HAS SITL4EET TO USE OF LOSE 100 LIE OF THIS OF COIN THE WHOLE BODY POUND 1FODOALBUSNIN DOSE WOULD BE ITT THE RANGE OF 30 TO 150 MUCH HIGHER WITH MILIFIADS ONE WANTED IF TO AN BODY DOSE WOULD BE HIGHESTA BIG WHOLI THIS WHY BODY DOSE IRTVR THE WISHED VAS AN ATTEMPT TO ORDS IT WAS INTENDED THIS IT ALL THEM CELLS THE ARC REAL ELANCUIA OTHER CURE REFUSE THEM THIS AND WATCH THEM LIE DO THESE FROM TREMENDOUS GET HAND IT WAS TO THEREFORE WHETHER SIT TRY MELANOMA FOR SUELARIOTIC GET OR TOWLTETHCR AS IS ALIT RELATIVELY USUAL BLACK MELANOMA TO TOR TABLE II TELL SON CSF IRIVESTIGA THORN TO THE TO SVLAT THUS THAT ARC OF HAVE TO OR EITHER VE CART ALT LOXY RISK THU 1K INVESTIGATION WE FIND HAS SO WE THE PHARMACOLOGY THE MD USE CLI NITAL 001ST NON SENSE CAN HE ALLOWED III LINT CAN RIOT THE LOOK AT THIS CONSIDER COTFLPOTLTLD AS TO LITTLE SITUATIONS TO LOSE WE DEAL ABOUT GIPAT IS NLEASU RES THAT TO LIKELY III THIN WIT IT ITLI HELP THE UTNAT II 100 PE CONGENER HADIOKN LJNC IN DIAGUESUE SPECIAL IETTFS YET EVEN ESTABLISHED TITE THOUGH EG PROBLERIN IOE 1SOJE 30 TO LOCAL TECRITE SUBCOMMITTEE TTPPROVCD ADRSIRISTRELION THIS 90 OF ALOGUE CXPERIN AN TO SYSTROTICTILLY WHOLE BODY DATA DENY HIM TO OF 70 IS CLONT WHETHER TH CERTAIN TO THEIR PATISATS 95 NTDS THAT DTTCTITIIIS WE COME NOW TO THIRD IRS SITUATIONS PRINCIPLE SECOND REVIEV CDMRNITTEE THE THE INVOLVING THE SURGEON GEN YOU ARC ALL FAMILIAR AND BY THE END OF 1RARCH BY FEBRUATY 1966 CRAPS EDICT WITH VHIEH HAD BEEN ISSUED WE 19664 LINT FORTNS JO CORUT ITITTEE TABLE THAT IN TIAC III IHA THIS IN SUL4ETT VAS RADIOISOTOPE OF CASES CON IFE INVESTI US IGI III IT TEE FRIGI DCII WERE INTERT OF OHTIGISIS AUDIOGRAMS TO TEST THE BEARING IN PEOPLE WHO HAD TERMINAL ILLNESSES EVENT THAT SOME OF TL TO VOLIL COME OBTAINING TO IN ATOPSY THE FUJI COMPARE THE AND LOGRATUS TERMINAL ILLNESS PATIENT CAREFUL TO STAY PA TIME ITT OT IS THE THAT IN THE REVIEW ITSELF ILA HUMAN OF SOME EXAMPLES LISTS PLAGUTD STUDY OF APART FROM ITO THAT COTMITTEE STLUTDIIAG DEALT WITH OR NOT WOULD BE WRONG THOUSAND LOWEVER MOST OF THE AND ONE HAS TO SIMPLE ISNT IT ONE CHANCE IN IS HELPED BEING TO THERE ARE TWO WAYS ON BODY DOSE FRONT TI IT ADMINISTERED 50 RIRADS THE SPINAL ENID MIGHT DATA AS HIGH AS 40 TO 60 RAD CHOICE WAS OBVIOUS HAVE TO TRATHECAL OTTO COULD TITIS OF OF GTE USE OF RETIRICTED TOPES GATIATS ETHICAL FOR IG PEOPLE BCSICFIT POSSILSILITY OR JET IT MALIGNANT CONSLTLR 2RE SITE THE HOPELESR CASE II SIIBEOMTNITT TI TIME ILISTLOR IN QUT IVOOLD TILE OW III THEIR WEFE 4UESTIONS RADIOSENSITIVE SECOND EVEN WAS FOR AND OTHER III TO 21 RTANTINC MAKE OTHER HELP NOT THENI SITE REQUESTED THE METABOLIC DISPOSITION THE USE USING FRCI TATIGITIG NO HUMAN OIL MET GOOD NOW THERE NOT TREAT VSS IN PEOPLE TO USE THIS ANALOGNO HAD DISSEMINATED MALIGNANT ARSORTUS NO OTHER THERAPY WAS AVAILABLE MEDIATE OF MILLFEURIES WHOLE ATLALOGUE THE ALMOST 100 CADS AT THE BECAUSE PERMITTED WHOMTHE 50 GIVE DOSE LOEAL DOSES CC STTSTI APPROVED TO ITLTLFLTHCLAILY JTCI JTSUL OR STUDS TO SULTO THE FIRST TOM THE IN SUGGESTED LII CONSIDER SERUM ALBUMIN APPICTT TOOL INVESTIGATIONAL TIM NOTHING OBJOCTIOUS TO RADIOJODINATED PRINCIPLE CIRCUMSTANCES YOU AN THAT TOTHER IT CERTAIN ITT CAN GAIN INTES 1970 TO ILACLIOJOSCO TRITIUTIT IT FF13145 THE DANGEROUS OF RADIOISOTOPE IGHT TGS HI II BE THE INNER ALT NOT EVERYONE WITH MISERABLE AND IN PAIN INVESTIGATORS AWAY EMIT III ALLY AT WERE QUITE AMATE WAY TO CAR WITH WILT AS BE HARASSED RNIAHT 792 CARR PHNNA CTIICAL AND TABLE CA LIT FLW PLAGUE REVIEW IT IJ BE MINOR AFTER THE TV NND COFLUFLITTEE CUES ST ABLE THCMU4 LIRE BUT BE AT TONY THE TO FRIGHRRRIIRIG STUDIES ABLE THAT ARE THEMSELVES BUT MAY BE STILL SAFR ID EN BARRASSING ITR IN JNYE CHARY SUPPOSE AL THE TO SUBJECT DURING AND PREGNANCY RECIPIEL DELIVERY DIDNT CAUSE OF PROCEDURE THE PATIENT XIL5 TOLD JE WAS BEING STUDIED HIS CONDITION WHILE THE BAR NO BENEFIT LAY THE VERO VERY THE THE SI NUMBER THREE SNAKE SIRE TO WOULD IT TE AND IRCATSNEMIT PATIENTS FORC INVESTIGATORS THE IS RID OF RATHER CAS GRAPEVIR IN KNOWN USED IS PA FRIES PROCED LIC THING TICUT CODS HI ILOWAI NY LLOWECR BY THE IT WE EVENTUALLY THE THAT LIOSPI WITH TAL SINCE BEING THE TERMINALLY WAS VETY PAINLESS AND SINCE THE INVESTIGATORS WERE NOT DOING FOR ANYTHING EXCEPT HEARING RESEARCH ALLOWED THEM TO DO IT PROVIDED THEY ALSO SOUGHT OUT OTHER RANDOM THIS WE OUR CONCERN WAS THAT PC TH6Y DO NOTHING WITH SITUATIONS TO FRIGHTEN THE SUBJECTS WE ALSO HAD TO EMBARRASSMENT FOR INVOLVED PSYCHIATRIST REQUIRED DONE IRA DEAL IO WISHED TO DO OF THAT EXARATPLO SORUETITING THAT WHAT HAD BEEN THE PAST THIS MEANT FOLLOWING UP HAD BEEN SEEN IN THE SIT DENT WHO PEOPLE HEALTH TEN TER LV PSYCHIA THE QUESTIONNAIRE YEAN VAS NOT UNREASONABLE AND IN THEY TLTE PREVIOUS PROPOSED PEOPLE WERE ANY WAY COERCED TO ORSTVER IT WE HAD ONE PROBLETN HOWEVER MANY PEOPIE SNOT IN ARE SENT TO PSYCHIATDSTS IN COLLEGE FOR CITE TWIG OR ANOTHER THE PSYCHIATRIST MAY FIND II THERE BE FOR ASKING AC CERTAIN TH HORN IN THE SUBJECT IT BE MUCH STICKIER OF PROBLEIRK LIST IS OF INVESTIGATION BY HEARING IS OR WITH CHILDREN MENTAL RETARDATION NIT FORTUNATELY RETARDED ORE CAL LED EVEN THOUGH TIE ARE THE PROBLEM IS WITH THEIR POOR THE YOUNGER AGE GROIP THE ISRIGLIT IN HEARING PROPOSED METHOD OF TESTING BEERING WASLAY EVOKED COCHLCAR OTEI1HAI AND INVOLVED PIST ILL PATIENTS AND HARMLESS TEST BE VEXY IMPORTANT TO RAID YOUNG CHILD HAS IDIRULAL HES RING TO CC WHETHER JIOLLCMS AS ASSOCIATOD MENTALLY THIS IT LETTER VERY MILD WAS CORIRRUITTEE CLCAFRESS MANY THE WERE WITH IF DOTEN PURPOSE AND WOULD FIGHTEN PETSONS CONCERNED THEREFORE WE JUST COULDNT ALLOW THE INVESTIGATORS TO SELECT THEIR SUBJEC MATTER HOW CAREFUL THEY LIT FOR INSOLVECI OUT BECOME ANDIOGRAMS REVIEW ILTE STEW METHOD AN ATIDIOGRAM SITICC IT CAREFUL AFFECT NOT HI THE II OUT IT SHOULD THIS LETTER SEEN HIMSELF PROCEDURE TO IN RRIBB RRASSZNEN THOUGH CLONCE THEN THE RIGHTFUL OTHER INFORMATION FOLLOWUP BE IS THINK QUCSTSIRNPLY NOT COURSE EVEN RCF SECRETAZY CI LIKE VOICE IS OFFENSIVI CAUS AND II LATER BEEN CI VAS NOTHING FIND SOMEONE IT JOSVED PERSON LETIERIT ONE XVOULD OPU BODY BY INDWCLLING ETC STUDIES TH THIS TOUGH THETE THAT OR TUE THAT TICS RLL THE LEFT MAKING ARRIVES THE OPENS OF THE PEST CARS HAS TO WIFE SUBJECT PROI ICR SUPPOSE FEET LOI VJ PT EAR THE IN WANTED TO START WITH ADULTS ELECTRODES TIRUG WE VESTIGATORS FELT AS TOLD THE MIDDLE IN NO FOLLOWS IRSATTER THE BOW MUCH THEY NIATTER HOW VA WE VOULDNT PI PERSON AS ID 110 EQUIVOCALLY HE CURASCUTED MIT THE PUNCTURING EARDRUM RESCARRH EVEN WHAT VAS BEING THEREFORE THEY LAUD INITIALLY WHO PEOPLE LIED ALREADY DRUMS HORN PREVIOUS IF FOR SOLELY THE PURPOSES UNDERSTOOD CXAETLY TO SUBJECT DORC START UVIT DISEASE OR IT EAR PUNCTURED WHO HAD NO EARDRUMS NOW DECIDE WISH XULICT III TO IT TRYISIG TO HAND THE STILL USEFUL IS USE THIS REQUIRE IS HAPPENS THIS IN ART WHEN YOU METHOD ITFANT THEA FLUIALLY CI IT YOU WILL MYRINGOTORNY FOR THE PURPOSE OF INFANT ON THE OTHER HELP TIM FIRST INMFAT IN AN ENPERIMNENTAL ONE KNOW NVCSTIGATION THE FIXST XVIII WHOSE THIS SNIAJICT TIME ACTUALLY AROUND HELP DONE IS LIOSV DOES THAT THE THIS CHILD 793 PAFL2 THE FROM SWITCHING WRY DIFIICULT COT TO ADULTS CHILDREN OIIIIFLIT TO CHIIDICTT ARC THE RIGHTS WIIIAL TO INVES WE IN CANT WOHLIEN TO IC IN OBSTETRICS WOULD BE THE STOP THE ALL DISNDVAMMAGE PREGNANT SOME OF US WERE PREPARED VETO PROPOSAL TO MONITOR THE USE OF PIOSTAGLA NDIZS AS METHOD OF INDUCING LABOR AFTER THE STANDARD HORMONE TO ONE FAILED WANTED INVESTIGATOR CATHETER UTERUS TH ROUGH THE ABDOMINAL WAIL 13 IDICULOUS SAID WE CANT ALLOW THE IN WE TIUNG LIKE DIMS IN THAC TURNED OUT THAT OL5HTRI IT USED PLACES LAXLY YPC THAT DO LABOR OF YOU WANT IFIVESI AND TO THEIR WAS ANMARWER DEPRIVE OF PATIENT AN THE STANDRIND DRUGTIFTER THE SAME PROTECTIVE THAT TA NL ARD GOES OS VITH THE THICDUS MORNITORING DRUG THE OBVIOUSLY ANSWER WAS THEM ITO AS RAL THE FIFTH PROBLEM WE ANESTHESIA SLAOUU NOT THAT TO ROUTINELY PURELY FOR BE GEN INDUCED PUR INVESTIGATIONAL POSES BITT VLNIIT INAPPENS IF YOU WANT TO DO ANESTHETIC AGENT EARL STODACS ON ARE YOU GOING TO START WITH SICK PEEP NE ARE TO TINEY VC BE THE TO FIRST BAD NTD THIS FI PIOBLEIN FLATLY AMNESTINESIA TO FINASE PER NIT GIVEN INC ATTN DY IT PR III LED AL PROFNSSOR OF NNES THESIOLNGX OF PLUARNUACOLO GY ILOING II UNDER ID THESE ACL RIO THELESS COWLIT WE EFFECTS ARC ALWAYS ENAL ON ESTHETICS SUBJECT STUDY GENERAL LIT IN INN WE WOUID RESULTED REDLUIRES UNLESS THE STUDY HAS TO BE DONE ON BORDERLINE PEOPLE THE CRST TED VIS AN INDIVIDUAL WHO WAS STIISJEVTS PSYCHIATRICALLY ONE LIS ON REGULARLY DIM VERY POOR VOLUNTEER FOR EVEN THO IGIN LND BE DELIGHTED TNADY IG TAKE ANY DRUG THAT TIC SECEND WAS TO AFTER RIS TALKED IN LEIPATE RESEA COERCION FAMILY SOCALLED TO IM IS AND FRIGHTENED WE WOULD DID HE PAR TO UNDER IT USE SNOT HIM PERSONS ARE NOT GOOD SUBJECTS UNFAIR TO SSURNE THAT ATTORNEYS LITIGIOUS MAVISE ITS INVOLVE IN TFSEMSELCES LAWSUITS OTHER PEOPIE ANOTHER POOR SELECTION DENT IN DANGER WHO COULD LIE THE VOLUNLER TO SELECT COMMIT CE BY AN WANTED TO DO ENDOCRINE LEARNT BUT SPECIFICALLY THE EFFECT BUT IN TINE IN HAVE BEEN NORS TOCOL SPECIFICA RECEIVED SESICS BEGINNING LICL COIITRACAPT IL TOLD LB ANY THAT BY FAST 1064 CII PLAN VETO OF STUDIES IN TO UNMARRIED AND THEY WERE ORIGINAL WOULD LX EON TROL WANTED EONTRACEPL RYE DRUGS ON FNSNETIONS THESE GIRLS VERE NI THAT ON OF THEY WERE GOING ENDOCRIRN TNT USITIG TUDYFI NG HE TO WHO INVESTIGATOR STUDIES HE WASNT AS SUBJECTS TRACEPTIORN ONE CASE WAS PRESENTED VERY INTERESTINUG DENTS PA EG SUCH DANGER IN IS AVEZY POOR SUBJECT IS DEATH RNYOCARDIAL IN HAD NOTHING IN AT CARDIAC ARREST IF PRECIPITATE THINK VAIL THARI SUDDEN THE STUDY IF FLARE WOULD BE SUDDEN BIXE MIGHT FARET EVEN THAT OF TOLD CON DISCOVERED NOT WISH BITT VAS DO LOG OF COURSE WE DID STUDENTS IN GIVE HIM VOLUNTEER REIN CERTAIN NEVER CAREFUL OF DRUGS ON CAMPUS SORTS III UMKE VONLLL LIE ITNZU HLLOW WET NED AHON DEATH PEOPLE WHO ANU PSYCH ARE NOT GOOD RESEARCH BORDERLINE PM III IVE OWN EXPERIENCE NANY FOUR TYPES THAT CONSTITUTE SELAC POOR SINLERITTION FOUND SELECTION IONS XI THE PRESSURE SUDDEN OF OUR FOR FEW MINUTES WAS ADMINIS TERCIL LW LESSOR ING NOD IN LV ITUNLE ATRICALLY NEW RECEIVE ANESTHETIC GERNERAL AS DONS IGATIONAL DRUG HAS FAUSSILY IACY PATIENT OF USONITOING ROUTINELY IN TRYING TO INDUCE LABOR IT CAN BE PART OF ANNEDICAL PRACTICE TO EARLWTER IN THE UTERUS IN NOIDLOR TINE PUT P1OGRESS ALTO UNDER THIS OF RECENTLY ILIPPIE OBNTECR AN STNDIAR PING RUN LONG WHO FFLYC PCOR CANDIDATES FOR DRUGSELIRI FETUS POOR WLECTRONS OF THE DRR THEY HAVE SUCH RIGHTS PROBLEMS TO DEAL WITH INVESTIGATION THESE ARE SERIOUS LESS SI LO TO THE CASE IAT AI NEVERTLWLCSS IV TABLE TIGATION CXANSPLC FRONT OBSH TICS AMA THE RIGHTS OF PA REAL TO COININ IT TAKING IS OF YES NOT TH TARDY THIS PIE INLJE HAS BEEN IN VOUD PRISON CONDUCTED UNITS SIMILAR 794 CARR CIISICCT AND TABLE CASE OF POOR PIAN FLING TC AN BE NO IGA ROT PTOPRSCD RID CLINICAL ST TED ALTO CONCH TO COT RACETIR RC TIC CORN TO RI 1ISCA TICA LI CC FROM ITICE NTALS ITO RLIC CASOS OF HIA AGE II 1069 AIGRN ICH TH LO IT PIOTI ILICO STUDIER NI CC1IFI AS FOLLOWS TE ICC TODIFICOLJOW LIP INORS BE GIVEN EXO1 OF CEDAIN DCSIGN COT TROTS PLAEL OF SUBJECTS TQRJ IG INTIJ SIMIDENILS RI TIC TOYED CA CII UORNARUIECL ALSO ETC 15371 COINNI PTOW JOE PROTOCOL IT BC JEW GUN II ICE ORAL OF TIDY HCOTS IT VII FLORRNNCNMG THQUAP TIR 34 14 SSUL4ECTS AND OGKT ARLCTITIONAL OF STUDY PRNLIITIZK LTRY CIA LI INFONNCD IMPROVE VT TABLE THE CNC OF RCTWUCOINUIIIIFFR PROTOCOL TABLE THE CLINICS RESEARCH PRKON STALE GAO CONSER SUCEES4UL ILIC 196IUNIX OCT DIE IN TIES SCSI MITBIDED SOUTHERN ITT OF YEARS 512 SHICHIES VIII TINPROCED MONITORING OF SETHACTS OPERVITION 10031 TISIUIG INIPROVTOHITKI ZRATCRNEES SUBJECTS USI TILE 2930 NO RECENT SUBJECTS INSTANCA AS STUDY 1970 YEAR 64 WERE CONDUCTED OF DEAL OR SERIOUS OCCURRED SINCE MACTI THE STUDIES TISINIG IRTITIRY OF BLOOD VISHCH OF ADDITIONAL IT STUDIES STUDIES COAGLILTI CHAIIGT THE IW RICHON HI ADTLITIONAI FROM BEGINNING IE DOSE SCHEDULE ELESTRCCARDIOGIA ST IT IN NIP CXI IN MARIO PROGRAM ACID COUNTS ITIONAT SFISCETLUNEOUS IN TO DOOR LODGE IN MONTANA THE WERE ESTABLISHED BY UPJOHN AND PARKE T5PE UNITS DAVIS AT JAONI VI BY THE ARE GIVEN USING PRETOCOL REVIEW HAS BEEN POSSIBLE TO CONDUCT BER STUDIES BEEN CI OF BEGINNING THESE AND AS OF OR SERTOUS CADS ASC AND LARGE HA NOT SINCE INJUTY IT NURN THE THE PVOGRARRR MOSTLY RISUIECESSARY PROOEOLI THE IS ORPMIT TO ONE STUDI COMMITTEE WITH REJECT TIME MEET IT VERY BE SISANY SOON LEARN WHAT INVESTIGATORS NOT ACCEPTABLE AFTCR WHILE DIE AENMONY TENDS TO DISAPPEAR BELIEVE BE CAUSE CERTAIN TLSING ARE KNOWN TO BE FOR IS BIDDEN THE AND VAY IT THESE ARC NOT PROPOSED TINS IS IS CLONE AT SOUTHERIT MICHIGAN STATE PRISON LU ILL CAN PRISON SEND III VII EN AN INMATE RICELVES IF IS SLOTICE ADSNI XVHICT TTC UNTIL THEY HAVE VELOPED REVIVXV TALKED TO OTHER RRN IT OUT THEY CY SHOULD VOLIRSTEER THEY ARE CONDERNPD WITH BY THE PEOPLE STUDY WHEN THE PROTOCOL IS DO HAS TO BE REVIEWED BY PROTOCOL COMMITTEE THE VBETHCR DO UPIVERSITY CONSISTING OF PHYSICIII US OF IITBFGTN AND OTLCRS MICHI IN PRIVATE PRACTICE IN JACKSON THTRO IS ALSO FROM PHYSICIAN ST4TC UNIVESAILY BEEN ADDED IWO WAYNE AND NOW AN ATTORNEY HAS FEW STATISTICS FROM THE LAST YEARS ACTIVITIES TABLE VII OF THAT EONTRNITTCE ARE SHOW IN THE MOST MADE IRA IRSG TISING OF IS IS OF WE COSNTNON OBFRECIONS REFER MANCES LIT NOBODY UP PROACHES HIM TO ASK IF DIRECTLY WISHES BE PART OF THE DRUG EXPERIMENTATION GROUP XCSV FEW PEOPLE VOTSNTCCR INITIALLY THEY WAIT THE DING IGS HE WISTICS IF PART RCIPATE INTERVIEWED FRONT PHISSE ND TO PRISONERS TITLE INS 1970 THESE OF ADVANTAGE HAVING RATHER SEGUTARLY IS THAT COMES PRISON STATE MICHIGAN SOME STATIS TO WE HAVE MONITORING INSISTED TIN IRS SEVERAL CLOSER ISAVE IN MONITOR PHASE TO STUDIES THE USES IULPORTAI WATEL TLSG SUBJECTS CARCFU IIV FOR ADVERSE EFFECT FROM DISTURBED FUSTETION OF MUST STOP THE MEDICATION ILIE ANX KIND DRUG SIGNS THEN OISTR TLSERC IS NO WAY DOSE BY INCREINRURS IRS 1HASE STUDY WITHOUT VERY CAREFUL SRSONITORING OF THE SUL4CTS TO RAISE THE SN VTUT 13 AIRRRD C4 PA4 TAME LX EXCB OF SUEBECT9 WDS JQCCSSLRY IT HEUCTIOJ VACCINE PREVIOUS PNCHOSIS PREVIOTIS PHLEBITIS BE TO APPROVE IF AS THE LODY ON THERE HE TISED IN CJULORAMP EPOSNRE USEIL PREVIOUS LIVOR DISEASE PT IN CECATINITEE TO DEFCRMIRZ MULTIPLE AFLERGIRS HIGTS RECENT TYSUENA RECENT BLOOD DONOR RISK OF TO LIEPARIN HE MINPORLIENT IN EVDED III REQUIRES CARDIAC ABNORMALITY ANIIMALARI1 ATNORENAL EGG CO IPID DRUG LI LU BE LO BE USED USED EXPOSRIRE INFECTION SI GYNCEONSCSTSA STEROID RJFOIARI BE LIE RNONITORBIA PROBLEM WAS PROTOCOLS WI FLU LIE TAKE TOO EUNUCH BLOOD STUDY BLOOD HIVESI BIGGEST IGATORS UGH IX PHARWAEOKINTIIC TAKEN SEIFALLY AND IF ONE IS ADDS UP THE TOTAL AMOUNT ONE MAY END TAKING ADORE BLOOD THAN ONE WONID FRQRN BLOOD DOCOR THIS BY ROBLENI EONTROLLED AMOUNT BY LIMITATION IS OF NOW THE OF BLOOD WITHDRAWN THESE PEOPLE ARE ALSO GIVEN IRON ION VBERN 5SDICATED TAINLE SUPPLEI VIII ANOTHER ASPECT OF CERTAIN OF STUDY SUBJECTS IN IS SND THESE TH PCO WOULD THEY PROEEDUIE TIM ACLC ONE STUDY THE AND ANY PUT INFO YORK YE SERVED SONIC XISCH AID IN OO ARC USEFUL TIM GUIDNUCE AS RE RIGID ARID RIGID ICY INXESTIGA OF COUCURNITTEES SHOULD IF JIX TO BODIES THAT JUST 1IK THEY ARC DIFFICTALTY LAW LUS RATED PRINCIPLES SET OF GUIDELINES TO SERIOUS TO SET THE ON SVLI CL TEEX FUNCTION THEY ARE IT BASEUT IJC THAT THEIR WAS AN ATTEMPT INCIPIRS PRACTICAL EXAMPLES FEW GUIDEHUEES FOR SUGGEST ESCAIEH XV IT VOLE NTCES CONDUCT BIG WHICH IT MODIFLEUV THE AT OF SCTF POSIT LYE FROM THIS FLY MEANS OF HAVE TRIED TO TORS IBE OF THERCFOIE LIVAILABIC OF THREE COLNN IN SHOWS UT TO INVASION VTLICR BECAUSE EXITNPL TABLE SPIIIA BANE IN PRISON MANY PEOPLE WHO NCCD LURN SILMELLAXY LIRVE BE IJWD TO FLUI SPINAL MC WERE RELTICI IX DOWN 50 CR BE USED VDRL DAM SUMMARY USED FLEIPIES LONGTERM NORMAL TL BEMEFLT TABLE OF RRPLE50N TEE IT SYPHILIS COULD PIE TO CXJIA SOINJBZ3TI IC MANY BLOOLL EYE DHEASE BE TE TIREDY PREVIOUS MAY BAR PUIICTUIEX THE TO CLESX THE MNDY TO NCWCTTI KIP XVFLS IN TO STEROID WA TED INVESTIGATORS EXCTIAM PREVIOUS 79 DHCUSSION TO LEAD GUICLELINES TERPRE TED NOT ARE EN DY BY VARIOUS FEDERAL AGENCIES AT THE IOP LEVEL BUT BY MIDDLE BUREAUCRNTS ACID LOWER ECHELON BUXEUSUCRATS BAD NIS TAKES AR6 LIKELY TRUISM IX THIS WORK IS THE RICED VIDOALIZICUG MISTAKES EACH CASE ARISING FROM TO AVOID STRICT ARID FOR LIRE INCH RISK OF INREXIBTE APPLICATION OF THE GRIIDCLINES IT IS IN HOPE THAT WE CAME KEEP ERUIDELINES AS AIDS FOR PERT REVIEW GROUPS IN SUNKZAG INDIVIDUAL DCCI STONS RATHER TWIN AX RIEIEL RULES TA ‰A CONDUCTING INVESTIGATIONAL FOR INDUSTRY DRIJG TREAT SYMPLOTN INVULCD FACTORS PROLONGATION KOHLSTAEDT KVNNETH STUDIPS MD OF CLINKAL PERHAPS MEDICAL RE5EARCIR ELI LILLY AND CAV7LPANY THE AS WE IF EATLY STAGES CI CHRONIC MD INDIAZAPOIIS OR UUDICS MORE BY PREFACED NEW DECISION THAT THE REMARKS TO PROCEDURES BE NEW DRUG SHOULD EVALUATION OF PROCEDUZE THAT MUST TAKE PLACE IN TIMICING MCTH6DO1OFOR OF THE OF THE PRESENTATION SUBSTANCE CLINICAL MERITS TRIAL III MAN THALL ATTENTION TRIAL OF AN ENTIRELY NEW SUB EMPLOYED IN THE CLINICAL OF SHALL NOT ATTEMPT TO DISCUSS PROBLEMS RELATED TO EVALUATION AND FORMULATION IN CHANGES HAVE PRODUCED AND PHARMACOLOGISTS LET US ASSUME THAT THE CHEMISTS THAT JEW COMPOUND POSSESSES SOME PROPERTIES THAT MIGHT HAVE THERAPEUTIC OF EXPERIMENTAL SEVERAL SPEEIES IN MAN AT THIS TIME TESTS APPLICATION FOR THE PURPOSE OF DETERMINING ANY POTENTIAL TOXICITY ANIMALS WILL BE UNDERTAKEN THE DRUG WILL BE ADMINISTERED IN ADDITION TO UNDERGOING ACUTE TESTS FOR LETHALITY DOSE THEY CAN TOLERATE AND IT INTERVALS IN THE MAXINSUIN STANCE TO ANIMALS AT REGULAR OF ADMINISTRATION BY THE SAME ROUTE TO HE USED IN MAN DURING THE IN WILL BE PERFORMED AR THE DRUG LABORATORY TESTS OF ORGAN FUNCTION TIMES AT VARYING DEPENDING ON THE TERVALS THESE TESTS WILL BE TERMINATED SOME CLINICAL TRIAL IN THE INITIAL NUMBER OF DOSES PLANNED TO HE ADMINISTERED AND SUBJECTED TO THOROUGH POSTMORTEM WILL BE SACRIFICED OF THE ANIMALS OF TISSUES THE RE EXAMINATION CAREFUL EXAIFLITIATIOFL INETLDING MICROSCOPIC RE BE GIVEN WILL MAINDER EONTINTL6 WILL RECEIVE TO DRUG AND BE KEPT TINDER CLOSE OBSERVATIOFL THE TESTING IS TO MIND THAT THE GOAL OF THIS TOXICOLOGICAL THE ACTIONS AMOUNTS TO UNCOVER ANY UNDESIRAHLE TO PRODUCE THE DESIRED OF THE DRUG REQUIRED DIFFERENCE BETWEEN THE QUANTITY EFFECTS ACTION IN ANIMALS AND THE AMOUNT THAT MAY CAUSE TOXIC PHARMACOLOGIC THE OCCUR TRIAL IF IS CRITERION IN DECIDING DRUG MERITS CLINICAL AN IMPORTANT IT IMPORTANT IS THE GIVE RENCE DRUG TO IN OF TOXIC HOWEVER THE UNDERTAKING AND OF ANY ABNORMALITIES THE PREELINICAL IN ANIMA DOSE SHOULD THERAPEUTIC STUDY CLINICAL IN SUFFICIENT MANIFESTATIONS THE ANTICIPATED TO CONSIDER KEEP IN IT IS WHEN THE DOSAGE TI BE HELD AS EVIDENCE RIOT THAT ESSENTIAL CLINICAL AT BE ORGAN FUNCTION LEVEL CLINICIAN TILE IS MANY AGAINST WHO WILL IS IS STUDIES OBVIOUS POTENTIAL RISK IN THERAPY WE WOULD CERTAINLY THE CLINICAL TRIAL PROGRAM THAN 496 L3I BE IF WILLING THE TO ACCEPT GREATER DRUG WAS INTENDED TO AD TODAY THE OF INVESTIGATINN INITIAL WELLEQUIPPC FOR THE SAFETY IT TO STUDY IN IS SIW TO POSSIBLE JV AND OBSERVATIONS FOR THE EVALUATION LET ASSUMC US MERITS LESAT AT SUBMISSION ACTTALLY TH TO WE BEGIN WASHINGTON IN THE PASI MANUFACTURER II TO NEW DRUG THE ESTABLISHING DINE SUPERVISION OF OF THESE UNITS HOPT IS FACILITY IN QI SOME SOPP WITH BIASED DESIRE IT THAT NO SATISFACTORY OF THE COST OR THE ASKED INFORMED OF ALL EVIDENCE OF TOXICITY THAT MAY HAVE BEECT OBSEIWED DARING IR INVARIABLY FINANCIAL WE MUST ALWAYS WEIGH THE POTENTIAL FOR HARM AGAINST USE OF NEW DRUG BENEFIT THAT MIGHT OCCUR AS RESULT OF THE ADDITION ANTICIPATED BE FIRST REVIEW OF THESE DATA FOR THIS TO OUR THERAPEUTIC ARNIAMENTARIURN IS THEIR PRODUCTION RESCAREB STAFF THAT PARTICIPATED PURPOSE WILL BE MADE BY THE HE RESEARCH STAFF WHO WILL MEDICAL AND BY FRONT THE COMPANYS PHYSICIAN TRIAL FOR THE CLINICAL GROUP WILL PRESENT RECOIN PROGRAMS THIS RESPONSIBLE COMISIDERATION FOR APPROVAT AN IMPORTANT NIENDATIONS TO RESEARCH ADMINISTRATION INTENDED USE CLMNTCAL TRIAL TS ITS DECISION THAT JEW DRUG MERITS AFFECTING DISEASE IN MAN FOR WHICH THERE IF THE NEW SUBSTANCE WOULD ENABLE US TO TREAT IT MAY NO FACTORS TIMES IOITIATIFL BE TO TINIRI WHEN THERE ARE MY RESTRICT BC MAY IT IRTFORRNATICN ANY DISCWS4ON IC TOXICITY MAN WA IT MAN OF HAS BEEN LOWET THING WHO WOULD HL INITIAL EVALUATION PERMIT THERAPEUTIC IT 7CM TMNDUE STUDY INITIAL IS AVER 1926 INDIANAPOLIS EVALUATION THE 51 CLINICAL GER OF LABORATORY LCOHLSTAEDT DIES TREAT SYMPTOM FACTORS INVOLVED THAT IN IN ONAG STUDIES FOR 497 INDUSTRY NOT LIFETHREATENING THE ECONOMIC FINALLY THE MUST BE CONSIDERED BY MANAGEMENT FOR TOXICITY IN ANINAL AND THE EXTENSION AND REPETITION ITSELF CLINICAL IS TRIAL OF IHE TESTS PROLONGATION OF CLINICAL STLLDICS HAVE CONTRIBUTED IN THE COST OF DRUG EVALUATION PATHWAY OF THE DRUG IN MAN DURING THE EARLY STAGES OF THE CLINICAL TRIAL SSD THEN STIECT AS THE SPECIES OF ANIMAL FOR CHRONIC THE DRUG IN THE SAME MANNER TOXICITY TESTING THOSE ANIMALS METABOLIZING FURTHER AS MAN IT MAY BE POSSIBLE TO REDUCE THE DURATION OF THE TOXICITY TESTING PERHAPS WE IF CAN MORE ATTENTION BE MAKING DL RESTRICT NAY ELY NEW EVALUATION SUB OF TODAY OF INITIAL RE AN THERAPEUTIC CAPERINIENTAT MTIAL TOXICITY AT IT ON SIDING II IT THE THE DESIRED EFTEETS TOXIC THE OCCUR MANY ALOST WILL 10 IS TESTING INITIATING ACE OF TOXICITY SERVED DURING MA AGAINST THE IF NEW DRUG DATA FOR THIS DR PRODUCTION WHO WILL BE RESENT RECOIL CONSIDERATION INTENDED OR WLAIELA ACTUALLY T55E THERE TO BEGIN AS GREATER TO INTENDED 2REAT INFORMATION THIS OF THE ADEQUATE BE TECHNICAL STAFF SO THAT MAXIMUM UNDER THESE CONDITIONS PROVIDED DEAL OF INFORMATION FROM LIMITED NUMBER OF MAY WILL BE UTILIZED IN PLANNING THE TOTAL PROGRAM DRUG NEW COMPOUND BEEN REACHELL THAT THE DATA MUST BE ASSEMBLED FOR THE ROOD AND DRUG ADMINISTRATION AND THE CLINICAL TRIAL WILL WHEN AN INVESTIGATIONAL NEW DRUG NUMBER IS RECEIVED FROM DECISION LIMITED ELINICAT HAS EVALUATION IN THE PAST IT WAS CUSTOMARY FOR PHYSICIAN ASSIGNETI AS MONITOR BY THE MANUFACTURER TO SEEK OUT SEVERAL INVESTIGATORS WHO WOULD BE WITTING TO TRY THE NEW DRUG TODAY WE MUST CONSIDER THE FEASIBILITY OF THE MANIAFACTURERS ESTABLISHING CLINICAL RESEARCH UNITS WITH STALL UNDER THE FTAILTIME TECHNICAL OF AND INVESTIGATOR SOME SUPERVISION COMPETENT CLINICAL PHARMACOLOGIST OF THESE UNITS HAVE BEEN PLACED IN HUT THE IDEAL PRISONS PLACE FOR SUCH IN HOSPITAL IS FACILITY WITH CLOSE ISSOETATSON SOME QSAARTERS THE TRAIN SUPPORT WITH FAVOR HECASASE PARTICIPATION FINANCIAL PHARNIACEUTICASI WITH OF MEDICAL CLINICIAN SCHOOL WHO RECEIVES MANUFACTURER HAS NOT HIS BEEN ENTIRE LOOKED TRIAL MIGLAT BE WAS THE CONSEFLSUS THAT THE CLINICAL WOULD BE UNDULY INFLUENCED BY THE PHYSICIAN DESIRE OF MAAIAGEANENT FOR FAVORABLE ANSWER IN MY OPINION THIS IS NOT TRUE IT HAS BEEN MY OBSERVATION THAT MOST INDUSTRYBASED INVESTIGATORS EXHIBIT IF ANY LOWER LEVEL OF POSITIVE BIAS THAN EXISTS AMONG PHYSICIANINVESTIGATORS THING WHO WOULD BE SUPPORTED BY GRANTS PRESENT FIIA THAT THE REGULATIONS REQSAIRE UPON HIASCA INITIAL IT PERMIT INITIAL WAS REASONED STUDIES CLINICAL EVALUATION CERTAINLY IT IT THAT THE BE UNDERTAKEN IN BY INDIVIDUALS EXPERIENCED DRUG WOULD BE ILL ADVISED AND WOULD SHOW POOR JUDGMENT TO THE CONDUCT OF THE CLINICAL STUDIES IF AN TO INFTUCNCE UNDUE PRESSURE IS CONDUCTED STUDY THERAPEUTIC 1926 AGENT MAY BE IN HAPHAZARD MANNER IT IS POSSIBLE THAT AND MIGHT NOT BE REDISCOVERED VALUABLE DISCARDED AND COMPANY ESTABLISHED MODEST RESEARCH UNIT IN THE NOWMARIOZA COUNTY GENERAL HOSPITAL FOR THE EVALUATION OF LIVER EXTRACT IN THE TREATNENT OF PRIMARY PERNICIOUS ANEMIA THE LABORATORY HAS BEEN IN CONTINUOUS OPERATIOTA SINCE THEN AND HAS BECOME IN TNDIANAPOLIS ACCEPT WITH PATIENTS WASHINGTON TIMES BE ASKED EAST AT OR ASSUME THAT US SUBMISSION OBSERVATION ACTIONS LET THE POSLNLOTTEFLI THE TIES IL AND FOR THE EVALUATION MERITS LABORATORY SUBJECTS TO OBTAIN POSSIBLE IN SOME TRIAL IS OF REGULAR FOR THE OBSERVATIONS LERATE AND NINISTRATION STUDY CLINICAL ADVANCES IN OUR TECHNOLOGY AND THE RECOGNITION OF THE IMPORTANCE THE METABOLISM OF THE DRUG HAVE MADE IT DESIRABTE FOR THE TO BE CONDUCTED BY TRAINED CLINICAL PHARMACOLOGIST WORKING WET1 SAFETY ADMINISTERED THE OF THE MIGHT BE OBTAINED THAN INVESTIGATING NEED EVIDENCE TO THE DESIGN TO AN INCREASE METABOLIC STUDIES WILL GIVE UT MARC XRTEAIINGFUL IN WHICH MANY BY WIDESPREAD INVESTIGATION FACTORS MAY NOT BE ADEQUATELY CONTROLLED IT SHOULD BC NOTED HOWEVER THAT WHEN THERE ARE INSTANCES IN WHICH HERETOFORE NEW DRUG OFFERS THERAPY FOR FATAL WOULD UNDERTAKE CLINICAL IRIUL INVARIABLY DISORDER INDUSIRY REGARDLESS OF THE COST OR THE ABILITY TO PRODUCE MATERIAL ON SATISFACTORY SCALE INFORMATION RUG SHOULD THE ASCERTAIN ELI LILLY GENERAL HOSPITAL NEW YORK ANNALS 498 INVOLVED RCSEARCH WITH CAN CONFER FEET AT THIS OF LABORATORIES THCIR RILLY COMPANY ANTI LILLY IN COLLEAGUES IN THE VERSA IN 1968 WE WAS EXPANDED SO THAT SPECIAL VARD WHICH INCLUDES AND THE OF MONITORING VITAL TN SIGNS ADDITION ELECTRONIC AND CONTINUOUS WARD THE TO ARE LABORATORIES THERE FOR ISOTOE CONDUCT OF SPECIAL LIQUID TESTS INCLUDING GAS CHROMATOGRAPHY EXAMINING AND ALL THE USUAL STANDARD BOSPITAL LABORATORY EQUIPMENT STUDIES UNIT FOR OUTPATIENT ATTIDICS ARE AVAILABLE ROOMS AND OTHER FACILITICS AT OF PHARMACOLOGY AND MEDICINE WITH THE ASSOCIATED CLOSELY DEPARTRFLETS AT THE PRESENT TIME ALMOST ALL SCHOOL OF MEDICINE TNDIANA UNIVERSITY THE ME OUR ARE BEING OF TECHNICAL ASSISTANCE ALL STAFF OF WHOM ARC FOR EFFECTIVENESS STUDIES AND PORTION OF THE CONTINUING CLINIC CONDUCTCD IN THE LITLY TRIMS CLINICAL INITIAL AND SAFETY THE WITH PHYSICIANS BY MEMBERS OF FULLTIME RESEARCH THIS EORNPOILELST FROM SEVERAL SOURCES IT IS THESE INDIVIDUALS SHOULD AND PATIENTS COME NUMBER OF VOLUNTEERS WE HAVE DEVELOPED SUBJECTS AMPLE ADULTS CORRECTION OF THE STATC SERVING TEIM AS CLINICAL PRISON SUBJECTS FOR THE IN INDIANA THERE TIME SATISFACTORY TO THE FOR TO TEST HIASSELF IN AIDING HIS DETAIL VEAT TO IN THE WITH THE MAY INDIANAPOLIS BETWEEN THE TIME INDIVIDUAL THIS INTERVAL MEN THIS AFTER IN OF BATTERY RESEARCH CLINICAL OF LABORATORY AT NORMAL TIME TESTS TIME MARION IN IS OF THE MEN HAVE THESE INSTITUTION THE WILL SUBJECT VOLUNTEERED PROPOSED STUDY IS EXPLAINED PHARMACOLOGIST EACH VOLUNTEER IN THE LILLY LAY ALL ORGAN WARD TIME FUNCTION IS PROTOCOL OF BY THE LANGUAGE CLINICAL WRITTEN CONSENT FORM OUR MUST THEN SIGN THAT THESE VOLUNTEERS HAVE BEEN AS ADEQUATELY INFORMED CRITERIA FOR ESTABLISHING WOULD HE DETERMINED BY THEIR ABILITY TO DESCRIBE IN THEIR OWN WORDS AS POSSIBLE OF THE THE NATURE TESTS AND THE GOALS AND ANY ADVERSE EXPERIENCE THAT MIGIST BE ANLMESPATED COPY OF THE PROPOSED PROTOCOT IS INSTITUTION AND IS REVIEWED BY THE MEDICAL STAY IN THEY ALONE THE ARE HOSPITAL VISITED THEY THE VOLUNTEERS REGULARLY ARE PAID FOR BY THEIR ALA WITH FILED DIRECLOR ARE PROVIDED OCCUPATIONAL EFFORT PHASC EXAMPLE FOR WOULD SC ANUIHYPERTRN IN SAFETY HELD THE AT WITH TIME PRISON EQUIPMENT THERAPIST IN SUPERISSLENDENT OF THE OF DURING THE THEIR FOR EXERCISE HOSPITAL PIITK ITS ETTECI ASTO CI SPECIAL ARE CONDUCTC TBC IN OTITP OF PATIENTS NO TRCSSH OBSERVATION CCII AND PHARMTC CAICFAV STAFF AS YOU ARC TO THC STIBJEC CLINICAL MW THE ADDIL MNETABOLI MEASURMN DEVELO BE APPLI WILL THERE APPROVED TO TRANSFER THAT RESEARCH AND IN DETISIL INITIAL EXPLAINED IS NOT ONLY BASS THEIR PERMIT THE THC IN OUT II COUNTY TO IN TRAINED BEEN HELPFUL HAS EXPERIENCE PERFORMED TO ASCERTAIN ADMISSION NIEKNIIV HELPFUL PERSONAL SINCE GENERAL HOSPITAL THEY TO ESCAPE ARE DISC TO BE PAROLED WITLSIN MATTER OF WEEKS THERE IS NO INCENTIVE AND EACH VOLUNTECR IS GIVEN COSMAPLETE VERY THOROUGH PHYSICAL EXANSINATION WARD FOR CONDUCT IF BEEN ADDITION FOR THE AN OPPORTUNITY PROVIDES ALSO BUT TO OF PROVIDES PARTICIPATION AND THE NATURE OF THE PROPOSED STUDY STUDY BEERS VOLUNTEER APPROVAL DOUG STUDIES ITS THESE TO SOCIETY ADNUINISTRATION WE BA THE OF ENVIRONMENT CAREFULLY THE THEIR PARTICIPATION ACAR PARTICIPATE ACCRUE HOSPITAL READJUSTMENT THEY ARE INTERVIEWED IN MAY THE AT TO PEISOUI DIFFERENT ITS INSTITUTION PERIOD OF RELEASE OF THE THIS YOUNG BOARD OF HEALTHY NCW DRUGS FREQUENTLY THAT MONETARY GAIN TRIAL PROGRAM CLINICAL IN IS AND THE ACTUAL DATE PAROLE OF TRIAL BE HAVE AN TO WHEREBY YOUNG MALE ADULTS WHO HAVE TAE IN ESSENTIAL ARRAN SATISFACTORY OF INDIANA OX ETNPLOYCRS FACILITY NEW WING HOSPITAL PATIENTS OR SUBJECTS IN WV FLQW HAVE SPACE FOR OF SPECIAL DIETS EXCELLENT EQUIPMENT FOR PREPARATION OCCUPIED PHYSICIANS CLINIC UND VICE RESEARCH THE AT THE HOSPITAL THE ELI SCIENCES LABORATORY FOR CLINICAL WHICH IS AFFILIATED WITH THE FROM HOSPITAL IS ABOUT TWO MILES TODAY INTEREST SQ114FE SCHOOL OF MODICINE UNIVERSITY MAIN OF FIELDS 69100 OCELIPIES INDIANA THE CVERAI IN RESEARCH OF ACIIDEINY FHE ESCROW UNTIL THEY ARE PAROLED WAYS OF WE HAVE ALL STAFF ST TO CHRONIC OF II ALL TOXIEOLOEY DISTRIBTITION EVALUATIOLI CAN HE ADJC NOW SCM CAUSED TO ISE CHANGES OL DRUG OF STUDIE THESE TO SLIT HAVE WITH ART THEITI AFTER ML KOLILSTAEDT AT THE HOSPITAL FOR CLINICAL CRY WITH IFIHIATED TWO MILES LINK THE WE HAVE FROM 196R CONDUCT THE CLINIE BEEN NICKNAMED THE WE ELECTRONIC LABORATORIES GRAPHY FIG ISOTOPE NT THE UNIT IEDICINE ALMOST OR EFFECT CRANS OF ALL OF THE IN OR OF ADDITION IN THE OUR SUBJECT BEEN HELPFUL VOLUNTEERED LY IS EXPLAINED INLY APPROVED TO THE SINCE LILLY THEY NYC TO ESCAPE CONIPLETE AN FUNCTION THE IT IR CLINICAL FORM OUR TELY OW WORDS NDENT MIGHT OF DURING THE THEIR FOR EXERCISE LOSPITAL ARE THE PAROLED URRANGEN TO ITS THERE MILD IS AMPLE AND THE AT MAKE TO OPPORTUNITY HYPERTENSION SAME TIME OF OBSERVATION OBTAIN EFLECTIVENESS AN OF ITS INFORMATION CLINICS SUCH AS DIABETIC EARDIOVASCULAR AND PASEROENTEROLOGICAR CONDUCTED BY LILLY PHYSICIANS IN MARION COUNTY GENERAL HOSPITAL THE OUTPATIENT AREA AND IN THE RESEARCH UNIT THUS IN THEY ONES BOTH COLLECT GROUP HAD TREATMENT AND WE HAVE EFFICIENCY ADDITION TO DETERMINING DOSE IT IS OFTEN POSSIBLE TO INVESTIGATE METABOLISM OF THE NEW DRUG IN THE COURSE OF THE INIHAT STUDY METHODS FOR MEASURING COOCCUSRATION OF THE DRAG SLID ITS MNETABOLITES USUALLY WILL HAVE BEEN DEVELOPED IN THE COURSE OF THE STUDIES IN EXPERIRRRCRJTAL ANIMALS OFTEN THEY WILL BE APPLICAHLE TO HUNARI SUBJECTS DURING PHASE THERE IS INCREASING RECOGNITION OF TILE NEED TO ESTABLISH THE METALOLIC PATH WAYS OF NEW DRAG AS SOON AS POSSIBLE IN TIRE COURSE OF CLINICAL TRIAL AS WE HAVE STARED THIS WILL BE IN HELPFUL SELECTING SPECIES OF ANIMALS FOR LONGTERM CHRONIC TOXICITY STUDIES RAR THE ALL STAFF OF THE ALL EVALUATION DATA FROM THE INFORMATION THAT AND DATA DISTRIBUTION TO OF INITIAL IS NOW US STUDIES KNOWN WILL INVESTIGATORS THE TO LET CLINICAT CLINICAL CAN BE ADDED INFORMED THAT TO IS PROTOCOL PROSPECTIVE SPECIAL COMMITTEE WHICH INCLUDES MEMBERS IN THE DEPARTMENTS OF MEDICINE AND PHARMACOLOGY AS WELL AS SENIOR MEMBERS OF TH COMPANYS CLINICAL RESEARCH SALT CAREFULLY REVIEWS EACH PROTOCOL PRIOR TO EVERY PROPOSED CLINICAL TRIAL AS YOU ARE WELL AWARE THE INITIAL TRIAL OF NEW DRUG ALWAYS ENTAILS SOME RITK TO THE SUBJECT WC HAVE MADE RTLAXIMSLNI EFFORT TO RCDTCE THIS TO MININSURN THE CLINICAL PHARMACOLOGIST MUST DEVOTE TIME AND EFFORT TO THESE PROGRAMS PERSONAL ATTENTION IS AND RESPONSIBILITY ESSENTIAL CANNOT BE DELEGATED WELL TRAINED COMPETENT GRADUATE NURSE IS INDISPENSABLE FOR MAXIMUM PROVIDES PATION OVER WITH CAREFULLY DOCUMENTED RECORDS OF THEIR DISEASE NO TROUBLE ATTRACTING THESE PATIENTS AS VOLUNTEERS FOLLOWING THEIR OBSERVATION IN OUR CLINICS BEEN APPROVAL AND TRIM OF PATIENTS VOLUNTEER TERVAL WITH IN YOUNG BOARD OF MAY DRUG SAFETY IN PATIENTS ARC HAVE AN WHO HAVE OF ASE SPECIAL IVENESS HEALTHY THE YEARS EVALUATION ANTIHYPERTENSIVE