Michael Leatherwood Motion

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 1 of 14
united s t a t e s district c o u r t
FOR t h e w e s t e r n DISTRICT OF OKLAHOMA
MICHAEL D. LEATHERWOOD,
Plaintiff,
CASE NO.
V.
C1V-15-767-C
HECTOR RIOS, WARDEN, et. al.,
FILED
JUN 1 6 2016
Defendants.
CARMELii/\..ccucR SHINN, CLERK
U.S. OlST.
BY.
WESTERN j|T; 0^
MOTION FOR PRELIMINARY INJUNCTION
COMES NOW, Plaintiff, Michael D. Leatherwood, filing pro se, hereby requests a
preliminary injunction issued to prevent Defendants from continuing to violate Plaintiffs

Constitutional Rights and causing irreparable injury,
STATEMENT OF THE CASE
Plaintiff has filed a civil rights complaint brought under 42 U.S.C. 1983, 1985.
Plaintiff is an incarcerated medium security inmate subject to a state-conviction and is confined
at the Lawton Correctional Facility ("LCF"). LCF is a private for-profit prison operating under
contract with the Oklahoma Department of Corrections ("DOC"). LCF is ovifned and operated
by the GEO Group, Inc. ("GEO"). Plaintiff states in his Original Complaint that Defendants
Rios and Berg are officials at the privately owned and operated for-profit prison and that
Defendant Minyard is a Contract Monitor employed by the Oklahoma Department of
Corrections and is responsible for monitoring the contract between LCF and DOC. Plaintiff
claims these Defendants are violating his Due Process and Equal Protection rights by offering
him significantly less variety of commissary items than are offered to similarly-situated medium
security inmates housed at DOC operated facilities and by charging him as much as 131%
more for similar and Identical commissary items as similarly-situated medium security inmates
'
at DOC operated facilities pay. As a medium security inmate Plaintiff is similarly-situated as

otiier medium security inmates. The only distinction between Plaintiff and similarly-situated
medium security inmates housed at DOC operated facilities is his arbitrary assignment to
housing at LCF.
Keefe Commissary Network. L.L.C. an affiliate of The Keefe Group
During the course of this case Plaintiff has learned that GEO/LCF contracts with Keefe
Commissary Network. L.L.C. an affiliate of The Keefe Group ("Keefe") to provide commissary
services to the medium security inmates at LCF.'
Plaintiff has also learned that the menu
selection and pricing of the items offered to inmates at LCF must be mutually agreed on by
Keefe and the LCF Warden/Facility Administrator. Keefe then sells the items directly to the
inmates - LCF is not involved in the process. Mr. Rios testified at deposition that Keefe
employs the commissary staff and that no LCF official supervises the Keefe employees.
(Attach. No. 1, Deposition Transcript of Hector Rios, p. 45, 25; p 46, 1-8) Mr. Rios also
testified that no LCF staff participates in ordering or delivering commissary to LCF medium
security inmates. (Attach. No. 1, p. 47, 13-25; p. 48, 1-5) LCF receives a 12%!commission on
the gross sales of commissary to the inmates. (Attach. No. 2A, Agreement between Keefe
Commissary Network, L.L.C. and GEO Group, Inc. dba Lawton Correctional Facility; 2B, GEO
Lawton Exhibit; 2C, Service Provider Agreement between Keefe Commissary Network, LLC,
an affiliate of The Keefe Group and GEO Group, Inc.)
Plaintiff has learned that Keefe also provides commissary items that are sold to medium
security inmates at DOC operated prisons. Keefe sells items to DOC, which then re-sells the
items to the inmates via commissary sales. (Attach. No. 3, Keefe invoice for items sold to
Joseph Harp Correctional Center) Many of the items which Keefe sells to the DOC are the
' Prior to filing the instant case Plaintiff was aware that Keefe was involved with commissary services at LCF but
did not know the extent of the relationship. Relevant Information about the extent of Keefe's involvement was
revealed through discovery.
identical items which are sold directly to inmates at LCF, including Keefe private-label (housebrand) products. However, the price of items sold directly to inmates at LCF are significantly
higher than the price of identical items which are sold to inmates at DOC. For example, Keefe
sells Maruchan brand Ramen soups to DOC for $.21, which then re-sells the soup to medium
security inmates for $.26 per unit. Keefe sells the identical Maruchan soup directly to medium
security inmates at LCF for $.60 - an increase of $.34 or %131
While Ranien soups are at
the lower end of the price scale on the commissary menu, they are a staple item for inmates at
LCF. Plaintiff reasonably believes that Ramen soups (all flavors) are the most commonly
ordered commissary items at LCF.
April 18. 2016. Price Increase of commissary items at LCF:
During the course of this case, on March 29, 2016, a memorandum was distributed to
I
inmates at LCF by Keefe commissary manager, Mr. Quiroga, stating that on April 18, 2016,
Keefe was increasing the price of many commissary items at LCF. The price increases range
from $.10, to as much as $.60, per item. The memorandum states the price increase is an
"annual price increase." (Attach. No. 4, March 29, 2016, Memorandum Re: Price Increase of
Keefe Commissary Items) Defendants Hector Rios and Michael Berg approved the April 18.
2016, price increase. When asked at a deposition if he was aware of the price increase, Mr.
Rios stated, "I'm aware of that." When asked if he approved the price increase, Mr. Rios
stated, "Yes, we approved it." (Attach. No. 1, p. 70, 2-8) Defendant Berg also testified at
deposition about the April 18, 2016, price increase. (Attach. No. 5, Deposition testimony of Mr.
Berg) Mr. Berg testified as follows;
Question;
Okay. And are you familiar that the commissary prices were just
increased again recently? April 18th.
Mr. Berg;
Yes.
- Keefe sells two different flavor Maruchan soups to DOC for $.21 per unit (Chili and Cajun Chicken), The Chili
flavored Ramon is sold to inmates at DOC for $.26, the Cajun Chicken is sold for $.28. Both the Chili and Cajun
Chicken Ramon are sold directly to inmates at LCF for $.60. DOC also purchases Ramon soups from Robinson
Enterprise, Inc. and re-sells the soups for $.27.
Question:
Okay. And who authorized that? Did you authorize that?
Mr. Berg:
Yes.
Question;
Okay. Did Warden Rios authorize that?
Mr. Berg:
Yes.
(Attach. No. 5, p. 19, 6-14)
Mr, Berg further testified as follows:
Question:
So you agree that you and/or the facility head are responsible for the
pricing of commissary?
Mr. Berg:
Yes.
Question:
Okay. So if the commissary items are found to be unreasonable, then you

- it would be your responsibility. You are the one that would have
approved that or agreed to it, right?
Mr. Berg:
Yes.
(Attach. No. 5, p. 21, 20-25; p. 22, 1-2)
For example, Keefe sells Its private-label Keefe 100% Colombian Coffee 3 oz. bag, to
DOC, which then re-sells the product to medium security inmates at DOC for $3.31Prior to
April 18, 2016, Keefe sold the identical product to inmates at LCF for $4.10 - but on April 18th
the price was Increased to $4.20. Keefe also sells its private-label Keefe Creamy Peanut
Butter 18 oz. to DOC, which is re-sold to Inmates for $2,70. Prior to the April price increase
the Identical Keefe product was sold to inmates at LCF for $3.10, but was increased to $3.20.
(Attach. No. 6, Price comparison of identical products sold at DOC and LCF by Keefe) Plaintiff
has inquired with DOC about whether there was a corresponding price increase of Keefe Items
at JHCC but has not received an answer. (Attach. No. 7, Affidavit of Plaintiff)
Variety Of Commissary Items:

' Price based on the JHCC's commissary menu in effect on 1/20/2016. Plaintiffobtained the menu via an Open
Records requests from the Oklahoma Department of Corrections.
Prior to April 18th tfie commissary at LCF sold Keefe's private-label Crunchy Peanut
Butter - but subsequent to April 18th the item was removed from the commissary menu at LCF
- but the identical Keefe Crunchy Peanut Butter continues to be sold to inmates at DOC. One
of the items offered on DOC's commissary menu is Aquafina Water 16.9 PL OZ for $.38 - LCF
does not offer any bottled water on commissary. In fact, LCF does not sell any beverages in
re-sealable bottles, rather, the LCF commissary sells canned beverages - thejDOC does not
sell any beverages in cans. The alleged reasoning is that LCF considers the "re-sealable
bottles" to be a security issue - but DOC considers "cans" to be a security issue (the cans can
be used as cutting-weapons and can be swung in sheets or towels as weighted-weapons).

The DOC commissary list eight (8) items under the title of cereals - LCF list two (2). One of
the cereals offered at DOC is Frosted Flakes - LCF recently removed the Frosted Flakes from
the commissary menu allegedly under the pretext of security. DOC offers eighteen (18) items
under the title of frozen snacks - LCF offers one (1). DOC offers thirty-three (33) items under
the title of Meats/Beans - LCF offers eighteen (IS)"*. Under the title of Meats/Beans DOC
offers items such as bacon, beef franks, deli ham, smoked skinless sausage - 1 lb, Tyson
chicken breast - 22 oz, JC Potter hot links, etc. (Attach. No. 8, JHCC Commissary menu)
(Attach. No. 9, LCF Commissary menu) When testifying at a deposition Defendant Berg was
questioned about the difference in variety of items offered. Mr. Berg testified as follows:
Question:
27
Okay. One. And on exhibit Number 7, which is Department of Corrections'

menu, frozen foods there's 18. Now, we've already determined that
cents and 60 cents are comparable in your view. Is one and 18
comparable as well?
Mr, Berg:
Yes
(Attach, No. 5, Deposition Testimony of Michael Berg. p. 36, 22-25; p. 37, 1-2)
JHCC's menu combines these items under one heading, LCPs menu list these items under two headings: "Bag
Chili & Meats and "Potatoes/Rice/Beans"

However, the variety of items offered to inmates at LCF is not in any way comparable to
the variety offered at DOC.
Plaintiffs First Amended Civil Rights Complaint:
Based on the information learned through discovery Plaintiff determined it was
necessary to add two additional defendants in this case, Plaintiff filed a Motion For Leave To
File A First Amended Civil Rights Complaint seeking to add Mr. Quiroga, Keefe Commissary
Manager at the Lawton Correctional Facility, and Keefe Commissary Network, L.L.C. an
affiliate of The Keefe Group, as defendants. The Court granted Plaintiffs motion. Doc. 73.
Plaintiff has properly served Defendants, Mr, Quiroga and Keefe Commissary Network, LLC.
History of Plaintiffs requests for temporary restraining order and preliminary
injunction:
Contemporaneous to filing the Original Complaint Plaintiff filed Motion For A Temporary
Restraining Order And Preliminary Injunction, Doc. 3. On November 4, 2015, the Court Issued
a Report and Recommendation which found the motion for a restraining order moot and
recommended denial of the motion for a preliminary injunction. Doc. 29. In recommending
I
denial of the motion seeking preliminary injunction the Court focused on two specific areas; (a)
Plaintiff's lack of irreparable injury, Doc. 29 at 3, and; (b) the threatened injury to Plaintiff does
not outweigh the damage the Injunction may cause Defendants. Doc. 29 at 5.
I
Plaintiffs lack of Irreparable Iniurv:
In analyzing the original Injunction motion the Court found that Plaintiff could not
"establish he faces an irreparable injury absent a preliminary Injunction." Doc, 29 at 3. The
Court states that: "Plaintiff is correct that '[w]hen an alleged constitutional right Is involved,
most courts hold that no further showing of Irreparable injury is necessary.'" Citing Kikumura v.
Hurley, 242 F.3d 950, 963 (10th Cir. 2001). But the Court found that "Plaintiff's case is an
exception." Doc. 29 at 3. In sum, the Court found that Plaintiff could not satisfy the irreparable

harm requirement because, if he prevailed on his claim, he could be compensated "for his
added financial burden," Doc. 29 at 4.
The threatened injun/ to Plaintiff does not outweigh the damage the injunction mav cause
Defendants:
In analyzing the original injunction motion, the Court found that "the threatened injury to
Plaintiff does not outweigh the damage the injunction may cause Defendants." Doc. 29 at 5.
In analyzing this factor the Court found that; "If this Court were to issue Plaintiffs injunction,
Defendants would have to re-price the existing commissary items to match DOC's prices,
regardless of vendor contracts or price-structures. And, Defendants would have to order

additional commissary items which may require using additional vendors or .altering existing
contracts. These changes - which would affect the entire LCF prison population - could have
I
a significant impact on LCF's prison operations." Doc. 29 at 5. (Emphasis added)

Plaintiff did not object to the Court's recommendation to deny the original request for an
injunction. In the First Amended complaint Plaintiff removed the requests for a temporary
restraining order and preliminary injunction. However, on April 18, 2016, Keefe, with the
express approval of Defendants Rios and Berg, Increased the price on many of the
commissary items on the menu at LCF - including the identical Keefe private-label
items, and other Identical items, which are sold to inmates at DOC.
ARGUMENT
PLAINTIFF IS ENTITLED TO A PRELIMINARY INJUNCTION
In determining whether a party is entitled to a temporary restraining order or a
preliminary injunction, courts generally consider several factors: whether the party will suffer
irreparable injury, the "balance of hardship" between the parties, the likelihood of success on
the merits, and the public interest. Each of these factors supports the grant of this motion.
I
Plaintiff Is Threatened With Irreparable Harm:
As a matter of law, the continuing deprivation of constitutional rights constitutes
irreparable harm. EIrod v. Bums, 427 U.S. 347, 373, 96 S.Ct. 2673 (1976). This principle has
been applied in prison litigation generally, see Jolly v. Coughlin, 76 F.Sd 468, 482 (2"'^ Cir.
1996); Newsome v. Norris, 888 F.2d 371, 378 {6"^ Cir. 1989); Mitchell v. Cuomo, 748 F.2d 804,
806 (2'"' Cir. 1984). In the original motion seeking an injunction, this Court found that Plaintiff
could not establish that he faced irreparable harm because he could be compensated later for
any monetary damages that he suffers as a result of paying the higher prices and for having
lesser variety. However, Plaintiff argues, in light of the April 18, 2016, price increase that he
does face irreparable harm. The predatory price scheme of commissary items at LCF limits
the number of items Plaintiff can afford. The April price increase of the commissary items will
further limit the number of items which Plaintiff can afford to purchase, items which, absent the
predatory price scheme. Plaintiff would othenwise be able to purchase - thereby permanently
depriving Plaintiff of the items. As the Court noted in the recommendation to deny the original
injunction motion, the price of commissary at LCF "affect[s] the entire LCF prison population."
But an injunction requiring LCF to price commissary items comparable to DOC would have a
positive affect on the entire prison population - denying the injunction, and allowing the
significantly higher pricing, including the April 18, 2016, price increase, to stay in place will
have a negative affect on the entire medium security inmate population at LCF.
Additionally, in the original injunction requests Plaintiff alleged disparity in the variety of
items at LCF versus DOC. Now, based on information obtained through discovery, Plaintiff
can clearly demonstrate a significant difference in the variety of items between LCF and DOC.
The cumulative effect of the predatory price scheme and the significantly lesser variety of item
availability causes irreparable harm which cannot be recovered through any damage award or
' Plaintiff asks this Court to take notice that while Plaintiff has not yet moved for class certification pursuant to
Fed.R.Civ.P. 23, the variety and price of commissary at LCF, affects eacti medium security inmate at LCF equally
- all of which are similarly-situated under the state-created classification of medium security. There is no sub-set
or sub-class of medium security that would distinguish medium security inmates at LCF from medium security
inmates at DOC operated facilities. See Attach. No. 1, p. 21, 13-25; p. 22, 1-8.

compensation. See RoDa Drilling Co. v. Siegal, 552 F.3d 1203, 1210 (10th Cir. 2009) ("We
have previously held that a plaintiff satisfies the irreparable harm requirement by
demonstrating 'a significant risk that he or she w/ili experience harm that cannot be
compensated after the fact by monetary damages.'") (citation omitted) (Cited by the Court in
Doc. 29). Plaintiff cannot be "compensated" for "added financial burden" when the predatory
price scheme, or the lack of variety, forecloses his ability make a purchase in the first place.
Doc. 29 at 4.
Balance Of Hardship:
In deciding whether to grant apreliminary injunction, courts ask whether'the suffering of

the moving party if the motion is denied will outweigh the suffering of the non-moving party if
the motion is granted. See, e.g., Mitchell v. Cuomo, 748 F.2d 804, 808 (2"" Cir. 1984) (holding
that danger posed by prison crowding outweighed state's financial and administrative
concerns); Duran v. Anaya, 642 F.Supp. 510, 527 (D.N.M. 1986) (holding that prisoner's
interest in safety and medical care outweighed state's interest in saving money by cutting
staff). Plaintiff states that the balance of hardship test weighs heavily in his favor. Plaintiff is
an inmate in the custody of the Defendants. Plaintiff has no alternative avenue to purchase
commissary items - the Defendants control the only avenue available to him.
The price
scheme of commissary is not even remotely related to a security, rehabilitative or

penological objective.
When asked if the pricing of commissary items serve any
rehabilitative objective - meaning is commissary at LCF priced higher to help rehabilitate

offenders, Mr. Rios responded, no.
(Attach. No. 1, p. 73, 19-23)
When asked if pricing

I
commissary items at LCF higher than similar and identical items at DOC serves any
penological objective, Mr. Rios responded, no.
(Attach. No. 1, p. 73, 24-25; p. 74, 1-5)
Defendant Berg also testified about this at a deposition. Mr. Berg was asked if the higher price
of commissary at LCF versus the price of similar and identical items at DOC serves any
security objective, Mr. Berg responded, "No not that I'm aware of." (Attach. No. 5, p. 28, 1625)
When asked if the higher price of commissary at LCF versus DOC serves any
rehabilitative or penological objective, Mr. Berg responded, "Not that I'm aware of." (Attach.
No. 5, p. 29, 1-12) See Gwinn u. Awmiller, 354 F.3d 1211 (10th Cir. 2004) (Absent allegation
of suspect classification, court's review of prison officials' differing treatment of various inmates
is quite deferential; to withstand equal protection challenge, classification must be reasonably
related to legitimate penological purpose).
In analyzing this factor in the original motion seeking a preliminary injunction the Court
found that if the Court issued Plaintiffs injunction that (a) "Defendants would have to re-price
the existing commissary items to match DOC's prices, regardless of vendor contracts or pricestructures" and. (b) "would have to order additional commissary items which may require using
additional vendors or altering existing contracts" and, (c) "could have a significant impact on
LCF's prison operations." (Doc No. 29) The Court cited Winrow u. Middleton, No. CIV-101115-D, 2011 WI7006584, at *2 (W.D. Okla. Dec. 20, 2011) (unpublished report and
recommendation) (refusing to grant the prisoner's request for injunctive relief in part because
"[t]he desired injunction would obviously interfere with prison administratjve decisions"),
adopted by 2012 Wl 95682 (W.D. Okla. Jan. 12, 2012) (unpublished).
But, LCF does not
operate the commissary - they have contracted commissary sen/ices to Keefe.
Mr. Rios
testified at deposition that Keefe employs the commissary staff and that oa LCF official
supervises the Keefe employees.
(Attach. No. 1, p. 45, 25; p 46, 1-8) Mr. Rios also testified
that no LCF staff participate in ordering or delivering commissary to LCF medium security
inmates. (Attach. No. 1, p. 47, 13-25; p. 48, 1-5)
In the context of prisons, security,
rehabilitation, and general penological interest are the dominant objectives - as demonstrated
by Defendant Rios and Berg's sworn testimony - requiring LCF to offer a commissary with
10
similar variety and pricing comparable to DOC's commissary, would not reasonably have any
effect on LCF prison operations.
Likelihood Of Success On The Merits:
Plaintiffclaims he is likely to succeed on the merits of the civil rights complaint. Plaintiff
is clearly being arbitrarily subjected to the desperate treatment of paying as much as 131%
more for similar and identical commissary items as similarly-situated medium security inmates
housed at DOC operated facilities pay.
Plaintiff is subject to the unequal treatment due
specifically and explicitly to his arbitrary assignment to the private for-profit LCF.
See
McDonald v. Bd. Of Election Comm'r of Chicago, 394 U.S. 802, 809 (1069) (regulation will be
set aside as violating the Equal Protection Clause if based on a reason totally unrelated to
the pursuit of a legitimate governmental interest.) (emphasis added)
LCF's predatory
commissary price scheme is totally unrelated to any legitimate governmental interest -
rather it is based on the profit motivation of the private for-profit corporations (GEO
Group Inc. and Keefe) - and cannot pass the rational-basis test.
Public Interest:
Plaintiff claims that requiring prison officials to observe the Constitution is always in the
public interest. LCF is the largest prison in the state of Oklahoma - housing more than 2500
medium security inmates. The inmates receive funds to purchase commissary items from their
non-incarcerated family and friends.
If the inmates are able to purchase more commissary
items at a lower cost - the savings will be enjoyed by their non-incarcerated families. The
price scheme has broad reach far beyond inmates incarcerated at LCF.
>
CONCLUSION
Plaintiffs First Amended Civil Rights Complaint sets forth that Plaintiff is similarlysituated to other medium security classified inmates and the only distinction between Plaintiff
and medium security inmates housed at DOC operated prison facilities is his arbitrary

assignment to LCF.
In the prison context, the Equal Protection Clause of the Fourteenth
Amendment requires inmates to be treated equally, unless unequal treatment bears a rational
relation to a legitimate penological interest. See Gwinn v. Awmiller, supra. Defendant Rios
and Berg's own sworn testimony confirm that the predatory price of commissary items at LCF
serves no penological or governmental objective. Plaintiff claims that requiring him to pay as
much as 131% more for similar and identical commissary items as inmates at DOC operated
prisons pay, based on nothing other than his assignment to LCF, is in violation of the
Fourteenth Amendment to the U.S. Constitution. The predatory price scheme of commissary
items at LCF cannot be justified as having any rehabilitative, security or legitimate penological
objective.
PRO SE PLAINTIFF
Plaintiff is a pro se litigant and is not a licensed attorney and is not educated or skilled in
the law. Plaintiff ask this Court to provide a liberal review of this motion in regards to his pro
se status and the findings oi Hall v. Bellmon, 935 F.2d 1106, 1110 (10*^ Cir., 1991) and Haines
V. Kemer, 404 U.S. 519, 92 S.Ct. 594 (1972).
ACTION REQUESTED
WHEREFORE, Plaintiff requests a preliminary injunction requiring the'Defendants to

perform one of the following options:
(1) Provide Plaintiff commissary services with a variety of items, priced comparable to, the
commissary service offered to medium security inmates housed at DOC operated
prisons.
Or as an alternative,
(2) Require Lawton Correctional Facility and Keefe Commissary Network, LLC / The Keefe
Group, to price identical commissary items which Keefe sells to both DOC (JHCC) and
12
LCF inmates at the price(s) that the item(s) are sold at Joseph Harp Correctional Center
("JHCC").
Additionally, Plaintiff requests an injunction freezing any future price increases of

commissary items at LCF until resolution of this case.
Respectfully submitted,
Michael"dr Lekherwood
DOC NO. 595058
8607 S.E. Flowermound Rd.
Lawton, OK 73501
day of
Subscribed and sworn to before me this
S/.L.h P
2016.
"^7
il
A.1.
My Commission Number:
No^ry PiilDiic
My Commission Expires: O/r^ '/)^/-2^/?
CERTIFICATE OF MAILING
13

I, Michael D. Leatherwood, hereby certify that a true and correct copy of the above and
foregoing instrument to which this certificate is attached, was served upon the following and
below named, by placing the same in a sealed envelope, first class postage-paid, and
deposited in the United States mail, recorded at the Lawton Correctional Facility, located at
8706 S.E. Flowermound Rd., Lawton, Oklahoma, 73601 on /V day of June 2016.
Don G. Pope & Associates, P.O.
Stefanie E. Lawson
611 SW24thAve. #102
Assistant Attorney General
Norman, OK 73069
*Counsel for Defendants Rios and Berg
313 NE 21st Street
Niki Cung
Keefe Commissary Network, L.L.C.
Kutak Rock LLP
10880 Linpage PI.

St. Louis, MO 63132
234 East Millsap Road #200

Fayetteville, AR 72703-4099
" Counsel for Defendant Quiroga
Oklahoma City, OK 73105

* Counsel for Defendant Minyard
No attorney has made an entry of

on behalf of Defendant Keefe Commissary
Network, LL C.
Respectfully,
Micha^D. Leathenwood
DOC No. 595058
8607 SE Flowermound Rd.
Lawton, OK 73501
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I I' I
Case 5:15-cv-00767-C Document 104-1 Filed 06/16/16 Page 1 of 29
Deposition Transcript of Defendant Hector Rios

{Leatherwood V. Hector Rios, etal., CIV-15-767)
(Deposition Date: IVlay 12, 2016)
Attach. No. 1

Hector Rios
Hay 12, 2016
Page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF OKLAHOMA

MICHAEL D.
LEATHERWOOD,
Plainti-Pf,
Case Number
CIV-15-767-C
vs .
HECTOR RIOS,
WARDEN,
et al.,
Dependants.
DEPOSITION OF HECTOR
Taken
on
behalF of^ the
RIOS
PlaintiFF
on the 12th day of May,

in Lawton,
*
REPORTED BY;
201
Oklahoma.
*
STEVE PLUMBTREE,
CSR,
CP
v..
Plumbtree Reporting
(405)620-6272 - plunibtreereporting@gmail.com - www.plumbtreereporting.com

Hector Rios
May 12, 2016
2 (Pages 2 to 5)
Page 4
Page 2
APPEARANCES
Pro Se. 8607 Southeast Flowermound Road, Lawtor>. OK
7}501. appearing pro se.
3
4
MR. DON G. POPE. Attorney at Law. Don G. Pope &
It is hereby stipulated and agreed by and

between the parties hereto, through their respective
attorneys, that the deposition of HECTOR RIOS may be
Associates, P.C.. 611 24th Ave SW, Suite 102,
takers on behaK of (he Plaintiff on May 12th, 2016
Norman, OK7B069, appearing on behalf of (he
in the City of Lawton. Oklahoma by Steve Plumbtree.

Ceitined Shorthand Reporter within and for the
State of Oklahoma, taken by rtotice pursuant to the
Federal Rules of Civil Procedure.
Defendant Rios.
MS. STEFANIE E.LAWSON, Attorney at Law.
STIPULATIONS
MR. MICHAEL 0. LEATHERWOOO, DOC Number SSSOSS,
Assistant Attorney General. 313 Northeast 21st

Street Oklahorru City,OK 7310S. appearing on behalf
le
of the Defendant Minyard.
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DEPOSITION INDEX
9
le
ITEM
11
Stipulation Page
12
PAGE
.4
13
Examination by Mr. leatherwood

Jurat Page
102
14
Certificate Page
15
Errata Sheet
103
104
16
It is further stipulated and'agreed by and

12
attorneys, that ail objections, except as to the
13
form of the question arui the responsiveness of the
14
answer, are reserved until the time of trial at
15
16
which time they may be made with the same force and
effect as if made at the time of the taking of this
17
deposition.
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17
19
18
19
2e
20
21
21
22
22
23
23
24
24
25
25
Page 5
Page 3
1
EXHIBIT INDEX
EXHIBIT
PAGE
Plaintiffs Exhibit Number 1
12
33
48
Plaintiffs Exhibit Number4
50
HEaOR RIOS.
having been duly sworn, testified as follows;

EXAMINATION
BY MR. LEATHERWOOD:
Q. Mr. Rios, I want to ask you a couple of
75
6
7
79
to make sure that you understand that you are the
Plaintiff's Exhibit Number 7
96
defendant and I'm the plaintiff.
13
11
12
13
Also I want to tell you that throughout the

questioning I'll refer to myself as the plaintiff
just so that it will make it easier to read the
transcripts later instead of referring to me as an
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14
IndividuaL
15
16
15
16
your attorney, he's here? ts that correct?
17
17
A.
18
18
Q. Okay. And are you a resident of the State
19
19
20
20
A.
21
21
Q. Areyou a resident o' the State of
22
22
23
23
24
24
25
25
10
11
12
Defendant's Exhibit Number 8
97
10
questions about the lawsuit that you are a defendant

in. And I'm the plaintiffin that lawsuit I want
Andyou are represented byan attorney. And

That is correct.
of Oklahoma?
Excuse me?
Oklahoma?
A. Yes, t am a resident of the State of

Oklahoma.
Q. What Is your title at he Lawton
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Hector Rios
May 12t 2016
3 (Pages 6 to 9)
Page 6
1
2
3
4
Cofrectional Facility?
A. Iam ttie senior warden of this facility.

Q. Okay. Are you also referred to as facility
administrator?
A. Yes, sir.
Page 8
1
2
A Yeah.
Q. And it's owned by a company out of Florida?
Q. Okay. As the facility administratoror the
wardea do you have any superior official at the
Lawton Correctional Facility? Or are you the
highest-ranking official at the facility?
10
A. Iam the highest ranking at the facility.
9
10
11
Q. And can you describe generally whatyour
11
12
duties or responsibilities are as a warden at the
12
13
Lawton Correctional Facility?
14
A. I oversee the operation of the facility. I
15
have three associate wardens with me. One is
16
Warden Serg who oversees the financial side of the
13
14
15
16
17
house.
17
19
20
Warden Catdwell whooversees the security side

of the house.
Warden Collins who oversees the program side of
21
the house.
22
23
24
25
Responsible for security, the safety of the

population of this facility, as well as the staff.
Q. Okay. What are your responsibilities
related to the commissary services that are provided
Q. Publicly-traded corporation?
6
7
8
18
corporation?
A. Yes. It's a private prison.
'
You said that's GEO?
A. Yes, I mentioned to you just a minute ago
itis run by GEO.
'
Q. Okay. And the facility generates revenue

through a contract witti the Oklahoma Department of
Corrections, is that correct?
A
I believe that is correct.
Q. Okay. Is the contract with the State of

Oklahoma and with the Oklahoma Department of
Corrections the only source of revenue for Lawton
Correctional Facility?
A. To my knowledge, it is,the only per diem
18
that GEO gets from the DOC.
19
20
21
22
Q. So it doesn't generate any other revenue

other than the per diem from DOC? There's no other
revenue sources that you are aware of?
A. Not to my knowledge I don't know.
23
24
25
Q. What's the primary function of the Lawton

'
A The primary function for the Lawton
Page 7
1
2
3
4
5
6
7
8
9
10
11
12
to the inrDatesat the LawtonCorrectional Facility?
A My responsibility?
Q. Yes-
A. To make sure that you know, we have the

commissary provided to the offenders, to the inmates
of this facility.
Q. Okay. The LawtonCorrectional Facility is
a private prison, is that correct?
A. That is correct.
Q. Okay. What exactly does that mean that

it's a private prison?
A.
It means that we have a contract with the
Page 9
1
2
3
4
5
6
7
8
9
10
Correctional Facility is to house offenders, medium

security, to keep them safe. We house - it's the
largest prison in the State of Oklahoma were
2600-plus offenders or 2,626 beds. We cannot go
further than that. Our primary function is to make
sure that the offenders are safe and go through
their programs, SO what is needed, what we can
provide to them, to make sure that they do their
time right and getting back and ready for society.
Q. Okay. Prior to taking your current
11
position with the Lawton Correctional Facility, had
you been a warden or faci% administratorat any

other prison?
13
State of Oklahoma to house their offenders. Or
12
13
14
their inmates.
14
A.
15
Q. Was that in the State of Oklahoma?
15
Q. Okay. So the Lawton Correctional Facility
Yes, I have.
16
is a--it's a corporation. It'sa businessseeking
16
A.
17
18
19
20
21
to make a financial profit is that correct?

A It is run by the GEO Croup. GEO
Corrections. There is a per diem that the State of
Oklahoma pays the company per Inmate. So yes.
Q. Okay. And so the Lawton Correctional
17
Q. Was it for a GEO private prison?
22
23
24
25
Facility, just to be clear, it's not a governmental

agency? It'snot likethe Departmentof Corrections
or the Federal Bureau of Prisons. It's separate
from the government. It'sa publicly-traded
22
23
No, it was not.
18
A.
19
Q. Okay. Was it with th >Federal Bureau of
No, it was not.
20
Prisons?
21
A.
'
It was with the Federal Bureau of Prisons.
Q. Okay. When you were a warden or facility

administrator at a prison with the Federal Bureau of
24
Prisons, did they have a commissary service that
25
sold items to the offender base there?
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Hector Rios
May 12, 2616
4 (Pages 10 to 13)
Page 10
Page 12
A.
what's on the document
0. How did it operate?
A.
Q. Okay. In the handbook. Pages 38 and 39

address the commissary, is that correct? Are you
familiar with that?
A. 1would have to look at the commissary. 1

don't know what pages.
We had
MR. POPE: I'm going to object to the form
Yes.
of the question.
THE WITNESS; Okay.

MR. POPE: We're not dealing with matters
related to the Federal Bureau of Prisons on that.
9
le
You can go ahead and answer the question if you
9
10
can now.
11
THE WITNESS: Yes, sir. It was a
11
Q. Okay. 1have an exhibit -- I'vegot two

copies, one for you and one for your counsel. And
if you would like that
Page 38 and 39 is what I'm referencing to.

MR. LEATHERWOOD: Ms. Lawson. 1didnt
12
15
commissary. We had our own employees assigned to

the commissary.
I oversaw the operation. 1also again associate
wardens. Very limited, depending -- because most of
16
(he facilities that 1 was a warden on was
16
17
penitentiaries, so I limited the items for security
17
18
18
MR. LEATHERWOOD: Yes, sir.
19
MR. POPE: Mine only goes up to Page 27.
26
for safety reasons.

So to answer it cleariy for you, we have more
items here at this facility than what 1had in the
21
federal Bureau of Prisons, facilities that 1was the
21
and kind of wockyjaw. I've got it highlighted in
22
warden at
22
there where it's got Page 38.
23
BY MR. LEATHERWOOO:
23
BY MR. LEATHERWOOD:
12
13
14
19
24
25
Q.
14
bring a copy for you. I'm sorry. 1wasn't aware

you were going to be here.
THE REPORTER: Do you want to make this
15
Number 1?
13
20
You are familiar with the Offender
24
Orientation and Reference Handbook, which is
25
'
MR. LEATHERWOOD: Yes, please.

MR. POPE: Did you s^ 38 and 39?
MR. LEATHERWOOD: Well, it's all backwards
Q. In the handiMok that you have a copy of, on
Page 38 it states -- I'm goinp to read verbatim from
Page 11
Page 13
commonty referred to as the offender handbook, is
that correct?
A.
Q. Okay. What is the purpose of the offender
That is correa.
3
4
handbook? What is it intended for?
A. It gives the offender the idea of their

rights. All the njles and regulations. It states
our expectations in reference to sanitation and also
12
has the type of programs that we have. So it's

basicallywhat we expect from the offender and
giving information to the offender, to the inmate.
of what is going on within the walls of the Lawton
13
Correction Facility.
le
11
14
15
10
11
12
Q. Okay. And the current version of the
MR. LEATHERWOOD: Yes, it is offered as an
exhibit to the deposition.
THE WITNESS: And what page are you

reading?
BY MR, LEATHERWOOD:
Q. On Page 38.
A. All right-
'
14
0. All right I'm going to start over with

that. On Page 38 it states that the offenders need
15
to obtain order forms from their housing sergeant to
13
handbook was revised in March 201S, is that correct?
the handbook. It says, 'Offenders need to obtain

order forms from their housing sergeant to place
orders for commissary items."
MR. POPE: Are you offering this as an
exhibit to the deposition?
16
place orders for commissary items. Is that
17
accurate? is that the process at Lawton
18
Q. Okay. And in March of 2015, you signed the

current version of the handbook authorizing it is
18
19
that correct?
19
A. It should be, yes.
16
17
20
21
22
23
24
25
A.
A.
1 believe it was.
That is correct.
20
Q. Okay. And when you signed the offender

handbook, what does that mean? What is your
21
sigrtature on the offender handbook intended to

translate to the offender population?
A. That 1reviewed the handbook and agree with
23
22
24
25
Q. Okay. Are you aware that that's rwt

current that's not the way that it happens at the
lawton Correctional Facility?
A. You know, either the sergeant or even the
commissary supervisor can pass those -Q. Okay.
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Hector Rios
May 124 2016
5 (Pages 14 to 17)
Page 14
1
Page 16
A. those commissary slips.
interest in GEO Group?
Q. Okay. On Page 38 it also says that, "Upon

your reception, you'll be issued a permanent
identification card that has a bar code (hat will be
utilized in chargingyoor trust account." Isthat
5
6
answersto interrogatories.
THE WITNESS; Yes, in the answers. And
so"
BYMR. LEATHERWOOD;
the procedure that offenders uselo pay for
commissary at Lawton Correctional Facility?
A.
Q. Okay, Why does the handbook that you
2
3
No, it's not,
le
authorized in March of 2015 state that if it's
11
incorrect?
12
A.
It must have been overseen,
13
Q. Okay, You reviewed it and just over -
9
10
14
Thai's not relevant to this matter.
A.
Q. Itwasjust an oversight?
15
16
A. (Witness nods head)
16
17
Q. Okay, The handbook alsostates on Page 39,
17
18
"The commissary hoursof operation are posted on the
18
bulletin board next to the canteen and a new price
28
21
list is posted everyFriday on the bulletin board in

each pod." Does commissary here, do the offenders
22
go to the canteen?
23
24
25
A. No, they do not go to the canteen.
Q. Okay. But that -- would you agree or

how would youinterpret that that says the
Q. Theanswer isyes?
A. -- yes.
Q. Did you purchase the stock? Or how didyou

receive the stock that yougot inGEO Group?
MR. POPE; Iobjectto that question.
15
19
MR. POPE; That's been provided inthe
11
12
13
14
Yeah.
A. You know, I believe that wasalready

answered. But to the same --
MR. LEATHERWOOD; Okay.

BYMR. LEATHERWOOD;
Q. Or were you awarded the Stock for

performance?
19
MR. POPE; Thesame objection.
20
BYMR. LEATHERWOOD;
21
22
Corporation, Is the value of the stock tied to the
23
24
25
are? The betterGEO performs, the higher the value

ofthe stock that youown?
Q. Okay. Now, you own stock in GEO
performance of the company overall like most stocks
Page 15
1
commissaryhours of operations are posted next to
the canteen? Would that infer that you go to the
canteen? Or
4
5
A. That was just an oversight on thai one.

Q. Okay. Mr. Rios, as the warden a( Lawton
Correctional Facility, how are your compensated? Is
it hourly? Orare you on a salary based?
8
9
10
11
12
A. I'm on a salary,
Page 17
1
2
MR. POPE: I'm going to object to the form

ofthe question, warden. But'if you can answerthat
question --1 don't know -
4
5
6
THE WITNESS: All right.