AS RESEARCH TO TIAL THE WITH THIS IS AT 15 VISITOR 499 LFLDUSTRY THEIR FOUND THIS TO PANDED SO THAT WHICH INCLUDES LUOUS NUY HAVE INTERVIEW FOR BE FAR MORE SATISFACTORY THAN ATTEMPTING PROGRAM IN SHE PRISON THE LILLY RESEARCH UNIT HAS HSLFWNY HOUSE THE VOIONENER UBJECRS ARE ESPECIALLY HELPFUL IN THE CONDUCT OF INCREASINGLY IMPORTANT METABOLIC STUDIES OF NEW DRUGS SONIC INSTANCES THE PATIENTS WITH RELEVANT DISEAE WILL BE USED IN THE INITIAL PHASE OF CLINICAL TRIAL PROPRAN RATHER THAN NORMAL VOLUNTEERS FOR EXAMPLE FOR EVALUATION CI RELATIVELY TOXIC DRUG IN CANCER EHEMOTHERAPY WE WOULD RISE PATIENTS WITH ADVANCED DISEASE SIMILARLY IN PHYSICIANS IN THEY MAY ELSIPLOYCES SWDIES ORTIG WILL BE INCLRIDING REVIEWED BY THE RESEARCH PHARMACOLOGY LOOSELEAF NOTEBOOK FOR EHENRISTRY BE COMPILED INTO WHEN THEY EXPRESS AN DRUG AS THE INFORMATION IS ACCUMUILATED BOOK UNDER ABE PROPER SECTION ASSUME THAT WE HAVE EVIDENCE INTEREST IN ADDITIRNAL THIS FURTHER PAGES THAT THE NEW DRUG HAS NOT CAUSED SERIOUS SIDE EFFECTS IN SUBJECTS OR ABC WE HAVE FOSIND THE PATIENTS DRUG TO BE CALLABLE OF PRODUCING IN MAN THE SAME DESIRABLE PHARMACOLOGIC CHANGES OBSERVED IN ANIMALS WE ARE READY TO UNDERTAKE LIMITED NUMBER OF STUDIES TO DEMONSTRATE FURTHER EVIDENCE OF THERAPEUTIC EFFECTIVENESS FOR THESE STUDIES THE NO PLRYSIEIANMONITOR TO HAVE AN INTEREST WITH THEM AFTER THEY IN THE DISEASE MAY SELECT FOUR UNDER STUDY THE HAVE ALSO ACCUMULATED SOME EXPERIENCE OR LIVE DRUG WITH CLINICIANS KNOWN WOULD BE PLACED THE NEW SUBSTANCE NEW YORK ANNALS 500 SCIENCES OF ACADCMNY CHICAGO WITH WHO HAVE PAR HE CURNBHTED EFFORT OF THIS GROUP WOULD BE IN THC PREL INILNARY FTUDY TICIPATCD GUIDELIOCS AND FOR FURRHCR STUDIES AT THIS SEMINAR THE TO BEAR ON 4CSIGN BROUGHT THE CLINICAL TRIAL ESNPHA GROUND IULCS WOULD BE SPELLED OUT FOR THE NEXT PHASE OF SS POW WOULD BE PLACED ON THE KINDS OF TESTS AND THE NATURE OF THE OBSERVATIONS CONCERENCE WE WOULD SPONSOR REQUIRED TO ESTABLISH VITRO TESTING TIGUINSI STAGE DATA COLLECT SUCH AS OF CSRGANISMS DESIRABLE IS IT TO LIMIT TO THE SCOPE SEVERAL MAJOR CLAMS IN SHOWN TO HAVE ACTIVITY AND BOTH THE GRAMPOSITIVE SUPPORT ANTIBIOTIC AN TO NVMHER IT THIS ONLY TO EVALUATE PROGRAM MID UTTEFFIPT FOR EXAMPLE IF WE WERE LOCATION UND THE INVESTIGATORS STAFF AT ETLECTIVENESS OF THC IN CENTRAL IN RESEARCH OF THE LILLY REPRESENTATIVES IN THERE IS EVIDENCE AND IF FOLLOWING ORAL ADSRZNSTRATION TO TREAT THAT THE SUBSTANCE IS WELL ABSORBED WE WOULD FIRST PLAN TO LIMIT ITS USE TRACT AND INEPT OF INFECTIONS IN THE UPPER AND LOWER RESPIRATORY TRACTS URINARY TRIAL WE WOULD NOT EXPECT TO BE THUS AT THIS STAGE IN THE CLINICAL SOFT TISSUES GRAMNEGATIVE CATEGORIES ABLE TO ESTABLISH FOR EFFECTIVENESS CLAIM IN DISEASES SUCH AS ENDO BACTERIAL ME TO GIVE ALL TO DATE THE PROMPTLY TO MI WAS OFTEN IMPE WERE RECEIVED SCALE CLINICAL THREE WEEKS HOWEVER WHEY HAVE FOLLOWING USE BETWEEN THE RESEARCH STALL OF AND THE INDUSTRY FORMS FOR CASE REPORTS THAT WOULD INCHTRLC THE OF DIAGNOSES RECOMMENDATION AND ESTABLISHMENT WE WOSILD PREPARE ALSO HAS IN PERFORM TO CS BY INDUST NECESSARY DRUGS PROGRAMS HOWEVER THE PARTICIPATION OF THE RESEARCH PLAN HAS MADE THE USC OF PRESENTS OF SEVERAL INVESTIGATORS STANDARD JOIN TO THE DATAPROCESSING FORMS REPORT IN THE THE IRS DESIGN ACCEPTABLE TO OTHER INVESTIGATORS SECOND STAGE OF OUR CLINICAL WHEN THEY ALE INVITED TO TRIAL AND TBE DEVELOPMENT OF THE CLINICAL OF THE PRELIMINARY DEVELOP THE PHARINACETITICAL MASTER PLAN FOR THE SECOND PHASE OF THE EVALUATION SATISFACTORY MENT AND CONTROL LABORATORIES WILL BE EXPECTED TO HAVE ESTABLISHED FORMULATION AND SET UP SPECILICATIONIS FOR MAXIMUM ASSURING BOTTLE OF MEDICINE IN UNIFORMITY WILL BEAR DATE EACH TRIAL PERIOD THE AFTER WHICH THE MATERIAL SHOULD NOT BE USED IN THE CLINICAL MAXIMUM EXPIRATION DATE SHOULD BE NO MORE THAN SIX MONTHS WHEN MATERIAL IS CAN BE EXTENDED BY THE MANUFACTURER IF THERE HAS BEEN REASSAYED THE SLATING MATERIAL NO TO BE USED IN THE TRIAL CLINICAL WE UNIFORM POTENCY USING CLINICAL TRIAL AN APPARENTLY MINOR DETAIL SUEB AS ASICRONSA AND COMPOSITION IN OF DISTRIBUTION OF ACTIVE DRUG IN5 THE INGREDIENTS MAY IMPROVE THE UNIFORMITY VALUE TO EXPEND II IS OF LITTLE WHEN FILLED INTO CAPSULES OR IN FORMING TAHIETS MATERIAL CAREFULLY CONTROLLED OF CLINICAL TRIALS IF THERE IS ON CARRYING OUT VERY FORMS USED THE MANS IN THE COMPOSITION OF THE PBARMACEUIICAL STUDIES AND THE SUPPORTING FACTURER MAY SPEND LARGE SUMS ON SUPPORT FOR CLINICAL PREPARA RESEARCH BUT UNLESS ADEQUATE ATTENTION IS GIVEN TO THE PHARMACEUTICAL TION OF MATERIAL THE VARIATION IN RESULTS ARISING FROM THE DIFFERENCE IN MATERIAL GREAT EFFORT GREAT VARIATION DIFFERENCE OF OPINION AMONG INVESTIGATORS MAY BE RESPONSIBLE FOR EFFECTIVENESS OF THE NEW DRUG ALL OF THE INFORMATION REGARDING FOR CLINICAL TRIAL ARE SUBMITTED INVESTIGATIONAL AS THE AS WELL AS PLANS MATERIAL TO THE FDA NEW DRUG INVESTI AS PART OF THE FOR THE STUDY INCLUDING CONTINUING PROCESS REGARDING SATI BEEN THAT ALL REPORT FORMS OF UPDATING THE WAY AND CASE REPORTS ARE RECEIVED IS POSSI CAN OMOX TO DENY TESTS INDUSTRY TECH IN JN SONIC PERFORMED IN TIC ANALGESTO TOLOGY OFFICE PRACTICE TINDER IS PHASE ILL INVEST AND WE ROUST DL BE EMPLOYED MEDICINE IT OR ASKED IS AT CLINIC THE EACH TIME IS NOT TO IN IF BE ILTO REDUCE CAN TLT AW4 STUDIES SYMPTOMS BIAS SOMETIMES DITTO INADVERTENTLY NIT USED BEING CON SIDE RA CONTROL TABLETS BE IT PREAL OPINION WILL IT HAS TO VARIATION THE SPECIFICATIONS APPLICATION GETS TINDER HAS PATIENT CHANGE IN POTENCY MUST EMPHASIZE THE IMPORTANCE SIGNIFICANT FDA STUDIES IN DURING THE TIME TECHNIC CAUSE THE PROGRAM TRIAL TE LABORATORY ERROR IN NOT LEND THEMSELVES PROLIFC SUMNA PROVIDE NEEDED FOR DOSAGE PROPOSED STUDY ALSO WOULD BE PROGRATTMED FOR DATA PROCESSING AND HAS BEEN THE NECESSITY TO USE REPORT FONRIS HAS CREATED SOME IRRITATION FORMERLY IT WAS CUSTOMARY TO PERMIT EACH PROBLEM WITH SONIC INVESTIGATORS TIARA COLLECTED IN THIS MANNER DID TO REPORT HIS DATA US LIE WISHED INVESTIGATOR DATA OF WHEN THE NEW DRUT ACCURACY THE CONFERENCE THIS SEVERAL INVESTIGATORS ACCEPTED BY OR OSTEOMYCLITIS EARDITIS III RATHER OR CO AN ACTL BETWEEN ACTISC KOHLSTAEDT CHICAGO WITH NE WHO HAVE PAR ROUP WOULD BE TO THE SCOPE MAJOR CLAIMS TI AVE ACTIVITY AND SERE IS EVIDENCE TS USE TO TREAT AND BE TRACT NARY TO ST BACTERIAL ENDO AND DUSTRY THE WOULD INCLUDE LIAGNOSES RAND HAS BEEN LO PERMIT SE EACH MANNER DID HIS PARTICIPATION JADE THE USE OF ARE INVITED TO INVESTIG OCCURRENCE REPORTS OF SCALE CLINICAL THREE WEEKS TRIAL HAVE ACCEPTED DEVELOP SATISFACTORY IN UNIFORNSITY GILL BEAR DATE ML PERIOD THE WHEN MATERIAL THERE HAS AIFORM AS OF BEEN POTENCY MIERONIZ ACTIVE ILTIE TO LALS IF DRUG EXPEND THERE RD THE IS MANU THE SUPPORTING UTICAL PREPARA SEE MATERIAL IN REGARDING THE SPECIFICATIONS REPORT FORMS UPDATING VED IT THE TO INTERVALS EXPERIENCE THE USE OF ALSO ON RESULTS CAN HE OF TH STUDY COMMUNIC DATAPROCESSING EQUIPMENT CLINICAL TRIAL UNTIL ALL THE IT REPORTS BY THE PHYSIEIANRNONITOR TODAY EVEN IN LARGE PROGRAM WE ARE ABLE TO HAVE PRINTOUT OF ALL THE DATA EVEJY FEW INVESTIGATORS HAVE OBJECTED THE OF THE TASK OF REPORTING TH SYSTEM EACH CASE TO ARE AS PREPARING DETAILED MADE KNOWN THE TO REPORTS THEM THEY SUNN CLINICAL UTICA FREQ ANY ADVERSE SOI INDUSTRY TREATMENT IS COMPLETED BY USE OF DATAPROCESSING RNETHODS WE CAN ASCERTAIN WITH CONSIDERABLE ACCURACY WHEN WE HAVE ACCUMULATED SUFFICIENT DATA TO UNDERTAKE OF PREPARATION THE NEW LRUG APPLICATION THE WORK ENTAILED IN PREPARATION OF THIS DOCUMENT ALSO HAS PROLIFERATED THE MANUFACTURER IS EXPECTED TO ASSEMBLE ALL DATA AND PROVIDE OF EACH SECTION OF THE APPLICATION ANY AHUORINALITIES FOUND IN LABORATORY TESTS MUST BE ISOLATED AND ATTENTION CALLED LO THEM THE PERFORMAN OF LABORATORY TESTS OF CERTAIN ORGAN FUNCTIONS WHICH ARE NECESSARY TO ESTABLISH UAFETY PRESENTS MAJOR PROBLEM FOR EVALUATION OF NEW DRUGS BY INDUSTRY IF LABORATORY PERFORMS TESTS IN CARELESS FASHION OR IF AN ERROR IN TECHNIC OCCURS DATA WILL APPEAR IN THE NEW DRUG APPLICATION THAT CAUSE THE FDA TO CONSIDER MAY THE APPLICATION AND REQUEST ADDITIONAL INCOINPLETE STUDIES SATISFACTORY SOLUTION TO THIS PROBLEM DOES NOT EXIST ONE PROPOSAL HAS BEETS ITS HAVE THE SPECIMENS SHIPPED BY AIR MAIL TO CENTRAL LABORATORY SO THAT AP TESTS CAN BE PERFORMED IN UNIFORM MANNER OBVIOUSLY THIS PROGRAM PRESENTS MANY DIFFICULTIES AND OBSTACLES ADDITIONAL EXPERIENCE MAY CNAL INDUSTRY TO DEVELOP PROCEDURE FOR OVERCOMING PROBLEMS SUCH AS THOSE DUE TO VARIATION IN TECHNIC IN IN LOPMCNT OF THE AT FOR AND TABULATED HOWEVER WHEN IN RNPOSITIVE THE WERE RECEIVED HE OBSERVATIONS LIMIT DATE ALL STUDIES THE STATUS OF EMPHA TRIAL GIVE PROMPTLY TO 311 INVESTIGATORS PRIOR WAS OFTEN IMPOSSIBLE TO KNOW AND GUIDELINES TO DRUG SONIC PERFORMED IN TRILOGY LABORATORIES SUFLICIENT HOSPITALS ANALGESICS BUT FOR OR DATA CAN BE OBTAINED FROM THE CLINICAL TRIAL ONSC DRUGS SUCH MATERIALS FOR OSE IN DERNIA ANY ANTIHYPERRESSAIV DRUGS THAT WILL ULTIMATELY BE USED IN ESSENTIAL TO HAVE PERIOD OF CLINIEAL TRIAL IN WHICH THC DRUG THIS TYPE OF STUDY HAS BEEN DESIGNATED AS PHASE LII INVESTIGATION OBVIOUSLY SHE USE OF THE DRUG CANNOT BE WELT CONTROLLED AND WE MUST DEPEND ON THE PATIENT TO FOLLOW INSTRUCTIONS ONE SAFEGUARD CAN BE EMPLOYCUI TO ASCERTAIN WHETHER THE PATIENT HAS TAKEN ALL OF THE MEDICINE PRESCRIBED SMALL EXCESS OF TABLETS OR CAPSULES IS PLACED IN BOTTLE AND THE PATIENT IS ASKED TO BRING THE CONTAINER OF THE MEDICINE TO THE PHYSICIANS OFFICE OR ELINIC AT THE NEXT VISIT THE NUMBER OF TABLETS OR CAPSULES IS CAREFULLY COUNTED EACH TIME IF DOSES HAVE BEEN MISSED TCO MANY TABLETS WILL BE JOFT THE IS NOT TO BE AWARE THAT HIS PATIENT IS COOPERATION BEING CHECKED EACH TIME IN STUDIES FOR EFFECTIVENESS ESPECIALLY WHEN THE ONLY CRITERION IS RELIEF OF SYMPTOMS THE DOUHLEBLINRS TECHNIE IS NREDED IN MANY INSTANCES THIS PROCEDURE CAN REDUCE BIAS IT SHOULD HE NOTED HOWEVER THAT DESPITE OUR BEST EFFORT IT IS SOMETIJUSES DITLIEULT TO BE SUIRE THAT NEITHER THE PATIENT NOR THE PHYSICIAN HAS BEEN NSADE AWARE OF INADVERTENTLY WHEN PLACEBO OR WHCN THE ACTIVE MEDICINE IS BEING USED OFFICE IS PRACTICE USED IT UNDER THESE CONDITIONS CONSIDERABLE CONTROVERSY HAS SURROUNDED THE USE OF THE PLACEBO IN OUR GREAT DEAL OF USEFUL INTORRNATION CAUS BE OBTAINED IF WE USE CONTROL RATHER THAN POSITIVE BLANK ONE TECHNIC IS TO PROVIDE THE PATIENTS TABLETS OR WITH TWO CAPSULES FOR EACH DOSE THEY NEED NOT BE SIMILAR IN APPEARANCE ONE WILL HE AN ACTIVE DRUG AND THE SECOND WILL BE PLACEBO BUS WE CAN ALTERNATE BETWEEN ACTIVE DRUGS WITHOUT THE PATIENT OR PHYSICIANS BEING AWARE OF THE OPINION RR CO ANNALS 502 CHANGE THAT ARE UNLIKE IT IS PLACEBO IN ADVISABLE HAVE TO THIS DRUG EFFECTS WE HOPE THAT IF FOR STUDIES CONDUCTED AEENRDIO POSSIBLE IT THEIR PREPARATIONS DRUG MARKETED PREPARATIONS TO COMPARE TWO DOUBLEBLIND TECHNIC AND STILL EMPLOY AND TWO THE 5C OF TWO ACTIVE DRUGS LAPSE BETWEEN OF THE ERIOD WASHOUT PROCEDURE PROVIDES FOR MAKES TECHNIC THIS OF SCIENCES NEW YORK ACADEMY TO THE DRUG EVALUATION PLAN WITH ARE CAREFULLY ASSURALKE OF HIGH DCIGNCD AND THEN OF MATERIALS QUALITY BE SHORTENED TRIAL MAY OF THE CLINICAL DURATION EMPLOYED PERHAPS THE WE ARE OF THE ORINION THAT ON DRUG EVALUATION TRAINED LARGE 50MM ARE BEING SPENT NUMBER OF ADEQUATELY THE INCREASE PROBLEM IS TO OUR MOST PRC5SIFL INDIVIDUALS BECOMES OF THC WHEN GREATER NUMBER CLINICAL PHARMACOLOKTISTS HE POSSIBLE IT WILL AVAILABLE TO IMPROVE THE FFIEIENCY OF THE INDUSTRY IN THE IT PMOBRBI IN FOCTIS FACLGATHERINP TO DRSTGTCIAL IS CJII THE PROGRAMS AND LEGAL BELIEVE DEMAND FOR KY IIRP‰ REGULATIONS TO IHC THE SOURCES NIH JIM SUPPC DEMIC INSTITO TIC THAT HAD BEEN CY THE PROXIRUILY WERE SUDDENLY WITH ECLUMILIL BEFORE FOR PHARIN IK IMPLICATIUOS AND WERE RICA IIOFLL RELATIVELY HA TESTS TOMEITY JUTO THE ARRANGING OR BILITY FOR WILL WAS NECESSARY TO BE DONE SOT TO SATISFY LUTORY TB AGENCY HAD ELAPSED EQ GETICRALLY FORMERLY SIN THE ITO PAC TAPE ABOUT AND TIONSHIP PEW DRUG REQ ON THE CI LESSLY OR CR111 DCVELOPTLWTT AS FOUND TBC TIMES WLSAT AS BE WERE SIMPLY TODAY BY EW WVX HR 2R TH CO TABLE OF CONTENTS PAGE TABLE OF AUTHORITIES STATEMENT OF ISSUES INTRODUCTORY FACTS RELEVANT PRESENTED STATEMENT TO ISSUES PRESENTED ARGUMENT CONCLUSION ADDENDUM 11 CONTAINING RELEVANT STATUTORY PROVISIONS 12 TABLE OF AUTHORITIES CO C4 PAGE CASES VGUNN FURNITURE CO 79 SUPP CO MINK PARKE DAVIS MICH COURT OF NO 26D4 NOV 21 1966 XPPEAIS LEAVE TO APPEAL DENIED 379 MICA 773 CERT DENIED 392 US 934 1968 OT JUSTICES WE 334 OPINION 95 SHENANDOAH LIME 80 SE 753 CO 211 MASS 1967 10 605 GOVERNOR 115 VA 865 CONSTTTUTIONS STATES UNITED THIRTEENTH AMENDMENT FOURTEENTH ANENDMENT STATUTES MICHIGAN 1935 PA 210 MCLA 800JOI ET SEQ 1953 PA 232 MOLA 791201 ET SEQ 1968 PA 15 MCLA 800321 ET SEQ MISCELLANEOUS 4I OAG AM JUR 194142 PRISONS NO 21939 PRISONERS 903 443 II STATE DID THE FOR SU1V24ARY HAVE 01 DISTRICT COURT ERR JUIJGMENT NO STANDING CONVICTS ISSUES WITHIN THE DISTRICT THE APPELLANTS THE APPELLEES ON THE TO RECOVER THE CONFINES COURT ANSWERED SAY SAY II II PRESENTED FOR REVIEW IN ORANTINO GROUWD THAT DEFENDANTS MOTION THE PLAINTIFFS WAGES FOR WORK PERFORMED AS OF STATE PRISON STATES UNITED FOR THE COURT SIXTH OF APPEALS CIRCUIT CO LII NO 711170 SIMS RICHARD ALLEN FRANK ROGERS BILLY LEE WALTER LEE BOYD SLAGER PETER GEORGE MILLS LEE WAIFLR CLEMONT DEDEAUX ORNEILL VILBURN WILLIAM FREFL HOLNACWL CLEARY HERBERT WILLIAMS BENNY SPELLS ORCEAN DAVIS JERRY INMAN RAYMOND BAILEY THOMAS MACK BOYD LORD RALPH WATSON CHESTER PHILLIP VERNON RALPH SAWICKI MCGHEE 4EVIS PAUL ROSS HERMAN UZAD GERALD WARNER RONALD LONNIE PAYNE NORMAN PAUL MILLER THOMAS MULLIGAN ROBERT MASON GAYLORD ESPICH AND MARSHALL CALVIN WILLIAMS PLAINTIFTH CO APPELLANTS CO DAVIS MTCHT CORPORATION THE UPJOHN DELAWARE CORPORATION DEPARTMENT OF CORRECTIONS OF THE STATE OF MICHIGAN ELEANOR HUIZEL JAMES WADSWORTH ERNEST BROOKS MAX ETHER PARLEY JOHN RICE DUAFLE WATERS FLORENCE CRANE JOSEPH ROBERT GROSS COTTON AND GUS HARRISON PARFL CS DEFENDANTSAPPELLEES APPEAL FROM THE DISTRICT COURT FOR THE EASTERN DISTRICT OF TEE UNITED OF MICHIGAN SOUTHERN DIVISION BRIEF FOR ATTORNEY GENERAL OF THE STATE OF MICHIGAN STATES STATEMENT INTRODTJCIYORY THIS OF MICHIGAN BRIEF ON BEHALF BY ORDER OF THE THESE DEFENDANTS TEN MICHIGAN CORRECTIONS IT OF THE THE ADEQUATELY STATE THAT OF THE COMPANY THE CONTAINED IN MEMBERS AS IN THEIR TN PARTICULAR OF THE OF THE OFFICIAL STATE AS PARTIES STATE OF MICHIGAN DIRECTOR OF THE DEPARTMENT THE HAVE WILL THIS ONLY ISSUE RAISED IS BY APPELLEES BRIEFS FIVE ADDRESS OR CAPACITIES THE IN FOURTH BECAUSE AS THEIR ISSUE BRIEF AND DISPOSITIVE THE OTHER COMPANY HEREBY ADOPTS AND PARKE BUT BECAUSE OF ISSUES UPJOHN COWPANY AND PARKE THEREFORE OF UPJOHN ISSUES CONTROLLING AND ALSO ATTORNEY GENERAL THE 1969 THE OFF OF MICHIGAN APPELLANTS ADDRESSED IS OF CORRECTIONS WHO SERVED AND WHO WERE ADDED ON NOVEMBER DEPARTMENT OR WHOM ACTED GENERAL BELIEVED CLAIM THE ATTORNEY GENERAL DEFENDANTS JUDGE APPELLANTS ATTORNEY IS DISTRICT ARE BY THE OF THE INDIVIDUALS ALL THE THE FILED COMMISSION CORRECTIONS OFFICERS IS THE DAVIS ARE DAVIS ARGUMENTS COMPANY FACTS RELEVANT TO THE ISSUES PRESENTED FOR REVIEW PLAINTIFFS THE STATE THE STATE OF MICHIGAN MCLA 791201 1953 PA MICHIGAN SEQ ET 232 TO APPOINT DIRECTOR OFFICER ADMINISTRATIVE COMMISSION FOR COMMISSION BY STATUTE THE SECTION IN OF THE EXERCISE AND IS 210 BUILDINGS MACHINERY BE NECESSARY TO PROVIDE FOR THE SECTION OF PRISONERS SISTENT MENT AND CONFINED AS IN WITH THE PENAL WITH THE PUBLIC 210 FULLY AS PT IS THE DUTY FOR PRACTICABLE OF THIS TO THE AUTHORIZES OF THIS IMPOSES CHIEF TO THE STATE OF AND ERECT EQUIP WHICH MAY AND EQUIPMENT AND REFORMATORY PURPOSES ECONOMY QUALIFIED USE PURCHASE BOILERS THE PRISONS OF IS ASSIGNED EMPLOYMENT OF PRISON PA 232 PA RESPONSIBLE 800301 OR PENAL INSTITUTIONS OF 1935 TO PROVIDE COMMISSION MOLA COMMISSION JURIS THE WHO OF CORRECTIONS IN THIS EMPOWERED BY SECTION COMMISSION PA LAWS AT TERMS 1953 DIRECTOR AND MAINTAIN PRISONS UNDER IS THE STATE STATE MICHIGAN OR POWERS AND DUTIES OF 1935 PRISON JACKSON CORRECTIONS IS THE PRISON PENOLOGY EMPOWERS THE SEVERAL OF COMMISSION THE AT UNDER TO SERVE PRISONS DEPARTMENT AND EXPERIENCE BY TRAINING OF CRIMES AND WERE SENTENCED WELL AS OTHER STATE AS OF THE CONVICTED DULY OF SOUTHERN MICHIGAN PRISON INSTITUTION DICTION WERE LABOR IN THE STATE UPON THE PRISON THE IN EMPLOYMENT TASKS THEIR CON IMPRISON PROHIBITIONS ON THE USE OF PRISON LABOR ARE IMPOSED BY CO SECTION OF HIBITIONS CONTAINED THEREIN EFFECTIVE APRIL WAS REPEALED ACT THE WAS AND PASSED TO AND EQUIPMENT OF INMATE ALSO LABOR WITH CERTAIN 1968 NEW ACT 1968 NEW ACT CONTINUED COMMISSION ACT PA 210 1935 USE 15 PA THE CORRECTIONAL MOLA 800321 SEQ ET DUTIES MAINTAIN PRO PRISON INDUSTRIES 1935 THE POWERS AND AND EQUIP THE KNOWN AS FROM THESE EXEMPTIONS OF THE BUILDINGS ACT INDUSTRIES SECTION STATE OFF CORRECTIONS BOILERS MACHINERY WHICH MAY BE NECESSARY TO PROVIDE FOR THE EMPLOYMENT LABOR SECTION CONTAINS OF PRISON OF 1968 PROVISIONS INMATES PA L5 REGULATING SECTION THE MOLA 800324 SALE OF PRODUCTS THEREOF IN PERTINENT THE NEW AND PART PROVIDES NOTHING IN THIS ACT SHALL BE DEEMED TO PROHIBIT OF ARTICLES MADE BY INMATES FOR THE PERSONAL BENEFIT OF THEMSELVES OR THEIR DEPENDENTS OR THE PAYMENT TO INMATES FOR PERSONAL SERVICES RENDERED IN THE PENAL INSTITUTIONS TO REGULATIONS SUBJECT APPROVED BY THE CORRECTIONS COMMISSION THE SALE SECTION THE MENT OF 1968 FORMER PRISON COMMISSION SHALL OF INMATES PURPOSES OF THEIR AT RETAIL PA INDUSTRIES PROVIDE IN TASKS IT 15 ACT PROVIDES AS FULLY CONSISTENT IMPRISONMENT SUPRA CONTINUING THAT THE AS PRACTICABLE WITH AND WITH THE PENAL THE PUBLIC THE POLICY OF CORRECTIONS FOR THE AND EMPLOY REHABILITATIVE ECONOMY IN 1963 NOVEMBER THE MICHIGAN OF CORRECTIONS DEPARTMENT CO ENTERED INTO WITH UPJOHN COMPANY AND PARKE AGREEMENTS PURSUANT TO WHICH THESE CLINICAL RESEARCH BUILDING AT JACKSON OF THE PROPERTY THE MICHIGAN THE EFFECTS UPON PARTIES IN CLINICS THE FACILITY TASKS THE CLINIC EVERY BY AND WITH PRISON ARE RECEIVED AND IN TESTS TO TASKS TO DETENNINE THE ARE BY PRISON HOURS THE LAUNDRY INMATES AN WHO THE IS OF OF INMATES TO WHICH MAKES ALSO THE PRISON HOSPITAL CONFINES OR THE MADE OF THE AT THE DIRECTOR BY PRISON POWER AND AUTHORITY FLILL AN INMATE OF THE REPAIRS PRISON COMMITTEE DET6RMINATION REQUEST ARE NOT TO PERFORM SERVICES TO BE WORKED BY INMATES OFFICIALS HARMFUL AND SPECIFIC PERFORMED WITHIN CLASSIFICATION GRANT AND MINOR WITHIN INVOLVES OPERATION COMMITTEE CONDUCTED AN INDEPENDENT PRISON BY INMATES FACILITY TO PRISON ASSIGNMENTS BY THE JACKSON ASSIGNMENTS CLASSIFI INDUSTRIES RESEARCH ARE BROUGHT THE THE RETAINED INMATEVOLUNTEERS MAINTENANCE OF ROOD IN INMATES AT PRISON BECAME DRUG COMPANIES CONNECTION WITH THE INCLUDE CLINICAL OF WHETHER TO RETAINED CLAIMS STATE AND POTENTIAL EFFICACY THESE FOR PARTICULAR REQUESTS OF TREATMENT OFFICIALS OF SUCH AS VARIOUS CONDUCTED FOR THE SERVICES ARE MADE BY INMATES CLINIC RESEARCH SERVICES ASSAGNMENT PRISON CLINICAL PREPARATION CONNECTED BUILDINGS FOR MATTER THESE THESE STRUCTURES THESE PERFORMED VARIOUS OF THE THE INMATEVOLUNTEERS THIS CONFINES AND OF DRUG PRODUCTS TESTING THE OF MICHIGAN CLINICAL THE WITHIN COMPANY TO CONSTRUCT WERE PERMITTED UPON COMPLETION STATE TO USE RIGHT COMPANIES DAVIS ON ANY ASSIGNMENT IS SUBJECT TO CALL AT ANY TIME BY INSTITUTIONAL ALL TO THE OTHER CLINICS INMATES REIMBURSE TO WORK IN WHO PERFORM SERVICES INMATES AND THE COMPENSATION THE THE COMPENSATION ARE PAID PURSUANT STATE OFFICIALS FOR CLINICS AMOUNTS PAID TO THOSE COMMENSURATE TQ AGREEMENT THE AT THE AMOUNT PAID RECEIVE WHO ARE ASSIGNED WITH HOWEVER PRISON THOSE THE TO INMATES PAID TO DRUG COMPANIES WHO ARE ASSIGNED ARGUMENT PLAINTIFFS TIYE NO STANDING HAVE OR QUANTUM MERRJIT MTNTMIJM BY THEM AS CONVICTS TO RECOVER WAGES FOR WITHIN STATUTORY WORK PERFORMED THE CONFINES OF STATE PRISON STATUTES MICHIGAN OF THE 210 CORRECTIONAL INMATES IN OR THEIR PURPOSES LABOR PERFORM NOT PRISON THE TRUE HELD OF THE IN 4I TREATMENT HAS IS IN BEEN OF THE PRISONER 753 AM JUR PENAL THE REQUIREMENT PRISONS THEIR KEEPING SAID THE BUT THE SENTENCE SUCH EXPENSE 605 HEALTH PRISONERS AS JUSTIFIABLE MEANS AND OF ENFORCING WELLBEING 98 334 NE TEACH FOR VIOLATION IS OF MAINTAINING CO OF 903 HIM IN OF CRIMINAL JUSTIFIABLE SUPPORT GOVERNOR EMPLOYMENT USEFUL HUMANITARIANISM EMPLOYMENT SHENANDOAH LIME THAT MAY BE UNCOMPENSATED WITH INTELLIGENT THAT AS HEALTH MASS INS PA REHABILITATIVE AND PRISONERS 211 TO CONSERVE AND AND 1935 OF PRISON EMPLOYMENT RECOGNIZED SERVICES OF JUSTICES SERVES MEANS OF DEFRAYING BO SR THE IS ENACTMENT 15 SUPRA PA THE OF MAINTAINING OF PERSONS UNDER ALSO 1968 FOR CONFINEMENT THOUGH QPJNION TRADE AND IT AND EVEN INMATE IN TO THE SUBSEQUENT THE PURPOSE OF PUNISHMENT DISCIPLINE IS WITH IMPRISONMENT WHILE PRISONERS THIS AS FOR ONLY PROVIDE CONSISTENT TASKS ACT INDUSTRIES SUPRA SPECIFICALLY AND PRIOR 115 THE LAW AS AND CUSTODY VA 86 AS STATED IT IN 4I AM JUR PRISONS 27 AND PRISONERS 903 THE REQUIREMENT OF LABOR IS REGARDED IN MANY WAYS VALUABLE ADDITION TO THE FORCES OF LAW AND ORDER TTS IMPOSITION IS NEITHER CRUEL NOR UNUSUAL IT OPERATES WHEN RIGHTLY REGULATED AS MITIGATION RATHER THAN AN AGGRAVATION OF THE PUNISHMENT INVOLVED IN IMPRISONMENT AND IS NOT OF ITSELF DISGRACEFUL OR DEGRADING BUT ON THE CONTRARY IS BENEFICIAL AND AS HUMANE THUS FOR SERVICES PERFORMED HURNAHITARIAN HAS ITS VISIONS PRIVILEGE ARE MADE BY THE STATE BETWEEN STATE 79 SUPP 110 THE STATE AND AS VE LOST THEIR 1948 RIGHT TO LIBERTY OF ANY THE NOT FACT BE USED TO THE IN CONVICTION AND THE AN ADDITIONAL WHICH THAT OF PRO THE EMPLOYER GUNN FURNITURE INMATES OF RIGHT SUCH STATUS TURN IN TO ELEVATE HUNTLEY OF PRISON THIRTEENTH PERMISSIBLE ARGUE THAT REQUIREMENT THAT OF THEIR PUNISHMENT AS REWARD INMATES TO BELONGS CRIME TO THE THEY FRUITS OF LABOR VIOLATION THE SERVES AND OUT LABOR OF THEIR ALTHOUGH APPELLANTS INMATES WHICH AND PRISONER THE RESULT TO COMPENSATE BUT SHOULD AS POINTED RELATIONSHIP STATE DIGNITY EFFECT OWN REHABILITATIVE EMPLOYEE THEIR IS OF THE PURPOSE OF ADDING RELATIONSHIP GO WILLIN THE THIRTEENTH AMENDMENT CLEARLY FOR CRIME THIS FOR IMPOSITION THEY PERFORM SERVICES AND UPON PRISON CONSTITUTES FOURTEENTH AMENDMENT REGARDS WHICH AMENDMENT THE INVOLUNTARY PERSON HAS BEEN RIGHTS SERVITUDE DULY CONVICTED STATES NEITHER SLAVERY NOR INVOLUNTARY SERVITUDE 2SPPP AS FOR CRIME WHEREOF THE PARTY BEEN DULY CONVICTED SHALL EXIST WITHIN THE UNITED OR ANY PLACE SUBJECT TO THEIR JURISDICTION RUNI EMPHASIS ADDED AS IIII STATES BASE APPELLANTS THIS ENTITLED IS PRISONER ASSUMPTION LIMIT THE WITH USE THIS WAS ENACTED FROM ANY TO THE THAT PRISON LABOR ON THE USE OF PRISON THE IN IT IS ACT AND WAS NEVER THE ESTABLISHED HAS BEEN LABOR FOR IS CLEARLY IN WAS NEVER INTENDED BY FEDERAL SECTION THE 10 TO GIVE OF 1935 CLEAR FOR FOR LABOR PA IS 21939 BENEFIT COULD NOT WITH THE SERVICES AND CLEARLY DIVERSIFIED THE OR COMPETITION 11 01 INDICATE TO RECOVER BY PRISON PA THAT THE OF FREE WAGE PURPOSE 1968 AND SUITABLE INTERESTS INMATES MINIMUM RATHERITS SECTION PRISON OF PRISON CAUSE OF ACTION TO GOVERNMENT 210 WITHOUT THREATENING 443 CUTRATE PRICES AT THE MICHIGAN FROM POTENTIAL TO PROVIDE BARBERS COMPETITION THAT THE THEIR STATUTORY PROVISIONS STATUTES NO OF SUCH COMMUNITY RISE OR STATE FREE 194142 WOULD BE IN ENACTED VALUE HISTORY INSTITUTION OF THE LIMITATION STATUTORY INMATE SUFFER PERFORMED BY BY THAT WHICH LABOR WHICH MIGHT INDICATED OAG O17 DIFFICULTY OF PRISON LABOR OF THE PURPOSE THEREFORE QUITE TO PROTECT INMATES THE THUS IN USE SUPPORT THE PRODUCTS OR SERVICES SERVICES SHOPS REASONABLE BOTH OF THESE OF SUCH SUCH BARBER ESTABLISHED EITHER LABOR TO OFFICERS SAID HE INDUSTRIES IS STATE THIS SERVICES BECAUSE THIS OF FREE BENEFIT IN STATUTES PURPOSES ON THE ATTORNEY GENERAL RULED MICHIGAN RENDER THAT THE LIMITATION AND LABOR THAT THEORY OF MICHIGAN PROVISIONS FROM THE COMPETITION PROVISIONS THE FOR SOLELY OF HIS LABOR FOR CERTAIN OR PRISON IS ON THE ARGUMENTS FRUITS TO THE POINT LOGIC THEIR 15 PURPOSE EMPLOYMENT LABOR OR THIS DISCRETION INDUSTRY PRIVATE INTENT LEGISLATIVE BY SECTION OF CORRECTIONS DEPARTMENT OF THESE ON WITHIN CONSISTS MAINTAINING IN PERFORMING OTHER KINDS OF THE CONFINES ANY CONSTITUTIONAL THE WALLS AND IN FEEDING ARE NORMALLY WORK ACTIVITIES AND PRISONERS ON WITHIN CARRIED OF NO DEPRIVATION HAS BEEN OR STATUTORY RIGHT OR ANY PRISONER MADE THE DEPARTMENT FULFILLMENT THESE THERE BETWEEN BY THE MUCH OF THE ACTIVITY THAT SERVICES OF WORK THAT THUS IS THAT FULFILL OF CORRECTIONS PROGRAM ESTABLISHED DRUG COMPANIES JANITORIAL WHICH DEPARTMENT BE EMPHASIZED PRISON PRISON ARRANGEMENT THE MUST THE IN AND THE AXID IT OBJECTIVES ARE CARRIED OF THE 15 PA OF 2968 VESTED IS ACTIVITIES TO DETERMINE AT BY VIRTUE CORRECTIONS AND THE DRUG COMPANIES AS POINTED 21A APPELLANTS THE THAN IN OTHER THE THE PRISON BY INSTITUTIONAL ASSIGNMENTS THE RESEARCH INMATES RECREATIONAL IN 218A BY THE FACILITIES RECEIVE MORE FREEDOM AND AT TIMES GENERALLY ASSIGNMENTS AUTHORITIES JUDGE DEMONSTRATE CLINICS ENJOY DISTRICT IN THE THAT THE CONTAINED INMATES SOMEWHAT HIGHER HAVE BETTER TO THE AVAILABLE FOOD THAN CLINICS PLAINTIFFS FOR APPENDIX UNCONTROVERTED STATEMENTS OF WARDEN KROPP AFFIDAVIT SERVICES OUT IN PERFORMING DAILY RATES BETTER OTHER ARE SAME MANNER AS OTHER INMATES TREATED WORK DESPITE BETWEEN BE IN LII THE DEPARTMENT VIOTHTION ALLOW THE OF THIS WOULD PROVIDE SUITABLE ARE IS NO DOUBT BELIEF 42 OF THE IT WAS CARRYING OUT ITS IN ESTABLISHING THIS AND THE COUNSEL APPLICABLE THE CASE OF MINK NOV 21 ARRANGEMENT ACTION MICHIGAN 392 IN IS STATED ARGUMENTS IN THIS THAT THE STATUTES FOOTNOTE THROUGHOUT ALL CASE NEVER ONCE HAVE IS DENIED 379 WHICH AN INMATE THE THE AND LAWFUL UNDER COURT OF APPEALS TO APPEAL AND DUTIES MICH LEAVE ILLEGAL THE SAME FOOTNOTE 1966 DECLARED IN THERE THIS COMPANY IN AND YET DAVIS C1968 THAT AND CRITERIA AND IN ARRANGEMENT PARKE US 934 AN ARRANGEMENT POLICY STATUTORY PROGRAM WOULD SEEM AN ARRANGEMENT THESE GOOD FAITH MAY BY THE DIVERSIFIED STATE IT ASSERTED SUCH AND BY PUBLIC THAT THE DENIED OF THE ACTED BRIEF THAT CONCEDED INTO REGULAR THE OF APPELLANTS DEFENDANTS CERT WITH ADEQUATE ARRANGEMENT STATUTE TO ENTER BELIEVED DEPARTMENT NOT OF THE INTERPRETATION LEGISLATURE THE DRUG COMPANIES IS POINT THAT PLEADINGS NO 2684 TE THAT AND THE THIS FOR PRISONERS BY RESPONSIBILITIES ON PAGE LAW HONESTLY PRISONERS EMPLOYMENT EFFECT OF CORRECTIONS WHERE IT ESTABLISHED CULL FAIR DEPARTMENT NATURE TO THE OF CORRECTIONS OT MICHIGAN QENERAL ATTORNEY TO SUGGESTIONS COURT MICH SOUGHT OF APPEALS CITES 1967 773 TO HAVE DISCUSSED THIS THE STATING IT IS ORDERED THAT THE COMPLAINT BE AND THE SAME HEREBY DENIED FOR LACK OF MERITORIOUS GROUNDS FOR THE RELICT SOUGHT IS APPELLEES NENT DOES NOT VIOLATE THEREFORE APPLICABLE DO TAKE THE MICHIGAN 10 POSITION STATUTES THAT TH ARRANGE CONCLUSION SUMMARY IT IN UPON THE IMPOSED DIRECTOR THE IN TO PERMIT WITHIN THE CONFINES OR THE TO ENGAGE IN AND HAS PRISON AND AS MINIMUM NOR ARE THEY ENTITLED ON MERUIT STATE BY FEDERAL WAGE LAW FOR TO THE MAY NOT THE REASONABLE VALUE VALUE PRTHG R6BERT SOLICITOR 1971 EITHER STANDARD OF THEIR OF THEIR ACTS SERVICES SERVICES 4TTORNEY GENERAL TATE OF MI ATTORNEYS 11 HI AN LLK RENGOSKI GENERAL SOLOMON XFENENFE7LD ASSISTANT ATTORNEY 11 ENTITLED SUBMITTED FRANK JUNE IS IS BASIS RESPECTFULLY DATED TO PRISONER RECOVER LABOR HAS RESEARCH INMATES OF MICHIGAN FAIR PURPOSES CAINICAL CONVICTED THE PRISONERS WAGE ESTABLISHED MICHIGAN QUANTUM WORK THE EMPLOYMENT OF CORRECTIONS ASSI AS HAS AND ITS PENAL PROPER DRUG COMPANIES TO BE EMPLOYED THE MINIMUM WITH DEPARTMENT OF THE OF MICHIGAN AND SUITABLE EMPLOYMENT THE CLINICS OF HIS STATE OF CORRECTIONS CONSISTENT THE FRUITS THE DIVERSIFIED WITHIN PERFONN SERVICES TO THE THE THAT DEPARTMENT STATE SUCH AGREED CLEAR OF FINDING OR THE ESTABLISHING REQUIRED MICHIGAN DUTY FOR PRISONERS IS GENERAL FOR DEFENDONTSAPPELLEES 800291 CORRECTIONS LAW SOLITAR OF ONFINERNENT DULY SEE OF KEEPER SHALL HO THE IT DURING THE TIME VIEWS WITH THE IN THE HOUSE SI NY NUMED ANY ELERGYRNA CLERGYMAN ES OF THE IN ALL LIE YEAS THE FIRST SECTI FIRST IGLOUS SECTION IN CON OF THIS RELIGIOUS DENOMINA FACILITIES FOR INTER PROVIDED HOWEVER OR OTHER PERSONS THEIR IN PROFESSION AND ARE PASTORS CONGREGATION IN THIS STATE STANDING REGUL OR URSU OF SAID PRISON HAVING THE CO ITAL USE WORKHOUSE HOUSE OF CORRECTION II POOR OOD AND FIRST BE SATISFIED THAT SUCH CLERGYMEN ARE KEEPE AIM OR JAIL KEEPER OR OTHER PERSDN DUTY FIXED ACT TO GIVE FREE ACCESS TION MID TO FURNISH THAT MICHL 60 CR4 800292 TROL COMMENTARIES PRISONERS BASED ON TC GUS BELIE REV 643 1962 PRIO REVIEW HISTORICAL OF AN HTIRCH NOTE SOURCE PA1850 CL1871 NO 185 FIT MAY CL1897 18 CL1 CLL 929 8190 PRISON INDUSR PA1935 NO 2154 1832 17659 ACR 210 SIT SEPT ZI AN ACT TO PROVIDC FOR THE EMPLOYMENT OF PRIFLN LABOR IN THE INSTITUTIONS STATE USE OT OF THIS STATE TO ESTABLISH TO THE POWERS AND DUTIES OF THE PRISON PRISON INDUSTRIES COMMISSION THE GOVERNORAND OTHCR OFFICERS AND ENIPLOYCS IN RELA SY PENAL FOR THE ABOLITION OF CERTAIN EMPIOYE THERETO AND TO PROVIDE OF TO PROVIDE FOR THE REQUISITIONING ARID DISBURSEMENT POSITIONS PRISON PRODUCTS TO PROVIDE FOR THE SALE ANDOR PURCHASE OF TAM PRISON EQUIPMENT TO CREATE REVOLVING LUND AND OTHERWISE TION CA PROVIDE FOR THE DISPOSITION OF THE PROCEEDS ABD ACCOUNTING PROVIDE FOR PURCHASING THE SALE EXCHANGE OR OTHER DISTRIBUTION OF SAID PROCEDURES INDUSTRY TO TO PROHIBIT OF PRISON PRODUCTS MADE OR TRANSPORTED INTO THIS TO STATE EXCEPT AS HEREIN PROVIDED FOR THE REQUISITIONING PROVIDE ANDOR PURCHASE AND SUPPLY OF INSTITUTIONS AND PRISON PRODUCTS FOR USE OR CONSUMPTION BY CEVBIIU IN DEPARTMENTS AND TO TO PROVIDE FOR VIOLATIONS JICTAITIES REPEAL CERTAIN ACTS AND PARTS OF AEFS 5O OF THIS ACT 800301 PRISONS CO RH 800 301 PCO OF THE PRISON STATC ENACT OF MICHIGAN EMPLOYMENT OF INDNSTRLES MATERIALS AND EQUIPMENT STATE PRTSON DLRECVR OF PRISON LABOR INDUSTRY ASSISTANTS APPOINTMENT IS SEC THE STATE PRISON COMMISSION HEREBY AUTHORIZED AND AND MAINTAIN BUILDINGS MA EMPOWERED TO USE PURCHASE ERECT EQUIP WHICH BE BOILERS AND CHINCRY EQUIPMENT MAY NECESSARY TO PROVIDE FOR THE EMPLOYMENT OF PRISON LABOR IN THE SEVERAL STATE PRISONS OR OF IHIS STATE FOR THE MANUFACTURE OF GOODS WARES PENN INSTITUTIONS AND MEICHANDLSE TO PURCHASE NEW MATERIAL TO BE USED IN THE MANN OF SUCH FUCINIC OF GOODS WARES AND MERCHANDISE AND TO DISPOSE MANUFACTURED PIUDUCTS IN SUCH MANNER AS SHALL HAVE BEEN OR MAY BE OTHERWISE PROVIDED BY LAW AND IS HEREBY NUTHNRIZED AND EMPOW CITID MAINTAIN TITE BUILDINGS MACHINERY BOIL AND EQUIPMENT AND THE MANUFACTURE OF GOODS WARES AND MER CHANDISE IN THE MANNER NOWIN OPERATION AT THE TIME OF THE EFFECTIVE DATE OF THIS ACT RUE COMMISSION IS HEREBY AUTHORIZED TO APPOINT DIRECTOR OF PRISON INDUSTRY AND TO EMPLOY SUCH OTHER AGENTS AND ERED TO CONTINUE TO USE ERS ASSISTANTS AS MAY BE NECESSARY TO COITY OUT THE PURPOSE OF THIS ACT UUSTOTIC NOIS SOURCE PAISSS NO 210 EN 21 SEPT REFERENCES STATE DEPARTMENT OF CORRECTIONS 1E291 SEE REFERENCES LIBRARY IO2 CONVICTS CJSCONVJCTS NOTES IN OF INMATES PRISON OFFICIALS DECISIONS WHOWERE TO WORK RRNGNED BY IN OF PLANT UPON SHELL CASING PARTS PRISON INDUSTRIES TO PAY PRIS MICHIGAN ON INDUSTRIES FLSED SLIM PER CIY FOR TO SUCH WORK ASSIGNED EVERY INMATE YORE NET CMPLCIVCVS OF NONUFACLURER WITHIN WAGE AND HOUR PROVISIONS OF STINRLARDS FAIR LABOR ACT NUNTLEY CUNN FURNITURE SUPP 110 IT WAS THAT LEGAL CO OCLOIS AND CONSTITUTIONNL NIECHORSICAT TRADE HEREAFTER STATE PRISON AND ASSENT WHICH WERE FUR NISHED TO WAR DUPAZRTINCNT BY MANUFAC TURER WHICH HAD CONTRACTCD WITH THE STAMPING VISION 517 GENERAL PRISON BLIES CT SERV 79 PRO SHALL 551 THOSE FOR BE PRISON ARTICLES TAUGHT TO CONVICTS EXCEPT THE OF WHICH THE IN THE OF MAKING CHIEF SUPPLY THE CONSUMPTION OF THE COUNTRY IS STATES OR COUN IMPORTED FROM OTHER TRIES THE AGENT OF THE PRISON ALONE HAD POWER TO CLCCIDE WHAT TRADES ARE WITHIN THE PROHIBITION AND THE COURT RE FUSED TO CONTROL HIS DISCRETION BY MAN LNNUS STATE PEOPLE CR RLL TIUSSELL PRISON MICH 187 INSPECTORS 1856 EFORMATORY BAITER SHOP MAY NOT RENDER BARBER SHOP SCRVICE TO PUBLIC IN WITH BARBER COMPCTITION ESTABLISHED THAT SHOPS IN VICINITY OPATTYGEN NO 21939 P443 194112 COITRECTIONS 800301 800301A SHORT INDU CITED KNOWN AND MAY BE ACT SHALL BE THIS SEC TITLE AS THE PRISON ACT NOTE HISTORICAL SOURER PA 1935 NO LA ADDED BY LYND ELY APRIL 210 NO 215 20 L04 800302 BCEEIPT MONEYS SEC THE TIME CREDITED THIS DATE FUID RCVOLVIDG FUND FUND AT INDUSTRY COLLECTED BY ALL MONOYS ACCOUNT PRISON ANY STATE IN OF THE EFFECTIVE TO GENCRAL ACT AND GOODS WARES AND MERCHANDISE IN ACCORDANCE INANUFACTURED BY PRISON LABOR OP HEREAFTER HERETOFORE OVER TO THE TURNED FORTHWITH OF THIS ACT SHALL BE WITH TIM PROVISIONS FUND THE GENERAL TO BE CREDITED TREASURER OF THE STATE OF MICHIGANTO PROVID LAW FOR BY OTHERWISE PROVIDED NND SHILL BE PAID OUT ONLY AS TIME OF THE OF SAID MONEYS ON HAND AT THE OUT OF THAT ED HOWEVER FIRST MONEYS COLLECTED FROM DATE OF THIS NET OR OUT OF THE FECTIVE IS HEREBY CRC ULD MERCHANDISE THERE THE SALE OF SUCH GOODS WARES SOLELY FOR THE BE USED DOLLARS TO FUND OF 500000 REVOLVING ATED AND MA SUPPLIES EQUIPMENT PURCHASE OF HP BOR UNDER THE DIRECTION AND TERIALS TO BE USED IN SAID INDUSTRY SUCH REVOLV HIS SUCCESSOR OR AGENT PROVAL OF THE STATE PURCHASING THE STATE FROM THE FUND SHALIBE ING OR SALE OR DISPOSITION MAINTAINCD TIMES IN AT ALL THE STATE TREASURY NOT IN THE SALE OR DISPOSI DOLLARS AND ANY PROCEEDS FROM OF 500000 EXCESS OF SAID FUND IN OXCESR TION OF SUCH GOODS WARES AND YNEVCBNNDISC SHALL BE PAID VIDED FOR BY FUND OF THE STATE OUT OF THE GENERAL AS ITIDY BE PR LAW TIISIORLC SOURCO NO PA1935 ON1 EFF 210 SEPT NOTE 21 CROSS REFERENCES REVOLVING FUNDS SEE 12110 ROFERCNVC LIBRARY CONVICTS CJS LS NOTES REVOLVING PRISON INDUSTRIES PRISON REVOLVING MAY MISSION FUND IS NOT BE ERECTED 26 DOCISIONI FUND ARID VORIDNG CAPITAL USED IN PAY FOR BUILDING FOR OF CONVICLS BY 552 YEVK THOUGH COMMISSION TO ERECT HAD AUTHORITY BVILDING 343 L3 OPATTYGCFLL93 COZN SUCH NO TKDA RAG 305 PRISONS 800303 BONDS OF SEC THE DIRECTED MAY STATE THE HAVE TENNIS BOND PRISON INTO HIS OF AND AUTHOR5ZED COMMISSION AS MA MONEYS MACHINERY GOOD AND SUF TO REFERRED STALE THE IN MICHIGAH SUM PENAL UPON IHE FAITHFUL AND PROMPT MONEYS AND OTHER PROPERTY WHICH DO11NR CONDITIONED OVER ACCOUNTING FOR ANTI PAYING COME OF THE HEREIN PEOPLE OF THE NOT TO EXCEED 50000 SHALL CONTROL AND EQUIPMENT TO THE HEREBY IS OFFLRERS OR AGENTS OF NND POSSESSION SUPLJCS FICIENT COMMISSION OF SUCH TO REQUIRE OR AGENTS OFFICERS NIL CARRYING OUT THE IN POSSESSION PROVISIONS GF THIS ACT HISTORICAL NOTE SOURCE NO PA1935 800304 EFF 210 SEPT 21 DEFINITIONS THE TERM PRISON PRODUCTS AS USED IN THIS ACT SHALL BE CONSTRUED TO MEAN ALL GOODS WARES AND MERCHANDISE MANUFACTURED PRODUCED OR MINED WHOLLY OR IN PART AND EITHER WITHIN OR OUTSIDE OR PRISONERS OF THIS STATE BY CONVICTS OR PRISONERS EXCEPT CONVICTS OR IN ANY PENAL ANDOR REFORMATORY INSTLTU ON PAROLE OR PROBATION MANUFACTURED IN FEDERAL PENAL AND CORREC TION EXCEPT COMMODITIES SEE TIONAL FOR USE BY THE INSTITUTIONS FEDERAL THE TERM PRISONS OF THIS STNT STATE PRISON AT JACKSON THE BRANCH STATE REFORMATORY THE THE STATE 1K CONSTRUED TO MEAN THE AT MARQUETTE AND THE PNISO AT JONIA RIND AUTHORITY GOVERNMENT SHALL DUTIES HEREIN VESTED IN THE PRISON COMMISSION PURCHASING AGENT OR HIS SUCCESSOR SHALL BE CONSTRUED AN RCSPECIS TO THE CONTROL AND SUPEIVISF ON OF THE GOV STATE OR IN AS SUBJECT IN ERNOR LJ NOTE SOIREE PA1935 NO FLY 210 SEPT LIBRARY CIS 800305 MLP LABOR FROM AND SHALL CHANGE STOCK SALE OF PRISON PRODUCTS EXCEPTIONS PRISON ON FARMS AFTER BE UNLAWFUL TO SELL OR ANY RAISED CONVICTS AND PRISONS 26 UNLAWFUL SEC IT REFERENCES 12 CONVICK CONVICTS TO PURCHASE ON THE SEVERAL 60 DAYS AFTER OR EXCHANGE PRISON PRISON 553 THIS ACT SHALL OR TO OILER FOR BECOME LAW SALE OR CX PRODUCTS EXCEPT PURE BRED LIVE FARMS AND SOLD FOR BREEDING PM II RSOO CORRECTIONS OTHERWISE POSES ANDOR TABLE OF THIS 2FLCFLTS THAT OR CONSUMPTION USE FOR OTHOR CUSTODIAL INSTITUTIONS OR THIS OR POLITIAO STATE GOVERNMENT OI AGENCIES IN THIS ACT NOR SHALL IN THE CHARI PENAL OR FOR DCPNRT OR THE FEDERAL STATE IIIMEOF THEREOF OR OTHERWISE AS SPECIFICAIIY PROVIDED THE LABOR OF PRISONERS LX SOLD HIRED LEASED LOANED CONTRACTED FOR OR OTHERWISE USED FOR PRIVATE OR CORPORATE PROFIT MAINTENANCE OR OP OR FOR ANY OTHER PURPOSE THAN THE EONSTVUETIORL ERATION THIS THE OF BY THE GOV AS DIRECTED COUNTY OR OF OF SAID WORKS WAYS OR PROPERTY PUBLIC MAY TO CITY USED OR CITY COUNTY AS AUTHORITY THEREOF PROVIDED THAT NOTHING SHALL BE DEEMED TO PROHIBIT THE SALE AT RETAIL OF ARTICLES BY THE NET CONSTITUTED MNDE FOR THE PRISONERS PENDENTS OR THE PAYMENT IN NR PROPERTY THE PRISONERS THRTL EXCEPT DIRECTED IN WORKS WAYS OF PUBLIC ERNOR ON THE INSTITUTION PENAL OF THEMSELVES OR THEIR BENEFIT PERSONAL TO PRISONERS FOR PERSONAL SERVICES TO REGULATIONS SUBJECT DE RENDERED BY THE PRISON TWINE COMMISSION OR THE MANUFACTURE SALE OR PURCHASE OF BINDER ROPE AND CORDAGE USED IN AGRICULTURAL PRODUCTION OR TO THE USE OF LABOR UPON AGRICULTURAL LAND WHICH HAS BEEI RENTED OR EASED PRISON SHARE CROPPING OR OTHER BY THE DEPARTMENT OF CORRECTIONS UPON BASIS PROVIDED THAT IN NO CASE SHALL ANY PIISOII PRODUCTS BE SOLD OR OFFERED FOR SALE AT HEAT AS AMENDED SELLING LIGHT BELOW COST OF PRODUCTION VHICH PRICE PRODUCTION SHALL INCLUDE AND LABOR SUPERVISION EXPENSES CONNECTED THEREWITH MATERIALS POWER AND ALL OTHER NO 42 PA1950 COST OF DISTRIBUTION LMD EFF HISTORICAL MMCLI 28 NOTE SOURCE IA1935 TA1937 NO NO NO PA1943 RALP15 NO FTP SEPT 21 210 95 IMD EW JUNE 21 299 HAD ELF JULY 2S NO 215 LMD EL APRIL 20 107 L3 CONVICTS CONVICTS CI5 LMD EFF APRIL MLP OF CONVICTS AND PRISONS REFORMATORY BARBER SHOP MAY NOT RENDER BARI SHOP SERVICES TO PUBLIC IN WITH ESTABLISHED BARBER COMPETITION 510 OF PRISON PROLIILIF ION AGAINST TICTS AT LCIOW COST OF PRICE INCITIDE IN DECISIONS AND APPLICATION SHOPS NOT ON 26 CONSTRUCTION AND APPUEARLON THE WORDS COST OF PRODUCTION 40 ADDED REFERENCES OF PRISONERS ENIPLOYNIONT SALE OF PRISON PRODUCTS TION LABOR 10 LIBRARY NOTES CORISINICTION AUTHORITY FOR USE OF PRISON AGRICULWRAL LAND WAS 1956 CERTAIN THE 194142 IN PROD RODTC ITEMS OF FOOD OF INMATES OF CLOTHING AND RNNINTCNNPCE PRISON 376 OPATTYGEN194748 NO 41 TMT IN VICINITY NO 21939 OPATTYGEN 443 SALE CI PRISON FOREIGN VOTE 224 211 PRISON PRODUCTS PRODUCTS PLAY NOT BE SOLD TO OR PRI PURCHASERS EITHER PUBLIC OPATTYGEN19495O NO SSSA UPATTYGEN19495O NO 958 554 RW AADFRL C4 800306 PRISONS IT TNKIWFUL TO SELL BY THE PRISON IS MITTUD OO3O1 SECTION PRODUCED TICK MICLIIJNN TO ET IN PROVISION SEQ PENAL OF FOR SALE RAISED ARE THEREON PDSON AND MAY NOT BE SOLD EN THE OPEN MARKET OPATTYGEN NO 140 344 PROD PROD IONS OTHER NO 2MG OF LIVESTOCK ACT PRISON INSTIFUL ATDNCIES OPATEYGENLN3556 NOR AS EXCEPT TNDXIRTRIES OF STATUS EMPLOYMENT GOODS TO PRISON GOVERN2RWNT OR AGENCIES THEREOF WOULD VARANT THE SALES TO PRIVATE COR UNDER CONTRACT WITH THE FED ERA GOVTRNNIENT IN MATTERS TO RELATING THE WAR EFFART OPATTYGEN 1947 48 NO 48I 176 PRP CEO UNDER PRISON TODUSTRICS ACT SECTIONS 800301 CT SEQ GOODS MAY NOT BE SOLD THEREFOR OPATTY 533 IAMR 210 NO WHICH RELATED SALES OF PRISON PRODUCTS UNLAWFUL PRIVATE NOW TO UNLAWFUL FOR I947 TO SECTARIAN OR PRIVATE ORGANIZATIONS IC GARDKSS OF CHAIRIFABLE OR NONPROFIT CHAR ACTER OPATTRCEN 104516 NO OF CPARTRRN2NT AUTHORIZOD 653 OF STATE SIU AFLYCEN INS MANUFACT TIRED RIS ORE PLISON PRODUCTS AND SALE THEREOF 1O COUNTY RVACL COMMISSION TO L037 ILRIOR DNIEAIALUNRNT OF L935 NO 210 WAS FORBIDDEN OPATTY ICIL NO 142 34U ON SHOP LA LABOR OF USE ABSENCE OF AUTHORITY SCETIEN FOR OR LABOR IT WAS PAUTY TO EMPLOY LABOR PRISON MR PERSONAL AND PRIVATE PURPOSES AND IT WAS UNLAWFUL FOR PRISON INDUSTRIES TO PURCHASE RAW MATERIALS AND EQUIPMENT FOR RESAIC TO EMPLOYEES PRIVOTE INDIVIDUALS AND CORPORATIONS OPATTYGEN NO 181 370 PRODUCTS MAY NOT BE SOLD TO MUNICIPAL LEAGUE AS JOBBER FOR RESALE TO MICHIGAN MUNICIPALITIES ATTYGEN 194743 NO O5K314 133 PRISON CONTRACTS VNLAWFUL IN ARO 1947 NO 659 JODER THIS PRISON AGRICULRTRRAL LABOR LEGISLATIVE MICHIGAN ILIGLIWAYS OF PRISONERS SARECRNP FEDERAL 4517 I935 MADE COIREETIONS PERMIT OR NO TBEICOF OP S70 421 MAY LABOR NOT BE SOLD HIRED USED UNLESS THE LOANED OR WAS NOT INMATES FOR PRIVATELY NSTI TOT IONS NONPROFI J94344 ALLOW WORK TO PRISONS PRISON LEASED TO IS ND OFL PUBLIC WORK WAY ROPEITY UNLESS SUCH USE IS DI REELED BY THE GOVERNOR OPATTYGEIL 194112 NO 22908 544 PRODUCTS PRODUCED WITH OH PRISON FARMS INCLUDING 800306 TYPES AND PRIORITY OF ENIPLOYTNENT OF PRISOU LABOR SHALL FE THE DUTY OF THE PRISON COMMISON TO PROVIDE AS XUJLY AS PRACTICABLE FOR THE EMPLOYMENT OF PRISONERS CONFINED IN THE PRISONS OF ILIIS STATE IN TASKS CONSISTENT WITH THE PELIAL AND REFORMATORY PURPOSES OT THEIR LNIPRSONMENT AND WITH THE RUBLIC AND OF ECONOMY THE TYPES AND PPROXIMATE1Y IN THE CIDER OF PRIORITY NS FOLLOWS SEC IT ROUTINE MAINTENANCE TO THE THEIR CONDUCT OR THE PENAL AND SEVERAL AND REFOIMATORY CONSTRUCTIVE ACTIVITIES PURPOSES AND TO THE THE STATE THESEFOR EDUCALIONAL ANDOR REHABILITATION THROUGH PRODUCTIVE OR SOCIALIZED ILIDLVIDTLFLL NEEDS AND CDTIRNBILITY ASSIGNRNENLS ATITI AS LEQUISI PRODUCTIVE PRISON FARMS CI FAVORABLE MINIMUM TO COSTS TO WHETHER FORMAL OR ON THE BASIS OF DETERMINED ON STATE HONED ILY HISTRICT ROADS WHEN REQUESTED CORDANCE WITH SECTION SOO102 WILEII ACTIVITIES ACTIVITIES CONTRIBUTING MANNER MOST IN PRISONS PUBLIC WORKS WAYS OR PROPERTIES THE GOVERNOR OR ON COUNTY TOWNSHIP OR BY THE OF THE OR MAINTENANCE COMMISSIONERS COMPILED LABOR OTHER AGRICULTURAL 555 LAND LAWS ON OR IN RENTED THEREOF OF IN AC ISIS CONNECTION WITH OR LEASED BY THE THE DE 800306 COUUECTIONS MN NIRLI OF CRTEIIOI1S SLI TORIES JIS FOOD OF MAY IN S1QPC CROPPING OR O1LW UPOII IFLLIC FLWI IND FOR THE MNTTINTEIIAIICE MANUFACTURE SALE CORDAGEUSED IN AGRICULTURAL OR THE OR MATORIALS IN UT SEPT AS AMENDED PA1956 1950 SUBSEC AN IN CL1045 REPLACED AND TO CL1929 ENC TO 21 LIBRSRS REFERENCE SUB IN TO REFERENCE EARLIER THE REFER WAS INSERTED LAND REFERENCES 1O3 CONVICTS STATE PURCHASING THE NOTE LILSTORLVII 210 TWINE ROPE AND HINDER TLIIOUGH SONRCC NO FOT CONSUMPTION OF PRODUCTION AGENT OR HIS SUCCESSOR AS PROVIDED IN THIS ACT EFF MARCH 28 NO 42 INVI PAI935 F41C FOR OTHER SLATE PURPOSES OF PURCHASE 1FLSIS AND SUPPLY OR TBQIIJNIENT PIOP RODUCLION OJC1ATIOIL OR FOR DISTIIBUTIOIL OF THE STATE PRISONS FOR THE LES LIT FLII ANDOR OILIER SUYPLIE CLOTHING REQUIRED THE OTHER 01 CJS NOTES OF 16 CONVKTS DECISIONS AUTHORITY TO REGULATE HARROPPING CONTRCT INNAFER OF DI IC PRISON EC AND THEY AN BE 11W TINTE THE RRIPIOYED ONLY BY LABOR OF HOG TO FULLY 1LW OS PRISON DC CO FURNITURE CIRNUT 751 LABOR 1C CEN HO SLATE ARE IINTUW FOR IN OF AIS THERETO LYE AUTHORITY 1947AS FILL OF OPATTY NO 65 110 LKSUPP 800307 PRODUCTION AND DISTRIBUTION TH4TDIDLION NETS FOR STATE PVIRPO DUTY PROD OF PRISON STATE OF PURCHASIZIG SGENT OF PRISON PRODUCTS PRODUCTION AND DISTRIBUTION OF THE STATE PURCHASING AGENT DUTY PURPOSES ESTIMATE OI HIS SUCCESSOR TO JRINIE ANNUALLY IN ADVA NEC AN LTEMI7CD FOR PROPER USE AND OF THE SUPPLLCS MATERIALS AND CRLTLIPRNELLT REQUIRED SEC REQUISITION ROR STATE BE 1W THE IN CONSUMPTION 110115 SHALL BE THE IT CHARITABLE JIEIIM ANDOR OILIER OF STATE FOR THE LEPARINLENTS LEGALLY DESLTCNTT ED OR THE DCLEGA SHALL HAVE THU AUT HOIITY TO ROQUL RE FLTITI LIE OR OTHER OFIKIAL SUCH REPORTS OF SUCH LO FL CCIII ANDRN REQUISITIONS AND ESTUJIATE OF EACH SHALL IT OF SAID AS MAY BE THE CUSTODIAL IFLSTITTI GOVERNMENTFOR WHICH BE MAY AND TED PURCHASING AUTHORITY WA TDEN OF THE SUPERINTENDENT ND DEPARTMENTS INSTITUTIONS BE NECESSARY FOR THE PURPOSES DUTY OF THE STATE PURCHASING AGENT OR HIS SUCEESSOL TO MAKE REQUISITION UPON THE PRISON CONIRNIS FOR SION SUBJECT TO THE APLROVAL AND ACCEPTANCE OF SAID COLIIINISSLOLI ALT OF SAID ESTIMATED II SHALL BE DTCFLIT NRA BILE AND IT PRISBNER SHALL HE THE TO REQUITE THE SLIPPLIES IEABK LABOR DTIT MALERIALS TO PRODUCE OR AND EQUIPMENT OF THE PRODUCTION AND EQUIPMENT PRISON OF THE PRISONS COMMISSION OF THIS TO PIOVIDE MANUFACTURE SUPPLY AND 550 IN AS SAME WI ITLATIUFACTUREJ DELIVERY LB IT THE SLATE FOR AND OF SAID 800308 PRISONS THE REGULAR AND SUITABLE WITH CONSISTENT AND FACILITIES AND OF THE EQUIPMENT LALICI JHE STATE SLATE AND TO TLIOIITY SAME TO THE AS THE IF CONVICTS 13 LIF 210 PRESCRIBE CONDITIONS OF SHALL HAVE FLU AN1 PRODUCTS PRISON WETE PURCHASED FROM OTHER SOURCES SANTE NOTE HISTORICAL NO METHODS AND OF DELIVERIES OF THIS PRISONS SUCCESSOR SHALL ACCEPT OR REJCCT SAID YCLUISITIOILOD EXTENT PA1935 HIS TESIS QUALITY AND TIMES CONDITIONS 1N PACKAGING IN IHE AVAILABLO AGENT OR PURCHASING STANDARDS SPECIFICATIONS AND EQUIPMENT TO THE FULLEST EXTENT EMPLOYMENT OF THE PRISONER MATERIALS SUPPLIES REQUISILIONED 21 SCPT REFCREPCE LIBRARY CIS 26 CONVICTS NOTES OF DECISIONS IN GCFL1UR CUNIRACTS FOR MADE BY TH HIGH AND WAY DEPARIRNEOL WHICH WITH LINT1 OF DEPARTMENT 800308 THE PENAL TO SUPPLY IS ABLE III OR CUSTODIAL HID PRISON OF SECT ION SHALL HE SNACK CONTRACTS PROPER PTOVISIOFL PRISON PIODTTCI SHALL PRICES DUCT ION REEDS SIT ID TO LE FIXED BE SUFLICIENT ANTI OF THE SH PAYMENT AT JUICES SI INLI SALE BE BE III FORM AND NOND BY OR ANY IRIDEMI FOR DCL TART II LENT SHALL TINY RIIERIT HE SALE OF PIISON OR IIST JUT LION COINHIL THE LINT SHALL HE PRODUCED MAKE RACTS SHALL FOR SAID NUICHIASER WHICH COFLIFLIISSI0FL FOR TLIE COSTS AND MAT ING HEREOF TILE ZI57 ISSI TO OF THE PRO PRO RIGHT SI TALL TEICOF SUBJECT CIA IRA MCIII TI OF THE DII PHI P0805 5011 ION COSTS ANY ONITILI FOR JLI AT IODTLC PRODUCTS ON FOR NONDELI UCRY OR FOR SUCH CLAIM BE VALID PROVIDED UNDER SUCH ROUT VACTS AFORC ISON 41 IC LIE STATE III PRODUCED IRIDS SUCH COIL ISCRI OR DCPA JOJIS OF ACTUAL STIVJAUS BY AUTHORITIES HIS ACT THC PRISON TIRE OF SUCH PRISON ISBUISED TOUT INET BY TO REIMBURSE AFTER OR FOR TLW PURPOSE OF DE FRAYING SUCH SLATE TO THE TTIT OF ADVANCE NI NO WIREQUISIL ICRIED OF THISSEETION THE PIOVISIOHIS FOR ILLS OR 1LW THE PIOVISIONS OR MANUFACI UTC AND THAT OR SOLD TINDIT PURCHASING PIOPER CAM THE PRISON PREVENT IDLENESS THE INDUCTS ADDITIONAL IUIIDER SUCH NIL CM STATE DEL LYCIED TLIAT WITH OTHER SULIPLICS EXCRNPTITIIT PRINTING NII OILS 308 APP NET II OPATYOEFL 194950 LIFE NO 1037 EMPLOYMENT MAY HE NECESSARY TO WITH MAY NMKE CONG TACT AND THORN GIVE NOIB PROV AFTER OF LVISIACI5 NI THE HAS BEEN MADE FOR THE EMPLOYMENT AND PROVIDED FOR IN SECTIONS AS HILLY AS PRACFICIILC HAT FURTHER MEANS OF PRISONER AND IN CASE IT SHALL SEC OT TO BY DB WITH WERE VOID ND APPROVAL BOARD DID NOT ADRNINRTRFLTIVE ING CONTRACTS FOR ADDITIONAL STATES OF THIS SAND OF PURCHASE TLE HLGBWY SIGNS AND THE NO STATE DAMAGES OR FTC 3101 OF EOI PURCHASER IT TO ACCEPT 800308 CORRECTIONS OR TO REJECT FOR SUFFICIENT CAUSE THE PRODUCTS CONTRACTED FOR IS NOT HERE BY ABROGATED IN THE FURTHER AND AFORESAID SO AS SECT OF THE PURPOSES OF THIS ACCOMPLISHMENT FAR UNDER APPLICABLE SAME IHE CONDITIONS AS AND METHODS OF PROCEDURE PROVIDED IN SUBSECTION HEREOF THE STATE PUR CHASITIG AGENT OR HIS SUCCESSOR MAY MAKE FURTHER REQUISITION FOR AD DITIUZIAL PRISON PRODUCTS FROM THE PRISONS CI THIS STATE AND EXCHANGE SAME FOR THE PRISON PRODUCTS OF PRISNN OF COUNTIES OR CITIES CC THIS STATE FTNM OR OF THE PRISONS OF OTHER STATES INISONS OL HER TIIAN THOSE OF THIS HEZEFOR CANNOT HE PRODUCED FLITNT RIBUTED DISI FOR IN IN OF IHI OF SI III SAID PIODUC LIE OF THE SECTIONS SECTION SECTION IS CONSTRUCTION AINED SHALL ALLOW PRINTING DIVISIONS PRODUCTS SHALL BE REQUIRED FOR AND OR DEPAILINCAIT OF THIS SIN TO AS PROVIDED IN THE SANAC PRNI1O1 FLS THE PIODTICFS OF THE HIS NET ATE SAID PRISON SUBSTITUTES OR EQUIVALOTIT OF THIS STATE WITH THE EQUIP THE PRISONS IN PROVIDED THE INSTITULIONS SECTION PRISONS COAZT AD FLVFLHLFLLL ROVIDETL STATE UF THIS BE DONE FOR COUNI TO ACT ICS NOTHING HEREIN OX POLITICAL STAB STATE SOOSOG 800307 80030T 800304 IIISTORLCAL NOTE SOURCE PAL935 NA 1O PAM37 NO 95 IMD EFF EFF SEPT JUNE 21 21 CROSS REFERENC PENAIUE REQUISITION EE 800315 PRODUCTION AND DISTRIBUTION OF PRISON 319 STATE DEPARTMENT CONVICTS OF 791201 CORRECTIONS SEE CQ REFERENCES LIBRARY IO1 CT 800 PRODUCTS FOR STATE USC SEE C3S CONVICTS 16 NOTES OR DECISIONS CONSTRUCTION AND APPLIENTLON SALE OF PRISON PRODUCTS 13 NOW SECTIONS 800308 OPATTYGEN 1935SO NO SALE CONSTRUCTION AND APPLIEATION PRISON COMMISSION NMY EMPLOY PSY CBINRRISTS AND PZY FOR THEM FROWN FUNDS AVAAILNLLE UNDER 1A1935 NO 210 FT 800309 SEC POLITICAL TSETL IT PEIRNI SUBDIVISION OF THIS FOR 344 PRODUCTS PRISON IN SHALL BE LAWFUL OF 800313 140 PRODUCTS MAY NOT BE SOLD TO MICHIGAN MUNICIPAL LEAGUE AS JOBBER FOR RCSNLE TO MICHIGAN RNTINICLPALITLES OP NU 0531I 133 ATLYTEN 1947IS PENAL DI INSTITUTION STATE TO SELL 558 OF PRISON PRODUCTS NOW MAINTAINED OR OTHERWISE DISPOSE BY OF ITS 800310 PRISONS PRISON PRODUCIS TO THE INSTITUTIONS LITICAL SUBDIVISION VISIONS SUCH INSTITUTIBNS ACT IHIS OF SHALL P0 THE PRO IOCATCD NOT APPLY TO SUCH PENAL NONE SUBDIVISION POLITICAL IS INSTITUTION SAID OF THE PVOVRNLOFLS OR HOUSE OF CORRECTION APPLY TO THE DETROIT ACT SHALL THIS WINCH AND IN IONS OF SECI OF THE COUNTY OR OR DCPMTRNCFLTS SQO307 500308 SECTIOLLS NISTORIC NOTE SOURCE NO ITHA1FL35 210 EFF SEPT REICTCUKCCS LIBNTRY 43 CONVICTS 800310 CJS IT TO BE THE INTENT HEREBY DECLARED IS OF THIS AND ACT FOR PRISONERS EMPLOY SUITABLE REGULAR DIVERSIFIED WITH PROPER PENAL OF THE STATE CONSISTENT ADERJUATE TO PROVIDE MONT OF ACT INTENT SEE 10 26 CONVICTS PURPOSES SELRMAIFLTFLFLFLCE FOR THE LABOR OF PRISONERS EXCLUSIVELY BY REASON OF THEIR THE SLATE FOR EXPENSES INCURRED TO UTILIZE AND FOR CRIMES AND ILOPRISFLIIFLCNT BOR OR CI COMRETIT IVE LLI TO ELIMINATE TO EFFECT 11W TEO LABOR NI ID JWODUC IS PRHZOII BETWEEN PRISONER RELATIONSHLPI OR JJ1IVU IC ILL TITISTRY OF PRISONER LABOR STATE AUTHORITIES WITH AND DISBURSEMENT REQUISITIONING AND PRISON PRODUCTS DIICETLY THROUGH ESTABLISHED WITH OF PIIVAIC NOFLTS THEREFROM MID NO POSSIBILITY JNTCRRNEDIATIFLG AND TURES THESE TO THE GOVERNOR THE NPPROPPIETTIOILS CONSIDERATIONS FINANCIAL SHALL REQUIRE THE AGENT SLATE LAND FOR RIND THE MMDERIALS PRISON AND DEPFLRTMFLTLITS LICEESSALY PRODITETS INST BUISED SUE ILL OR COLLECTIVELY SEPARATELY OR PRODUCTION OF NIANUFACTITRE WITH SECTIONS ACCORDANCE ILIEREFOR IN FOR THE PRISON RULUISII PRISON OR DEPAIL ITULIONS AT PRICES HIS CONSUMIN IOIND ACT OF THIS FOR CVEDITJIIG ING OR OF ACCOUNTING OF SUPPLIES ANDOR ITUTIONS OF MINIMUM OR EXPENDI EJIDS SUL TABLE METHODS OF PURCHASING CCSSOL TO ESTABLISH OR ADVISABLE SHALL WHICH PROVIDE AS MAY HO NECESSARY MUD ISI IIG AND STIPLILY ON ACCOUNT OF THE SI IA FIXED ACCOUNTS AND DEBITING MENTFI TO INDICATE CEOUHITS OF CONSUM AND DIS FOR PRODUCTS REQUISITIONED FAIRLY THE TRUE COSTS OF MAINTENANCE AND DEPART MANAGEMENT OF SAID PRISONS INSTITUTIONS DISBURSE OR MENTS PIOVIDED THAT SAID PRICES OR THE REQUISITIONING DETERMINED BY OR CON IN NO CASE HE INENT OF SAID PRISON PRODUCTS SHALL OTHER SOURCES TINGENT UPON COMPEL HIVE BIDDING FROM EFLICLENCY FOR THE PRISON OF PURCHASE OF NIL COMMODITIES IN THIS PRODUCTS AS PROVIDED FOR 55P 01 REQUIREMENTS OTHER THAN OR COMPETITIVE BIDDING ACT BY 800310 CORRECTIONS OTHER METHODS ESTUJIISHED BY LAW OR APPROVED PRACTICE PROVIDED THAT NO BIDS MAY BE ASKED RECEIVED EXCEPT FOR COMMODITY REQUJRC INENTS WHICH IT HAS BEEN DEFINILCLY DECIDED SHALL NOT BE SUPPIED BY OF REQUISITIONING FLRISON PRODUCTS AS HEREINBETORE LROVIDED 800304800306 SECTIONS NOTE HISTORICAL SOURCE NO PA1935 EN 10 210 SEPT CROSS REFERENCES STATE AND ACCOUNTING REVENUE DISPOSITION STATISTICAL DETAIL5 TO LABOR RELATING IN 2110 PCNAL INSTITUTIONS COLLECTION AND COMPILATION 40852 SNO SUPERVISOR OF INDUSTRIAL 791271 PLANTS SCC LIBRARY ROFEREIJEES CON C3S CONVICTS 13 NOTES OF DECISTONS SALE OF PRISON PRODUCTS UNDER MAY PRISON PRODUCTS MAY NOT BE SOLD TO MICHIGAN MUNICIPAL LCNGUT AS JOBBER FOR RVSULE TO MICHIGAN MUNICILALITIES OP NO 05314 ATTYGCN 194748 133 800311 ITHE OP ALLOWAIICCS VMOFL COMUHISSION REGARDLESS OR CHARACTER NONPROFIT NO 04317 OF OR PRIVATE CHARITABLE OPATTYOEN 653 TO PDSONERS SCHEDULE IDOPT IT1TI OR TO THEIR TO PRISONERS PROVIDED LIE BASIS ORGANIZATIONS 194546 ACT INDUSTRIES SCHEDULE OF PNYMENLS OR ALLOWANCES SEE 11 MAY PRISON BE SOLD TO SECTARISN COT OF LFLYFLYLFLTS DEPENDENTS FROM SUCH FUNDS AS SUCH SHALL BE MADE ON THE OF OR REWARD FOR INDUSTRY OR BEHAVIOR TO PIJOIIIS TO THE STATE HORN THE ACTIVITIES TO THEREFOR BUT OF NEED OR OF MOTIVATION AND SHALL NOT BE RELATED WHICH SAID PRISONERS MAY BE ASSIGNED NOTE HISLORICAL SOURCE NO LA1935 800312 210 11 FIT ABOLITION SEC 12 IHE PRISON ALL SALE POSITIONS OF PRISON ACT SHALL BE ABOLISHED BECOME LAW WILHIIM HISTORICAL NO 210 12 EL IN INDUSTRIES SEPT 21 600 OR ESTABLISHED CREATED PRODUCTS OR FOR THE INCONSISTENG SOURCE PA1935 OF PRISON OFFICES OR OFFICES HERETOFORE WHICH MAY BE THIS OR WITH THIS ACT OR DISTRIBUTION INDUSTRIES 21 OF POSITIONS CONSISTENT LOT SCPT 30 LAYS NOTE VITH AFTER THE THIS CONDUCT OF OPO RATION ACT SHALL OF HAVE AM LT EZA 800315 PRISONS 8003 13 SEA 13 OF THE EQUIPMENT THE IRESCNT THE PROVISIONS DITIONS SALE PRICE TERMS COMMISSION PRISON OF THE EQUIPMENT OF THIS AND ACT OF SUCH SALE IN THE EONCLITIOII HEREBY EMPOWERED TO SELL SUCH AS CARNIOT BE UTILI2ED UNDER DETERMINE TO BEST IS IMISOILS TAR INTERESTS COW THE PRICES TERMS AND OF THE STATE PROVIDED THAT SO FAR AS PRACTICABLE SUCH SALES SHALL BE THE MEANS OF ESTABLISHING EX TENDING OR ENCOURAGING PILVATE OR COOIERATIVC IN THIS STATE INDUSTRY AND THE SAID PRISON COMMISSION IS EMPOWERED IO EXPEND THE PROCEEDS OF SUCH SALES AS MAY BE DEEMED WISE OR NECESSARY IN THE PROVISLOO OF SUCH OTHER EQUIVMCNT OR FACILITIES AS SHALL BE REQUIRED FOR MAKING EF FECTI FO HE FULLEST POSSIBLE EXTENT THE AND PROVISIONS OF PURPOSES THIS ACT HISTOTICAL PA19 NO 210 13 EFF NOTE 21 SEPT NOTES OR FLOVLDONS CONSTRUCTION 4ND APPLICATION PRISON COMMISSION MAY NNIRLOY PSY CHINTRISTS AND PNY FOR THEM FROM FUNDB 800314 AVAILABLE UNDER NOW 13 PA1935 SCRIJONS OPATTYCEN 193530 NA 210 800305 NO II 800113 140 VIOLATIONS SEE 14 WILFUL VIOLATION OF ANY OF ITO OF THIS ACT BY AN THEREOF OR BY ANY OFFICER OF ANY INSTITUTION OF EITHER SHALL BE SUFFICIENT CAUSE FOR REMOVAL FROM OFFICE AND SUCH OFFICER SHALL ALSO BE SUBJECT TO PROSECUTION AS HEREINAFTER PROVIDED OFFICER OF THE STATE OR OF ANY POLITICAL HISTORKAL PROVISIONS SUBDIVISION NOTE SOURCE PA1FL35 NA 2I0 800315 SEC 14 ELY SEPT 21 PEMIALLY ANY PERSON FIRM OR CORPORNI ION WHO SHALL WILFULLY VIOLATE ANY OF THE PROXISIONS OF IBIS ACT SHALL BE DEEMED GUILTY OF MISDE MEANOR AND UPON CONVICTION IHEREOF SHALL BE PUNISHED BY FINE OF NOT LESS THAN 100 TLOLLATS NORMORE THAN 500 DOLLARS OR BY IMPRISONMENT 111 THE COUNTY JAIL FOR PERIOD OF NOT MORE THAN 90 DAYS OR BY BOTH FINE AND LNIPNSONNZENT AT THE DISCRETION ILISTORLCAL PAL35 NO 210 15 ELY SEPT OF THE COURT NOTE 21 CROSS REFERENCES MISDVRNEANOR SEE 7508 7509 800315 CONIWCNOPJS C4 SEES 16 17 TJUSO AND REPEMCD BY SECTIONS ELAINE XVERE NO 267 LIND ELF MAY 25 THE FOLLOWINP ERABRITY FL45 RCPE 16 17613 NO PA19JI 151 CL1920 202 CL1929 17624 17621 PA191T NA 17632 II 17636 17608 CL1929 150 PA SECTION NO 140 CTLP29 1A1909 NO 210 PALO NO PA1935 SLV REPEATER PA1921 PA1907 17GM EL NO 343 CL1020 NO 291 CL1929 17644 17645 17623 8003 18 PRODSIONS CONFLICT WITH IN II AFLONAL NTHORI IABOT PRISON TY VOID SCO 28 WITH IS ANY CONTAINED IN PROVISION NND RULES ILIE HEREBY DECLARED THIS OF THE NATIONAL REGULATIONS ACT WHICH PRISON IS IN LABOR CONFLICT AUTHORITY VOID HISTORICAL NOTE SOURCE NO 210 PA1035 8003 19 18 FIT PRODUCTION AND DISTRIBUTION EEQUUISLTIOUT UCTS FOR STATO SEE 19 21 SEPT USE STATE PROD OF PRISON BOARD ADMINISTRATIVE DEITIES PRODUCTION AND DISTRILUTION OF PRISON PTOD BE THE DUTY OF THO STATE ADMINISTRATIVE BOARD TO PREPARE ANNUALLY IN ADVANRE ON ITEMIZED ESTIMATE OF THE ARIIE1C AND MATERIULS REQUIRED FOR USE BY THE INSTITUTIONS DEPARTMENTS AND OFFICES OF THE STATE VHICH MAY BE PRODUCED BY PRISON INDUSTRY AND THE STATE ADMINISTRATIVE BOARD SHALL HAVE THE AUTHORITY TO REQUIRE OF EACH OF SAID INSTITUTIONS DCPARTMENTS AND OFFICC SUCH REPORTS US MAY BE NCCESSNUY FOR THE PURPOSES OF SUCH ESTIMATE IT SHALL BE 11W DUTY OF THE STATE ADMINISTRATIVE HOARD TO ISSUE PIEVRHNSE ORDERS TO THE PRISON COMMISSION TOT ALL OF SAID ESTIMATED UCTS REQUISITION USE FOR STATE IT SHALL PTO ART IRKS IT AND MAICRIALS PRACTICABLE THE DUTY OF THE AS REQUISITIONED WHICH THEY MISSION AND ARE THE NS THE INSOFAR SAME WITH TO PRODUCE BASED AFTER IN OFFICIALS SPECIFICATIONS SUSPECT IF THE ACCEPT FOR PRISON OR REJECT SAID WITH CONSULTATION CONTROL OF SAID THE INSTITUTIONS PRISON IKIJIORLEAL CQNVICTS 13 19 ELF SEPT CORN DEPWTMENTS PRISON PRODUCTS TO THE SAME EXTENT OTHER SOURCES NOTE SOURCE NO 210 NLEERN PURCHASING AGENCY SHALL PRESCRIBE PRODUCTS AND SHALL HAVE AUTHORITY TO SAME WERE PHLRCHASED FROM 2AIL35 SHALL AND IT SHALL BE LABOR COMMISSION PRISON TO FULFIL SUCH PURCHASE ORDERS IN STIJET CONFORMITY WITH THE SPECIFICATIONS UPON PRISON OR OFFICES OF THE STATE THE STATE THE COMMISSION PRISON 21 LIBRARY REFERENCES V35 562 CONVICTS 20 AS PITTSON OVITITRCO 810301 NO 1A NOBLO VH CRC OW JIG II NOW SECLION REPENTED BY SECTION XUUOI OF FLI 19138 APRIL RCPCA LED OF SCCTI ONLI BY SEC IONS IAC NOW SCELLEN HEPONIEIT SBII2 8HK IXVIFILT HUH ELF IS MA TV TICD CCIV IS TILE CET NFLIJ AL 9G8 ACT 1NIUE7V1I1II PAIOIIO RQEALOD 800319 TO 800323 LAWS ANNOTATED COMPILED HI 8X 4NTT S0OEN STETLON ROO III 5451812 10 SOLUVIL SOO SOO 801 S001113 SOO05 8AOAI06 III BOALICIL II HO CQ41J1 OF AN CVT ROCHR IRRTC ILUL OH ON ALTILBIIAI THIS UI LIALIIT ILT IUIIT LIE LI LIRAAFLAI AIR IAIS HAL 800121 ILI TT IS NA IUIJS JHC RLY DAI RFLLY TC IRA MAUD SOC UNDERLINE HAN I4IG CAHIUA LAY II IIII4 IUITLUAIIX IRSI ILL IIAIL OF VDR LAG IGIINYIILS ARWIRCI 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CI DOT LII EFF OF TII OF VISUAL STITUTHI HIROLILECT LII NC OF ULTILTTTEMLIS 0I OF 01 III CO PIHTLN YMTD EN II SEETLOET AIIM OFFICE 14 III AN OFRLCCR OF O17 0113 SEIL JETT LIST TICLI ITS 8028E CF SON IJETROIT I9CTORONCES CJS ANY OF THIS NET NO 35 SPUD PENALTIES FIRM CRSOI IC II GUI II IIIIL OF 01 IC EFF GCCRSOC CO III ILTISDCUIICN FIRM STATES II TIJOTISOCI 49 FL FL VORPORATLOIT SLTO ATLAIT CC II COELCIETI THE VIOLATIONS II FIT SOOMW TUTEIS 800334 SHUCIS HIY APRIL LIBRARY VI NET 1002124 SCTITIII OC THIS OCCY OFFICER THEREOF OR IY FOR RLI NAVAL IZO CI IL AWN CCI IFEULLY VIOLATES AMY OF IHUE PRO UPR JCTRT JIORSON 1ITO ILC TTLJHSCD BY CC IN 1ALUFII APRIL SUBSTATMILVO 40 CHANGES TEXT ICIDLEATED HY UUNDERHHCCE ODELLONUS COMPII ROPEAL OF PRLSO 800335 15 IIII RR TO IE OF 80021 OF THE LUTLLJC NV VA OF IS ECFLCNS 800303 UZONCIED 13FL IS RTICNLED ACTI 1VLS MIII 15 ACT UIDUSIRIES CM MA NO 210 ACT 8028A LAWS ANNOTA1ED APRIL IT CHAPTER IIUI LIII MC LN LION LILT OR NANCE BO COCITY II CLII SOY THE III TFFI HUH LI 110 ILL IL TIFLIGID JI FT BE INLILI HUN IRISTLIC RS1 LIII III LII SITI IA1I LCIUL VURIIUITIFLHII XNILIL RCPFQLI AL BY 01 NRC III II AU IL TRILL AWAIIIFIK LOIISTS ILIOW TO NI WS 0CLIRIIT IT 802 HOUSES CI RFFU IE IIUIIU IIO OOTO DETROIT OR WITH SEE OX OF THE COTIIICII THIOIIZED TIC LIT IX LIII JIR ITY IIIDITIL IC 1T RCI DCL NO ONE 101 FROM IC SIC TOIL IL TAT ID HUT CIT UI LINT CUI BY BY LID FLIT IN IRILIL TOTIITLS ML LIEU IAAIITO RUERIT NO ACTERLEKS 47 THE LIELIZI III YIIIIIIP III II BCIILLF NG IT HI1IIIT TO OF ITD ITT WI LID TO TIM TTIO KI OIL TO XTXOXIU OF SITS SO QI IVITEMEBY N4Y NY ORDER RUUMURT 0X1T031 TIM AT UJUUIIIUL RI 11 LOU 18T LIE ROITIILY II CII II NWALTLNG JXIJIIIIITLIFLHI UT CITY OR OFF OR TICUCI AIMI II UIILUUIII ITCIITIIIT UT RCR AT CUSTODY OIL OUI ILL HO IZED CIII TILT OWILILTIG 044111 IIIUIIENTET II ILTOR TO IN AW OROLFICCR OX OR MIII WITH THE CIII IGIUTIIITIIT IIGET1L JILIRHNIIITY IKI PALO LCD CIORVIUU NVUITLIG 3I1I54R NIUILIIIR4UIIUTIS LXIII OR IFL DCI OIL ED IN CTIYHTIHR PLRLON DOIR PHO RIG CUT SLIUDI ILIOLILLO CURRED TIE CLIX FOR SUCH HUT I83 UILILILY OT CI CUGCT ITINIT 104 HOUY ETROIT SOU UI AUTLXOIIZED UDTML IIERLIUIE IN EGLION 0113 TWA COUNTY AND CITY OF DETROL IC LIES ITAYRNON NTLCR IIIIY AU HERS 12IIPLITIRI LIJINTI SRI TIOC000 SIIPIFLHI OR TON LUG AFTROCRNCULT HOTWV TRIAL OR SONIC O020 II IRT FIOFLTOIIC PA 1070 NO RMOJUDED IV RUT IH IF ILL NEW CSIIITHIGI OAT II CORHECIION I9FLIN CL 114W14 27I TO CIIAT1EIZ 11111101 AN J1TR ORDILI LFLLIIITLFLHUIL OR LIMIT DIIDRIET WUS AIJIOVIUD CO1T1LI 01 PTYZNOIT VIHI IJG OCULAR 114 AND EXPENSES CPU CITY IF SIT HAT PRORI4HD CPTCIIIU IIO11SI OR TJII1IEFLT CHFLFLJES NTY RKCEIIIIG OF CORRECIXONI PETNORI OI TII IILI ULDOCI II 274 TAKE CFEIT ICEGIIAILON TJII LIE CIT NO ILL TIHIS II AND VICLATINIL ORULLNARIRE IIAIGX III CNIIILY TIGO CLIS ACT CF MU 80I4A IF II CXIIES TIUCI 1T COINIV ILL ILILI UI INIITI URGE II TIJEHEOF I1ECULATXON J1IE TAYIII2ILT IIIV II AND COUNTY JAILS JIG 21U AND WORKHOUSES CORILECTIONSJATLS III 11141 P4 II 801 ILIRRI CR 1FL endstreamendobj TABLE OF CONTENTS C4 PALE COUNTERSTATEMENT OF ISSUES COUNTERSTATELNENT PRESENTED OF FACTS ARGUMENT THE DISTRICT COURT WAS CORRECT IN RULING THAT COUNTS II III AND IV OF PLAINTIFFS AMENDED COMPLAINT ARE NOT MAINTAINABLE CLASS AS ACTION TINDER RULE 23 FEDRCIVP II III THE DISTRICT COURT WAS CLEARLY CORRECT IN DEFENDANTS NOTION FOR SUMMARY GRANTING THE UNCONTROVERTED JUDGMENT ON COUNT FACTS ESTABLISHED MATTER OF LAW THAT AS APPELLANT INMATES WERE NOT EMPLOYEES OF PARKE DAVIS CO OR THE UPJOHN COMPANY WITHIN THE MEANING OF THE FAIR LABOR STANDARDS ACT THE DISTRICT COURT WAS CLEARLY CORRECT IN MOTION FOR SUMMARY JUDGMENT GRANTING DEFENDANTS ON COUNT TI OF THE INMATES THE COMPLAINT UNCONTROVERTED FACTS ESTABLISHED THAT THE INMATES COMPANY MEANING IV 10 THE WERE NOT EMPLOYEES OF PARKE DAVIS OR THE UPJOHN COMPANY WITHIN THE OF THE MICHIGAN MINIMUM WAGE LAW OF 1964 21 DISTRICT COURT WAS CLEARLY CORRECT IN GRANTING MOTION FOR SUMMARY JUDGMENT ON COUNT III AND IN CONCLUDING THAT LAWFULLY CONFINED PRISON INMATES IN MICHIGAN DO NOT OWN THEIR OWN LABOR AND DO NOT HAVE PRIVATE CAUSE OF ACTION FOR DAMAGES BY REASON OF THEIR WORK ASSIGNMENT TO RESEARCH CLINICS LOCATED WITHIN THE PRISON WALLS OF ALLEGEDLY IN VIOLATION MICHIGAN STATUTE TO PROTECT FREE LABOR FROM COMPETITION DESIGNED BY PRISON LABOR DEFENDANTS SUMMARY OF ARGUMENT 24 24 TN MICHIGAN THE LABOR OF LAWFULLY CONFINED PRISONERS BELONGS TO THE STATE OF MICHIGAN 27 THE MICHIGAN PRISON INDUSTRIES ACT DOES NOT PROVIDE DIRECT OR INDIRECT BASIS FOR PRIVATE DAMAGE REMEDY 30 STATED PURPOSES OF THE ACT UNDER THE ACT 323 PLAINTIFFS DO NOT HAVE DAMAGE REMEDY UNDER THE PRIVATE ACT 33 EXPRESS PLAINTIFF3 ACTION IN PENALTIES DO RIOT TORT HAVE CAUSE OF 36 PLAINTIFFS UNDER ARE PRECLUDED FROM RECOVERY CONTRACT THEORY AN IMPLIED HAVE NOT SUSTAINED PLAINTIFFS SHOW RECOVERABLE DAMAGES AND 39 CANNOT 41 42 CONCLUSION DISTRICT COURTWAS CORRECT IN GRANTING DEFENDANTS MOTION FOR SUMMARY JUDGMENT ON COUNT TV BECAUSE EVEN ASSUNTFLQ THAT THE OF PLAINTIFFS LABOR WAS UTILIZATION DID CONTRARY TO MICHIGAN LAW PLAINTIFFS THE NOT SUFFER DENIAL OF ANY RIGHTS STATES CONSTITUTION BY THE UNITED PROTECTED 44 48 RELIEFREQUOSTED II TABLE OF AUTHORITIES C4 CASES PAGE ANDERSON SALANT ANDREWES AAS BARNGRCVER 214 PETTIGREW THOMSON BEEGLE 322 BERKA RI NY 38 US 214 CAL 119 COFFIN CO REICHARD DAVIS DEMARCO DICE CAL F2D 143 390 ET AL NASHUA APPEAL DISMISSED PP RYAN 116 FALLIS UNITED 443 865 6TH DR 1944 COUNTY 15 STATES EXNPLOMENT 2D DIR 836 193 GOLDBERG CF2D 491 GOODOHILD 1910 38 345 P2D OF COFFEY 62 655 COUNTY 2329 1963 45 SUPP 846 DATE 1ST CIT 1946 1945 17 SUPP 39 780 COMMISSION MD 15 PA 1967 MICH 45 APP 96 21 ARK 247 WHITAKER 178 1885 263 SECURITY HOUSE 1961 28 HELENA 53 318 27 4ARIN OF MICH GA 