MR. POPE. Idon't know ifyou can
understandhowto answer, but answer ifyou can.
7
8
MR. POPE: I objectto that question.

And you've already answered, but that's not
relevant to this matter,
THE WITNESS; Okay,
9
10
THE WITNESS; Well, you know, I'm going to

tellyou that Ireally don't focus on the stocks.
To be honest Idon't. Whether they are given to me

or not, Idon't pay attention to them,
11
What Ipay attention to is\vhat's going on with
12
the safetyand orderly runningof the facility. The
stocks doesn't mean anything to me. The money does
13
BY MR. LEATHERWOOD:
13
14
14
not meananything (o me. So Ido not pay attention
15
Q. Doyou receive any kind of bonus or

incentivepay based on the financial performance of
15
to the stocks.
16
the Lawton Correctional Facilities?
16
BY MR. LEATHEftWOOD:
17
MR. POPE; The same objection, and Iwill
17
Q. Doyou owr) stock or have anyother
18
direct you not to answer that question,
18
ownership interest in Keefe Group or anysubsidiary
19
BY MR. LEATHERWOOD:
19
or affiliate of Keefe Group?
2d
Q. Okay. Doyou receive any kind of bonus or

incentive paid based on any other factor?
20
21
22
MR. POPE; The same objection. Idirect
21
22
A. Ibelieve it was answered already, and the

answer is no.
Q. Doyou know ifGEO Group, Incorporated owns
23
you not to answer the question.
23
stock in Keefe Group or anysubsidiary or affiliate
24
BY MR. LEATHERWOOD;
24
ofKeefe Group?
25
Q. Doyou own stockor have any ownership
25
'
MR. POPE: Object to the question, calls
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Hector Rios
May 12, 2616
6 (Pages 18 to 21)
Page 20
Page 18
1
2
for speculation.
Answer if you can, warden.
my experience that it's very rare when we trartsfer a

medium security to a medium security. Very rare.
For the simple reason that there is no beds
available in the publics. So in order for me to
transfer a medium-security offertder to another
medium, it is very rare. Case-by-case scenario.
Q. Okay. Okay. Who establishes the security
THE WITNESS: 1do not have any 1do not

have any knowledge on that.
6Y MR, lEATHERWOOD;
Q. Allright. Prior to October or so of 201S,

the lawton Correctional Facility housed strictly
medium-security inmates, is that correct?
level of an inmate that is housed at Lawton
Correctional Facility? Is that done here or is that

done prior to the inmates arriving here?
le
A.
That is correct.
Q. And now the Lawton Correctional Facility
10
11
houses inmates which are classified as maximum
11
12
security also, is that correct?
12
78 of them. That is correct.
A. It is prior to the inmate arriving here.
Q. Okay. What is the difference between a

medium-security ievel inmate housed at Lawton
13
A.
14
Q. Are the maximum-security inmates housed in
14
IS
general population with the medium-security inmates?

A. No. they are not.
15
Correctional Facility and a medium-security level

inmate housed at a Department of Corrections
13
16
operated facility? What's the difference in those
17
Q. Okay, And why not?
17
offenders?
18
A. They are classified as a different level.
18
16
19
This is a medium-security facility. They're housing
19
MR. POPE: Object to the form of the

question. I'm not sure what you are asking.
20
is more structured, therefore Ihey are not housed

with general population.
Q. Okay. So the classification is important?
20
BY MR. LEATHERWOOD:
21
22
23
A.
24
Q. Okay. How are medium-security inmates
25
Yes.
21
22
23
assigned to be housed at Lawton Correctional
24
25
Q.
Is there a there difference between a
medium-security inmate at Lawton Correctional

Facility this morning and the equivalent similarly
situated medium-security inmate at one of the
several Department facilities this morning? Are
Page 21
Page 19
they different within their classification?
A. A medium security -if 1may, you
Facility by the DOC? How do Ihey end up being here

versus at another facility in the state?
MR. POPE: Again 1would object to the
mentioned medium-security facility - offenders at a
question, calls for speculation.
4
5
medium facility inmate. 1do not know the other

medium. This is the only prison that 1have worked
in the State of Oklahoma being a private. 1have
Ifyou can answer the question, go ahead.

THEWITNESS: You know, they come here
through population. They are the ones that
not been exposed to the public of the Department of
designate all the offenders that come to the Lawton

Correctional Facility.
Corrections,
11
But we all know that a medium-security inmate is

the same as an medium-security inmate in another
facility the same as it is here.
12
Correctional Facility isn't irwolved in that
12
BY MR. lEATHERWOOD:
13
process?
13
9
10
11
14
15
16
17
18
19
26
21
22
23
24
25
BY MR. LEATHERWOOD:
le
Q. You are not really involved -- the Lawton
A.
Not at all.
14
Q. It's whoever shows up shows up.
Can the medium-security inmates that are

assigned to the Lawton Correctional Facilitybe
housed at medium-security Department of Corrections
operated facilities?
A. I'm sure they can.
Q. So an inmate can be laterally transferred
Q. Okay. So medium is medium is medium,
regardless of where they are housed?
15
A.
16
Q. Okay, The only difference between a medium
17
19
inmate here and a medium inmate at one of the public

facilities is just their location and where Ihey are
housed? That's what we're getting to. Is thai
20
correct?
18
(Witness nods head)
21
A.
from Lawton Correctional Facility, which is a medium

facility, they can be transferred to another
22
0. Okay, Are there different subject
That is correct.
23
classifications or subsets of medium-security
medium-security facility in DOC?

A. It depends on the situation. It has been
24
inmates? Meaning is there a low-mediumand a
25
high-medium? Or is it just medium?
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Hector Rios
Nay 12, 2016
7 (Pages 22 to 25)
Page 22
1
2
A. It isjust medium.
Q. Okay. And that's--the classification of
Page 24
1
A Depending on their level.
Q. Okay. Doyou believethat the
medium, that's a state-created classification,
medium-security inmates housed al the Lawton
right? That's not something that LCF has done, but
that wascreated bythe state eitherthrough policy
4
5
Correctional Facility should be treated differently

than medium-security inmates housed at Departmentof
or statute?
6
7
Corrections policies? Do you believe that?

MR. POPE: Objection.
7
8
9
10
11
A. Amedium-security inmateisa
medium-security inmate.
Q. Okay. And do you know howthe

medium-security classification wascreated? Doyou
know ifit's created throughstatute or policy?
Go ahead and answer ifyou caa warden.

THE WITNESS: Do I believe that an inmate
10
11
at a minimum -- medium-security facility in another

placeshould be treated differently than the ones
here in Lawton? Is that the question?
12
A. I do not know.
12
13
Q. Are medium-security inmatesat Lawton
13
MR. POPE: Inwhat capacity? Ithinkyou
14
15
Correctional Facility similarly situated to

medium-security inmates housed at Department of
14
15
need to clarily your question.

MR. LEATHERWOOD: Okay.
16
Corrections operated facilities?
16
SY MR. lEATHERWOOO:
17
18
19
MR, POPE: Object to that question because

similarly situated is a legal definitionand Warden
Rios is not an attorney and does not have the
17
18
Q, Well, withincommissary. Let's use that as

an examplefor this question. Doyou believe that
20
capabilityof answering that.
19
20
the offenders, the medium-security offenders that

are housed arbitrarily at the Lawton Correctional
21
BYMR.LEATHERWOOD;
22
23
24
25
Q. And based on whatwe've whatyou have

shared with us, an inmate security classification
level doesn't change when they are being transferred
to Lawton Correctional Facility from a state
21
22
Facility, should be treated differerMly than

offenders,medium-security offenders,that are
23
housed at the Oklahoma Department of Corrections
24
facilities related to commissary services?
25
A Okay. Ailof them should be treated
Page 23
Page 25
1
2
3
facility or from Lawton Correctional Facility to a

state facility. Theirclassification will staythe
same. Ifthey are medium, they are medium. That's
1
2
established, is that correct?
the warden of this facility, when I look at a
equally, period, regardless qf where you are at

Okay?
Commissary is a privilege not a right Ias
A. Yeah, ifthey are mediums coming from
commissary list and I see that there's items that
6
7
another medium, they are medium. Ifthere were

minimum securitycoming into, then their
6
7
need to be removed due to the security of orderly

running the facility, let's say, for instance, honey
classification is increased.
But to answer your question, I believe if I
10
11
understand it right, is that a medium security

transferring to a medium security, there's no -
12
they are the same.
13
Q. Theyare the same. Okay. Dothe
buns. Let's say, for instance, anythingthat you
9
10
and you probably saw that change in reference to no

more regular Cokes other than Diet Cokes. No more
11
12
bottles other than cans. Allthese things I can

change for the orderly running of the facility. For
your safety, for the safety of the other inmates.

So to answer your question, it's yeah, all
14
medium-security inmates at the Lawton Correctional
13
14
15
16
Facility and the maximum-security inmates at the

Lavrton Correctional Facility, do they have the same
15
inmates should be treated Mith respect all the
16
same.
17
privilegesavailable to them?
17
18
19
20
21
22
When it comes to the commissary, the warden has

that authority to make the changes. Or to eliminate
or to add commissary items.
Q. Okay. You made the statement that
commissary is a privilege arid not a right At what
point do you think that a privilege takes on the
23
becomes a right?
18
19
20
21
22
23
24
25
A. Depending on whatyou are asking.

Privilegesin reference to?
Q. Forinstance, the commissary. Purchasing

commissary.
A. is the same thing.

Q. Okay. Recreation?
A. Is different.
Q. Different. Visitation?
24
25
MR. lEATHERWOOO:, Object to the form of the

question. It asks for a--1 think, one, asks for
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Hector Rios
May 12j 2016
8 (Pages 26 to 29)
Page 26
speculation, Two, it aslcs fora legal conclusion.

He's not competent to answerthose questions.
BY MR. LEATHERWOOD:
4
5
Q. Well, could I3sk within your belief, when

does a privilege become a right? Not legally, but
within your belief.
7
8
9
16
MR. POPE: That doesn't--that's going to

still have the sameobjection whether it's his
belief or not. The issue isit's a legal
distinction that Idon't think he hasthe ability to
11
answer.
12
13
irrelevant anyway. So -
14
BY MR. LEATHERWOOD:
And furthermore, his belief regarding that is
15
Q. In your opinion, is the overall environment
16
17
18
19
20
21
22
at the Lawton Correctional Facility more dangerous

thanthe environment at the Department of
Corrections operated prisons?
A. It is my belief that every -- anyprison
or -- no matter what it's a challenging place. It
can be a dangerous absolutely. Not justthe
Lawton Correctional Facility, but even inthe
23
mediums in DOC.
24
25
Q. Butdo you think this Lawton Correctional
Facility is more dangerous overall than --
Page 28
1
2
3
4
the only reason is that because they cannot be

either managed or they cannot be at that facility so
they try another facility.
Just like Lawton Correctional Facility, if you
5
6
7
cannot be managed in this facility or you cannot

longer be in general population, we do have the
capability to moving you somewhere else for your own
safety.
9
10
11
Q. Okay. The reason I asked you that is

because you are probably aware that lateral
transfers into the Lawton Correctional Facility from
12
13
Oklahoma Department of Corrections' facilities at

least appears to be significantly greater than the
14
15
number of offenders laterallytransferredfrom

Lawton Correctional Facility. In your experience.
16
is that accurate?
17
MR. POPE: Is there a question there?
18
19
MR. LEATHERWOOD: Yeah, the question is is

that accurate?
20
MR. POPE: I think that calls for
21
speculation. I'm going to object to the question.
22
23
MR. LEATHERWOOD: He'sthe facility head,

MR. POPE: Ifyou can answer the question
24
go ahead.
25
THE WITNESS: I never question to
Page 27
2
3
4
A. Iwould not saythat.

Q. Is being assigned forhousing atthe Lawton
Correctional Facility versus being assigned to
housing at a Department of Corrections facility
intended to be punishment for the offender?
Page 29
1
2
population who they send here. As the administrator

of the facility. I believe with the experience and
what we're doing here we on manage anyonethat

comes to this facility. We Will find a way to
manage the Individual appropriately.
Now if that Individual cannot be managed, then
we have procedures in place to be able to get him
A. I don't agree with that. It's not.
Q. Are youawareof any policy or custom that
4
5
6
7
when an offender at a Department of Corrections"
transferred out of here.
9
10
facility getsintrouble, maybe theyget a

misconduct or get ina fight or something ofthat
BY MR. LEATHERWOOD:
11
nature, that the offender is then transferred to the
12
13
14
15
A. We do get a lot of offenders for

disciplinary problems, whether they are from the
minimum-security facilities or from arrother medium.
16
Yes. And I think we send some of their inmates that
17
18
have disciplinary problems to other facilities.

Q. So an inmate that's at a Departmentof
17
19
20
Corrections facility like Joseph Harp or Granite or

Lexington, they get introublethere and theyare
19
that the Oklahoma Department of Corrections
26
21
transfers offenders to Lawt in Correctional Facility

that they just don't want?
21
routinely laterally transferred to the Lawton
22
23
Correctional Facility forthat forthe reasons

theygot introuble -- they had gotten in trouble.
24
25
some inmates that havedisciplinary problems. And
A. Idon't know that. Iknow that we do get
19
11
12
Q. Is the Lawton Correctional Facility more

prepared to manage offenders with disciplinary
issues than Department of Corrections' facilities
13
would be?
14
15
A. Every facility is the same. Whether they

can manage it or not or we can manage it nor not.
16
all Ican tell youisthat we'll manage whatever DOC
18
Q. Okay. Have you ever made the statement
brings to this facility.
'
22
A.
23
Q. You've never made that statement
I have never made that statement
24
I'm still kind of on that same issue and you may
25
or may not know the answer. If you caa answer it
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Hector Rios
May 12j 2616
9 (Pages 30 to 33)
,
Page 30
1
2
3
4
5
6
please. Doyou knowhow manyoffendershave been
laterally transferred to Lawton Correctional
Facility from medium-security Departmentof

Correction facilities in the previous24 months?
3
4
Q. To Keefe Group, right? Keefe Corporation,

It's Keefe Commissary Networks,1believe, and then
5
6
7
something else. Does Keefe have authority overthe

inmates in the Lawton Correctional Facility? Do
they haveany responsibility fortheirsecurity?
A. Medium-security facility medium-security

inmates?
Q. Yeah, from medium-security Department of
Corrections' facilities to the Lawton Correctional
Facility within the last 24 months.
10
A. Not 24 months. But I'm going to say that
11
12
13
14
15
16
17
the average stay here istwo and a halfyears.

That's the average stay here at Lawton Correctional
Facility. Okay?
Last year we transferredin and out
approximately 1400. Thatmeans 1400were released
whether minimum, whether to the streets, whether to
a high-security facility or to a medium. So we
18
received 1400 new inmates.
19
Page 32
Q. Okay. Does the contract that the lawton
with the commissary.

A. Yes.
A They have a responsibility to get the
9
10
11
canteen out or the commissary out.

Q. Okay.
A. They are not responsible for the inmates.
12
I'm responsibleforthe inmates. Theyare

responsible for providing a service to the
population.
Q. Right. Okay.
A. Okay?
Q. Does the Lawton Correctional Facility
13
14
15
16
17
18
generate revenue from the ^sale ofcommissary items

sold to inmates at Lawton Correctional Facility?
A Yes. Those revenues go back to the inmate
Correaional Facility have withthe Oklahoma
19
20
21
Department of Coêctions allow the Lawton
21
welfare.
22
23
Correctional Facility to delegate itsauthority or

responsibility overthe inmates to a third-party?
22
23
24
Q. Okay. So there is a revenue source from

commissary. And that's based on the gross sales of
commissary, is that correct?
20
24
25
A. I don't understand your question.

Q. Okay. You are responsible for the
25
A I believe it is. And agaia to clarify
Page 31
Page 33
incarceration ofthe inmates andtheir safety,
security, and things like that. Does the contract
1
2
this, I do have my Associate Warden of Financeswho

takes care of that. Hejust informs me if I need to
3
4
that you have with the Oklahoma Department of

Corrections, can youdelegatethat authority offto
know. Or gives me ifsomething is going oa So

that question, Iwould direct it more to Mr, Berg.
anotherthird-party? Can you assign thatauthority?

A. Well, you know. Idon't know ifyou " I
3
4
7
8
still don't understand the question.

Q. Okay.
Q. Okay.
6
7
A Who is my Associate Warden of Finances.

Q. Okay. I want to enter this. This is a
copy of the agreement with Keefe. This will be

Exhibit Number 2,
'
MR. LEATHERWOOD: There'sa copy for you,
10
third-party? You know, I have correctional officers
8
9
10
11
herethat theyare posted intheirassigned post. I
11
sir.
12
have associate wardens, I have department heads. I
12
BY MR. LEATHERWOOD;
13
have line supervisors. And then I have myline
14
staff. They are responsible for certain areas.
13
14
Q. Keefe is the sole prowderof commissary

serwces to inmates at Lawton Correctional Facility,
Q. Yeah, I'mtalking about like another
15
is that correct sir?
15
A. When you saydo I delegateto the
16
entity. Can you contract to another entityand say,
17
"Hey, you take care of these inmates over here.
17
Q. Who establishes the price of commissary
18
18
Instead of us, you take care of them."
19
20
A. Well, we come to subcontracting medical,

subcontracting the commissary. Ifthat'swhat your
21
22
23
24
question--answersyour question. I still don't

understand the question.
Q. Okay.
A Ido -- I'm sorry.
25
Q. WeN. does that yousaid yousubcontract
That is correct
16
items at Lawton Correctioral Facility?
19
A.
20
Q. Okay. Do you have any role in that?
Keefe.
21
A.
22
Q. Okay. Can the inmnes assigned to the
No. I do not.
23
Lawton Correctional Facility purchase commissary
24
items from any other source other than Keefe?
25
A. No.
Plumbtree Reporting

Hector Rios
nay 12j 2016
10 (Pages 34 to 37)
Page 36
Page 34
1
2
Q. Can the inmates assigned at Lawton
Correctional Facility purchase commissary items from

the Oklahoma Department of Corrections commissary?
successive one-year terms thereafter unless either
partyto this agreement shall give notice in writing
A.
Q. Who decides what items are offered for sale
to the other party. Thisagreement may be

terminated by either party for any reason upon
giving 30-days written notice to the other party of
on the commissary at Lawton Correctional Facility?
such termination."
7
8
A.
No.
And so we've established that this agreement
you know, Keefe does. We however, we
sit down aruf meet with a major with medical, with AW

Finances, myself, and look at the list that Keefe
was" it was initially signed in 2010. And it
has. Arui we make a determination or a decision on
10
11
which items needs to be removed. As 1 mentioried
11
12
earfier, if there's a security, a safety issue with
12
states that it would be in effect for three years

from that date, which would cariy it until Jartuary
of 2'13. And then it would the agreement will
automatically renew for two successive one-year
13
the item that we are selling, we will remove it from
13
terms.
14
the list.
14
9
10
15
Let's say an example is your clippers. Clippers
15
16
were removed from the list. You know, a lot of the
16
So from January 2013. it Would have renewed for

one year, .tanuary2014, and it would have renewed
one more time January 201S. It would have run from
17
sweets were removed from the list.
17
'14 to'15. And ttiere ^
18
19
20
So we meet and we make a determination what

needs to be on the list or removed from the list.
Q. Youstated that you don't have any
18
19
20
Would it have expired in January of 201S?

A.
1 believe it wouldn't have.
Q. So this contract -- have you signed a new

contraa to replace this contract with Keefe?
21
responsibility for the pricing of the items that are
21
22
offered by Keefe.
22
A. i have not
23
A. No. That is correct. 1do not have any

say-so on the prices.
23
Q. Okay. So at this point relying on this
24
25
Q. Okay, The contract that 1have given you
24
25
contract you don't have a contract with Keefe? Is
that "would that be accurate?
Page 37
Page 35
1
2
as Exhibit Number 2, did you sign that contract?

A. As this was in January 2010.1 did not.
'
MR. POPE; 1would otlject to the question
on that It specifically states that the contract
Q. Okay. It was signed by a different warden

that was the head of the facility at that time,
would renew for one year unless designated in
right? Is that--
writing. And I'm kind of interjecting here, but

you've been supplied with a replacement contract
through June where - on tfiat So 1think your
A.
That's what it looks like.
Q. So now is this the agreement that sets
forth the terms between the Lawton Correctional
11
Facilityand Keefe? Is this the only agreement? Or

are there other agreements? Are there addendums to
this? Or what is the purpose of this particular
12
contract?
10
13
14
15
16
A. You know, to be honest with you, 1- this

is --
The contract, 1 have never reviewed this

contract
question is a little bit speculative.

MR.LEATHERWOOD; Okay. Based on the
language of Section 7 of the current contract
13
Exhibit 2, where it says the agreement will

automatically renew for two successive one-year
terms thereafter, unless either party to this
agreement shall give notice in writing to the other
14
party.
15
16
There's nothing about that that states that it

would renew a third time. It clearly states that it
will renew two successive times, which would have
10
11
12
17
Q. Okay.
17
18
A.
18
been January '13 to '14, one time. '14 to '15, two
19
times. 1don't think that's ambiguous or unclear in
19
1 have never sat down and read this
contract
20
Q. Okay. On Section 7 of the contract it
20
any way.
21
talks about the terms and the termination. I'm
21
22
going to read that section that it says, "This
22
23
agreement shall continue in effect for a period of

three years, the base term, from the date thereof.
The agreement will automatically renew for two
MR, POPE; Unless upon 30-days writterj

notice to the other party it's terminated.
MR. lEATHERWOOD: No. it says this
24
24
25
23
25
agreement may be terminated byeither partyfor any

reason upon giving 30-days written notice. That
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Hector Rios
May 12, 2616
11 (Pages 38 to 41)
Page 40
Page 38
1
2
3
4
that allows for either party to terminate it at any

time during the running of the contract. But
clearly the contract terminated in January of 2015.
BY MR. LEATHERWOOD;
THE WITNESS: 1understand what he's
saying.
3
4
So to answer you, no, it has not been extended

more than two years. It has pot been extended. It
cancelled on the 1Sth, 2015 and has been extended.
BY MR. LEATHERWOOD;
Section 7 of the contract that you have in front of

you, which is Exhibit Number 2 to the deposition, is
this contract still in force?
we have other documents that I'll introduce that
A. You know, what 1read is this agreement is

tenrtinated by either party for the reason upon
9
le
would cover it But absent any other documents that

would have replaced this or superseded this, this
11
giving30-days notice, written notice to the parties
11
contract at this time in May of 2016 is no longer in
12
of its termination. So this contract is still in
12
effect?
13
effect in my opinion.
Q. And you read that into this?
A. There is no -- we have not made any reason
13
for giving 30-dsys notice to either (or such

termination. To the best of my knowledge.
16
S
6
le
14
15
16
17
18
Q. Mr. Rios, based on the language of
Q. Okay.
14
15
Q. Okay. So absent any other documents and
A. According to the language, no.
Q. Okay. But this contrairt was in effect up

until January of 2015 and going backwards from
there. You agree with that correct?
17
A. 1believe 1just meritioned it to you.
18
Q. Okay. That's correct
19
MR. POPE: Uh --
19
28
MR. LEATHERWOOD; Go ahead, please.
26
Okay. Section 5 of the contract, where it talks

about service fee, it says that the institution will
21
be paid a service fee for the services to be
21
22
23
MR. POPE; 1 think he's confused about
this. And I'm going to suggest that the contract

speaks for itself.
22
provided byit hereunder equal to 12 percent based
23
uponagreed-upon pricing by the parties of adjusted

gross sales.
24
THE WITNESS: Yeah,
24
25
MR. POPE: 1think the real question is is
25
When it says based upon agreed-upon pricing of

Page 41
Page 39
1
does Warden Rios have any knowledge as to whether
this contract is still in effect or not. And not
based upon his reading of it but just of his own

personal knowledge with it
I'm trying to -
the parties, what does that mean?

A. Where are you reading from?
Q.
It's on Section 5.
MR. POPE; The page before. Right there.

THE WITNESS; That the company will get
MR. LEATHERWOOD: No, 1understand.
paid 12 percent based on the pricing.
MR. POPE: - ask questions for you. But
BY MR. LEATHERWOOD:
8
9
I'm just trying to clarify.
MR. LEATHERWOOD: 1 understand. Let me ask
le
just one more question about this.
le
11
BY MR. LEATHERWOOD:
11
Q. WhenKsaysagreed-upon pricing?
A.
Uh-huh.
Q. What exactly does that mean? Agreed upon

between who?
12
0. The second sentence of Seaion 7, where it
12
13
13
Q. Okay. Between Keefe and GEO or Keefe and
16
says this agreement will automatically renew for two

successive one-year terms thereafter, unless either
party to this agreement shall give notice in writing
to the other party. Do you interpret that that it
17
could extend beyond two years?
14
15
18
19
20
21
14
15
16
17
18
MR, POPE: Warden, if --
May 1?
MR. LEATHERWOOD: Yeah, please. Please.

MR. POPE: Warden, did the contract begin
Q. Okay, And you've been the facility head

since 2013?
A
October 2012,
20
Q.
October 2013?
21
January 2010?
22
23
THE WITNESS: Right 1understand what

he's saying. 1understand what he's saying.
MR. POPE: Okay
24
25
the Lawton Correctional Facility?

A Lawton Correctional Facilityis my
understanding.
19
22
24
It is between Keefe and GEO.
23
25
Paragraph Number6 of the same document talked

about menu. It says, "Product selection and pricing
will be agreed upon by institution and Keefe,'
Would again, wouldth mean that the Lawton
Correctional Facility has to agree upon the pricing
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Hector Rios
May I2j 2016
12 (Page^ 42 to 45)
Page 44
Page 42
of the commissary items?
A.
Yes.
Q. Okay. And as the facility head, would you
4
5
6
you designated somebody else to agree on pricing?

A. It would be my Associate Warden of
Finances.
be the one responsible for that agreement? Or have
Q. Okay. So Mr. Berg? Would that be correct?
3
4
Q. Okay.
A. Where they keep thei items.
Q. Is there any Lawton Correctional Facility

or GEO staff member assigned to the Keefeoffice?
Any officer assigned there? Any staff member
assigned there to oversee? I
A.
8
9
Q. Who provides security to their office?

A. They go through the same training that my
No-
10
11
Q. So he would be the one that you designated

to agree on any pricing agreement for the commissary
10
11
12
items?
12
office which has access to the Plaintiffs trust
13
14
15
16
17
18
19
26
21
22
23
24
25
A. We have never to my knowledge, we have

never discussed the prices. I understand the prices
go up. What we do is we notify the populationof
(he prices going up regarding all the items.
Iunderstand pricesgo up due to gas. due to
whatever needs to be done, you know. Whether it's
the transport bringing it in here, whether gas is
going up. priceschange.
DoIchallengethe pricesthat change? No, Ido
not. Ido not question the priceswhen they go up.
Q. you don't question them. So whatever Keefe
decides to pricean item at that's going to be it?
A. As long as it does not disrupt the orderly
13
fund account?
14
correctional officers go through.

Q. Okay, ts there a computer in the Keefe
A. They have a compute'. I don't -- I'msure
15
that I
16
17
18
MR. POPE: If you know.

THE WITNESS: No, I don't --1 know they
have a computer. Where they are hooked up to, I do
19
not know.
20
BY MR. LEATHERWOOD:
21
'
Q. Okay. Do you know how Keefe charges
22
inmates for commissary items? Do they -- when they
23
24
process their orders and they charge an inmate $10

or t2S. do you know how they charge that offender?
25
How that's processed?
Page 43
Page 45
njnning of the facility, I'm not --1 don't question
A.
it.
Q. When establishing he price of commissary
3
4
5
6
7
8
9
10
Q. Theycan charge whatever they want?

A. YoLi know, what goes up is usually frve
cents, 10 cents. I'm not going to question that.
IfI see that it's going up five dollars, you are
absolutely right I'm going to question that. It's
common sense. I'm not going to question five. 10
cents because I know the economy changes. Gas
changes.
11
Ifwe see somethingout of the normthat is
11
12
13
14
going up three dollars,five dollars, absolutely

I'll question it. That will disrupt the orderly
running of the facility. But Iwill not question
12
15
the five cents, 10 cents.
15
16
17
18
19
20
Q. Okay. So if it's reasonable, then you
wouldr>'t question it and you would if it was

unreasonable, then you would question it ifyou felt
it was unreasonable, that they were being unfair?
A.
That is correct.
3
4
5
6
7
the medium-security offenders at the Lawton

le
13
14
or rehabilitation of these offenders"?
16
17
18
19
20
23
from?
23
we provide them with an office there.
A. Okay.
Q. Do they take into account any security or

rehabilitative objectives in pricing it saying,
'Hey, we need to price it here to help with security
21
25
A. Can you repeat it again?

Q. When they are pricing items to be sold to
Q. Okay. Does Keefehave an officeat the

Lawton Correctional Facility where they operate
A. They use the gym, west gym. They have a --
items at Lawton Correctional Facility, does Keefe

factor in any security or rehabilitative objective
into their pricing?
21
22
24
No, I do not.
22
24
25
A.
I don't know the--
MR. POPE: And I object to the form of the

question. 1think it calls for speculation as to
how Keefe does that.
'
MR. LEATHERWOOD: Okay.
MR-POPE: Anyway, that's fine. You've

already answered it.
THE WITNESS; I don't know.
MR. POPE: So--
BY MR. LEATHERWOOD;
Q. Okay. So just to be clear. Keefe employs
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Hector Rios
May 12^ 2ei6
13 (Pages 46 to 49)
Page 48
Page 46
1
the commissaiy staff members, and these staff
members are not Lawton Correctional Facilityor 6E0
employees, is that correct?
5
6
7
8
A.
That is correct.
Q. OKAY. And do you or any Lawton

Correctional Facility or GEO staff member supervise
the Keefe employees?
A.
No.
9
10
11
Q. Who supen/ises the Keefe employees inside

your facility?
A. They have a supervisor, okay? The main
12
contact for Mr. Q, if he has any questions or
13
anything, he goes straight to Mr. Berg, Mr, Berg is
14
the contacting person. Mr. Q, he's a supervisor.
15
16
He's been through the training. We allow him to,

you know, go to each pod, each unit with no
17
18
19
20
problems. So he is the onlysupen/isor for Keefe

working inside Lawton Correctional Facility.
MR. POPE; Could you explain to him the
name for Mr. Q? Iknowthat you are--
21
22
THE WITNESS: Well, I need to see his last
1
2
3
4
5
A. That was my - not to my knowledge. If

they help, they might just help inescorting. Your
max custody unit would be the only otte. Unit 2.
you'll have a staff member there.
Q. Okay. I'm going to enter what will be
Exhibit Number 3. And this is a document it's
titled GEO Lav/ton Exhibit.
MR. lEATHERWOOD: A copy there for
16
Mr. Rios.
11
BY MR. LEATHERWOOD:
12
13
14
15
Q. This was p'ovided to rpe by Mr. Pope, And

it's a document that was signed by the executive
vice-presidents, general manager of Keefe Commissary
Network and someone with the GEO Group which is
16
Ronald A. Brack. And this was signed on 2013, but
17
it -- specifically in reference to the Lawton
18
19
A.
20
Q. And the effective date is 12/1/2013.
21
Have you seen that before?
22
name. Quiroga. That's Quiroga.
Q. Corrert.
Uh-huh.
A. This is the First time. |
THE WITNESS; So I can
23
24
Q. Okay So you hadn't seen this contract

the previous contract which is Exhibit Number 2,
MR. LEATHERWOOD; Yes.
25
you hadn't seen thai before oday?
23
MR. POPE: It's different than that,
24
25
Page 49
Page 47
1
2
3
THE WITNESS; I could bring it I'm not

seeing it. So I call him Q.
MR. LEATHERWOOD: It's right there.
Mr. Rios.
5
6
7
THE WITNESS; Quiroga.

MR. POPE; And would you spell that for
him? Because suspect he needs that.
8
9
10
11
12
THE WITNESS: Mr.Quiroga. Q-u-i-f-o-g-a.

BY MR. lEATHERWOOD:
Q. And so he would if he has any questions

about the operations, he would go to Warden Berg?
A.
Yes.
13
14
Q. Warden Berg. Okay. Do any Lawton

Correctional Facility or GEO Staff members
15
16
participate in ordering commissaryitemsfor

offenders? Do any staff members help process the
17
orders?
A. That is conL
Q. And then you haven't seen Exhibit Numbers,
3
4
which is the GEO Lawton exhibit you haven't seen

that before today either?
6
7
Q. That's what you are telling us.

In the first section or paragraph of
No.
Exhibit Number 3 is a sentence which states. 'KCN
will work with GEO to keep pricing to the inmate
IB
populationlowand comparableto Oklahoma Department
11
of Corrections commissary prii:ing.' Howwould you
12
Interpret that Mr. Rios. in your personal
13
interpretation?
14
15
MR POPE: Iwould object to the form of

the question. Ithink the memo speaks for itself.
16
I don't know Chathis interpretation adds anything
17
to that.
18
A. Not to my knowledge. I don't know.
18
19
Q.
19
20
that?
20
be equal to IXDC. Comparabte to DOC's commissaiy
21
22
23
A. To my knowledge, yes.
Q. Doany Lawton Correctional Facility staff
members participate in delivering the commissary
21
prices.
22
BY MR. lEATHERWOOD:
24
items to the offenders?
23
24
Q. Okay. When was the last time that you

reviewed(he price of commissary items sold at the
25
Oklahoma Department ofCofrections?
25
Keefe, Mr. Q and his staff, handles all of
A. Do any staff?
But go ahead artd answer it Ifyou can.

THE WITNESS: Yeah that the prices should
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Hector Rios
May I2j 2016
14 (Pages 50 to 53)
Page 50
Page 52
I
A. I think I have mentioned (hat already. We
MR, POPE: Mr, Leatherwood, if I may --
met to see the items. Did I see the prices? No. I
MR. LEATHERWOOD: Yes.
did not check the prices. All I checked was the
items that were there that we needed to review.
4
5
6
7
8
9
le
11
12
13
14
15
I believe there were some new items that Keefe
wanted to put in the commissarylist. We reviewed

those. We agreed with some, we disagreed mth some.
But I never checked the pricing.
Q. Okay. Being the facility head, how could
you -- without having reviewed the Oklahoma
Department of Corrections' pricing, how could you
maintain or make sure that the items being sold in
the commissary at Lawton Correctional Facility are
beirtg priced comparable lo (he Oklahoma Department
of Corrections? Howwould you know if they were
MR. POPE: -- explain that. Thediscovery

stuff was gathered by the facility staff and
provided to me to provide to you,
7
8
9
18
MR. LEATHERWOOD: Uh-huh,
MR. POPE: And the warden may not remember.

but these documents were provided to him for his
approval. But agala it was a'whole stack of stuff

that was about sixmonths ago.
11
MR. LEATHERWOOD: Right When yousay--
12
13
MR. POPE: And his recpllection of that is

maybe a little bit-
14
MR. LEATHERWOOD: Sure. And I'm not
15
referring to did he see them in reference to the
discovery requests.
16
comparable or not without reviewing the Department
16
17
of Corrections' pricing?
17
MR, POPE: Uh-huh.
18
A.
I have not reviewed it.
18
19
Q.
Okay.
19
he seen them prior to the filing of the lawsuit so
20
A.
And I don't know what else to answerto you
21
here.
22
Q.
Sure.
23
A.
It was not reviewed.
20
21
22
23
that he could operate -- insurethat the commissary

was operated correctly pursuant to the agreements
that are signed in-
MR. POPE: Okay.
24
25
Q. Okay. Exhibit Number 4 that I'm going to

Irtcroduce is a service provider agreement. This
24
MR. LEATHERWOOD: WhatI'masking is,has
MR. LEATHERWOOD: J- by the corporation,
25
MR. POPE: So your question is not in
Page 51
1
2
documentwas also provided by Mr. Pope.

MR. LEA7HERW00D: There's a copy foryou,
3
4
5
6
7
8
relation to the
Mr. Rios. There's a copy so that you have one.
2
3
MR. LEATHERWOOD; To the discovery, no. My

question is is - Iguess the point that I'm getting
BY MR. LEATHERWOOD:
at is how could
BY MR. LEATHERWOOD.
Q. Mr. Rios, haveyou seen thisdocument

before that's entered as Exhibit Number <17
A. Imust have glanced through il. Idon't

know. I don't recall. I don't--
MR. POPE: This is from the stuff
10
11
12
yesterday.
THE WITNESS: Yeah. Probably from
yesterday because - oh. yeah. So --
13
BY MR. LEATHERWOOD:
14
15
16
17
Page 53
Q. Okay. Prior to yesterday had you seen it?
A. No, not prior to yesterday. Maybe on

these, the same thing too. So
Q. Okay. Prior to the Tiling of the instant
18
lawsuit, you haven't seen Exhibit Number 2, which
19
was the contract between Keefe and Lawton
20
Correctional Facility. You haven't seen Exhibit
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Q. Mr. Rios, how could you insure that the

commissary at the Lawton Correctional Facility is
operating the way it's intended to operate if you
haven't seen the documents thai were in place?
A. Prior to this, no, I have not. Okay? My
main focus, mymain focus here waseverybody's

safety. We were going from lockdownto lockdown to
lockdown. Wewere having inmates getting slabbed.

This is nothing of my focus. My focus was your
safety and everybody else's safety. That was my
focus here. Okay? That was my locus.
My focus was not about s.commissary list. My
focus was to keep people safe in here, to keep my
staff safe, to keep all the inmates safe. That's
why all the changes have been made in reference to
21
Numbered 3, which is the GEO I can't remember
21
food service, in reference to Unit 2. It's not the
22
exactly how it was tilled. GEO lawton exhibit. And
22
commissary. It's people. Thk was my focus.
23
youhaven't seenthe sen/ice provider agreement
23
24
which is betweenKeefe Commissary Network and GEO
24
here, I certainly want to be safe and I want the
25
Group?
25
staff to be safe. I agree witftyour efforts on
Q. Okay. I appreciate that And as an inmate
Plumbtree Reporting
(405)620-6272 - plumbtreereporting@gmail.eom - www.plumbtreereporting.coni

Hector Rios
May I2j 2016
14 (Pages 50 to 53)
Page 50
Page 52
1
2
A. (think I have mentioned that already. We

met (o see the items. Did I see the prices? No, I
did not check the prices. All 1checked was the
rtems that were there that we needed to review.
3
4
MR. POPE; explain that. The discovery

stuff was gathered by the facility staff and
providedto me to provide to you.
7
8
9
10
11
12
13
14
15
16
17
I believe there were some new items that Keefe
wanted to put <n the commissary list. We reviewed
those. Weagreed with some we disagreed with some.