1968 CRITZ DENIED 1968 DIN 9TH CC MFG US FOSTER GREER 40 40 239 SE COMMISSIONERS 782 1955 F2D 315 CART 1899 69 AND FOR F2D BOARD OF COUNTY 289 PFLD RHAY 1905 46 KAN 523 DRAPER 39 904 1943 CORPORATION 1959 EDENS NW 777 GOINGS COURT IN SUPERIOR 513 MR 2937 1915 423 104 57 GRAND RAPIDS OPERATING 241 1927 BRICK 533 7TH 875 NW CHATTAHOOCHEE NW 108 IOWA 128 1910 425 34 WOODWARD 125 DOLDEN 96 255 F2D 138 1944 743 463 13 SW 764 COOPERATIVE 1890 INC 37 366 US 12 ERICKSON GLENDALE FERRY 375 CO MICH 289 134 NW2D 191 1965 WALLING 113 F2D 616 8TH 21 CIR 17 III CASES PAGE HART HUDGINS MARCH 18 AL ET TC 65 19717 CC GUNN FURNITURE HUNTLEY 1948 NW 130 79 SUPP LUCAS CENTRAL 277 145 MICH SUPP 327 MEZULLO MITCHELL MASS 331 MALETZ 233 SHEPARD PATTERSON PRIOR TOWNS ALA 183 F2D 404 354 COAL IRON 1914 HOE ET ND 39 CONN 1956 2D CIR 365 130 MICH 356 1954 SUPP 835 1959 34 IX MINN MICH 41 1862 36 1966 65 FLUTLER 3246 1959 NWQD 71 94 455 NW 85 INC BREUER SO 21 804 1901 1084 ET AL TC 10 16 9162826 1314 WALLING PORTLAND TERMINAL WALLING SANDENG ET GO GIR 1914 112 38 1945 SILBERTSON MD 8TH 695 NW 150 367 CO ELMER OHIO 472 659 AND BRONK 126 THOMPSON MICH AM DEC 81 MUSKOVITZ TENNESSEE 1906 667 64 NE2D 118 1967 12 MOREHOUSE WYANDOTTE 192028 373 MIMI F2D CC NORTHWESTERN KITE 1955 SIGLER MICH 166 NW FRD CO WIRTZ WD MICH 110 338 108 MATTHIES SEYMOUR MFQ 23 REVERSED ON OTHER GROUNDS 270 VAN 192029 34 CO VINCENT CC RAILROAD 1911 662 SEAGRAVE TATA LA 3845 MICHIGAN LEPARD ED 1132486 AT 136 STATES 330 F2D SUPP 217 UNITED CO US 6TH CIR 78 148 ED US 389 1947 148 1943 PA 1963 191 12 1113 12 1967 3435 SEG 111214 171819 STATUTES UNITED FAIR STATES LABOR STANDARDS AS AXNENDED 29 ACT USC 29 USC 55251 ET 520L SEQ ET 2122 PT CASES PAGE FLSA S3D MX ELSA 3E 11 FLSA 53Q 11 ELSA 23 MICHIGAN MCL MCL MCL MCL MCL MCL MSA 172552 40 382D MSA 172552 80038 MSA 281407 800301 ET SEQ MSA 281521 SQOACS MBA 281525 M5A 281526 800306 IYCL 800310 MBA 281530 MCL 800311 MSA 281531 MCL 800314 MSA 28A534 MCL 800315 MSA 281535 408382B 22 21 2846 ET SEQ 24 2445 2846 30 2832 33 33 RULES FEDRGIVP RULE 89 23 MISCELLANEOUS SB MOORE FED PRAC23022 41 AM JR AND 58 AM JR WORK AND LABOR 510 41 98 CJS WORK AND LABOR S12 36 PROSSER PRISON TORTS 2D ED 1969 PRISONERS QD AD 1955 34 37 36 UNITED STATES FOR TIFE COURT SIXTH OF APPEALS CIRCUIT NO 711170 CALVIN SIMS RICHARD ALLEN FRANK ROGERS BILLY LEE WALTER LEE BOYD SLAGER PETER GEORGE MILLS LEE WALKER CLEMONT DEDEAUX ORDELL VILBURN WILLIAM CLEARY HERBERT WILLIAMS FRED HOLNAGEL BENNY SPELLS ICENNETH RAYMOND INMAN BAILEY ORCEAN DAVIS JERRY MACK BOYD KELTON THOMAS LORD RALPH WATSON CHESTER PHITJLIP SAWICKI MAGHEE WILLIAMS VERNON RALPH I4EVIS WARNER RONALD TCENNEDY PAUL ROSS HERMAN HEAD GERALD NORMAN PAUL MILLER THOMAS LONNIE MULLIGAN PAYNE ROBERT MASON GAYLORD ESPICH AND KENNETH MARSHALL PLAINTIFFSAPPELLANTS CO CO PARKE DAVIS THE UPJOHN MICHIGAN CORPORATION DELAWARE CORPORATION DEPARTMENT OF CORRECTIONS OF THE STATE OF MICHIGAN ELEANOR HUTZEL JAMES WADWORTR ERNEST BROOKS MAX FIBER JOHN FARL2EY RICE DUANE WATERS FLORENCE CRANE JOSEPH GROSS ROBERT COTTON AND GUS HARRISON DEFENDANTSAPPELLEES APPEAL THE FROM THE DISTRICT COURT OF THE UNITED EASTERN DISTRICT OF MICHIGAN SOUTHERN PARKE BRIEF DAVIS FOR DEFENDANTSAPPELLEES COMPANY AND THE UPJOHN STATES DIVISION COMPANY FOR PRESENTED COUNTERSTATEMENT OF ISSUES C4 WAS THE DISTRICT TI COUNTS IT UNDER THE INMATES OF PLAINTIFF CLASS AS FEDRCIVP COURT CORRECT IN GRANTING WERE NOT WITHIN DRUG COMPANIES LABOR ESTABLISHED DISTRICT COURT CORRECT FOR SUMMARY IN MOTION BECAUSE THE UNCONTROVERTED FACTS INMATES WERE NOT WITHIN ESTABLISHED MEANING MICHIGAN 1964 COURT CORRECT IN GRANTING ON MOTION FOR SUMMARY JUDGMENT III BECAUSE UNDER LAWFULLY CONFINED PRISON OWN THEIR OWN LABOR OF ACTION FOR DAMAGES THE UNCONTROVERTED INMATES IN BY REASON ALLEGEDLY IN DO NOT PRIVATE LOCATED OF CAUSE WORK OF THEIR VIOLATION FACTS MICHIGAN AND DO NOT HAVE TO RESEARCH CLINICS WALLS II THAT OF THE DISTRICT PRISON ON COUNT JUDGMENT THE WAS THE ASSIGNMENT GRANTING OF DEFENDANT DRUG WAGE LAW OF COUNT FAIR EMPLOYEES MINIMUM DEFENDANTS OF THE THE MEANING DEFENDANTS COMPANIES OF DEFENDANT EMPLOYEES ACT STANDARDS WAS THE ON MOTION FOR SUMMARY JUDGMENT INMATES THAT RULINQ BECAUSE UNCONTROVERTED FACTS COUNT TV IN 23 RULE DISTRICT DEFENDANTS III IV CORRECT NOT MAINTAINABLE ARE WAS THE THAT AND III COMPLAINT ACTION COURT WITHIN THE MICHIGAN STATUTE TO PROTECT DESIGNED BY COMPETITION FREE LABOR FROM LABOR PRISON C4 WAS THE DISTRICT DEFENDANTS TO COUNT IV COURT CORRECT MOTION BECAUSE OF TO MICHIGAN LAW RIGHTS CONSTITUTION EVEN INMATES UTILIZATION ANY FOR SUMMARY THEY PROTECTED IN JUDGMENT ASSUMING LABOR SUFFERED BY THE GRANTING THAT AS THE WAS CONTRARY NO DENIAL UNITED STATES OF COUNTERSTATEMENT OF CASE TILE C4 OF THIS FOR PURPOSES PARKE DAVIS APPELLEES INMATES PLAINTIFF ACCEPT THEIR BRIEF FACTS ARE PLANNED CAREFULLY VERY BY THE REQUIRED FEDERAL FOR THE TEST THE TEST EXPERIENCED HIGHLY OF TECHNICAL ASSIGNED PRISON PERFORM VARIOUS JANITORIAL OPERATING 25A PP 36A 58 ET MEDICAL TESTS INMATES TASKS TASKS SEQ ACTUALLY RANGING APP APP COPY ATTACHED INMATES CONDITION ARE VOLUNTEERS HAVE RUN UNDER MICHIGAN TO WORK AT ONLY PERSONNEL DRUG COMPANIES THE OF THE THE SUPERVISION WHO WORK AT PRISON RESEARCH THE COMMISSION CLINICS HAS TO FROM COMMON LABOR SEMITECHNICAL TO EEG MACHINE HEREAFTER ARE THE DRUGS AS AND MONITORED BY DEVELOPED SCIENTIFIC PRISON OF PHYSICAL AND OF THE PERSONNEL JACKSON IN CLINICS ARE OF LAWSUIT OF THE PART UNCONTROVERTED CONSIST CLINICS INMATE IN FORTH REVIEW FOR TESTING THESE SET FOLLOWING AT THE EXCELLENT IN PROGRAMS THE DRUG COMPANIES NOT DEFENDANTS CASE DRUG ADMINISTRATION PROGRAMS AND ARE NO COMPLAINTS COMPANY UPJOHN PRESENTED AND SUPERVISED AND WHO ARE WHO VOLUNTEER ACCEPTED ISSUES RESEARCH CONDUCTED THE THE HOWEVER TO THE RELEVANT THE OF THE STATEMENT ADDITION IN AND UPJOHN OR SIMPLY AND DAVIS PARKE HEREAFTER COMPANY DEFENDANTS ONLY APPEAL WORK BRIEF TO ILAINTIFFSAPPELLANTS SEE BUSINESS ALL THE WEEK JUNE PLAINTIFFS 27 1964 ARE MEMBERS OF THIS IN LATTER ADDITION IN GROUP TO THE THIS LAW SUIT PAY CREDITED SEEK THEY TO THEIR COMPENSATION ACCOUNTS RESPECTIVE LII PRISON BY THE MICHIGAN THE INVOLVED IN AND DETENTION IMPRISONMENT THIS OPERATED WITHIN WALLS OF JACKSON THE PROVIDE CONDITIONS BECAUSE THE CLINIC TIMES PRISON APP THE 112A NEW THE TO BE HIGHLY INMATES ON AT FACILITIES NON 112A EDUCATIONAL RATES WHICH AND IN FOR INMATES THE CLINICS APP HAS BEEN FACT IN TO WORK AT THE HAND MANY OF OTHER REHABILATATIVE HAVE BEEN OPPORTUNITIES CONSIDERED BY THE 112A ASSIGNMENT TO THE RESEARCH WERE PAID COMMISSION FOR COMPARABLE DESIRABLE ON THE ASSIGNMENTS PRISON THEREFORE CLINICS REQUESTED TO BE ASSIGNED CLASSIFICATIONS RESPECTIVE CORRECTIONS ASSIGNMENTS ON MOST OTHER CORRECTIONSCOXNNIISSICN FACILITIES RECREATION TO APP CLINICS DAILY THE RELATIVELY INMATES INMATES FREQUENTLY SPECIFIC STATE THAN ASSIGNMENT BY THE VALUABLE PRISON LOCATED AND GENERALLY GOA OTHER TO RESEARCH THE ARE UPJOHN APP PRISON SPECIAL ENJOY PERSONNEL RESEARCH ARE AND PLAINTIFFS FOR FOOD MORE FREEDOM AND MORE CONTACT WITH BETTER INMATES DAVIS SUPERIOR FACILITIES ASSIGNMENT REGARDED BY PARKE INMATES P41 BRIEF PLAINTIFFS FACILITIES OF ALL BRIEF PROCEEDING WAS LEGAL HEREAFTER APPELLANTS COMMISSION BY THE CORRECTIONS ACCOUNTS AND ARE WORK ON OTHER COMMISSION WERE ESTABLISHED SOMEWHAT HIGHER PRISON ASSIGNMENTS INTO BY THE THAN RATES APPLLLA12A THE THEIR DIRECTOR OF EACH AND ASSIGNMENT TASKS RESPECTIVE PRISON THE ACTUAL WITHIN JACKSON ACTING WITH COMMITTEE APP 109A CLASSIFICATION NAMED INMATES UPJOHN SOME WERE GRANTED BY THE INMATES THE APP DENIED HAVE BEEN HAVE BEEN TO ASSIGNED APP LLOA 124A THEIR PRIOR KNOWLEDGE OR APPROVAL 125A CERTAIN INDEED TASKS FACILITY EXPRESS WHILE WISHES CALL DAVIS AT OF THE ANY TIME 124A REASONS BY THE INSTRUCTIONS AND COULD BE APP 125A COULD REMOVED BE GIVEN 42A LILA TO RESEARCH AGAINST APP THE 124A25A THE HE WAS SUBJECT APPLLOA AUTHORITY TIME WITHOUT OFF TASKS ASSIGNED RESEARCH FACT WERE VETOED BY THE PRISON HIS TO HOURS APP 28A FOR VARIOUS THE APPROVAL APP 124A25A BY THE WITHOUT TO EITHER ASSIGNED BY PRISON AUTHORITY WITHOUT ASSIGNED ADMINISTRATORS ADMINISTRATOR IN BEEN CERTAIN ADMINISTRATORS 29A BEEN OFFICIAL PRISON AND APP BY ANY PRISON AND AND REMOVED HAVE HAD BEEN APPROVAL DAVIS CONVERSELY CLINIC OF FOR REQUESTS BEEN FACILITY AND HE RESEARCH CLINIC HAVE RESEARCH TO THE 39A40A HAVE CLINIC INMATE OR UPJOHN WERE SUBJECT INMATES AND OTHERS ONCE AN PARKE OTHERS THE THE ASSISTANCE RESEARCH CLINICS OF TO MADE BY AUTHORITIES PRISON THE KNOWLEDGE OR APPROVAL PRIOR THE 123A24A 109A IS MADE BY PARKE CERTAIN SOME WERE PRISON OF TREATMENT INMATE EVERY OF THE SPECIFIC FACILITIES AUTHORITY IN DAYTODAY ASSIGNED THE SHORT AS NOTED BY THE DISTRICT SUPERVISION TO THE INSTRUCTIONS RESEARCH AUTHORITY OVERRIDING EXERCISED BY PARKE THEIR AUTHORITY TO INMATES DAVIS FACILITIES OF PRISON COURT THE OR UPJOHN WAS ALWAYS OFFICIALS TO DISAPPROVE THE OF INMATES SUBJECT TO WHO FREQUENTLY DRUG COMPANIE ARGUMENT C4 CO THE THAT ARE II COUNTS AND NOT MAINTAINABLE AS INMATES COULD DEMONSTRATE THAT THE THAT MEMBERS IS NOT THE ACTION CLASS AS SUCH TO THE ACTION THE IS THAT MAKE 26 THE PLAINTIFF ACTION IS OF IS 23 DISTRICT AND THAT THEY THAT TV OF THEIR HAD FAILED TO WAS SATISFIED 23 THAT FEDRCXVP COURT JOINDER OF ALL NOT ITS OF RULE 23 THEIR OF THE HAVE ED 1969 MAINTAINABLE AUTOMATICALLY COMPLAINT TRIAL RULES THE BEEN MEE THRESHHOLD TO ESTABLISH COURT THAT THE AND THAT SEE 3B ALL MOORE RED PRAC REQUIREMENT CLASS ALLEGED IT DESIGNATES COURSE ON THE PLAINTIFFS SATISFACTION THE MEMBERS OF THE JOINDER CLEARLY RULE III OF RULE SO NUMEROUS ONE CONTEMPLATED BY PREREQUISITES 23022 II WAS SIMPLY REQUIREMENT IS UNDER OF THE COUNTS MERELY BECAUSE BURDEN REASONABLE IS ACTION AMENDED COMPLAINT ACTION RULING RULING IN IMPRACTICABLE PLAINTIFFS AS CLASS PURSUE CLASS CORRECT OF PLAINTIFFS IV FOR THE CLASS AS COMPLAINT IE BASIS WAS CLEARLY COURT III THE THE DISTRICT OF RULE BE SO NUMEROUS AS 23 TO IMPRACTICABLE RULING CORRECT INMATES NOT BY THE UNTIL PROVIDE DISTRICT ORAL THE COURT ARGUMENT COURT WITH ON THIS DID COUNSEL ANY HINT WAS POINT FOR AS TO THE SIZE APPROXIMATE OF COMMENT WAS BASED COURT NOTED IN USED TO ESTABLISH TO MAKE MATTHIES OPINION THAT MFG REV ON OTHER GROUNDS CORP THE ORDER SHOULD ACTION PARKE 277 PLAINTIFF WITH LEFT AND CLASS F2D 338 OPEN THE IS DISTRICT CANNOT BE SO NUMEROUS AS 64 THAT 1968 DCONN 1958 1959 OF REVISING DEMONSTRATE BE AFFIRMED THAT ITS THEIR 23 UPJOHN DISTRICT COURTS OF RULE THE LUCAS APP 189A90A 1967 POSSIBILITY LATER CIRCUMSTANCES SURROUNDING 2D CIR DMINN REQUIREMENTS SHOULD THE 2D CIR 836 365 THE SUBMIT THE FRD 23 INMATES RESPECTFULLY ORDER WAS PROPER F2D CO FSUPP COURT COMPLIES DAVIS UNDER 390 270 AS H6WEVER PROSPECTIVE EDENS SEYMOUR SEAGRAVE SPECULATION UPON PURE ITS AND COUNSELS CLASS ALLEGED IMPRACTICABLE JOINDER DEMARCO CITING THE AND IT C4 C4 THE DISTRICT PLAINTTFF OR PARKE STANDARDS FACTS INMATES DAVIS CO WTTHIN THE OF THE COMPANY UPJOHN MEANING OF THE FAIR LAW LABOR ACT THE INTERROGATORIES FOLLOWING THE TN GRANTING MATTER OF THAT EMPLOYEES WERE NOT CORRECT JUDGMENT ON COUNT ESTABLISHED AFTER REVIEWING TO WAS CLEARLY FOR SUMMARY MOTION UNCONFLTOVERTED COURT FACTS HAD BEEN PLEADINGS DISTRICT AFFIDAVITS COURT ESTABLISHED CONCLUDED AND ANSWERS THAT BY UNCONTROVERTED SWORN TESTIMONY NOT THE DRUG OFFICIALS PRISON DECIDE WHICH INMATES WILL COMPANIES WORK IN THE CLINICS AND INMATES HAVE BEEN ASSIGNED TO THE CLINICS DESPITE THE DISAPPROVAL OF THE DRUG COMPANIES NOT THE DRUG PRISON AUTHORITIES DETERMINE WHEN INMATES WILL COMPANIES TO THE BE REMOVED FROM THEIR ASSIGNMENT AND INMATES HAVE BEEN SO CLINICS OF THE REMOVED WITHOUT THE APPROVA THE TASKS DRUG COMPANIES PARTICULAR INMATES IN THE PERFORMED BY WORKING CLINICS MUST BE APPROVED BY PRISON THE HOURS WORKED BY TO THE APPROVAL OF INMATES ARE SUBJECT INMATES WORKING IN PRISON OFFICIALS THE CLINICS MAY BE GIVEN TIME OFF FROM THEIR TASKS BY PRISON OFFICIALS WITHOUT THE CONSENT OR KNOWLEDGE OFDEFENDANT THE INMATES ARE DRUG COMPANIES BY DEFENDANT DRUG COMPANIES SUPERVISED IN THE DAYTODAY PERFORMANCE OF THEIR WORK AT THE CLINICS APP 20JA OFFICIALS 10 THE BASED UPON THOSE COURT RULED THAT EMPLOYEES OF THE C4 FAIR 29 LABOR INDIVIDUAL ACT HAS BEEN OF JUDICIAL EMPLOYEE AND THE WITHIN OFTEN ANY AMENDED AS ISSUE WHETHER FIRM WE THEREFORE UPON WHICH ITSELF THE PARTICULAR INTERPRETATIONS FLSA OF THE FLSA EMPLOYEE OF EMPLOY DISTRICT WERE NOT THE MEANING 20119 PASSAGE OF FLSA LITIGATED THE LAW THE INMATES USC 29 HEREAFTER THE WAS THE OF DRUG COMPANIES 25162 SINCE BODY MATTER STANDARDS USC PERSON AS FACTS UNCONTROVERTED DEFINES OF THE TO RELY AN OR ANOTHER HAVE AVAILABLE EMPLOYER TERMS EMPLOYER GIVEN AS INCLUCLING PERSON ACTING DIRECTLY OR IN THE INTEREST OF AN TO AN EMPLOYEE EMPLOYER IN RELATION INDIRECTLY FTJSA 3D ANY FLSA INDIVIDUAL 3E AND FINALLY TO FLSA SUFFER 3G LITERAL THE ACT 203D EMPLOYEE INCLUDES AN IN USC 29 29 EMPLOYED BY AN USC 203E THE TERM OR 29 USC WOULD ENCOMPASS EMPLOY INCLUDES PERMIT TO WORK OF THE APPLICATION ALL EMPLOYER DEFINITIONS EMPLOYED HUMANITY CONTAINED WALLING THE INMATES CONTENTION THAT THE ESPICH AFFIDAVIT ISSUE OF MATERIAL GENUINE FACT PLAINTIFFS BRIEF PP 1718 IS WITHOUT MERIT AND WAS PROPERLY DISPOSED OF BY THE DISTRICT COURT APP 197A98A THERE IS NO HINT WHATSOEVER IN THE ESPICH AFFIDAVIT AS TO HOW HE ALLEGEDLY OBTAINED PERSONAL KNOWLEDGE OR THE COMPETENCY TO TESTIFY WITH RESPECT TO THE INTERNAL ADMINISTRATIVE OF JACKSON PRISON OR THE REGULATION TERMS OR CONDITIONS OF THE UPJOHNPARKE DAVIS WITH RELATIONSHIP THE PRISON AUTHORITY APP 178A79A PRESENTED 11 SAND THEREFORE TEST 33 1961 1963 THE MORE IS EXPRESSED NOT IS THE IN DICTATE THE PARKE CLASSIFY THE RESEARCH CLINICS IGNORE INCARCERATED MICHIGAN PARKE DAVIS OF PARKE WHAT DOES AND UPJOHN AND REALITY THEIR TO PA SUPP 835 83 CONTROL ECONOMIC APPEARS ECPRESS OF PARKE WHOSE LABOR REALITY TO BE PERSONNEL WHILE AND ANY WITH TIME OR XMPLXED OR UPJOHN SO ASSIGNED WITHIN 12 CANNOT THE IS IS TO OF RESEARCH CONTROLLED ONLY WITHIN OF MICHIGAN WHO CANNOT WHOM THERE STATE WHO ARE BY THE STATE TO THE LAWFULLY TO DEFENDANTS STATE OR CONSENT AT OR UPJOHN TO THE BELONGS TO AUTHORITY PRISON DAVIS HERE THAT SUBMIT COMMON SENSE THE BY SITUATION COMMON SENSE KNOWLEDGE STATE THE OF BY THE DEFY ESTABLISHED OR UPJOHN DAVIS EM SITUATION THE RESPECTFULLY ASSIGNED EMPLOYEES OR UPJOHN COMPENSATXON 130 28 154 148 RATHER CASE HELP AS BE REMOVED BY THE DAVIS BUT REALITY INSTANT FRAMEWORK OF RULES PARKE US 366 OF THE ECONOMIC WHO MAY BE ASSIGNED DAVIS INC FURTHER YARDSTICK PRISONERS WITHOUT CLINICS THE INMATE ECONOMIC REALITY COMMON SENSE WHAT IS INVOLVED ECONOMIC CC REALITIES POINT ON OPINIONS SUPP 217 ECONOMIC ABSOLUTE AZI GOOPERATIVE COURTS AND FOR APPLICATION TESTS TERMS OF IN TECHNICALITITES LEGAL FOR PLAIN SYNONYM 1943 JUDICIAL NORTHWESTERN KITE 1955 THAN RECENT SILBERTSON MITCHELL RATHER HOUSE WIRTZ MINN TEST IN WHITAKER GOLDBERG GTHCIR 21 DEVELOPED MORE MEANINGFUL HAVE PROPER FAD 72 136 ISSUE TO THIS THE AL ET BE FIRED BY THE WHO MAY BY NO AGREEMENT FOR POSSIBLY MEANING OF THE BE EMPLOYEES ELSA FACTORS MANY C4 C4 IN VARIOUS WHICH CASES BE CONSIDERED IN PERSONS THE AL ND QUESTION EMPLOYEES BY THE COURT WHO HAS THE RETAIL INC BREUER 1945 IN SALESMEN ET THESE AND HIRE AL AL ET OF BEER TRUCKS OR WHETHER HIRED WHO ACTUALLY FACTORS FIRE LC 10 THE PAR WHICH INVOLVED WERE THE THEY AND OF SUPRA SANDERS WALLING DISTRIBUTOR BEER TO SANDERS OF WHETHER DRIVERS OF THE OF OF STATUS EMPLOYMENT RIGHT WA1LIN ELMER OHIO THE THE MOST IMPORTANT QUESTION VAN 1LEEET 62826 IS ALL EMPLOYEE ISSUE DETERMINING INDIVIDUALS PARTICULAR TO IN AND DISCUSSED SUGGESTED THIS INVOLVING RELEVANT ARE BEEN HAVE WERE EMPLOYED PAID THEM THIS STATED THE IN COMMON THE EXPERIENCE IS TO ASCERTAIN WHO HAS EMPLOYER ON HIS OWN ACCOUNT TO HIRE AUTHORITY AND FIRE 136 AT 81 USUAL TEST BY WHICH MEN DETERMINE AFTER RULING EMPLOYED THE THAT BY THE DEFINITIONS AS MATTER OF DISTRIBUTOR PROVIDED IN THE THE IN LAW COURT ACT AS THE DRIVERS WENT ON TO COMMENT ON FOLLOWS THE WORD SO BROADLY DEFINING CONGRESS UNDOUBTEDLY HAD COMPLAINANTS PURPOSE TO RELIEVE OF THE NECESSITY OF PROVING THE CONTRACT OF EMPLOYMENT ADMINISTRATOR DESIRES US TO CONSTRUE EMPLOYEES SO AS TO INCLUDE NOT ONLY THOSE WHO WORK FOR AN ACCUSED EMPLOYER BUT ALSO THOSE WHO WORK THIS FOR ANYBODY ELSE MANIFESTLY WOULD ENCOMPASS ALL EMPLOYED 137 F2D AT 91 HUMANITY EMPLOY 13 WERE NOT IN C4 HAVE THE NEITHER INMATES ASSIGNED BY THE OR KNOWLEDGE INMATES THE BY HAVE NOR THE RIGHT STATE INMATES HAVE OF PARKE INMATE UPJOHN HAD REQUESTED UPJOHN ASSIGNMENT CLEARLY RIGHT OR POWER TO HIRE OR THIS THE MOST COMMON TEST INMATES THE IN ET IN THE DAYTODAY TO THE RESEARCH CLINICS DUTIES THE AND INSTITUTIONAL ON THE HAVE NO JUDGED BY DO NOT EMPLOY INMATES OR UPJOHN AN ELSEWHERE AND UPJOHN THE CONTROL AL SIMPLY AS THAT TERM IS SUBJECT TO APPROVAL SUBJECT OFFICIALS EVEN THE DAVIS STRICT IS OF THE WHICH CALLS OR OF UPJOHN THE AUTHORITY BY FREQUCNT MUST ASSIGNED THE VARIOUS DAVIS DIRECTION PRISON SUPRA LIMITS OR UPJOHN BY PARKE ROUTINE TNC INMATES TASKS VERY TO INTERRUPTION 14 FORCE WORKING DREUER OF THEIR ESTABLISHED THE BY NO MEANS CONCLUSIVE ARE WITHIN BUT IS OF ELMER BASIS PERFORMANCE PERSONNEL DRUG COMPANIES DAVIS PERFORMANCE ARE NECESSARILY ALWAYS PERSONNEL CONVICTS THE CLINICS THE PRIOR REMAINED DAVIS TO ASSIGNED WITHOUT THE PRIOR ASSIGNED THESE AND CONTROLLED BY PARKE ROUTINE IS FIRE FACTOR ALTHOUGH VAN FLEE DIRECTED PARKE OF PARKE DIRECTION RELEVANT SEE BEEN OR UPJOHN BE REMOVED THE FLSA THE ALSO TO ASSIGNED EMPLOYEES WERE NOT USED DAVIS UPJOHN TO FIRE OR UPJOHN WHO WERE REQUESTED HAVE BEEN INMATES THE DAVIS REMOVED FROM ASSIGNMENTS BEEN AND OF TREATMENT WITHOUT OF PARKE OR APPROVAL KNOWLEDGE DAVIS TO HIRE DIRECTOR APPROVAL PARKE SITUATION THE RIGHT CLINICS THE INSTANT INMATES AND CALLS BE HONORED ON FROM THIS C4 FURTHER ARE APPELLANTS THE EMPHASIZES OF INMATES STATE SITUATION OF THE REALITY WHO ARE PRISON UNDER LII THESE MEN ARE NOT IS AND ANY THE BY THE TRUSTY PRISON INMATES CONTROL LIMITED COMPLETELY THE CONTROL ARE BY THE OF JACKSON THEREFORE DAVIS RULES EVEN PRISON AUTHORITY WORK DETERMINATION THE WALLS OR PARKE BY UPJOHN ASSIGNED NOR ON OUTSIDE HAS MADE THE WITHIN BY PRISON AUTHORITY PRISON DIVISION AUTHORITY MEN MUST BE CONFINED THESE PRISON IN THE ASSIGNMENTS THAT AND DIRECTION CONSTANT THE HOURS DURING TO THE CLINICS MOREOVER THE HOURS DURING WORK ARE IS WITH THE CHARGED AND ASSIGNMENT INMATE IT IS DISAPPROVED CLEAR THAT PARKE ASSIGNED TO INSIDE WARDEN WHO DEPUTY HOURS OF PARTICULAR JOB OF AN CLINIC UPJOHN BY THE PRISON WITHIN THE THE AND MAY DISAPPROVED RESEARCH DAVIS AN INMATE CUSTODY OF INMATES AND ONCE HE HAS WHO WAS ASSIGNED INMATES THE HAS BY THE SECURITY MORE THAN PRISON THE TO APPROVAL SUBJECT WHICH IN DIRECT IN AUTHORITY SHORT AND CONTROL ONLY VERY NARROW SENSE ANOTHER FACTOR OF WAGES OR OTHER COMPRISED PAY IF IE ANYONE OF TWO IS ASPECTS ACTUALLY FIRST IS WAGE LIABILITY MAKES THE WITH THESE INVOLVES THIS COMPENSATION THERE DEALING OF IMPORTANCE FACTOR THERE AT PAYMENTS ASPECTS 15 IN IS THE PAYMENT REALLY TO ANY OBLIGATION ALL AND SECOND WHO FOR WORK PERFORMED THAT ORDER IT IS CLEAR THAT TO LIABILITY AFFINGEM I8 UNDER INMATES WITH THE FOR LABOR STATE 1901 NA1OB4 WARDEN OF JACKSON THE PRISON FOR USED IN THE MANUFACTURING PRISON PLAINTIFF ON 576 HE DAYS HAD BEEN MICHIGAN IN OF LAW MICHIGAN IN DEFENDANT THE HOLDING HIS THE SUIT DEFENDANT IF THE PROMISE OF CONVICTS 300 AFTER INCARCERATED FOR THE CONTRACT WITH HAD LABOR HIS VALUE ON THE THE THE TO BE RELEASE FROM OF HIS SERVICES ALLEGATION SUPREME COURT STATED LAW RAISES AN UNPLXCATION OF TO PAY PLAINTIFF FOR THESE IT CANNOT BE AN IMPLICATION SERVICES OF FACT BUT FICTION IT IS CLEAR THAT DEFENDANTS HAD NO THOUGHT OF SERVICES FROM PLAINTIFF TO ACCEPTING BE COMPENSATED IN ANY OTHER WAY THAN UNDER THEIR EXPRESS CONTRACT WITH THE WARDEN IT IS SAID IN SOME CASES WHERE THE DEFENDANT IS GUILTY OF WRONG THAT THE LAW WILL RECOGNIZE AN OR MORE ACCURATELY SPEAKING IMPLIED CONTRACT AND ENFORCE CONSTRUCTIVE IT CITATION OMITTED BUT WHERE ALL THE CIRCUMSTANCES IMPLICATION REPEL OF IN PROMISE FACT THE LAW WILL NOT IMPLY PROMISE UNLESS SOMETHING HAS OF BEEN DONE ON WHICH AN IMPLICATION PROMISE CAN BE RESTED AS IN THE CASE OF SALE OF PERSONAL PROPERTY BY TORT FEASOR WHO THEN BECAME LIABLE TO FOR MONEY HAD AND RECEIVED AN ACTION THESE DEFENDANTS CITATION OMITTED WITH THIRD CONTRACTED PARTY FOR LABORERS UNDER SUCH CONTRACT THE THIRD CERTAIN LABORERS PARTY FURNISHED THE AMONG THEM THE PLAINTIFF DEFENDANTS PAID TO THE THIRD PARTY THE CONTRACT PRICE FOR THE LABOR SO SUPPLIED NO CONTRACT RELATIONS EXISTED BETWEEN THE TO THIS SUIT THERE WAS NO PARTIES 16 MICH BRONK 126 THOMPSON SUED DEFENDANT FOR UNLAWFULLY BY THEM UNDER PERFORMED OF SHIRTS LABOR BASING PARTY HAS NO PRIVATE THAT OF THEM THEY WERE NOT COMING TOGETHER CONSENTING BARGAINERS MANIFESTED BY IN CONTRACT RELATIONS CONDUCT ACT OR SOME INTELLIGIBLE WHOLE TRANSACTION WAS AND THE SIGN BROUGHT ABOUT AND ACCOUNTED FOR BY CIRCUMSTANCES REPELLING EVERY POSSIBLE OF CONTRACT RELATIONS IMPLICATION 127 MICH AT 45657 BETWEEN PRIVITY C4 IN DNH THE 1945 COURT THAT HOLDING WITH THE THEY THE ISSUE CITY OF CO NOT SUPP 62 1ST CIR F2D OF WHETHER CERTAIN NASHUA BUT WERE EMPLOYEES PREMISES WERE MFG 154 DISMISSED BY DEFENDANTS PROTECT IN WAS FACED NASHUA AL APPEAL AND TRAINED HIRED ET DUGAS THE ASSIGNED 1946 GUARDS TO OF DEFENDANT NOTED COURT 846 THATT THE PURPOSES AND AIMS OF THE IRAIR AND STANDARDS ACT ARE SOCIAL REMEDIAL IT WAS NET ITS PURPOSE TO BUT CREATE NEW WAGE LIABILITIES WHERE SUCH IITHTED TO MEASURE THEM BY THE STANDARDS FIXED BY 62 SUPP AT 849 EMPHASIS ADDED LABOR LAW UPJOHN ACT IS AND PARKE INAPPLICABLE TO WOULD BE TO CREATE AL GLENDALE FERR CO WHERE THE MFG SUBMIT RESPECTFULLY CO SUP 132 WALLING F2D WHERE NONE EXISTED SEE ALSO 616 AN EMPLOYEE AS ANY INDIVIDUAL EMPLOYED BY AN EMPLOYER AND THE WORD EMPLOY AS USED IN THE TO SUFFER OR PERMIT TO ACT INCLUDES WORK BUT SINCE THE OBVIOUS PURPOSE OF THE ACT IS TO ESTABLISH 17 HELENA 8TH CIT COURT NOTED THE ACT DEFINES THAT THE TO HOLD OTHERWISE INSTANTSITFLATIOFL NEW WAGE LIABILITY NASHUA DUGAS ET THE DAVIS 1942 MINIMUM WAGES AND MAXIMUM HOURS THE WORDS LAST QUOTED CANNOT BE TO INCLUDE AS AN EMPLOYEE INTERPRETED ONE OVER WHOSE HOURS OF LABOR THE ERFLPLOSER HAS NO CONTROL AND TO WHOM THE EMPLOYER IS UNDER NO TO 132 F2D AT 620 WAGES PAY 6BLI ADDED EMPHASIS THE TRAINEES JUSTICE ASSIGNED FOR THE STATES TO WHOM THE ANY PAYMENTS PORTLAND UNITED SUPREME ALLEGED COURT TERMINAL CO 330 US 148 THE OPINION CLEARLY INDICATES TO THE CLINICS ARE NOT COVERED REASONS EXPRESSED IN FLSA 1947 BLACKS VERY THAT HAD NOT EXPECTED EMPLOYER COULD NOT RECOVER UNDER HAS RULED BY THE PORTLAND WALL LANGUAGE THAT TO MAKE THE FLSA FROM INMATES IN PART TERMINAL 3G SECTION OF THE ACT DEFINES EMPLOY AS INCLUDING TO SUFFER OR PERMIT TO WORK AND DEFINES EMPLOYEE AS ANY INDIVIDUAL THE EMPLOYED BY AN EMPLOYER DEFINITION SUFFER OR PERMIT TO WORK WAS NOT INTENDED TO STAMP ALL PERSONS OBVIOUSLY AS EMPLOYEES WHO WITHOUT ANY EXPRESS OR IMPLIED COMPENSATION AGREEMENT MIGHT WORK FOR THEIR OWN ADVANTAGE ON THE PREMISES OF ANOTHER OTHERWISE ALL STUDENTS WOULD BE EMPLOYEES OF THE SCHOOL OR COLLEGE THEY AND AS SUCH ENTITLED TO RECEIVE ATTENDED MINIMUM WAGES SO ALSO SUCH CONSTRUCTION WOULD SWEEP UNDER THE ACT EACH PERSON WHO WITHOUT PROMISE OR EXPECTATION OF COMPENSATION BUT SOLELY FOR HIS PERSONAL PURPOSE OR WORKED IN ACTIVITIES CARRIED PLEASURE ON BY OTHER PERSONS EITHER FOR THEIR PLEASURE OR BUT THERE IS NO INDICATION FROM THE PROFIT LEGISLATION NOW BEFORE US THAT CONGRESS INTENDED TO OUTLAW SUCH RELATIONSHIPS AS THESE THE ACTS THAT EVERY PURPOSE AS TO WAGES WAS TO INSURE PERSON WHOSE EMPLOYXNENT CONTEMPLATED SHOULD NOT BE COMPELLED TO SET HIS SERVICES FOR LESS THAN THE PRESCRIBED MINIMUM WAGE THE DEFINITIONS OF EMPLOY AND OF EMPLOYEE ARE BROAD ENOUGH TO ACCOMPLISH THIS BUT BROAD AS THEY ARE THEY CANNOT BE INTERPRETED SO AS TO MAKE WHOSE WORK HIS SERVES OWN PERSON ONLY INTEREST AN EMPLOYEE OF ANOTHER PERSON WHO GIVES HIM AID AND INSTRUCTION 330 AT 152 3E COMG US EMPHASIS ADDED 18 COUNSEL DEFENDANTS C4 REPORTED CASES PRISONERS 65 LC HUDQINS 32 MARCH ETBLA HART HUDGINS THE WITH FLSA STATE AND DURING SUMMARY WHO VOLUNTEERED SOUGHT THREE 17000 YEAR JUDGMENT PERIOD THE COURT INMATE AN TO PLASMA 1948 REMARKABLY OF PERFORM FOR DEFENDANTS ALLEGED MINIMUM IN WD MICH HUDGINS BLOOD ILUDGINS IN AL WAS ASSIGNED OF EXTRACTING BUSINESS INVOLVED SITUATION INVOLVED DUTIES CLERICAL FAR COPY ATTACHED 110 PLAINTIFF TWO ONLY ET 1971 SUPP AL HAND THUS HART 18 79 ET THAT FLSA PENITENTIARY AND TECHNICAL THEIR INMATES ONE AT TO THE LOUISIANA CERTAIN THE AS PLAINTIFFS GUNN FURNITURE HUNTLEY SIMILAR UNDER ARISING BELIEVES IN CONNECTION FROM OTHER OF THE VIOLATION WAGES FOR WORK PERFORMED GRANTING DEFONDANTS MOTION CORMNENTED THERE WAS NO CONTRACTUAL AGREEXFLEFLT ORAL OR WRITTEN BETWEEN THE INMATE AND EITHER OF THE DEFENDANTS PLAINTIFF NO EMPLOYEREMPLOYEE THERE WAS SIMPLY BETWEEN ANY OF THESE PARTIES RELATIONSHIP IN THIS CASE ALL CONTRACTUAL ARRANGEMENTS AND THE DEFENDANTS HYLAND WERE BETWEEN STATE PENITENTIARY HART AND THE LOUISIANA OF CORRECTIONS AND THE LOUISIANA DEPARTMENT AT THE THE PLAINTIFF WAS AN INMATE LABOR AND AS SUCH HIS PENITENTIARY IT WAS THE BELONGED TO THE PENITENTIARY THAT HIM TO WORK FOR PENITENTIARY ASSIGNED IT WAS THE AND ANDOR HART HYLAND THAT DECIDED WHAT DYLAND ANDOR PENITENTIARY FOR THAT HART WOULD PAY TO THE PENITENTIARY LABOR THE FACT THAT THE PENITENTIARY ALL OR PART OF THE MONEY PAID BY DEPOSITED OF HYLAND ANDOR HART FOR THE SERVICES DOES THE ACCOUNT OF THE INMATE TO PLAINTIFF NOT MAKE THE PLAINTIFF AN EMPLOYEE OF THE IN ORIGINAL DEFENDANTS EMPHASIS 19 67 FOR IN FOLLOWED BY THE DISTRICT CONRT JACKSON THE AND MATERIALS THE THE THE PROJECT WERE SELECTED DIEM ASSUMING FOR PURPOSES THE LAW THE INMATES THE WERE NOT STATE EMPLOYEES INMATES WHO WERE DEFENDANT THE INMATES OF ARGUMENT LABOR THE COURT CONCLUDED PRISON THE OF STATE ASSIGNED FOR TO AUTHORITY PRISON APPLICABLE OF EQUIPMENT REIMBURSED THE STATE AND ASSEMBLIES DEFENDANT COMPENSATION BY THE THE EMPLOYEES AND INVOLVED INMATES NOT COMPLY WITH PRISON OF WAS AN THE GOVERNMENT THE BY THE LHE WITH WITH THE AUTHORITY PRISON WOULD SUPPLY OF AND UTILITIES PER TO SUPERVISION SUPERVISED PAID SOLD IT AND AND BY DEFENDANT PLANT CONTRACTOR THE WHICH CASING TURN DID BY THE ASSIGNED CITED WERE INMATES PLAINTIFFS STAMPING ET AL FOR THE MANUFACTURE OF PARTS WORKED UNDER ALSO CASE PRISON HART HUDGINS WHO HAD BEEN WHEREBY MICHIGAN IN THIS SUPRA CONTRACTOR WHO HAD AN ARRANGEMENT OUTSIDE SHELL IN COURT IN PRISON TO WORK IN GUNN RURNITURE HDNTLEY THAT THE REGULATIONS THAT DEALING MATTER OF AS OF THE ARRANGEMENT DEFENDANT CONTRACTOR THE IN HUNTL ALMOST THE IDENTICAL INMATES PARKE ASSIGNED FRIVOLOUS NATURE AND PARKE OF THE DISTRICT DAVIS COURT SU AND AND UPJOHN THE INSTANB INMATES RESPECTFULLY ON COUNT AFFIRMED 20 IN OFFICIALS PRISON OF THE OF UART HUDGINS DAVIS BY THE REALITIES UPJOHN BE IN CUNN FURNITURE THE THE CIRCUMSTANCES THIS DO NOT SITUATION SUBMIT AL SUPRA CASE THAT INMATES ARE EMPLOY TO THE ALLEGATIONS OF THE ET CLINICS MAKE AND THE CLEAR THEORIES JUDGMENT COMPLAINT MUST ITT C4 DISTRICT THE INMATES COMPLAINT THAT INMATES THE OR THE JUDGP FOR SUNNARY MOTION DEFENDANTS CORRECT COURT WAS CLEARLY THE ON COUNT UNCONTROVERTED EMPLOYEES WERE NOT UPJOHN COMPANY WITHIN THE GRANTING II OF THE ESTABLISHED FACTS OF PARKF MEANING TN DAVIS OF THE COMPANY MICHIGAN MINIMUM WAGE LAW OF 1964 DEFINITION THE THE MICHIGAN THAT SET MINIMUM FORTH IN CD PERMIT PLCL THE WAGE CONSTRUED IS THE FAIR ENACTED ACT ONE OF AND MSA THE ECONOMIC MICH 289 293 134 354 MICH 695 699 94 SECURITY COMMISSION 1968 AND REMEDIAL SOCIAL SINCE 15 THE MICH COMPENSATION ACT 1965 APP 96 99101 TEST AND THE 166 UNDER APPLICABLE 21 DEVELOPED EMPLOYMENT THE TEST THE EMPLOYMENT WAGE LAW OF 1964 THE WORKMENS MUSKOVITZ TATA IS NW2D 530 ALSO UNDER SECURITY OF THE JUDICIALLY ERICKSON GOODCHILD FOSTER MINIMUM IN CONTAINED MICHIGANS 1959 71 NW2D OR ACT HOWEVER SECURITY 191 NW2D LEGISLATION WOULD SEEM EQUALLY UNDER TO IDENTICAL NEVER BEEN HAVE IN 2HD 17255 DEFINITIONS REALITY FORTH ACT ENGAGE SUFFER TO EMPLOYMENT SET ALMOST IS STANDARDS 1964 IN EMPLOY OF 1964 REPORTED DECISION 375 WORKMENS CI 408382 TERM LABOR EMPLOY MEANS TO WORK LAW IN COMPENSATION TEST WAGE LAW COURT NOTED THAT DISTRICT MINIMUM OF THE THE ACT ECONOMIC REATITY HOWEVER APPELLANTINMATES EMPLOYEES OF PARKE ECONOMIC OF TEST SAXNE URGE THAT IN EXTENDED THE BY THE FAIR THE OF THE MICHIGAN SLACK CONSIDERATION INTO WORD EMPLOYEE AND WOULD BE THAN BROADLY THIS FEDERAL IN THE LAW SHOULD ACT WHICH TO TAKE THE REASON THAT OF THE COURTS LEGISLATION MORE EVEN PLAINTIFFS BRIEF IS CITATION IN NOT FOUND ARE UP BE INTERPRETED RESTRICTIONS VARIOUS MICHIGAN EMPLOYEES PERFORMING EMPLOYER THEIR 408382B MOREOVER PREMIUM THE PAY STATE 65 AGE AT TOTALLY COVERAGE IN THE MSA IS SUCH AS 22 TO INAPPLICABLE AND IS LOCATIONS SITE FIXED ACT IS ACT DUTIES OR PREMISES MCL STATE OR OVER AGE 18 UNDER EMPLOYERS THE EXAMPLE EMPLOYEES OVERTIME NATURE WITHOUT SUPPORTING IGNORES FOR BECAUSE ACT ACT FOR THE AND LAW FEDERAL ADVANCED AND MERIT CONTAINED THE UNDER WAS MICHIGAN BE RELATIONSHIPS ACT APPLY STATE TO WHICH APPELLANT STANDARDS REMEDIAL BY THE INTERPRETED ARGUMENT WITHOUT THE THE IN THE LABOR LAW DOES NOT WHERE FEDERAL TAKING THE INTENTION ACT WAGE LAW SHOULD BEYOND SOUGHT TO BE COVERED CLEAR PROBLEM MINIMUM MICHIGAN FORTH SET APPLICABLE THIS AND COVERAGE SCOPE IS REALITY DEEMED REASONS STANDARDS LABOR RECOGNIZING APPARENTLY INMATES FAIR BE FOR THE OR UPJOHN RESPECT TO THE ABOVE WITH THE DAVIS CANNOT TO INAPPLICABLE OTHER DESIGNATED THAN ON BY THE 17255 CONTAINS FOUND IN NO PROVISION THE FAIR LABOR FOR STANDARDS ACT FRSA C4 ONLY ONE DECISION STATUS OF AN INMATE DICE 523 HOARD JAIL HAVING BEEN AT MINIMUM MINIMUM TO 45 DICE RELEASE WAGE LAWS OF THE FOR THE COURT AFFIRMED OF THE CLAIM FILED STATE CONFINEMENT DAYS HE PERFORMED SUGGESTION 178 KAN COUNTY ON CERTAIN SUM OF UNDER 200 PER THE KANSAS COURTS DENIAL TRIAL THE COUNTY IN PRISONER THE LAW WAGE OF COFFEY WAS WORK ON COUNTY BUILDINGS UPON HIS DAY DICE WITH FOUND DEALING COMMISSIONERS SENTENCED HIS BEEN STATE 1955 782 MISDEMEANOR CARPENTRY UNDER OF COUNTY P2D 289 HAS OF RECOVERY WE THINK THE ENACTMENT OF OUR MINIMUM THAT WAGE LAWTHE LEGISLATURE EVER INTENDED SITUATION THAT IT SHOULD APPLY TO SUCH AS WE HAVE HERE NO GOOD PURPOSE WOULD BE SERVED BY SETTING OUT ITS PROVISIONS OR DISCUSSING WE SIMPLY HOLD THEM IN THAT THE MINIMUM WAGE LAW HAS NO TO CONTRACT OF APPLICATION SUCH AS WE HAVE IN THIS EMPLOYMENT 289 P2D AT 784 CASE IN IT MAY NOT BE SAID DETAIL PARKE DAVIS COMPANY RESPECTFULLY SUBMIT WITH TO COUNT TI RESPECT CLEARLYCORRECT THAT THE OF AND THE JUDGMENT APPELLANT AND MUST BE AFFIRMED 23 UPJOHN OF THE INMATES COMPANY DISTRICT COURT COMPLAINT WAS IV THE DISTRICT COURT WAS CLEARLY CORRECT GRANTING DEFENDANTS MOTION FOR SUMMARY JUDGMENT ON COUNT III AND TN CONCLUDING THAT LAWFULLY CONFINED PRISON INMATES IN MICHIGAN DO NOT OWN THEIR OWN LABOR AND DO NOT HAVE PRIVATE CAUSE OF ACTION FOR DAMAGES BY REASON OF THEIR WORK ASSIGNMENT TO RESEARCH CLINICS LOCATED WITUIN THE PRISON WALLS ALLEGEDLY TN VIOLATION OF MICHIGAN STATUTE DESIGNED TO PROTECT FREE LABOR FROM COMPETITION FLY PRISON LABOR IN SUMMARY OF ARGUMENT PLAINTIFFS AMENDED COMPLAINT COMMON LAW CAUSE OF THEIR LABOR MICHIGAN PRISON 281521 BOILS DOWN TO OF ACTION INDUSTRIES THAT CLAIM VIOLATION ACT SECTION TO COUNT III RESPECT FOR DAMAGES IN ALLEGEDLY JJ ET WITH THEORY THAT THEY BY REASON OF MCIJ IN PROVIDES THE HAVE PRIVATE OF THE UTILIZATION SECTION 800301 OF OF THE SEQ ET PERTINENT FORMER MSA AS PART FOLLOWS NOR SHALL THE OF PRISONERS BE CONTRACTED FOR OR OTHERWISE USED FOR PRIVATE OR CORPORATE PROFIT OR FOR ANY OTHER PURPOSE THAN THE MAINTENANCE OF OPERATION OF CONSTRUCTION PUBLIC WORKS WAYS OR PROPERTY AS DIRECTED BY THE GOVERNOR SOLD HIRED MCL THE MENT TO THE ILLEGALLY LOANED INMATES RESEARCH CLINICS THEY LABOR MSA 800305 PLAINTIFF THUS WAS ILLEGAL PERSONS LEASED CONTEND THAT WAS PROHIBITED FURTHER COMPELLED 281525 CLAIM THAT TO WORK ARE 24 THEIR UNDER UNDER ENTITLED WORK ASSIGN THE ACT THE TO AND COMMON DAMAGES LAW MEASURED BY THE TORT OR ON AN REASONABLE VALUE CONTRACT IMPLIED OF THE LABOR EITHER ON THEORY LII THIS COMMON LAW PROPOSITION CASE INSTANT THERE OF THE RIGHTS IN DAMAGED PLAINTIFF ANY NO INVASION OF ANY AND PLAINTIFFS INMATES TO THE INAPPLICABLE PERSONAL HAVE NOT BEEN WAY ARGUMENT APPEARS TO BE FOLLOWS CONVICTED JACKSON PRISON OF THE RESEARCH PRISON THEIR LABOR 30 THE UTILIZATION CANNOT THE STATUTORY OF INMATE THEM MICHIGANS RIGHT WORKING INCLUDING PLEASE TO WHICH LABOR AT COMPENSATION THAT HAS RIGHT PLAINTIFFS INDUSTRIES AT THE UNDERLYING CLINICS BE TAKEN BRIEF ACT PRISON PROHIBITS CONSTITUTIONAL OR TO THE AWAY FROM THEM FRUITS IN CLINICS RESEARCH TO RIGHT OF SUCH WORK VIEW OF THE PROHIBITION THUST RECE CONSTITUTIONAL PRISON MICHIGAN RESEARCH LAWFULLY AND HAVE AND TO RECEIVE AWAY FROM PLAINTIFFS WORK AT IN 46 AND 31 IMPRISONED AS THEY CLINICS TAKEN LAWFULLY PAGES LABOR EXCEPT TO THE EXTENT THEREFOR BEEN FELONS OWN THEIR TO DISPOSE THE BEEN ESSENCE OF PLAINTIFFS THE AS HAS IS COMPENSATION PLAINTIFFS HAVE FOR WORK PROHIBITED 25 CONSTITUTIONAL BY THE RIGHT STATUTE TO WORK AT RESEARCH CLINICS THE AS IF INMATES WERE NOT PRISON THEY C4 THIS LAW IN NO CASE AT DEFENDANTS THE ONTSET IT THE EMPHATICALLY TO OF AVOID FOR PURPOSES ONLY APPEAL SHOULD THAT THERE TO BE APPEARS THAT DENY IS BE MADE VERY PLAINTIFFS THAT THAT INDUSTRIES ISSUES FACT DEFENDANTS MOTION FOR SUMMARY JUDGMENT THAT WORK ASSIGNMENTS ASSUME AND THIS VIOLATION IN ARE THAT HOWEVER OF THEIR THE THAT PRISON INVOLVE MIGHT PROBLEM PROCEDURAL THE RECOGNIZER ISSUE LEGAL CLEAR WORK ASSIGNMENT OF VIOLATION IN DEFENDANT DRUG COMPANIES DETERMINATION SOLELY NOVEL SO POINT RESEARCH CLINICS TO THE ACT IS THEORY OF THE ACT DEFENDANTS CONVICTED SUBMIT IN INMATES PRISON ALL THAT THE LABOR OF LAWFULLY BELONGS MICHIGAN OF THEIR TO THE BY NECESSARY IMPLICATION PURSUANT TO STATUTORY MANDATE WORK REMAINS DURING THE PERIOD OF LAWFUL AND EFFECT OF THE PRISON TO RIGHT THE PRINCIPAL PURPOSE WAS TO PROTECT NOT TO THEIR THE RETURN LABOR RIGHT TO DISPOSE BEING IN FREE TO PRISON THE TO THEIR OF THEIR EXPRESSLY LABOR RESIDUE FROM COMPETITION INMATES THE PROSCRIBED AREA OWN LABOR LABOR SUBJECT NOT AS THEY TO BE PUT 26 OF PLEASE TO HARD INCARCERATXON INDUSTRIES TO THE AND THE ACT LABOR DISPOSE OR TO LIMIT HAVING FORMER THEIR BY PRISON RIGHT OF LOSS OF UNDERLYING ON THE LABOR OF AND CONFINEMENT MICHIGAN NO STATE RIGHT CONTRARY AS PART OF THEIR THE IMPRISONMENT INJURED IN CLINICS EVEN WITHOUT INJURY DAMAGES EITHER IN ANY WAY BY THEIR THAT IF ON IN PRISON JACKSON CONFINEMENT TO THE THEM BY THE COFFIN COURT OF ALL TO DISPOSE THIS THE RESERACH THAT LAW TO MICHIGAN CONTRACT INMATES ENTITLED TO THEORY CONFINED PRISONERS CONFINED THE TO OF MICHIGAN THEIR OPPORTUNITY AND CONSEQUENTLY OF OF THEIR LABOR AS PLEASE THEY EXCEPT RIGHT MAY BE WAS RECOGNIZED BY THIS OPPORTUNITY STATE GENERAL PROPOSITION REICHARD STATED AT ARE BY NECESSARY IMPLICATION EXTENT TO WHICH GRANTED IN OR IMPLIED CONVICTED DEPRIVED RIQHT BEEN ARE NOT CLEARLY THE LABOR OF LAWFULLY TO THE STATE OF MICHIGAN LAWFULLY NOT WAS CONTRARY THUS TORT HAVE WORK ASSIGNMENT ASSIGNMENT PLAINTIFFS INMATES MICHIGAN I3ELONGS THE PLAINTIFF F2D 143 443 6TH CIR 1944 COURT WHICH IN THIS AT 445 PRISONER RETAINS ALL THE RIGHTS OF AN CITIZEN ORDINARY EXCEPT THOSE EXPRESSLY OR BY NECESSARY IMPLICATION TAKEN FROM HIM EMPHASIS BY ADDED LAW IN TO HIS THE TO LABOR ADDITION IS LOSS OF THEIR THE LABOR OF THE TO DETERMINE RIGHT PRISON THEIR BY PRISON AS THEY PRISONERS COVERED SPECIFICALLY POWER AND DUTY WORK AND HOWEVER SEE FIT BY STATUTE COMMISSION COMPENSATION INMATES WHITE 27 NOT IN LOSS OF HIS IN RIGHT MICHIGAN TO COMPEL AND THE PRISONERS CORRESPONDING TO WORK OR TO DISPOSE PRISON ARE CLEARLY SET OF OUT IN SECTION OF THE PRISON INDUSTRIES ACT AS FOLLOWS C4 CO IL SHALL BE THE DUTY OF THE PRISON COM MISSION TO PROVIDE AS FULLY AS PRACTICABLE FOR THE EMPLOYMENT OF PRISONERS CONFINED IN THE PRISONS OF THIS STATE IN TASKS CON SISTENT WITH THE PENAL AND REFORMATORY AND WITH THE PURPOSES OF THEIR IMPRISONMENT PUBLIC ECONOMY AND OF THE TYPES AND IN THE ORDER OF PRIORITY AS APPROXIMATELY FOLLOWS 800306 MC 281526 SIMILARLY MGL NSA 80038 MSA 221407 PROVIDES ALL CONVICTS OTHER THAN SUCH AS ARE CONFINED SOLITUDE FOR MISCONDUCT IN THE PRISON SHALL AS FAR AS PRACTICABLE BE KEPT CONSTANTLY EM PLOYED AT HARD LABOR AT AN AVERAGE OF NOT LESS THAN 10 HOURS UNLESS DAY SUNDAYS EXCEPTED OF LABORING OR INCAPABLE BY REASON OF SICKNESS OTHER INFIRMITY IN IN VIDES WITH 11 SECTION THE PRISON TO COMPENSATION RESPECT INDUSTRIES OF PRISONERS ACT FURTHER PRO THAT IHE PRISON COMMISSION MAY ADOPT SCHEDULE OF PAYMENTS OR ALLOWANCES TO PRISONERS OR TO THEIR DEPENDENTS FROM SUCH FUNDS AS MAY BE PROVIDED THEREFORE BUT SUCH PAYMENTS SHALL BE MADE ON THE BASIS OF NEED OR OF MOTIVATION OF OR REWARD FOR INDUSTRY OR BEHAVIOR AND SHALL NOT BE RELATED TO PROFITS TO THE STATE FROM THE ACTIVITIES TO WHICH SAID PRISONERS MAY BE ASSIGNED THE SCHEME OBVIOUS WAS STATED MCL 800311 CONCLUSION BY JUDGE STARR MSA 281531 TO BE DRAWN FROM THIS IN HUNTLY GUNN FURNITURE SUPRA AS FOLLOWS IT IS CLEAR THAT THE LABOR OF THE PLAINTIFFS AS INMATES OF THE STATE PRISON BELONG TO THE STATE OF MICHIGAN 79 SUPP AT 113 28 STATUTORY CO THIS C4 OTHER STATES 425 1916 THE RHODE HAS BEEN PROPOSITION THUS RELIED ISLAND IN ANDERSON UPON BY PLAINTIFFS MADE THE COURT RECOGNIZED IN SALANT RT 38 PLAINTIFTS FOLLOWING CASES IN 463 96 BRIEF AT 39 OBSERVATION AS TO THE BENEFIT OR PROFIT FROM HIS SERVICES HIS LABOR WAS AND WAS YATT OF HIS SENTENCE FURNISHE117O THE CONTRACTOR THY THE STATE FOR IN THO CONTRACT HIS IN COMPENSATION FIXED ABILITY TO DISPOSE OF HIS PERSON OR SERVICES DID NOT ARISE FROM THE CONTRACT BUT FROM HIS STATUS AS CONVICT UNDER SENTENCE IN PRISON IITS SERVICES BEING PART OF HIS SENTENCE COULD NOT BE OF OR CONTRCLTHD OTHER WISE THAN BTIHUTHTWEW HIS DISABILITIES IN REGARD TO TTE DISPOSAL OF ARE DUE TO TEE PROVISIONS OF TIXE STATUTES APPLICATYE ALIKE TO ALL CONVICTS AND WERE NOT IMPOSED 21 OF BY THE CONTRACT MADE UNDER SAID SECTION LAWS OF 1912 CHAPTER 825 OF THE PUBLIC 38 AT 472 ADDED EMPHASIS DT HIS RN IN COFFEY DICE THE COUNTY SUPRA THE TL SOARD OF COURT COJ OF CONCLUDED IN THE FIRST PLACE THE LEGISLATURE BY THE ENACTMENT OF DEALT WITH 1949 622109 THE SUBJECT OF EMPLOYMENT OF THOSE PERSONS WHO HAVE BEEN CONVICTED OF MISDEMEANORS AND ARE IN THE COUNTY JAIL SERVING SENTENCES UNDER THE OF THAT SECTION PLAINTIRRT5WID CORN ED TO WORK AT HATS LABOR FOR OF EVERY WORKING WHILE SO CON WHIFJ HE WOULD NOT TO RECEIVE 289 P2D AT 783 EMPHASIS PAYMENTI GS FIRST HAVEB FTII AWDED FLY THE COURT THE SAME TOKEN IN HUDGINS HART ET AL SUPRA SAID THE WAS AN INMATE PLAINTIFF AT THE PENITENTIARY AS SUCH HIS LABOR BELONGED TO THE PENI IT WAS THE PENITENTIARY THAT ASSIGNED TENTIARY TITWTEWORK FOR IYLAND ANDOR HART AND IT WAS THE THAT DECIDED PENITENTIARY WHAT HYLAND ANDOR HART WOULD PAY TO FOR THAT LABOR AND EMPHASIS 29 IT OF IMPLICATION THEREFORE IS THEIR UNDER APPLICABLE STATE OF MICHIGAN WORK WHILE THEIR CONFINEMENT PLAINTIFFS NOR THE IMPRISONED LABOR AS SAW THEY COMPENSATION FOR ANY ACCORDINGLY PLAINTIFFS NOR IN INJURED SOME OTHER AND KITCHEN HAVE STATE NOT BASIS BRIEF BEEN ASSIGNED TO THE RESEARCH WHAT THEY INDIRECTLY OF THE COMPELS THE FACT PRIVATE BASIS STATED THE IT PERMITTING OF THE PURPOSES SECTION EXPLICITLY SETS 10 OUT DECLARED OF THE ACTION OF THE THE DAMAGES DAMAGE THEY ON THE ACT ACTION AS PLAINTIFFS TO DO ARE ATTEMPTING DISCUSSION DO DIRECTLY ACT THAT TO SERVE PRISON APPROPRIATE PURPOSES CIVIL TO DAMAGE REMEDY RELIANCE CANNOT THEY CONCLUSION FOR THAT APPEARS PURPOSES THE AS ADMIT ACT THEREFORE STATED ACT EVIDENT THAN ACT DOES NOT PROVIDE PRIVATE IS RATHER THERE TO COMPENSATORY FOR IT PERFORM TO RIGHT DISCLAIM 43 OF OF ANY SUCH AS THE GENERAL PURPORTED TO DEPRIVED ALTHOUGH PLAINTIFFS PAGE THEM COMPELLED ARE NOT ENTITLED THEIR NOT RIGHT BEEN THE MICHIGAN PRISON INDUSTRIES BASIS DIRECT OR INDIRECT FOR THE THE THE TO RECEIVE RIGHT TO WORK AS COOKS INDUSTRY THUS HAVE AND TO BELONGED TO WORK OR DISPOSE RIGHT ANY WAY BY HAVING PRISON NOT NOR THE FIT WORK THE FOR EXAMPLE CLINICS DID LABOR BY NECESSARY MANDATE BY LEGISLATIVE LAW PLAINTIFFS CASE THAT APPARENT CLEARLY AS THE ACT SUCH BASIS MCL OF THE PRISON WAS NOT FOR DAMAGES ACT PURPOSES MICHIGAN INTENDED BY PRISON TO SERVE INFLATES WOULD CONTRAVENE 800310 MSA LEGISLATION OF ACT SECTION 10 IT IS HEREBY OF THIS ACT TO BE THE INTENT 30 INDUSTRIES IN ITS 281530 TO PROVIDE ADEQUATE REGULAR DIVER SIFIED AND SUITABLE EMPLOYMENT FOR PRISONERS OF THE STATE CONSISTENT WITH PROPER PENAL PURPOSES THE LABOR OF TO UTILIZE PRISONERS FOR SELFMAINTENANCE AND FOR THE STATE FOR EXPENSES INCURRED CRIMES AND IMPRISONMENT BY REASON OF THEIR TO ELIMINATE ALL COMPETITIVE RELATION BETWEEN PRISONER SHIPS LABOR OR PRISON PRO DUCTS AND FREE LABOR OR PRIVATE INDUSTRY EXCLUSIVELY REIMBURSING SUBSECTION OF THE ACT PURPOSES FOR THE EXCLUSIVELY SUPPORTS INMATES THIS IS THE TO THE TO BE UTILIZED PLAINTIFFS COLLECT PURPOSES COMPENSATORY OF THE OF THE STATE PLAINTIFFS THEIR AN INTENT ACT IS OF PRISONERS IS TO BE STATE LANGUAGE MICHIGAN THAT THIS THE IN THE OWN PRIVATE ALTHOUGH THAT LABOR LABOR UTILIZED THUS OF PRISON ADDITION HOWEVER OF PRISONERS PROFIT INDIRECTLY WOULD THUS ONE OF THE AS CONTRAVENE TO PERMIT VEHICLE TO ONE OF THE EXPRESS ACT ACT RECOGNIZE BRIEF IN IT OF MICHIGAN DAMAGES FURTHER WAS BETWEEN RELATIONSHIPS OF THE THAT SUBSECTION PURPOSES LABOR FOR THEIR USE THE TO THE BENEFIT INDICATES LANGUAGE NOT THAT PROPOSITION BELONGS INDICATES CLEARLY TO ELIMINATE PRISONER THIS INDICATES LABOR IMPORTANT THAT ALL AND PURPOSE ONE OF THE COMPETITIVE FREE LABOR AND EMPHASIZE THAT IJT WOULD CERTAINLY BE ABSURD FOR MEN CON VICTED FOR SERIOUS CRIMES TO BE GIVEN WORK THAT WOULD IN EFFECT DEPRIVE THOSE LIVING JUST AND LAWFUL LIFE OF THE RIGHT TO EARN PLAINTIFFS LIVING BRIEF AT 36 31 PRIMARY IN THUS LII OF THEMSELVES AS PLAINTIFFS THIS FURTHER BY THEM IS SIGLER LOWRIE 404 TOTALLY F2D PRISON OF COMPENSATION QUESTION AS OF THE 11 AND LIVES 8TH 659 INMATES TO PRISON ANY COMPENSATION PERFORMED SECTION LAWFUL LIVING INCOME LAWFUL SEEKING ARE THOSE POLICY NONCOMPETITION BENEFICIARIES OUT THE INTENDED POINT LABOR FOR BY GRACE OF THE STATE CIR MICHIQAN IN 1968 INDUSTRICS ACT TO BE PAID TO INMATES COVERS SPECIFICALLY THEIR FOR THE LABOR FOLLOWST OF PAYMENTS OR ALLOWANCES TO COMMISSION THE PRISON SEC 11 PRISONERS OF OR SCHEDULE ADOPT PARENTS MAY OR TO THEIR ALLOWANCES TO PRISONERS FROM SUCH FUNDS AS MAY BE DEPENDENTS THEREFOR BUTSUCH PAYMENTS SHALL PROVIDED OF NEED OR OF MOTIVATION BE MADE ON THE ASIS OR BEHAVIBR AND AF OR FOR INDUSTRY TO TH STATE NOT BE RELATED TO PROTITS TO WHICH SAID PRISONERS FROM 800311 MAY BE ASSIGNED SFI FL4 THIF 281531 THIS TO THE SOUND INFERENCE TO THE THE COMMITS CLEARLY OF THE ANY PERSON OR ENTITY NEGATES INMATES AS ALLOWANCES VEHICLE PAID OTHER PRISON ANY DIRECT THE MATTER OF COMPENSATION COMMISSION PRISON UPON TO COMPENSATE ACT ITSELF BEYOND DISCRETION THAT BE CALLED BY PRISON PROVISION MSA MCL THAN OR INDIRECT 32 PRISON IN USE ANY COMMISSION THE INMATES FOR RECOVERY BY THE AND NEGATES OF SUM THEREFORE ITS TERMS OF COMPENSATION COMMISSION IS PENALTIES UNDER THE ACT C4 LII THE EXPRESSLY WHATSOEVER OF ANY MENTION INMATES PENALTIES RATHER THE CIVIL FOLLOWING UNDER PROVIDED DAMAGE REMEDY THE AVAILABLE OMIT TO ARE PROVIDED PENALTIES SPECIFIC ACT SECTION 14 WILFUL OF ANY OF THE PROVISIONS OF THIS ACT BY AN OFFICER OF THE STATE OR OF ANY POLITICAL SUBDIVISION THEREOF OR OF ANY INSTITUTION OF BY ANY OFFICER CAUSE FOR SHALL BE SUFFICIENT EITHER REMOVAL FROM OFFICE AND SUCH OFFICER SHALL ALSO BE SUBJECT TO PROSECUTION AS HEREINAFTER PROVIDED VIOLATIONS MCL 800314 MSA 281534 SECTION 15 ANY PERSON FIRM OR CORPORATION WHO SHALL WILFULLY VIOLATE OF THIS ACT SHALL ANY OF THE PROVISIONS BE DEEMED GUILTY OF MISDEMEANOR AND SHALL BE PUNISHED UPON CONVICTION THEREOF FINE OF NOT LESS THAN 100 DOLLARS NOR BY OR BY IMPRISONMENT MORE THAN 500 DOLLARS IN THE COUNTY JAIL FOR PERIOD OF NOT MORE THAN 90 DAYS OR BY BOTH FINE AND IMPRISON OF THE COURT MENT AT THE DISCRETION MCL CONSPICUOUSLY TO PRIVATE LABOR 800315 ABSENT DAMAGE WAS REQUIRED ALLEGEDLY IN FROM THE REMEDY IN PLAINTIFFS THE OF THE DO NOT VIOLATION IS ABOVE PROVISIONS FAVOR OF THOSE ANY PRISONERS TO REFERENCE WHOSE CONTRACT ACT XAVE PRIVATE DAMAGE REMEDY ACT DEFENDANTS RECOGNIZE STATUTORY 281535 TO BE PERFORMED PURSUANT VIOLATION UNDER MSA THAT CONSTITUTING 33 IN CERTAIN CRIME CIRCUMSTANCES MAY ALSO GIVE RISE TO CAUSE OF ACTION TO THE APPLICABLE IT NOT TO BE BASED THE LONG BEEN RECOGNIZED INFERRED 1944 743 COURT WHICH CRIMINAL UPON IN THE INVOLVED REMEDIES 1943 CIVIL CONTAINED PROVISION CIVIL ARE IN THUS CERT ACTION IN NOT IS CASE STATUTES CIR 7TH 875 DOCTRINE PRESENT THAT FROM CRIMINAL F2D 138 THIS HOWEVER INMATES THOMSON US DAMAGES PLAINTIFF LIGHTLY BEEG2TE 322 HAS FOR DENIED FOR DAMAGES AN ANTITRUST STATUTE CONCLUDED PLAINTIFF URGES THAT THE SECOND PARAGRAPH 20 WHICH FIXES CRIMINAL RES FOR VIOLATION OF THE ACT CREATES PONSIBILITY ALSO CAUSE OF ACTION IF OPEN BIDDING IS PREVENTED OF WHETHER AN INTER IRRESPECTIVE WE THINK THIS LOCKING RELATIONSHIP CONSTRUCTION REMEDIAL UNJUSTIFIED STATUTORY CAUSES OF ACTION MUST FIND EXPRESS BASIS IN ACT THEY DO NOT ARISE BY CONGRESSIONAL FROM IMPLICATION FOR CRIMINAL PROVISION 138 F2D AT 880 PENALTY ACCORD MEZULLO OF SECTION MALET MASS 331 1954 WHERE NO EXPRESS IS REMEDY THAT IT BE INADEQUATE CLASS THE UNITED MICHIGAN UNITED THE INTEREST THE STATUTE WAS INTENDED STATES 389 CENTRAL BASIS STATES FULL OCCURRED 191 RAILROAD 202 CO 34 166 DAMAGE HAS OF THE STATUTE FELL WAS OF THE WITHIN MICH THAT TYPE SEE ALSO 373 THE AND WYANDOTTE 1967 REQUIRED WAS LIABILITY TO PROTECT TO FORESTALL US CIVIL COURT PLAINTIFFS WAS INTENDED HAD FOR EFFECTIVENESS OF THE NE2W 118 SUPREME CRIMINAL THE HARM THAT 238 STATUTORY SHOWN THAT TO ENSURE THAT STATUTE THE PROVIDED 232 130 THE CO LEPARD NW668 1911 BOLDEN LII LII GRAND RAPIDS NW 214 1927 241 DEFENDANTS SUBMIT CONCLUDED THAT ACT PROOF HAVE BEEN THAT CLEAR INTENDED INJURY TO FREE THAT FACT THIRD THEY CORRECTIONS THESE PRIVATE AND INDUSTRIES AND WRONGS HARM WHICH INMATE BY THE BETWEEN IS SEEKS IS TO PREVENT WHEREAS COMPETITION IS RECOVERY SIMPLY TO PERFORM LABOR STATE THOSE PROVISION PURPOSES ACT PATENTLY WERE NOT INMATES THE IT THE THE THE UNDER DEPARTMENT MICHIGAN OF AND UPJOHN DAVIS PLAINTIFFS ATTEMPT COMPENSATORY REMEDY EITHER MICHIGAN THE NOR UNDER PROVIDED SECOND SEEK PLAINTIFFS TO SATISFY NO ALLEGATION EXPRESS THE CORRECTLY FAILED PENALTIES THE BY PRISON PROVIDING IS IS PLAINTIFF CIRCUMSTANCES TO REGULATE DESIGNED OF THE CONTRACT UPON THE INDIRECTLY HAVE INEFFECTIVE WERE COMPELLED AND PARKE IN PUBLIC LABOR ILLEGAL AN ALLEGEDLY PURELY THE FOR WHICH HARIN ALLEGED INTERESTS CRIMINAL OR CASE THERE BE PROTECTED UNDER TO ACT THE FREEMAN JUDGE THIS FIRST INADEQUATE THE OF THE THAT THAT IN PLAINTIFFS CRITERIA THE WYANDOTTE PROFFERED MLCH 318 239 GORPPRATION OPERATING PRISON PURELY PUBLIC DIRECTLY INDUSTRIES OF ADMINISTRATION TO BASE STATE REMEDIES ACT OR STATUTE PRISON TO REDRESS WHOLLY INAPPROPRIATE CHARACTERIZATION OF THE MINK CASE MICH OF NO 2684 COURT APPEALS COMPANY PARKE THE DAVIS ORDER AT NOVEMBER 23 379 MICH 773 CERT DENIED TO APPEAL DENIED PLAINTIFFS FOOTNOTE 42 OF 934 IN THE ON 392 1968 THE DENIALS OF MR MINKS BRIEF IS NOT SUPPORTED BY THE RECORD MANDAMUS ACTION BY THE MICHIGAN COURTS ARE EXTREMELY SUMMARY THE PLEADINGS AND BRIEFS INDICATE THAT THE DENIALS WERE PROBABLY BASED ON PROCEDURAL GROUNDS 966 LEAVE US 35 1967 PLAINTIFFS CAUSE DO NOT HAVE OF ACTION TORT IN C4 LII IS IT CONCERNED WITH INDIVIDUALS IN HORNBOOK THE WHICH PLAINTIFFS ANY WAY INVADED BY THE PLAINTIFFS THEM BY OF THE PRISONERS APPEARS OF OF THIS PRISON WHICH LABOR 98 CJS HAS TO DISCUSS 31 OF TORT THEIR WORK AND LABOR AT BRIEF SECTION AGAINST TORT INTEREST PROPERTY ANSWERED BRIEF AUTHORITIES THE IN THE CITED ILLEGAL QUOTE 36 IT BY COMPULSION FROM AS FOLLOWS AND WHERE ONE PARTY WRONGFULLY COMPELS SERVICES TO RENDER HIM VALUABLE TO PAY THEIR VALUE IS IMPLIED SO BE TO PAY FOR SERVICES RENDERED WILL WHO INTENDED NEVER WRONGDOER AGAINST TO AVOID OR WHO INTENDED DECEITFULLY OF SUCH PAYMENT AND WHETHER THE RENDITION SERVICES IS SECURED THROUGH DURESS COMPULSION OR FRAUD MAKES NO DIFFERENCE WHERE WITHOUT TO PERFORM IS ONE COMPELLED LEGAL AUTHORITY WORK FOR ANOTHER THE LAW RAISES AN IMPLIED FOR THE VALUE OF CONTRACT FOR COMPENSATION THE SERVICES RENDERED ANOTHER PROMISE PROMISE IMPLIED TO PAY FIRST HOWEVER THE PRISONER PLAINTIFFS 12 ILLEGAL 31 BEEN TO HOLD THAT CONSTITUTES WAS IN WHICH CONSTITUTED DEFENDANTS THE THAT DRUG COMPANIES PROTECTED ALREADY OF PORTION ARE CLAIMED AT PAGE INTEREST ALLEGEDLY BRIEF THROUGH SUBMIT DEFENDANT THE BY PRIVATE UNREASONABLE SOCIALLY BY DEFENDANTS PLAINTIFFS APPROPRIATE PLAINTIFFS OF INVADING CONTENTION THIS TWO SECTIONS ACTIONS LABOR SUFFERED DEFENDANTS CONTEND THAT OF THEIR AGAINST AS REGARDED TORTS OF INTERESTS NO LEGALLYPROTECTED POSSESS UTIJI IS FIEJA PROTECTED 2D ED 1955 TORTS PROSSER LEGALLY THE OF LOSSES COMPENSATION THEIR OF OTHERS CONDUCT LAW THAT PARKE THE IN LAW IS THE AND TOO BROAD OF IN RIGHT THAT IT THE SECTION BY QUOTATION 34 THIS STATEMENT OF CRUCIAL FACT ABSENT THAT THE ASSUMES PARTY POSSESSED SIMILARLY AND PRISONERS UPJOHN SUBMIT THAT CASE PRESENT INVASION DAVIS WAS INJURED THAT BY WRONGFUL PARTY AM FROM 41 PLAINTIFFS AT DRIEF JUR PRISON 38 IT SEEMS AGREED THAT LESSEE OF CONVICT LABOR WHO KNOWINGLY THE SERVICES RECEIVES OF CONVICT ILLEGALLY COMPELLED TO PERFORM SUCH LABOR IS GUILTY OF TORT TOWARD SUCH CONVICT FOR WHICH HE IS LIABLE IS BASED ON CASES OR INVOLVE THE FACTS 39 IT STATUTE IN THE DID THE QUOTED PROPOSITION DIFFERENT SIGNIFICANTLY FROM THOSE IN SALANT DECIDED THAT THE RHODE CONTRAVENE THE RHODE ISLAND NOT PLAINTIFFS SUPRA BRIEF LABOR ISLANDPRISON ANTISLAVERY PROVISION CONSTITUTION REFERRED ALLEGED ARKANSAS BASIS AUTHORITY TO OF CASE IN JURY VERY IN PLAINTIFFS HOLDING THAT THE BRIEF IN COURT 513 ARK 247 INVOLVED IN AFFIRMED 13 FINDING OPINION ANDERSON CHARACTERIZATION 39 IS GREER 37 INACCURATE 1890 764 OF OF TWO DIFFERENT NO ERROR ON NO CITING WHATEVER THE GREER CASE MAY STAND AT SW DETERMINATION LIGHT SHORT CONCLUSIONARY WHATEVER SUBMITTED INSTRUCTIONS THE STATUTES OF CRITZ GREER ANDERSON CASE THE IN ERROR IS THE ARE ANDERSON IN WAS SIMPLY THE THE WHICH DO NOT SUPPORT CASE INSTANT THUS AT WHICH FOR IT OF GREER QUOTED AND GOES FAR BEYOND THE CASES OF CHATTAHOOCHEE CO PRICK GOINGS LII CO GA 69 SE865 81 AM DEC 367 AND CO IRON ALL CITED WHO HAD REQUIRED BEEN TAKABLE IS TO BEEN THESE THAT LABOR STAND ARE ENTITLED COURSE THAT IN CO INJURED IN THE STATES VIOLATED FROM COMPETITION SIMILARLY BETWEEN THE THESE PRESENT STATE OF BY PRISON NONE THEIR OF THE BRIEF BEEN THAT THAT TO DISPOSE TORTFEASORS THE INJURY AND CASES THE UNMIS THE LABOR MICHIGAN BELONGED PERSONS RIGHT FROM THE PRISONERS PRESENT OF THE HUNTLEY HAVE THEREFORE OF THAT LABOR EVEN DESIGNED TO PROTECT FREE AUTHORITIES RETIED LABOR OTHER CONSTITUTE 38 HAD ITSELF AND THE THEIR CASE DISPOSITION STATUTE STATE OF SOMETHING SUPRA AND THE PLAINTIFFS BY THE DISPOSITION IN THE PROPOSITION CAUSING TERM IMPRISONED DEFENDANTS OF COAL PLAINTIFFS PRISONERS TO RECOVERY TO THE BELONG BY PLAINTIFFS FOR THE CASES THE VARIOUS EXPIRED INVOLVED THESE WHICH 1914 ILLEGALLY WRONGFULLY DEPRIVED OF DISTINCTION GUNN FURNITURE IF 3941 WRONGFUL DEPRIVATION PLAINTIFFS NOT BEEN LABOR OR PARTICIPATED POINT IN WORDS THE CASES OWN LABOR OF AT ALA 804 PRIOR AND TENNESSEE CONVICTION SO 65 BRIEF OTHER IAI HAD WHO CAUSED VOID COMPELLED TO LABOR WHILE THROUGH OF THEIR CASE BUTLER PATTERSON SENTENCE 1862 TO PERFORM FOR THE THEM INJURED MD ENTITLED THEREFORE TO EXPIRED PLAINTIFFS IN OR CONFINED WAS NOT 1910 PRECEDENT FOR THE UPON DAMAGE RELIEF SOUGHT BY THEM UNDER COUNT III CASE THIS IN C4 LII IT AUTHORITIES RAGHT TO RESPECTFULLY RELIED IS NOT SUBMITTED THAT UPON BY PLAINTIFFS ON DAMAGE REMEDY CONTENTION PRESENT IS LEGALLY TORT DO NOT IN SUPPORTABLE DOCTRINE IS WHERE THIS SAME CONTRACT SUCCINCTLY STATED AGREEMENT THIS R1 THAT CONTEXT OF THE CASE THE SEE THE CLAIMED SUPPORT THE AND CASES AND THAT THEORY PLAINTIFFS AXE PRECLUDED FROM RECOVERY CONTRACT IMPLIED THEORY IN THE WHICH HAAS DURNP DOCTRINE IF RULE THAT TO THE 214 NO CONTRACT IS TIBE THAT IF NY 116 FACTS OF THE IT 255 US RYAN AN WILL BE IMPLIED WOULD BE ILLEGAL EXPRESS WOULD BE ILLEGAL ANDREWS ALSO THE CLEAR UNDER WERE 259 491 CASE LAW WILL EXPRESS 108 1885 AT NOT NE IMPLY CARDOZO 1915 423 APPLICATION BAR INDICATES AN THE SHOULD OF CRUCIAL BE NOTED THAT MANY OF THE CASES CITED BY PLAINTIFFS CASES SUCH ACTIONS BENEFICIARIES INJUNCTION BY THE INTENDED OF THE MICHIGAN PRISON INDUSTRIES ACT MIGHT BE QUITE PROPER SEE FOR EXAMPLE 145 MICH 667 1906 MATHENY VINCENT 327 108 CITED AT PAGE 35 OF PLAINTIFFS IN WHICH REPRESENTATIVES OF BRIEF LABOR AND MANUFACTURERS IN THE MICHIGAN BROOM INDUSTRY WERE SUCCESSFUL IN OBTAINING AN INJUNCTION AGAINST RESTRAINING PRXSCIW5FFLHALS THEM FROM PERFORMANCE OF CONTRACT FOR THE MANUFACTURE OF BROOMS THE DECISION FORMER MICHIGAN BY PRISON INMATES WAS BASED ON CONSTITUTIONAL THE OF MECHANICAL PROVISION PROHIBITING TEACHING TRADES TO PRISON INMATES AND DETERMINATION THE COURT THAT BY THE CONSTITUTIONAL WAS INTENDED FOR THE BENEFIT OF THE PROVISION IN THAT CASE PLAINTIFFS ARE NW 39 PLAINTIFFS INMATES LABOR THE ADDITION VERY FREE BECAUSE STATUTE OF PARKE AND UPJOHN DAVIS SERVICES PROMISED CAN BE TO PAY WOULD HAVE BEEN WOULD BE 119 104 57 IMPLIED FOR FRUSTRATED HIGHER THAN CONVICTION FORMS AN INTEGRAL LEVIES THAT TO VIOLATE VERT GRANT BOTH RATHER TO PLAINTIFFS THEIR LABOR THE STATE WOULD RELY ON THE FOR THE EVEN SUCH PART VALUC HAD DEFENDANTS SUCH EXPRESS PROVIDED CONFINED PART THE MAY BE IMPLIED BERKA OF EXPRESSLY PROMISE OF THE CONVICTED THE WHICH STATUTORY MANDATE THAN PROMOTE THE 40 128 SEEK FOR UNDER IN TO OBTAIN AS CONSEQUENCE PRISON TO PERMIT SUCH RECOVERY OF BENEFITS CRIMES PLAINTIFFS SEEK AND PUBLIC POLICY INTEREST 533 LAW FOR DEPRIVATION OF IOWA CAL 125 MICHIGAN PUNISHMENT WHICH UPON THOSE RELIEF PLAINTIFFS PUBLIC WHERE PUBLIC WOODWARD PETTIGREW CRIMES VERY WOULD VIOLATE PROMISE THEREBY OF SERIOUS WOULD OF COURSE NEGATE SYSTEM ANYONE WITH BELONGED SINCE OF COMPENSATION PERFORMED BY PERSONS OF THEIR WITH PLAINTIFFS 1899 BARNGROVER 1905 NEVERTHELESS COMPENSATION INVALID BEEN SHORT NO PROMISE 777 NW904 LABOR LABOR BETWEEN AGREEMENT ILLEGAL NO PROMISE POLICY THEIR TO PAY PLAINTIFFS HAVE TO CONTRACT IN FURTHER IMPLYING POLICY AN EXPRESS UPON WHICH SUCH AN AGREEMENT PROHIBIT THEIR WERE NOT THEIR TO RESPECT CASE WOULD CLEARLY AND DEFENDANTS PLAINTIFF IN PLAINTIFFS IN INCONSISTENCY WHICH THE MICHIGAN DEFENDANTS HEREIN SUBMIT WOULD AND WOULD OF JUSTICE PRISON SUB PLAINTIFFS DAMAGES HAVE NOT AND SUSTAINED CANNOT SHOW RECOVERABLE C4 IN ORDER TO RECOVER CONTRACT THEORY PLAINTIFFS IMPLIED SHOW THAT HAVE THEY AS HAS HAVE NOT BEEN TO VARIOUS PRISON TASKS AT THE DAMAGES EXISTED IN THE SATISFY THE LAW IF THIS CASE OUT PLAINTIFFS BY THE CLINICS PLAINTIFF VERY CLEAR STATE RATHER SOME THEORETICAL RULE SIMPLY OF MICHIGAN THAN TO THE INDUSTRY PRISON APPLICABLE OR DO CANNOT THEY ASSIGNED RESEARCH EVEN IS THIS POINTED BY BEING OR SOME OTHER FURTHER DAMAGES BEEN TORT STATUTORY WOULD OF COURSE HAVE TO DAMAGED ALREADY INJURED LAUNDRY CANNOT BEEN ON DAMAGES INMATES THE DO NOT AND MEASURE OF TO THE RELATING THAT TO MONEY RIGHT REASONABLE VALUE OF SERVICES IS DETERMINED LARGELY BY THE NATURE OF THE WORK AND THE CUSTOMARY RATE OF PAY FOR SUCH WORK IN THE COMMUNITY RWHEREL THE WORK WAS PERFORMED 58 AM JR WORK AND LABOR TO AT 518 EMPHASIS ADDEDF THUS MOREHOUSE IN THE COURT CHARGED HELD AND 183 VALUE THE PERFORMED IS BY REAL PATCH AT OF HIS COMMUNITY 472 TO CONSIDER PROPER RECEIVED PAW REASONABLE IT MICH 183 SHQPARD 474 ESTATE IN AN 150 NW 112 THE USUAL AGENTS AND BROKERS ACTION BY BROKER 1914 COINNISSION IN PAW FOR THE SERVICES WITHIN CIRCUMSCRIBED WHICH THE WORK HERE IN BY THE 41 WALLS OF JACKSON QUESTION PRISON WAS PLAINTIFFS TO THE SITUATIONS SITUATION UNCONTROVERTED APP LILA AT ALL OF THE FORTH AND ARE PRISON ACT IF THAT RESEARCH CLINICS AT FOR PLAINTIFFS THEY AT PAID COMMISSION TO PROVIDE OF THE 27 AFFIDAVIT COMPARABLE INDICATE RATE THAN THE IS REQUIRED ARE RESEARCH CLINICS HAD NOT SUPERIOR PURSUANT TO SECTION BEEN BEEN AND ARE OF PRISONERS EMPLOYMENT THAT INDUSTRIES PRISON AT AND WITH FROM THE APPEARS NO HARM OR DISADVANTAGE HIGHER WOULD HAVE LOWER RATE RELATION IN WARDEN KROPPS AFFIDAVIT IN SUFFERED WORKING CONDITIONS APPARENT TASK SET 26 AS PRISONERS TO OTHER ASSIGNED THE MUST BE CONSIDERED PLAINTIFFS WERE AND THE SINCE FACTS PARAGRAPHS PRISONERS THAT OF OTTER 112A PLAINTIFFS THUS IT TO THE ASSIGNED TO ASSIGNED IS SOME OTHER INFERIOR COMPARATIVELY WORKING CONDITIONS PLAINTIFFS ARE NOT ENTITLED NOT TO AN HAVING BEEN DAMAGED IN AWARD OF MONEY DAMAGES ANY IN THIS WAY THEY CASE CONCLUSION IN CLAIM THAT FOR COUNT RELIEF BY WAIVING III OF SOUNDING THE TORT THE AMENDED IN TORT AND SUING 42 COMPLAINT PLAINTIFFS PLAINTIFFS FURTHER ON IMPLIED CONTRACT ALLEGE CLAIM THEY ARE ENTITLED TO THE DAVIS PARKE AND VALUE REASONABLE OF SERVICES RENDERED TO MINIMUM UPJOHN AS MEASURED BY STATUTORY WAGE C4 PROVISIONS OF DEFENDANTS LAW PLAINTIFFS HAVE RESPECTFULLY FAILED SUBMIT TO STATE IMPLIED CONTRACT UPON WHICH RELIEF ARE NOT ENTITLED TO FURTHER COMPENSATION THAT JUDGE THE SUMMARY FREEMAN JUDGMENT SHOULD IN CAN THAT 43 MATTER IN TORT OR BE GRANTED THAT PLAINTIFFS CLAIM OR ANY THEORY FAVOR OF DEFENDANTS BE AFFIRMED AS AND GRANTED BY C4 THE DISTRICT COURT WAS CORRECT IN CRANTINC DEFENDANTS MOTION FOR SUMMARY JUDGMENT ON COUNT TV BECAUSE EVEN OF PLAINTIFFS ASSUMING TIIA THE UTILIZATION LABOR WAS CONTRARY TO MICHIGAN LAW PLAINTIFFS DID NOT SUFFER DENIAL OF ANY RIGHTS PROTECTED BY THE UNITED STATES CONSTITUTION IT AMENDED DIFFICULT IS COMPLAINT UNDER THE 13TH COUNT II IN PURPORTEDLY AND 14TH THE UNDER ALLEGING OF PLAINTIFFS VIOLATIONS OF TO THE ARGUMENT ADDS AMENDMENTS IV RIGHTS UNDER PRESENT LITIGATION ON PAGE THEORY TO SEE WHAT COUNT COUNT BRIEF OF THEIR 47 PLAINTIFFS THEIR STATE AS FOLLOWS TV BEGIN FROM THE BASIC ASSUMPTION APPELLANTS THAT THE RIGHT OF AN INDIVIDUAL TO THE FRUITS OF HIS OWN LABOR BELONGS TO HIM ALONE AND IS CONSTITUTIONALLY PROTECTED PROPERTY RIGHT UNDER THE FOURTEENTH AMENDMENT EXCEPT TO THE TAKEN AWAY FROM HIM EXTENT IT IS LAWFULLY THE RESIDUE OF THAT RIGHT AFTER PART OF IT IS CARVED OUT AND GIVEN TO THE STATE BY STATE LAW BELONGS TO THE PRISONER APPLICABLE THIS CONTENTION ARGUMENT UNDER COUNT MICHIGAN LAW LAWFULLY JACKSON PRISON MUST HAS NO RIGHT AND THUS HE MAY SEE OF THE FIT STATE TO BE CONVICTED BE PUT TO HARD TO HIS LABOR OWN LABOR AS THAT MICHIGAN FELON RIGHT PRISONER 44 TO PLAINTIFFS IDENTICAL AS HAS ALREADY III EXCEPT IN APPEARS BEEN DETAINED PURSUANT WITHIN STATUTE TO OR TO DISPOSE MAY BE GRANTED COMPLETELY UNDER STATED OF HIM FORFEITS IT AS BY GRACE HIS WORK AS HE CHOOSES TO FREEDOM AND C4 IT IN ORDER RESTRAINT STATE LABOR PRISON CERTAINLY THEIR LABOR IS IN THAT BECAUSE THE VIOLATION THE AT WORK IS THAT THAT UNITED AS LAWFULLY IT IS AND OF RESTRAINT RIGHT ON THE TO ALLEGEDLY RISK OF BEING ABSURD PLAINLY OR OTHER OF CRIMINAL STATES RIGHT AND ONLY STATUTE WHICH MAY CONSTITUTIONALLY THEREOF THAT 9TH 193 780 PROPOSITION IS IS BE DEPRIVED EXACTLY 45 INMATES CIR WHAT THE MAY 1963 1967 SAY THAT OF THEIR THEY BRIEF MD PA TO FREEMANS JUDGE PLAINTIFFS SUPP 263 THE F2D WITH PRISON TO WORK 315 INMATES PUTTING AGREE CONVICTED RHAY WAY OF FRUITS THE BECAUSE EXPRESSLY ANOTHER THE CLINICS VIOLATION INMATES DRAPER FALLIS RESEARCH IN THAT PURPOSES THE STATE THE LABOR OF STATUTORY THAT STATUTORY AT LABOR AND DISPOSE CONSTITUTIONAL BE COMPELLED CONSTITUTIONALLY 47 SUBMIT HAVE FACT WHEN THE ACT OF THE THIS DIRECTS VERY LABOR PLAINTIFF PAGE INMATES OF THE TO SPEAK SO EFFECT FOR CERTAIN COMPEL THIS RETURN IN LABOR THE TO RIGHT FURTHER PRISON SHOULD LABOR CONCLUSION BASIC 281525 FREE PRISON MICHIGAN LABOR NOT ALTER DEFENDANTS AGAIN TO THEIR PROHIBITS THE DOES NOT PLAINTIFFS THEIR THEREFOR COMPENSATION TO DISPOSE RIGHT WITH DOES MICHIGAN TO THE UTILIZED REDUNDANT HAS IN STATE SOLE COMPETITION STATE ON THE THE ONLY AVOID TO MSA NOT TO UTILIZE INMATES OF THE SECTION 800305 WHICH HAS THE STATE PRISON THAT MCL ACT INDUSTRIES THE TRUE IS RECEIVE TO PRISON LABOR STATE AND OF MICHIGAN HAS DONE BY STATUTE NSA 281526 MUST BE PUT TO THE MCL AND TO HARD HAD PRIOR THEY THUS STATE CO PLAINTIFFS STATE OF 47 PAGE CASES PLAINTIFFS VIOLATION LABOR IN CONCEDE THUS EVEN LAW IT OF THEIR THOSE LABOR CASE LABOR 513 CAL 1959 THE HEAVYWEIGHT 31 IS CONSTITUTE CIR ASSUMED AND OF BE TO THAT BRIEF 1968 UTILIZATION THE OF PLAINTIFFS 8TH PLAINTIFFS JUDGE IN FREEMAN CONSTITUTIONAL TO COMPEL COURT ARE NOT HERE INVOLVED OR CREATIVITY AS COMPELLING CHAMPIONSHIP PLAINTIFFS EXIST WORK OF PRISONERS AND FOR COUNTY IN PICTURES MAY MAY BE CONSTITUTIONALLY IT INVOLVING SUCH LIMITATIONS LIMITATIONS ARGUABLY SUPERIOR TO PAINT HUNTLEY RIGHTS VIOLATED OFFICIALS INMATE BELONG PRISON ITSELF SUBMITTED IS THAT IN 659 THOUGH OFFICIALS BY PRISON POWER OF PRISON PRISON LABOR MERE VIOLATION RIGHTS F26 404 WHATEVER CONSTITUTIONAL COMPEL PRISON IN THAT CONSTITUTIONAL CONCLUDING NOT BEEN PRESENT TO THEIR JACKSON NOT DOES LOWRIE OF MICHIGAN WAS CORRECT HAVE FEDERAL THEREIN CITED IN INMATES PRISON SUPRA OFFICIALS SIGLER 281407 ARE CONFINED FURTHER LAW BY PRISON VIOLATION DETENTION PLAINTIFFS GUNN FURNITURE 800306 AND WHATEVER RIGHTS TO LAWFUL WHILE MCL MSA 80038 LABOR TO PURSUANT OR AS SUGGESTED IN OR DISPOSE IN IMPROPER OF MARTIN TO P24 345 TO FIGHT FOR AN ARTISTIC PRISON PLAINTIFFS BRIEF HOWEVER DO NOT AND CANNOT 46 THE INDIVIDUALITY MUHAMNED ALL REQUIRING ON THE CONTEND THAT THEIR INVOLVED WORK ASSIGNMENTS ANYTHING BUT AT THE PRISON LABOR ORDINARY RESEARCH ALBEIT CLINICS OF VARYING DEGREES OF SKILL IT CONTENTIONS IS RESPECTFULLY OF PLAINTIFFS FREEMAN WAS CORRECT ON COUNT IV OF IN SUBMITTED INSUBSTANTIAL ARE GRANTING PLAINTIFFS THAT SUMMARY AMENDED 47 THE CONSTITUTIONAL AND THAT JUDGMENT COMPLAINT FOR JUDGE DEFENDANTS VI C4 RELIEF CO PEFENDANTS PARKE SUBMIT THAT FEBRUARY JUDGE 1971 DAVIS FREEMANS APP REQUESTED AND UPJOHN ORDER ENTERED SHOULD 223A RESPECTFULLY MILLER RESPECTFULLY IN THIS BE AFFIRMED CASE ON COURT BY THIS SUBMITTED CANFIELD PADDOCK STONE BY FOR PARKE DAVIS ATTORNEY 2500 DETROIT BANK AND TRUST 48226 DETROIT MICHIGAN DYKEMA GOSSETT SPENCER COMPANY BUILDING GOODNOW AND BY ROLL FOR THE UPJOHN ATTORNEYS 2700 PENOBSCOT BUILDING DETROIT MICHIGAN 48226 DATED DETROIT JUNE 15 MICHIGAN 1971 48 COMPANY TRIGG C4 CM ADDENDUM RULE 23 FEDRCIVP CLASS ACTION TO CLASS PREREQUISITES ACTIONS ONE OR MORE MEMBERS OF REPRESENTATIVE THE MEMBERS LAW OR FACT OF THE OF THE STATE REPRESENTATIVE WILL PARTIES INTERESTS OF THE OF MICHIGAN EMPLOYEE MEANS AN INDIVIDUAL OF THE 65 YEARS EMPLOYER CLASS OF CLAIMS OR ARE TYPICAL AND THE AND ADEQUATELY FAIRLY CLASS WAGE LAW OF 1964 172552FLB BETWEEN EMPLOYED BY AN EMPLOYER EMPLOYER OR AT OF ALL QUESTIONS THE PARTIES MINIMUM MSA AND ARE AS IF ONLY JOINDER CLASS MCL 408382B 18 THAT OR DEFENSES OF THE REPRESENTATIVE THE OF ALL THERE COMMON TO THE CLAIMS PROTECT SO NUMEROUS IMPRACTICABLE IS DEFENSES IS SUE OR BE SUED MAY ON BEHALF PARTIES