But I never checked the pricing.
Q. Okay. Being the facility head, how could
you without having reviewed the Oklahoma
Department of Corrections' pricing, howcouldyou
malr^tain or makesure that the items being sold in
the commissary at Lawton Correctional Facility are
being priced comparable to the Oklahoma Department
of Corrections? How would you know iftheywere
comparable or not without reviewing the Department
of Corrections'pricing?
18
A.
19
Q. Okay.
A. And Idon't know whatelse to answer to you
26
21
22
23
24
25
I have not reviewed it.
here.
Sure.
A.
It was not reviewed.
Q. Okay. Exhibit Number 4 that I'mgoing to

introduce is a sen/ice provider agreement. This
MR. POPE: Mr. Leathenvood, if I may
MR. lEATHERWOOD; Yes.
7
8
9
10
11
MR. LEATHERWOOD; Uh-huh.
MR. POPE; Andthe warden may not rerrtember,

but these documents were provided to him for his
approval. But again, it was a whole stack of stuff
that was about sixmonths ago.
MR. LEATHERWOOD; Right Whenyou say--
12
13
MR. POPE; And his recollection of that is
maybe a little bit
14
MR. LEATHERWOOD: Sure. And I'm r>ot
15
referring to did he see them in refererKe to the
16
discovery requests.
17
18
19
20
MR. POPE; Uh-huh.
21
was operated correctly pursuant to the agreements
22
23
24
25
that are signed in-MR. POPE; Okay.

MR. LEATHERWOOD:
by the corporation.
MR.POPE; So your question is not in
Page 51
1
2
3
documentwas also provided by Mr. Pope.

MR. LEATHERWOOD: There's a copyfor you,
Mr. Rios. There's a copy so that you have one.
BY MR. LEATHERWOOD:
5
6
7
8
9
Q. Mr. Rios, haveyou seen this document

before that's entered as Exhibit Number 4?
A. I must have glanced through it. Idon't

know. I don't recall. I don't -MR. POPE: This is from the stuff
'
MR. LEATHERWOOD; What I'masking is,has

he seen them prior to the filing of Uie lawsuit so
that he couldoperate -- insurethat the commissary
Page 53
1
relation to the
MR. lEATHERWOOD;
0 the discovery, no. My
question is is --1 guess the point that I'm getting
at is how could --
BY MR. lEATHERWOOD;
Q.
Mr. Rios, how could you insure that the
commissary at the Lawton Ciarrectional Facility is
operating the way it's intended to operate if you

haven't seen the documents that were in place?
A. Prior to this, no. I have not. Okay? My
10
11
12
yesterday.
THE WITNESS; Yeah. Probably from
yesterday because -- oh, yeah. So --
11
main focus, my main focus f)ere was everybody's
12
safety. We were going from lockdown (o iockdown to
13
BY MR. lEATHERWOOD:
10
13
lockdown. We were having inmates getting stabbed.
14
Q. Okay. Priorto yesterday had you seen it?
14
15
A. No, not priorto yesterday. Maybe on
15
This is nothing of my focus. My focus was your

safety and everybody else's safety. That was my
16
17
these, the same thing loo. So --
16
Q. Okay. Priorto the filing of the instant
17
focus here. Okay? That was my focus.

My focus was not about a commissary list. My
18
lawsuit you haven't seen Exhibit Number 2. which
18
focus was to keep people safe in here, to keep my
19
was the contract between Keefe and Lawton
19
staff safe, to keep all the inmates safe. That's
20
Correctional Facility. You haven't seen Exhibit
20
why all the changes have bênmade in reference to
21
Numbered 3, which is the GEO - I can't remember
21
food sen/ice, in reference to Unit 2. It's not the
22
exactlyhow it was titled. GEO Lawton exhibit. And
22
commissary. It's people. That was my focus.
23
24
you haven'tseen the service provider agreement

which Is betweenKeefe Commissary Network and GEO
24
here. I certainly want to be safe and I want the
25
Group?
25
staff to besafe, Iagree witti your efforts on
23
Q. Okay. I appreciate that. And as an inmate
Plumbtree Reporting

Hector Rios
May 12, 2016
15 (Pages 54 to 57)
V_
Page 54
1
that 1certainly do.
Page 56
1
three associate wardens. Each have a certain
division. They are like my advisors.
So on this particular, if Warden Berg is

assigned to this area and he didn't see any problem
with it then we would mc>ved on. If1have to get a
The service provider agreement on Page Number 2
documentation that's signed, ljust kind of sign

1sign it. And if there's any issues, he will let
under the heading of Menu, I'm going to read that

exactly the way it is Inthe agreement. Itsays,
'Product selection and pricing will be agreed upon
by GEO and Keefe. Menuselection and pricing shall
be reviewed as needed, and no less than annually.
All changes proposed by Keefe must be approved by
me know of the issues.
GEOwarden/facility administrator. Price
13
Q. Okay. So based on that you haven't

personally, even though it -- this docuntent says
facility head -- or facility administrator, you
personally haven't approved the price of commissary
items, but one of your associates, Mr. Berg, has you
14
would believe?
15
4
5
6
7
10
11
12
13
14
IS
adjustments must be approved by the warden facility

administratorof GEO priorto implementation,'
Would you interpret that paragraph to mean that
you as the warden or facility administrator has to
approve the pricing of the commissary items?
A. 1did not hear a word you said.
4
5
6
le
11
12
19
A. 1go back again to saying that 1have three

associate wardens, different divisions. 1sign the
documentation, okay, by their advice. "Warden,
these are -- in the commissary lists, 1don't see
any problem in them." They pass them to me. 1sign
20
and 1 move on.
21
minutes? We've been going about an hour or so.

MR. LEATHERWOOD: Sure. No problem. No
22
problem.
22
about the revenue that the Lawton Conrectional
Q. You didn't hear what 1just read?
16
17
A.
17
18
Q. Okay.
16
19
20
No, 1did not.
18
MR. POPE: Can we take a break for a few
21
Q. Okay. Let me ask yoU, earlier 1asked
23
MR POPE: Okay.
23
24
(RECESS)
24
Facility generates, and we're in agreement that the

12 percent commission that's paid to the Lawton
25
Correctional Facility based on the sales of
25
MR. POPE: We can go back on the record.
Page 55
1
2
3
4
5
6
7
8
9
BY MR. LtATHERWOOD:
Q. Mr. Rios, I'm going to start back where we

left off,
Page 57
1
commissary items is deposited irtto the Offender
Welfare Fund?
A. Okay.
Q. On Page 2 of the exhibit that was entered
as Exhibit Number 4.
A. All right. Idon't havethat, so -Herewe go. All right.

Q. Whereit says under the tide of Menu, I
A. To the best of my knowledge, yes,
Q. Okay, Does theLawton Correctional
Facility have a specific policy about what the funds
in the Offender Welfare Fund can be used for?
10
believe it'son the second page, I'm going to read
11
12
13
exactly what it says. Usays,'Product selection

and pricing will be agreed upon byGEO and Keefe.
Menuselection and pricing shall be reviewed as
14
needed and no less than annually. All changes
7
8
9
10
11
12
13
14
15
16
proposed by Keefemust be approved by GEO warden

facility administrator. Price adjustments nnust
15
16
probably answer this a little bit better than I can.

Q. Okay. Are the funds that are deposited in
17
18
approved by the warden facility administrator of GEO

prior to implementation."
17
18
the Offender Welfare Fund, are they used to pay the

wages or salaries or compensation of any Lawton
19
Correctional Facility staff members?
19
And what Iwas asking iswould you interpret
A. I'm sure we do have some verbiage on that.

Idon't knowin which policy. But I knowthat we
spend it within the population.
Q. When you say you spend it in the
population, what does that -- what is it spent on?
A. We spend it on sport items. On things that
the inmates need. Thoseare to name a few. Again,
it goes to my associate wardea Mr. Berg, who can
20
21
that under your own interpretation to mean that you

as the warden or facility administrator has to
20
A. No, they are not.
21
Q. But you think that Mr, Bergwould be is
22
23
approve the pricing of the commissary items that are

oKered to the minimum security inmates at Lawton
22
he the one in charge of the Offender Welfare Fund?
24
24
25
25
A. I think I mentioned earlier that I have
23
A. Yes-
Q. And would he be the one that designates

what those funds are spent towards?
Plumbtree Reporting
(405)620-6272 - plumbtreereporting^gmail.com - www.plumbtreereporting.com

Hector Rios
May 12j 2016
16 (Pages 58 to 61)
Page 58
Ves-
Page 60
A.
Q. And then you would approve that?
microwaves.
A.
Yes.
Q.
Based on his recommendation?
3
4
5
6
Q. fvlicrowaves. Thoseare good. So but the

inmates don't -- when -- ifan inmate discharges, he
doesnt take that microwave wrth him, right? That
is in possession of and ownership -
5
6
7
A. Based on his recommendation. Based on the

institutional needs. If we can fund it from the
Inmate Welfare, that's what we do.
Q. And you say it buys like sports equipment?
A. Sports equipment. There's for the
16
tournaments. All the goody bags and stufffor
11
tournaments.
12
Q.
13
A. We do those. Or it comes out of the inmate
14
Uh-huh.
Welfare. You know --
15
Q. Televisions that are on the pods?
16
Televisions comes from the
17
Q. Computers for the computer classes?
18
A. I don't know, Honestly I don't know,
A.
The microwaves, we do the same with the
A.
Q. " of the Lawton Correctional Facility?
A.
No.
It is.
10
11
Q. Okay. So those are funds that the Lawton

Correctional Facility -- that microwave has value.
12
Yeah. I understand it's a microwave. And I
13
understand there are S200televisions, Buttheydo
14
have value that adds value to the Lawton
15
16
17
Correctional Facility as an asset for GEO Group,

right?
A. Right.
18
Q. Okay. So you said a whileago, ifyou can
19
20
Q. Okay. The televisions, for instance, those

are purchased, or sporting equipment that's
19
fund it from the Offender Welfare Fund, that's what
20
21
purchased through the Offender Welfare Fund, who
22
owns that -- those items once they are purchased?
21
22
23
24
25
you try to do. Butyou weren't real specific But

we're talking about microwaves, televisions,
sporting equipments. And we have established that
GEO or Lawton Correctional Facility actually owns
those and enjoys any value that those items add to
the Lawton Correctional Facility asset?
23
A. They are provided to the offenders. They
24
are provided to the inmates for them to recreate,
25
for them to watch TV.
Page 59
Page 61
1
2
Q. Well, I mean who owns the television? Who

owns that item? Do the inmates own it or does GEO
A Enjoy.
I
Q. That the GEO Corporation ifthere's any
3
4
value from a television, if thJ television was sold

for $100, GEO gets that $10(j. GEO gets the value of
own itor does Warden Berg own it? Who owns the
4
5
television to this purchase?

MR, POPE: Object to the form, it's been
asked and answered.
MR. lEATHERWOOO: I don't think it has been
answered yet. Who owns it hasn't been answered yet.
BYMR. lEATHERWOOD:
10
Q. Who owns the equipment or items that are
11
12
13
14
15
16
purchasedwith funds through the -A. Idon'i think nobody owns the equipment
because it's being used by the offenders, by the
inmates. Televisions are being used by the inmates.
They are in Lawton Correctional property.
Q. So the lawton Correctional Facility owns
17
Ihem?
18
19
20
21
A. You know, ifthat's what you want (0 call

IL call it.
that item that's paid for through the OHender

Welfare Fund?
A. Ithink the offendersget the valueof it,
notGEO. You guys arewatching it, you know. You
9
10
11
guys are playing cards. It's provided back to the

population. That's how I understand it.
Q. Are the ice machines paid for by the
12
Offender Welfare Fund?
13
14
Q. You don't know. Okay. What I'm trying to
I don't know.
15
get at. Mr, Rios, is -- I'll try to simplifyit a
16
17
little bit. Are the funds that are deposited in the

Offender Welfare Fund used to cover expenses that
18
the Lawton Correctional Facility would have
19
othenAtise? If there was no Offender Welfare Fund,
Q. Okay. I guess what I'm -
20
would there not be any microwaves?
A. I know that whenever that television is
21
I believe there would be microwaves.
22
Q.
If there wasn't an Offender Welfare Fund,
22
23
broken, it's thrownawayto the trash because it's

not repairable. You go and buy another one and put
24
it up.
25
5
6
Q. Right. Right.
23
would there be basketballs?
24
A It's a program. Absolutely.
25
Q.
And if there wasn't an Offender Welfare
Plumbtree Reporting
(405)620-6272 - plumbtreereportinggniail.com - www.plumbtreereporting.cofii

Hector Rios
May 12j 2016
17 (Pages 62 to 65)
Page 62
Fund, would therebe televisions foreveryone to
watch?
Page 64
guys.
A. I believe so.
2
3
Q. What I'mgettirtg at is if you said that

yeah,you would have microwaves anyways if there
Q. Okay. So those expenses that you are
wasn't an Offender Welfare Fund if the Lawton
paying for out of the Offender Welfare Fund,the
5
6
7
Correctional Facility was not making a 12 percent

commission, you would have to buy that microwave out
of your money.
Lawton Correctional Facility gets value through
that?
A.
Q. Through that 12 percent?
16
Yes.
A. (Witness nods head]
11
12
Q. Okay. So would youalsoagree then the

Lawton Correctional Facility has a vestedinterest
13
14
15
inthe price of commissaTy so that12percent

commission isas high as it can possibly be?
MR. POPE; Iwould objectto the form of
16
the question.
17
18
19
20
21
22
THE WITNESS: Because Idon'tthink they

do. Idon't. Ireally don't think that it'sabout
the profit. You are coming out here about the
profit. It doesn't matter inmy professional

opinion. That money is being used going back to the
population.
MR. POPE: Mr. tealherwood, this is not an
9
10
argument to debate. We have had the deposition

here. Ifyou have questions to ask, ask. Otherwise
11
let's move on.
12
13
MR. LEATHERWOOD: I agree with(hat Iwas

tryingto
14
MR. POPE: Thank you.
15
16
MR. LEATHERWOOD: -- get mypoint-MR. POPE: Okay,
17
MR. LEATHERWOOD: -.that otherwise --
18
19
20
MR. POPE: And that's the whole thing.

You're tryingto make a point and that's not what
this deposition is for.
21
MR. LEATHERWOOD: Np problem.
22
23
MR. POPE: Thank you.

MR. LEATHERWOOD: No problem.
23
If we give everybody like inSeptember, we give
24
a pint of ice cream. Where did that come from? It
24
25
comes from the Inmate Welfare.
25
BY MR. LEATHERWOOD:
Q. You earlier said that access to the
Page 63
1
2
3
4
5
On4th ol July, we put chicken on the tray.

Where doesthat come from? Itcomes from, you know,
the Inmate Welfare. It's going back intothe
offenders. I'm not benefiting byit. The only
benefit Iget isIhey - they are out there, they
are recreating. Give them programs. If il benefits
7
8
9
Page 65
1
commissary is a privilege and not a right Andwhen
Iasked youabout that there was an objection and
you didn't expand on that Could the Lavrton
them, go for it.
4
5
6
7
Correctional Facility simply choose not to offer

commissary to the medium-security inmates that are
assigned here?
A. They can.
BYMR. LEATHERWOOD:
Q. The answer isyes, that you couldsimply
9
10
just choose not to have any commissary service?

A. We can limit it absolutely.
11
12
Q. But could youjust choose not to haveany?

Justdon't do it We're just pot going to do it
13
14
15
MR. POPE: He's answered the question three

times already. I
MR. LEATHERWOOD; No, he said they could
Q.
So
lo
A. But youmake itseem like we're trying to
11
make up money. It's going back to the population,
12
That's the way I see it. And I'll continue to see
13
14
it that way becauseit's benefitting you. It's

benefitting the visitors whenthey come in here and
15
have theii families.
16
Buying some books for them. Absolutely. Buying
16
limit it.
17
some books so the father can read to the son if he's
17
BY MR, LEATHERWOOD:
18
19
20
21
22
23
there. That's what benefitting them. They want to

playcards, let them playcards. It's
benefitting - it's going back into the population.
That's the way I see it.
Q. Okay.
A. So I'mgetting confused here with this
18
19
not have it at all? Can they.choose not to have a
20
commissary service at all? ,
24
25
because you aresaying that I'm making a profit.

I'm rwtmalting a penny. It's going back to you
Q. I'm asking -- the question is.is can they
21
MR, POPE: And he said they can,
23
24
they could limit rt I apologize,

I don't have a copy of this to enter in to --
25
well, I do.
22
MR. LEATHERWOOD:' Ithought he said that
Plumbtree Reporting

Hector Rios
May 12^ 2016
18 (Pages 66 to 69)
j
Page 68
Page 66
1
BY MR. LEATHERWOOD:
Q.
But Section S.12 of the contract that the
Corrections?
Lawton Correctional Facility has with Oklahoma

Department of Corrections, it specifically says that
the contractor, which is Lawton Correctional
6
7
Facility, will providea commissary for offenders

that contain items similar to department's
facilities.
6
7
8
Based on the language of that sentence, the
Yes.
Q. Okay. And you dont know how much that

item sells for at the Oklahoma Department of
3
4
A.
2
3
A.
No.
Q. Okay. Ifyou knew that the price of the

identical Ramen noodle soup at the Lawton
Correctional Facility was more than 100 percent more
than the Identical item at the Oklahoma Department
10
contractor will provide, do you -- would you
10
of Corrections, would you believe that's reasonable?
11
interpret that as being that you could just choose
11
A. No.
12
not to have one? Or that the contract mandates it?
12
Q. Would you believe it's comparable?
13
A.
14
Q. That's all. Areyou familiar with that
The contract mandates them.
'
13
A. No.
14
Q. Okay. Are you aware that Keefe has what
15
would be called private-label products or house
16
17
A. I have read my --1 have read the contract.

Q. Okay. In section -- in that section,
16
products? Like their Keefe coffee is their brand.
18
Section 5.12 of the contract, where it says that the
18
19
26
Q. Okay, And are you aware that Keefe sells

their private-label products to the Oklahoma
Department of Corrections, as well as they sell them
here directly to the inmates?
15
section of the contract, Mr, Rios?
19
price shall be comparable to those set bythe
20
department Some of the other documents that you
17
21
have looked at also state that it should be
21
22
comparable.
22
23
24
Doyou currentlythink that the pricing of the

commissary items at Lawton Correctional Facility are
25
comparable to the pricing of the itemsat the
23
24
25
A.
Yes.
A. Yes, I've heard that.
Q. Okay. And right now I understand that you

stated that you don't know this. But would you be
surprised to learn that the private-label products
Page 67
1
Department of Corrections?
Page 69
1
that Keefe sells to medium-security inmates at DOC
A. And again I willanswer the same thing that
are significantly lower than the price of the same
3
4
private-label product at LaviônCorrectional

Facility?
5
6
7
8
9
10
11
I have answered already. I have not seen any of

DOC'S commissary list.
Q. Okay. I'll have to wait until we get
there. I'vegot that for you later,
Are you aware generally that there is a
difference, and maybe even significant difference in
the price between the commissary offered at the
Oklahoma Department of Correctionsand the
commissary items offered at lawton Correctional
12
Facility?
13
A. I believe I alreadyanswered that.
14
Q. You
15
A. I have not seen the list of the Department
16
of Corrections.
17
Q. Have you been told by anyone, inmates, that

they believethat there is a difference in pricing?
18
19
20
21
22
A.
I have heard it.
Q. You've heard that? Did you investigate it

when you heard it?
A.
I did not.
A.
I don't know that.
6
7
8
9
Q. Okay. Okay, The commissary at Lawton

Correctional Facility sells a 3-ounce Maruchan brand
Ramen soup. It's M-a-r-u-c-ih-a-n. I don't know if
I'm pronouncing that correctly, but that's the
10
11
12
13
noodle soup to the inmates at Lawton Correctional

Facility for 60 cents
The identical Maruchan brand Ramen noodle soup
14
15
16
is provided to the Oklahoma Department of

Corrections by Keefe for 21 cents. The Oklahoma
Department of Corrections marks that up to 27 cents
17
and sells that to the inmate.
brand. And they sell that Maruchan brand Ramen
18
So the inmates at Oklahoma Department of
19
Corrections are purchasing that product for 27
20
21
cents, including the markupifrom DOC. The

medium-security inmates at Lawton Correctional
22
Facility pay 60 cents for the identical product.
23
It's more than a 100 percent difference,
23
24
Q. Doyou know--do you knowwhat a Ramen

soup is? A Ramen noodle soup. Do you knowwhat
24
Does that worry you? Does that bother you?
25
that item is?
25
A.
I didn't know it was that much.
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Hector Rios
May 12, 2016
19 (Pages 70 to 73)
Page 70
Page 72
Q.
Are you aware that the price of commissary items
at Lawton Correctional Facility were increased again
on April 18, 2016?
Lawton. then does that make a difference, then I
would direct him to answerthe question regarding
5
6
7
8
9
A.
I appreciate that answer. Mr. Rios.
I'm aware of that.
Q. Vou're awareof that. And did you approve

that?
A. Ves, we approved it. And there was
something that was put out by Warden Berg, whether
assumption. We just
MR. POPE; If you are offering it as a
hypothetical that if prices are higher at DOC versus
that.
BY MIt LEATHERWOOD;
Q. Then if the fact the pricesof commissary

itemsat the Lawton Correctional Facility are higher
le
it was on the informational channel, that there was
le
than the identical or similar items offered at the
11
some items, not all, some items. I think it was five
11
12
12
security objective?
13
cents, 10 cents on some candy bars, to put that

announcement to the population through information
Department of Corrections, would that sen/e any
14
chartnel.
15
19
Q. Okay. Vou stated earlierthat you think

that the inmates -- medium-security inmates at
Lawton Correctional Facility should be treated equal
to medium-security inmates at state yards, state
facilities. And you agree that that would also
26
apply to commissary services?
20
21
A. I would agree with that.
21
not seen the other prices.
Q. Okay. Are you familiar with the equal
22
BY MR LEATHERWOOD.
16
17
18
22
13
MR. LEATHERWOOD; Is that-
14
MR. POPE; All right
understand that if that's the correct price, 27
18
comparing to what we sell them, that is a concern.
19
That is a concern.
protection clause of the 14th Amendment of the
23
24
United States Constitution?
24
A.
No, I'm not. I mean I have to read it.
were extremely, extremely high. The Ramen noodles I
17
23
25
THE WfTNESS: You know, it can. Ifthey
15
16
25
V.
On the other items, like I said again. I have
Q. Right t understand that
A. So I -- you mentioned the Ramen noodle, 27

comparing to it. That is high. I don't know the
Page 71
1
2
3
But right now I'm not.
Q, Okay- Do you agree that it applies to

innâtes in prison?
Page 73
2
other prices. But it can cause a problem.

Q. Having them priced too high could cause
a -
A. Yes.
5
6
MR. POPE: Iwould object to the question.

First off, it'scalling for a legal conclusion,
A.
Q.
Absolutely.
" disruption to your facility?
A.
Yes, it can.
8
9
which he has no abilityto answer.
Okay. What I'm asking, though, is does the

pricing - wouldyou price an item higher based on
any kind of security issue? Would you say, "Hey, if
Two, he'salready indicated he's not familiar

with it
10
BY MR. LEATHERWOOD.
11
12
13
Q. I'm surprised that you weren't aware ofthe

difference in price of that one product, lam
surprised by that so I'm glad that that's come
13
14
clear.
14
15
10
Letme ask you, does the higher price of
11
12
15
Q.
we price this higher, the facility will be safer"?

Is the pricing related to security at alf?
A. I think anything can be related to
security. The pricings, ifthey are extremely high,
they can cause an issue in the facility. So yes.
Q. Okay. So rather if the pricing is high,
rather than enhancing security, it could actually
have a negative effect on security?
16
commissary items at Lawton Correctional Facility
16
17
18
versus the price of similar and identical commissary

itemsat Department of Corrections serve any
17
19
security objective?
19
20
21
MR. POPE; Iwould object to that question.

It makes a presumption that the prices at Lawton
20
21
22
23
Correctional Facility are higher thanthe DOC

prices. And Idon't see the relevance ofsecurity
price it higher to help rehabilitate these
22
offenders?
24
25
issues regarding that.

MR. LEATHERWOOD; Well, it doesn't make an
18
23
24
25
A.
Yes.
Q. Okay. Does the pricing of commissary items

serve any rehabilitative objective? Meaning do we
A.
No.
Q. Okay. And if the price of commissary items

at Lawton Correctional Facility is higher than the
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Hector Rlos
May 12t 2016
20 (Pages 74 to 77)
Page 74
1
2
3
4
price of similarar>d identical items at the

Department of Corrections,would that be to serve
any penological objective?
A.
No.
5
6
Q. Does the Oklahoma Departmentof Corrections

receive any moneyfrom the sale of commissary items
at Lawton Correctional Facility?
A.
I don't know.
Page 76
1
2
3
4
5
6
Q. What do you mean alcohol that you were

Tinding? What-A. Home brew. We were finding a lot of home
brew made out a hon^ bun.
Q. Okay.
A. And everything that had sugar, we decided
to remove. I believe some of these items has come
back to the list if I'm no: mistaken.
9
10
11
Q. Doyou know who would knowthat?

A. Mr. Berg would probably be Q. Okay.
10
11
A. Yes.
12
A.
12
Q. Or under your direction as a security
the one to ask.
13
14
15
16
17
Q. Is the priceof commissary itemsat the

Lawton Correctional Facility strictly a business
matter? So that Keefe can make profit?
MR. POPE: Iwould object to the form of
the question. Ithinkthat's speculative.
13
18
THE WITNESS: Yeah, it's like wow.
18
19
MR. POPE: The definition of business
19
14
15
16
17
Q. Theywere removed under" withyour

authorization?
basis?
A. Right.
Q.
8ut now some of them have come back. Are
they no longer a security issue?

A.
I believe the oatmeal was the one that came
back if I'm not mistaken.

a
'
Okay.
26
matter other than Keefe making a profit
20
A. I believe.
21
BV MR. LEATHERWOOD:
21
Q. One of the items that's on this list that
22
23
Q. Okay. It's not--well, we've established

it's not related to security. Actually you said it
24
25
could be a security problemif it was too high. Was

two toy?
22
23
24
25
'
was removed was the Kellogg's Frosted Flakecereal.

Do you know why that was removed?
A. Agaia we found that sonê of these items
were being found on the home brew that was being
Page 75
Page 77
A. Absolutely. But--
found.
Q. On or about November 16, 2015. a number of
items that had been offered on the commissary menu
2
3
Q. Okay. Let me ask you a question about

that. Becausethis --1 don't have any idea.
for several years were removed from the menu. Are
Inmates make home brew using these items and that's
you familiar with that?
an intoxicant?
7
8
9
A.
I am familiar with that.
Q. Okay. And I'mgoing to enter this as

Exhibit Number S. So there's one for you, Mr. Rios.
These items that were removed, do you know who
10
directed them to be removed? Was it a issue? Was
11
it someone at Lawton Correctional Facility that
12
directed them to be removed?
A.
'
That is correct.
Q. Okay. And when you discover the inmates
that are dolr>g that are those inmates subject to
discipline that are the ones misusing the products?
10
11
A. Yes. they are.

Q. Okay. But and they are subject to
18
decided to move due to the alcohol that we were
12
13
14
15
16
17
18
19
finding. I know for a fact a big issue was the
19
20
honey bun.
20
21
A. Because we were finding it in homemade

Q. Okay.
A. So that was mydecision. Whenwe reviewed
22
A. -- brew, intoxicants.
the commissary item, we made the decision to remove

some of these items that were causing the alcohol
that we were finding.
23
Q. Okay. Butthen on the:2015 Oklahoma
24
25
holiday package, the identical Frosted Flakes item

was sold again. Was it a security issue on the
13
A. The recommendation came from Keefe for the
14
simple reason that some of these items were not
15
being - were not selling.
16
17
21
22
23
24
25
Let me lake that back. These are some of the
items that had a lot of sugar on them that we
Q. Okay. So that was
discipline, but then all the other inmates are then

deprived of those items because of the actions of
those (ew that are violating the policies or A. Yeah, for the orderly running of the
facility, we made a decision to remove them.
Q. Okay. The Frosted Flakes, that's one of
the items that you removed because of a security
issue?
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Hector Rios
May 12j 2916
21 (Pages 78 to 81)
Page 78
Page 80
holiday package? Or is it only an issue when it was
sold
A. You know. 1don't agree with those
Q. Okay. Section 7 of ICF030120 is titled The

Property Matrix. Are you -MR. POPE: What page are you on?
packages. That's something that is from DOC. 1
MR. lEATHERWOOD: That's Page Number 5,
really did not have a say-so on that one.
MR. POPE: Okay.
Q. When -- you said that's from DOC?
A. 1disagree with the Christmas packages that
8
9
you guys get. 1really do. As a matter of fact 1

didn't give them in June.
10
Q.
11
A. 1disagree with all those -- all the amount
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Uh-huh.
Q. I'm talking about the holiday package menu
that Keefe allows inmates to buy. Not -- I'm not

talking about that free little bag of stuff.
Q. Areyou familiar with that section of the
policy?
A.
10
of items that the Christmas packages directed by DOC

are allowed. If that was the package that corn
flakes or Frosted Flakes came into in that package,
that was out of my control.
BY MR. lEATHERWOOD:
11
12
13
14
15
'
Yes.
Q. And Section 7(a) is titl^ Allowable

Property. Are you familiar wijhthat?
A.
Yes.
Q. Okay. I'm going to read the first

paragraph of ICF030120. Section 7(a). It says, 'The
warden will abide by the property matrix as listed
17
on the maximum allowable pioperty Attachment B

attached and maximum allowable clothing male
16
18
Attachment C, which authorize and limit items both
No. no, no, no. no, no. That's the one I'm
19
talking about
Q. Okay. So the Department of Corrections
directs you --
20
personal and state issued an offender may possess."

Areyou familiar with that?'
A. Right. Twice a year.

Q. To allow Keefe to sell that holiday
package?
23
Q. Okay. Attachment B is titled Maximum

Allowable Property, which is the Oklahoma Department
24
of Corrections Policy 030120,|Attachment B. Is that
25
correct?
A.
21
22
A.
Yes.
Page 81
Page 79
1
A. Right.
A.
Q.
Q. Okay. And Attachment C is titled Maximum
3
4
Allowable Clothing is the Oklahoma Department of

Corrections'Policy 030120,Attachnwnt C. Is that
correct?
3
4
5
But the DOC doesn't have a contract with
Keefe or anything, right?

A. They allow that package. It's -- we get it
once a -- twice a year 1believe is what it is.
That is correct.
Q. Okay. Exhibit Number 6 is the GEO property

policy.
MR. LEATHERWOOD; Mr. Rios, that's 3 copy
incorporates the Oklahoma Department of Corrections'
for you. And Mr. Pope.
Policy 030120.Attachments Band C. That's correct?
6
7
le
11
12
BYMR.LEATHERWOOD:
Q. You are familiar with the policy which is
LCF030120 titied Offender Property, is that correct?
13
A.
14
Q. Now on June 7, 2013, you approved
15
Yes, sir.
LCF030120, is that correct?
A. Thai's correct
Q. Okay. Just so that I'mclear, LCF030120
10
A.
11
Q. Okay. In the beginning of LCF030120, it
Yes-
12
states that the warden will abide by the property
13
matrix as listed on Attachments B and C. Is the
14
Lawton Correctional Facility in compliance with
15
Attachments 6 and C?
16
A.
17
Q. Okay. DOC030120, Attachment B. which B
19
Q. And when you approved it what does that

mean? What does that imply that you approved rt?
A. That 1agree with the policy that we have
19
nîum-security facilities are permitted one
20
in place.
20
electric razor or beard trimmer. And the electric
21
Q. Okay, And you familiarized yourself with

the policy before you authorized it then, warden?
21
razor or beard trimmers is available by canteen
22
purchase or catalog purchase.

Are inmates at Lawton Correctional Facility
16
17
18
22
A.
That's correct.
18
23
1 believe we are.
attached to LCF030120. the matrix indicates that at
23
A.
24
Q. You would agree to that?
24
permitted to purchase an electricrazor or beard
25
A.
25
trimmer from commissary?
Yes.
1 review it.
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Hector Rios
May 12, 2016
22 (Pages 82 to 85)
L.
Page 84
Page 82
1
A.
They were removed.
Q.
They are rot allowed to be purchased?
inmates at medium-security facilities are permitted

one ice bucket which is to be no larger than a
six-can container and hard plastic Igloo type. And
A.
No,
Okay. Oo you know why?
that the ice bucket is available by canteen purchase
A.
It became a security concern. Again,
only.
Are the inmates at Lawton Correctional Facility
offenders were -- inmates were using those for

tattooing. Using the motor for tattooing. Using
the edge of the clipper to cut metal. So we decided
to remove them.
le
6
7
permitted to purchase hard plastic Igloo-type Ice
buckets from the commissary?

A. No, they are not.
Q. Can you expand on that and tell me why?
Q. Beforeyou removed them, did you get
10
A. Again, we replaced those with a clear,
11
authorization from the Oklahoma Department of
11
12
Corrections?
12
large -- we were finding a lot of phones, a lot of
weapons inside those ice bijckets or ice -- six-pack
13
A. No, I did not,
13
14
Q. And you said that they became a security
14
ice chests, small ice chests. Therefore we made a
15
issue. Are they a security issue only at the Lawton
15
decision to remove them,
16
Correctional Facility? Or are they not security
16
17
17
18
issues at the medium-security Department facilities?

MR. POPE: I would object to the question.
18
just a minute? I need to visitwith the warden
19
1think that calls for speculation.
19
outside.
20
Answer it Ifyou can. warden.
22
in other facilities. Therefore I cannot answer
23
24
25
MR. POPE: Could I call a halt here for
THE WITNESS; All right
26
THE WITNESS: I don't know what's going on
21
Q. Okay.
(OFF THE RECORD)
21
22
BY MR. LEATHERWOOD;
thaL
23
BY MR. LEATHERWOOD;
24
Q. Back on the record ri ady to go. I was

asking you about the ice bi ckets that are permitted
25
on the property matrix tha^ - the Oklahoma
Q.
What--
Page 85
Page 83
1
2
A. I knew it caused a security problem here.

Q. Okay.
Department of Corrections' property matrix. And you
2
3
stated that you had to remove those because of a

security issue.
A. We were finding a lot of weapons. A lot of
4
5
weapons. We were finding out we're finding a lot

of tattooing going on. And we found they were
A.
Q. Okay. And I asked you, did you obtain
coming from these clippers,so we decided to remove
authorization from the Oklahoma Department of
them.
7
8
9
Corrections before you denied inmates access to that

item?
I
A. In one way or another, 1they know.
8
9
10
11
Q. Okay. And so similar to with the

commissary, some inmates were misusing these items
and that resulted in all inmates losing that right
or that privilege to have that item? Not just the
12
ones thai were misusing them?
13
14
15
16
17
18
A.
That is correct.
Q. Okay. But earlier you said that inmates

should be treatment equally. And the inmates that
aren't misusing them, do you think that they should
lose that right?
A. I made a decision to remove the clippers.
Yes-
10
I " either with the contract monitor or the audits
11
12
they come in here and do. Or my-- just a casual

conversation with my immediate supervisor or
13
Mr. Williams. I'm sure it was discussed the reason
14
that these were removed. Okay?
15
16
Okay. All right. And DOC030120,
Attachment B, is attached to ICF030120. The rriatrix
17
indicates that inmates at medium-security facilities
18
are permitted one radio or cjock radio. The policy
19
20
21
Q. Okay. But you agree that they are allowed

on the Oklahoma Department of Corrections' policy
which is attached to the LCF policy which you
19
indicates that the radio or clock radio is available
20
bycanteen purchase or catalog purchase.
22
authorized?
22
permitted to purchasethe little radiosfrom
23
canteen?
23
A.
24
Q. Okay. The DOC030120. Attachment B. which
25
Ves.
is attached to ICF030120. the matrix indicates that
21
24
A.
25
Q. Those items haven't been removed just
Yes.
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Hector Rios
May 12, 2016
23 (Pages 86 to 89)
Page 86
1
2
3
4
5
6
recently?
A. Idon't knowifthey have or not.

a Okay.
A. Whenyou say recently?
MR. POPE: What page is that on?
MR. LEATHERWOOO: Of the policy?
MR. POPE; Uh-huh. Ifound it Page5 of
Page 88
1
inmates at medium-security facilities are permitted
five personal jeans and that the jeans are available
3
4
5
by canteen purchase or catalog purchase.

Are inmates at Lawton Cofreaional Facility
permitted to purchase personal jeans from the
canteen, from the commissary?
18
11
a couple of weeks ago had that item removed. And
12
13
I've been told, but I can't confirm it either. I

don't know, but I've been told that that item was
8
9
10
11
12
13
14
removed. It's not on the menu. I know that. But
14
15
I've also been told that it was remc>ved from being
16
sold and that it was at Warden Collins' direction.
17
18
Idon't knowthai. That'sjust what I'vebeen told,

so Idon't know. Ithought maybe you would know
19
more about that.
15
16
17
18
19
the exhibit-
BVMR. LEATHERWOOO:
26
Q. The new property menu that was put out just
A. No,they are noL

Q. Again, can you " do you know why not?
A. Again, it's a security issue. This was
maybe overlooked on my part but we do not allow
jeans in this facility.
Q. Okay.
A. We provide you with a uniform.
Q. Okay. But being security --
A. I'm not going to get into detail with you

in reference to the security of this particular area
here. I'm not. I'm not going;to allow inmates of
Lawton Correctional Facilityto wear jeans.
Q. Okay. When a medium-security inmate is
20
laterallytransferred from an Oklahoma Department of
21
Corrections' facility, and that.inmate has jeans in
inmatK at medium-security facilities are permitted

one reading light, and that the reading light is
22
23
24
his possession (hat he was able to purchase per the

policy, and he arrives at Lawton Correctional
Facility, what happens to Uie ttems that he had
available by canteen purchase only.
25
purchased?
A.
I'm not aware o( it.
21
22
Q. And the DOC030120, Attachment B, which is

attached to LCF030120, the matrix indicates that
23
24
25
Page 89
Page 87
1
2
3
4
pay to be mailed home,
Q. Okay. Didyou get ar authorization from

the Oklahoma Department of Con-ectionsto prohibit
personal jeans at Lawton Correctional Facility?
because that item was also removed from the most
recent property menu that's been distributed by
Keefe.
8
9
A. And it was brought to my attention

yesterday when I was making rounds,
Q. Okay. So you're awareof it but right now

h's not on the menu, but you are aware of it?
A. They can be mailed home on his -- he can
3
4
5
16
11
9
16
A. I believe (hat this has.been in place even
before l got here.

Q. Okay.
A. Okay? Again, we must have overlookedthis

section of the policy by not removingthis.
11
Q. You overlooked the section of the LCF
12
A. Yesterday when Iwasmaking round, I had an
12
policy when yousigned it? That's whatyou are
13
offender or an inmate mention it to me in reference
13
referring to?
14
to that.
14
A.
15
Q. Okay,
15
16
17
18
19
26
21
22
V-.

permitted to purchase a reading light from canteen?
A. Yes, they are.
Q. Okay. The reason I'm asking that is
Q. Okay. But that's not an item that you had

personally directed them-
No.
17
Q.
-- to have removed? Someone else on your
18
19
staff had done that?
A.
I'm not aware of it. This --
Q. You we don't know right now. Voudont

know?
23
A.
24
Q. Okay. CX)C030120, Attachment C, whichis
25
16
A.
Yes.
attached to LCF030'120, the matrix indicates that
Yeah.
A. Because you cannot F'Urchase five shins,

five pants.
Q. Okay. And that was just an oversight.
The policy, the attachment to DOC030120, at the
20
endofthe policy, at the endof that attachment it
21
22
states that all clothing items purchased through the

canteen or through retail purchase will be
23
transferred with the offender.
24
25
Doyou have anyideawhy that's included inthe

DOC policy? What their intent what OOC's
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Hector Rios
May 12i 2016
24 (Pages 90 to 93)
Page 92
Page 90
1
Intentions is in having that in the policy?
A.
I don't.
Q. Okay. The commissary menu at Lawton
Correctional Facility offers standard common sodas
6
7
Q.
milk.
Whole -- milk. Yeah like a bottle of
A. No. You know, if we re goirtg to sell
milk I can't -- we don't sell it here. Anywhere
such as Coke, Or. Pepper, whatever. These sodas are
that I've been as a warden Kave we sold milk. So --
only sold in cans at the LawtonCorrectional

Facility. Is that correct?
Q. Uh-huh,
A. " no. And I don't believe they were
8
9
10
selling it when I got here. So no.

Q. Okay. And you weren't aware that you can
buy whole milk at the Deparlment of Corrections'
resealable bottles and not cans. Do you know why

there's a difference? Why they sell bottles and you
11
facilities
12
A.
13
sells cans?
13
Q. " for your cereal or for drinking?
14
15
A. Again, that was a security issue. And I

decided to move (he bottles and bring in the cans.
15
Q. Okay,
A.
I am not aware of that.
16
Q. Okay. Do you know why DOC sells bottles
16
A.
Powder milk? Yes. Butwholemilk.no.
A.
That is correct.
9
10
Q. Okay. And these same sodas at Oepartment

of Corrections' facilities are sold in plastic
11
12
17
17
and not cans?
18
19
A.
14
I don't.
Q. Could it " if it was--if the purpose of
20
21
that was that the cans are considered to be security

risks over there because they can be turned into
22
sharp instruments and metal instruments and they are
I'm not aware.
Q. Okay. Can inmates at Lawton Correctional
18
Facility purchase cranberry juice?
19
20
A. I don't recall. I don't know if they if

we have juice on the commissary.
21
Q. Okay. And also grapefruitJuice. The
23
heavy and can be used as weapons kind of like almost
22
23
Lawton Correctional Facility does not sell

grapefruit juice, do they?
24
a club, would you see (hat being a reasonable reason
24
A.
25
why they sell the plastic resealable bottles instead
25
Q. Okay. Butthe inmates at medium-security
No. No.
Page 93
Page 91
1
of the cans?
A. Vou know, again to answer your question, we
2
3
Q. Okay.
A. For security reasons.
Q. Can inmates at Lawton Correctional Facility
5
6
to purchase grapefruitjuice and cranberryJuice?

A. Right. I didn't know that.
Q. Okay. Frozen foods. Can the inmates at
Lavrton Correctional Facility purchase frozen foods
such as sausage and biscuits, burritos, pizzas,
chimichangas, or hot wings from the commissary?
4
5
purchase bottled water on commissary like the
inmates at the Department of Corrections can?

A. No, (hey cannot.
A.
Q. Do you know why they cannot?
9
10
Q. Okay. And again, that would be a security
le
No.
A. We don't - Ido -- yjsu know, Idon't know

why. Ijust don't know why,
11
issue?
11
12
12
Q. Butit's not because of a security issue?
13
A. No, it's not because of a security issue.

Q. Okay.
15
A. Nothing in bottles
Q. Nothing in bottles. Okay. Were you aware
that inmates, medium-security inmates at Department
of Corrections' facilities can purchase Aquafina
15
16
bottled water in the bottles?
16
tell me I have to get freezers and alt that. So the
13
14
v..
Department of Correction facilities do -- are able
removed all the bottles in the canteen.
14
A. Maybe it is -- you know, commonsense will
17
A.
I was not aware.
17
answer is no. The storage. So --
18
Q.
You are not aware of that. Can the inmates
18
Butanyway, going back to your question, no.

It's not a security issue and we don't sell it.
19
at Lawton Correctional Facility purchase whole milk
19
20
from the commissary?
20
Q. Okay. And you weren'taware that offenders
21
at the medium-security De jartment of Correction
Q. Okay.
22
facilities can purchase thos
23
A.
No.
21
A.
22
No.
23
A.
24
Q. Do you know why not?
24
Q.
You didn't no that?
25
A.
25
A.
I was not aware.
Not that I'm aware of.

Whole milk?
! items?
Plumbtree Reporting

Hector Rios
Nay 12, 2016
25 (Pages 94 to 97)
Page 94
1
2
3
4
5
6
7
8
9
10
11
Q. Okay. Nowthat you are aware, are you

surprised by that?
A. Nothing surprises me-Q. Nothing surprises -A. " with the Oklahoma Department of
Corrections to be honest with you.

a Okay.
A. Okay?
Q. Okay. Are you aware that the Joseph Harp
Correctional commissary has 18 items listed on their
commissary items under frozen food menu?
Page 96
1
2
A commissaiy list
Q. Are you aware that the Joseph Harp
Correctional Center has 11 items listed on there
commissary menu under refrigerated foods?
A.
No.
Q.
Okay.
I'm not aware of it.
Q. Okay. I'll enter this as Exhibit 7.
MR. LEATHERWOOD; I only have one copy
10
unfortunately. But it's all--we'll just have
11
to - I guess you guys can share.
12
A.
No, I'm not aware.
12
BY MR. LEATHERWOOD:
13
Q.
16 items. Can inmates at lawton
13
14
15
16
17
Q. This is the commissary menu from the Joseph

Harp Correctional Center, okay? I received this
from the Oklahoma Depaitnient of Corrections with an
Open Records request. And so I'm whether it's
accurate or not is only depending on what they
14
15
16
Correctional Facility purchase meat items such as

bologna, beef franks, bacon, deli ham, smoked
sausage, or chicken breasts from the commissary?
17
A.
18
Q. Doyou knowwhynot?
18
provided to me. Andthis has all the items that are
19
A.
19
available to the medium-security vendors over there.
20
21
I was going to show you this on Page 12 where it

talks about the soups that we talked about earlier.
20
21
No.
I don't.
Q. Are those items not sold on a security

basis?
22
A.
22
That is the identical soup that is on the Lawton
23
Q. No. And are you aware or if Itold you
23
Correctional Facility menu for 60 cents is the one
24
25
that they are available to inmates at the Oklahoma

Department of Corrections, again you wouldn't be
24
that's listed right there.
No.
25
A. Okay.
Page 97
Page 95
1
2
3
4
5
6
7
8
9
10
V.
surprised because they're -A. You know, no. I don't know why they have
Q. All of those are same soups. Not only
that but Keefe actually provides that product as I
stated earlier,to the Department of Corrections.

They provide it to them for 21 cents. They have
some markup on it. Keefe sells that identical
product over here for 60 cents.
them in other facilities. Iguess, you know, I-Q. With that knowledge, with knowing that,
that they are available, and your earlier statements
about inmates should be being treated equally,do
you believe that inmates here should be able to
purchase those items, frozen food items?
A. In my professional opinion, no. I mean
I " maybe that's how Iwas -- you know, 25 years in
10
11
the Bureau of Prisons, TVs, all that we didn't
11
12
agree. You know that's maybe the mentality that I
12
has been properly authenticated. And the warden has
13
have.
13
already testified that he has not seen it before.
14
15
16
17
But Idon't agree - everybody should be treated

equally. Iagree with that 110 percent. There's
some things that you put in place for reasons. Ido
think that this will probably create more of an
14
With the assumption that ttvs is what you received
15
16
from Open Records Act I don't know that he can

testify as lo anything on the document itself other
17
than to note that that's what the document says.
18
issue to have all these items sold due to storage,
18
19
due to sanitation, due to, you know, insects and
19
MR. LEATHERWOOD. I agree with that Yeah,

that's I agree with that.
20
whatnot in my professional opinion.
20
BY MR. LEATHERWOOD;
21
22
23
Q. Okay. Can inmates at Lawton Correctional

Facility purchase Philadelphia cream cheese from
commissary?
21
24
A.
No, I don't believe it's in the --
25
Q. Okay.
Knowing that and if this isi in
fact reliable,
is that something that you c in

> - that you would
correct?
MR. POPE: Let me see that.
Just for the record, I don't think this document
Q. If in fact it is authentit, assuming for
22
our purposes here that it is authentic, as
23
Exhibit 8, this is the current .awton Correctional

Facility commissary menu.
24
25
MR. LEATHERWOOD: I have got a copy for
Plumbtree Reporting

Hector Rios
May 12, 2016
26 (Pages,98 to 101)
Page 98
Page lee
L.
that for Mr. Pope.
it. I will consider it.
THE WITNESS: All right.
MR. POPE: Let me see that.
Q. And again considering the authenticity of

that document if it's correct,and you learn that a
number of the identical items that are being
5
6
provided, for instance specifically by Keefe, that

are being provided to the Oklahoma Department of
4
5
7
8
9
16
11
12
13
14
15
16
17
(OFF THE RECORD)

BY MR. LEATHERWOOD:
Q.
On Exhibit 7, which is the menu here, on
the first page, about halfwaydown it lists the

Keefe 100 percent Columbian coffee, which Is Keefe's
private-label coffee. I didnt highlight- i
apologize, Mr. Rios.
A.
Yes.
Q. Again assuming the reliability of the menu,

itsellsforS3.31. The identical private-label
coffee is sold here at Lawton Correctional Facility
for$4.20. Effectively 90 cents more for the
identical product.
If that's the case. Mr. Rios. would that be
Corrections, when those items are available at the
8
9
10
11
Lawton Correctional Facility at a significantly

higher price or a price that wouldn't be considered
comparable, wilt you consider addressing that and
insuring that the offenders here are afforded equal
12
treatment related to that?
13
14
A. They will be considered.

And also for the record, in reference to the
15
16
17
frozen items, you know, going back, the prices will

be too high. I don't think they have I don't
think they have the distributor that they probably
have in ioseph Harp or whatnot- That's my
understanding on it Because I think I can
18
19
20
comparable in your opinion?

A. This is a little bit more expensive.
Q. One more question about the property that
18
19
20
remember, I can recall going back and talking about
21
we talked about Mr. Rios. We identified a number
21
these frozen items when I first came. This was
22
23
24
25
of items that are available to medium-security

offenders at the Department of Corrections, and
those items are authorized by policy. Some of those
itenv you have stated that you have prohibited. The
22
about three and a half years ago. And it was looked
23
at and I believe it was not comparable. The
24
distributor or something to ât effect that we
25
were not able to do that-
Page 101
Page 99
1
contract (hat we talked about earlier between
Oklahoma Department of Corrections and GEO
3
4
Corporation, Section S.9, which is offender

property, it states that facility policy, which
disallows department authorized offender property.
6
7
must have the approval of the department.

And you stated that on some those you have not
received --
18
11
12
13
14
15
16
A.
Uh-huh.
Q. department approval before removing

them--
A. Right.
Q. --are depriving the inmates at Lawton
A. Right.
Q. Okay. Would you consider, again assuming
Q. Okay- But the choice of having Keefe run

the commissary operations here, that's effectively
your decision, would that be correct? I mean you
could have a different distribbtor oryou could

operate the commissary youjself
A. No. That's out of my area here. That is
corporate or GEO company.
Q. Okay.
A. Nothing to do with me.
10
Q. Right. So ifGEO says you're going to use
11
Keefe, then you don't have any choice.
12
MR. LEATHERWOOD: Mr. Rios, I appreciate

your time.
THE WITNESS; All right
MR. LEATHERWOOD; Thank you very much.
Anything?
13
14
15
16
17
that Document Number 7. the Exhibit Number 7,
17
18
19
20
21
22
assuming that it's accurate and that it's authentic

and that the medium-security offenders at Department
facilities are allowed lo purchase frozen items and
refrigerated Items and meat items, knowing that and
based on your belief that inmates should be treated
18
23
24
equal, would you consider allowing those Kerns on

the commissary at lawton Correctional Facility?
23
25
A. I would really have to take a good look at
25
19
20
21
MR. POPE: Nothing fur her on that. You

need to make an election then regarding that so that
you can read and sign that
Hewill read and sign the deposition.

(DEPOSITION CONCLUDED AT 11:52 AM.)
22
24
Plumbtree Reporting
(405)620-6272 - plurnbtreereporting@gmail.eom - www.plumbtreereporting.coni

Hector Rios
Nay 12j 2016
27 (Pages 102 to 105)
'
Page 102
1, HECTOR RIOS, do hereby State under oath that
I have read the above and foregoing transcript in
2
3
Itsentirety, and that the same is a full, true, and

correct transcription of my testimony so given at
said time and place, except for the corrections
noted.
ERRATA SHEET
JURAT
WITNESS: HECTOR RIOS
DATE: May 12th, 2016
3
5
REPORTER; Steve Piumbtree. CSR, CP

NO CORREaiONS ARE NECESSARY
PAGE LINE CORREaiON
HEaOR RIOS
le
10
11
SUBSCRIBED AND SWORN TO BEFORE ME. the
11
12
undersigned Notary Public in and for the Slate oi
12
13
on this, the
14
,2016.
day of
13
14
15
15
16
Notary Public
16
17
17
My Commission Expires:
18
18
19
REPORTED BY; STEVE PLUMBTREE. CSR. CP
19
20
20
21
21
22
22
23
23
24
24
25
25
Page 105
Page 103
STATEOF OKLAHOM^ OKLAHOMA COUNTY) SS:
I, Steve Plumbtree, Certified Shorthand Reporter

within and for the State of Oklahoma, do hereby
certifythat the above-named HECTOR RIOS was by me

first duly sworn to lesti^ to the truth, the whole
truth, and nothing but the truth in the case
aforesaid;that the above and foregoing deposition

was by me taken in shorthand and thereafter
TO:
MR. DON G. POPE
Don G- Pope & Associates, P.C.

611 24th Ave SW, Suite 10^
Normaa OK 73069
FROM: STEVE PLUM8TREE. CSR. CP
5
Plumbtree Repoting
17525 Old Pond Rd
10
transcribed: that the same is true arid correct and
11
that K was taken on the 12th day of May, 2016 at

the lime of 9:25 a,m. in the City of Lawton, County
12
MEMORANDUM
CERTIFICATE
Edmond. Oklahonna 73012-6894
DATE: May 26. 2016
Please have HEaOR RIOS read your copy of his
deposition taken on May 12th, 2016 inthe
above-styled case and sign the jurat page before a
13
of Comanche, Stale of Oklahoma under the
10
14
stipulations hereinbefore set out. and that I am not
11
notarypublic. Also, make ar>y rieeded corrections on
15
attorney for or relative of any of said parties or
12
the enclosed errata sheet and not directly on tfie
16
otherwise interested in the event of said action.
13
transcript.
17
18
IN WITNESS WHEREOF, I have hereunto set my hand
and official seal this 23rd day of May, 2016^
19
You have 30 days to return the jurat page and
the correction page tothe abo\^ address, after
16
which the deposition will be sealed and forwarded to
17
20
Oklahoma Certified Shorthand Reporter
21
this matter
Certificate No. 00332
22
19
STEVE Pitfl^REE, CSR. CP
23
15
18
21
22
14
the attorney whotookthe deposition for useinthe

casewithout the juratpageor the corrections being
attached to the original deposition.
Thank you for your attention and cooperation in
20
v..
Page 104
Expires: December 31, 2016
23
24
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25
25
Plumbtree Reporting
(465)620-6272 - pluinbtreereportinggmail.com - www.plumbtreereporting.com
Agreement between Keefe Commissary Network,

L.L.C. and GEO Group, Inc. dba Lawton Correctional
Facility
AttacI1. No. 2A
KEEFE CQMMISSabv network 4.GRERMF1MT
This Agreement made and entered into as of this _>y of
2010, by
and between KEEFE COMMISSARY NETWORK, L.L.C. an affiliate ofTHE KEEFE GROUP,
("KEEFE") and GEO Group, Inc., dba Uwton Coirectional Facility, aCorrectional
INSTITUTION in the State ofOklahoma. ("INSTITUTION").
Whereas, KEEFE is in the business ofsupplying food and other related products to
inmate commissary departments ofcorrectional facilities throughout the United Statei including
INSTITUTION; and.
Whereas, the parties wish to enter into aCommis^ Nerwork Agreentent to facilitate the
ordering of commissary supplies by inmates and the payment thereof.
Now, therefore, in consideration ofthe mutual promises and conditions herein Lntained,
itis agreed between the parties:
'
PFERATrON OF COMMISSARV neTWORIC rv iNSTtTtlTTnN
INSTITUnON agrees that during the term ofthis Agreement, it will, at its expense,
provide personnel to operate the computer equipment and account for inmate welfare funds
OPERAI ION OF COMMISSARV NETWORI^ Ry KKF.FF
KEEFE agrees to:
A. Provide Services as described in Auachmcnl Cofthis agreeinenl.

B. hmpioy the persons nect'.ssary to receive and distrihuie the conimiss
ir>' orders
directly to the rNSTITUTION's inmates.
C. Obtain the fNSTITUTION Warden's written approval for any fCKKFil

employee prior to working at this INSTITUTION. KEEFE will ailov/ ihe
^n-hcrr<âhn/
IS
INSTITUTION to perform abackground check as well as eight (8) hours of

orientation training prior to KEEFE employee working unescorted on the unit
at the INSTITUTION'S cost for the background check and training, except for
the KEEFE employee's wages and benefits.
D. Comply with applicable INSTITUTEGN policy and procedures and Annerican

Correctional Association Standards for Aduli Correctional Institutions.
E. Provide aweekly report on unfilled or backordered items to the
FNSTJTUnON's Business Manager.
F. Notify te INSTITUTION'S Business Manager seven (7) days in advance in

Wilting of any proposed product price changes.
KEEFE agrees that on an as needed basis, it mil download all imiiaie orders for
missary items. KEEFE will bag. box, and ship such commissary items lo the INSTITUTION
for distribmion lo fce inmales and will bill the INSTITUTION monthly or mote frequently for all
such purchases. In addition, KEEFE will keep the computer equipment updated with complete
infonttation as lo coramissaty items available, pricing, and other terms and conditions ofsale.
Employment ofthe INSTITUTION'S innâtes in the commissaty is hased on assignmem made hy

the INSTITUTION with agreement by KEEFE. Inmates working i the con,,is,y m,.y not
access the computer or cash register, directly hand Ihe ilcm(s) sold to the inn,ate custo,
tier or
participate in record keeping.

harbwarf
Duringthe term ofthis agreement, KEEFE shall supply INSTITUTION with stjch
computerequipment and software needed to ntanage the commiss.y opet^tion. thjeven, that
institution elects to terminate the Agreement, INSTITUTION will promptly returt all
equipment ad software .0 KEEFE. KEEFE hereby grants .0 INSTITUTION aroyal ty free

license to use the KEEFE Commissaiy Network software. INSTITUTION acknowledges the
proprietary nature ofthe software d/or written software documentation and herebyagrees NOT
.0 disclose, reproduce, transferor use thesoftware and/ordocumentation for any pôse other
than those specifically allowed by the les ofthis agreetnen. without specific written
permission ofan Officer of KEEFE
PAYMRNT
KEEFE will invoice INSTITUTION for all commissaty items purchased pursuant to the
Commissary Net^vork Agreement. INSTITUTION will pay such invoices in accordance witl,
KEEFE'S standard credit tenns (NET 30 DAYS) from the Inmate Trust Accoum, Keefe is
responsible for the reponing ofany sales, fees or other taxes levied against the sales or
performance under this contract.
5-
SERVICF, FFF
institution will be paid aservice fee for the services .0 be provided by it

.0 12% (based o agreed upon pncing by the parties, ofadjusted gross sales. A,
lereunder
gross sales are gross sales less tbe sales ofnoncommissioned ,terns as determined by ijusied
institution that are listed on Exhibit A,0this Agreement. This paymentwil be fithheld
from the invoicesupplied by KEEFE on commissarysale.,. In theevent that mmate'slunds
<EEFF. and
available ,0 purcltê commissar products are inhibited in any way by change i pouU
INSTITUTION, the service fee paid to WSTlTiniON shall bereduced accordingly i KEEFE
after negotiaiion with INSTITU TION.

6-
MENtf
Product selection and pricing wiil be agreed upon by INSTITUTION and KEEFE. Menu
selection shall be reviewed as needed, and no less frequently than annually. All product and
price changes must be approved by INSTITUTION. Any pnce adjustments will be n,ade at least
yarty on the contract anniversary dale with prior approval ofINSTITUTION.
TERM S, TF.RJVIJNATTON
This Agreement shall conUnue ineffect for aperiodofthree years (the base te'rm) from
the date hereof. The Agreement will automaiieally renew for two (2) successive one U tenns
thereafter, unless either party to this Agreement shall give notice in writing to the othe rparty.
agreement may be tenninêd by either pmy for any reason upon giving 30 days Written
notice to the other party ofsuch termination. This agreement auromaticaily tenninates without
requirement of wntten notice mthe event the contract between INSTITUTION and ihi:
Oklahoma Department ofCorrections expires or cancels for any reason. All notices w. be sem
to the individual or their successor approving this agreement.
governing law
This Agreement shall be governed by the laws ofthe State of Oklahoma.
-ENTIRE AGREEMFNT-WAIVRR
Thi. Agreement cons.Uu.es .he en.ire Agreement between the parties wi, respfct ,o ,he
provision ofdelivery êrviees, and there are other or further written or oral der.s,a
idings or
agreenrents with respect thereto. No vartation or n.odiHeation ofd,e Agreement and no
vvalvcr
ofits provisions shall be valid unless in writing and signed by the duly authorised oHic. of
KEEFE ad ,NST,TUT.ON, This Agreement supersedes all other agreements between
parties for the provision ofCommissaiy Delivery Services.
1
^0-
INDEMNlFlPATrruM
the
'
The panies shajl indemnify each other against any loss, damage, injuo-, o, de
by the negligent acts or cntisîons by their agents oremployees for losses, damages,
death caused btheir negligence and arising out of the:consumption or use of the proc
services provided; however, nothing contained herein shall require the parties to defe
ath caused
njuries or
ucts sold or
nd or
indemnify each other for losses, damages, injuries or death arising out ofthe negligence of their
respective agents or employees.
IN WITNESS WHEREOF, th. pîes have executed this Co.,ni=sa,y

Agreement as of the year and date first above written.
KEEFE commissarynetwork (KEE
^/i,
E)
îll.
mmm
John Puricelli
Executive Vice President, General Manager
Dale
GEO Lawton Correctional Facility (INSTITL TION)

BY
-C^6AA.^X^!~
TITLE
DATE
IV .1
I f^
Commissary Agreement
Exhibit A
Noncommissioned Items
Stamped envelopes
Postage stamps
Indigent Kits
Admission Kits
On-site, special commissaiy item sales sold by rNSTITUTION
r --
How Commissions Are Detp.rminAH
r j i r a . s.es. AdJ^ted g.oss

noncommissioned sales.
Monthly Sales
Less Postage/Non Commissionable

= Adjusted
.Qalc
X12% Commission Offered
sales and stamped envelopes are noncommissioned.
Attachment C
KCN Commissary Operation

"-nT't
> "=entered in attheleast
perAccounting
week. Deliveries
inmates will
be the next dayâfter orders'<are
Trustonce
Fund
System.to the
The On-sile KCN staff will distribute menus to the inmates.
The On-site KCN staff will collect the completed order forms.
Oa-site KCN staffwill enter the order forms into the KCN computer system
%the On^sl KCN s'S''''
^ t o the inmates
The On-site KCN staff will handle credits to the inmates' accounts.
whMwTor'''
be delivered
sealed,Theclear,
plastic,
perforated,
htwo (2) copies ofme oraer receipt sealed
within thein bag.
receipt
will contain
the bags
followmg minimum information:
Inmate Name
Inmate Location
Inmate Identification Number
Date
Beginning Available Balance Prior To Order

Item Number(s} ofProducts Ordered
" Description of Item(s) Ordered
"
Quantity Ordered
Extended Price of Item(s) Ordered
'
Total of Order
Individual Unit Price of Hem(s) Ordered
Balance of Account After Order
order TSVeTebfwUl
the order Anv inf
boZTco^ZT
the InstituSon's rlcoS
acknowledgini; receipt of
2nd or
automatically transpose ;)s athecopy
for
damages or shortage^ on
'''''''' '
KCN and the [n.stitution personnel wl! meet and mutually agree upon the items to be
the commissaiy program. After the initial meeting, NO I^MS will be o witho carried in
Jt the
WRITTEN PERMISSION ofthe Inslitution. It is the responsibility of KCN to keep the

Institution current on new products that may be offered.
iCCN wili make available for purchase by all inmates, commissary items including, but not
cate
w
materials, games, snacks, candies, and alimited [êlection oof
ml
wr agreement
^ ubetween the Institution
'
or size without
mutual written
and K.CN.
Items offered in the Commissary will meet the following specifications:
A. Food Items will be wr^ped/packaged and dated for individual consumpti6n.

I
B. All containers will be made of, non-breakable material and clear where available.
i
^ S kichS'^
^'il
S^CiLT
ofnon-breakable plastic and no longer than six
sufficient stock levels in order to limit shortages. KCN will not substitute
,--pt for
KCN will provide for "returns" for orders that are delivered to inmates thai are released or are
otheîse unavailable lo receive product. KCN will do the following, contingent on the
crediiTr
^ that have been released.)
commissary for unavailable inmates the next day
credits for inmates
^ and issue
iJh^crwhi'
'
"
t
memhtr V
No
emplojee
ofKeeie
^rug check. Thi'oughout their employment staff
Se w
o^rS^Vtis
This ensu es asL and
r"' S
ftfaccu"c?TS:r'
pulled Lut ha?oS'
S
"'^"faoturer. and transfer orders from

mcnls are
.r^
""
' >
Institution. There will be no local presence at Keefe while pulling
orders. Kwfe's delivery staffwill be from the local area lo guai-antee timely and efficient
delivery of comfnissar>'.
KCN will provide an experienced site manager and all the necessary eraployees lo stJck
ommissaiy bays, fill orders, deliver orders, maintain the equipment, and manage the Iprogram.
KCN also understands and will comply with any request from the Institution for emp
background checks.
oyee
KCN employees wl) be responsible for the foliowing duties:

Processing and inputting orders at the Institution
Receiving ail commissar>- bags siiipped from our distribution center

Sortmg pulled orders for the Institution by housing unit to ease deiiverv'
Delivering orders to the individual inmates atthe Institution
H^dlmg ail commissary grievances, replacements or credits at the Institution

Attendmg Institution meetings as requested
Providing general maintenance and clean up ofcommissaiy related waste

Providing order forms for distribution to the population
Keefe employees will also meet the trucks canying Uie filled commissary orders at the
commkd
InstimSS
^
ôon.7)rro.. ihe lastitution to
^desk/work area to input
^[^/'^^^^handle paperw-ork. Catalogue purchases will go direcly to the
The Instiiutinn will h
o^ê with adetailed packmg

slip for distribution
i.e.s subsequent
,eceip, tobythe:inmate
.jopeny
employees at time ofdeliveo'- Answers to
the Institution.^^
provided to the Business tvjanaoer of
GEO Lawton Exhibit
Attach. No. 2B
GEO Lawton Exhibit
Facility Name:
lawton Correctional Facility
Address:
8G07 SE Flower tvlound Road
C]tv/State/2ip:
Lawton, OK 73501
Effective Date:
12-1-2013
Commission/Finandal:
129iofgrosscomi7iissionablesales
'
'
IndigentKits: Provide up to 500 Indigent kits (contents agreed upon between Keefe and E0} per
month at no charge to the faciiitV-
KCN wUI wor1( with GEO to Iteep pricing to the inmate population low and comparable to Ot<lahoma OOC
commissary pricing.
Service level/T^ of Operation/Order Entry:

Commissary provided once a week to all inmates
KCN onsite employees (manager and commissary clerks)
Orders are bagged in Keefe Garland, Texas distribution center
Hardware/Software provided:
KCN will provide our own network for commissary (including allassociated costsand wiring)
KCN will provide al) necessary hardware and software
Access Corrections Deposit Services (including lobby kiosk once KCN network in place)
Additional Details:
KCN will provide a waste disposal rebate at the rate of 2.5% of net sales
Gross Sales-Commissions Net Sales
The GEO Groupie. >QEpV
VP 4 C.A O. Cailroller
GEO GfOUD. Inc.
Printed Name and Title
'Z/4l
Date
Date
Service Provider Agreement between Keefe

Commissary Network, LLC, an affiliate of The Keefe
Group and GEO Group, Inc.
Attach. No. 2C
SERVICE PROVIDER AGREEMENT
This Agreement is made and entered into as of this
day of 2011. by
and between KEEFE COMMISSARY NETWORK, L.L.C. an affiliate of THE KEEFE GROUP
("KEEFE") and The GEO GROUP, INC ("GEO").
RECITALS
Whereas, KEEFE is in the business of supplyingcommissary services and other related

products to correctional facilities throughout the United States; and
Whereas GEO is an operator of correctional facilities throughout the United States; and
Whereas, the parties wish to enter intoa Commissary Agreement to facilitate the ordering, sale
and compensation of commissary supplies and services for GEO facilities.
AGREEMENT
NOW, THEREFORE, for and in consideration of the mutual promises and conditions herein
contained, it is agreed between the parties;
OPERATION OF COMMISSARY BY GEO: GEO agrees that during the term of this Agreement,
it will, at its expense, provide personnel to operate the computer equipment and accost forinmate
welfare ftinds.
OPERATION OF COMMISSARY BY KEEFE: KEEFE agrees that on an as needed basis, it will
download all inmate orders for commissary items. KEEFE will bag,box, and ship suchcommissary
items to GEO for distribution to the inmates and will bill GEO monthly, or more frequently, for all
such purchases or as otherwise directed by the facilityaccording to any amendement or facility
contract attached herein. In addition, KEEFE will keep computer equipment updated with complete
information as to commissary items available, pricing, and other terms and conditions ofsale.
PAYMENT: KEEFE will invoiceGEO for all commissary items purchased. GEO will pay such
invoices in accordance with KEEFE'S standard credit terms (NET 30 DAYS).
SERVICE FEE: The service fee to be paid to each GEO facility will be negotiated based on each
GEO facility's specific requirements. The facilities covered under this agreement are listed in Exhibit
A to this Agreement. All terms of any current contracts for any facility will remain in full force unless
agreed to be modified or amended by mutual agreement of the parties. GEO facilities may be added or
removed from this Agreement by amendment throughout the term of the Agreement,
The parties reserve the right and may agree, in writing, to increase or decrease the service fee paid for
specific GEO facilities. Changes in the service fee will be based on changes in service levels, menu,
technology, services and/or operations.
Service fees will be paid as a percentage of adjusted gross sales. Adjusted gross sales are gross sales
less the sales of noncommissioned items as determined by KEEFE and GEO and listed on Exhibit B to
this Agreement.
In the event that the inmate's funds available to purchase commissary products are inhibited in any
way by change in policy from GEO, the service fee paid to GEO shall be adjusted ac cordingly, by
KEEFE, after negotiation and written agreement with GEO.
MENU: Product selection and pricing will be agreed upon by GEO and K.EEFE. Mjenu selection and
pricing shall be reviewed as neêd, and no less than annually. All changes proposed by KEEFE must
bepre-approved by GEO warden/facility administrator. Price adjustments must be approved by the

warden/facility administrator of GEO priorto implementation.
Product pricing shall bebound by fair market value ofitems, defined by this agreement as pricing
generally found in convenience stores. Where a retail comparison does not exist, i.eJ corrections-
specific products, pricing will be agreed up by GEO and KEEFE.
'
Inmates must be notified of changes in pricing and/or menu 30days prior to implementation, imless
otherwise approved by GEO.
Any temporary substitutions for menu items must be approved by the GEO warden/f icility
administrator prior to delivery.
HARDWARE: During the term ofthis agreement, KEEFE shall supply GEO with such computer
equipment and software to perform all commissary and inmate trust processes. Inthe event that GEO
elects to terminate the Agreement, GEO will promptly return all equipment and software to KEEFE.
After initial negotiations and installation of equipment, GEO may request additional hardware as
needed. Compensation for additional equipment byGEO to Keefe will be negotiated and may include
direct invoicing, service fee adjustment orother service and/or menu modifications asagreed by both
parties.
Keefe will provide hardware or reimburse GEO for hardware that will enable Keefe ûipment to
reside on a separate inmate services network. Inmate services network will require Cisco fiber/copper
switching as provided byor reimbursed by Keefe. If inmate labor is utilized to access any network
equipment or service on the inmate services network, a Cisco firewall will be provided by or
reimbursed by Keefe to ensure security of network. All equipment provided by Keefe in support of
inmate services network must beapproved byGEO regional director of information technology prior
to implementation.
Theprovision and installation of wiring for the inmate services network will beprovided byor
reimbursed by Keefe. Keefe and GEO will mutually agree upon scope and cost of wiring prior to
commencement of inmate services.
SOFTWARE; KEEFE hereby grants to GEO a royalty free license to use the KEEFE Commissary
Network software. GEO acknowledges the proprietary nature of the software and/or written software
documentation and hereby agrees NOT to disclose, reproduce, transfer or use the software and/or
documentation for any purpose other than those specifically allowed by the terms of this agreement
without specific written permission of an Officer of KEEFE.
data MANAGEMENT/OWNERSHIP: Data collected in the database by the KEEFE KeepTrak

Banking and Commissary system is the property of GEO. KEEFE will make these dataavailable to
GEO in an agreed upon format as needed or at contract termination. KEEFE supports the transition of
data fi"om its KeepTrak system to successor banking systems and has developed templates for data
transition including line item financial and commissary detail perinmate account.
ACCESS TO SERVER/INTERNET FOR PROVIDER SERVICES; Servers provided by KEEFE
for use by GEO for the KEEFE KeepTrak Inmate Banking solution require access to fiosted KEEFE
services. Should GEO add the KEEFE-provided servers to the GEO Active Directory and/or firewall
policies the following applications should be provided port and host name access:
Local Service / Application
Outbound
KJLEl't Central Services Host Ni
me
Port
Sybase Afaria Application