CLASS CLASS FIXED SITE THE AGES OF ON THE DESIGNATED PREMISES BY THE COURT CATVIN IT MS WALTETH CUIMONT FWVLI WILLIAMS LGIU DTJAARY KENN SAI41 WAFLN 0F INMAN TWITMACEL LKKY PAUL TIH7 PAYM TT NF MMU NJ PH4 LI RD2QALFLTH THLTAN FLBDTHUX NT LI IIM RAVMON DIR INI GWTKTI PVTFL EOTCP TLLWV THIA PAUL MELLEF44T TAVL BENNY FLYIS SYJITEVL JMVRLV RALIFLA FLT WLO UFLAD HTH LIIRI9 WAR AV TAV TT4I OT THUH 40 ITHIAWART FL CII TLHTG IGA LAN1W LDFHP TOW CCI IT CNTPOI OF MR OP TORLL TATIT4 MH9FL UIZ H1 MAX FLUAHE CCYCTON FLWVN AND ROV JCLIPT CU 2I FUL FJI JRR IRFL III IT TTFI CTILLA LW II III PN KU RODJHITT TABLE OF CONTENTS PAGE TABLE OF AUTHORITIOS STATEMENTS OF ISSUES PRESENTED VI STATERNEN OF THE CASED NATURE OF THE CASE STATEMENT OF FACTS SUMMARY OF ARGUMENT ARGUMENT DID THE DISTRICT COURT ERR IN RULING THAT COUNTS II III AND IV OF PLAINTIFFS AMENDED COMPLAINT ARE NOT RNAINTAINABLC CLASS AS ACTION BECAUSE OF PLAINTIFFS FAILURE TO ESMBLISH THE SIZE OF THEIR CLASS SUFFICIENTLY IT DISTRTCT COURT ERR IN GRANTING DEFEN MOTION FOR SUMMARY JUDGMENL UNDER GOUNL OF PLAINTIFFS AMENDED COMPLAINT BECAUSE PLAINTIFFS WERE NOT EMPLOYEES WITHIN THE MEANING OF THE FAIR LABOR STANDARDS ACL DID THE DANTS THE QUESTION THE RIGHT TO TO HIRE BE DECIDED AND APPLICAELON OF HUNTLEY 15 FIRE OTHER FACTORS PERTAINING OF ECONOMIC APPLICATION REALITY TEST 16 TO 20 GURIN CONCLUSION III DID 15 DISTRICT COURT ERR IN GRANTING SUMMARY TO DEFENDANTS ON COUNT II JUDGRNCNT OF PLAIN TIFFS AMENDED COMPLAINT BECAUSE PLAINTIFFS WERE NOT EMPLOYEES WITHIN THE MEANING OF THE MICHIGAN MINIMUM WAYC LAW 23 26 THE 27 PAGE C4 TV DID THE DISTRICT COURT ERR IN GRANTING SUMMARY OF PLAIN JUDGMENT TO DEFENDANTS ON COUNT III TIFFS AMENDED COMPLAINT BECAUSE PLAINTIFFS WERE NOT DEPRIVED OF PROPERLY UNDER MICHIGAN LAWAND BECAUSE PLAINTIFFS WERE NOT INTENDED BENEFICIARIES UNDOR THE MICHIQAN PRISON IN DUSTRIES ACT PLAINTIFFS THEORY THE LAW OF MICHIGAN THE ILLEGALITY THE BASIS OF THE 30 OF RECOVERY 32 OF DEFENDANTS UTILIZATION ILLEGAL LABOR DY DEFENDANTS TORTIOUS ACT 34 ACES OF PLAINTIFFS CONSTITUTED DISTRICT 38 COURTS 41 RULING DID THE DISTRICT COURT ERR IN GRANTING DEFENDANTS NOTION FOR SUMMARY JUDGMENT AS TO COUNT IV OF PLAINTIFFS AMENDED COMPLAINT BECAUSE EVEN THE ILLEGAL USE OF PLAINTIFFS ASSUMING LABOR CONTRARY TO MICHIGAN LAW THEY SUFFERED NO DENIAL OF FEDERALLY PROTECTED RIGHTS CONCLUSION ADDENDUM CONTAINING 30 46 50 RELEVANT STATUTORY PROVISIONS II AND RUWS 51 OF AUTHORITIES TABLE C4 C4 PAGE CASES MICH LATHROP 36 1850 438 SALANT ANDERSON BROMWELL OI PRISON OF STATE AGENT 96 CO BRUSH 286 CHARITIES CHATTAHOOCHEE PRICK GA 425 RI 1915 STATE BOARD R7S7 DC CO GOINGS 39 KY 1922 69 SF 865 38 1910 CITIZENS 143 BANKING COOPER PATE F2D CO MONTICELLO CIR 8TH 261 US 378 DANK STATE 1944VT77 546 1964 12 49 NEWPORT NEWS GENERAL AND NONSECTARIAN 375 F2D 648 4TH CIR HOSPITAL ASSOCIATION GYPN 1967 DAVIS DETROIT RHAY US WHITAKER NY 261 GREER CRITZ 13 F2D MICH 78 1890 33 1949 34 58 COMPANY 9TH 1953 INDUSTRIES 47 INC 12 1968 TRUST CO SW 43 ARK SW 764 ARK PALM SPRINSS 909 CIR 9TH INC 16 NEW JONES 193 LITTON 1966 DC NYJCRS HARRIS 214 HOUSE COOPERATIVE 1960 28 GREEN 329 F2D 315 164 VSTXPP GOLDSTEIN 363 ENGINE CORSD GOLDBERG 325 MICH 885 38 DRAPER 366 FIRE LIAISE MICH 81 PARK HIGHLAND DONOVAN FIDELIS 293 DISTRICT SCHOOL 12 39 1924 ALPINE ESTATOS 1964 CIR J11 FRD 13 37 39 INC 13 29 PAGE FURNITURE GUNN HUNTLEY WAX MICH 1948 DC PA 281 299 US LEE GO 145 PRIOR 1968 333 MICH AM DCC 81 III NE2D POWELL EMPLOYMENT SEC COMM LOWRIE SIGLER TENN 218 PCTOFSKY WALLING F2D 136 SANDERS WRI MCCANN 389 WYANDOTTE CO UNITED MICH 37 455 CIR 519 STATES 1958 SO 65 6TH 2D 389 CIR CIR 1943 1967 US 4748 804 USDC1950 175 78 40 38 BUTLER R2D F20 345 8TH 659 FSUPP 90 1938 1923 CO COAL IRON 1914 ALA TISA 453 724 404 35 MD 1862 367 HUGHES 18 MABEY 49 1906 327 PEOPLE PRICE SNPP CR CO ILLINOIS US VINCENT PATTERSON 43 36 WASHINGTON MANTHEY MARTOCELLO 11 1936 334 110 1941 COLLAR KENTUCKY WHIP FSUPP 79 2324254344 CO EQUIPMENT ICEPLANT CC 191 12 16 49 1907 42 CONSTITUTIONS UNITED STATES THIRTEENTH AMENDMENT 47 FOURTEENTH AMENDMENT MICHIGAN ARTICLE SEC 18 CONSFRITUTICN IV OF 1850 35 PAGE C4 STATUTTS LFL STATES UNITED IS 29 29 29 USC USC USC USC MICHIGAN 1761 203 36 CI 15 203 15 203 16 STATUTES ANNOTATED SEC 172552 27 SEC 1725514 27 SEC 281525 35 SEC 281530 35 SEC 2822712341 SEC 282308 23 RULES FEDERAL RULES RULE 23A U1E 8B OF CIVIL PROCCDUTE 791OAY1314 11 MISCELLANEOUS AMERICAN JURISPRUDENCE AMERICAN JURISPRUDENCE CALLAGHANS CORPUS MICHIGAN JURISSECUNDUM VOL 2D VOL PLEADINGAND VOL 38 41 98 44 48 PRACTICE VOL 32 32 C4 PRESENTED POR REVTEW STATEMENT OR ISSUES DID THE DISTRICT III AND IV TO ERR TN RULING OF PLAINTIFFS AS MAINTAINABLE FAILURE COURT THAT COUNTS AMENDED COMPLAINT ACTION CLASS ARE NOT BECAUSE OF PLAINTIFFS ESTABLISH SUFFICTENTLY II THE SIZE OF THEIR CLASS THE DISTRICT THE APPELLANTS THE APPOL1E QOURT SAY ANSWEREDNC YES NO SAY II DID THE DISTRICT COURT ERR IN GRANTING DEFENUANTST MOTION FOR SUMMARY JUDGMENT UNDER COUNT TIFFS AMENDED COMPLAINT EMPLOYEES WITHIN DARDS THE BECAUSE PLAINTIFFS MEANING OF THE FAIR ACT NO COURT ANSWERED THE DISTRICL THE APPELLANTS THE APPELLEES SAY SAY YES NO VI CT PLAIN WERE NOT LABOR STAN C4 III DID NENT THE TO DISTRICT COURT DEFENDANTS ON COUNT COMPLAINT BECAUSE IT MEANING OF THE THE DISTRICT THE APPELLANTS THE APPELLEES PLAINTIRFE OF WERE NOT PLAINTIFFS TH GRANTTNG SUMMARY ERR IN MINIMUM MICHIGAN AMENUED WITHIN ENPLOIEES WAGE JUDO LAW AR NO COURT SAY NO SAY IV DID THE DTSTRICT COURT ERR IN GRANTING SUMMARY MENT TO DEFENDANTS ON COUNT ITT COMPLAINT BECAUSE PLAINTIFFS NOT INTENDED INDUSTRIES THE BENEFICIARIES UNDER COURT ANSWERED THE APPELLANTS THE APPELLEES SAY SAY DEPRIVED BECAUSE PLAINTIFFS ACT DI PLAINTIFFS WERE NOT LAW AND PERTY UNDER MICHIGAN OF NO YES NO VII THE MICHIGAN JUDG AMENDED OF PRO WERE PRISON C4 DID TILE DISTRICT COURT ERR IN GRANTING DEFENDANTS MOTION FOR SUMMARY JUDGMENT AS TO COUNT IV TIFFS ILLEGAL AMENDED COMPLAINT USE DISTRICT THE APPETLANTS THE APPEILCES COURT SAY SAY TUE LABOR CONTRARY TO MICHIGAN NO DENTAL OF FEDERALLY RIGHTS THE PLAIN DECAUSE EVEN ASSUMING OF PLAINTIFFS LAW THEY SUFFERED OF ANSWERED YES NO VI NO PROTECTED UNITED COURT STATES FOR SIXTH THE OF APPEALS CTRCUTT NC 711170 RICHARD ALLEN FRANK ROGERS BTLLY LEE WALTER LEE FLOYD SLAGER PETER GEORGE MILLS WILLIAMS WILLIAM ORDELL VILBURN LEE IT WALKER CLEMONT DEDEAUX BENNV FRED SPELLS HERBERT WILLIAMS HOLNACEL CLEARY BAILEY ORCEAN DAVIS JERRY KENNETH INMAN RAYMOND THOMAS BOYD LORD RALPH WATSON CHESTER KELTON MACK PHILLTP MQGHEE VERNON IT MEVIS RALPH SAWICKI KENNEDY PAUL ROSS HERMAN HEAD GERALD WARNER RONALD LONNIE PAYNE THOMAS MULLIGAN NORMAN PAUL MILLER AND KENNETH MARSHALL ESPICH ROBERT MASON GAYLORD CALVIN SIMS PLAINTIFFSAPPELLANTIS CO CO THE UPJOHN PARXE DAVIS MICHIGAN CORPORATION OF THE EJEPARTMENT OF CORRECTIONS DELAWARE CORPORATION ELEANOR JAMES WADSWORTH HUTZEL STATE OF MICHIGAN RICE FARLEY JOHN ERNEST BROOKS MAX FIBER JOSEPH ROBERT FLORENCE GROSS DUANZ CRANE WATERS COTTON AND GUS HARRISON CJ DEFENDANTSAPPELLEES APPEAL FROM THE FOR THE DISTRICT EASTERN COURT OF THE DTSTRICT OF MICHIGAN SOUTHERN DIVISION PLAINTIFFS APPELLANTS UNTTED STATES ERIEF BI ITSCC CO CO STATE NATURE OF THE CO AND THE 23 APRIL SEEK AT ARE AND COUNT AND THE ENTITLED TI STATE AMENDED INERUIT THEORY WHILE PLAINTIFFS THE PLAINTIFFS THAT IN ECONOMIC REALITY THE THE UNDER LABOR DRUG COMPANIES AND THE UNDER ACTION EMPLOYEES THE RESULTANT PLEADINGS AND THE LTICITLBCCS THE FACT D4INIMUM ALLEGE OF THE WAGE LAW QUANTUM COUNTS OF THE OF AND TI DRUG COMPANIES CONTROL CORE OF COUNT ITI OF THEIR OF BY PLAIN PROPERTY CORRECTIONS THE AND IV CONSPIRACY ON THE PART MICHIGAN ACT 58A LAW UTILIZATION DEPRIVATION PLAIN ON VIOLATIONS OF CUSTODIAL THE 1970 STANDARDS RECOVERY ON UNDER ON 21 ALLEGES LABOR FOURTEENTH AMENDMENT UNDER MICHIGAN THE FAIR DAMAGES BASED DEPARTMENT OF CORRECTIONS ALLEGED ILLEGAL THE FILED ON JANUARY COUNT DAVIS BY PARKE COMPLAINT FILED SEEKS III GRAVAMEN OF THE DESPITE THE SEEK MICHIGAN OPERATED FIRST THE WHO ARE OR PEOPLE SOUTHERN CLINICS PROTECTION WERE ACTUALLY IS MICHIGAN THEORXES BY OF PRISON COUNT TV SEEKS UNDER RIGHTS PRISON COMPLAINT COUNT MICHIGAN FILED DRUG AT THE SIMILAR ALLEGES OF IN TO PROTECTION OF THE TIFFS CO ACTION STATE LABOR RECOVERY UNDER FOUR TIFFS IS THE THEIR UPJOHN 1968 CLASS IS BEEN PRISONERS RECOVERY FOR ING CASE CASE THIS HAVE OF THE 58A OF THE DEPARTMENT UTILIZE TO ILLEGALLY PLAINTIFFS LABOR WTTHOUTPROPER PAYMENT THERE 6TH FOR AFTER ANSWERS WERE FILED ROGATORIES BY PLAINTIFFS JUDGMENT SUMMARY HAD BEEN ANSWERED AS TO LIABILITY MOVED FOR SUMMARY IV THEY MOVED TO DISMISS MENT OF CORRECTIONS PLAINTIFFS ITS NOT BE MAINTAINED COULD THE DISTRICT GARDING THE CIENTLY ESTABLISHED FURTHER TREATING JUDGMENT ORDER CLASS FILED GRANTED THE THE SIZE MOTIONS ORDER TO THE ARE AT AFTER REFERRED TO AS JACKSON AFTER REFERRED TO AS UPJOHN REFERRED TO AS PARKE DAVIS TO RE MOTION HAD NOT SUFFI PLAINTIFFS DISMISS PLAINTIFFS 52A ACTION 190A THE AS MOTIONS COURT FOR SUMMARY ON ALL DEFENDANTS PLAINTIFFS COUNTS BY CLAIM FILED OF APPEAL PRESENTED FOR REVIEW ISSUES OF SOUTHERN MICHIGAN THAT 224A 1971 PLAINTIFFS PRISON TO AND DEFENDANT CLASS THE SUMMARY JUDGMENT FEBRUARY RELEVANT OF III MOVED TO DISMISS GRANTED DEFENDANTS THAT DEFENDANT AND DEFENDANT DEPARFR FOR AN ORDER CLASS FINDING MOVED FOR ENTIRETY AS COURT ACTION FROM THIS FACTS ITS INTER AND COUNTS 53A MEMBERS MOVED THE COURT ALSO TI COUNT IN PLAINTIFFS UNDER JUDGMENT INDIVIDUAL AMENDED COMPLAINE DRUG COMPANIES ACTION AND DEFENDANTS UNDER COUNT III ONLY DRUG COMPANIES ALSO BY ALL OR HAVE BEEN IACKSON INMATES MICHIGAN 59A THE AND PARKE DAVIS ARE CORPORATIONS AT THE STATE SOMETIMES UPJOHN HERE COMPANY HERE COMPANY HEREAFTER ORGANIZED FOR PROFIT 429 CO MICHIGAN IS OF THE STATE ARE OTHER EITHER CLAIM DRUG MANUFACTURING WHILE CORPORATION DELAWARE OF UPJOHN PLAINTIFFS THOSE BEEN INMATES ARE OR HAVE AS DO THE BESIDES AND NAMED AT ACTS OF THE PUBLIC NSA 282341 TION BODY ORGANIZED OF ALL INDIVIDUAL OF THE TIFFS THE OF PRISON DEFENDANTS CLAIM COMMISSION BACK SAME CASE ALL COMMISSION AL SEC ARE THE OVER BEEN RELEVANT WHO HAS BEEN MANAGEMENT NSA 282274 OR HAVE TIMES ADMINISTRA THE OVER THE 282271 SECTIONS SPECIFICALLY INDUSTRY OF IS THE MEMBERS TO PLAIN DIRECTOR OF BEEN CARRYING ON THE 59A DEFENDANT DRUG COMPANIES HAVE DRUG RESEARCH AT JACKSON DATING THIS THE ACT NUMBER 232 1953 OF EXCEPT FOR GUS HARRISON BOTH DAVIS IN WHO COMPLAINT AND WHO HAVE JURISDICTION AND AND CORRECTIONS MICHIGAN UNDER OF MICHIGAN LABOR LAWS THERE COMMERCE DEPARTMENT OF CORRECTIONS ORIGINALLY INSBILUTIONS THE BUSINESS DOING THIS DAVIS 59A AND HAS EXCLUSIVE PENAL AND CONTROL STATE ARE IN JACKSON PLAINTIFFS DEFENDANT MICHIGAN CORPORATE NAMED UNDER ORGANIZED IS INTSERSLATE IN PARKE INDUSTRY BOTH COMPANIES BUT STATE OF MICHIGAN THE THROUGHOUT THE IN GENERALLY ENGAGED FOR 1934 SOME YEARS THE ACTIVITIES OF PARKE 36A WHOSE POWERS WERE TRANSFERRED TO THE DEPARTMENT OF GORRECTITONS CREATED BY SEC 275 OF THE EXECUTIVE ORGANIZATION ACT OF 1965 SEC 329 ET SEQ TO SECTION 277 OF SAID ACT PURSUANT MSA THE DEPARTMENT OF CORRECTIONS IS ADMINISTERED BY THE CORRECTIONS COMMISSION OF SIX MEMBERS WHICH NUMBER WAS CONSISTING ORIGINALY REDUCED TO FIVE THE BY LHE EXECULIVE ORGANIZATION ACT OF 1965 EXECUTIVE OFFICER OF THE DEPARTMENT OF CORRCTIONS IS ITS PRINCIPAL WHO IS APPOINTED BY THE COMMISSION DIRECTOR LI VOLUNTEERS FROM AMONG THE PRISONERS GENERALLY USED AS GUINEA CO TO ENGAGE IN PIGS U1TIN PRODUCTS WHICH ARE REFINING INTERSTATE IN UPJOHN WITH AGREEMENT AN AGREEMENT CORRECTIONS NOVEMBER THE 1963 SIMILAR TO RETAIN AN ARCHITECT AND ON NOVEMBER AND OF TO PAY CLINICAL THE ALTHOUGH THE DEPARTMENT OF CORRECTIONS PLETELY IS CONSTRUCTION DRUG COMPANIES FIXED EQUIPMENT IS ANY INSURANCE IGAN IN THE PLETED ALL EVENT ARE TO BECOME DRUG COMPANIES RESEARCH ONLY THE THE IS 1963 THE 47A THE ENTIRE GIVEN THE BUILDING AND TO BECOME ON TO OF ABANDONMENT OF THE BUILDING AND EQUIPMENT ON THE OF AT PRISON THE TO APPROVE COMPLETED OF THE BUI STATE RESTORE PROJECT THE OF AS LONG THE AS THAT RIGHT SORT TO USE THE OF RCSEARCH MICH BUILDING WHEN PARTIALLY CBNSTRUCTION BUILDING IS CORN SITE PROPERTY OF THE DEPARTMENT OF CORRECTIONS ARE GIVEN COM TO BO EQUIPPED IS USED TO COM EXPENSE FROPERTY OF THE BE 32A DRUG RIGHT AS SOON AS THE THE PROCEEDS ARE THE MATERIALS FOR BUILDING DEPARTMENT OF CORRECTIONS ALL ACCEPTED BY THE AND ARID THE BY 18 TO DEPARTMENT OF RESEARCH BUILDINGS CONSTRUCTING BEFORE FUR DEPARTMENT OF CORRECTIONS AND PLANS ARE PROGRAMS AGREEMENT WAS EXECUTED BETWEEN THE PLANNING THE AND GREAT PART BY LABOR THESE AGREEMENTS GENERALLY REQUIRE PANIES DAVIS RESEARCH AT THE PRISON COMPANY AND THE L4ICHIGAN UPJOHN PARKE BY AND FINISHING FROM JACKSON PURSUANT CONSTRUCTION TO THE CLINICAL OF THE 21 IN BETWEX PARKE DAVIS WAS SIGNED IN DRUG TESTING ISLA DRUG COMPANIES RELATING CONDUCTING THESE DEPARTMENT OF CORRECTIONS THE BY SOLD OR HAVE BEEN ADMINISTERED ADMINISTERED NISHED COMMERCE AND DRUG TESTING ARE THE FOR CLINICAL CONDUCTED AT THE THE PRISON FOR THE AGREEMENTS FURTHER THE RESPONSIBLE DRUG COMPANIES RESEARCH IN OF CLINICAL CONDUCT MAKE THE BUILDING DEPART THE CO MENT OF CORRECTIONS THE HAVE AGREEMENTS AND IT ACTS IS THE STAFF AND NOT SO CALLED DID RESENTATIVES OF THE ANY OTHER WOULD HAVE COERCION OR THREAT IN NOT PRISONERS REFUSAL TO THEM AND EXPRESSLY REP WOULD AS THEY AND PENALTIES IF WHO DO SO BY THE JUST INDUSTRY IMPLIED WAS CLEARLY THE OR DRUG TESTING THE PIGS WERE ORDERED TO RE SUITED AS OTHERS ADMINISTRATIVE PRISON THAT AND RUN BY DEFENDANT ORGANIZED DEPARTMENT OF CORRECTIONS BE ORDERED BO WORK IN DIRECTED AS WELL VOLUNTARY GUINEA SO BECAUSE THEY THUS WORKING WORK AS DILNICS WORKED AS PART OF THE AS EXECUTION TERMS JJA OCCURRED NAMED PLAINTIFFS THE TO WITH THEIR ACCORDANCE SUBSEQUENT TO THEIR PERIOD DZUG TESTING DRUG COMPANIES REASONABLE STEPS RESEARCH BY THE DRUG COMPANIES CARRIED OUT IN OF BY PLAINTIFFS ALL IN BEEN THE DURING COMPLAINED WORKED ALL TAKE CONDUCT OF CLINICAL THE FACILITATE TO AGREES TO SUCH STATED 94A MANY DIFFERENT THE DRUG CLINIC FACILITIES RATE OF PAY PER DAY JOB AND OPPOSITE CHIEF TECHNICIAN TECHNICIAN TECHNICIAN CHIEF CLERK NURSE NURSE TRAINEE CLERK SUPERVISOR THEY EACH TILE JOB CLASSIFICATION CLASSIFICATIONS ARE LISTED HAVE AS FOLLOWS UPJOHN THE COMPANY RATE PERFORMS SPECIFIC OPERATION OF TASKS SUCH AS EEC MACHINE SAME AS CHIEF SAME AS CHIEF CLERICAL TASKS CLERICAL EASKS ACTS AS NURSE WITH CLINICAL SAME AS NURSE WITH AT 182A DUTIES ORDINARILY EXISTED TECHNICIAN TECHNICIAN IN CONNECLION TESTS SUPERVISOR 76 50 35 75 49 50 30 OF PAY 125 75 50 125 75 100 50 CV COOK CHIEF COOK KITCHEN PO KITCHEN PAN MAN L4AINTSNAFLCE HEAD PORTER PORTER PARKE FLAWS CLERK CHIEF PREPARATION CLERK CHIEF OF HEAD PORTER MAINTENANCE PORTER ARID MAN NURSE SUPERVISOR NIGHT OF THE DUE DRI TO EACH ARC PRISONER PROGRAM AND HAD TASKS OTHER THAN CEIVED THE NO COMPENSATION PLAINTIFFS LIZED AND FOR PARKE OTHER ON THE DUCED THE PRIVATE DAVIS THINGS MARKET AND PAYMENT NOTED FOR SERVICES THE AS WELL AS CLINICAL THE TRANSPORTED THROUGHOUT THE UNITED TESTING THE ACCOUNT BY THE BY THEM THIS CASE OF DEFENDANTS AND THEIR 60A ARE ACLIVITIES OF DRUGS NOT DELIVERED 0A IN UTI UPJOHN AMONG PRESENTLY OF DRUGS CURRENTLY BEING STATES RE ABOVE PLAINTIFFS PURPOSES AND IN RESPONSIBILITY IN SHIPPED AMOUNTS WORKED LONG HOURS INVOLVED TESTING BY EACH BY CHECK THEN AND RENDERED SHARCHOLDCRS INCLUDE FOR SOLD COMMERCE PROFITMAKING THEIR 100 SUBSTANTIAL THE RESEARCH CLINICS 80 60 60 ARE PAID NOMINAL THE 75 PRISONERS TO THE INVOLVING 125 ATTENDANT RATES 35A DEPARTMENT OF CORRECTIONS THIS AND DAILY ASSIGNED PAY DETAILS STATE OF MICHIGAN TO THE COMPANIES OF LABELS FOR SAMPLE PRISON JANITOR NOTED THE ABOVE AO 60 40 ETC CALL SLIPS INMATE WORKERS AND VOLUNTEER PAYROLLS DOUBLE CHOCKS LABELS COOKING AND OTHER KITCHEN DUTIES JANITOR AND MESSENGER MAINTENANCE AND MINOR REPAIRS COOK 55 40 RATE BLOOD URINE CONTAINERS 80 CONPANY DUTIES CLASSIFICATION JOB 55 40 25 35 40 25 COOKS AND SERVES FOOD SAME AS CHTEF COOK ASSISTS IN KITCHEN ASSISTS IN KITCHEN MAINTENANCE AND MINOR REPAIRS JANITORIAL TASKS JANITORIAL TASKS PRO INTERSTATE SUMMARY APTTMFNT JR C4 CO MAY PROPERLY MAINTAIN PLAINTIFFS CLASS THE ACTION UNDER IS CIRCUMSTANCES IT IS LEDGE WITH WITHIN PECULIARLY OF EXISTS WHICH IS CLASS LITIGATION FACT IN OF NUMBER OF AT LEAST TO MEET THE NUMBER OF KNOW SUCH MORE KNOWLEDGE OF THE DEFENDANTS CLASS SUFFICIENT AND AS BECAUSE THCM TO KNOW THE FOR CERTAINTY THE OVER THE ROCORD SHOWS THAT ACTION RFLES FEDERAL THE IMPOSSIBLE SITUATED SIMILARLY PEOPLE 23A RULE THIS FIFTYSCVCNPEOPLE OF REQUIREMENTS IT OF THEIR UNDER COUNT RECOVORY OF WAGES UNDER INMALES SEEK FOR DIFFERENCE THE DRUG COMPANIES LAW CLINICS AT WHICH OF THE WOULD FOR THEIR AMOUNT THE ECONOMIC NOTHING OF AND COMPANIES TT UNDER AND IS TO BE MORE THAN AN RESULTANT BENEFIT ATTEMPT TO THE LEE WORKED JUST ECONOMIC BENEFIT LEGISLATION THE THE FAIR LIBERALLY AND LHE TO AVOID STATE THE THEM BY DEFENDANT PAID BE PAID WORKED ARC THAT WERE LABOR STANDARDS ACT FAIR TO PLAINTIFF COMPLAINT AMOUNTS REQUIRED REALILIES PLAINTIFFS DRUG LHE NORMAL BETWEEN THE DRUG COMPANIES MENTS WITH THE CONTROL PLAINTIFFS VISION REMEDIAL BETWEEN THE AND FEDERAL CUSTODIAL AMENDED AT SITUATION 5IT AND AS CIVILIAN OF MICHIGAN SUPER EMPLOYEES THE OF MICHIGAN MINIMUM DRUG 7K STANDARDS ACT WAS CONSTRUED STATE THE FOR ULTIMATE EXCEPT LABOR UNDER EMPLOYEES ARRANGE IS WAGO REQUIREMENTS AND THE EMPLOYERS TTT C4 CO THE FOUND ARE ACT MICHIGAN MINIMUM MICHIGAN PEOPLE NOT PROTECTED BY THE FEDERAL COVER THOSE TIFFS PURPOSE OF THE NOT TO BE WITHIN PROTECTION LAW AND OF THE PLAIN IF LATTER THE THEM TO APPLIED THE WAGE ACT WAS TO IV AS EVERY PLAINTIFFS FRUITS THE OF TAKEN FROM LEGALLY DENIED THE INMATES IN OF PRIVED OWN LABOR THEIR THEM CORRECTIONS THE AND MAY THAT PLAINTIFFS LHE HIS THE CASE THIS LABOR HAS BEEN REASONABLE VALUE ARE OR HAVE BEEN HAS PRISONERS IS LABOR OF DO PERSON ILLEGALLY DEPRIVED TO EXPRESSLY THE TO UTILIZE RIGHT RIGHT SUCH RIGHT OF MICHIGAN LEGISLATURE DONE IN OF RECOVER RIGHT EXCEPT TO THO EXTENT DEPARTMENT FASHION FRUITS THE THE OTHER PERSON HAVE PROPETY OFI THEREOF AND THE FACT DOES NOT NEGATE THIS RIGHTS THE RIGHT OF ACTIONS THAT PLAINTIFFS THAT RIGHT DEPRIVED ARE THE FRUITS ENTITLED IN OF ONES LABOR IS FOURTEENTH AMENDMENT AND ILLEGAL DENTAL CONSTITUTES OF DEFENDANTS THEY TO THE PROTECTED UNDER VATION IN RIGHT THIS CASE PLAINTIFFS OF TO DAMAGES WERE OF DUE ILLEGAL PROCESS PROPERTY DEPRI THE UNDER MICHIGAN PROPERTY RIGHT FOR WHICH LAW ARGUMENT C4 CO CO DID DISTRICT THE AN AS ING FOUR COUNTS OF THEIR BECAUSE OF PLAINTIFFS COURT ANSWERED DISTRICT THE APPELLANTS THE APPELLEES PARAGRAPH THE ESTABLISH CLASS THE PLAINTIFF NOT MAINTAINABLE SUFFICIENTLY TO RULING TV OF PLAINTIFFS AND ARE ACTION CLASS SIZE III COMPLAINT FAILURE IN II COUNTS THAT ERR IN COURT YES SAY SAY NO THEIR OF INMATES NO AMENDED ALLEGE CONTAIN COMPLAINT THAT THERE ARE NUMEROUS OTHER PEOPLE WHO EITHER IN THE STATE PRISON ARC OF HAVE BEEN INMATINES OF SOUTHERN MICHIGAN AT JACKSON MICHIGAN WHO HAVE THE SAME CAUSE OF ACTION AS HEREIN AFTER SET FORTH ON THE PART OF THE NAMED PLAINTIFFS AND THE NAMED PLAINTIFFS ADEQUATELY ACTION SUCH UNNAMED PEOPLE THIS REPRESENT IS BROUGHT PURSUANT TO RULE 23A OF THE FEDERAL RULES OF CIVIL PROCEDURE ON BEHALF OF ALL SUCH TO PEOPLE WHOSE NUMBER MAKE IT IMPRACTICAL THE NAMED PLAIN HAVE THEM JOIN AS PLAINTIFFS TIFFS 59A ADEQUATELY REPRESENT SAID CLASS DEFENDANT UPJOHN FIND THAR RULE 23 EHE ACTION OF THE FEDERAL OF NONQUALIFICATION AGREED THAT WAS NOT COUNT RULES UNDER CONTPANY MOVED THE PROPERLY BROUGHT AS OF APPELLATE THE CONTAINING RULE TRIAL CLASS PROCEDURE CLAIM UNDER THE FAIR ACTION SEVERAL 52A WERE ALLEGED COURT TO UNDER GROUNDS PLAINTIFFS LABOR STANDARDS ACT WAS RULED THE BY THEREUNDER JUDGMENT TO ACT LIMITING OF THAT PROVISION PERSONS THE EFFECT WRITTEN WHO HATE FILED HOWEVER AS TO COUNTS OF CONSENT C4 CO IV PLAINTIFFS CONTENDED THAT THE II TO COUNTS RULE ITT CA 23 ACTION TO AN TO BECOME PARTIES AND DISTRICT IV THIS GRANTED DEFENDANTS THE SO NUMEROUS MEMBERS THE DISTRICT CLASS ACTION JUDGE INVOLVED IS FOUND 23 MET WERE MOTION AS SOLELY ON OF ALL 190A EVIDENCE HIM TO DETERMINE AND BE JOINDER IMPRACTICABLE INSUFFICIENT TO ENABLE WAS APPROPRIATE CLASS THAT ITT WAS PREDICATED RULING THAT RULE OF REQUIREMENTS COURT AND WHICH REQUIRED THE II OF THE WHETHER SIZE OF THE OR NOT CLASS THAT STATING THE ONLY INFORMATION THIS COURT HAS BEEN GIVEN ON CLASS SIZE WAS SUPPLIED BY PLAINTIFFS ATTORNEY DURING ORAL ARGUMENT WHEN HE COMMENTED THAT THE CLASS WOULD PROBABLY CONTAIN BETWEEN 70 AND 200 PERSONS SINCE THIS ESTIMATE WAS UNSUPPORTED BY ANY MATERIALS BEFORE THE COURT IT MUST BE DEEMED PURELY SPECULATIVE AND SPECULATION CANNOT BE USED TO ESTABLISH THAL PROSPEC TIVE CLASS IS SO NUMEROUS AS TO MAKE JOINDER UNDER THE SURROUNDING CIRCUM IMPRACTICABLE STANCES IT IS NECESSARY TO LOOK WHETHER OR NOT THE COMPLAINT AND COURT AMENDED ASS CIT THE OMIT WHOLE RECORD WAS CORRECT COMPLAINT 189A FIRST PLAINTIFF IN OF THIS CASE ALL INMATES TO DETERMINE BOTH IN THEIR ALLEGED THERE ARE NUMEROUS OTHER PEOPLE WHO EITHER IN THE STATE PRISON ARE OR HAVE BOON INMATES OF SOUTHERN MICHIGAN AT JACKSON WHO MICHIGAN HAVE THE SAME CAUSE OF ACTION AS HEREINAFTER SET FORLH ON THE PART OF THE NAMED PLAINTIFFS AND THE NAMED PLAINTIFFS ADEQUATELY REPRESENT SUCH UNNAMED PEOPLE THIS ACTION IS BROUGHT PURSUANT TO RULE 23A OF THE FEDERAL RULES OF CIVIL PROCEDURE ON BEHALF OF ALL SUCH PEOPLE WHOSE NUMBER MAKE IT IMPRACLICAL TO HAVE THEN TO KK ADEQUATELY THE NAMED PLAINTIFFS 52A REPRESENT SUCH CLASS THE OF THE AS PLAINLIFTS JOIN BY THE MEMBERS FILED INDIVIDUAL WHILE MICHIGAN THE ANSWER FOR PURPOSES OF THE THUS THAT STATE THEY DO NOT THAT THEY BELIEF OF THE FACT TO THEIR STATE AS TO THE OF THE INVOLVED STATEMENT DEMONSTRATE TIFFS SUITING THE OF IN THEIR HOWEVER WITHIN SUFFICIENT THEIR TO FORM SINCE KNOWLEDGE FOR THEM MARLOCELLO 43 DO POSSIBLY DASED SHOULD NOT HAVQ THE ANSWERS CO RULES FEDERAL NOR COULD THEY AVERMENT IS THE THUS ALLEGATION ALL UPON THIS EFFECT FSUPP OF 281 1941 OF INVOLVED IT 8B BY RULE EQUIPMENT PRESENT STATE HOWEVER THAT AND UPJOHN VETY SIGNIFICANTLY PERFORMED SERVICES IT THEREFORE INMATES DENY 68 DEFENDANTS ISA PARKEDAVIS NOR DENY PROOFS INFORMATION DENIAL DC PA OF THOSE KNOWLEDGE OR INFORMATION TRUTH OF THE INMATES THEIR NOT DOES APPLICABLE OF STATE ALLEGED PLAINTIFFS ON BEHALF ADMIT AS REQUIRED ARE WITHOUT SO WHEN ALL IS THE OF BOTH NEITHER THEY PLAINTIFFS LEAVING OF RECORD THE ANSWERS 20 23A OF THE ITS ADMITTED IS ALLEGATION ATTORNEY GENERAL RULE NUMBER TO THE AS ALLEGATION THAL DENYING AND DEPARTMENT OF CORRECTIONS IS THE PLEADINGS APPELLANTS THE FACT THERE WHEREAS THERE FROM PARTIES WERE TO REST THERE THAT ON THE ARE STATE NINETEEN OF THE SPECIFICALLY THE REQUESTING TO HE ADDED AS THE ON THE NUMEROUS ALLEGED CLASS ARE NOW THIRTYFIVE ORIGINALLY THAT POSITION WHO WOULD BE MEMBERS OF THE NOT NECESSARY THIS IS IS ADMITTED PLEADINGS NAMED DIFFERENCE SU OTHER TO PLAIN RE PROGRESSED THIRTYONE LISTS CLASS MAKING COULD THAT ARE PEOPLE MOST DIFFICULT HAVE HAS MADE BEEN THAT SIZE 261 THE TRUST WAS HELD LITTON TO IN IN THAT THIS IT IS TO HAVE NEWPORB NEWS GENERAL F2D 648 CIR NOTES FACT WOULD BE THOSE HAS WHO LAW ALREADY NO BAR BE MAIN TO AND CLASS FOR ACTION FS 164 IN OF FORTY RESTORATION FIDELIS SDNY STOCKHOLDERS SEVENTY OF EIGHTEEN AND 293 MONTICELLO TWELVE BY TRUSTEE PROPER CLASS INC CO VS AN ACTION AGAINST PROPER 1968 WAS DETERMINED ACTION WAS HELD NONSECTARIAN SUFFICIENT HOSPITAL IN CYPRESS ASSOCIATION 375 1967 SEE TISA SIMILARLY AN EXECUTIVE NUMEROUS BOARD TO MAKE IT OF POTOFSKY MORE THAN IMPRACTICAL 90 FS SUWNARY OF INMATES WAGES 1966 MEMBERS WAS FIFTY TO BRING 12 PAID CUSDC 175 THEM ALL COURL EXHIBIT IS SEPTEMBER THIS THE FEDERAL CASE ALONE IN OF THE OF ALL FLANKING 1944 INDUSTRIES VS FICIENTLY CLASS DRUG 141A HAL MOREOVER CITIZENS CIR OF BETWEEN THIRTYFIVE WHERE CASE THAT SO 8TH CLASS THE OF EXAMPLE OF COLLATERAL 4TH LIST CASE NAMED THOSE NOTICE JUDICIAL TO GATHER THIS THE NUMBER IN AND IN THIS IN FOR FROIN PERMANENTLY PLAINTIFFS THE F2D TO BE SUFFICIENT 1950 RECORD ACTION 143 CORPORATION CLASS THE FIFTYSEVEN HAVC TAKEN ESTABLISHED CLASS FUNDS LEAST OF ACTION CAUSE BANK AT THE FOR OF TRUST OF PART EMPLOYEES WORKING INCARCERATED NOT FOR CLEAR TAMING HOLDERS AS INMATE CERTAINLY SUFFICIENTLY STATE OF NAMES LOWER COURT MIGHT FILED TWENTYTWO OF WHICH ARE DIFFERENT COMPANIES ACTION CT EXHIBIT FURTHERMORE BY UPJOHN IN SUF BEFORE THE THAT WORD THE HAVE COURTS IMPRACBICABILILY POINTED OUT AS IN ON NUMEROUS OCCASIONS RULE 23 DOES NOT MEAN C4 BUT IMPOSSIBILITY AT CTASS F26 909 9TH FRD 363 DCNY 1966 329 CC 39 OF IN THE MAY BE AFRAID SITUATION OF JOINING ALL LACK THE WITHIN CLEARLY BEEN OF EASY IT SEEMS KNOWLEDGE WITH THE TO THE REGARD OF APPELLEES POSSESSION IT THAT LOWER COURT WAS WRONG IN THE COULD IN INTERESTS IS REALLY THE MAINTAINED NOT BE OF BE DECIDED OF EVIDENCE OF THE HIM TO GRANT APPELLEES REQUIRED CAUSE SECONDLY THE ONCE ACTION MAIN AS FOR ALL OF MOTION AND BE BROUGHT BEFORE RATIONALE BEHIND THAT IT THEY AGAINST THIS THE CLASS OF THE THE CLASS THE 13 CLASS AT ONE ACTION INFOR SO THAT THAT CERTAINLY OF JUSTICE COURT COURT RECORD THAT THAL ALL OF THE PEOPLE THE IS WOULD HAVE FOR AN ORDER ACTION CASE FORTH SUCH THAT RULING ORDERLY ADMINISTRATION AND IN OF THE TO PUT SIZE CLASS THAT ATTENTION FOR APPEILANTS DIFFIC4T SUFFICIENT ACTION THIS IN ALL OF REPRISALS SIZE AND THE TO MATION ACTION RIGHTS TO APPELLANTS BE THE FIRST BECAUSE OF POSSIBLE IT WOULD ALONE RESULT THINGS MAY BE UNEDUCATOD AND PLAINTIFFS ENOUGH FOR THEM TO BRING CONTAIN ESTATES NEW JERSEY TRUST PLAINTIFFS WHEREAS NOT JOINING AUTHORITIES FINALLY ALL THE OF ALPINE SEVERAL KNOWLEDGE OF THEIR ACTION TAKING SPRINGS GOLDSTEIN INSTANT THEY OF THEM BY PRISON SINCE 1964 CIR GROUP OF POTENTIAL AND ILLITERAEE PALM THE IMPRACTICABILITY MANY OF THIS OR INCONVENIENCE DIFFICULTY THE MEMBERS INC ONLY THE TIME DID THAT THIS IT IS THIS HAVING WHICH PROCEDURES APPELLANTS C4 RULING PROPERLY THAT COUNTS MAINTAINED IT AS ITI URGE THAT AND CLASS IV OF THE DISTRICT THEIR ACTION UNDER 14 COURT COMPLAINT RULE 23 ERRED COULD NOT IN BE II C4 DID DISTRICT THE DEFENDANTS COMPLAINT OF PLAINTIFFS WITHIN APPELLANTS THE APPELLEES PLAINTIFF COMPLAINT OF DEFENDANT TION FAIR OF THE MEANING OF EMPLOYEE IS RELEVANT DEFINED EMPLOYER IS TO THE 29 MALTER OF PROTEC OR THE STATE LAW PLAINLIFTS OF MICHIGAN USED IN THE ACT ARE THE FOLLOWING USC EMPLOYED BY AN SEC 203 AS OR ANY PERSON ACTING DIRECTLY IN THE INTEREST OF AN E7NPLOYER LO AN 29 203D ARE LOJA INDIVIDUAL DEFINED INDIRECTLY IN RELATION SEC THEY AS ANY TERM AS OF DOFENDANT DRUG COMPANIES ELA THAT COUNT GROUND THAT AND ENTITLED THEMSELVES TERMS EMPLOYER THE ON THE SLATUTE TIHAL RECOVERY UNDER ACT ARGUING OF EITHER EMPLOYEES THE SEEK DRUG COMPANIES STANDARDS LABOR THE AN II NE SAY INMATES FOR SUMMARY JUDGMENT WERE NOT WITHIN YES SAY AND AMENDED COMPLAINL EMPLOYEES MOVED MO ANSWERED QUESTION TO BE DECIDED THE THEIR ACT COUR THE DISTRICT WERE NOT MEANING OF THE THE LABOR STANDARDS THE AMENDED BECAUSE PLAINTIFFS EMPLOYEES FAIR GRANPINC FOR SUMMARY JUDGMENT MOTION UNDER COUNT ERR IN COURT EMPLUY 15 USC TO EMPLOY MEANS TO SUFFER USC 29 BECAUSE OF THE BREADTH OF THE THE FACT THAT LITERAL ITS HUMANITY TO DETERMINE THE VS WHITAKER ALL PARTIES AND THE CORRECT ONE EMPLOYEES LABOR THIS RULED AS ALL DR EMPLOYED 1943 OF ECONOMIC AN EMPLOYEE OR NONEMPLOYEE TNC CRITERION 366 US BY ALL AGREED WITHIN THE RULING WAS 28 MEANING 33 FILED OF WERE THE BY TO BE PARTIES OF LAW THAT PLAINTIFFS MATTER THE REALITY AFFIDAVITS THE CONSIDERING DRUG COMPANIES 6TH AND LANGUAGE TEST THE COOERATIVE COURT AFTER NOT FAIR 206A ACT TO HIRE RIGHT HOUSE APPLYING THE OF STANDARDS THE OF ONE AS STATUS THE DISTRICT 1960 F2D YT 8O NARROWER TEST APPLIED ABOVE WOULD ENCOMPASS APPLICATION SANDERS HAVE COURTS WORK TO OR PERMIT 203Q SEC AND FIRE OF HIS THE BASIS PART IN CONCLUSION HIS THAT DEFENDANTS OR FINALLY THE CLINICS KROPP OF THE DANTS AS AS WELL ANALYZED AUTHORITIES AND THE OF THE STATE AND UPJOHN PRISON AS THE RELIED CONTROL REGULATION COULD NOT HIRE FIRE INMATES WORKING IN 202A SUBSTANCE OF THE THE ADMINISTRATOR CONTROL CLINIC OF SOUTHERN DEFENDANTS UPON BY ASSIGNMENT OF AT HOURS THE JACKSON 123A MICHIGAN LOSA ANSWERS COURT IS CLINICS WOCKED BY THE 16 AND WILLY OF WARDEN FILED TO INTERROGATORIES DISLRIC TO THE OF RALPH AFFIDAVITS AND INMALES THAT REMOVAL BY DEFEN 24A THE PRISON THEREFROM THE PLAINTIFFS SUPPORT CONTROL OF CLUSION THAT IN THE COURT THE DETERMINED PROPOSITION THAT THAT AFFIDAVITS FILED BY AND THE THUS THE ULTIMATE REACHED THE ARE PARTIES BY FILED WERE UNDER THEY DEPARTMENT OF CORRECTIONS THE AFFIDAVITS NOT CON FACTRUALLY L97A CONFLICT HOWEVER HE COURT EXPRESSLY DISREGARDED THE AFFI DAVIT OF GAYLORD LEE ESPICH WHICH STATES OF DEFENDANT REPRESENTATIVES COMPANY PERSONALLY PROVED WORKED SAID TIN NOT WORK THERE UNLESS WHQ COULD APPROVEDI THE REASON FOR THIS AND THEY UPJOHN PERSONS WERE SO 178A ACCORDING WHILE THE FREEMAN WAS TO JUDGE AFFIANT ESPICH STATES HE IS FROM PERSONAL KNOWLEDGE COMPETENT THAT THE UPJOHN COMPANY PERSONALLY APPROVED ALL INMATES WHO WORKED IN THE SAID CLINIC AND PERSONS COULD NOT WORK THERE THAT WERE NOT SO APPROVED HIS COMPETENCY AND FIRSTHAND KNOWLEDGE OF THESE FACTS IS UNSUPPORTED BY ANYTHING CONTAINED IN HIS AFFIDAVIT DOES ESPICH NOT IN HIS AFFI DAVIT OR OLBERWISE REVEAL HOW HE KNEW THESE FACTS INASMUCH AS SUMMARY JUDGMENT PROCEDURE LACKS THE SAFEGUARD OF OF AN IT IS IMPORTANT THAT IT BE SHOWN THAT AFFIANT HE IS COMPETENT TO TESTIFY TO THE MATTERS THEREIN STATED INDEED SINCE ESPICH IS SIMPLY ONE OF THE INMATES WHO WORKED IN THE UPJOHN LAB IT IS DIFFICULT TO SEE HOW HE COULD BE ORATORY FROM FIRSTHAND COMPETENT TO TESTIFY KNOWLEDGE ON WHETHER UPJOHN PERSONALLY APPROVED ALL IN MATES WHO WORKED IN ITS CLINIC HENCE THAT PORTION OF ESPICH AFFIDAVIT REFERRING TO UP JOHNS SELECTION OF INMATES WILL BE STRICKEN AS TO CONFORM WITH RULE 55E FAILING 19TH TO TESTIFY CROSSEX THIS DESPITE THE FACT THAT AFFIANT ESPICH ALSO STATED THIS AFFIDAVIT IS MADE UPON THE BASIS THE PERSONAL KNOWLEDGE OF AFFIANT OF THE IS FOLLOWING MATTERS AND AFFIANT COMPETENT TO TESTIFY TO THE MATTERS STATED HEREIN OF 17 IS ONE OF THE MAIN PTAINTIFFS HAS WORKED IN THE DRUG CLINIC CONSTRUCTED BY THE UPJOHN COMPANY BUILDINGS AT THE STATE PRISON OF SOUTHERN MICHIGAN WITH SOME OF THE FURTHERMORE HE IS FAMILIAR AND OTHER INMATES OF OTHER NAMED PLAINTIFFS SAID PRISON WHO WORKED IN THE SAID CLINIC AFFIANT HEREIN AND COURT APPEARS TO BE SAYING THE OF ONE OF DEFENDANTS COULD HAVE REPRESENTATIVE HOW EMPLOYEES WERE SELECTED THERE THAT IS NO REASON WHO HIMSELF EMPLOYEE WITH ING COURT THE FOR THIS WAS HAS TO OF WITH METHODOF SELECTING PLAINTIFFS IS RAISED DO NOT SUBORDINATE SO THAT FACTUAL FILED FACT IN IN LATTER EHE CASE THIS CONTROL EMPLOYMENT BY THIRD HIS IT OPINION IN THE IN SHORT ASIDE WHETHER ACTUAL JUST ROUTINE THEY IS SERVICES AS CIVILIAN BY THE STATE THEY NEGATES DID OF MICHIGAN THE THE THE DRUG COMPANIES ACTUAL THE TASKS ULTIMATE INMATES BY THE LEGAL NOT PLAINLIFFS WOULD HAVE BEEN 18 SEE THAT THE THIS COURT WERE DRUG IS AFFIDAVITS THE EXIST OF POSSIBILITY RIGHT WERE QUES DEPARTMENT OF THE BASIS AS THE RENDERED BY REPRESENTATIVES EMPLOYEES THEM OF DO NOT FURTHERMORE PERFORMANCE OF THEIR OR IN DEALING THE LEGALLY THOSE ON THE PLAINTIFFS UNCONTROVERTED THAT WORKED THERE STAND ERROR ESPICH CONTROL TO BE DECIDED PARTY FROM THE AN SOME CONTROLLED THE WORK ASSIGNMENTS MOREOVER ENCE OF CUSTODIAL COURT WAS IN CONTROL WISHES THEIR WHICH CANNOT ISSUE RATE SHOULD THAT DISPUTE RATHER ACKNOWLEDGING THIS CORRECTIONS OF OF INMATES DEPARTMENT OF CORRECKIONS HAD CUSTODIAL TION TO AS DRUG COMPANIES OF PLAINTIFF THE AFFIDAVIT