KCN DepositApply
(Windows Service)
443
KioskDirector.dll and
443
80
AFARIA.KEEFECOMMISSARY>JETWORK.COM
SERVICES.ACCESSCORRECT10NS.COM
1
SERVICES.ACCESSCORRECTIG NS.COM
KioskSecureMail.asmx (KCN
EdgeMail Web Service)
Keefe will provide or reimburse GEO for internet connectivity for all equipment requ ired for inmate
services network.
DEPOSIT SERVICES; This agreement shall include KEEFE'S Access Corrections Secure Deposit
Services for all facilities at GEO's request. KEEFE will facilitate family deposits to inmate trust
accounts via website, toll free phone number and deposit kiosk placed in a mutually agreeable site
within the facility. Deposit kiosks will only be placed in those facilities pre-approved by GEO.
GEO Facility shall be responsible for providing power and network connectivity for the kiosk.
KEEFE will guarantee all nightly deposits and ACH transactions to a GEO designated bank account.
No fees for this service shall be the responsibility of GEO. KEEFE has included the tee structure for
this service as Exhibit Dof this Agreement. GEO may request an increase in these fees to provide a
revenue share to GEO.
SECURE MAIL SERVICES; This agreement shall include KEEFE'S Access Corrections Secure
Mail Services for all facilities at GEO's request. KEEFE will provide all hardware and software
required to support electronic mail services at no cost to GEO.
GEO may choose any and all facilities for implementation of these services. Any and all fees for the
service shall be at the expense of the resident or the resident's families and fnends to send or receive
electronic messages to and from the resident. KEEFE has included the fee structure for this service as
Exhibit E of this Agreement. GEO may request an increase in these fees to provide a revenue share to
GEO.
I
MUSIC SERVICES; This agreement shall include KEEFE'S Access Corrections Secure Music
Services for all facilities at GEO's request. KEEFE will provide ail hardware and software required to
support the music/MP3 service at no cost to GEO.
GEO and KEEFE must mutually agree upon all facilities where these services will be eligible based
upon GEO'S contract, resident ADP, hardware requirements, etc. Any and all fees for the service
shall beat the expense of the resident or the resident's families and friends to purchase MP3 players
and music downloads. KEEFE has included the fee structure for this service as Exhibit F of this
Agreement. GEO may request an increase in these fees to provide a revenue share to GEO.
All music made available for inmate purchase must be approved by GEO warden/facility administrator
priorto release to the inmate population.
RELEASE SERVICES: This agreement shall include ICEEFE'S Access Corrections Secure Release
Services. KEEFE will provide all hardware and software required to support the Secure Release
service at no cost to GEO.
GEO may choose any and all facilities for implementation ofthis service. All fees for the service shall
beat the expense of the resident to provide a debit card with the resident's account balance loaded
upon release trom a GEO facility. KEEFE has included the fee structure for this service as Exhibit G
ot this Agreement. GEO may request an increase in these fees to provide a revenue share to GEO.
I
FUTURE TECHNOLOGY/SERVICES: KEEFE agrees to make available to GEO all future
technology and/or services as they become available. These services will be added by addendum to
this master agreement. Where applicable, service fees may be modified to compensate for additional
services as agreed upon by both parties. Implementation ofthe technology and/or services will be
negotiated on a per facility basis and will require approval from GEO prior to implementation
SERVICE/SUPPORT: KEEFE will maintain all hardware and software at no costto GEO for the
life ofthis agreement.. During the term ofthe Agreement, KEEFE agrees to keep current both the
hardware and sofhvare. KEEFE will provide 24-7-365 support for all software and hardware provided
by KEEFE. Details of KEEFE's service and support is include herein as Exhibit H.
TERM &TERMINATION: This Agreement shall continue in effect for a period ofthree (3) years
{the Base Term) from the date ofexecution for each GEO facility. The Agreement may be renewed
for successive one year terms thereafter, by mutual agreement ofthe parties. Afler the Base Term, this
Agreement may beterminated by either party with 30days prior written notice.
Termination bv Convenience. GEO shall have the right to terminate this Agreement or any
individual facility contract for any reason or no reason at any time upon the giving ofat least sixty (60)
days prior written notice to the other party.
Loss ofCommissary Rights. GEO may terminate this Agreement or any portion thereof upon written
notice if GEO's right to provide commissary services atany of the listed facilities terminates.
CONFIDENTIAL INFORMATION. Contractor agrees that any and all information associated with
GEO or itsaffiliates thai is not otherwise publicly available ("Confidential Information") that is
disclosed to or received by KEEFE (i) shall be treated as GEO's confidential, proprietary, and trade
secret information (with GEO reserving all rights to its Confidential Information); (ii) shall beheld by
KEEFE in strict confidence, (iii) shall beused by KEEFE only for purposes of this Agreement, and
(iv) that no Confidential Information, including without limitation the provisions of this Agreement,
shall be disclosed by KEEFE without the prior written consent ofGEO. KEEFE shall safeguard
Confidential Information with at least the same degree of care (which shall always be at least a
reasonable amount ofcare) that ituses to safeguard its own confidential, proprietary, and trade secret
information. All data regarding iiunate purchases or derived therefrom is the Confidential Information
of GEO. The terms of this Section shall survive any expiration or termination of
this Agreement.
'
ASSIGNMENT. KEEFE acknowledges that GEO has entered into this Agreement because of the
unique technical abilities, capabilities, and credit worthiness of KEEFE. Therefore, KEEFE may not
assign this Agreement or any rights obtained hereunder or delegate or subcontract any duty of
perfomiance owed by KEEFE hereunder without the prior written approval ofGEO. Any assignment
made in contravention of this Section shall benull and void for all purposes.
GOVERNING LAW: This Agreement or any claim between the parties shall be construed, enforced
and litigated in accordance with the laws of the State of Florida, without regard to conflicts of law
pnnciples. Any suit or proceeding arising under this Agreement shall be brought exclusively in Palm
Beach County, Florida, and each of the parties hereby consents to the personal jurisdiction of the
courts, federal and state, located therein, and designates, if necessary, the Florida Secretary ofState to
accept service on its behalf.
ENTIRE AGREEMENT-WAIVER: This Agreement constitutes the entire Agreement between the
parties with respect to the provision ofdelivery services, and there are no other or further written or
oral understandings or agreements with respect thereto. No variation or modification of the
Agreement and no waiver ofits provision shall be valid unless in writing and signed by the duly
authorized Officers ofKEEFE and GEO. This Agreement supersedes all other agreements between
the parties for the provision ofCommissary Dehvery Services.
INDEMNIFICATION; The parties shall indemnify each other against any loss, damage, injury, or
death caused by the negligent acts or omissions by their agents or employees for losses, damages,
injunes or death caused by their negligence and arising out ofthe consumption or use of the products
sold orservices provided; however, nothing contained herein shall require the parties to defend or
mdemnify each other for losses, damages, injuries or death arising out ofthe negligence of their
respective agents or employees.
Notice. Each party shall promptly notify the other ofany Claims that may be present^ to it by any
person or entity. No settlement which prevents GEO from continuing to use the Services, System or
Software of ICEEFE shall bemade without GEO's prior written consent. In all events, GEO and
KEEFE shall have the right to represent their interests in the defense ofany suit or proceeding through
counsel of its own choosing.
Audit. Keefe shall keep and maintain detailed records and books ofaccount containing accurate and
complete entries in respect ofall transactions and matters relating to the subject matter ofthis
Agreement. GEO or its designee shall have the reasonable right but not more than 1time per annum,
at GEO's sole expense, to inspect and audit any and all such records within a period ofthree (3) years
atêr the termination ofthis Agreement; provided, however, that Keefe shall have the ri^t to exclude
any trade secrets from such inspection and audit. IfGEO's examination discloses that financial reports
made by Keefe to GEO were in error, Keefe will immediately pay to GEO any deficiency found to be
owing, plus interest from the date ofthe error at the lesser ofeighteen percent (18%) per annum or the
maximum rate allowed by law. Ifthe audit determines that Keefe over reported the amounts owed by
GEO by three percent (3%) or more for any one month period, then Keefe shall also bear the expense
of Company's examination and audit.
PUBLICITY. KEEFE shall not make any public announcement, press release orother
similar disclosures regarding this Agreement nor shall it use GEO's or its affiliates names or
the name ofthe Facility, trademarks, or logos in any advertising or marketing without the prior
written consent of Customer.
insurance. At all times during the term ofthe Agreement, KEEFE shall carry, at its
own expense and with deductibles for its own account, with insurance companies satisfactory to
GEO, insurance coverage of the types set forth below and made apart hereof for all purpose. Within
thirty (30) days from the date of fCEEFE's acceptance hereof, but in any event prior to the
commencement of the Services, KEEFE shall fiimish to GEO for inspection, insurance certificates
evidencing insurance coverage satisfactory to GEO. KEEFE acknowledges that GEO does not
maintain any insurance whatsoever for the benefit ofKEEFE, its heirs, representatives, successors or
assigns.
Automobile Liability:
Bodily Injury (Each Person) $250,000^00

Bodily Injury (Each accident)$500,000.00
Geoerai LiabUity (including Contractual Liability):
Bodily Injury
Property Damage
Excess Liability:
Umbrella Form
Worker's CompeDsatioo:
$500,000.00
$100,000.00
$1,000,000.00
Statutory
WARRANTY. KEEFE represents and warrants that (a) the Services ofKEEFE will be performed in a
good and workmanlike manner in accordance with generally accepted professional standards; (b) the
Software and System will accurately reflect and process all sales, prices, credits and other transactions'
(c) all Sen'ices performed by KEEFE for oron behalfof GEO. and all Software does not and will not
violate, mfringe or misappropriate the rights of any third parties including, without limitation, the
copyright, trademark, patent, or the trade secrets of any third persons; (d) KEEFE has the experience,
skill and ability msuch fields and related disciplines as may be necessary to perform all Services
required by this Agreement with a high standard of quality; and (e) KEEFE has and shall maintain
physical, network, and data security consistent with the best practices ofthe industry and designed to
protect GEO's computer systems and networks and associated data from loss, misuse; unauthorized
access, disclosure, alteration, or destruction. KEEFE acknowledges that GEO is relying on KEEFE's
skill and expertise for the perfonnance ofthis Agreement, and aêes to notify GEO whenever KEEFE
does not have the necessary skill and experience to fully perform hereunder.
Equal Employment OpDortuDitY. Keefe agrees that they shall not discriminate against any employee
or applicant for employment or on any matter directly or indirectly related to employment, because of
race, color, religion, sex, sexual preference, national origin, physical or mental handicap where not
relevant to the job, height, weight, age, marital stams, or other criteria made illegal by state or federal
law or GEO policy. In addition, Keefe agrees to take affirmative steps to ensure that applicants are
employed, and that employees are treated, during employment, without regard to the criteria listed
above.
Notwithstanding the foregoing, Keefe agrees to comply with all applicable federal, state and
local laws, including the Civil Rights Act of 1964 as amended.
'
The Equal Employment Opportunity clause in Section 202 paragraphs 1through 7of
Executive Order 11246, as amended, relative to Equal Employment Opportunity and the implementing
Rules and Regulations ofthe Office ofFederal Contract Compliance are incorporated!herein by
specific reference.
The Affinnative Action Clause in Section503 ofthe Rehabilitation Act of 1973, as amended,
relative to Equal Opportunity for the handicapped is incorporated herein byspecific reference.
The Affinnative Action Clause in 38 USC Section 2012 of the Vietnam Veteran's
Readjustment Assistance Act of1974, relative to Equal Employment Opportunity for the special
disabled veteran and veterans of the Vietnam Era, is incorporated here by specific reference.
IN WITNESS WHEREOF, theparties have executed this Commissary Agreement asof the year and
date first above written.
KEEFE COMMISSARY NETWORK (KEEFE)
John roncinT
ti
/ii
Date
THE GEO GROUP, INC. (GEO)
RONALD A. BRACK
VP & C.A.O. Controller
Printed
Date
Exhibit A
The Toliowing GEO facilities shallbe included in this Agreement:
* Additional GEO facilities may be added or removed from this Agreement throughout the term
of the Agreement.
Exhibit B
Noncommissioned items
Tobacco
Stamped Envelopes
Postage Stamps
Indigent Kits
Admission Kits
On-site. special commissary item sales sold by GEO
How Commissions Are DeterminpH
The cotiunissions will be based on the weekly, adjusted gross commissary sales. Adjusted gross sales
are gross sales less postage sales or other noncommissioned sales.
Monthly Sales
Less Postage/Non Commissionable
= Adjusted Gross Sales
X % Commission Offered
Postage sales and stamped envelopes are noncommissioned.
'
Exhibit D
Secure Deposit Fee Schedule
ELECTRONIC DEPOSIT SERVICES

Cash
Deposits via
Lobby
Credit/Debit
Credit/Debit
Gross Amount
Deposits via
Deposits via
Deposits via
Deposited
Website
Phone
Lobby Kiosk
1 Kiosk
$0.01 - $19.99
$2.95
$3.95
$2.95
' $3.00
$20.00-$99.99
$5.95
S6.95
$5.95
$3.00
$100.00-$199.99
$7.95
$8.95
$7.95
$3.00
$200.00 - $300.00
$9.95
$10.95
$9.95
$3.00
Credit/Debit
Exhibit E
Secure Mail Fee Schedule
ELECTRONIC MAIL SERVICES

Per Paae Electronic Mall Price
$0.50
Per Photo Download Cost*
$1.00
*Photos are available for download and storage on the MP3 player only upon approval from GEO.
Exhibit F
MP3 Program Fee Schedule
MP3 SERVICES
MP3 Player Price to the Resident *non-commissionabte*
Per Song Download
$130.00
$1.60
*The player may be provided to GEO at no commission or adesired commission amount may be
added to the S130.00 player price above.
Exhibit G
Release Card Fee Schedule
Card Activation Fee
Temporary Card
Permanent Card
$3.00
$4.9S
$0.00
$0.00
$1.00
$2.00
$0.00* for the first transaction
$2.50
Signature Purchase
Fees
PIN Purchase Fees
ATM Fees
$2.50* for each additional
ATM Declines
ATM Balance Inquiries
Monthly Fee
$1.00
$0.50
$0.00
$1.00
$0.50
$9.95"
Inactivity Fee
5.95***
$5.95"
'Certain ATM machines may impose their own fees

"Optional monthly fee waives purchase fees for month
***Fee charged after 120 days of inactivity
Exhibit H
Hardware & Software Support

Page 1 of 3
Ongoing Support
o KEEFE provides five levels ofsupport. All support staff are employees of KEEFE.
1.
Contact Services
first line of contact for service requests via phone or e-mail
Phone requests are routed through CISCO Call Manger on a24 x7x3^5 basis - phone
requests are placed by dialing 800 864-5986.
i. When are phone service.s available?
1. Business hoursare definedas 8 AM- 5 PM Mondaythrough Friday.

2. During business hours, inbound cailsare answered by an administrative
attendant. The administrative attendant determines whether the call is
related to marketing, accounting, or technical services. If the call is

technical in nature, the attendant can route the call either to the direct
extensionof an individual technician or to the call-queuefor the first

available technician.
a. Calls queued for the first available technician can travel through
fourstaiT levels, withan increasingcumulativenumber of
extensions accessed throughout wait-time. ,
i. If a queued call is not answered within five minutes, the
call is routed to a voice mail extension which records a
message from the caller and automatically begins

paging a group of six escalation phone numbers
b. Calls directed to an individual technician arc subject to the

current availability of that technician at the time the call is
transferred.
3. Any inbound call outside of business hours can access technical support
bychoosing option 7 ona touch-tone phone. When option 7 is selected,
the call routing routine first checks for available staff^ extensions. If
none are available the call is routed to a voice mail which automatically
begins paging a group of six escalation extensions. Oii-call staffare
equippedwith notebook computer systemsintegratedwith wireless
internet access and VPN access to theKEEFE Corporate Service Center.
E-mailrequests are monitored during businesshoure by a designated ServiceCenter
administrator.
i- 1heSolutions Center administrator screens e-mail either for immediate respotise

or for escalation as a serviceevent.
ii. If escalated to a service event, the Service Center Administrator opens a CRM
Case and either assigns the case to a technician or adds the case to the service
ticket queue.
Contact Services Staffare located at the KEEFE Service Center Corporate Office in St
Louis MO Monday through Friday 6 AM - 7 PMCST
'
On-Call Staffare located off premises Monday through Friday 5 PM - 8 AM, Saturday and
Sunday 24 hrs per day, and Monday morning 12 AM - 8 AM.
'
i. On-Call staff are located at the KEEFE Service Center Office in St. Louis MO
Monday through Friday 8 AM - 5 PM
All customer support cases are documented in Microsoft CRM. History is available to all
field sales staffand regional management ona real time basis.
'
Exhibit H

Page 2 of 3
Examples of first line support services

i.
Resolution of communications eiTOre
ii. Analysis of hardware errors and replacement of defective hardware

iii. Standardend-usertraining
iv. OrderTracking. Order Processing. Pricing Updates
2.
Escalation Services
^
I
resolution of complex helpdesk service requirements. Contact Services escalate
more complex service requirements to a higher level ofcomplexity and urgency
3.
4.
On-site maintenance of kiosks and server as required
'
Data Center Services
operation and control of corporate computersystems relating to the customer
Collection and maintenance ofsite specific DB2 backups for business continuity
Project Services
planning and implementation ofsoftware, hardware and.network deployments at

customer sites
5.
Engineering and Development Services
specification and development of hardware / softwaresolutions forcorrectional

commissary environments. Engagement at thislevel requires KEEFt corporate
review / approval ofcustomer requests sponsored by KEEFE regional

representatives on behalf of the customer.
'
Hardware Service Agreements - repair and or replacement of

defective hardware
Hardware failures are covered under contracts with manufacturers such as Dell. Wyse, NCS. Brother. Tally
Genicom, etc. These are typically 24-hour turnaround contracts for workstations, same day service for servers,
and depot/wananry replacement for peripherals and kiosks. The facility may also opt lo have KEEFE provide on-
site ordepot service spare equipment to maximize utilization and minimize downtime ui the event ofhardware
failure.
I
Server maintenance is covered by Dell as follows:
o Gold Del! on-sile server service - would include 4-hour 24 x 7 x 365 on-site response time
guaranteed by Dell Computer Corp after dispatch by KEEFE help desk staff
Workstation maintenance optionsare as follows;
o Standard Dell on-site workstation service - would include 8-hour 8x5 on-site response
lime guaranteed by Dell Computer Cons after dispatch byKEEFE help desk staff
Depot -backup workstation service - would include the storage ofa'cold spare' workstation CPU at the Regional
Distribution Center. In the event ofa workstation
o
failure at the facility, thecoldspare could be installed and connected to theKrver database
for use ina matter ofhours by KEEFE staff. At such time asthe original workstation is
repaired the process can be reversed atoff-peak hours to re-introduce die original
workstation, and remm the 'cold .<T5are' lo depot sows. The cost of'depot - backup
workslation service' is reflected in the cost proposal
Exhibit H

Page 3 of 3
PodKioskmaintenance options are as follows:
o Dôt- backup pod kiosk shells are stored at the regional distribution center. In the event
ot akiosk failure, facility tnaintenance staffwould be trained to remove the defective pod
kiosk shell and replace it with the spare. The defective shell would be shipped to KEEFE
Technical Services to be refurbished. Once refurbished, the shell woulti be shipped back to
theregional business center as one of the spare units.
Lobby Kiosk maintenance options areas follows:
o Depot - backup lobby kiosk shells are stored atthe regional business center. In the event of
a lobby kiosk failure, facility maintenance staff would be trained to remove the defective
pod kiosk shell and replace it with the spare. The defective shell would be shipped to
KEEFE Technical Services to be refurbished. Once refuibished. the shell would be shipped
back to the regional business center asone ofthe spare units.
Monitor, modem, printer, OMR scaimer maintenance options are asfollows:

Standard peripheral replacement services - Inthe event of failure ofone or more ofthese
peripherals, KEEFE will ship a replacement for next day delivery and installation by
facility staff. In the event that the OMR scanner can be repaired! replaced directly by NCS
and this would be aquicker solution to return the equipment to service. KEEFE Tech
services will exercise the NCS service option.
On-site depot pcnpheral replacement services -KEEFE will store one ofeach ofthese peripherals at the:regiona]
Distribution Center. In the event of afailure ofone or more of these peripherals. KEEFE regional Distribution Center staff
will replace the penpheral(s) with aspare umt. and return the failed unit to KEEFE Headquarters Technical Services for
repau- or replacement by the related vendor. KEEFE Headquanere will renim aservice replacement to the regional
Distnbuuon Center and have the failed unit repaired or replaced by the associated manufacturer or vendor. The cost of'on-
stte depot penpheral replacement services' is reflected in the cost proposal.
Keefe invoice for items sold to Joseph Harp

Correctional Center
Attach. No. 3

DEPARTMENT OF CORRECTIONS
CANTEEN PURCHASE ORDER
VENDOR:
Page 1 OF 3
KEEFE GROUP
ORDER NUMBER
10880 LINPAGE DR
ST LOUIS, MO 63132-1008
CJHC160229
ORDER NUMBER MUST APPEAR ON INVOICES
INVOICE TO: JOSEPH HARP CC
DATE
OBJECT
10/30/2015
564110
16161 MOFFATROAD
LEXINGTON, OK
Facility Contacts:
JOSEPH HARPCC
SHIP TO:
Phone#: 405-527-4807
Fax#:
JOSEPH HARP CC
405-527-4811
16161 MOFFATROAD
LEXINGTON. OK 73051
rTEU
NUUBER
COMMODITY CODE gr PRODUCT

CODE or SERVER ID NUMBER
QUANTTTY
UNrr
CS
009800895007
NUTELLA
15/CS
$62.250000
$62.25
CS
011111323971
LEVER 2000
48/CS
$47.040000
$94.08
CS
017000009100
DIAL GOLD BAR SOAP - 3.5 OZ,
72/CS
$43.200000
$86.40
CS
017000044286
DIAL ADVANCED THERAPY LOTION

120Z.
6/CS
$15.300000
$30.60
CS
017000046006
DIAL FULL FORCE BODY WASH 160Z.
6/CS
$36.000000
$72,00
CS
019100005228
JERGENS BATH SOAP - 4.5 OZ.
24/CS
$19.200000
$115.20
CS
022200002943
AFTER SHAVE ORIGINAL
24/CS
$53-760000
$107.52
CS
022200004923
MENNEN SPEED STICK SPRT 302
12/CS
$29.760000
$178.56
CS
024463061095
SRIRACHA HOT SAUCE 17 OZ.
12/CS
$31,320000
$62.64
10
CS
024600010986
MORTON MCCORMICK SALT AND
12/CS
$21.360000
$21.36
TASTER'S CHOICE COFFEE 8 OZ
12/CS
$102.000000
$204.00
NESTLE DARK CHOCOLATE WHIPPER
12/CS
$52.800000
$105.60
PRODUCT OR SERVICES DESCRIPTION
UNTTPRICE
EXTENSION TOTAL
PEPPER SET
11
CS
028000414009
12
CS
028000426501
MIX 2LB
$1,140.21
TOTAL
$4,617.39
Authorized By
Requested By
NOTICE TO VENDORS
PRICES EXCLUSIVE OF FEDERAL AND STATE TAXES
ORDER NUMBER MUST APPEAR ON INVOICES.
ALL PRICES F.O.B. DESTINATION UNLESS
BILLS OF LADING, PACKING LISTS AND
OTHERWISE NOTED.
CORRESPONDENCE

ORDER NUMBER
CJHC160229
rTEH
NUMBER
Page 2 OF 3
COUHOUTY CODE or PRODUCT

QUAKTITf
UNIT
13
cs
035000566850
14
cs
035000765529
CODE or SERVER 10 NUMBER
PRODUCT OR SERVICES OESCRtPTION
UNITPRRE
EXTENSlim'TOTAL
ULTRA BRITE TOOTH PASTE 60Z
24/CS
$36.720000
$73,44
COLGATE MAXCLN SMTFOAM
24/CS
$83.040000
$166,08
WHITEN 60Z
15
cs
038200000063
PICKLE DILL
12/CS
$6.240000
$12.48
16
cs
038200000094
PICKLE HOT
12/CS
$6.240000
$12,48
17
cs
038276005061
PINK OIL MOISTURIZER 8 OZ
12/CS
$56.400000
$169.20
18
cs
041368210216
BLISTEX MEDICATED LIP OINTMENT
24/CS
$46.800000
$46.80
(1)
19
25
cs
041789002779
RAMEN CAJUN CHICK CL 2.8 OZ
24/CS
$5.040000
S126.00
20
30
cs
041789002793
RAMEN HOT-SPICY VEG 2.8 OZ
24/CS
$5.040000
$151.20
21
cs
042037103101
CHAPET LIP BALM
12/CS
$6.040000
$16.08
22
cs
047400098190
GILLETTE CLEAR GEL DEODORANT
12/CS
$52.800000
$158.40
30Z.
23
cs
052100009711
GARLIC POWDER SPICE CLASS
12/CS
$14.400000
$43,20
24
cs
052100019802
IMITATION BACON BITS 2 OZ
12/CS
$14,400000
$14.40
25
cs
052100020204
SP CLASSICS CHILI POWDER
12/CS
$14.400000
$14.40
26
cs
052100020747
SPICE CLASSICS CHOPPED ONION
12/CS
$14.160000
$14.16
27
cs
070330902824
BIC PENS BLUE CT2
12/CS
S8.880000
$35.52
28
cs
070330902831
BIC CRYSTAL PEN 2P
12/CS
$8.880000
$35.52
29
cs
075285002766
SPORTIN WAVES
6/CS
$14.940000
$29.88
30
cs
075610018103
ROYAL CROWN HAIR DRESSING
12/CS
$12.000000
$48.00
31
cs
087381000805
KEEFECRMYPEA BUT160Z
12/CS
$20.880000
$125.28
32
cs
087381000812
KK CHUNKY PEANUT BUTTER 1802
12/CS
$20.880000
$41.76
cs
087381001796
SQEZ SALSA 15.50Z PLAS BTL
12/CS
$18.600000
$18.60
33
34
cs
087381003547
POLO BLACK ICE BODY WASH
12/CS
$34.800000
$104.40
35
cs
087381003554
JALAPENOS SLICED CACTUS ANNIES
12/CS
$13.800000
$55.20
36
cs
087381012662
HOT & SPICY PORK RINDS 20Z
24/CS
$16.320000
$32.64
37
cs
067381017100
BRUSHY CREEK CHILI NO BEANS
24/CS
$36.000000
$144.00
36
cs
087381017117
BRUSH CREK CHILI W/ BEANS
24/CS
$36.000000
$144.00
39
cs
087381017124
BRUSHY CREEK CHILI W BEANS HOT
24/CS
$36.000000
$72.00
40
cs
087381017155
BRUSHY CREEK BEEF STEW
24/CS
$36.000000
$72.00
41
10
cs
087381030925
THAI PALACE NOODLES CHILI 3.7

OZ/24CT
24/CS
$12.240000
$122.40
42
cs
087381037320
KK MAYONAISE 18 OZ SQZ BTL 12/CS
12/CS
$36.120000
$72-24

ORDER NUMBER
CJHC160229
ITEM
NUMBER
COMMODITY CODE or PRODUCT

CODE or SERVER ID NUMBER
Page 3 OF 3
QUANTITY
UNIT'
UUTPWE
43
cs
087381060465
ZiPPY CAKES STAWBERRY ZUZU'S

40Z.
36/CS
$17.640000
$35,28
44
cs
087361060489
BLUEBERRY DONUTS 6 PACK
12/CS
$20.640000
$165.12
45
cs
087381065972
ZIPPY PEANUT BUTTER CREMES
24/CS
S12.480000
$37.44
46
cs
087361077562
SQUEEZE GRAPE JELLY 20 OZ
12/CS
$26.400000
$52.80
47
cs
087381077579
STRAWBERRY SPREAD 20 OZ
12/CS
$26.400000
$52.80
48
15
cs
087381102431
KEEFE ALTURO BLEND COFFEE 302.
24/CS
$34.320000
$514.80
49
cs
087381125133
GUCCI BLACK ICE BODY WASH 15 FL

OZ
12/CS
$34.800000
$104.40
50
cs
087381219528
NEW DAY COT SWABS 100CT
24/CS
$16.320000
$32.64
51
cs
087381853753
MOON LODGE EXTRA BUTTER
90/CS
$26.100000
$78.30
PRODUCT OR SERVICES DESCRIPnOH
EXTENStONTOTAl.
POPCORN 2.80Z BA
52
cs
781923254014
BULLIARD HOT SAUCE HABANERO
24/CS
$14.400000
$28.80
53
cs
791669198978
FRUIT & CREAM OATMEAL VARIETY
12/CS
$24.000000
$48.00
54
cs
791669199234
RALSTON MAPLE&BRN SUG INST OAT
12/CS
$24,000000
$48.00
1.510ZPKS
55
56
57
cs
816559011967
COAST SOAP 2CT
24/CS
$25.680000
$51.36
cs
839294262548
PERCARA MOUTHWASH 240Z.
12/CS
$12.000000
$12.00
cs
883484333532
PERT PLUS 13.5 OZ
6/CS
$21.840000
$43.68
March 29, 2016, Memorandum Re: Price Increase of

Keefe Commissary Items
Attach. No. 4
memorandum
Correctior.,
The GEO Group, Inc.
GEO Corrections
6607 S.E. Flower Mound Road
Date:
Lawion, OK. 73501
To: Offender Population
www.geogroup.com
cc:
From: Mr. Quiroga Commissary Manager
RE: ANNUAL PRICE INCREASE (EFFECTIVE 4-18-16)

Final
Price
Item #
Description
Various
NEXT 1 SOAP. BAR 5 OZ 80/CS CLEAR PUSTIC
Various
SODA 12 OZ 24/CS CAN
Various
TONY CHACHARES RICE DINNERS 8 OZ 12/CS BOX
Various
CANDY BAR SINGLES WRAPPED
CACTUS ANNIES_CHIPS_1G OZ -13 OZ BAG CLEAR

Various
WINDOW
BRUSHY CREEK_CHIL1_&_BEEFSTEW 11.25

Various
OZ 24/CS POUCH
FRESH CATCH_FISH STEAKSJN SPICY MUSTARD

SAUCE_&_IN OIL W/GREEN CHILIS 3.53
Various
0Z_ 24/CS POUCH
Various
JAR CLEAR
KEEFE KITCHENS_PEANUT BUTTER 18 OZ 12/CS PLASTIC

22960 - IVORY_SOAP PURE BAR 3.1 OZ 3EA/PK
0410
72EA/CS
Current
w/out
Price
Tax
$1.15
$1.10
$2.65
$1.20
$1.25
$1.20
$2.85
$1.40
$2.20
$2.40
$2.10
$2.20
$1.50
$1.60
$3.10
$3.20
$0.95
$1.05
$1.10
$1.20
$4.10
$4.20
20922-TONE_SOAP COCOA BUTTER BAR 3 5

0415
OZ 48/CS
7022 - KEEFE_FREE2E DRIED COFFEE_COLOMBIAN 3

2015
OZ 24/CS POUCH CLEAR RESEALABLE
2974 - MAXWELL HOUSE_COFFEE_REGULAR 4

2017
OZ_24/CS POUCH CLEAR RESEALABLE
$4.15

Annual Price Increase
10472 - FRESH CATCH TUNA W/JALAPENOS 3 53

2584
OZ 24/CS
80001725 - BRUSHY CREEK BEEF SUMMER SAUSAGE 11

2526
02 24/CS
6060 - ZIPPY CAKE_CUPCAKES_CHOC CREME 4

3270
OZ 36/CS PLASTIC OVERWRAP
6055-ZIPPY CAKE_CAKE_SWISS ROLL 12 OZ 6/BX
3331
24BX/CS PAPER BOX
3431
4086-GEN ICECREAM PINT 1/EA
798-MARS_SNICKERS_ALMOND 1.76 OZ 24/BX

4043
12BX/CS WRAPPED
$2.2
$3.60
$3.70
$1.10
$1.30
$1.85
$2.30
$2.05
$2.95
$1.40
$1.60
$1.00
$1.20
$1.20
$1.40
$3.20
$3.40
$1.85
$2.05
$1.80
$1.80
$1.65
$1.75
$1.35
$1.45
$1.70
$1.80
$2.10
$2.30
$1.80
$2.00
$1.75
$1.95
40609 - SATHERS_CANDY_LEMON DROPS 4.25

4110
OZ 60/CS PRINTED BAG
40615 - SATHERS_CANDY_SF WILD FRUIT 1.75

4155
OZ_60/CS PRINTED BAG
9393-VELVEETA_CHEESE SHARP CHEDDAR 16

4176
0Z_12/CS SQUEEZE BOTTLE
9771 - SEVILLA^REFRIED BEANS_SPICY_8

6047
5880- KEEFE KITCHENS_RICEJNST WHITE 8

6050
OZ_24/CS POUCH CLEAR RESEALABLE
4385 - FRESH CATCH_MACKEREL FILLETS IN OIL 3.53

6178
OZ 24/CS POUCH
6179
OZ_24/CS POUCH
4388 - FRESH CATCH_SARDINES SOYBEAN OIL 3.S3

4391 - FRESH CATCH_SALMON FLAKES IN WATER 3.53
6191
OZ 24/CS POUCH
LOW FAT
7629 - CACTUS ANNIES_CORN CHIPS_CHILI CHEESE 12

6247
OZ. 15/CS BAG CLEAR WINDOW
175 - CITY COW_CHEESE BAR CHEDDAR 4

6422
OZ 4S/CS WRAPPED CLEAR
178 - CITY COW_CHEESE BAR_HOT PEPPER 4

6449
OZ_.48/CS WRAPPED CLEAR
381 - GEN_PICKLE MILD DILL 9.6 OZ 12/CS POUCH

6501
CLEAR
355 - CACTUS ANNIESJALAPENO PEPPERS SLICED W/

6506
BRINE 12 OZ 12/CS TUB CLEAR
Page 2 of3
$1.05
$"

Annual Price Increase
6512
90-KEEFE_HOT SAUCE LA 6 OZ 24/CS PLASTIC
$0.95
$1.15
$2.80
$3.00
$1.50
$1.70
$0.80
$1.00
$2.50
$2.70
$2.60
$2.80
$2.20
$2.30
$1.17
$1.37
BOIILE
3732 - KEEFE KITCHENS_MAYONNAISE REGULAR 18

6545
OZ 12/CS PLASTIC BOl RE CLEAR
5070 - CACTUS ANNIES_TORTILLAS_FLOUR 8 OZ 6CT 8

6600
IN 48/CS BAG CLEAR RESEALABLE
3092 - THAI PALACE_NOODLES_CHILI 3.7

6673
OZ 24/CS WRAPPED CLEAR
9783 - SEVILLA_REFRIED BEANS_REGULAR 8

6700
6772
02 12/CS BOX
2770-TONY CHACHARES_RICE DINNER JAMBALAYA 8
4317 - FRESH CATCH_CHUNKLIGHTTUNAJN

6826
WATER 4.23 OZ 48/CS POUCH
5068001099-SOFT TOUCH_SOCKS CREW #673 GRAY

6974
HEEL & TOE EA WHITE
COMMISSARY MANAGER
Mr. Quiroga
Page 3 of 3
Deposition Transcript of Defendant Michael Berg

(Leatherwood V. Hector Rios, etaL, CIV-15-767)
(Deposition Date; May 12, 2016)
Attach. No. 5

Michael Berg
May 12, 2016
Page 1
L
IN THE
UNITED STATES
DISTRICT COURT
MICHAEL D.
LEATHERWOOD,
PlaintiFP,
Case
Numben
CIV-15-767-C
vs.
HECTOR RIOS,
WARDEN,
et a l . ,
Defendants.
DEPOSITION
Taken
on
OF
MICHAEL
behalf
of t h e
BERG
Plaintiff
on the 12th day of May,

in Lawton,
9|C
REPORTED BY:
2016
Oklahoma.
SfC
STEVE PLUMBTREE,
CSR,
CP
Plumbtree Reporting

Michael Berg
May 12, 2016
2 (Pages 2 to 5)
Page 2
APPEARANCES
MR. MICHAEL D. LEATHERWOOD, DOC Number 595058.

Pro Se. B607 Southeast Flowermound Road, Lavvton, OK
73S01. appearing pro se.

MR. DON G. POPE, Attorney at Law, Don G. Pope &
2
3
4
Associates, P.C, 611 24th AveSW, Suite 102,
Norman. OK73069, appearing on behalf of the
Defendant Rios.
MS.STEFANIE E. LAWSON, Attorney at Law.

Street. Oklahoma City,OK 7310S,appearing on behalf
of the Defendant Minyard.
DEPOSITION INDEX
le
ITEM
11
12
Stipulation Page
.4
Examination by Mr. Leatherwood
13
Jurat Page
14
Certificate Page
15
Errata Sheet
PAGE
47
48
49
16
STIPULATIONS
It is hereby stipulated and agreed by and

between the parlies hereto, through their respectrve
attorneys, that the deposition of MICHAEL BERG may
be taken on behalf of the Plaintiff on May 12th,
2016 in the City of Lavvton, Oklahoma by Steve
Plumbtree, Certified Shorthand Reporter withirt and

for the Slate of Okfahoma, taken by notice pursuant
to the Federal Rules of Civil Procedure.
Assistant Anomey General. 313 Northeast 21st

8
Page 4
le
It is further stipulated and agreed by and
11
12
13
attorneys, that all objections, except as to the

form of the question and the responsiveness of the
14
answer, are reserved until the lime of trial, at
15
which time they may be made with the same force and
16
effect as if made at the time of the taking of this
17
deposition.
18
17
19
18
19
20
20
21
21
22
22
23
23
24
24
25
25
Page 5
Page 3
1
EXHIBIT INDEX
EXHIBIT
20
Plaintiffs
Plaintiffs
Plaintiffs
Plaintiffs
Plaintiffs
Plaintiffs
Plaintiffs
21
22
22
27
37
39
44
5
6
7
8
9
10
PAGE
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Number 2
Number4
Number 7
Number 8
Number 5
Number 9
Number 10
MICHAEL BERG,
having been duly sworn, testified as follows:

EXAMINATION
BY MR. LEATHERWOOD;
Q. All right. Yourname is Mr. Berg?
A-
Q. Michael Berg?
Yes.
A.
Q. And you understand that this is a civil
10
Yes.
rights lawsuit and you are the defendant?
11
11
A.
12
12
Q. And that I'm a plaintiff in that lawsuit?
13
13
A.
14
14
Q. Okay. And you are represented by an
Yes.
Yes.
15
15
16
16
attorney?
A.
17
17
Q. And your attorney is present?
Yes.
18
18
A.
19
19
Q. Okay. You are a citizen of the State of
20
20
21
21
22
23
22
23
24
24
25
25
Yes.
Oklahoma?
A.
Yes.
Q. Okay. What is your title at the Lawton

A.
Assistant warden of finance and
administration.
Plumbtree Reporting

Michael Berg
May 12, 2016
3 (Pages 6 to 9)
I.
Page 6
1
2
3
4
5
6
payroll for the facility, accounts receivable.

accounts payable.
A.
Q. Okay. Okay. Now, does the Lawton
Correctional Facility receive - generate any

revenue from the sale of commissary items that are
sold to the medium-security inmates?
A. No. Not the facility itself, no.
8
9
You are just the book guy?
Correct.
4
5
Q. Okay. So do you have any responsibilities

related to security? Or is it alljust financial?
8
9
Q. Okay. The facility does not receive okay.

But the Lawton Correctional Facilityis paid a
10
commission on the sale of commissary items, is that
11
correct?
14
Q. Just the financial- Okay. What is your

role related to the commissafy services that are
provided at Lawton Correctional Facility?
A. Mainlya facility liaison with the
15
commissafy since we contract with them. So if
IS
16
there's any issues with the commissary, they go

through me if we have any issues over it. 1have to
look at those issues on what we are going to sell.
16
18
who's in control of that - is it an account? Would
Q. Okay. So when it comes to the commissary.

are you their supervisor, the Keefe supervisor? Is
19
that be accurate that it's an account?
20
21
that your responsibility to supeA/ise the Keefe
21
22
staff members?
22
10
11
12
13
17
18
19
23
24
L.
Q. Okay. Can you tell us what you do
generally under that title?

A. 1manage the money for the facility. So
any kind of finances. Work with the trust fund,
Page 8
25
A.
A.
Just financial.
No,
Q. No. But you are just--you just work to

solving problems. If they have a problem here, they
12
13
A. No. All commissions go to the Offender

Welfare Fund. Inmate Welfare Fund.
THE REPORTER: Can you say that again?
14
17
20
THE WITNESS: Inmate Welfare Fund.

BY MR. LEATHERWOOD:
Q. Okay. So is the Offender Welfare Fund.
A. It's an account, yes.
Q. Okay. It's an account titled the Offender

Welfare Fund. And who's in control of that account?
23
A. The facility.
24
Q. The Lawton Correctional Facility?
25
A.
Yes.
Page 7
going to come to you first and foremost?
Page 9
1
Q. Okay. And who oversees that?
A.
Q. Okay, Do you own stock in GEO?
Q. Okay. You do. So why do you say that the
A.
Lawton Correctional Facility doesn't receive revenue
Q. No. Do you own stock in Keefe?
A.
from the sale of commissary if it does receive that

12 percent commission?
A. Because it doesn't belong to the Lawton
Correctional Facility,
1
2
A.
7
8
9
Yes.
No.
No-
Q. Okay. Do you receive any kind of bonus or

performance pay related to the financial success of
7
8
9
1 do.
Q. Who does it belong to?
10
A.
The offenders.
11
MR. POPE: Object to that question and

direct you not to answer that.
11
Q.
The offenders own the account? Or I'm
12
BY MR. LEATHERWOOD-.
12
10
13
14
15
16
Q. Okay. Do you receive any financial bonus
or incentive pay based on the financial success or

finances of Keefe, the commissary services at Lawton
17
A.
18
Q. Are you familiar with the security
No.
13
confused. I'm trying to make sure

A. That money is per policy is only available
14
for use for the offenders of this facility.
15
16
Q. Okay. Is there a specific policyabout

that?
17
A.
18
Q. Do you know what that policyis?
Yes.
A. No. Not off the top of my head.