THAT THE KNOWLEDGE THE KNOWLEDGE CERTAINLY BELIEVE APPELLANTS PORTION TRUE BE NOBODY EXCEPT THE EMPLOYMENT AT THE SELECTED STRIKING THE THAT 178A NOTES IN SUPERVISED COMPANIES TO DETERMINE DIRECTED OF THE IN THE DEFENDANTS THE COURT GAVE NO WEIGHT 200A PLAINTIFFS TAKEN AS TO THE WHOLE WHILE EXHIBITS INDICATING FILED BY ULTIMATE CO CONTROL OF THAT WAS IN IT ORIGINATED FOR TIME INMATE FACT THE REQUESTS IN OFF IN ASSIGNMENT OR FOR THE PRISON MANY CASES HIRING DESCRIPTION FOR THE STAFF JOB INDICATES THAT OF HELP IEEE INMATE EMPLOYEES AND DAILY THINGS AS ESPECIALLY ONO OF HIS INTERESTING SEVERAL OF KROPP WARDEN FROM DW WILLY OF THE AT THE EXHIBITS RATE CON THE PRISON FOR HIRING IS LOTTERDATEDJUNE IS OR FOR PERMISSION EXHIBIT POSITION AUTHORITIES SHOW CLEARLY DRUG COMPANY THAT 132A NEW INMATES OF THE REASSIGNMENT TAINING INMATE OF REPRESENTATIVES QUITE THEY OF 11 SPEAK SALARY 1965 UPJOHN CLINIC AND OF CLINIC RELEASIRIG SUCH 140W TO GEORGE WHICH STATES AS FOLLOWS DEAR SIRR SINCE THE JOINT RESEARCH FACILITIES OF PARKE DAVIS AND UPJOHN CLINICS HAVE BEEN IN OPERATION FOR OVER YEAR WE FIND IT NECESSARY TO REEVALUATE THE PAY SCALE FOR INMATES WORK ING IN THE CLINICS WE OFFER THE FOLLOWING REASONS ON OCCASION WE HAVE FOUND IT DIFFICULT TO HIRE INMATES WITH THE QUALIFICATIONS WE BECAUSE IT IS POSSIBLE REQUIRE FOR THOSE MEN TO GEE EQUAL OR MORE PAY FOR FEWER HOURS OF WORK ARID LESS PERSONAL RESPONSIBILITY THE STANDARD OF PERFORMANCE OF THE COMPANIES MUST IN TURN BE REQUIRED OF INMATE HELP IN THE CLINICS THE INDUSTRIES COMPUTER CENTER AND PSYCHIATRIC UNITS RECOGNIZE THE PERFORMANCE OF THEIR INMATE EMPLOYEES WITH HIGHER ISSA PAY THE COURT DISREGARDS THIS SHORTHAND NOTATIONS OF PROCEDURES RESULTING SORT OF COMMENT IN THE OFTEN USED BY BUSINESSMEN IN THE ATTAINMENT 19 OF LETTERS AS BEING MERE TO CONNOTE ANY VARIETY FORCE APPELLANTS WORK CT THAT HOWEVER BELIEVE CONSIDERED IN DETERMINING ARE TO BE RESOLVED AND OF THE THEY OR NOT FACT ADMISSIONS IN DEFENDANT DRUG COMPANIES MISTAKEN IN DETERMINING CONTROL AND BELIEVE SITUATION SHOULD BECAUSE ONLY BELIEVE THAT FACTUAL IS OF LEAST AT THE THE COURT WAS BELIEVE IN THE IS THAT THE FURTHER DRUG COMPANIES WERE ALLOWED BY THE DEPARTMENT OF CORRECTSONS CIVILIAN THE RIGHT THE INMATES THE TO HIRE NOR DETERMINED 202A DISTRICT OF PLAINTIFF TIE FIRE WAS ALWAYS OF THEN THEY WOULD WITH IN THE THE THE TO THE DEFENDANT TO HAVE THEIR OWN FINAL RETURN FOR THE CUSTODIAL THAT AND COMPANIES REALITY TO BE THIS THE MUST BE THAT USE OF THIS CONVICT HAVE RE LABOR PRIVATE CORPORATIONS NORMAL TO THEIR RIGHTS LINQUISHED DETERMINE WHEN AND WHETHER THEIR ENTER NEED ADDITIONAL TO S6LECT PRISES HELP THE MEMBERS OF THEIR WORK FORCE TO THE OF OFFI FACT THAT TEST NEITHER SUPERVISION CONTROL OF PRISON HOWEVER TO THE REALITY DRUG COMPANIES HAD EMPLOYNENT ISSUE ECONOMIC ECONOMIC OF THAT AND RECOGNIZED RELATIONSHIP FOUND THAT INMATES SUBJECT COURT NOT DETERMINATIVE FABRIC AS TO APPLXCABION PERTAINING FACTORS HAVING IS INMATES REALITY EMPLOYEES OTHER CIALS THE WITH HAND THE REALITIES AND APPELLANTS ALMOST AS FREE HIRE TO WOULD SHOW THOSE REALTIE4 TRIAL THE ATTITUDE ISSUE RESIDED CLINICS ISSUE THE RIGHT TT TO BE IN DISTRICT THE APPELLANTS RULE FACTORS THE RELATIONSHIP THAT WORKING IN INMATES THERE MATTER OF LAW THAT AS DEPARTMENT OF CORRECTIONS OF THE TOWARD THE ONE OF WHETHER APPELLANTS FIRE DO CONSTITUTE AVT ALONE ENTIRE CONSIDERED FROM THEIR WORK FORCE MEMBERS WITH ARE DISSATISFIED TO CONTROL LABOR FORCE EXCEPT IN THE MOST ROUTINE REMOVE WHOM THEY THAT MATTERS APPELLANTS SUCH SUPPORT WHETHER THE RIGHTS BELIEVE APPELLANTS IS THE ERRONEOUS IN IS COURT IT SEEMS ON THE DONE THEY METHOD CARRIED OUT CLEAR HAVE FORCE IN RECORD THAT OF THOSE PARTICULARLY THAT THE AND AS FAR THE DRUG ROOST ROUTINE THE AS THE TASK ACTUAL AS TO ABSOLUTE CONTROL AND SUPERVISION AS TO METHOD UTILIZED IS THE MOST PART FINDING ONLY IT MATTER THE UP ANY FOR NOT INDEED OF GIVEN THEM DOES SIMPLY EMPLOYMENT SITUATION NORMAL LABOR MATTERS SINCE WORK THAT THE REALLY EXERCISE THEY CONTROL OF THE HAVE COMPANIES FACT WOULD IN AS THEY JUST CORPORATIONS HAVE PRIVATE WHETHER IN OR RECORD REGARDLESS OF THE TECHNICALITIES ISSUE FACTUAL THE MATTER OF LAW AND THAT AS FINDING THAT URGE TO BE CARRIED OUT IN DICATES THAT HUNDREDS OF DEVICE HERE CLEIM AS FACT THE ECONOMIC DEFENDANT DRUG COMPANIES REALITY ARE INVOLVED IT LIES DID ONE IN OF THEIR HAVEOBTAINEDT HP WORTH OF LABOR THEY IN SITUATION OR OBTAINING THOUSANDS OF DOLLARS HARDLY THE OF IN BRIEFS FREE BY USE OF THE TO THE MOUTHS OF DEFENDANTS SUBMITTED TO THE LOWER COURT IT IS SUBMITTED THAT ON ITS FACE CORPORATION EMPLOYING THOUSANDS OF PERSONS IS NOT INTERESTED IN THE ASSISTANCE OF FEW INMATES BECAUSE OF OF SAVING DESPITE THE WERE IRIITTATES RECTIONS AT PER PAID DIEM LABOR THE FACT FOR THEIR RATES FR COSTS THAT THE SERVICES EEFRALLISHED DISTRICT BY THE BY 21 THE COURT FOUND LHAT DEPARTMENT OF FLEPARTMENT THE COR ECONOMIC THAT IS REALITY AND COMPANIES DRUG THE COST OF THEIR AS INDICATED COMPA4ES HAVO OF THE FACT THAT PRISON FACT IN EMPLOYEES SUBJECT TO CONTROL OF HIS OUT THE PERMISSION THE JOB AT TIME ANY THIS EMPLOYERS AND INTERFERE WITH HAVE BECAUSE THEY MEET THE HIS JECT OFFICIALS THE BE IT RULES IS THE TEST EMPLOYEES CONTROL ALL DECISIONS MADE MOST NATURAL AND IS OP NOT EMPLOYEES BECAUSE THE THAT HE IS NOT WORK MAKE HIM FROM WITH QUIT NOT EMPLOYED BE SUBJECT CAN BE TO TWO DOESNT NECESSARILY OF ONE TO COURT EMPLOYEES ARC THEY NATURAL IN VESTED BY THE PRISON IT IS LOWER YET THE COURT STATES AT NOT EMPLOYEES THEY IN THE DO NOK SUB AND PRISON WHEN TO WORK FOR THERE OFFICIALS CLEAR COURTS FINDING THE ARC THE TO BE EXPECTED WORLD THAT OF 22 AND APPLYING PRISONERS THE PRISONERS THE WORK IN PRISONERS AUTHORITY ARE OVERSIGHT CONTROL BASIS OF BEING THING COMPANIES USE PRISONERS REAL THE OR PERMITS PRIVATE ONERS ARE CONTROL CIRCULAR MEET THE REGULATIONS THE THE COULD HE IS PERSON UNEMAN EVERY HE COULD THEY REASONING OF THE EMPLOYER SUFFERS THIRDPARTY THEM AND WITH BE NOT PREVENT HIM DOES THAT PAY CANNOT THEY NO QUESTION THAT SIMILARLY SEEMS OF BEING AND MAY BE PARENTS AND IS NO ONE WOULD SAY THAT TEST TO CUSTODIAL IT EXISTS THE TO CUSTODIAL SUBJECT MOAN THAT THIS YET WHAT AMOUNT THEY ARE NOT THERE TC CONTROL OF THE OTHER DONRT TEST DOES ANOTHER TWO JOBS THE REALITY ABOUT SAY INMATES JOB THE ENTIRE ECONOMIC THE PARENTS HOWEVER OF CAUSE OF TO THE DRUG BY ALREADY REFERRED AN ANALOGOUS SITUATION MINOR WHO WORKS AT AN EMPLOYEE OF EXHIBITS AUTHORITIES CIPATED BEING DEAL GREAT THE CONTROL BY THE BORNE IS EMPLOYMENT PAGE WHEN THAT THAT 25 SHOULD IN CUSTODIAL THE HIS PRIS THE COURT DOES NOT NOW NEVERISHELESS HOLD THAT ANY PRISONER WHO IS ASSIGNED TO PERFORM WORK FOR BY PRISON OFFICIALS PRIVATE CORPORATION ON THE PENIBENTIARY BE CAUSE OF HIS PRISONER PREMISES IS STATUS OUTSIDE THE COVERAGE OF THE FAIR LABOR STANDARDS ACT WE ONLY FIND THAT ON THE PRESENT FACTS PLAINTIFFS ARE NOT IN ECONOMIC REALITY CMPLOYEES OF DEFENDANT DRUG COMPANIES AS THAT WORD IS DEFINED IN THE 206A ACT IT IS HARD TO TO BE WITHIN ONERS AT SUPERVISION CLEAI NOT ONLY THE THEIR THEIR SUBSTANTIAL IN AMOUNT AND IS THE TO APPLY THE THAT THEY IN PRISONERS WHO ARE SUCH CORRECTIONS DEPARTMENT AND ARE NET IX STILL MICH CASE 194E3 ARE INDEED OF LLUNTLEY PAID NO ONE OF ILUNTLEY TO OF THE SUBSTANCE IN GOING SUBJECT IT THIS TRANS FURTHER CASE WOULD IN WORK RELEASE RATE FOR CIVILIAN TO CONTROL BY THE SEEMS WOULD ARGUE THAT CONCERN THEY WORK FOR VS HOWEVER THIS JUDGE OBVIOUSLY GUNN FURNITURE CASE IS CLEARLY PLACED GREAT RELIANCE CC 79 FSUPP DISTINGUISHABLE 110 WD FROM THE IN FACT MICHIGAN LAW PROVIDES THAT EVEN PRISONER ON PAROLE SHALL REMAIN IN THE LEGAL CUSTODY AND UNDER CONTROL OF THE CORN MISSION SEC 282308 YET OBVIOUSLY PAROLEES ARE NSA KEPT FROM BEING IS THE DRUG DRUG COMPANIES THE AND IT BORNE BY THE DRUG INURES SITUATION THE GUNN THE DISTRICT ON THE IS THE EMPLOYEES OF THE PARTICULAR APPLICATION UNDISPUTEDLY ALLOWED TO PARTICIPATE INCARCERATED THOUGH ACT SERVICES TO THE PRISONERS LABOR EVEN WOULD HOLD SERVICES WORK FOR THE ARGUMENTS APPLICABLE PROGRAM AND YET THEY OF THEIR FACT PRIS COURT DEFENDANT DRUG COMPANIES THE BY OF COMPANIES OF IS JOB VALUE ALSO ALL LABOR STANDARDS COST BUT IS FAIR THE THAT THE COMPANIES ACTION WHAT SITUATION IN IMAGINE EMPLOYEES BY SUCH CUSTODY 23 AND CONTROL ONE INSTANT C4 THE THAT IN THE SUMXNARIZINQ OF THE ALLEGATIONS FA6TS THE COURT IN HUNTLOY STATED CCMPLAINTT OF WERE INMATES SHOW THAT PLAINLIFFS THAT THEY WERE UNDER THE STATE PRISON AND SUPERVISION SOLE CONTROL DIRECTION AND OF THE MICHIGAN PRISON INDUSTRIES THE COURT WENT SLATE TO CTI EMPH ADD OFFICIALS PRISOTI THE COMPLAINT NOT ALLEGE OR WAS ANY COLLUSIVE AND MICH ARRANGEMENT BETWEEN DEFENDANT FOR THE INTENT IGAN PRISON INDUSTRIES THE LAW OF THE AND PURPOSE OF EVADING THE STATE OR THE APPLICATIONOF THAT INTIMATE DOES THERE ACT THE ABOVE THIS TWO STATEMENTS CASE HERE WERE SUBJECT PLAINTIFFS DANTS WE HAVE CONTROL TO DIRECT HAVE TO AVOID ALLEGED THAT TIHE PARAGRAPH 10 OF PLAINTIFFS ALL OF THERE OF APPLICATION SWORN STATEMENTS AND ALLEGED DIFFERENT STRIKINGLY SHOW FACTS BOTH SUPERVISION OF THE CONSPIRACY IS THE LAW OF AMENDED COMPLAINT HE THAT FROM PLAINTIFFS DEFENDANTS BETWOEN THE STATE AND DEFEN OF MICHIGAN STATES ACTS AND ACTIONS COMPLAINED PLAINTIFFS OF BY WERE ACCOMPLISHED BY OF ALL THE THE AGREEMENT AND COOPERATION BOTH CORPORATE AND INDIVIDUAL DEFENDANTS AND THE ILLEGAL UTILIZATION NAMED HEREIN LABOR INURED TO THE BENEFIT OF PLAINTIFFS OF ALL DEFENDANTS FURTHER SAID ACTIONS CONSTITUTED IN FACT OR IN LAW AN ATTEMPT THE LAWS OF AND VIOLATE TO EVADE AVOID THE USE OF OF THE STALE MICHIGAN REGARDING AND THE LABOR PROFIT FORPRIVATE PRISON STATES AND THE UNITED LAWS OF MICHIGAN REGULATING THE MINIMUM WAGE TO BE PAID FOR OF THE LABOR THE TIFFS WERE INCORRECT ETA DISTRICT IN JUDGE TRYING STATED IN TO DISTINGUISH 24 HIS THE OPINION HUFLTLEY THAT CASE PAIN ON THE BASIS IN THAT THE THE INSTANT WHILE CASE WORK FORCE CONVICT THE DRUG COMPANIES DISTINCTION IN HIS EXERCISE SUPERVISION HUNTLEY ONLY PRISON STATED OPINION OVER THAT THE INMATES DITECTED EMPLOYEES TO MAKE SUCH WOULD IN HUNL1E IGNORE THE ALLEGAFRION THAT THE PRISON EMPLOYEES WHO SUPERVISED THE INMATES WORK IN THE STAMPING IN THEIR UNDER THE WERE PLANT SUPERVTSION AND DIRECTION OF THE DEFENDANL2 79 SUPP AT 112 SINCE THOSE ALLEGATIONS HAD TO BE ACCEPTED AS TRUE FOR THE PURPOSES OF THE MOTION TO DISMISS THE HUNTLEY COURT WAS REQUIRED TO ASSUME THAT THE DEFENDANTS IN THEIR AGENTS SUPERVISED PLAINTIFFS ROUTINE WORK AT THE STAMPING PLANT THAT ASSUMPTION CORRESPONDS TO THE UNCONTROVERTED FACTS NOW BEFORE THE COURT 204A APPELLANTS STATING RELEVANL THE BELIEVE THAT ABOVE THE LE THE THE COMPLETE RAISED POINT DISTRICT DISTRICT IS JUDGE ERROR IN IN HUNTL FROM THE QUOTATION BY THE WAS SIMPLY JUDGE AS CASE FOLLOWS THEY ALLEGED THAT THE SUPERINTENDENT GENERAL FOREMAN NIGHT SUPERINTENDENT PAINT FOREMAN SUPERINTENDENT OF THE TOOL ROOM AND OTHER EMPLOYEES OF THE OF WHOM WERE NOT INVOLVED IN THE PRESENT INMATESANDNOT SUIT WERE TO BE PAID BY THE DEFENDANT IEKTHEIR SERVICES IN SUPERVISING THE INMATES IN THEIR WORK IN THO STAMPING PLANT AND THAT THESE EMPLOYEES OF THE PRISON INDUSTRIES WERE UNDER THE SUPER PRISON INDUSTRIES VISION ARID OFDCFCNDANT DIRECTION EMPH ADD TO APPELLANTS THIS LANGUAGE SEEMS CLEARLY TO INDICATE WERE AT ALL ROUTINE WORK UNDER THE CONTROL OF REPRESENTATIVES THE PRISON DOING THEIR TIMES BOTH IN INDUSTRIES THE WORK BY PRISON TERMS FACT OF OF THEIR THEIR AUTHORITIES 25 CUSTODY AND THE INMATES THEIR EVERYDAY OR EMPLOYEES SUPERVISIONAT APPELLANTS THAT OF WORK IN BIEVE IS CRUCIAL FACTOR DISTINGUISHING BEARING ON THE QUESTION LII THE WORK HAS IN ELEMENT ALL THE CONSIDERED BOON ALWAYS THEIR DETERMINING CASE FROM THE EUNTLEY RIGHT OF PERSONS IN TO CONTROL NOT THE SOLE IF AND CASE THEY WERE EMPLOYEES OR NOT OF WHETHER AFTER DRUG COMPANY THIS CRUCIAL LEAST AT THEIR AS EMPLOYEES STATUS CONCLUSION IN FINALLY ABOUT THE OF INTENTION THE CONGRESS ACT AND HIS BROAD COVERAGE THE DEVELOPMENT OF THIS BASIS THE VERY CRIMINAL TO MAKE CLEAR NOT TO THE DEFINE TERM PRIVATE CORPORATIONS BETWEEN CONVICT AND EMPLOYEE FREE THE IN FINDING THIS COURT CASE SHOULD FURTHERMORE SHOULD OF LOWER THE AND IT IS IS HAS BEEN BY THE QUOTED IT IN ITS SPEAKS CLEAT OF THIS EARLIER CASE ON COURT BY CASE WOULD POLICY SEEM WOULD POLICY TOWARD THE COMPETITION OF DEFENDANT DRUG CLAIMS COURT THERE ARE SERIOUS NOT ONE WITH REGARD TO ISSUES FACTUAL COUNT OF IN WHICH THE SUMMARY JUDGMENT ON THE BASIS WERE SUCH DECISION PCOPER APPELLANTS URGE THAT CIRCUMSTANCES OF THIS IN THEIR FAVOR UNDER THE AND COMPANIES DECISION BE MADE BE WAY SO AS TO ENCOURAGE SUCH MADE HAVE THAT LABOR THE DESPITE THINK AND CONGRESSIONAL POLICY TO VIOLATE JUDGE AS NOTED COVERAGE STATUTES FEDERAL THAT DISTRICT APPELLANTS CONGRESS INTENDED THE OPINION IT CASE TI THE DISTRICT DID ERR IN COURT GRANTING SUMMARY JUDGMENT TO DEFENDANTS WERE NOT EMPLOYEES WITHIN PLAINTIFFS OF PLAINT SET MICHIGAN ACT FORTH THE DISTRICT THE APPELLANTS THE APPOLLEES OF II CLAIM IN PERTINENT ANSWERED COURT UNDER WAGE LAW NO NO SAY THE TILE YES SAY PLAINUFFS SEC 172551D725516 PROVIDES MINIMUM MICHIGAN THE COUNT BECAUSE AMENDED COMPLAINT OF PLAINTIFFS TI ON COUNT COXNPLAINT MINIMUM MSA AND AMENDED WAGE LAW OF THE COM STATE SEC 1725514 OF OF THAT PART ACT SHALL NOT OF THIS IS WHO SUBJECT TO EMPLOYER APPLY OF THE FEDERAL THE MINIMUM WAGE PROVISIONS AS FAIR LABOR STANDARDS ACT OF L938 PROVISIONS TO ANY AMENDED THE ACT CONTAINS THE DEFINITIONS FOLLOWING RELEVANT TELTLPLOYEEI MEANS IN SEC AN INDIVIDUAL BETWEEN THE AGES OF 18 AND 65 YEARS EMPLOYED BY AN OMPLAYER ON THE PREMISES FIXED SITE OF THE EMPLOYER 01 AT DESIGNATED BY THE EMPLOYER ANY PERSON FIRM OR THE STATE AND ITS CORPORATION AND IN SUBDIVISIONS AGENCIES POLITICAL IN AND ANY PERSON ACTING STRUMENTALITIES OF SUCH EMPLOYER WHO EMPLOYS THE INTEREST AT ANY ONE TIME WITHIN OR MORE EMPLOYEES SUCH EMPLOYER SHALL BE CALENDAR YEAR ANY SUBJECT TO THUIS AEL DURING THE REMAINDER OF SUCH CALENDAR YEAR MEANS INCLUDING EMPLOYER 27 172552 EMPLOY PENNIT THERE JURISDICTIONALLY FURTHER OF ING THAT POINTED IS THE NOT BUT ON HIS OF THE ACT THE RECORD BY THE THAT THERE OF DOES NOT REMEDIAL THE APPLY MICHIGAN AND FOR NATURE OF THE LAW SHOULD BE ACT THAT COURT OF RELATIONSHIP FOUND BASED FAIR LABOR URGE THAT FOR ALL BE CON MINIMUM WAGE SHOULD THEY MICHIGAN URGE THAT TO TAKE INTERPRETED UP THE REASON TAKING THE LEGISLATION COURTS EVEN MORE BROADLY ABSENCE THE ISSUE CREATED CASE THIS FURTHER APPELLANTS TENTION RELATIONSHIP UNDER THE FACTUAL IS CON EMPLOYEES WERE NOT OF THE MEANING MEAN THE EMPLOYEE STATUS TO THE APPELLANTS ARE BUT OPINION THE COURT THEN INMATES THE WITHIN HIS MASTER REFERENCE LAW WITHIN SURROUNDING IT C209A VERY LEAST IH THE WAGE OF THE WITH REGARD TO COUNT STATED EMPLOYEES QQ7A WITH PLAINTIFF LAW ACT SITUATION COUNT WAGE ERNPLOYEES OF PROVISIONS DRUG COMPANIES NOT MICHIGAN OF THE MINIMUM IN TEST FACTUAL UNDER THAT MINIMUM OR AT THE THE ECONOMIC REALITY REASONS SIDERED LAW TOTAL REASONING MICHIGAN THAT IN THAT OR THESE CONSTRUING MICHIGAN WERE COMMON LAW DEFINITION THE STANDARDS PLAINTIFFS OUT RATHER THE INCLUDING TO THE WORD AS DEFINED RECTLY ENGAGE SUFFER COURT FOUND SUBJECT THAT TO MICHIGAN DISTRICT THE FOUND IN BEEN NO CASES HAVE MEANS WORK TO IT SLACK INTO WORD WAS THE WHERE FEDERAL CONSIDERATION EMPLOYEE AND WOULD BA INTERPRETED THAN DETERMINATION WAS BOUND TO MAKE ITS BY UNDER THE THE MICHIGAN FEDERAL IN BY THE LAW THE IN LAW THE STATE MICHIGAN TN THE COURTS THE EJISTRIEL OWN DETERMINATION 28 CLEAR THE POWELL DISSENTING LAW OF MICHIGAN THE SEC COMM EMPLOYMENT LHIS CII MICH 345 TALBOT OF JUSTICE OPINION 455 1956 SMITH HAS IN BECOME SUBJECT ONE OF ECONOMIC THE TASK PERFORMED LARGER PART OF CONTRIBUTION TO THE COMMON TASK COMMON OBJECTIVE ACCOMPLISHMENT OF THE TEST IS FAR FROM THE CIT OMIT COMMONLAW TEST OF CONTROL SINCE THE WITH THE CORRECTION ACT CONCERNS ITSELF EVILS OF ECONOMIC THROUGH REMEDIES WHICH CIL AT THE COMMON LAW UNKNOWN WERE THE TEST RATHER LOOKS AT THE OMIT WORKMEN TO SEE WHETHER OR NOT THEIR WORK PART OF THE CAN BE CHARACTERIZED CIT INTEGRATED UNIT OF PRODUCTION ITS IN WHETHER THE WORK DONE OMIT AND AN USUAL OF THE FOLLOWS PATH ESSENCE IN APPLYING CIT OMIT EMPLOYEE CONTROL IS ONLY ONE OF MANY SUCH TEST THE ULTIMATE FACTORS TO BE CONSIDERED QUESTION IS WHETHER OR NOT THE RELATION IS OF THE TYPE TO BE PROTECTED SHIP THE EMPLOYED IS TEST IT LOOKS AT REALITY WHETHER OR NOT IT IS REBECCA COHEN BY THOSE STANDARDS HER WORK IN AN EMPLOYEE WAS CLEARLY ESSENCE FOLLOWED THE USUAL PATH OF AN IT WAS AN INTEGRAL PART OF HER EMPLOYEE CONBRIBUTION IT WAS EMPLOYERS BUSINESS IF CONTROL AND TO THE COMMON OBJECTIVE HER CLEAR THAT IT IS REMAINS THE TEST EXERCISED OVER HER ALL OF THE TESTED EMPLOYERS HER CONTROL THIS APPLYIFLY COURT SHOULD DISTRICT IF NO SUBJECT MINIMUM WITH WAGE REGARD JUDGMENT TO THE HAVE TO DEFENDANTS DEMANDED CONCEPT FOUND FEDERAL OR AT THERETO WORK THE THAT ACT THE VERY COUNT WERE PLAINT 29 INSTANT OF CASE THE DEFENDANT DRUG COMPANIES TO THE SUBJECT THAT COURT TI THE THE LEAST DISTRICT UNDER TO ERRED FACTUAL IN PLAINLIFFS MICHIGAN ISSUE GRANTING EXISTED SUMMARY AMENDED COM IV THE DID NERE NOT DEPRIVED PLAINTIFFS WE NOT INTENDED MICHIGAN PRISON THE APPELLANTS THE APPELLEES DEPRIVED DISTRICT THE MENT THEORY IS IT THAT THE PERSON THE IT DECLARATION THEORY THE REQUISITION CONDUCT OF THEIR ANCN OF WHICH SERVICES OF DEFENDANTS NECESSARY TO START LABOR SOCRNS OF OF EVERY THEY GJA FOR SUMMARY JUDG TUE GENERAL PRO COUNTY BELONGS TO MOTION THAT USE THIS IN PERSON AND THEIR OTHER THE FOURTEENTH AMENDMENT BASIC LEGAL DOCUMENTS OR STATEMENT PERSON IS OF MLCHIGAN AND OUT WITH UNNECESSARY TO CITE INDEPENDENCE TO SUBSTANTIATE STATE OF THEIR III OF RECOVERY WHEN OF II NO SAY VALUE THE BY NC COUNT PLAINTIFFS THAT YES SAY COURT ALSO GRANTED DEFENDANTS ON THIS POSITION ACT SUED UNDER COUNT REASONABLE UNDER THE COURT ANSWERED DISTRICT PLAINTIFFS BECAUSE PLAINTIFFS BENEFICIARIES INDUSTRIES THE III OF PROPERTY LAW AND BECAUSE UNDER MICHIGAN WERE ILLEGALLY ON COUNT AMENDED COMPIATNT OF PLATNTIEFS FOR THE GRANTTNG IN JUDGMENT TO DEFENDANTS SUMMARY COMPLAINT EIU COURT DISTRICT AULHORIZE LABOR TO LAWFULLY LHE INCARCERATED DEPARTMENT CERTAIN 20 THE TATULES OF CORRECTIONS EXTENT AND THE TO CONDITIONS CT WHICH THAB UNDER TO THIS TC LABOR FOR THE ARTISTIC IS BENEFIT CLEARLY AT OR COULD NO AS WORK IT ACTING APPLICABLE SET THAK BY THE STATE BUT ONLY THE TO THE ALTHOUGH THIS TO IT ARE CLEAR LABOR EXEEPL THEM THEY WERE DEPRIVED THE STATE THE REQUIRE FROM WHICH IN WITH STORIES THE FOR ANSWER OF SOUTHERN WORK OF THE RIGHT LABOR INMATES CLAIMED OF THIS PROFITS IS LEGALLY OF PRISONERS GIVEN THE BEYOND THAT PROTECTED PROPERTY INTERESL FLOVCL SITUATION PLAINTIFFS SO FAR OF PROPEREY IN GENERAL ROLE IS THAT TO THE THE THE SINCE WITH NOBODY HAS EVER EXTENT IS WRITE TO TO PERSON PRISON STATE MI EXHIBITIONS TO PLAINTIFFS ENTIT LED AND INVADING ILLEGALLY MUHAMXNED COMPEL INMATES IS WOULD ANYONE CONTEND OR AX AUTHOR SHOP TO REQUISITION RIGHT OF THEIR THE THE OF ALL DEPRIVED OR FIGHT FACT CRAFTS NOT EXAMPLE COULD SEEMS OF STATE TO REPEAL PRISONERS FRUITS FOR CAN TT MATTER AND RE INMALES PICTURES STATE AN ARLE CLAIM HAS THE THE PRICES STATE IS TO THE OUT SPELLED CAREFULLY GIVEN CHAMPIONSHIP STATE TO PAINT OF HAS SOLD SORT OF THAT OWN LABOR GO TO THE ABILITY MICHIGAN IS CLEAR HEAVYWEIGHT MONEY TO THE IS DEPARTMENT OF CORRECTIONS THE THE IS TO THEIR RIGHTS FIGHT LABOR ARE EXTENT IT THAT BE UTILIZED PRISONER EXTENT THIS THEIR CAN AS THIS FORMALLY THE PRINCIPLES WERE ENTITLED IT WAS LEGAJLY TO TAKEN CASE STATED AS FOLLOWS AND WHERE ONE PARTY WRONGFULLY COMPELS TO RENDER HIM VALUABLE SERVICES TO VALUE IS IMPLIED PROMISE PAY THEIR SO TO PAY FOR SERVICES RENDERED WILL BE PROMISE IMPLIED AGAI INST WRONGDOER WHO NEVER INTEN6ERI TO PAY OR WHO INTENDED TO AVOID DECEITFULLY ANOTHER 31 OF THE FROM THE RENDITION OF SUCH SERV ICES IS SECURED THROUGH DURESS COMPUJSION OR FRAUD MAKES NO DIFFERENCE WHERE WITHOUT LEGAL ONE IS COMPELLED TO PERFORM WORK FOR AUTHORITY AN IMPLIED ANOTHER THE LAW RAISES CONTRACT FOR FOR THE VALUE OF THE SERVICES RENDERED COMPENSATION WORK AND LABOR EEC 12 PAGE 737 98 PAYMENT CYS MC LAW OF MICHI IN THE PERFORMANCE OF LABOR LAW WILL THE MICHIGAN OR THE WERE PERFORMED OR RENDERED AT LEDGE AND ASSENT CIRCUMSTANCES APPROPRIATE LEADING MOREOVER MICHIGAN AT SUCH THOUGH STATES REQUEST PROMISE WILL RULES THIS HIS BE IMPLIED ACT FOR WHERE THEY OR WITH NO TORTIOUS THE TO PAY PROMISE OF SERVICES RENDERING ANOTHERS EVEN AUTHORITY IMPLY IS KNOW UNDER INVOLVED WAY LAW TORT ARISING OUT OF CONTRACT BETWEEN THE PARTIES OR CONSISTING CONVERTFLOA OF PROPERTY INTO MONEY OR MONEYS WORTH MAY BE WAIVED AND SUIT MAY BE BROUGHT IN ON CONTRACT OR PROMISE ASSUMPSIT IMPLIED BY LAW NOTWITHSTANDING THE FACT THAT AN ACTION OF ON THE CASE MIGHT HAVE BEEN BROUGHT TRESPASS UNDER THE STATUTE THE RIGHL TO WAIVE TORT AND TO MAINTAIN ON CONTRACT OR PROMISE ASSUMPSIT IMPLIED THE BY LAW IS EXTENDED TO CASES CONVERSION OF PERSONAL PROPERTY INTO MONEY UAL OF AND FURTHER THE COMMON RELATION SAME AUTHORITY STATES LIES WHERE LABOR HAS BEEN SERVICES RENDERED PURSUANT TO PERFORMED OR CONTRACT EXPRESS OR IMPLIED ALTHOUGH THE CONTRACT IS NOT BINDING BECAUSE OF FRAUDS OR UPON PLAINTIFF MISTAKES OF DEFENDANT OR ITS TERMS ARC NOT ENFORCE ABLE BECAUSE OF THE STATUTE OF FRAUDS ASSUMPSIT CNCRALLY IN THE ABSENCE OF AN EXPRESS CONTRACT FOR LABOR OR SERVICES AND PAYMENT OF COMPENSATION AS WHERE LABOR WAS PERFORMED AT ANOTHER REQUEST OR WITH HIS KNOWLEDGE AND ASSENT AND THERE IS NO EVIDENCE OF CONTRACT PRICE OR WHERE SERVICES WERE RENDERED AND ACCEPTED WITH FULL KNCVULEDGE OF THE FACTS BE MAIN ASSUMPSIL MAY ORDINARILY TAMED FOR THE REASONABLE VALUC OF THE LABOR PERFORMED OR SERVICES RENDERED UPON AN IMPLIED VALUE THEREOF PROMISE TO PAY THE REASONABLE MICHIGAN PLEADING AND PRACTICE VOL SECTIONS 6210 AND 6220 32 THE CASES TIONS THIS SUPPORTING SUFFICE WILL AN ACTJON VS DONOVAN FEW HALSEY FTRE DEFENDANT AND THE AGAINST CITA AND LEGION RECOVERED FOR LABOR PLAINTIFF OF ASSUMPSIT FOR PLAINTIFF JUDGMENT IN AS EXANPIES COMPANY 58 MTCH38L885 IN ARC PROPOSITION ENGINE PERFORMED COURT SUSTAINED THAT HOLDING SOME POINT WAS MADE ON THE HEARING THAT BY THE BYLAWS OF THE COMPANY NO DEBT COULD BE CON TRACTED EXCEPT BY ORDER OF THE BOARD OF DIRECTORS THERE THERE IS NOTHING HOWEVER IN THIS POINT TO HAVE BEEN NO QUESTION ABOUT THE LEGAL OR THE FACT THAT IT OF THE DEFENDANT OF THESE DID AND EMPLOYED THE SERVICES MEN WHOSE CLAIMS WERE HELD BY THE PLAINTIFF SEEMS BUS EXISTENCE THERE IS NO PRETENSE THAT THE COMPANY DID NOT FOR THE AMOUNT RECEIVE GOOD AND VALUABLE SERVICE BE OF CLAIMS RECOVERED AND THAL IT WAS SOUGHT TO THE BENEFIT OF THE FOR COMPANY AND WITH ITS KNOW THE ASSURNPSIT ALONE UNDER SUCH IMPLIED LEDGE CREALE THE LIABILITY SUFFICIENT TO IS FACTS SIMILARLY IN PLAINTIFF SUED RENDERED BECAUSE DICT LEDGE ON THAT THE BY THE AND THE SCHOOL DISTRICT DEFENDANT SCHOOL DISTRICT ON THE CLAIM HE HAD SHOW THAT VS SUPERINTENDENT AS THE SISTED DAVIS BASIS THAT GROUND AND REFOSED RENDERED BOARD OF TRUSTEES MICHIGAN SUPREME COURT THE MICH TO RECOVER SCHOOL BY HIM WERE ON APPEAL FOR SERVICES TEACHER VER DIRECTED OFFER OF PROOF PERFORMED WILH THE RE DEFENDANT QUALIFIED LOWER COURT PLAINTIFFS 1890 214 YEAR HE WAS NOT AND THE NO CERTIFICATE SERVICES THE DURING 81 CASE KNOW WAS REVERSED STATED WHERE RECEIVES CORPORATION MONEY MUNICIPAL UNDER SUCH CIRCUMSTANCES OF OR PROPERTY PARTY OF CONTRACT THAT THE LAW INDEPENDENT THE TO THE CORPORATLON OBLIGATION UPON IMPOSES DO JUSTICE HELD THAT RESPECT TO THE SAME IT HA TO AN ACTION MAY BE LIAB1R WITH IT 33 TO BEEN WLC II ITJ THE SUPREME COURT AT 100 PAGE IN FOLLOWING DETROIT VS WAS APPROVED BY THE LANGUAGE PARK HIGHLAND 326 MICH 78 TT MICHIGAN 1949 CONTRACTS THERE ARE TWO KINDS OF IMPLIED IN IN FACT AND THE OTHER IMPLIED IMPLIED THE DOES NOT EXIST UNLESS LAW THE FIRST ONE MINDS OF THE PARTIES MEET BY REASON OF WORDS SECOND IS OR CONDUCT THE QUASI OR CONSTRUC AND DOES NOT MEETING OF MINDS REQUIRE TIVE OF LAW TO ENABLE BUT IS IMPOSED BY FICTION EVEN IN CASE NO TO BE ACCOMPLISHED JUSTICE CONTRACT WAS INTENDED IN ORDER TO AFFORD THE REMEDY DEMANDED BY SUCH REMEDY TO AND ADJUST EXACT JUSTICE OL THE LAW SOMETIMES INDU‰ES CAUSE OF ACTION CONSTRUCTIVE CON IN THE FICTION OF OR QUASI TO FOR WITH AN PAY IMPLIED TRACT THE COURTS HOWEVER EMPLOY RECEIVED BENEFITS AND WILL NEVER PER THE FICTION WITH CAUTION IN IT IN CASES WHORE CONTRACTS IMPLIED MIT SUBSTITUTE ONE FACT MUST BE ESTABLISHED OR PROMISE OR DEBTOR FOR ANOTHER THE THERE INMATES THE WERE LABOR REMAINS IN FACT IT IS MANDATE THIS MICHIGAN STATUTES THE ONLY LAW AND SHALL IS POLICY NOT PRISON AND OF WHETHER PLAINTIFF THEIR STATE LABOR AS THAT OF MICHIGAN FOR PRIVATE CLEARLY LABOR FROM OF OF THE HO USED EXPRESSLY REGULATING QUESTION DEPRIVED ILLEGALLY THE OF PRISONERS PROFIT ACTS OF DEFENDANTS ILLEGALITY OR CORPORATE SPELLED OUT IN THE FOLLOWS ACT SHALL AND AFTER 60 DAYS AFTER THIS SHALL BE UNLAWFULL TO SELL OR LAW IT BECOME OR TO OFFER FOR SALE OR OR EXCHANGE EXCHANGE TO PURCHASE ANY PRISON PRODUCTS EXCEPT PURE BRED LIVESTOCK RAISED ON THE SEVERAL PRISON FARMS AND SOLD FOR BREEDING PURPOSES7OTHENILSE THAN FOR USE OR CONSUMPTION IN THE PENAL CHARI INSTITUTIONS OF TABLE ANDOR OTHER CUSTODIAL OF THIS THIS STATE OR FOR DEPARTMENTS STATE SUHCLIVI IONS THEREOF OR THE FEDERAL OR POLITICAL THEREOF OR OTHERWISE GOVERNMENT OR AGENCIES ACT NOR SHALL PROVIDED IN THIS SPECIFICALLY BE SOLD HIRED LEASED THE LABOR OF PRISONERS 34 LOANEDCONTRAC LED FOR OR OTHERWISE USED FOR 3EVATE OR CORPORABE PROFIT OR FOR ANY OTHER WAN POSE OPERALION MSA MBA MAINTENANCE OR WORKS WAYS OR PROPERTY ASMRECTED SEC 2R1525 GOVERNOR ADDED THE EMP MANDATE THIS CONSCFI THE OF FURTHER IS EXPRESSED IN SEC 281530 WHICH STATES IT HEREBY DECLARED TO BE THE IS OF INTENIL ACT THIS TO PROVIDE ADEQUATE REGULAR DIVERSIFIED OF THE AND SUITABLE EMPLOYMENT FOR PRISONERS STATE CONSISTENT WITH PROPER PENAL PURPOSES TO UTILIZE THE FOR SELFMAINTENANCE LABOR OF PRISONERS EXCLUSIVELY AND FOR REIMBURSING THE INCURRED BY REASON OF THEIR STATE FOR EXPENSES AND IMPRISONMENT CRIMES PRI TO ELIMINATE A13COMPETITIVERELATIONSHIPS BETWEEN PRISONER LABOR OR EMPH ADDED FREE LABOR OR PRIVATE INDUSTRY THIS ALL OF THE ANCIENT STATES IN IN THIS FOR HISTORY CONSTITUTION PUBLIC EFFECT COUNTRY 1906 ONE AND SEC EXAMPLE IN IS POLICY IN RECOGNIZED ONE WHICH HAS OF ARTICLE 18 MANY IF NOT RATHER OF THE MICHIGAN PROVIDED BE TAUGHT TO TRADE SHALL HERCAFTER THIS OF STALE EXCEPT CONVICTS IN THE STATE PRISON THE CHIEF OF WHICH ARTICLES THE MANUFACTURE OF THESE FROM OTHER IS FOR HOME CONSUMPTION 5MPORTED SUPPLY STATES OR COUNTRIES NO IN THE COURT OF THE CASE MECHANICAL MANTHEY OF THIS MICHIGAN STATE VS VINCENT ENJOINED STATE PRISON 145 MICH 327 THE WARDEN AND FROM PERFORMIN9 MANUFACTURE OF BROOMS BY INMATES BECAUSE THE 1906 THE SUPREME BOARD OF CONTROL CONTRACT FOR THE SUCH ACTIVITJ VIOLATED THE THE CORRECTIONAL INDUSTRIES ACT ACT 15 1968 THE FORMER REPEALED PRISON AND LABOR TNDFLSTRIES ACT BUT THE NOW ACT CONTAINS SUBSTAN SIMILAR FOR PURPOSES OF THIS CASE PROVISIONS TIALLY 35 CONSTITUTIONAL IS IE VALID IN PROVISION THE THAT QUESTION OF PREVENTION SUCH STATE POLICY BETWEEN CONVIOL COMPETITION LABOR IIL AND 1936 EVEN IN BE LEGALLY EXACTLY OF STATE PRISON SO WOULD CERTAINLY LAWFUL WHAT IS BEING AND POLICY MENT SO AS PRISON THE DONE IN STATE OF THIS TO PREVENT REHABILITALION ARE ALSO SIMILAR TO ENFORCE POLICY AND GAIN OBJECTS DEPRIVE CLEAR CONTRACLS WHERE THEIR FOR SERIOUS THOSE LIVING YET VIOLATION THE TO LIMIT THROUGH SIMILARLY JUST IS OF THE EXACTLY STATUTES INMATE TEMPTATION EMPLOY TO THE DESIRE TO PROVIDE SHORT THE INTEREST STATE HAVE NOT HESITATED JURISDICTION TO IMPROPER UTILIZATION THE VIOJATION CRIMES ITS OF IN IF THAT OF THIS IN OXPOSITIOIL REGULATION IN TO BE LEGISLATURE LIVING OPPORTUNITIES STATES THE NO DETAILED IN COULD 1850 438 ADDITION ABUSE CONCERN OTHER REFUSE IN FOR POSSIBLE LEQIS2ATIVE PRISONERS ITS CASE SO HAD US 299 WAS VOID PURPOSE TO EARN CO CONVICTS OF COURT SUPREME CR METHOD OF DOING EFFECT RIGHT THIS LABOR FOR MEN CONVICTED WOULD IN OF OFFICIALS AND VALID PROPER LIFE TO REQUIRE STATES ILLINOIS MOTIVATING REASON BE ABSURD WORK THAT BE GIVEN AND AS CO VS MICH VS LATHROP CLEAR UNITED FOR THIS CONTRACT COGENT THE WHEN THE DAYS PRESCRIBED OR ONE IS THE THE LEASED FOLLOWED REGARD COLLAR WHIP LONG AGO 334 LV WAS ESTABLISHED LABOR FREE TO STRIICE SIMILAR LAWS WAS CONCERNED OF DOWN OR AND ROR EXAMPLE FOR ANALO THE CONGRESS OF THE UNITED STATES HAS SEEN FIT INDEED FOR KNOWINGLY TRANS TO ESTABLISH CRIMINAL REASONS PENALTY GOUS OR PRISONER MADE GOODS COMMERCE CONVICT PORTING IN INTERSTATE TITLE 19 SEC 1961 USCA 36 THE ILLINOIS COMPEL THE PUBLIC WELFARE CAR ILLINOIS THE LICENSE OF THE BEING SOLD ON THE OF THE BOARD TIFFS OPEN SO DOING THE SUPREME THE FOR 18 FOR WERE NOT PLATES STATUTE APPLICABLE THE MARKET AND THEIR NE ARKANSAS FROM APPEALED AND THE AND THE 2ND 453 SUIT OF PENITENTIARY CONV LEASING THROUGH TO BE USED PLATES WELFARE TO AVOID VS HUGHES IN TO SECURE BECAUSE THE STATE OF PUBLIC FOR MATIDAMUS PETITION DRIVERS ILL COURT IN LABOR TO BE MANUFACTURED OF RREE LABOR 1933 WAS BROUGHT TO RESTRAIN FRCM HIRING OF CONSTRUCTING DECREE LABOR PRISON WITH DC THE REQUIRED COMPETILION COMMISSIONERS PURPOSE LOWER PRODUCTS TO DEPARTMENT OF WERE TO BE MANUFACTPRED BY CONVICT WRIT WAS DENIED PARTINENT REFUSED SECRETARY OF STATE WHERE THEY FOR USE COURT SUPREME DISMISSING OUT DAM THEIR COURT OF ARKANSAS REVERSED THE DECISION MEMBERS AND THE PLAIN SUIT AND IN STATED IT IS HAVE NOT BEEN LEASED URGED THAL THE CONVICTS WITHIN THE MEANING OF THE STATUTE BECAUSE THEIR AND PHYSICAL CONFRROL IS UNDER THE SUPERVISION DIRECTION OF GUARDS AND WARDENS APPOINTED BY THE THE PHYSICAL PENITENTIARY CORNMXSSION CUSTODY OF THE CONVICTS BY THE GUARDS AND WARDENS APPOINTED BY THE PENITENTIARY COMNISSION DOES NOT AND CAN NOT PREVENT THE CONTRACT FROM BEING ONE OF HIRING OUT OR LEASING THE CONVICTS SUCH CONSTRUCTION OF THE STATUTE WOULD IN EFFECT RENDER IT USELESS AND INEFFECTUAL FOR THE PURPOSE FOR WHICH IT WAS ENACTED THE PUBLIC POLICY OF THE STATE AS SHOWN BY THE LEGISLATIVE WILL WAS TO PREVENT LETTING OF THE CONVICTS TO PERSONS OR CORPORATIONS TO BE WORKED BY THEM FOR PRIVALE GAIN TO ALLOW THE CONTRACTS TO STAND WOULD BE CONTRARY TO THE POLICY OF THE LAW AS TENDING TO RESULT IN THE OBVIOUSLY VIOLATION OF THE PURPOSE AND SPIRIT OF OUR STATUTE THE RULES AND REGULATIONS PRESCRIBING WHICH ARE TO GOVERN THE PENITENTIARY BOARD IN THE CONTROL AND WORKING OF THEN TATE CONVICTS VS JONES 261 SOUTHWESTERN 43 ARK 37 1924 SITUATION INVOLVED VS MABEY PRICE IN UTAH HELD COURT 218 PAC FOR THE MANUFACLURER OF MANUFACTURING AND THE PURCHASE THE SUPERVISION OF THE CONTRACTING OF WARDEN CONVICT WRIT OF PROHIBITION THE AGREEMENT STATC BOARD UTILIZATION RULE AND 286 THE WHICH MD SHIRT BY IN THE STATE ALL STATE OF SHIRTS PRISON LABOR UNDER THE UTAH COURT THE PRISON THE PROHIBITED SUPREME DEFENDANTS LABOR THE GRANTED FROM CARRYING OUT CO VS DCEKY PLAINTIFFS OF THE BOARD OF STATE THE WAS CONSLTTULION 737 1922 CON BY DEFENDANTS ACT CASES ARE NOT MANY IN UTILFLATION CONCERNING ILLEGAL STATED BY ONE LEGAJ SUEDINETLY UTAH CASE SEE BROMWELL BRUSH ALTHOUGH THE GENERAL WITH RESTRAINING SIMILARLY TORTINUS STITUTED LABOR OF CHARITIES ILLEGAL THE IN EQUIPR MANUFACTURER FROM MANUFACTURED THEREIN AND OVERALLS 1923 724 INSTALLATION OVERALL BY INSTANT TO THE CONTRACT BY VOID WHICH PROVIDED CORRECTIONS SIMILAR VERY AUTHORITY AS THIS AREA OF CONVICT THE IS LABOR FELLOWS TT SEEMS AGREED THAT LESSEE OF CONVICT LABOR WHO KNOWINGLY RECEIVES THE SERVICES OF CON VIOL ILLEGALLY COMPELLED TO PDRFONN SUCH LABOR IS GUILTY OF FOR WHICH TORT TOWARD SUCH CONVICT HE IS LIABLE 41 AM JUR 908 THE QUESTION HAVE AGREED QUANTUM MERUIT IN VIOL ATION RECEIVED WILL BY RAI SO AN THEORY OF THAT WILL WHICH HAVE FEW CASES RELATIVELY AN ACTION LIE OF ASSURNPSIT WHERE PRISON LABOR LAW AND WHERE THE LABOR OF CONTRACTOR THROUGH IMPLICATION OF AN ILLEGAL PROMISE UPON 38 DISCUSSED BASED UPON IS CONVICT AGREEMENT THE THIS BASIS UTILIZED HAS BEEN THE LAW OF THE TORT SO COMMITTED P1 LAST AS 191EB CITED THE BY CASE THE AT VS CONTRACTOR RHODE PAGE ISLAND SALANT THO STATEDIN CNURT SUPREME 425 96 427 OF CONVICT HAS BEEN RECEIVED CONTRACT WHICH WAS ILLEGAL CONTRACTOR UNDER BY TO MAKE THE CON EITHER THROUGH WANT OF AUTHORITY TO LABOR VOID COMMITMENT OR HOLDING TRACT OR IT HAS BEEN HAD COMMITMENT EXPIRED AFTER VALID OF RAISE AN IMPLICATION HCLD THAT THO LAW WILL COMMITTED BASIS OF THE TORT SO THE PROMISE UPON 53 ARK THUS IN GREER CRITZ BY THE CONTRACTOR THE THE STATUTE PLACED MANAGEMENT 13 764 247 OF CONVICTS UNDER THE AND CONTROL AND THE HIRING UNDER COIW OF THE COUNTY COURTS JURISDICTION TRACT WITH THE JUEGE OF THE COUNTY COURT IN VA WAS DELIVERED CATION OF THE COURT THE CONVICT HIS AND WORKED WORK OUT FINE TO THE CONTRACTOR TO THE COURT UNDER SAID CONTRACT FOR THE CONTRACTOR GIVEN BY BET THAT THERE WAS NO POWER OR AUTHORITY TO THE JUDGE OF THE COUNTY COURT IN THE STATUTE CONTRACT FOR VACATION OF SAID COURT TO MAKE THAT PURPOSE WHICH CODID BE DONE ALONE BY THE AND HELD THAT THE ORDER OF THE COURT ITSELF DEFENDANT BEING PARTY TO THE CONTRACT WAS BOUND AND THAT AS HE TO KNOW OF THIS TACK OF AUTHORITY HE BENEFIT OF THE SERVICES HAD THE PLAINTIFFS THEM TO FOR WAS OBLIGED PAY WHERE THE LABOR 8W IN GA CONVICT 1910 WHOSE LABOR BROUGHT SUIT AUTHORITIES TRACTOR AFTER HIS SUPREME COURT HELD THAT BEEN DETENTION TO YET BENEFIT THE WRONG AND THAT THE JOINT ACT OF IT SENTENCE THE LEASED THE HIS HAD RUN OUT COURT FURTHER 69 SF CUT BY THE HEM DEFENDANT IF BAD THE AND HE WAS COMPELLED TO WORK FOR DETENTION THEN COTPJFLITTED THE WA ILLEGAL DEFENDANT WAS THE COURT STATED BY ORDER 39 CON THE GEORGIA PEBITION THAT 865 STATE ON APPEAL DEMURRER TO PLAINTIFFS TORTFEASOR WAS HAD BEEN FOR WORK PERFORMED FOR WAS ILLEGAL WHO KNEW THAT DEFENDANT FACT LAWFUL PROPERLY OVERRULED TIFFS CO VS GOINGS CHATTABOOCHEE BRICK PLAIN THE AND CONTINUED PARTICIPANT FURTHER OF AN CXECNTTVE THAT OFFICER IN THE OF THE DIDNT STATE LIABLE BEING MAKE IT AS THE LAWFUL THE OR PREVENT SUMMARIZUD AT PAGE COURT DEFENDANT FROM 867 TM THE DETENTION OF THE PLAINTIFF BEYOND THE TERM OF HIS SENTENCE WAS AN ILLEGAL OF DEPRIVATION HIS AND HE WAS COMPELLED LIBERISY TO WORK FOR THE AND THE LATTER ZIENDANT HJTHSENTENCE KNOWIN HAD TERMINATED AND THAT HIS DETENTION WAS ILLEGAL CONTINUED TO FURNISH MAINTENANCE TO RECEIVE PHE BENEFIT OF SUCH WRONG TO HAVE THE PLAINTIFF UN TO WORK FAIR AND TO TAKE IT LAWFULLY IN THE WRONG PART CHEREVN IT WAS DONE AND WAS TORTTFEASOR WITH THE PITR JOINT CIPAL CASES LIE WHO MALICIOUSLY PROCURES AN HJURY TO BE DONE TO ANOTHER WHETHER IT B4 AN ACTIONABLE BREACH OF CONTRACT WRONG OR IS JOINT WRONGAOER AND MAY BE SLLCA EITHER ALONE OR JOINTLY WITH THE ACTOR CIV CODE 1895 SECTIONS 3853 ONE WHO AIDS ABETS OR 3873 OR ENCOURAGES OR DIRECTS INCITES BY CONDUCT OR WORDS IN THE PERPETRATION OF IS TRESPASS LIABLE 22 AM EQUALLY WITH ACTUAL TRESPASSERS ENE LAW 2ND EDJ 566 567 TN ADD TORTS WOODS SECLION IT IS SAID WHOEVER 1321 ASSISTS IN THE DOING OF AN UNLAWFUL WILLFULLY ACTI BECOMES ANSWERABLE FOR ALL THE CONSEQUENCES OF SUCH ACT TT COWJ WRONQDOE ED IN SIMILARLY MD WITHOUT THE THE 1862 FORCED ON THE KNOW THE STATE THE TORT AND AND BENEFITING MANCE SUCH THE AND THE LABOR IN IT FROM IL HELD WHAT IT IS WORDS OF THE AGAINST HAD TORT AND THAT THE THE THE IRNPL WORTH AND THE OF COURT AT PAGE LESSEN THE 442 40 DEFENDANT ONE ACCEPTING PLAINTIFF COULD WAIVE PERSON TITILIZING HIS ASSENT TO ITS PERFOR AS REASONABLE BY COURT BY TO THE 367 EMPLOYER WAS PRESUMED TO THAT TO HAVE LAW LEASED COMMITTED HELD BECAUSE WAS DEEMED BEEN IS THAT WAS FURTHER ASSURNPSIT COURT PLAINTIFF LABOR PLAINTIFF LAW SUE HIS AM DEC 81 CONVICTED PRISONER HAD BEEN HEJD THAT COURT APPELLATE LABOR PLAINTIFF JURISDICTION VS PRIOR PATTERSON PROMISE AFFIRMED PLAINTIFFS TO PAY FOR JUDGMENT LABOR LABOR IN FOR THE AT THE TIME THE APPELLEC WAS CONVICTOD AND SENT TO THE PENITONTIARY THE COURT OF COMMON IN THAT BEHALF HENCE HAD NO JURISDICTIOI PLEAS THE CONVICTION AND JUDGMENT WORE NULLITIES AND FURNISH APPE11ANT NO PROLECBION FOR THE HIM IN THE PENITEN TORT COMMITTED IN CONFINING TIARY PATTERSP MD 12 241 MUST THE APPELLANTS PRESUMED TO HAVE KNOWN THE LAW AND THAT THEY HAD NO LEGAL RIGHT TO THE APPEJIEE OR CAUSE HIM TO LABOR IMPRISON TO HIM IN THAT THEY MAY HAVE BEEN RESPONSIBLE THEY UNDOUBTEDLY SOME FORM CANNOT BE DOUBTED COMMITTED TORT AND THE QUESTION HERE IS WHETHER THE TORT CAN BE WAIVED AND AN ACTION WE WILL MAINTAINOD EN AN IMPLIED ASSUMPSIT EXAMINE THIS SO FAR AS IT RE FIRST QUESTION LATOS TO PATTERSON HE IT SEEMS WAS THE LESSEE OF THE PENILENTIARY AND RECEIVED ALL LABOR HE MUST THE B6NCTIT OF THE APPELLANTS BE PRESUMED TO HAVE ASSENTED TO THE PERFORMANCE OF THE LABOR AND BEING BENEFITED THEREBY THE LAW IMPLIES PROMISE TO PAY WHAT IT IS TN OUR OPINION SO FAR REASONABLY WORTH THE TORT AS PATTERSON IS CONCERNED MAY BE HE MAINTAINED AND ACTION ON THE WAIVED AN IS THE EN HOWEVER IMPLIED ASSUMPSIT CASE DIFFERENT AS TO MILLER THE WARDEN OF THE TIRELY HE RECEIVED NO BENEFIT OF THE PENITENTIARY LABOR AND NOT HAVING BEEN BENEFITED PLAINTIFFS TO SUPPORT THERE IS AS TO HIM NO CONSIDERATION AN IMPLIED ASSURNPSIT TO PAY TENN ALSO SEE COAL IRON THE INSTANT CO VS BUTLER 55 THOUGH THE SO ALA 804 1914 IN TIFFS AS ACT WAS WELL IN LABOR THIS AS LEGAL THE CASE MEMBERS OF DEPRIVING PROFIT AGREEMENT AND THE ACT BASIS DEFENDANTS ACTIONABLE OF THE ITT SUCH THEIR UTILIZING OF SAID DRUG COMPANES KNOWN TO BE ILLEGAL RULING JUDGE GRANTED ON TWO GROUNDS 41 SUMMARY THE PLAIN TORTIONS COMMITTED BY PLAINTIFFS DISTRIELCOURTS DISTRICT ON COUNT MAKING PURPOSES OF DEPARTMENT OF CORRECTIONS OF SUCH UTILIZATION IS THE AS DETENTION OF PROPERTY BY ILLEGALLY PLAINTIFFS FORTHE PRIVATE THE THE MICHIGAN DEPARTMENT OF CORRECTIONS THE BY DEFENDANT EVEN JUDGMENT FIRST WAS TO THAT IN HIS RELEVANT THE OPINION DUSTRIES DO NOT PLAINTIFF MUST PERSONS CRIMINAL CIVIL BASE ACTION IS NOT NESS INTERESTS WAS INTENDED THE THREE CLASS THE THREE BE CRITERIA TO INADEQUATE TO BE PROTECTED OF HE CAN WYANDOTTE CITING CO WHICH CRILERIA IN IMPLIED THE ARE INSURE THE STATUTE FOLLOWING FULL EFFECTIVE THE CLASS THAT STATUTE TYPE THE THAT STATUTE FORESTALL TO IT THE BY WITHIN FALL OCCURRED WAS OF THE HAD APPELLANTS THOUGH ACTION OF FORLH THE PLAINTIFFS OF HARM THAT WAS INTENDED EVEN IS THAT STATUTE OF THE THE LIABILITY AND 2L3A SETS THOSE IN PRISON TO PROTECT BEFORE DAMAGE ROMEDY WILL CIVIL EXPRESSED CRIMINAL 1967 191 WYANDOLTE CASE MUST BE MCT BEFORE WHERE IT US 389 WITHIN VIOLATION ON ITS FOR DAMAGES GOVERNING DAMAGES WAS INTENDED STATUTE THE C1AI TO DEMONSTRATE HE FALLS FIRST STATES UNITED RISE GIVE STATUTES MICHIGAN SEEMS DO NOT THAT ALL SUCH STATUTORY ON ANY RELY THOSE CAUSE ARE PRESENT REQUIREMENTS THIS IN CASE FIRST CRIMINAL TIAL QUATE TO ALL ITS IT UNDER LIABILITY INSURE ARRANGEMENT OF FBLL THE PATONTLY PRISON HERE IS CLEAR THAT INAUSTRIES SS EFFECTIVENO QUESTIONED BEING IS THE PLAIN VERY THE ACT XS EXISTENCE PROOF OF POTEN MADE OF THE THAT IM7XIICU9TTNG AND TO NOTE THAT THRAUCGHOUK ALL OF THE PLEADINGS IN THIS CASE NEVER ONCE HAVE DEFENDANTS COUNSEL IS LAWFUL UNDER THE APPLICABLE THE ARRANGEMENT AROUMENTS ASSERTED THAT THE MICHIGAN STATUTES THAT AN ATTEMPT IT IS ALSO INTERESTING BY PRISONER CONDUCT COMPLAINED OF THROUGH MANDEMUS WAS INEFFECTIVE COURTS BY THE MICHIGAN MINK ULDER 1967 VS OF PARKC DAVISCCMJ NOV 21 CORT 1966 DENIED 392 TOAVE US MICH COURT OF TO APPEAL 934 1968 42 TO HALT THE AND DENIED APPES NO 2684 DENIED 379 RICH 773 FURTHER OF HARM THAT TYPE FINALLY SEEMS IT THAT STATED THEY THE THE LEAST SOME PURPOSES THEIR DOES BY THE IT IF EVEN SUCH UTILIZATION THE PRISON PART LABOR OF OFFICIALS ON 1LIANTL FOR DO RIOT LABOR IN SECOND AGREE OF THE WITH UNDER THUS ILLEGAL THE OF VIOLA WHERE VIOLATION MAY CS STATUTE IS DOES EVIDENTIARY DID NOT DEPRIVE THEM THE COURT BASED LAWFULLY LABOR CONCLUSION INCARCERATED RELIED GUNN RIG THE REASONS ALREADY THIS BROAD STATEMENT WAS ILLEGAL OF ANY PROPERTY TO WHICH THIS AND HE THE COURTS DECISION DISTRICT OF PLAINTIFFS BELONGS SUING COMMON LAW CAUSE UTILIZATION INMATES ON BY DEFENDANT DRUG ACT THE VS WITHIN ACTION OF STATE QUESTION TO PROTECT ARE ACTION ITS GROUND OF THE INMATES FALL OF AUTOMOBILES OPERATION HUT IN RELY SITUATION THE LO ACTION NOL CONDUCT IS NEGLIQENCE CAUSE OF THE EY SIMILAR OF CAUSE THEY WERE ENLITLED THAT IS DO PLAINTIFFS OF ALREADY INTERESTS WAS INTENDED OF THE THEIR AND REASONS BUT RATHER STATUTE GOVERNING THE OF THAT THE WAS THAT THE THAT BREACH OF DUTY ON AN CLEMENT STATUTE HE EXACTLY LEGISLATION MAY APPELLANTS ONE ELEMENT EXIST ESTABLISH THE HOWEVER VIOLATION STATUTE NF TABLISH NOT STATED THAT ESTABLISHING DON AS IT DOES ESTABLISH COMPANIES ACTION THAT THAT LAW COMMON THE OF THE OF INTERESTS OF ACTION FOR MAJOR CONCERN THE CAUE INMATES IS TO FORESTALL ARE FOR AT BE OCCURRED WAS INTENDED STATUTE TO PLAINTIFF AND THAT CLASS HAS HARM THAT THE ON THE BELONGS FOR TO THE BELIEF THIS BELIEF IN COMPANY SUPRA STATET OF STATE 43 THE OF APPELLANTS LAW SIMPLY MICHIGAN RATHER ONLY THE INSOFAR AS THAT RIGHT LABOR OF THE HAS INMATES PRISON INDUSTRIES FRUITS OF THEIR HAS AUTHORITY BEEN NOT RICES ACT BUT LABOR IT FROM THE UNLESS STATED THAT FROM SECTION COME IT RIGHT IS OF RIGHT OF EVERY TAKEN LEGALLY STATE BY THE REQUISITIONED LEGALLY LHE MICHIGAN PERSON AWAY THIS TO THE ONE AS FOLLOWS BEEN HELD THAT THE RIGHT OF REPEATEDLY LABORER TO ENTER INTO CONTRACTS FOR HIS SERVICES IS PROPERTY WITHIN THE MEANING OF THAT THE CONSTI THE CONSTITUTIONAL GUARANTIES TO ACQUIRE TUTIONA OF EVERY MAN LAWFULLY RIGHT HAS THE EONLRACLS INCLUDES THE RIGHT OF MAKING SERVICES OF FOR PERSONAL AS MEANS ACQUIRING AND THAT EACH PERSON IS ENTITLED TO PROPETTY MAKE SUCH CONTRACTS IN REFERENCE TO SUCH LAW FUL BUSINESS OR OCCUPATION AS HO MAY CHOOSE FREE FROM HINDRANCE OR OBSTRUCTION BY HIS FELLOW MEN EXCEPT FOR THE PROTECTION OF EQUAL THE CONSU OR SUPERIOR RIGHTS ON THEIR PART TUTIONAL ALSO EMBRACES THE TO LIBERTY RIGHT THE RIGHT TO CONTRACT REGARDINR EMPLOYMENT HANDS WORKMAN TO USE HIS OF FREELY RIGHT ARID TO USE THEM FOR WHOM HE PLEASES UPON SUCH TERMS AS HE MAY CHOOSE IS AN ABSOLUTE RIGHT OF WHICH HE CANNOT BE DEPRIVED EVERY MAN MAY ENGAGE TIC WORK FOR OR TO DEAL WITH OR TO REFUSE TO WORK FOR OR TO DEAL WITH NNY MAN OR CLASS OF MEN AS HE SEES FIT WHATEVER HIS MOLIVE OR WITHOUT BEING HELD IN THE RESULTING INJURY ACCOUNTABLE THEROFOR LABORER THEN ANY WAY HAS UNDER THE TO FULL FREEDOM LAW RIGHT IN DISPOSING OF HIS OWN LABOR ACCORDING TO HIS AND AT TERMS AGREEABLE TO HIM EXCEPT OWN WILL SO FAR AS THIS RIGHT BY VALID NAY BE RESTRICTED ENACTED IN LHE EXETEISE OF THE STATUTES POLICE STATE TO DIS MOREOVER THE RIGHT POWER OR RECEIVED UNDER CONLRACTS POSE OF THE OF LABOR IS UNDER ORDINARY CIRCUMSTANCES THE CONSTITUTIONA3 QUAR PROPERTY RIGHT WITHIN LABOR AND LABOR AFLTIES 48 AM JUR 2D PROF ARTY COMPEN RELATIONS INSOFAR AS THE BELIEVE IT IS SEC HUNTLEY CASE IN ERROR AND PAGE DEVIATES IT SHOULD 55 1970 FROM THIS BE NOTED PRINCIPLE THAT THE APPELLANTS THEORY OF VI CCA KCQJ COUNT III RAISED OF THE OR ARGUED IT AMENDED THE IS ADMITTED THE BY KNOWINGLY ACCEPTED THE STARITIAL FASHION ALSO BENEFITED WITH AN ORIGINAL AND WITH USAGE OF THE PLICITNOSS HAVING KNOWIAGLY PLAINTIFFS OF THE OF PRISON LABOR THE AS IN FOR SUMMARY JUDGMENT FACTS FOR SUMMARY AS NOTED JUE4IMNT AS SAID PLAIN UTILIZA FOR THAT OF HUNDRED FIFTY LAW WITH COMPANIES OF SUB IN THEIR TWO BUILDINGS THOUSAND DOLLARS STATE CONTRACLS EX BECAUSE OF THE ALREADY ACCRUING THERE TO SUCH REGARD DEFENDANTS DETAILED ABOVE BENEFITS THEREFROM IN ARE OF THE CASE TO RESPONSIBLE PAY THEREOF TO COUNT TO AND ACQUISITION THIS COURT ABOVE OF REPLACEMENT COST TODAY AS THOSE VALUE DISTRICT LABOR WHICH ACCRUCD ACCEPTED THE DIRECT ILLEGALLY WELL THE THAT LABOR STATUTORY REFERENCES AND EVEN DEPARTMENT OF CORRECTIONS FIVE OF THE LABOR REASONABLE THE DISPUTED THE BY DEPARTMENT OF CORRECTIONS PLAINTIFFS FARTHER OF THAT MUCH BIGGER CAN BE NO MISUNDERSTANDING FOR THE AND OF ROUGHLY UNDOUBTEDLY CASE ECONOMIC INTERESTS SIGNIFICANTLY COST WAS NOT DEPARTMENT OF CORRECTIONS BENEFITS TO THEIR THIS IN MOREOVER THE MICHIGAN SHAREHOLDERS BEEN THAT BY DEFENDANT DRUG COMPANIES TION HEREIN EUNTLEY CASE IN WAS FURNISHED TIFFS ISSUED COMPLAINT ERRED III IN AND PELLANTS LIABILITY ONLY GRANTED 45 GRANTING DEFENDANTS FURTHER BELIEVE UNDER UNDER THAT THE THEIR COUNT III MOTION UN NICLION SHOULD HAVE IIL DID DTSTRTCT THE AS TO COUNT IV CO1V TO NO DENIAL SEEK UNDER THE COUNT BECAUSE THE APPELLANTS THE APPELLEES COUNT TV OF AND OF PJAINTIIFS NO NO THEIR RECOVERY FOR VIOLATION THIRTEENTH PROTECTED RIGLITS YES SAY SAY SUFFERED ANSWERED COURT OF AMENDED THEIR COMPLAINT IN PLAINTIFFS COMPLAINT PLAINTIFF CONSTITUTIONAL FOURTEENTH AMENDMENFRS AMENDCI TILE CON LABOR THEY OF FEDERALLY DISTRICT AMENDED ASSUMTNG EVEN LAW MICHIGAN THE UNDER INTNATES OF PLAINTIFFS USE OF PLAINTIFFS ILLEGAL GRANTING MOTTON FOR SUMMARY JUDGMENT DEFENDANTS TRM ERR IN COURT RIGHTS PARAGRAPH 10 OF ALLEGED ALL OF THE ACTS AND ACTIONS COMPLAINED PLAINTIFFS WERE ACCOMPLISHED BY THE AND AGREEMENT COOPERA LION OF ALL THE DEFEN NAMED DANTS BOTH CORPORATE AND INDIVIDUAL UTILIZATION OF PLAIN HEREIN AND THE ILLEGAL TIFFS LABOR INURED TO THE BENEFIT OF ALL DEFENDANTS CONSTITUTED FURTHER SAID ACTIONS IN FACT OR IN LAW AN ATTEMPT TO EVADE AVOID AND VIOLATE THE LAWS OF THE STATE OF MICHIGAN THE REGARDING USE OF PRISON LABOR FOR PRIVATE AND THE LAWS OF MICHIGAN AND THE UNITED PROFIT STATES THE MINIMUM WAGE TO BE PAID REGIALATING FOR LABOR OF BY IN ON COUNT IV THE GRANTING DISTRICT DEFENDANTS JUDGE HELD MOTION FOR SUMMARY THAT 46 ASSUMING JUDGMENT DEFENDANTS USED PLAINTIFFS LABQR LAW IN OF STALE ON THE OF DIR 8TH FROM THE FRUITS SERVITUDE IN BASIC OF HIS 1963 THAT ASSUMPTION OWN LABOR EXTENT THE THAT RIGHT IS IT STATE BY APPLICABLE LAW CONTAINED ZATION IN SIQIER VS TOWRIE CONCLUSION TO HIM UNDER DO NOT 659 BEGIN TO THE CONSITUTION IS HIM THE CUE AND GIVEN TO THE F2D 404 FOURTEENTH AMENDMENT EXCEPL AWAY FROM CARVED AND THE VS RHAY OF DRAPER AN INDIVIDUAL ALQNE THE PRIMARILY APPELLANTS OF RIGHT OF CONNECTION WITH AND BELONGS APPELLANTS RELIED COURE COLOUR NO DENIAL CASES THE IS SUFFERED AMENDMENT IN LAWFULLY TAKEN IT UNDER ON THE BELONGS PART OF AFTER THE ACTED AND THIS REACHING PROTECTED PROPERTY RIGHT ALLY TO 1968 THIRLEENTH DR 9TH 193 HAVE 221A RIGHTS INVOLUNTARY F2D PLAINTIFFS DOING THE OF LANGUAGE CLAIM 315 SO PROTECTED FEDERALLY LAW AND CONTRARY TO NICHIQAN RESIDUE TO THE OF STATE PRISONER WITH DISAGREE THE BROAD GENERALI VS HAY SUPRA THAT DRAPER THERE IS NO FEDERALLY PROTECTED RIGHT NOT TO WORK WHILE PRISONER EVEN THOUGH IMPRISONED AFTER CONVICTION THAT CONVICTION IS BEING APPEALED OF NOR DO THEY ARGUE RATHER THE THAN STATE THAT COUNTY JAIL PRISONERS CONSTITUTIONAL LAST CASE JUDGE CITED IREEMAN WHEREIN AT IMPRISONED BEING NECESSARILY RIGHTS NOR DO THEY PAGE 39 TAKE OF HIS IN THE STATE INVOLVES VIOLATION WHICH ALSO WAS THE ISSUE WITH THE MEMORANDUM OPINION PENITENTIARY HOLDINTI STATEMENT IN THIS HE STATES YET MEREJY BECAUSE PENAL OFFICIALS HAVE TREALED SLALE PRISONERS AL VARIAFICO WITH TBE APPLICABLE STATE LAW DOES NOT IN ITSELF CONSTITUTE VIOLATION OF THE DUE PROCESS OR EQUAL PROTECTION RIGHTS OF THOSE PRISONERS 219A 47 OF OF OF CASE THE THE TROUBLE WITH CASE THIS TO COVER PLAINTIFF CASE LAW AND THAT THAT STATEMENT IS THAT WHAT APPELLANTS ARE RESULT AS CONSTITUTIONALLY OF LABOR AS THEY LAWFULLY TAKEN AWAY FROM WHERE TREATING TREATMENT INVOLVED AND JUDGE THEM PROCESS DEPENDING RIGHTS VIOLATED HOWEVER SUPRA VS TIARY THE DID STATE NOB AOL PRISON OUT THAT THAT THE IMPROPERLY OF NEBRASKA AND RETURN TO TO POINT FOUND THE VESTED CHARACTERISTICS AT PAGE FOR HOWEVER MONIES TO THE THE ARE MANY OTHER STATE LAW WOULD ON THE PARTICULAR 40 COURT OF APPEALS EXPENSES RESULTING THAT USED BY THE PRISONER FOR CASE THE PAY TO CLAIM ACT ESCAPE COURT WAS CAREFUL WARDEN HAD NEVER STATING FOR REIMBURSE FROM HIS HOWEVER PROSPECTIVE CANCELLATION OF CONDITIONAL IN GRANT ALTHOUGH SEEMINGLY CONSISTENT WITH THE INTENT OF THE STATUTE NEVERTHELESS NOT OF FED DEPRIVATION ERAL CONSTITUTIONAL THE RIGHT STATUTORY FOR CANCELLATION MAKES EXPLICIT PROVISION THAT THE SPENDING ACCOUNT NEVER TAKES ON VESTED CHARACTERISTICS AND ASSUMING THE FUTURE CREDIT PRISONERS CANCELLATION OF VIOLATION OF LHE STALULE IS THIS DOES NOT PROPERLY STATE THE CIVIL RIGHTS THE PENITEN NEBRASKA STATE PRISONERS TAKING IN BEEN HAS 220A WARDEN OF CERTAIN IT FOR AT ITS REASON OF SUCH FUNDA RIGHT SIGLER LOWRIE IN THAT TO DISPOSE PAY PLAINTIFFS TO 661 AT DEPRIVED CLINICS DENIAL CONSTITUTIONAL IN CIRCUIT WITH BEEN RIGHT EXTENT OF DUO FAILURE EIGHTH THE THERE AT VARIANCE THEIR LABOR IN THE ABLE VALUE IS NOT LOWRIE THE OBVIOUSLY FREEMAN STATED MENTAL NAMELY TO PLEASE PRISONERS VIOLATION CONSTITUTE R4 THIS WITH STATE HAVE THEY IN THAT AT VARIANCE TREATMENT PROTECTED OF THEIR CASES OF THAT IS SAYING BEEN TREATED HAVE INMATES DOESNT GO FAR ENOUGH IT RELIEF UNDER TAKEN ON IT IS TRUE THAT THE ATTORNEY GENERAL THAT THE WARDEN DID NOT CANCEL THE CREDIT BUT ACTUALLY FINED THE PRISONER HOWEVER WO FEEL IN VIEW OF THE FACT THAT THE PRISONERS VESTED INTERESTS ARE NOT IN VALVED THE EFFECT OF THE WARDENS ACTION IS TO FINE THE PRISONER BY MERELY CANCELLING HIS CONDITIONAL CREDIT AS TO THE PLANE EXPENSE NO MONEY EXCHANGES HANDS IT IS BOOKKEEPING CREDIT ONLY WHICH IS CANCELLED IN THIS INSTANCE IT IS NAIT THE CHOICE OF WORDS BUT THE MEASURED ACTION INDUCED WHICH BECOMES RELEVANT WHEN SUCH ACTION FAILS TO ENCROACH UPON FEDERAL RIGHTS AN ESSENTIAL IS INGREDIENT OF OUR JURISDICTION MISSING STIPULATED THE COURT CLEARLY THE PRISONER TO SEEMED AN ABSOLUTE TIFF OWN INMATES LABOR IN AND VS 519 2D HAS NOT JUDGMENT PLAINT HAS 390 WASHINGTON CIR 1967 OF WHETHER THE PRISONER FURTHER IT ILLEGALLY DONE FOR SO HAS IN DISTRICT EXTENT THEIR 333 378 US STATE COURT DEFENDANTS AS TO COUNT IV BY THE OF IN THEIR FEDERAL THEM DEPRIVES RIGHTS F2D NCMANN 389 1964 546 OF THE OF MICHIGAN ERRED OF CONSTITUTIONAL ALL PLAIN THAT FRUITS STATE WRIGHT POWER TO TAKE THE CLAIM GIVEN THE THE TO CONSTITUTIONAL TO THE FEDERAL 19687 LAW HAD GIVEN VESTED RIGHT APPELLANTS LAW BUT THE VS PATE THE OWN LABOR THE TO STATE HIS VESTCD RIGHT ACLATED US IS BY STATE THAT COO STATE TO HIS GIVEN THE RIGHT IT HAVE CASE NOT RIGHT CONSTITUTION OF IT THIS IF MONEY OR CONDITIONAL BEEN VIOLATED WOULD HAVE THAT THE TO RIGHT MONEY AS OPPOSED TO ONLY RIGHTS INDICATE GRANTIN PLAINTIFFS REGARDLESS RIGHTS THE OF LEGISLATURE SURUFFLALY AMENDED COM CONCLUSION APPELLANTS THE ORDER TAINED DISTRIOL ON ALL COURT ACTION BLISS AS FENDANTS THE OF AND GRANTING ASK TO SUMMARY JUDGMENT AS TO LIABILITY OR IN COUNTS THIS THE CASE TO THE ALTERNATIVE OF THE COURT TO RIND APPELLANTS REMAND THIS OF PLAINTIFFS COUNTS THIS THAT DISTRICT TO REMAND SUMMARY BE MAIN JUDGMENT TO DE COMPLAINT PLAINTIFFS ONLY COURT CANNOT ACLION AMENDED THAT THE COURT TO REVERSE ASK THIS THEREFORE UNDER FOR CASE ARC COUNT TRIAL FOR FURTHER ENTITLED AND III TO ON DAMAGES ONLY ON ALL FOUR TRIAL AMENDED COMP1AINT RESPECTFULLY SUBMITTED DEAN DEAN BY ROBERT 1616 FLINT SEGAR HART S4I4 GENESEE TOWERS BLDG 48502 MICHIGAN ATTORNEY FOR APPELLANTS 50 PC ADDENDUM CONTAINING PROVISTONS THE STATES CODE WHICH PROVISIONS ARE AND RULES TITLES OF IN INVOLVED STATUTORY RELEVANT 18 AND 29 ROXVANT PART THE OF ARE UNITED FO11OWS AS IN INTERSTATE WHOEVER KNOWINGLY TRANSPORTS COMMERCE OR FROII ANY ROREIGN COUNTRY INTO THE UNITED STAKES ANY GOODS WARES OR MANUFACTURED PRODUCED OR MINED WHOLLY OR IN CONVICTS OR PRISONERS EXCEPT CONVICTS PART BY OR IN ANY OR PRISONERS ON PAROLE OR PROBATION SHALL BE PENAL OR REFORMATORY INSTITUTION FINED NOT MORE THAN 1000 OR IMPRISONED NOT MORCH MORE THAN ONE THIS CHAPTER YEAR OR SHALL BOTH NOT APPLY TO AGRI CULTURAL COMMODITIES OR PARTS FOR THE REPAIR OF FARM MACHINERY NOR TO COMMODITIES MAIM FACTURED IN DISTRICT OF COLUMBIA FEDERAL FOR USE BY THE FEDERAL OR STATE INSTITUTION OF COLUMBIA GOVERNMENT OR BY THE JITRICT OR BY STATE ANY STATE 18 OR POLITICAL USC SUBDIVISION OF SEE 1761 INCLUDES ANY PERSON ACTING OF AN IN THE INTERESL OR INDIREELLY DIRECT3Y TO AN EMPLOYEE BUT SHALL EMPLOYER IN RELATION NOT INCLUDE THE UNITED STATES OR ANY STATE OR SUBDIVISION OF STATE POLITICAL EXCEPL WILZH OF TO EMPLOYEES POLITICAL RESPECT STATE OR SUBDIVISION HOSPITAL THEREOF EMPLOYED CL IN OR SCHOOL REFERRED TO IN THE LAST INSTITUTION SENTENCE OF SUBSECTION OF THIS SECLION OR IN THE OPERATION OF OR CARRIER RAILWAY REFERRED TO IN SUCH SENTENCE OR ANY LABOR OTHER THAN WHEN ACTING AS AN OTGANIZATION OR ANYONE ACTING IN THE CAPACITY EMPLOYER OF OFFICER OR AGENT OF 5UCH LABOR ORGANIZATION EMPLOYER EMPLOYEE INCLUDES ANY INDIVIDUAL LHAL SUCH LERM BY AN EMPLOYNR EXCEPL FOR THE PURPOSES OF SUBSECTIEN CU OF INCLUDE 51 EMPLOYED SHALL XIOT THIS SECTION INDIVIDUAL EMPLOYED BY AN EMPLOYER IF SUCH INDIVIDUAL IN ENGAGED AGRICULKURE IS THE PARENT SPOUSE CHILD OR OTHER MEMBER OF THE EMPLOYERS INWIEDIATE FAMILY OR WHO IS EMPLOYED BY AN ANY INDIVIDUAL INDIVIDUAL IS EMPLOYED AS HAND HARVEST LABORER AND IS PAID ON RATE BASIS PIECE IN AN OPERATION WHICH HAS BEEN AND IS CUS RECOGNIZED AS HAVING TOMARILY AND GENERALLY BASIS IN THE RATE BEEN PAID ON PIECE OF COMMUTES FROM 13 DAILY REGION EMPLOYMENT HIS PERMANENT RESIDENCE TO THE FARM ON WHICH HE IS EMPLOYED AND HAS BEEN EMPLOYED IN WEEKS DURING AGRICULTURE LESS THAN THIRTEEN THE PRECEDING CALENDAR YEAR ANY EMPLOY INCLUDES TO SUFFER OR PCRMT 29 USC SEC 203 CD CE WORK OF TITLE PROVISIONS STATULES ANNOTATED WHICH ARE AND 17 IN INVOLVED TITLE 28 RELEVANT OF THE PART TO MICHIGAN ARE AS FOLLOWS DEFINITIONS AS USED EMPLOYEE MEANS AGES OF 18 AND ON THE PREMISES SITE DESIGNALED IN AN YEARS THIS ACT INDIVIDUAL BETWEEN THE EMPLOYED BY AN EMPLOYER FIZED EMPLOYER OR AT OF THE BY THE EMPLOYER EMPLOYER MEANS ANY PERSON FIRM OR CORPOR SUB THE STATE AND ITS POLITICAL ATION INCIUDING AND INSTRUMENTALITIES AND DIVISIONS AGENCIES ANY IN THE INTEREST OF SUCH EMPLOYER WHO PERSON ACTING CR MORE EMPLOYEES AT ANY ONE TIME WITHIN EMPLOYS SUCH EMPLOYER SHALL BE SUBJECT ANY CALENDAR YEAR TO THIS ACT DURING THE REMAANDOR OF SUCH CALENDAR YEAR LMPLOY TO WORK MEANS 17255 TO ENGAGE SUFFER MSA OR PEINTIT NIECE RATE SCALES THE PROVISIONS OF THIS ACT SHALL NOL APPLY TO ANY EMPLOYER WHO IS SUBJECT TO THE MINIMUM WAGE PROVISIONS OF THE FAIR AS FEDERAL LABOR STANDARDS ACT OF 1938 AMENDED EXCEPT IN ANY CASE WHERE APPLICATION OF SUCH MINIMUM WAGE PROVISIONS WOULD RESULT IN LOWER MINIMUM WAGE THAN PROVIDED IN THIS ACT OR NOT TO PERSONS EMPLOYED IN SUMMER CAMPS OR MORE THAN MONTHS OR TO AGNCUTTURAI FRUIT GROWERS EXEMPTIONS 52 GROWERS AND TOMATO GROWERS OR OTHER AGRICULTURAL EMPLOYERS WHO TRADITIONALLY CONTRACT FOR HUE HARVESTING ON PIECEWORK AS TO THOSE EMPLOYEES OF SUCH EMPLOYERS BASIS THE BOARD SHALL USED FOR SUCH HARVC5TING UNTIL SUFFICIENT DATA TO DETERMINE AN ADE HAVE ACQUIRED ESTABLISHMENT OF SCALE OF PIECE FOR THE QUATE BASIS SHALL DETERMINE SUCH SCALE WORK AND EQUIVALENT MINIMUM WAGE FOR SUCH EMPLOY TO THE PREVAILING SHALL OCCUR NO THUER WHICH DETERMINATION INENT PICKLE THAN MAY SUCH PIECE RATE SCALE SHALL J957 BE EQUIVALENT TO THE MINI MUM HOURLY WAGE OF PRODUCTION IN THAT WHEN THE PAYNLERIL BY UNIT AND TO WORKER OF AVERAGE ABILITY IS APPLIED IN HARVESTING PARTICULAR COMMODITY DILIGENCE HE SHALL RECEIVE AN AMOUNT NOT LESS LHAN THE HOURLY MINIMUM WAGO 172 55 14 MSA SAME UNLAWFUL SALES OF PRISON PRODUC LS OR LABOR FROM AND AFTER 60 DAYS AFTER EXCEPTIONS PRICES SHALL BE UNLAWFUL TO THIS ACT SHALL BECOME LAW IT SELL OR EXCHANGE OR TO OFFER FOR SALE OR EXCHANGE OR TO PURCHASE ANY PRISON PRODUCTS EXCEPT PURE BRED LIVESTOCK RAISED ON THE SEVERAL PRISON FARMS AND SOLD FOR BREEDING PURPOSES OTHERWISE THAN FOR CHARITABLE ANDOR USE OR CONSUMPTION IN THE PENAL STATE OR FOR OF THIS OTHER CUSTODIAL INSTITUTIONS SUBDIVISIONS DEPARTMENTS OF THIS STATE OR POLITICAL OR THE FEDERAL THEREOF GOVERNMENT OR AGENCIES PROVIDED THEREOF OR OTHERWISE AS SPECIFICALLY ACT BE LABOR OF PRISONERS CONTRACTED FOR OR SOLD HIRED LEASED LOANED ETHERWISE USED FOR PRIVATE OR CORPORATE PRORITOR FOR ANY OTHER PURPOSE THAN THE CONSTRUCTION MAINTENANCE OR OPERATION OF PUBLIC WORKS WAYS OR PROPERTY AS DIRECTED BY THE GOVERNOR EXCEPT THAT THE PRISONERS OF COUNTY OR OF CITY MAY BE USED ON THE PUBLIC WORKS WAYS OR PROPERTY OF SAID COUNTY OR CITY AS THEREOF DIRECTED BY THE CONS LITUTED AUTHORITY THAT IN THIS ACT SHALT BE DEEMED PROVIDED NOTHING OF ARTICLC MADE TO PROHIBIT THE SALE RETAIL THEMSELVES BENEFIT OF FOR THE BY PRISONERS PERSONAL OR THEIR DEPENDENTS OR THE PAYMENT TO PRISONERS FOR RENDERED IN THE PENAL INSTITUTION PERSONAL SERVICES TO REGULALIONS APPROVED BY THE PRISON SUBJECT SALE OF PURCHIA OR THE MANUFACTURE COMMISSION OF BINDER TWINE ROPE AND CORDAGE USED IN AGRICULTURAL IN THIS NOR SHALL THE 53 THAT IN NO CASE SHALL PRODUCTION PROVIDED PRISON PRODUCTS BE SOLD OR OFFERED FOR SALE AT BELOW COST OF PRODUCTION WHICH PRICE COST OF PRODUCTION SHALL INCLUDE MATERIALS DISLRIBUTION AND SELLING LABOR SUPERVISION HEATS LIGHT ROWER AND CONNECTED THEREWITH INTENT THE OF INTENT ACT OF IT THIS REGULAR DIVERSIFIED IS ALL CEHER 281525 ANY EXPENSES NSA DECLARED TO BE TO PROVIDE ADEGUALE AND SUITABLE EMPLOYMENT STATE CONSISTENT WITH HEREBY EEL FOR PRISONERS OF THE PROPER PENAL PURPOSES TO UTIJIZO THE LABOR OF PISORIER CX FOR SELFMAINTENANCE AND FOR REIM OJUSIVELY BURSING THE STATE FOR EXPENSES INCURRED BY REASON OF THEIR CRIMES ANCT IMPRISONMENT ALL COMPETITIVE CC TO ELIMINATE RELATIONSHIPS BETWEEN PRISONER LABOR OR PRISON PRODUCTS AND FREE LABOR OR PRIVATE INDUSTRY AND DISBURSE CD TO EFFECT THE REQUISITIONING MENT OF PRISONER LABOR AND PRISON PRODUCTS DIRECTLY STATE AUTHORITIES WITH NO THROUGH ESTABLISH6D OF THEREFROM AND POSSIBILITY PRIVATE PROFITS WITH THE MINIMUM OF INTERMEDIATING FINANCIAL CONSIDERATIONS OR EXPENDITURES APPRTPRIATIONS AND THE TO THESE ENDS THE STATE PURCHASING GOVERNOR SHAJI REQUIRE SUITABLE AGENT OR HIS SUCCESSOR TO ESTABLISH METHODS OF PURCHASING AND OF ACCOUNTING WHICH SHALL PRCVIDE AS MAY BE NECCTSSARY OR ADVISABLE FOR THE PURCHASING ARID SUPPLY ON ACCOUNT OF THE CONSUMING INDTITUTIONS ANDOR DEPARTMENTS OF SUPPLIES AND SEPARATELY OR COLLECTIVELY MATERIALS NECESSCR FOR THE PRISON MANUFACTURE OR PRODUCTION OF THE PRISON PRODUCTS ROQUISI TIONED THOREFOR IN ACCORDANCE WITH SECTIONS FOUR FIVE AND SIX OF THIS ACT FOR CREDITING ACCOUNTS AND DEBITING PRISON ACCOUNTS OF DONSURNING INSTITUTIONS OR DEPARTMENTS FOR PRECINCTS REQUISITIONED AND DISBURSED AT FIZED TO INDICATE THE TRUE COSTS PRICES FAIRLY OF MALNTENAFLEE AND EFFICIENCY OF MANAGEMENT OF SAID AND DEPARTMHRTT PRISONS INSTITUTIONS PROVIDED THAT SAID PRCSNS OF THE REQUISITIONING OR DISBURSEMENT OF SAID PRISON PRODUCTS SHALL IN NO CASE BE DETERMINED BY OR CONTINGENT UPON FROM OTHER SOURCES COMPETITIVE BIDDING 54 FOR THE OR PURCHASE OF ALL COMMODITIES OTHER THAN REQUIREMENTS PRISON PRODUCTS AS PROVIDED FOR IN THIS ACT BY COMPETITIVE BIDDING OR OTHER METHODS ESTABLISHED BY LAW OR APPROVED PRACLICE THAT PROVIDED NO BIDS MAY BE ASKED OR RECEIVED EXCEPT FOR WHICH IT HAS BOON DO COMMODITY REGUIRCIUCRITS DECIDED SHALL NOT BE SUPPLIED FINITELY BY RE OF PRISON GUISITIONING PRODUCTS AS HEREINBEFORE 281530 PROVIDED MSA PRISONER ON PAROLE LEGAL CUSTODY WARRANT FOR RELURN PAROLE VIOLATORS AS ESCAPED PRISONERS FORFEITURE OF GOOD TIME CONVICTION AND SENTENCE FOR CRIME CCFLNMI TTECL ON PAROLE TREATMENT AS TO LASTINCORRED SEC 38 TERM PAROLE AS PERMIT PAROLESHALL REMAIN IN THE AND UNDER THE CONTROL OF THE COMMISSION THE ASSISTANT DIRECTOR OF THE BUREAU OF PARDONS AND PAROLES IS HEREBY AU AT ANY TIME IN HIS DISCRETION AND THORIZED OF PAROLE UPON SHOWING OF PROBABLE VIOLATION TO ISSUE WARRANT FOR THE RETURN OF ANY PAROLED IN THE STATE PRISONER TO ANY PENAL INSTITUTION UNDER THE CONTROL OF THE C4OITMJSSION PENDING HEARINGUPON ANY CHARGE OF PAROLE VIOLATION THE PRISONER SHALL REMAIN INCARCERATED JN SUCH PENAL INSTITUTION EVERY PRVSONOR ON LEGAL CUSTODY THE PROVISIONS OF HIS FOR WHOSE RETURN WARRANL HAS BEEN ISSUED BY THE ASSISTANT DIRECTOR OF THE BUREAU OF PARDONS AND PAROLES SHALL AFTER THE ISSUANCE OF SUCH WARRANT BE TREAFED AS AN ESCAPED PRISONER TO THE STATE AND SHALL BE LIABLE OWING SERVICE WHEN ARRESTED TO SERVE OUT THE UNEXPIRED PORTION OF HIS AND THE TIME FROM IMPRISONMENT THE DATE TO THE THE DECLARED VIOLATION DATE OF HISAVAILABILITY FOR RETURN TO ANY UNDER THE CONTROL OF THE PENAL INSTITUTION SHALL NOL BE COUNLED AS ANY PART COMMISSION OR PORTION OF THE TIME TO BE THE WARRANT OF THE ASSISTANT DIRECTOR OF THE BUREAU OF PARDONS AND PAROLES SHALL BE SUFFI CIENT WARRANT AUTHORIZING ALL OFFICERS NAMED THEREIN TODETAIN THE PAROLED PRISONER IN OF THE STATE UNTIL HIS RETURN TO ANY ANY JAIL UNDER THE CONTROL OF THE PENAL INSTITUTION COMMSSJON CAN BE EFFECTED PRISONER PAROLE VIOLATING AND MA OF SER 55 TO RETURN TO PRISONER SHALL FAIL ANY PAROLED ENCLOSURE WHEN REQUIRED BY WE PRISON ASSISTANT DIRECTOR OF THE BUREAU OF PARDONS AND PAROLES OR IF HE MAKES ESCAPE WHILE ON PAROLE HC SHALL BE TREALED IN ALL RESPECLS AS IF HE HAD ESCAPED FROM EHC PRISON ENCLOSURE AND SHALL BE SUBJECT TO BE RETAKEN AS PRO VIDED BY THE LAWS OF THIS STATE THE IIL THE PAROLE BOARD IN ITS DISCRETION MAY TO THE CAUSE THE FORFEITURE OF ALL GOOD TIME DATE OF THE DECLAREDVIOLATION CRIME WHILE AT LARGE COMMITTING CONVICTED AND SENTENCED UPON PAROLE AND BEING THEREFBR SHALL BE TREATED AS TO THE LAST INCURRED TERM AS PROVIDED UNDER SECTION 34 ANY PRISONER PAROLE GRANTED PRISONER SHALL BE CONSTRUED AS SIMPLY PERMIT TO SUCH PRXSONER TO GO WITH OUT THE ENCLOSURE OF THE PRISON AND NOT AS AND WHILE SO AT LARGE HE SHALL BE RELEASE DEEMED TO BE STILL OUT THE SENTENCE SERVING IMPOSED UPON HIM BY THE COURT AND SHALL BE ENTITLED TO GOOD TIME THE SAME AS IF HE WORE CONFINED IN PRISON 282308 NSA THE RULES ARE AS OF CIVIL PROVISIONS OF RULES AND 23 PROCEDURE WHICH ARE INVOLVED IN OF THE RELEVANT FEDERAL PART FOLLOWST FORM OF DENIALS DEFENSES PARTY SHALL STATE IN SHORT AND PLAIN TERMS HIS DEFENSE TO EACH CLAIM ASSERTED AND SHALL ADMIT OR DENY THE AVERMENTS UPON WHICH THE ADVERSE PARLY RELIES IF HE IS WITHOUT KNOWLEDGE OR INFORMATION SUFFI CIENT TO FORM BELIEF AS TO THE TRUTH OF AN AVERMENT HE SHALL SO STATE ANA THIS HAS THE EFFECT OF DENIAL DENIALS SHALL FAIRLY MEET THE SUBSTANCE OF THE AVERMENTS WHEN DENIED IN GOOD FAITH PLEADER INTENDS TO DENY ONLY OF AN AVERMENT HE PART OR GUALIFICALION SHALL SO MUCH OF IT AS IS TRUE AND SPECIFY MATERIAL AND SHATJ T3ENY ONLY THE REMAINDER UN LESS THE RILEADER INTENDS IN GOOD FAITH TO CENTRE VERT ALL THE AVERMENTS OF THE PRECEDING PLEADING HE MAY MAKE HIS DENIALS AS SPECIFIC DENIALS OF DESIGNATED AVERMENTS OR PARAGRAPHS OR HE MAY GENERALLY DENY ALL THE AVERMENTS EXCEPT SUCH 56 HO DESIGNATED AVERRAE OR PARAGRAPHS AS INTND EXPRESSLY ADRNIS HOH WHEN HO DOES SO AVORMENTS INCLUDING TO CONTROVERT ALL ITS OF THE GROUNDS UPON WHTCH THE COURT DEPENDS HO MAY DO SO BY JURISDICTION SET TO THE OBLIGATIONS SUBJECT GENERAL DENIAL RULE 28 FORTH IN RULE 112 AVERMENTS FRC ONE OR MORE CLASS ACTTON TO PREREQUISITES CLASS MAY SUE OR BE SUED AS RE MEMBERS BF ON BEHALF OF ALL ONLY IF PRESENTATIVE PARTIES OF THE CLASS IS SO NUMEROUS THAL JOINDER THERE ARE NEMBERS IS IMPRACTICABLE THE CLASS TO QUESTIONS OF LAW OR FACT COMMON OF THE REPRESEN THE CLAIMS OR DEFENSES OF THE CLATHS OR ARE TYPICAL TATIVE PARTIES THE ROPRESEFLTA OF THE CLASS AND DEFENSES AND PROTECT WILL ADEQUATELY FAIRLY TIVE PARTIES THE CLASS 28 OF THE INTERESTS RULE 23 ALL FRC SUPP 57