Q. Is it a Department of Corrections' policy
19
classifications that offenders are classified as
19
20
maybe a medium-security offender or a
20
21
maximum-security offender? Do you know the
21
22
differences between those?
22
A.
23
Q. It is a Department of Corrections' policy.
23
24
25
A. Vaguely.
Q. Okay. Again that's not reallysomething

that you deal with, right? Because--
or is it -Yes-
24
Okay. What are the funds that are deposited in the
25
Offender Weifare Fund used for?
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Michael Berg
May 12, 2ei6
4 (Pages 10 to 13)
Page 10
1
2
3
A. Mostly recreational Items for the facility.

So the basketballs, racquetballs. ping pong balls,
board games for the housing units.
Page 12
1
group of offenders-
Q. If there wasn't an Offender Welfare Fund,
and if there wasn't a commission being generated
Q. Uh-huh.
from the sale of commissaryitems, how wouldyou
A. Things of that nature.
fund ping pong balls and basketballs?
0. Okay. Do you know generally how much money
A. Great question. 1don't know. 1haven't
is deposited in the Offender Welfare Fund from the
had to do that.
commissary commissions on a monthly basis?

A. Not off the top of my head.
Q. Okay. To use the funds from the Offender

Welfare Fund, does that require authorization or do
yoj authorize that yourself?
A. i authorize that myself.
9
10
Q.
11
A. About 17,000 1would say just off the top
12
Plus or minus about $20,0007
9
10
my head.
11
12
Q. Okay. So you don't have to receive

authorization from the facility administrator?
Q. Okay. 1would agree with that. That's
13
14
probably about accurate. So $17,000 a month.
14
15
15
16
$17,000 a monthworth of ping pong balls? Are there

anything else that it's spent on other than ping
16
sign, yesQ. Okay. I'mjust trying to wrap my mind
17
pong balls and basketballs?
17
around -- again, 1don't know exactly, but the most
13
18
A.
19
20
Yes.
A. All of our purchases, we do have the warden
18
recent Offender Welfare Fund statements that 1 have
Q. What are some of the other items? I'm
19
26
22
asking you to provide as expansive of a

A. 1mean 1don't know everything off the (op
of my bead. The cable for the facility, for the
indicate, you know, like 1said, maybe $17,000 a

month. It's hard for me to digest that you are
spending $17,000 a month on cable and pink pong
22
balls. Does that money accumulate in there? I mean
23
cells, for the pods. That's taken out of there.
23
does it accumulate a large balance?

A. 1mean there's a balance there, yes, sir.
Q. Okay. Well, so what you are saying is the
21
24
Q. Okay.
25
A.
1 would have to look for
21
24
before 1
25
Page 13
Page 11
1
2
3
answered any others.
Q. Okay, Computers? Does it buy computers
for classroomsor anything likethat?

1 would have to look to see.
offenders own that account. In fact that's the
2
3
words that you used. Something to that effect.

right? Can the offenders direct how that money is
spent?
A.
Q. Okay. Televisions?
A.
Q. Okay- Microwaves?
A.
Q. And who owns those microwaves and the
Yes.
Yes.
le
televisions?
10
11
A. They belong to the offender population.

They don't belong to GEO.
11
12
13
Q. If GEO sold the facility to CCA, would they
that?
leave those televisions here?
14
15
16
17
A. Ifthere were still DOC inmates here, yes.

Q. When a DOC inmate discharges, does he take
the television with him? I m not trying to be
18
sarcastic, but --
18
17
19
A.
20
Q. Well, you said he owns it.
20
A. 1said as a whole. I mean they are
21
21
or not though?
A. 1would have to look at the policy.
Q. Okay. Okay. When Keefe wants to add or

omit commissary items, are you the first contact on
15
No-
Q. 1mean you said they own it. And if they

own it, then maybe the offender population would
like to spend it on certain things. And you
think -- you don't know if that would be authorized
13
12
14
16
A. I'd have to look at the policy.
19
A.
Yes.
Q. Okay. And they would come to you and say.

hey, we want to take this off or put this on. And
then what would you do?
A.
Tal<e it to the warden to see if it would
create any kind of issue on the facility.

Q. Okay. Are you familiar with the contract
22
welfare items are as a whole for the population. So
22
that Keefe has with the Lawton CorreCTional
23
if DOC closes the facility and every Oklahoma inmate

went to another facility, those items go with the
offenders. Not with a particular offender, with the
23
Facility?
24
A.
25
Q. Okay. Would you agree that that contract.
24
25
A little.
Plumbtree Reporting
(405)620-6272 - plumbtreereporting^gmail.com - www.plumbtreereporting.cotn

Michael Berg
May 12, 2016
5 (Pages 14 to 17)
Page 14
Page 16
the language of the contract, intends for the
Q. Okay. And now they have put a bunch of
commissary at the Lawton Correctional Facility to be

comparable in the variety of items and the pricing
items back on that have a bunch of sugar, right?

A. 1couldn't tell you off the lop of my head.
that are available to medium-security offenders at
But
Department facilities?
Q. Uh-huh. Okay. Since you've said that you
are kind of the go-between, are you familiar with
let's see. we've got it in an exhibit here. Are you

familiar that the Ramen noodle soup that is sold to
inmates, it's the Maruchan brand Ramen noodle soup.
Are you familiar with that?
A.
Yes.
11
Q. Okay. Do you think that currently the

commissary at Lawton Correctional Facilityis
comparable in the number and variety of items and in
pricing to thai available to medium-security
offenders al the Oklahoma Department of Corrections'
12
facilities?
7
8
9
le
8
9
10
11
12
A.
A little. 1 mean 1 know we sell Ramen
soup.
13
A.
14
Q. And that's your current belief?
14
the Oklahoma Department of Corrections for 21 cents.
A.
15
The Departrrent then has some markup on it and it's
15
Yes.
13
Yes.
Q. Okay. That Ramen soup is sold by Keefe to
16
turned around and sold back to the offender base at
17
Q. When was the last lime that you reviewed

the Oklahoma Department of Corrections' commissary
17
either 26 or 27 cents. 1 think it's 27 cents. That
18
menu?
18
identical product Keefe sells lo the inmates at
19
24
Lawton Correctional Facilityfor 60 cents. Would

you believe that is comparable?
A. Again, every year we're audited by DOC and
they said -
Q. What do you I'm asking your opinion.
what you believe as the warden of this facility. Do
25
you believe that's comparable? Not what the
16
19
20
A. The entire menu? 1haven't in years.

Q. Okay. In years. When was the last time
20
21
that you reviewed the entire Lawton Correctional
21
22
Facilitycommissary menu?
A. It was last year.
Q. Okay. You haven't reviewed the Department
of Corrections' commissary menu in years, but you
22
23
24
25
23
Page IS
Page 17
think that Lawton Correctional Facility's menu is
comparable in the variety of items and pricing. How
A.
would you be able lo make thai determination if you
Q. You believe 100 percent more - 100 percent
haven't reviewed their menu in years?
S
6
7
A. We're audited annually by the Department of

Corrections.
you?
A.
10
11
12
Q. Right. And you just rely on them to tell
8
Yes.
Q. Okay, So if they tell you that you are

good 10 go, then you just rely on that?
A.
10
11
Yes.
14
15
16
Facility and directed Ihem to remove items from the

commissary menu?
A. Probably.
16
18
Q. Okay. And when you did so, why were you
19
20
21
22
23
24
25
doing that?
Yes.
A.
1 don't know.
Q. In your opinion, would 200 percent markup

be comparable?
A.
contacted the Keefe staff at the Lawton Correctional
19
A.
Q. What wouldn't be comparable? Ifsomething

was marked up 200 percent would that be comparable?
Would that be okay?
guess.
15
18
difference in price you believe is comparable?
13
14
17
Yes.
12
Q. Okay. Okay. Have you recently, in the

past six months or in the past year, have you
13
Department of Corrections says.
1 would have to look at it at the time 1
MR. LEATHERWOOD: Can we take a break for a
minute? 1need to go to the restroom.

MR. POPE: Sure.
17
(RECESS)
MR. POPE: Back on the record?
MR. LEATHERWOOD: Yeah, we're back on the
20
record.
1 believe that was when we did our menu
21
BY MR. LEATHERWOOD;
review and we removed some items containing sugar.
22
A.
0. Okay. And those were for security

purposes?
A.
Yes, sir.
Q. To determine if something is comparable or
23
not as far as a price, do you have a formula that
24
you use to corrpare that?
25
A.
Plumbtree Reporting
1 don't

Michael Berg
May 12j 2616
6 (Pages 18 to 21)
L.
Page 20
Page 18
1
2
3
4
5
6
7
Q. Do you know who does have a formula?

A. DOCwhen they audit us.
Q. Okay. So for the purpose for our
A.
Q. Okay. There's an exhibit. 1want you to
purposes here, you are relying wholly on DOC saying

eveiything is good to go. And so as long as they
say it's good, you're good with it?
A.
Yes.
No.
see this.
MR. LEATHERWOOD; Exhibit Number 3.
MR. POPE: Okay.
6
7
BY MR. LEATHERWOOD:
Q,
Exhibit Number 3 is titled GEO Exhibit --
Q. Okay. When you are considering whether or

not the price of a commissary item is acceptable or
reasonable, do you factor In any security objective
10
it here.
11
to that? Does the price of commissary relate to
11
BY MR. LEATHERWOOD;
12
security objectives?
12
9
10
what is it called? GEO Exhibit
13
14
A. Not to my knowledge.
Q. Okay. So it's not a security issue?
IS
What about considering the same thing. When you
15
MR. LEATHERWOOD: Let me see if 1 can find
Q. The highlighted portion of that it says.
16
are considering the price of a commissary item and
16
17
18
determining whether it's an acceptable or reasonable

price, is there any rehabilitative (actor being
18
"KCN," which is commissary KeefeCommissary

Network, "will work with GEO to keep pricing to the
inmate population low and comparable to Oklahoma
Department of Corrections" pricing."
Without knowing what the Oklahoma Department of
Corrections' pricing is. how can you comply with
19
considered in that?
19
that section of that exhibit?
20
20
24
A.
Q.
in the
A.
Q.
25
being served by the price -- through the price of
13
21
22
23
14
What do you mean rehabilitative?

Well, does the price of commissary assist
rehabilitation of the offender population?
Not to my knowledge.
Okay. Is there any penological objective
17
21
A. i'm audited annually.

Q. Do you consider it your responsibility to
22
comply with this contract? This? Or it DOC'S?
23
A,
24
Q. Okay. But you defer to DOC?
It's mine.
25
A. Yes. We're audited. We passed.
Page 19
Page 21
commissa/y?
Q. Okay. So it's just not something you would
consider then because you
Q. So - and I'm not trying to be

argumentative. What 1want to be clear on is if DOC
says it okay. I'm going to go with whatever they
A.
say. Is that basicallywhat you are telfing us?

A. No. But if what we're doing is passing
Q. Okay. And arc you familiar that the
audits and okay, then what is there to change?
commissary prices were just increased again
recently? April 18th.
A.
Q. Okay. You are familiar with that. Okay?
9
le
11
12
A.
No.
Yes.
Q. Okay. And who authorized that? Did you

authorize that?
A.
Q. Okay. Haveyou seen this document before?

Yes.
10
A.
Yes.
11
Q.
How about the Exhibit Number 2? Which is
Yes-
12
the Keefe Commissary Network agreement. Are you

familiar with that?
13
Q.
Okay. Did Warden Rios authorize that?
13
14
A.
Yes.
14
A. I've seen it, yes.
15
Q. Okay. When y'all authorized it did you
15
Q. You've seen that before? Okay, is that --
16
question the price increase at all? Or did you just
16
that contract or that agreement, it also states that
17
say, hey, that's what Keefe wants to do, let them
17
18
have their way?
18
pricing will be agreed upon between the institution

and <eefe. And so you're aware of that right?
19
20
21
A.
We reviewed it. I( exorbitant so we
posted It to the population.
19
20
Q. Okay. And when approving the most recent
21
A.
Yes.
Q. So you agree that you and/or the facility

head are responsible for the pricing of commissary?
22
price increase that was effective April 18th of
22
A.
23
23
Q. Okay. So if the commissary items are found
24
2016, when you approved that did you take into

account the Department of Corrections' pricing on
24
to be unreasonable, then you -- it would be your
25
the same or similar items?
25
responsibility. You are the one that would have
Yes.
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(405)620-6272 - plumbtreereportinggmail.com - www.plumbtreereporting.cora

Michael Berg
May 12, 2016
7 (Pages 22 to 25)
Page 22
1
approved that or agreed to it right?
A.
Q. Okay. Okay, Then Exhibit Number 4 is a
Page 24
Yes.
service provider agreement between Keefe and GEO

Group. Are you familiar with that?
item, do you think that that's equal treatment?
A.
Q. What if that inmate had to pay $2 for that
identical item? Would that be equal treatment?

A. Are the commissaries run identicaify at
both facilities?
Yes,
A.
Q. Okay,
Q.
Is commissary run ider>tical?
A.
I've seen it.
A.
Yes.
Q.
You've seen it before?
9
10
11
12
13
A little.
10
Q. Okay. Do you know if Warden Rios is
11
familiar with those documents?

A.
A. Well, 1can only explain how we run a
15
commissary here.
Q. Okay. But what I'm in reference -- what
I'm getting at is the price of that product. You
are saying that it's equal for one inmate to have to
16
pay -
12
1do not know.
Q. 1don't understand. Expand on that please

so 1 can understand.
13
14
16
Q. You do not know? Okay. This Exhibit

Number 7 is the commissary menu at Joseph Harp
Correctional Center. Okay? And 1received this
17
through an Open Records Act. 1don't know how
17
A.
18
reliable it is or not. We've discussed that
18
Q. What do you mean by the service levels?
19
earlier.
19
A. Well, we bag and deliver cell to cell.
14
15
20
8ut assuming that it's reliable, and Keefe
Are the service levels the same?
20
Q.
21
A. That's how we operate this facility.
24
sells do you think it's okay for Keefe to sell

their private-label products to the medium-security
inmates at Department of Corrections' facilities at
one price and sell the identical private-label
25
product to inmates at the Lawton Correctional
25
21
22
23
22
23
24
Uh-huh,
Q. Uh-huh, So but again, the price of the

item, you think that that's equal? And I asked this
a minute ago. but 1want to kind of take it a
different angle. Is there any price if an
Page 23
1
Facility at a higher price?
A.
Q. You think that's okay?

Q. Are you familiar with - and I'm not -
4
5
Yes.
Page 25
1
inmate, a medium-security inmate at a Department of
Corrections' facility pays 27 cents for an item, is
there any price that would be unreasonable for an
inmate at Lawton Correctional Facility to have to

pay for the identical item?
last time not asking for a legal opinion. But are
you familiar with equal protection?

A. Not really, no.
Q. Okay. Do you believe that inmates are
9
10
11
12
13
entitled to be treated equally as other inmates that

are classified the same as they are?
A.
Sure.
8
9
10
11
Yes.
MR. POPE; 1 think this calls for
speculation on what --1 think he's answered that if

there's some differences in operation, that may be a
factor to be considered.
And in essence if you are just asking him to
14
speculate as to when it becomes urireasonable, then

we would object to that.
MR. LEATHERWOOD; All right. Well, 1was
15
asking for his personal opinion.
12
Q. Okay. So you believe that a
A.
13
16
medium-security inmate, which is a state

classification, you believe that a medium-security
inmate at Lawton Correctional Facility should be
16
17
treated equal to a medium-security inmate at the
17
MR. LEATHERWOOD: Of when.
18
Oklahoma Department of Corrections' facility, is
18
19
that correct?
19
MR. POPE: And that's still speculation.

MR, LEATHERWOOD: Okay.
MR. POPE: Okay?
14
15
20
A.
21
Q. Okay. Would you agree that if the inmate
21
BY MR. LEATHERWOOD:
22
22
23
Q. Okay. Are you aware that the commissary

menu at Lawton - at Department of Corrections
24
at the Oklahoma Department of Corrections' facility

is able to purchase an item at 27 cents and the
medium-security inmate at the Lawton Correctional
24
includes
25
Facility has to pay 60 cents for that identical
25
23
20
MR. POPE: Okay.
Yes.
MR. POPE: Which exhibit are you looking
Plumbtree Reporting

Michael Berg
May 12, 2016
8 (Pages 26 to 29)
Page 26
1
at?
MR. LEATHERWOOO; Well, Exhibit 7 is the
Page 28
1
A.
Q. Okay. Do you understand the concept of
Yes.
people being similarly situated?
menu.
BY MR. LEATHERWOOD:
A.
Q. Okay. And are you familiar with the equal
Q. Let me ask you this. At Lawton
Yes.
Correctional Facility, beverages are available
protection clause of the 14th Amendment of the
through commissary to be purchased in cans, is that
United States Constitution?
correct?
10
A. 1think so, yes.
Q. And there are no beverages that are
MR. POPE; Objection, already asked and

answered.
le
BY MR. LEATHERWOOD:
11
available to be purchased in reseslable bottles. Is
11
12
that correct?
12
13
A.
13
Q. Do /ou believe that the equal protection

clause applies to inmates in prison facilities?
MR. POPE: Objection, calls for a legal
14
14
conclusion which he is not qualified to answer
15
Q. Olcay. Do you know why?

A. Not off the top of my head, no, 1don't
15
BY MR. LEATHERWOOD:
16
Q. Okay. Did you know that the offender
16
17
population, medium-security offenders at the
17
18
Department of Corrections, are able to purchase

beverages in resealable bottles and not in cans?
18
21
Q. Okay. 1don't know that you can answer

these questions because it seems to be maybe outside
of your abilities. But 1need to ask them just to
make sure that they are on the record here.
Does the higher price of commissary items at
Lawton Correctional Facility versus the price of
22
similar and identical commissary items at the
23
Department of Corrections sen/e any security

objective?
19
26
21
22
23
24
25
A.
Correct.
No. Like 1 said, 1 haven't seen a menu
from another facility -Q. In years?
A. in years.
Q. Okay. Were you aware that let me ask
you. Can the inmates at Lawton Correctional
19
20
24
25
A.
No. not that I'm aware of.
Page 29
Page 27
Facility purchase frozen foods such as sausage and

biscuits, burritos, pizza, chimichangas, things that
are frozen?
A.
Q. Okay.
A. - don't know off the top of my head.
Q. Okay. Vou don't know if they can or not.
6
7
8
9
le
1 don't have the menu memorized, so 1
Okay.
Prior to today, did you know that Keefe was
selling private-label products to DOC?
11
A.
12
Q. You did not know that. Okay. Let me ask
13
14
15
16
17
No.
you about these exhibits.
Exhibit Number 7 is the Department of

Corrections' menu.
And Exhibit Number 8 is the Lawton Correaional
Facility menu.
2
3
Q. Okay. Does the higher price of commissary

items at Lawton Correctional Facilityversus the
price of similar and identical commissary items at
Department of Corrections sen/e any rehabilitative
objective?
6
7
8
9
10
11
A.
Q. Does the higher price of commissary items

at Lawton Correctional Facilityversus the price of
similar and identical commissary Items at Department
of Corrections' facilities serve any penotoglcal
objective?
12
A.
13
Q. Okay. Does the Oklahoma Department of
14
Corrections receive any money from the sale of
IS
commissary items at lawton Correctional facility?
16
17
A. Read that again?

Q. Does the Oklahoma Department of Corrections
18
receive any money from the sale of commissary items
19
coffee for $4.20 that the sell to the Lawton
19
at Lawton Correctional Facility?
29
Correctional Facility inmates. The exact same
20
21
identical product, Keefe's private-label coffee is
21
A. Like 1said, the profit goes in a welfare

fund which belongs to the Oklahoma Department of
22
sold at DOC for i3.31. It's 89 cents different for
22
Corrections' offenders. I'm not sure how to answer
23
the identical item.
23
that question.
MR. POPE: If 1may, I'd like to enter
MR, LEATHERWOOO: It's a yes or no.
18
24
25
Keefe has a -- their private-label Columbian
Again, do you think that that is equal

treatment?
24
25
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Michael Berg
May 12j 2016
9 (Pages 30 to 33)
Page 32
Page 30
MR. POPE; If 1may?
MR. LEATHERWOOD: Yeah, go ahead.
MR. POPE: Just a general objection to your
1
2
3
4
last --
1
2
3
4
MR. LEATHERWOOD: Go ahead.
MR. POPE: three questions that there
was a presumption or a statement of a higher price
at LCF versus DOC. 1would just offer an

observation that that was a presumption of the
question as opposed to an actual finding of facL if
you will.
10
11
from it, you don't care?

A. 1don't think that's the way to put it
Q. It's not " you are exactly right. That

wasn't worded very well. You don't have a vested
interest according to you, in the price of

commissary items at Lawton Correctional Facility?
A. 1mean it's part of my job to monitor the
commissary. So if you mean it that way, then it's a
part of my job to -
10
Q. Well, no. What I'm getting at is you're
11
saying that the Lawton Correctional Facility does
12
MR. LEATHERWOOD: Based on the information
12
not received money. They -- a part of their revenue
13
13
is not derived from the sale of commissary items.
16
that 1have prowded

MR. POPE: The presumption of your question
based ort those two documents, yes.
MR. LEATHERWOOD: Sure There's no problem
16
responsibility to our shareholders, it doesn't
17
with that
17
increase shareholder value --
14
15
MR. POPE: Okay.
18
19
20
BY MR. LEATHERWOOD:
Q. Now, the instant question is -- and again.
14
A.
15
Q. Therefore, as far as we don't have
Correct.
18
A.
19
Q. it doesn't make more profit for the
26
Correct
Lawton Correctional Facility, it's irrelevant

effectively?
21
I'm not trying to be difficultwith this. It's a
21
22
yes or no. It's a pretty simple question. Does the

Oklahoma Department of Corrections receive any money
22
A.
23
23
Q. Okay, But you use the money, that
24
from the sale of commissary items at Lawton
24
12 percent commission,you use that to provide items
2S
25
that are used at the facility. TVs, microwave, ping
Correct,
Page 33
Page 31
1
MR. POPE: 1believe that's already been
asked and answered. He said he didn't know.
MR, LEATHERWOOD: Well, he did answer. He
A. For the offender population.
Q. Okay. For the offender population. And if
there was no commissary at all, then Lawton
BY MR. LEATHERWOOD:
Q. What I'm asking is the Oklahoma Department

of Corrections as an agency. As an entity.
Correctional Facility would still buy ping pong

balls and TVs, but they would buy it out of your
probably your general fund? Your operating account?
said, well, it belongs to the offenders.
5
6
7
pong balls.
A.
That's a no.
Q.
The answer is no.
A. Yes. Since I've been here, we've always

had the welfare fund to be able to provide those
10
A. To my knowledge, no, 1rrean
10
items. So I'm not sure where that would come from
XI
Q. Okay,
11
in that instance.
12
A.
12
-- like 1 said.
Q. Okay. Okay. The Offender Welfare Fund at
14
lawton Correctional Facility, it's separate from the

Offender Welfare Fund at the Oklahoma Department of
or rehabilitative or penological objectives, is it

then just a business matter? 1mean it needs to be
this price for our business to be successful?
A. For Keefe, yes.
15
Corrections, correct?
22
Q. for Keefe, Right?

Since the Lawton Correctional Facility doesn't
receive - according to you, since the Lawton
Correctional facility does not receive any money
23
from the sale of commissary, why would you even care
23
24
what the price is? Would that be accurate? 1mean

you guys don't care? Since you don't receive money
24
13
14
15
16
17
18
19
20
21
25
Q. So the price of commissary items at lawton

Correctional Facility, if it's not based on security
13
16
A.
17
Q, Okay. Theyhave an OffenderWelfare Fund
18
19
that they use for whatever they do. Youguys have

one at this facility only lor this facility and you
26
guys control the hjnds on that?
21
22
25
A.
Correct.
Correct.
Q. Okay. Does any staff receive compensation

or salary from the Offender Welfare Fund? Does it
pay for anyone?
A.
No.
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Michael Berg
May 12j 2016
10 (Pages 34 to 37)
Page 34
1
2
Q. No. It doesn't pay for anything like that.

Okay. Now, Keefe, they are responsible for the
Page 36
1
Number 6, and again assuming that Exhibit Number 7
is authentic and accurate, would you agree or

disagree that Exhibit 7 is comparable in the variety
of items to Number 8? Are they comparable or not?
cotnmissaiy operations. They are not responsible for
security or rehabilitation. Would that be correct?
A.
Q. Okay. So they are here to make money.
Correct.
mean they are a business in business to make money,

and certainly they want to make a pro^t is that
correct?
le
11
A.
1 mean 1 haven't had a chance to--
Q.
Take a look. There it is.
A.
to look. But--
So what was your question again?
A. To my knowledge, yes.
Q. Okay. And so assuming that Keefe wants to
10
11
Q. My question is. is do you believe that the
Department of Corrections' menu let me slate it

another way. Okay. Do you believe that the Lawton
12
make a profit then they're pricing their products
12
correctional Facility menu is comparable in the
13
so that they can -- with the objective of making
13
variety of items as are offered on the Department of
14
profit?
14
Corrections' menu?
15
A.
16
15
A.
Q. Unrelated to security or rehabilitation?
16
Q. Okay. On the Lawton Correctional Facility
17
A.
17
menu, which Is Exhibit 8. how many frozen food items
18
0. Okay. I'm trying not to belabor this point
18
are available on that menu?
19
and 1apologize. But the Offender Welfare Fund
19
A. 1wouldn't know without looking.
20
belongs to the Inmates. And the items purchased
26
Q.
There it is.
21
through that whether it be televisions or things of

that nature, you say belong to the inmates?
A. In a sense, yes.
Q. In a sense. What do you mean?
A. Because it's a group of people. It's not
21
A.
So It looks like ice cream.
22
23
24
25
1 would assume so.
Correct,
22
Yes.
Q. Okay. One. And on Exhibit Number 7. which
23
is Department of Corrections' menu, frozen foods
24
there's 18. Okay? Now, we've already determined

that 27 cents and 60 cents are comparable in your
25
Page 37
Page 35
1
2
3
4
5
6
7
necessarily it belongs to you as an inmate, but as

the population as a whole.
Q. It belongs to them all. Okay. As a whole.
But those items are owned by the Lawton Correctional

facility?
A. No. We're not purchasing them.
Q. That's a difficult concept For me anyhow.
I'm not familiar with that concept so I'm having a
hard time. Thai's why I'm asking the questions. 1

was trying to gain a better understanding of that
Do (he televisions and microwaves and ping pong
balls ar)d whatever else that you purchase through
10
11
12
13
14
15
16
17
18
19
20
21
22
the Offender Welfare fund, those are - they are

minimal, but they are assets, is that correct?
A.
Yes.
Correct
Q. They are assets of the offenders.
Okay. Outside of the audit 1know the audit

was conducted 1think just maybe six months ago.
sometime -- it seemed like it was September or
A.
Yes.
Q. Okay. Exhibit Number 5, Mr. Berg. These

are items that were removed from the commissary 1
guess in -- what would that be, November, You are

familiarwith that right?
7
8
9
10
A,
Yes.
Q. Do you know why they were -- why those

items were removed from the commissary menu?
A. The sugar content
11
Q. Because of the sugar content.
12
A. With the exception of the toothbrush and
13
the dental -- the dentist here wanted the medium
14
toothbnjsh removed.
16
Q. Okay. So the dentist influenced the

commissary menu?
17
A.
18
Q. Had them remove the toothbrush. These
19
items were removed because of the sugar content.

What was the problem with the sugar content?
20
Yes.
21
A.
22
Q. What was your concern with the sugar
23
October. 1 don't --1 can't remember when the last
23
24
audit was. Outside of that audit if you review in

this Exhibit Number 7 and then reviewing Exhibit
24
25
view. Is one and 18 comparable as well?
15
Q. But they are not assets of the Lawton

A.
25
What --
content?
A. They're concerned with the sugar content

The amount of hooch that we were at the time.
Plumbtree Reporting
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Michael Berg
May 12, 2016
11 (Pages 38 to 41)
Page 38
Page 40
Q.
The amount of what?
A.
Homemade alcohol.
more along your lines. The offender population pays

for commissary purchases through their trust fund
account, is that correct?
Q. Homemade alcohol. Okay.
A. Sorry.
A.
Correct.
Q. Offenders use foods with high sugar
Q.
Who controls the trust fund account?
A. The facility.
Q. Lawton Correctional Facility?
cor^tents to make alcohol?
A.
Correct.
Q.
Is thai correct? And so those items were
A.
Q. Okay. Now. that account does not belong to
10
the offenders? Or it does? Or how does that work?
removed based on that?
10
A.
11
Q. Okay. Would you know why those items, some
Yes.
11
Yes.
A. The trust fund account is mostly made of
12
of those items are available to be purchased at
12
individual vendor accounts. So it's one checking
13
Oklahoma Department of Corrections? Are they not a

security issue there? They are a security issue
13
account, but then the software divides it up. you
14
know, 2600
14
15
17
here at Lawton Correctional Facility, but they are

not deemed a security issue there?
A. 1don't have any idea about other
18
facilities and their -
19
Q. Right. Right. 1understand that. On the

holiday, one of the items that was removed is the
Frosted Flakes cereal. You guys consider that, 1
guess, because of the sugar content again be a
security issue. Bui the Frosted Flakes are
19
24
available to be purchased by Department of
24
25
Corrections' facilities.
25
15
16
26
21
22
23
16
Q. Right. Each one has their own-A. Right.
17
Q.
18
A. Right.
20
21
22
23
--number in there.
Q. Okay. And the Lawton Correctional Facility

operates the trust fund account. Now. when an
offender places a commissary order, they complete an
order form and they provide it to Keefe. Keefe

processes that. Do you know what the process is of
them processing that order form?
A. Yes. They scan it into the same software
Page 39
1
The Oklahoma holiday 2015 menu, I'm going to

enter this as Exhibit that will be Exhibit 9?
MR. POPE: Okay.
3
4
BY MR. LEATHERWOOO:
Page 41
1
2
and then it deducts the money from the offender

account at the time that order is processed.
Q.
So Keefe scans it into that account?
A.
(Witness nods head)
Q. Are you familiar with this?
Q,
Is that correct?
A.
A.
Yes.
7
8
9
Some.
Q. Okay. The same Frosted Flakes cereals that

were removed from the commissary is available to be
purchased on this menu that was distributed by the
8
9
Q, Okay. So Keefe has access to the

offenders' trust fund accounts?
A. Through the commissary ordering system.
facility to the offender population. Why was the
le
yes.
11
Frosted Flakes considered a security issue and
11
12
removed from the commissary but available to be
12
Q. Okay. And they charge offenders and

then " so they have access to that account and they
13
purchased on this special purchase?
13
can charge it debit it credit it whatever?
10
14
A.
1 don't know.
14
A.
15
Q.
Is that correct?
16
A.
Yes.
17
Q. Okay.
18
A. For commissary purchases, yes.

Q. And is that done through a computer system
21
Q. You don't know. Who's responsible for

overseeing or authorizing the holiday package? The
201S holiday package.
A. Off the top of my head, I'm pretty sure
it's a DOC-led program that we review in the
facility and then distribute to the population.
Q. Okay. Could you tell DOC that you didn't
22
want to do this?
22
15
16
17
18
19
20
23
24
25
A.
I'm sure we could.
Q. Okay. Okay. Let me ask you about how

commissary items are paid for. This is probably
19
20
21
23
24
25
Correct.
in their office?
A.
Yes.
Q. Okay. They don't have--do they have to

get your approval before they do that? Or do they
just have broad discretion over how they access the
account as long as it's related to commissary?
Plumbtree Reporting
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Michael Berg
May 12, 2016
12 (Pages 42 to 45)
v..
Page 42
Page 44
A. 1mean generally 1mean that's the way the

system Is set up so they have had approval for it.
But on a week-to-week basis, no. 1do not.
MR. LEATHERWOOD: Number 10.
Q. Okay. Do you know who approved that? That

a (hird-party vendor would have access to the
MR. POPE: Have you - is that correct?
offender's trust fund accounts?
MR. POPE: And go ahead and we'll -- go
ahead and finish that, t don't know what number you

are putting on it.
Okay.
A. The contract.
Q.
MR. LEATHERWOOD: Right. And this is

the " what we're talking about. Exhibit Number 10,
10
The contraa?
is the FY 2014 Correctional Service Contract between
Q. Do you know where in the contract?
10
GEOGroup, Incorporated and the State of Oklahoma
A.
11
Department of Corrections.
12
allows them to process orders.
12
13
13
MR, POPE: Okay. AH right. One last

thing 1would like to put on record and then we
14
have discussed, had a little bit of a discussion
15
Q. Okay. Does your contract with the Oklahoma

Department of Corrections, does it allow you to
grant authority to a third-party vendor to access
15
prior to the depositions that you have filed a first
16
inmates' funds?
16
amended complaint with the Court and then you filed
11
14
17
18
A.
1 mean we have a contract with Keefe that
It allows subcontracts that the DOC
approves, yes.
17
a motion to supplemer^t that. And actually filed a
18
second what the Court interpreted 1think as a
It does allow that. That's correct. But
19
second motion to supplement the complaint And
20
does it anywhere in here allow them to have access
20
Judge " or Magistrate Mitchell issued an order for
21
to the inmates' money?
21
you to file a second amended complaint as opposed

to just trying to supplement your initial.
19
22
23
24
25
Q.
Q. Not to your knowledge? Okay. Okay.
22
23
24
That's reasonable.
In your position as the business warden
2S
In our discussion, it's my understanding that
you have not yet done that. Is that correct?

MR. LEATHERWOOD: Nor do 1intend on doing
Page 45
Page 43
1
basically, right? That would be appropriate. You
don't have any responsibilities related to inmates

that are trans -- laterally transferred into the
facility, out of the facility? That's not something
that you handle?
6
7
8
9
le
11
A.
No.
Q. Your area is handling you're the money
4
5
6
7
8
man?
A.
Yes.
Q. Okay. Okay.
MR, LEATHERWOOD: 1don't have any other
9
10
11
that.
MR. POPE: Okay. Anyway, the pointing
being is that you have not as yet.

MR. LEATHERWOOD: 1have not as of yet
MR. POPE: But you do not have the
intention (o do so?
THE WITNESS: That is correct. Yes, that

is -- that's correct.
MR. POPE: Okay. 1just wanted to make

that of record while we were on the deposition.
There is we're essentially operating off what
12
questions, Mr. Berg. 1appreciate you being here.
12
may be a first amended complaint and a supplemental
13
Thank you very much for THE WITNESS: Yep.
13
14
on that. And although Anyway, but -- and there's been no second
14
15
amended complaint as yet?
16
contract a number of times. The one between --1
16
17
presume between GEO and DOC.
17
MR. LEATHERWOOD: Right. And for the

record, since you wanted to include this in the
15
18
19
20
21
22
23
24
25
MR. POPE: You have referenced this
18
record, as 1stated to you before the deposition
MR. POPE; Did you introduce that as an

exhibit to the deposition?
19
started, it was never my intent to file a second
20
amended complaint.
MR. LEATHERWOOD: 1did not. Ifyou would

fike me to, then 1certainty --
21
MR. LEATHERWOOD: Yes.
MR. POPE: 1think if you have referenced
it it would be appropriate to do so.

MR. LEATHERWOOD: 1agree with that.
MR. POPE: 1 understand.
22
MR. LEATHERWOOD: 1 believe that was a
23
24
misinterpretation because of the sequence of when 1

received documents through the prison facility
25
mailroom. 1had not received the order granting my
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Michael Berg
May 12, 2016
13 (Pages 46 to 49)
Page 46
1
motion to file the first amended complaint
MR. POPE: Sure.
MR. LEATHERWOOD: So that document -
Page 48
1
CERTIFICATE
STATEOF OKLAHOMA )
OKLAHOMA COUNTY )
I, Steve Plumbtree, Certified Shorthand Reporter
) SS:
have since sent a motion to the Court and to you,
both of you, asking her to strike that portion of
Document Number 80 about the second amended
complaint And we'll see how that results.

MR, POPE: Okay. I think that's
appropriate to have that in the record.
10
11
12
13
14
4
5
within and for the State of Oklahoma do hereby
certify that the above-named MICHAEL BERG was by me

first duly sworn to testifyto the truth, the whole
tnjth, and nothing but the truth in the case

aforesaid; that the above and foregoing deposition
was by me taken in shorthand and thereafter
Warden Berg, you have the right to review and

sign your transcript And we need to advise this
guy, and I'm telling him now that we do want to
11
transcribed; that the same is true and correct and
12
review and sign.

THEWITNESS: Okay,
that it was taken on the 12th day of May, 2016 at

the time of 12:00 p.m. in the City of Lavrtoa County
14
of Comanche, State of Oklahoma under the
15
10
13
16
stipulations hereinbefore set out and that I am not

attorney for or relative of any oi said parties or
16
17
otherwise interested in the event of said action.
17
18
18
19
19
20
20
21
15
(DEPOSITION CONCLUDED AT 12:55 P.M.)
21
22
22
IN WITNESS WHEREOF, Ihave hereunto, sfiUU band

and officialseal this 23rd dav of May. 2011
STEVeIiSmWREE. CSR. CP
Oklahoma Certified Shorthand Reporter
Certificate No. 00332
23
23
24
24
25
25
Expires: December 31, 2016
Page 49
Page 47
1
2
JURAT
I, MICHAEl BERG, do hereby state under oath that
I have read the above and foregoing transcript in
its entirety, and that the same is a full, true, and
correct transcription of my testimony so given at
said time and place, except for the corrections
noted.
2
3
ERRATA SHEET
WITNESS: MICHAEL BERG
DATE: May 12th, 2016
REPORTER: Steve Plumbtree, CSR, CP

NO CORRECTIONS ARE NECESSARY
PAGE LINE CORRECTION
MICHAEL BERG
10
10
11
SUBSCRIBED AND SWORN TO BEFORE ME. the
12
undersigned Notary Public In and for the State of
13
on this, the
14
, 2016.
day of
15
11
12
13
14
15
16
Notary Public
18
19
20
21
22
23
16
17
17
18
19
REPORTED BY; STEVE PLUMBTREE CSR. CP
20
21
22
23
24
24
25
25
Plumbtree Reporting
(405)620-6272 - plunibtreereportlng@gmail.com - www.plunibtreereporting.com

Michael Berg
May 12j 2016
14 (Page 50)
L.
Page 50
MEMORANDUM
TO:
MR. DONG. POPE
Don G. Pope & Associates, P.C.

611 24lh Ave SW, Suite 102
Norman, OK 73069
FROM: STEVE PLUM6TREE, CSR. CP
Plumbtree Repoting
17525 Old Pond Rd
6
7
8
9
le
Edmond, Oklahoma 73012-e894
DATE; May 26, 2016

Please have MICHAEL BERG read your copy of his
deposition taken on May 12th, 2016 in the

above-styled case and sign the jurat page before a
11
notary public. Also, make any needed corrections on
12
the enclosed errata sheet and not directly on Che

transcript.
13
20
You have 30 days to return the jurat page and

the correction page to the above address, after
which the deposition will be sealed and fonvarded to
the attorney who took the deposition for use in the
case without the jurat page or the corrections being
attached Co the original deposition.
Tfiank you for your attention and cooperation in
21
this matter.
14
15
16
17
18
19
22
23
24
25
Plumbtree Reporting
Price Comparison Of Keefe Commissary Network,

L.L.C. items sold at Joseph Harp Correctional Center
and Lawton Correctional Facility
Attach. No. 6
KEEFE PRODUCTS
Comparison of identical Keefe products being sold to medium security inmates at

Oklahoma Department of Corrections operated prison (JHCC) and at Lawton
Correctional Facility (LCF).
Price at
KEEFE Product
JHCC
Price at
Price Increase
LCF
at LCF
% of Price
Increase
Keefe 100% Columbian
Coffee 3 oz. bag
3.31
4.20
0.89
27%
1.96
3.45
1.49
76%
2.70
3.10
0.40
15%
1.84
2.20
0.36
20%
Beans - Hot
1.87
2.20
0.33
18%
Brushy Creek Beef Stew
1.90
2.20
0.30
16%
Ramen Chili Noodle Soup
0.26
0.60J
0.34
131%
Ramen Cajun Chicken

Soup
0.28
0.60
0.32
114%
Jalapenos
1.86
2.60
0.74
40%
Sevilla Refried Beans 8 oz.
1.82
2.70
0.88
48%
Thai Palace Noodles Chid

3.7 oz.
0.73
1.00
0.27
37%
Keefe Alturo Blend Coffee
3 oz. bag
Keefe Creamy Peanut
Butter 18 oz.
Brushy Creek Chili with

Beans
Brushy Creek Chili with
Cactus Annies Sliced
Note: This list contains both Keefe private-label products and non-Keefe brand products.
Note: This list may not contain all the commom Keefe products being provided/sold by
Keefe to both DOC and LCF.
Note: The price of the items cited are taken from the Lawton Correctional Facility
commissary menu current as of Arpil 18, 2016, and the Joseph Harp Correctional Facility
commissary menu as of January 20, 2016.
Affidavit of Michael D. Leatherwood
Attach. No. 7
UNITED STATES DISTRICT COURT

MICHAEL D. LEATHERWOOD,
Plaintiff,
CASE NO.
V.
CIV-15-767-C
HECTOR RIOS, et al.,
Defendants.
AFFIDAVIT
I, Michael D. Leatherwood, being of lawful age, duly sworn according to law, depose and
state as follows:
1.
On May 23. 2016,1 forwarded a Request To Staffs to the Commissary Supervisor
at Joseph Harp Correctional Center ("JHCC") seeking to know ifthe price of a number of items
offered by Keefe Commissary Network, L.L.C. had been increased in the past sixty (60) days.
(Request To Staff attached)
2.
Pursuant to Oklahoma Department of Corrections policy, OP-090124(IV)(C)(6) a
Request To Staff will be responded to within ten (10) days of receipt. See OP-090124(IV)(C)(6)
(The staff member assigned will respond in writing within ten working days of receipt to all
"Request to Staff' forms being used to attempt informal resolution.) (Emphasis added)
3.
As of the date of the instant affidavit, twenty-two (22) days have passed since the
Request To Staff was submitted to JHCC. Plaintiff has not received a response to the Request
To Staff.
Respectfully,
MichaeTD. Lâtherwood
DOC No. 595058
Plaintiff, Pro se
8607 SE Flowermound Rd.
Lawton, OK 73501
Subscribed and sworn to before me this
day of
2016.
My Commission Number; /5 /)d^/'9/^

Nqtpry Public
Must Be Submitted Through the Law Library

Offender Grievance Process
REQUEST TO STAFF
(NAME AND TITLE OF STAFF MEMBER]
FACILITY/DiST/UNITi
Tj^rr
DATE: S'^S-/6^
have not_j^ already submitted a-Request to Staff" or grievance on this same issue.
I have
If yes. viât date:
_ facility:
Iaffimi that Ido do not_/ have agrievance pending on this issue. grievance #;
IS request
does
does not relate to a pending misconduct report. If it does this
icimc lu d [jetiuing
misconouct
quest may only be answered^ bv theP investigator
to the misconduct.
in\/cfinfltnr assigned yv
i
^
rpnii=.<st mav Ar>iw
mustte^spUific o
being returned unansSd
issue orincident
.. c.
'
o" ^hich
you desire assistance. This statement
involved, and how you were affected. One
specifically state your problem may result in this
v *^
OR7Sfi/nooS/j^
APTinu DCrt^^
should be done and
SIDE IF MORE SPACE IS NEEDED. DO NOT ATTACH ADDITIONAL PAGES.)
handled; that is, what exactly
70
ACF, Pô^7
y?Â/
DOC NUMBER:
SIGNATURE:
UNIT &CELL NUMBER:(^/]//f
WORK ARRinMMFMT-
A//?P,^py
DO NOT WRITE BELOW THIS LINE

DISPOSITION:
STAFF MEMBER
1. Original to file
2. Copy to offender
RECEIVED DATE
MAY 232016
LCF LAW LIBRARy
^ O IÎP'
AD (R 11/14)
Joseph Harp Correctional Center

Commissary Menu
Attach. No. 8
HfllKWf'SMfOSJIiOW
EXHIBIT
Case 5:15-cv-00767-C Document 104-10 Filed 06/16/16 Page 2 of
18
T3ate\Time: 1/20/2016 2:00:53 PM
ODOC
Institution; JHCC
Institution:
ZL
Price List
Joseph Harp Facility
Selling Price
Department
Category
Item#
Item Description
BEVERAGE
CARBONATED
012000006142
PEPSI, CHERRY 120Z.
$0.53
012000006319
PEPSI VANILLA 120Z,
$0.53
012000014260
PEPSI PLASTIC BOTTLE 12 OZ
$0.61
012000014307
DIET PEPSI. 12 02 BOTTLE
$0.59
012000015939
MT DEW 12 02 BOTTLE
$0.65
312000547058
SIERRA MIST 12 OZ BOTTLE
$0.58
012000001086
BOTTLE WATER AQUAFINA
$0,37
014800582000
REALIME JUICE PLASTIC 24/2.50Z
$0.76
025500203B05
FOLGERS 802. COLOMBIANA COFFEE
$7.53
028300000896
SHAMROCK FARMS WHOLE MILK
$1.64
NGN CARBONATED
120Z EOT
028300000995
SHM-RK FARMS CHOC MILK 120Z BOT
$1.64
031200000606
OS RUBY RED GRAPEFRUIT JUICE
$1.02
100Z
031200000613
OCEAN SPRAY CRANBERRY JUICE
$1.02
100Z
041820051476
FLAVOR CHARM FRENCH VANILLA
$1,81
CREAMER
051000146533
V8 SPLASH BERRY BLEND
$1.91
051000146540
V8 SPLASH TROPICAL BLEND 160Z.
$1-91
070038345763
ALWAYS SAVE TEA BAGS 100 CT
$1.72
070893021420
STURMS POWDERED MILK
$4.48
072392319213
HAWAIIAN PUNCH SUGAR FREE
$1.38
072392319237
HAWIIAN PUNCH GREEN BERRY RUSH
$1.37
072392319244
LEMON BERRY SQUEEZE DRINK MIX
$1.37
072392319251
BERRY BLUE TYPHOON DRINK MIX
$1.39
KEEFE 100% COLOMBIAN COFFEE 3
$3,31
087381070228
OZ BAG
087381102431
087381102448
KEEFE ALTURO BLEND COFFEE 302.
$1.96
KEEFE PREMIUM FREEZE DRIED
$2.14
COFFEE 3 OZ
CLOTHING
ACCESSORIES
025725331123
ATHLETIC SUPPORTER MEDIUM
$7.15
025725331130
ATHLETIC SUPPORTER LARGE
$7.15
025725331147
ATHLETIC SUPPORTER X-LARGE
$7.15
031600115115
KIWI BLACK POLISH
$2.66
031600664224
KIWI BOOT LACES 72" BLACK
$3.51
031600664606
KIWI BOOT LACES 72" BROWN/TAN
$3.51
031600666167
KIWI BLACK LACES
$1.17
031600666396
KIWI 54- FLAT WHITE LACES
$1.13
038472795421
GEL INSOLES SIZE 7-8
$14,76
038472795438
GEL INSOLES SIXE 9-10
$14.54
038472795452
SPENCO GEL INSOLE - 5
$13-37
038472795469
SPENCO GEL INSOLES SZ.14.15
$17.52
Page 1
Date\Time: 1/20/2016 2:00:53 PM
ODOC
Institution: JHCC
Department
Price List
Category
FOOTWEAR
Item#
Item Description
Seiling Price
049794327108
VINYL PONCHO
$5.15
070685100111
HAV-A-HANK HANDKERCHIEFS
S0.80
080376020918
ULTRA GEL INSOLES MENS
$9.43
085405510705
PURITAN SUSPENDERS TAUPE
$13.00
744234210025
BALLCAP FLEXFIT
$11.10
744234218205
WATCH CAP {STOCKING CAP GREY)
$3.55
744234658056
BASEBALL CAP
$4.50
087381226113
SLIP ON SHOE W/ADJUSTABLE
S3.29
VELCRO SZ M
087381226120
SLIP ON SHOE W/ADJUSTABLE
$3.61
VELCRO SZ L
087381226137
CRAW BLACK XL SLIP-ONS
$3.99
087381226144
CRAW BLACK XXL SLIP-ONS
$3.93
091207118261
NIKE DART 11 RUNNING SIZE 9
744234203942
PROMO 1/4 LENGTH TOE & HEEL
$77.95
$1.55
SOCK
744234203959
883780554822
SOCK GRAY HEELH'OE PROMO
REEBOK CLASSIC NYLONSRUN SHOE
$1.61
$53.95
ELK 8.5
PANTS/SHORTS
887687440509
N-B- MX490WT2 SZ-9-5
$67.94
023255034910
RUSSELL GREY SHORTS SZ. MED
$13.64
023255034927
LG RUSSELL MESH SHORTS
$13.23
023255034934
XL RUSSELL MESH SHORTS
$13.34
023255034941
XXL RUSSELL MESH SHORTS
$13.50
023255034965
3XL RUSSELL MESH SHORTS
$13.72
023255034972
$16.14
039307693639
LEVIS 550 RELAX FIT 32X38
$46.35
052177000673
LEVI'S 501 36X32
S54.60
099999121872
SWEATPANT 4X
$21.07
099999127119
BADGER SILVER MESH SHORTS
$14.47
MEDIUM
099999128185
GILDAN SWEATPANTS MED
$16.20
711293058899
RUSSELL SWEAT PANT NO-POCKET
$16-48
MED
711293058929
RUSSELL SWEATPANTS W/0

POCKETS LARGE
$16.89
711293058936
XL RUSSELL SWEATPANTS
$16.35
711293058967
2XL RUSSELL SWEATPANTS
$16.35
711293059018
$21.18
711293059025
$21.06
744234207940
$24.05
744234209319
SWEATPANT NO POCKET GRAY 5XL
$21.13
744234211459
$16.89
760609156293
WRANGLER 32X32
$28.37
760609156408
WRANGLER 36X32
$24.44
Page 2

ODOC
Date\Time: 1/20/2016 2:00:53 PM

Institution; JHCC
Department
Price List
Category
SHIRTS
Selling Price
Item#
Item Description
760609156415
WRANGLER 36X34
760609156477
WRANGLER 40X30
023255501436
RUSSELL SWEAT SHIRT M
$16.32
023255501443
RUSSELL SWEATSHIRT LARGE
$16.32
023255501450
XL RUSSELL SWEATSHIRT
$16,33
023255501467
2XL RUSSELL SWEATSHIRT
023255501474
RUSSELL 3XL SWEATSHIRT
$20.01
023255501481
RUSSELL SWEATSHIRT 4XL
S19.94
DICKIES LS BLUE BUTTON FRONT
$37.04
029311045968
$25.12
$24.44
$16.34
SHIRT 2XL
UNDERGARMENTS/
$6.79
091641100020
INDERA THERMAL TOP LARGE
091641100990
GOLDMASTER THERMAL SHIRT 6X
$15.83
099999128239
GILDAN SWEATSHIRT MED
$13-37
099999129748
SWEATSHIRT 6XL
$21.75
099999215113
6X BEEFY T-SHIRT HANES
$11.36
744234207810
RUSSELL SWEATSHIRT 5X
$28.22
744234207827
RUSSELL SWEATSHIRT 6X
$23.02
744234217284
H/VNES BEEFY T - SZ. MED
$5.95
744234217291
LG BEEFY T SHIRTS
$7.03
744234217307
XLBEEFY T SHIRTS
$7.19
744234217314
HANES BEEFY T-SHIRT-2X
$9-54
744234217321
3XL BEEFY T SHIRTS
744234218540
HANES BEEFY T-SHIRT 5XL
075338041100
HANES BRIEFS 3 PACK/ 4X
$15.60
075338041117
HANES BRIEFS 5XL 3PK
$14.03
075338046334
BOXER BRIEFS SMALL
075338660912
HANES BRIEFS 3PK 2XL
$12.83
075338660929
HANES 3XL BRIEFS
$18.15
076031760121
FRUIT OF LOOM BRIEFS 3PK SZ MED
$9.36
076031760138
FOL BRIEFS LARGE 3PK
$9.43
076031760145
BOXER BRIEFS FOTL XL 3PACK
$9-20
076031769018
FOTL BRIEFS 3PK SZ 2XL
091641100037
INDERA THERMAL SHIRT WHITE XL
$6.75
091641100068
INDERA THERMAL BOTTOM L
S6.59
091641100075
INDERA THERMAL BOTTOM XL
$6.66
091641100365
INDERA THERMAI SHIRT WHITE 2X
$11.65
INDERA LONG JOHNS MEN THERMAL
$11.65
091641100372
$10-58
$9-49
$9.27
$12.35
TOP SZ 3XL
091641100389
THERMAL SHIRT 4X
$11.65
091641100396
INDERA THERMAL PANT 2XL
$10.91
091641100402
INDERA THERMAL 3XL BOTTOMS
$11.65
091641100655
GOLDMASTER THERMAL PANT 4XL
$10-57
091641101003
INDERA THERMAL TOP 7XL
$16.25
Page 3

ODOC
bate\Time: 1/20/2016 2:00:53 PM

Institution: JHCC
Department
Price List
Category
Selling Price
Item#
Item Description
091641101027
INDERA THERMAL PANT 6X
$15.64
091641101034
INTERA THERMAL PANTS 7/8XL
$20.62
099999123746
6X WHITE BOXERS
$4.10
099999124798
6X THERMAL SHIRT
$7,28
099999124811
MD THERMAL SHIRT
$5.05
099999127270
4X THERMAL BOTTOMS
$6-74
099999127287
5X THERMAL BOTTOMS
$7,10
099999127294
6X THERMAL BOTTOMS
$7.25
099999127317
MD THERMAL BOTTOMS
$5,32
MENS BOXER BRIEFS WHT SM FRUIT
$6.56
099999215205
OF LOOM
CRAFTS
ELECTRONICS
CRAFT SUPPLIES
BATTERIES I
744234211527
GRT BOXER SHORT WHITE SMALL
$2,82
744234211534
GRT BOXER MED
$2,93
744234211541
LG GRT WHITE BOXERS
$2.93
744234211558
GRT BOXER 1CT XL
$2.94
744234211565
2XL GRT WHITE BOXERS
$4.45
744234211572
3XL GRT WHITE BOXERS
$4.32
744234211589
GRT SPORT BOXER/BRIEF 1CT SM
$3.78
744234211596
GRT SPORT BOXER/BRIEF 1 CT MEO
$3.80
744234211602
GRT SPORT BOXER/BRIEF 1CT LG
$3-81
744234211619
GRT SPORT BOXER/BRIEF 1CT XL
$3.87
744234211626
GRT SPORT BOXER/BRIEF 1CT 2XL
$5.06
744234211633
GRT SPORT BOXER/BRIEF 1 CT - 3XL
$3.94
744234217338
HANES BEEFY T-SHIRTS SZ 4X
021200010309
SCOTCH TAPE 1/2 " ROLL"
$1.24
026000013222
ELMERS GLUE-ALL 4 FL OZ
$1.18
039408250410
SEWING KITS W/O SCISSORS
$0,99
075755664227
POSTER BOARD
$0.73
000040150314
WATCH BATTERY SR920W
$3.85
000040150383
WATCH BATTERY 364
$3.96
000828610085
STEREO PLUG -3.6MM SOLDER
$1,09
025215741074
WATCH BATTERY SR626SW 377 1.5 V
$4,35
038975335148
STEREO JACK-3.5MM SOLDER
$1.73
043168713757
25 WATT SPOT LIGHT BULB 2PK
073096300019
BATTERY D PANASONIC 2 PACK ALK

48CT
$2.90
073096300026
PANASONIC C BATTERIES ALK 48CT
$2.98
PANASONIC ALKALINE AA BATTERIES
$1.74
073096300071
$11.11
$10.88
4PK(PLU
073096300088
PANASONIC AAA
$1.71
629312145065
SUNBEAM gv BATTERIES
$2.21
683969885132
WATCH BATTERY - AC DELCO CR2016
$4.35
683969885149
WATCH BATTERY CR2025
$4.35
Page 4

ODOC
date\Time: 1/20/2016 2:00:53 PM

Institution; JHCC
Department
Price List
Category
Selling Price
Item#
Item Description
785618135626
WATCH BATTERY CR2032
S3.93
785618359411
WATCH BATTERY SR44F 357SILVER
S2.90
1.55V
785618370416
PANASONIC WATCH BATTERY 370
S3.97
785618373417
WATCH BATTERY 373/SR916SW
$3.18
840005007983
CLEARTUNES CT-LED2 REMOTE
$7.25
FANS
046013199003
FAN LASKO
MISCELLANEOUS
000040180748
RIGHT ANGLE F ADAPTER
$1.45
021299124260
KOSS HEADPHONE REPLACEMENT
$2.12
$27.77
FOAM 6PK
021299131909
KOSS RIO STEREO HEADPHONES
$40.50
021299147573
KOSS THE PLUG
$18.70
021299147771
KOSS SPORTAPRO HEADPHONE
$33.70
021299148358
KOSS HEADPHONE HOI
$39.21
021299175484
KOSS KE5K EARBUDS
021299179574
KOSS CL20 HEADPHONE
022447170122
5FT COAXIAL CABLE
025215190391
MAXWELL HEADPHONE EXT
078742546575
BATTERY OPERATED CANDLE LAMPS
$7.49
$40.53
$6.53
$12.86
$8.34
2 PACK
2801
TV ADAPTER JACK 3.5 MM
$1.17
2802
MATCHING TRANSFORMER
$0.57
2805
TV REMOTE CONTROL ALL VARIETIES
2808
DUAL/SINGLE HEADPHONE ADAPT
$10.88
$2.59
MONO/STEREO
2817
COAX COUPLER
$0.72
2821
3.5MM MONO TO STEREO 3.5MM
$1.79
2822
3.5MM PLUG TO F JACK
$1.35
2829
EARBUD HEADPHONE REPLACEMENT
$1.43
FOAM
2832
6FT AUDIOA/IDEO CABLE
$2.76
2833
AUDIOA/IDEO COUPLER
$2.25
602846202015
SPUTTER 2 WAY
$4.25
729288030553
SANGEAN EU-55CL HEADPHONE
$44.56
729578404606
LED BOOK LIGHTWITH CUMP
$16.48
82861009
PANEL MOUNTAUDIO JACK 3.5MM
$1.38
840005002360
CLEAR TUNES 13" TV REMOTE
$7.06
840005003497
SURGE PROTECT 5 OUTLET CT-35
$15.51
840005004975
CLEAR TUNES GAME CONSOLE 50-IN-
$51.92
MP3 PLAYER; PRE-
080203010990
MAXXPR04 PLAYER
719850518480
5-PRE-PA(D SONGS (INCREMENT OF
$72.54
$9.99
5) FIVE
MP3 PROGRAM
080009010996
MAXXPR04 SCREEN PROTECTOR
$7.13
080167010012
MAXXPR04 ARMBAND W/ COVER
$14.43
Pages

ODOC
[fate\Time: 1 /20/2016 2:00:53 PM

Institution: JHCC
Department
Price List
Category
RADIOS
Selling Price
Item#
Item Description
7198S0515878
REPLACEMENT WALL CHARGER
$16.74
719850515939
REPLACEMENT EARBUDS
$16.14
027242S63230
ANALOG SONY WALKMAN RADIO SRF-
$34.86
39FP
TELEVISIONS
WATCHES / CLOCKS
$61.46
729288045120
SAN6EAN DITGAL RADIO DT-120CL
044476083792
ONE FOR ALL REMOTE
810930020364
RCA 15.6"TELEVISION
$272.86
810930021040
RCA 15" LED HDTV W/0 SPEAKER
$272.60
840005008821
CT-1514S 15" TV
$303.14
039800030566
WATCH BATTERY 390
075036777615
WATCH BAND 16MM -20MM TIMEX
$11.10
075036824319
VELCRO WATCH BAND 13-16 MM
$10.87
079767945312
CASIO ANALOG WATCH MRW200H-
$32.83
$5.66
$1.08
1BV
FOOD
BREAD/
S6.93
083275050918
ADVANCE CLEAR BATTERY ALARM
633711300000
CLEARTECH CLOCK RADIO
$28.42
753048551448
TIMEX IRONMAN WATCH T5K821
$53.81
753048552832
TIMEX T5K802 MARATHON WATCH
$28.17
011128000018
FIELDS PECAN PIES
$8.84
FUDGE DIPPED CHOCOLATE CHIP
$2.97
024300031113
GRANOLA BARS
024300041013
LIL DEB OATMEAL CREME PIE
$1.91
024300041020
LIL DEB HONEY BUNS6CT
$1.96
024300041068
LIL DEB COSMIC BROWNIES
$1.97
024300041143
LIL DEB STAR CRUNCH
$2.18
024300041204
LIL DEB NUTTY BARS
$1.92
024300041303
LIL DEB SWISS ROLLS
$2.04
024300041334
LIL DEB STRAW SHORTCAKE
$2.25
024300041686
LIL DEB FROSTEDFUDGE CAKES
$2.36
024300044311
LIT DEB MINI POWDER DONUTS 100Z
$1.98
024300044328
LIT DEB MINI FROSTED DONUTS
$1.97
10.50Z
024300044557
LITTLE DEB MINI GLAZES DONUTS
51.97
030700158008
TOASTIEM POPYPS STRAWBERRY
$1.78
030700158107
POP TARTS BLUEBERRY 6PK
$1.94
048564060054
GUERRERO CORN TORTILLAS
$1.39
070038324300
ALWAYS SAVE WIDE EGG NOODLES
52.06
160Z
070038592594
072250037129
A/S CHOC CHIP COOKIES
$2.47
NATURES OWN 100% WHEAT BREAD
$1.58
200Z
077633047375
BREAD SUNBEAM GIANT 2402
$1.45
077948007019
CALIDAD FLOUR BURRITO TORTILLA
$2.41
10/CT
077948007040
CALIDAD FLOUR TORTIALLAS 24CT.
$3.61
Page 6

ODOC
Date\Time: 1/20/2016 2:00:53 PM

Institution: JHCC
Department
Price List
Category
Kern#
Item Description
085264455995
CHOCOLATE HONEY BUN
Selling Price
$0.95
CLOVERHILL 4.75 OZ
CANDY I SNACKS
086106022498
LIL DUTCH CHOC. CHIP COOKIE 502
S0.66
086106022580
ICED OATMEAL COOKIES,502
$0.66
086106022740
LIL DUTCH DUPLEX CRM COOKIE 502
$0.66
087381065972
ZIPPY PEANUT BUTTER CREMES
$0.76
745527400116
BUDSBESTVANILLA WAFERS 12/1002
$1.33
745527520173
BUDS BEST PECAN C CHIP COOKIES
$1.17
021900062196
TOM'S RIDGES CHIPS 902.
S3.05
021900062417
TOM'S BBQ POTATO CHIPS
$3.05
021900062813
TOM'S SOUR CREAM & ONION 8,502.
$3.05
021900961879
TOM'S NACHO CHEESE 10 02
$3.05
BAKER'S HARVEST SALTINE
$2.15
023300173946
CRACKERS
023300336242
BAKERS HARVEST CINNAMON
$2.56
GRAHAM
023300400226
BAKER'S HARVESTSNACKCRACKER
$2.27
028000202033
NESTLE BUTTERFINGERCANDY BAR
$1.01
1.9 02
028400002103
SANTITAS CORN TORTILLA CHIP 1102
$1.71
028400078344
FRITO PEANUT IN SHELL
$0.81
028400419222
FRITOS CHILI CHEESE CORN CHIPS 4
$1.21
1/4 02
028400420532
LAYS BARBECUE CHIPS2 3/4 02
$1.21
028400420549
LAYS CLASSIC POTATO CHIP 2 3/40Z
$1.39
028400420617
LAYS SOUR CREAM & ONION CHIPS
$1.21
028400420730
NACHO OORITOS 3 1/8 02 BAG
$1.21
028400433181
CHEETOS CRUNCHY 3 1/2 OZ
$1.21
026400433921
CHEETOS JALAPENO CHEDDAR
$1.22
028400433938
CHEETOS FLAMIN HOT 3.502.
$1.22
CHESTER'S CHEDDAR POPCORN 2
$1.24
028400436243
5/80Z.
034000003204
034000004409
ALMOND JOY
$1.00
REESES PEANUT BUTTER CUPS 1.5
$1.02
OZ
034000190454
HERSHEYS 1/2 LB CANDYBAR
$3.05
034000191413
HERSHErS - GIANT WI ALMONDS
$3.05
HERSHEY'S SPECIAL DARK CHOC BAR
$3-05
034000195282
6.802
034000544066
TWIZZLERS BUCK TWISTS
$1.96
034000560026
TWIZZLERS STRAWBERRY 160Z
$3.86
040000000327
M&M PEANUT SINGLES 1.74 OZ
$1.00
040000000518
STARBURST ORIGINAL
$1.03
040000001607
SKITTLES ASSORTED 2.17 OZ
$1.00
040000004356
TWIX COOKIE BAR 1.790Z
$1.02
Page?
Date\Time: 1/20/2016 2:00:53 PM
ODOC
institution: JHCC
Department
Price List
Category
Selling Price
Hem#
Item Description
040000422068
MILKY WAY 1,84 OZ.
$1.00
040000422082
3-MUSKETEERS CANDY BAR 1.92 OZ
$1.01
040000424314
SNICKERS 1.86 OZ,
$1.02
041168631675
ATKINSON'S CHIC-0- STICK
$0.34
OS1576000017
SWEET SMILES STARLIGHT MINTS
$1.95
1202
051576000024
SWEET SMILES BUTTERSCOTCH
$1.98
DISCS 12 OZ
051576000062
SWEET SMILES FANCY MIX 120Z
S1.89
072392902491
KOOLPOPS GIANT FREEZE
$0.56
POPSCICLE
072600009172
HERRS JALAPENO POPPERS 70Z
$2.41
076410901817
LANCE CHEESE NIPS
$0.36
076410901855
LANCE CREAM CHEESE&CHIVES
$0.40
076410902173
LANCE JALAPENO CHEDDAR
$0.43
077034009521
KAR'S ALL ENERGY TRAIL MIX
$0.64
UNSALTED
077034016307
KARS SALTED MIX NUTS
$3.47
087381012662
HOT & SPICY PORK RINDS 20Z
$1.08
087381853753
MOON LODGE EXTRA BUTTER
$0.47
POPCORN 2.80Z BA
087381853784
ML KETTLE CORN
$0.50
851224004035
POPS SNACK SHACK ROOT BEER
$0-74
BARRELS
851224004042
POP'S SNACK SHACK PARTY MIX 40Z.
$0.74
851224004059
POPS SNACK SHACK ATOMIC
$0.93
FIREBALLS 4 OZ
851224004080
POPS SNACK SHACK JOLLY
$0.93
RANCHER 40Z
CEREALS
024300031908
SUNBELT RAISIN DATE ALMNO GR
$3.12
CEREAL160Z
042400188971
BERRY COLOSSAL CRUNCH 260Z
$5-27
042400189060
MOM FROSTED FLAKES 30 OZ.
$5-59
042400189077
MALT O MEAL RAISIN BRAN 27.40Z
$5.69
042400189114
MOM GOLDEN PUFFS 30.6 OZ.
$6.13
070038595489
BC CORN FLAKES
$3.03
791669198978
FRUIT & CREAM OATMEAL VARIETY
$3-00
RALSTON MAPLE&BRN SUG INST OAT
$2.37
791669199234
1.510ZPKS
CONDIMENTS/
$6-02
021000616893
KRAFT VELVEETA CHEESE 12/1LB
024463061040
CHILI GARLIC SAUCE 8 OZ
$2.68
024463061095
SRIRACHA HOT SAUCE 17 OZ.
$3.43
024600000505
SALT SUBSTITUTE MORTON
$3-28
024600010986
MORTON MCCORMICK SALT AND
$2.54
PEPPER SET
024600011983
MORTON FINE SEA SALT
$2.16
038200000063
PICKLE DILL
$0.84
Page 8
OateVTime: 1/20/20162:00:53 PM
ODOC
Institution; JHCC
Department
Price List
Category
Selling Price
Hem#
Kern Description
048707454009
SQUEEZE CHEESE JALAPENO
$3.31
048707459004
SQUEEZE CHEESE CHEDDAR
$3.32
048707930015
SQUEEZ RANCH DRESSING 1.50Z OLD
$0.35
FASHION
052100009711
GARLIC POWDER SPICE CLASS
$1.65
052100019802
IMITATION BACON BITS 2 OZ.
$1.59
052100020167
CAJUN SEASONING SALT 4 OZ
$1,56
052100020204
SP CLASSICS CHILI POWDER
$1.65
052100020389
SEASONING SALT 4.75 OZ
$1.62
05210002S704
LEMON PEPPER MCCORMICK 2.5 OZ.
$3.51
070038305408
HOT COCOA MIX
$2,13
MUST/y^D SQUEEZE BEST CHOICE
$1.70
070038307020
40Z FREE
070038307099
KETCHUP
$2,02
070038325833
COFFEE CREAMER BC
$2,40
072360000150
SALSA ELPATO JALAPENO
$1.97
073210009002
STAR FARMERS MARKET OLIVES
$1.67
BLACK
073210009026
STAR FARMERS MARKET OLIVES
$1,60
074350000010
CAVENDERS GREEK SEASONING
$1,93
074609072409
KC MASTERPIECE ORIG BBQ SAUCE
$3.29
180Z
074609072867
HICKORY N BROWN SUGAR BBO
$3.29
SAUCE KC MASTE
076114304419
BEEF FLAVORED BOUILLON CUBES
$1,90
3.50Z
076114304440
CHICKEN FLAVORED BOUILLON

CUBES 3.50Z
$2.01
078006008375
SPICECO VEGETABLE FLAKES
$1.44
087381000805
KEEFECRMYPEA BUT180Z
$2,70
087381000812
KK CHUNKY PEANUT BUTTER 180Z
$3,07
087381001222
PICANTE SAUCE SQZ KEEFEE
$2.09
087381001796
SQEZ SALSA 15,50Z PLAS BTL
$2.08
087381003554
JALAPENOS SLICED CACTUS ANNIES
$1.86
087381037320
KK MAYONAISE 18 OZ SQZ BTL 12/CS
$3.67
087381049422
VELVEETA INSTANT NACHO CHEESE
$1.09
SAUCE 1.50
087381077562
SQUEEZE GRAPE JELLY 20 OZ
$2.65
087381077579
STRAWBERRY SPREAD 20 OZ
$2.90
300258479314
SWEETMATE PINK 100 CT 12/CS
$1.76
605021000918
SUGAR TWIN 100 PACKETS
$1.75
744234802596
SIAM SWEET & HOT SAUCE
$2.35
781923254014
BULLIARD HOT SAUCE HABANERO
$0.83
851224004806
AMERICA'S BEST DEHYDRATED
$1.24
MUSHROOMS
857361000558
PAMPA EXTRA VIRGIN OLIVE OIL
$3.59
Page 9

ODOC
Date\Time; 1/20/2016 2:00:53 PM

Institution: JHCC
Department
Price List
Category
Item#
DINNER MIXES
037600473712
Item Description
Selling Price
8.50Z
HORMEL ROAST BEEF ENTREE
$7.87
6/170Z.
041000022319
LIPTON TERIYAKl RICE
$2.15
041000022784
LIPTON CHEDDAR BROCCOLI RiCE
$2.06
041000028021
KNORR TERIYAKl NOODLES
$2.15
041000142130
KNORR STEAK FAJITAS RICE
$2.15
070038332558
MACARONI & CHEESE
$0.65
071187113180
COOKQUIK LONG GRAIN RICE PRE
$1.05
COOKED 70Z
071429096236
087381030925
ZATARAINS JAMBALAYA
$2.94
THAI PALACE NOODLES CHILI 3.7
$0.73
02/24CT
FROZEN SNACKS
013120012518
EASY FRENCH FRIES
$1.59
014500011329
BIRDS EYE BROCCOLI/CAULIFLOWER
$3.07
120Z.
027086185544
BEEF CHIMICHANGA
$1.24
031000126001
BANQUET HOT WINGS
$4.98
042800116000
TOTINO COMBINATION PIZZA 12/10
$1.96
OZ,
FRUITS/VEGETABLES
047677102323
BLUE BELL MSM'S ICE CREAM COOKIE
$1.56
047677474208
TWIX ICE CREAM BAR
$1.51
070038356714
BEST CHOICE STIR FRY 160Z.
$2.22
070110056532
OWENS SAUSAGE BISCUIT
$1.66
070496172123
BOMB FRIED CHIMI
$2.65
070560923262
PICTSWEET CUT CORN
$2.32
071117011715
BEEF AND BEAN BURRITO REESERS
$1.42
071117011739
RESER GREEN CHILE BUR
$1-42
071899051015
BLUE BELL ICE CREAM PINTS
$2.26
072730600423
HILAND SANDWICH IC VANILLA
$0.60
072730606401
HILAND OLD RECIPE IC BAR
$0.47
072730660007
NUTTY ROYALE l/C 40Z,
$0.79
076862111116
4 STAR BEEF CHILI
$3.87
029700001452
IDAHOAN 40Z CHEESE POTATOES
$1.57
029700001483
LOADED BAKED POTATOES 40Z
$1.57
029700021504
APPLEWOOD SMOKE BACON
$1.57
POTATOES
038200000094
851224004820
PICKLE HOT
$0,73
DEHYDRATED DICED TOMATOES AND
$1.17
GREEN CHIL
HOLIDAY
744234807508
MEATS I BEANS
015900000425
JUMBO KOSHER HOLIDAY PACK 2015
$8.05
BAR-S MEAT BOLOGNA 12/1 LB.
$2.05
#00042
015900000944
BARSALL BEEF FRANKS 16/120Z
$3.64
015900060009
BACON
$5.03
015900134014
BAR S MEAT FRANKS (8) 12 OZ
$1.42
Page 10

ODOC
Date\Time; 1/20/20162:00:53 PM
Institution; JHCC
Department
Price List
Category
Selling Price
Hem#
Item Description
015900190751
BARS DELI HAM 4X6160Z.
$4.87
015900235889
BAR S SMOKED SAUSAGE SKiNLESS 1
S2.32
LB
$10.50
023700021885
TYSON CHICKEN BREAST 220Z.
031000100100
BANQUET FRIED CHICKEN 29 OZ
$9.10
037600190671
SPAM SINGLES HORMEL
S1.65
044700009550
0/M LIVER CHEESE 12/8 OZ.
$4.47
BRIDGGORD PEPPERONI SLICES 3,5
$2.71
047500013017
OZ
054500191454
BALL PARK FLAME GRILLED BEEF
$9.99
PATTY
071177000650
COUNTRY BOY SUMMER SAUSAGE
$9.34
2LB.
071421598643
BIG AZ CHEESEBURGER
S3.49
072674004158
J C POTTER HOT LINKS
$3.57
072674004165
J C POTTER SMOKED SAUSAGE
$4.33
076713000231
SCHAWB'S BEEF HOT LINKS
$4.24
087381017100
BRUSHY CREEK CHILI NO BEANS
$2,07
087381017117
BRUSH CREK CHILI W/ BEANS
$1.84
087381017124
BRUSHY CREEK CHILI W BEANS HOT
$1,87
087381097713
SEVILLA SPiCY REFRIED BEANS 80Z
$2,20
087381097836
SERVIL REFRIED BEANS 80ZPK
$1,82
MOUNTAIN VIEW MILD SMOKED
$4,30
689076335751
SAUSAGE
689076336055
MOUNTAIN VIEWSAUSAGE HOT LINKS
$4,30
160Z.
744234801292
SARDINES IN HOT SAUCE

FISHERMAN'S PARADI
$1,12
744234802435
FISHERMANS CLAMS 30Z
$1.44
FISHERMAN'S PARADISE SMOKED
$2.64
744234802442
OYSTERS
744234802992
FISHERMAN MACKEREL FILLET OIL
$2,10
50Z
744234803364
FISH STEAKS WITH GREEN CHILI
$1.22
3.50Z
744234803838
FISHERMAN'S PARADISE PINK
$2.16
SALMON 30Z744234804200
FISHERMAN'S PARAD LT TUNA N/WAT
$2.64
4.2302
REFRIGERATED FOOD
744234804873
REG BEEF SAUSAGE LEGENDARY
$1,81
744234804897
HOT BEEF SAUSAGE LEGENDARY
$1.81
021000612239
PHILADELPHIA CREAM CHEESE 80Z
$3,64
027400103070
SHEDD-S COUNTRY CROCK BUTTER
$3,19
150Z.
030900361451
READY CUT PEPPER JACK CHEESE
$7,00
043000009536
COOL WHIP TOPPING 80Z
$2,28
070038360568
BEST CHOICE COLBY BLOCK CHEESE
$4.93
160Z,
Page 11

ODOC
Dale\Time: 1/20/2016 2:00:53 PM

Institution: JHCC
Department
Price List
Category
Item#
Item Description
070038360827
BESTCHOICE AMERICAN CHEESE
Selling Price
$4.61
SLICES
070038591948
BEST CHOICE SHREDDED CHEESE
$3.88
12QZ.
071117011746
RESERS SPICY CHICKEN BURRITO 10
$1.42
OZ.
073420000110
SOUR CREAM DAISY
$3.16
746295001871
SANDWICHVILLE GRILLED CHICKEN
$1.77
MELT 4.25
SOUPS
746295010101
SANDWITCHVILLE TWIN CHILI DOG
$1.68
041789001260
MARUCHAN CUP SOUP CALI VEG
$0.64
12/CS
04178&002188
RAMENCHiU MOODLE SOUP 302
S0.2fi
041789002588
RAMEN ROAST BEEF SOUP 302
$0.27
041789002779
RAMEN CAJUN CHICK CL 2.8 02
$0.28
041789002793
RAMEN HOT-SPiCY VEG 2.8 02
$0.27
041789002823
RAMEN PICANTE BEEF
$0.27
087381017155
BRUSHY CREEK BEEF STEW
$1.90
735375118066
TRADITIONS CHICKEN RAMEN
$0.71
NOODLES
HEALTH AND BEAUTY
HAIR CARE I
020886040907
FREE STYLE HAIR TIES METAL FREE
$1.41
18 CT
020886295062
AFRO COMB LARGE
$0.40
020886321914
FREE STYLE MILITARY BRUSH
$1.66
038276005061
PINK OIL M0ISTURI2ER 8 02
$6.15
038771002428
AFRO PICK LARGE
$0.70
03940B020181
MILITARY STYLE HAIRBRUSH
$0.69
072982001092
PROLINE COMB THRU RELAXER
$4.81
075285002766
SPORTIN WAVES
$3.33
075610018103
ROYAL CROWN HAIR DRESSING
$1.89
078898010098
PONYTAIL HOLDERS - BANDS
$0.69
087381203770
MURRAY'S POMADE (GREASE)
$2.58
ELEMENTS FIRM HOLD GEL W ALOE
$3.04
087381249419
VERA150Z
096002008212
SOFTEE BLUE HAIR DRESS
$2.33
096002009219
SOFTEE COCONUT OIL COND 502
$2.85
12/CS
LOTIONS / POWDERS
MISCELLANEOUS H/B
2210
COMB BLACK 5"
$0.11
5033102908009
ION ALCOHOL FREE HAIR SPRAY 802
$7.65
827755034353
1NFUSIUM23 LEAV-IN COND 8 OZ
$4.87
045893072482
SUAVE COCOA BUTTER LOTION 100Z
$3.03
045893072727
SUAVE EXTRA RELIEF LOTION 100Z
$3.03
075707011000
COCOA BUTTER STICK
$2.65
087381203190
NEW DAY VASELINE 3.750Z 12CT
$1.44
087381223754
NEW DAY BABY POWDER 15 02 12 CS
$1.89
011017101406
CORN CUSHIONS-DR SCROLLS
$4.10
Page 12

ODOC
OaleMime; 1/20/2016 2:00:53 PM

Institution: JHCC
Department
Price List
Category
Selling Price
Item#
Item Desciiption
020886000017
SOAP DISH
$0.49
031600115122
KIWI POLISH BROVW LIQUID
$2.80
031600117119
SHOE POLISH LIQ WHITE
$2,81
041388210216
BLISTEX MEDICATED UPOINTMENT
$2,68
(1)
HOUSEHOLD
BED / BATH ITEMS
HOUSEWARES
042037103101
CHAPET LIP BALM
$0.91
071603127500
PUMICE STONE
$2,02
08052910045G
EARPLUGS
$0.75
080692420102
READING GLASSES-1.00MG
$6,51
080692420126
DEL REY READING GLASSES 1.25
$6.51
080692420157
DEL RAY READING GLASSES 1.50
$6,51
080692420171
DEL REY READING GLASSES 1.75
$6.51
080692420225
READING GLASSES 2.25MG
$6,51
080692420270
READING GLASSES 2.75
$6.51
087381219528
NEWDAY COT SWABS 100CT
$1.13
2205
BLACK FRAME SUNGUSSES
$2.51
2208
HAIR NET
301875479022
AMBI FADE CREAM
$7,39
381370022299
AMBI FADE CREAM 2 FL OZ
$6.65
744234600659
SUNGLASSES - BIKER
$6,67
011110581013
FLAT YELLOW SHEET
$7.67
011110581020
PILLOW CASEYELLOW
$3,51
011110582362
ROBINSON YELLOW BATH TOWEL
$8.32
079465675856
YELLOW WASHCLOTH
$2,24
099999123050
YELLOW FLAT SHEET
$6.77
099999123067
YELLOW PILLOWCASE
099999131468
DELUXE HEAVYWEIGHT BLANKET
2914
PLASTIC SHOWERCAP
$0,35
630840207095
HEAVY WT BATH PUFF
$1-63
719850506395
STANDARD PILLOW
765950001148
YELLOW WASH CLOTH
076501308419
COLEMAN ICE CHEST5QT
077834004719
PLASTIC BOWL W/LID 2302 48CT
080195010992
BRUSHY CREEK HOT POT 350 WATT
087381216107
TUMBLER WITH LID 220Z.
$0.60
087381218125
CLEAR THERMAL MUG 220Z
$2,42
744234400143
FOOD INSERT FOR HOT POT
$4.06
744234600024
LAUNDRY BAG
$3,91
744234602547
FORK/SPOON 3 PC SET
$1-80
744234604312
3 CUP REUSABLE BOWL
$4,04
744234604329
REUSABLE BOWL 5,2 CUP
$4.84
744234604343
LEVEL 10 BOWL 10,3 CUP
$7,50
$0.73
$2,76
$15,85
$11,82
$1.69
$15,34
$1,19
$22,32
Page 13
*Date\Time: 1/20/2016 2:00:53 PM
ODOC
Institution: JHCC
Department
Price List
Category
Item#
LAUNDRY/CLEANING
024598011545
Item Description
CLASSIC BURST W/BLEACH ISLAND
Selling Price
$1.63
SENSATION
035000446671
AJAX12.6 R..02
$1.53
048155908185
POWERHOUSE DRYER SHEETS
$1.50
053200082598
SCRUBBER SPONGE 2PK
$1.30
ALWAYS SAVE PAPER TOWELS 60
$1.11
070038328407
2PLY
087381217890
HERITAGE LAUNDRY SOAP WITH
$1.42
BLEACH
MISCELLANEOUS
099999131116
GREEN LAUNDRY BAG 24X28
$6.69
6903148078891
TIDE DETERGENT 17,92 02
$1.70
6903148078938
TIDE CITRUS 17.92 02
$1,69
896969001017
PEAL STARCH 160Z.
$3.06
018643878610
HANGER EIGHT PACK
$1.47
PARADE SOFT WHITE LIGHT BULB
$3.19
020055410401
40WATT
039408250618
MIRROR ARCRYLIC WITH MAGNET
041165005035
SNO-CONE CUP 200CT SLEEVE
070038608776
BEST CHOICE ROUND TOOTHPICKS
$2.40
$12.18
$0.92
250 CT
071649402005
MASTERLOCK V85 COMBINATION
$9.58
LOCK
077834001558
FLY SWATTERS PLASTIC
$0,78
099999132229
CANTEEN BAG FLOURESCENT
$4,65
YELLOW
099999213362
OFFENDER PROPERTY BAG 24'X16"
$13.65
X12-
MEDICAL
COLD / ALLERGY
099999230567
CLEAR HOBBY CRAFT BAG 12X12X12
$15.95
744234403113
CLEAR PROPERTY BAG 24X11,5X16
$20.64
096295122442
COUGH DROPS, SUGAR FREE
$1.66
096295126112
LEADER ALLERGY RELIEF
$2.25
LORATADINE lOCT.
306030857943
QUALITEST GUIATUSS - Q-TUSSIN 4
$1.15
02
309040012241
ALLERGY TAB ANTIHIST4MG
$0.91
309043865752
MAJOR DEEP SEA NASAL 45 ML
$1-02
MAJOR SORE THROAT LOZENGES
$2.05
309046255499
CHERRY 18
DIGESTION
635515979574
QC CHEST RUB 3.5 02 JAR 113 GM
$3,27
635515986725
CHERRY COUGH DROPS 30 CT
$1.09
016500044048
ALKA-SELT2ER EFF TABLETS 24CT
$6.28
042037103040
BEEENO 30 TABLETS
$6.37
096295115222
LEADER 0MEPRA20LE ACID
$13.04
REDUCER 14CT
305361020088
GAS RELIEF - RUGBY 125MG/60CT.
$4.18
305364306080
RUGBY FIBER LAX CAPLETS (60) 60CT
$5.48
306030235161
QUALITEST PINK BISMUTH 30/BOX
$3.21
Page 14
bateUime: 1/20/2016 2:00:53 PM
ODOC
Institution: JHCC
Department
Price List
Category
Item#
Item Description
Selling Price
100CT
PERSONAL HYGIENE
311845091512
OYSTER SHELL CALCIUM
$5.48
357896504014
ONE A DAY VITAMIN 100 TABS
$1.58
837864000460
DAILY VIT FORMULA +IRON 100 TAB
$2.00
BATH TISSUE
036196204502
BATH TISSUE
$1.41
DENTAL
0047701020189
DENTEK FLOSSERS 3CT.
$0.28
009283044053
EVERLAST SINGLE MOUTHGUARD
$2.82
011509002051
SEABOND DENTURE ADHESIVE
$8.64
UPPERS 30CT
011509002068
SEABOND DENTURE ADHESIVE
$8.64
LOWERS 30CT
011509089007
DENTURE BATH SEABOND
$1.93
011509149008
DENTURE BRUSHSEABOND
$3.46
020886202015
TBRUSH HLDR 2-PC BAG/BARC
$0.36
035000550101
COLGATE TOOTHBRUSH SOFT
$0.37
035000556769
COLGATE TOOTHBRUSH (SOFT)
$0.77
035000566850
ULTRA BRITE TOOTH PASTE 602
$1.46
COLGATE MAXCLN SMTFOAM WHITEN
$3.68
035000765529
60Z
DEODORANT
SHAMPOO/
037000003915
CREST TARTAR 6,40Z./24 CT.
$3.33
076660008649
FIXODENT ADHESIVE CREAM 1.34 02
$3.63
076660725362
FIXODENT POWDER X-HOLD 1.6 OZ
$428
085317003715
FRESHMINT DENTURE CLEANSER
$1.63
2124
NO SHANK TOOBRUSH
$0.19
300410810016
ORAL B DENTURE BRUSH
$0.41
$10.56
310158054559
SUPER POLIGRIP 2.402.
310158082040
SENSODYNE TOOTH PASTE
$7.21
839294262548
PERCARA MOUTHWASH 2402.
$1.08
022200004923
MENNEN SPEED STICK SPRT 30Z
$2.60
022200940214
MENNEN SPEED STICK 1.8 OZ
$2.11
022200951043
SPEED STICK AQUA GEL 30Z
$2.73
023400076864
DIAL ROLL ON DEODORANT
S0.98
041348004909
BODY GUARD SPORT STICK 2.502
$1.41
075610430103
SULFUR 8 CONDITIONER - 2 OZ.
$3.07
079400338334
SUAVE 2-IN-1 ANTI DANDRUFF SHAM
$3-79
AND COND
079400764409
SUAVE CLARIFYING SHAMPOO
$1.62
079400922908
SUAVE CONDITIONER WATERFALL
$1.59
MIST 1502
635515992566
QC-T+PLUS THERAPEUTIC
$5.00
SHAMPOO 1602.
816559012209
V05 3-IN-l SCEAN SURGE
$1.38
816559012858
V05 EXT BODY CONDITIONER
$1.36
816559012885
V05 EXTRA BODY 12.502 / 6CS
$1.41
883484333532
PERT PLUS 13.5 02
$3.94
Page 16
t)ate\Tifne: 1/20/2016 2:00:53 PM
ODOC
Institution: JHCC
Department
Price List
Selling Price
Category
Item#
Item Description
SHAVING
022200002943
AFTER SHAVE ORIGINAL
$2.34
022200002950
MENNEN AFTA SHAVE COND.
$2.24
024500060029
M5 MAGNUM RAZOR
$6.62
024500060036
M5 MAGNUM REFILL 4CT.
S6.49
024500332775
PERSONNA PIVOT RAZORS
$1.51
024500500600
BURMA SHAVE BRUSH
$5.00
043429003030
BUMP STOPPER
$2,70
047400073715
MACH 3 RAZOR REFILLS 48/5CT
$14.42
047400648517
GILLETTE MACH 3 HD
$10.44
048155921122
COMFORT GLIDE SHAVE GEL
$1.43
072790000119
MAGIC SHAVE GOLD POWDER
$2.35
MAGIC SHAVE CREAM REGULAR
$3.52
072790000188
TUBE 6 OZ
075020018427
092281122564
NORELCO HQ56 REPLACEMENT HEAD
$33.57
PAN. REPL. BLADES FOR ER389K
$12.56
TRIMMER (WE
2107
SHAVING MUG
744234404332
LEVEL 10 BATTERY OPERATED
$0,55
$21.56
RAZOR
744234404349
REPLACEMENT HEAD FOR LEVEL 10
$5.40
RAZOR
SOAP
017000004754
TONE SOAP - 48/4.25 OZ.
$0.98
017000009100
DIAL GOLD BAR SOAP - 3.5 OZ.
$0.69
019100005228
JERGENS BATH SOAP - 4.5 OZ.
$0,87
035000141071
IRISHSPRING SOAP 4 OZ
$0,89
GILLETTE CLEAR GEL DEODORANT
$4,49
047400098190
30Z.
048155906662
048155921115
HAND SOAP ANTIBACTEREAL MELON
$1,08
ALCOHOL FREE HAND SANITIZER 70Z
$1.05
PERS CAR
087381125133
GUCCI BLACK ICE BODY WASH 15 FL
$3,56
OZ
STATIONARY
BOOKS
GAMES
087381220982
NEXT1 SPORT BAR SOAP 50Z 80/CS
$0.61
039408070445
PHOTO ALBUM 40 PG.
$4,29
087381202568
ADDRESS BOOKS (SML) 36/CS
$0,79
088908151390
WEBSTER'S DICTIONARY
$1.41
088908151406
SPANISH DICTIONARY
$1,26
PLAYING CARDS - AVIATOR POKER
$1,82
073854009147
12CT
073854009185
PLAYING CARDS - AVIATOR PINOCHLE
$1.88
12CT
079252610145
PLASTICRULER
$0,59
2319
ENVELOPES CLASP 9X12
$0.22
STAMPS
2349
POSTAGE STAMPS 49 CENT
$0,49
WRITING SUPPLIES
000005080007
PENCIL #2 4PK
$0,56
043100352402
DOCUMENT FILE 10X15 24CT
$1.65
MISCELLANEOUS
Page 17

&ate\Time: 1/20/2016 2:00:53 PM
ODOC
Institution: JHCC
Department
Price List
Category
Selling Price
Item#
Item Description
070330902824
BIG PENS BLUE CT2
S0.95
070330902831
BIC CRYSTAL PEN 2P
S0.96
070972747548
LEGAL PAD 50 SHEETS
S0.90
075755121102
PAPER WIDE RULE 200 SHEETS
S2.59
075755411104
YELLOW LEGAL PAD 5X8
S0.85
075755411852
WIRELESS NOTE BOOK
$1.58
075755436084
FOLDER WITH BRADS AND POCKETS
$0.53
075755721012
ENVELOPES SHORT 100 COUNT
SI .50
075755721197
ENVELOPES LONG 50 COUNT BOX #10
$1.34
085317003494
PEN - CLEAR 4 INCH FLEX 144CT
$0.25
2308
PENCIL MECHANICAL
$0,37
2312
ENVELOPES 10X13
$0.16
2318
ERASERS WEDGE CAP
$0.08
724328860015
INC PINK ERASERS 2 PK
$1.69
744234402123
HI-LITER PINK
$1.04
744234402130
Hl-LITER BLUE
$1.04
744234402147
HI-LITER GREEN
$1.32
851806000875
PENCIL SHARPENER
$0.80
Page 1S
Lawton Correctional Facility

Commissary Menu
Attach. No. 9

Lawton CorrecUonal Facilitr - Commts$ar
Uera*
D*TlpOcw)
2015
Keee Cotwrbtei CoWoe3 oj m
son
MawneO House CoflM 4 oz "M
2029
Keele lOOa. Tea-H
2282
2027
Keete Alswo eiera) Coflee 3oz
2216
Assorted Tea Bag I8pk. *H

Svyeel-Mate Suoar Subsmna, tOO-ci Bonni
211$
SS Suoar Free Black Cherrv "H
2116
2)20
SS Suoar Free Walermeton "H

SS Sujar Fre LemonaiJe "H
2169
SS Lemonade *H
2190
SS ^lawberTWWaiennelon "H
2f94
Galoraoe Drrk UcrFrviii Puneft 7.5 oj
2228
Kod Aitf DrWt MoStrawberiv Waurmefcin 12o;
2204
SS PneacleX>>e>Tnov
SS Fiu Punch >(

2376 Coke 1201*
24d8
2377
2378
Dei Coke 12oz*

0. Pepper 12 oz
23ao
C>raf>9eSoOal2oi*
2383
Ssfie 12oz-
3343
6^
3036
3040
HoneyToastedCute 20 oi - RetealaUe Bag

Variety Oairrveal (boa '
f OOMI i.'CRUKI.ItS
3004
3030
Cheese craiiiers shole cack*

PS oactiers scwie*
Cfweelale Chio Cookies 6 oj -H
kd OaSnaal Cookes 6 oz H
Oranoe PtteaccJe C<emes 6 oz ^

Peanul Butter Cookies 6 oz-H
Vanila Creme Cookies e oz
3050
CtKXolaleChb Cookie* 16 oi K
3041
3107
Iced Oaweal Cookies ie oz "H

Salbrte Crackers 16 oz "H
3114
Gokleo VaUov Srtac* Crackers IS.l oz
3223
$4^
$4^
2787 ToRvChadêres OffTvRtoDmef 8o2

2786 ToftvChachetec-RMBeansMRix 7u
$3.46
6772 Tony QmefterceJamfaalava (^nef 6 02
$3.65
$1.75
B*(;(,HII.I >. Ml A1 i
6172 BCCMiNOfieans 11.25 02
$0.12
6173
$0.12
6174
PeanutBtflter on CheeseCrackers skuler**^
$425
$425
$2.6S 0147 Pvnvr-Up Cool Zone
$3.10
>2j
3331
Sw^nofls Gok.
3214
Fudoe Brovinies325 oz
3226
bed CltoCDleie Danui3.9oz'

Chocolate Cupkes 4 oz *
VanJIa Water Cookies 16 oz
Cnocslats Creme Cookies ><oz
3270
3052
3008
3010
SoflChoeotateChIoCootdet 2.75oz
301$ Oanieal flaw Cookies

3043 MurraysSnorlbread Cookies
3332
Onking Stcks (bo of 61*
32d5
Ruetieriv Donuls (box of 61
6 oz
4100
42.20 0369 Porto Ruor CsMge AehM>4 Padc
Lertton orops *
4121
Jelly Beans 4.25 oz

Jelly Beans 7 oz
4122
4145
4146
41S0
4162
$0.12
6176
6C6eef Stw 11.25 oz
tZJO
6193
6196
0011
6196
Bruthv Cfet Lesovia with BeeS wiSauce It 25 ot
S4.eo
$3.20
0010
$0.30
$2.64
SAnhv Creek 680 Beet

oz
Premhim Chcken Breasi43cz
V06 Condiboner *5 oz
$2.0C
0030
$2.86
$0^
$0.30
S2^
Suloher 6 Shampoo 7.5 oz
2616
Be4 8 QwMe Sfek
$3 61
2624
BrusTry C>ek Browt Suoar $<jnme Swsaoe 5 oz
$1.20
Brushy OMk Beef Sj^nmef

6140 BriMhv Creeek Porti Jerk SMe 5 02
6^7 Hom>el Soam S#>o}es 2.5 02
$1^
3585
2626
11 oz
Sumnftf Sausaoe 5 02
$1.2D
2596 Cre^ C7>eM w/JaJapeno 2 02
$1^
3530 VelveetBslatepeooQieeee Squeeze 16 02
$4.85
$2^
6429 Jalat>eno Chaeee 2 02

6426 Cheddar CheeM 2 02
6422 Cheddar Cheeee Bar 4 02
4176 VeMeta QêcWar C7)eeee S<)uee2e 1602
riLKf.tb |*L.4n.\u^
6500 VanHodenPEMeHoOôz
6501 (MMIPicMeSoz*
06CAr*>iB-s SIid
Vekmta Macaioni and Cheese 3 oz *H
$1.60
$3,00
ssss 0355 ThekennoShamooo 15oz
$1.75
$1 75
$2^
(1.20 0815 WawBnnh

>3.20 0S20 Vent Hair Brush
$3.40 0821 Palm Brush
$225
$0.91
$0 42
toso 0825 ro-f>lck

%0S0 0835 Do Rao Black
$2.15
$2.00 0655 PonvTalHaBer
$0.13
SI.IS 0227
Snbkersbar wtelmomis*
4005
SutterfTtoer *
Snickers Bar *
4035
4036
4037
41M
Reese's PB Cups
3431
6417
6416
6208
6216
Qufxsarsa Art^Firoal Powder 3 02
$0.60 0364 8lac* Ice Bo<tvWash Orv&ored bvPolo) 15 02
$0.60 0376 Black Ice Bo^ Wash flrttcdred by GiRC^ 15 o

to.so 0397 NeA One Cocoa Butter Bar of Soao 5 02
$>J 0400 Msh$pmg3.2 02
_Thai_Palace Nooflles wti Chill3 7 oz
0410 hcfy Bar Soap 3.1 02

$1.75 0415 Tone Soap 3.5 02
$1.75 0426 Ne4 One Sport Bar Soap 5 o2
Plan Baoel 4 oz '
$0.98
4201 Amt>iCocoaOuOerSoap3.So2
$l.TO
$4^
$1.^
$5.25
$16.40
$7.40
$2 75
$20
$2.10
$1 89
$1 48
$175
^27
$436
$4 36
$125
$1.05
$1.05
Loaf o1 WtMat Bread*
Tokvo Df>er SovSauoe 602 *
Dish
$1.20
$1.25
$2 15
$0 50
$3 55 0600 Cfswtord UcutfiMBSh 6 02

$2 60 0508 Ajm TarBr Control 6 02
Colpate TooO^paate 4.6 02

$2.30 0621 Coktc Whenr>Q TooWaste 6 4 02
$1.^ (M) Cooi Wave Toothpaste 4 02
$3.00 0542 Dental Flosser. 35 pk
$4 20 0516
$1.35
Tacote Hot Sauce 5 oz
4 02
Banxkxia Uoced Nuts withPeanuts 10 02
Ba<cek>na Health Mt<3.25
Sarcelora DriedTrooteal Fnj Gtend4 oz

Barcekiria Sudani Trat Mix 3.75 oz
Barcetona Honey Roasted Peanuts 2.5 02
6607
HOT HOT PtaniK 1 T", nr
6102
Com Nuts - Ranch i .402

SMled Jalapeno Chtos 1ioz "H
60B3
Moon Lodge White 13>e<3d3r Popcnm 5 oz
6127
Hoi ft spicy Porte Rhos 2 02
6078
Jalapeno Pretzel Pieces 2.25 oz
6080
Whoki Stâbar>o 6 oz *H
6081
Rê Potato Chbe 6 oz "H

Swfled Jaiaoeno Ch*>s6 oz "H
Sour Cream and Onion Goz *H
$1.66
$1 31
$0.75
3764
$320
$1.60
$3.50 0664 Oral Pain Retef ,33 oz
$2.67
$1.48
8600 Phone
^TAMPb \
$1.45
$1.60
1001
1004
F. C Mackerel Flakes h Ct.ii Oi w/Jalapenos 3.53 o
$t.90
F.C. Fitfi Steaks/CH wflSraen (aiBes 3.B3 oz *H

F. C MaAarel w^lot Cti Sauce 3.53 oz
F.C. Tuna o/Jalapenos 33 oz *H
1049 Snoie Stamp
$1 60
$1.55
1050
$2.39
FC. Ttra >1a pouch 423oz*H
$2^
pack
1200 AAA Bavertes 4 pack
F.C.Fsh Steak n Scry
oz
$4 55
Tek<Pro Soil Toothbnish

0590 Good Sense Denture Tablets 40 d
$1.55
F.C. Sardnes n Sovtean oa 3.53 oz m
Crunchy Peanut Bucer 16 oz *
$2 45
$2.26
Madiat3.S3 02^
Peanut Butter 18 02'
$1 26
$225
$0.30 0653 Universal V^na Super fVhey Proteh Powder $10.25

$4.10 06BO 1-Dav\/Itamin.90ct
$2.36
S1.9S 06S1 1-DavVilamt)wi'ron.SOct
$2.36
$3.00 0685 VOmnCSOOmo.lOOct
$2.57
$2.25 OC^ lAAi^Formuia VCamr. SO Cl
1S.&4
6632 Chopped Onsns *
MLPea(Msl.7Soz-
6143
0721
Beet Ramen 3 oz
6272 Garlie Powder *
6606
6101
GSArafCBl Tears
HOIand Scicv VeoetaUe Ramen 3 oz

Caiun Sftnnc Ramen 3 oz
2035 Samoa*
Com Nu& Chie Com ^hrts t .4 oz

Kraft BBO Com Nuts 1.4 oz
FiJdie-Faddle Potxxm 6 oz *
6234
Suoar Free Coutf> Drops
0691
$0.60
6525 San & Pepoef Shakers

3760 VoflotaMe Flakes *
6097
3242
6220
$0.60
LA Hcpt Sauc 6 02 *
df Ice Crawn
BoOer Poocom 3.5 oz
3679
Chcken Ramen 3 02
Z DiQby SF NVId Frun 1.75 Ol *
Barcek>na CâiunMric Stacy
6217
Chft Ramen 3oz
$2.85
$2.06
$156 6907 Mra Screngih AcetamhODhen, 60 a

$1.15 0673 Ranidtfne fZantac) 75mfl. 30 ct
$1.15 0679 Good Sense (PrBosec) 20mQ. 14 ct
$0.60 0693 GS E 0<oos

$0.60 0251 Anfrtunoa] Foot Cream
$0.60 0720 Medkeied */ifrFunoal Powder 3 02
ShnflKee Hot Sauce SrraO^ l7o2
BenJieyny/aUnooas
6201
6241
6213
Chicken Soup 3 oz
Ume Cnn Shr^p 3 oz
Tens Bee) Ramen 3oz
MawAr>aa 18 02"
Plan Hersney CantfyBat
6212
BBacoM Sioel $onaf>er smo. 100 d

Good Sense Miora^ fteliel. 24 cl
$2.05 0196 Good Sense Alfergv Reif. 14 a

$2.70 0670 Good Sense Nawt Sorsv 1 02
Retiiod Beam Soz*H
KmMJDl4 0Z'
' 4000 MSM Plan*

4043
$0.44
St.K 0235 SuaveLotonnttiAloe Vera IO0Z

S125 0265 Ambi $ldn Craem 2 02
$2.60 0770 i
0174
Spirv Retried Beans 8 02 *H
$0.08
\ iHlUN ^ SKIS CKtAM "

0214 NeM 1 Cocoa BuOar Lotsn 15 02
0260 Musde eeim 3 02
SevSIa Bean anfl R Hot ChiUFlavor 4.4 oz
$9.30
$335
$9.05
$1.91 0957 Daly Shampoo >/Eucalyplus S Mra t5oz

$3.00 0363 Siylftq Getw/Aioe 15 oz
0800 5-Comb
$1.25
El Pso Satoa Greeft Jalaspeno 12 02
CerxJvAjl-stara (Moed) 3.7S0Z
40)0
Neuffaoena T .Qei Sriamooo 4 4 oz
MufTBV's ftimade 4 oz
$1.18
Velvvela Beans ana Ri Soicy 4 oz

Sevla Bean and Ree C3>li Flatoi 4.4 oz
$2.05
0040 SoRee Halt Food 5 02
$3.70 0056
Velveeia Macaroni and Oieese SocvS oz
Huv Fona Sauce Chli Gartc Sa.ce 6 02

Kuv FcAQ Sau Srracfta CMi Sauce 17 ca
: 4156 Vanlla Caramels 3 oz

M&M Peamjt*
VOSShsnooo ISoz
VelveetaOieesvRico 2oz*H
BBQSaiX 1202
Slarftt lAiB 3.75 02

Alomic Fretaks 3 oz
Soui Frut Bans 4.2S oz
4001
$O.SS
$4.00
$3 00
cOSDIMtMS
ButttrscoKii Buttons 4.25 oz
*110
$1.65
$0.30
$030
Cactus Annie Tomias 6 <a
4019
0201 Herage6ftW^tnH4er1So2
0300 Oispoeable Ra20f

$2^ 036$ Dofpo Ruor - 3 &ade
Loaf ot Wtite Bread"
^go .Oatmeal Cakes 12-pBck
DMown 2 02
iZJO 0305 DtoosaWe BiZor Twn 6UK)e
BC ChHiw/ Beans 11.25 02

6C HOT Chli w/ Beans 1125 oz
Price
|2,6S 0114 spMetck Gel Oeod/AnboerK).

$2.85 0115 SoeecSsCicii $oi<) Oeod/Ajnoerso
SN K l,S IMilKll.v
I 3200 Banana Dalwe Moon Pie
mantKAM fcsiUM\c
Description
Price
6449 Jalapeno Cheese Bar 4 02
' 3046 CUstax Creme Cookies 6 oz K

3031
PwcrtpQon
2786 TonvChatfw/es GurrÔfVêc 6 02
$1^
3039 Mans Coonas

3146 CJ>ese crackers 9 oz.*
3219
3222
(ten*
$4.20
$1^
RoolbeerlZot
2433
Price
MISCI U
Sttjce
Ml \\S
50 Count Envelooes
HAFirKlfS
Stamped Enveiooe
01 Postage Stamp
Book of Ten Stamps
1051 3 cent s&mo

1210 M Baneries 4
1216
C Batteries 2 poek
$1.45
1219 D Batteries - 2 pack
$0.24
1209 9 volt Queries
W>e4ess Noiobook Paper
$1.50
Address Book
$2.45 0846 HanuCd^ Greedno Card

$065
0967
Yellow Leoal Pad 50 sheets
$1.10
T10J
Round SticSt
PtKo Album
OoutM Sk Dernros
Uno Plavtw Cards
n09
$2.96
AcrvlcMlrTor6)(4
Ceras] Bowl
Coffee Cup 12 oz
$0.2S
$0 45
Ffiendst^) Card
$2.60 1110 Friendsho Card - Glossy

$1.43 1115 Amwrsaiv Card
$1.65 1120 Thank You Card
na>^ Cards
Ptioctite Cards
Rutibennald Bowl
Meano You
Ar^nle BeMav
n03 BnhdavCard
T104 G1 WeJI Card
$0.80
r2 Pend W/Eiaser
Id 1.6 Ot
1124
Soan^ Friendshtp Card
$5 60 1126 Spanch Mother's Day Card

$2.09 1129 Valen&te's Day Card
$0 60 1132 Christmas Card
$3.50 1139 Father's Day Card
$0 71
44^90
$2 65
$24S
$325
$2.95
DUl i II\CC\HD>-
WhSe Leoer Pad 8.5 X11
Be
$0 01
$0.03
Bnmn Uni-source Envelopes 9x12
Wh4e Sketch pK)
$0 70
$0^
1140
riflv r.*rrt
$0 75
$0.75
$0 75
$0 75
$0 75
$0.75
$0 75
$0.75
$0.75
S0.75
$0.75
$0,75
$0.75
$0.75
jt
3SK
3062
9006
301C
3CU3
CftocooK Cwne Coocie$ >4oz

Soft ChocDlateCVVD Coolw 27S o2
SônUead Cookies 6 oz
Dunktftc StekA fbox o( 61*
Caiun Shrimp Ramen 3o2
6673
Thai Pafaee NootfM viSh fili
$2.40
2967
$2.60 1 2966
$2.70 1 6610
_OMm<a^Cakw t2Pae* *
6600
019
4100
6046
6052
6053
Lemon orops *
4121
>>ellv Beans^.ZSoz
4122 Jellv8eaAs7 oz
4145 Startle Mrs 3.75
AUmic FfebalU 3 oz
41S0
41S2
Soul Frui Balls 4^ oz

Can<*Ai1-Slar IMwed) 3.75 oj
Vanjia Catamals 3 oz
4000
MM Plan
4001
M&M Peanut *
4043
Snie4(ef8baf rAlrT>onas*
BuQerfnoer *
SAlAers Bar *
4035
Hes's PB Oup&*
4036
PhUn Hervhev Candv Bar *
4037
Herahey w/^moods
4155
G O^bySFWitf FnH i .75 oZ

Pra of tee Cream
6417
PI. WUl.S f. PUt'(.OK\

Poarvjt Bimer iSdz*
Crun&iv Paanut Butter ta oz"
6201
BuBer Poocom
Barcekxw Caiun l(Spcv3.5 oz

Barcelorw MstaaNuts wih Peanuts 10 oz
6206
6216
oz '
Barcelona Health Uaaii

Barcelona Dr^ Trooiaal Ftu< BImd 4 oz
Barcelona SUidentTra( Mk3.7S oz

Barcekna Honey RoaSM Peanuts
6220
Com Nuts ChteCom Nuts 1.4 02
6097
KraR BBO Com Nuts 1.4 oz
3?42
6606
6607
oz
Fddle.Fajdle PoBcom 6 02
ML Peanuts 1.75 oz
HOT HOT Pearuits 1.75 02
6234
Corn Nuts Rar>ch 1.4oz
Stutfed JaiAoertoChtes \ Soz 'H

Mooci Lodoe Whae Ched<tarPopcorn 5 oz
6063
6127
6076
6060
6061
Hoi 6 SpiCY Pork RjrKls 2 oz

iaiasieno Pretzel Reces 2.26 02
Whole Shabang 6 oz *H
RMe Potato Chice 6 oz *H
6101
Sufletj Jalapeno Ctw 6 oz *H
6143
Sour C/eam and Or>ion6oz *H
6165
B80 Chips 6oz *H
6247
Chli Cheese Com Chips 12 oz "H
6117
Cheese Citjr^chy 11 oz
6346
Hot Hot Cheese Cfur*Jiv 95 oz *

fiouvl Tortilla Chips 12 oz *H
NaciioChps 10 02 *H
6119
6150
6155
Com Chips 13 02 ">1
6166
6171
BBOCom Chips 12 oz *H
Kol6 Spicy Com Ch^ 12 02 *H
6196
Cheetos FlamrHoi Cheese Crvindty 6oz
6167
Cheeios Cheese Ciwctiy 2 oz
6349
The Whote ErKhlada 11 oz
6692
Cactus Annies Chees Pulls 10 oz
6696
MoonLodQeHoi BBOChJps 6 oz
3154
Scorch Haênero
f>ip irw>^
Black Ice Bodv Wash <t)sptre9 bv Pok>l 15 oz

Aack kx Bcdv Wash {Vttplred bvOucd) 16 o
$^0
kB&h SprrH)3.2 oz
0400
0410
Kory Bar Soap 3.1 oz
$436
S4 36
S1.25
SI.05
.05
$1.75 041S Torie Soap 3.5 02
$1.20
$1.75 0426 Nea One Spon Bar Soep 5 oz
S1.25
$096
jynb< Cocoa Buffer Soap 3.S oz
4201
S2.1S
$1.70 0491
>0.50
$ 3 ^ DSOO Crawtofij Moi/Awaah a oz
1.25
S2.25
$2.60 0506 Am Tarer Control 6 oz

0516 CoHsie Toothpaste 4.6 o2
0521 Coloate Whiunho Toothpaste 6.4 oz
0530 Cool Wave Toofhpeste 4 oz
0542 Denial Ftosser. 35 pk
0550 Tek'Pro Solt TootTibniSh
S0.9Q
6506 Tokw Oner Sov Sauoe 6 oz *
Ue4
2769 Taoaso Hot Sauce 5 oz
MM
66S6 Shho Kee Hot Sauce Srracrj 17 oz
$1.60
0500' Good Sene Oencure Tablets 40 d
$3.50
0664
1.40
aSI?
$1.15 0764 _
San IOCS*
BfOB Sa 6 Peooer Shaken
37eo VeofttM Rakes '
$0.90 0653 Unrverul Vanlla Super Whev Protein B9wi}ei $10.25

$4.10 0680 1-DavViBn)n.90et
$2^
$1.95 0661 1<D&vViBnin w%xsn.90CT
$2J6
$3.00 0665 VtenihC500mg. lOOd
$2^7
$ 2 ^ 0604 Mutt^Fomvula Vlamn. 50 a
S5^
PHOM TJML
$2^
621S EJPstoSatsaGreenJalaMnol2oz
so.se
6261 KeIcnuo14oz'
6S4S Uavweee 1B oz
2035
tl.40
$1.40
6272
GarlePoMdef *
S1.40
6632
Chopped Onicns *
>1.40
t1.40
6634
4oZ
Oral Paih Rellel .33 oz
$2 45
64 55
SI.68
SI .31
S0.75
$2.67
SV4d
Pefft)re
2.4 oz
$3^
$5^1
C. Mackefcl 3ôz^
F.C. Serenes h Soybeah Oil3.53 02 *H

F.C.Feh Steak h Spicy Miaarci Sauce
F. C. Mad(erel flakes InOJi Oi w/JatoDenos 3.59
$3.20
6660
$3.20
$1.00
$;.is
6190
F.C, Rsh Steaks/OB w^reen ChKies 3.53 oz *H
3554
F. C. Madierel
2564
F.C. Tuna wAfatapeoos 3.53 02 *H
$3.56
S1.15
6626
$1.15
$1.15
$OdO
S^jce 3^ oz
sTAVf'>i.H.AT1fHI(S
$1.45
$1.60
1001
1004
$V90
1049
S1.60
Stamped Envelope
$0.70
01 PosiaeoS^p
$0.01
Snole Stamp
1050 BookolTenSWps
S0f4e
64^
$1.55
1051 3cefn stwi>p
$2.39
1210
F.C. Tuna h a pouch 4 ^ oz *H
$24n
1013
50 Coir;t ErrbielODes
1219 0 Batteries - 2 peck
$0.24
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1046
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1015
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1047
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Case 5:15-cv-00767-C
Document
Filed 06/16/16 Page 3 of 3
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1129 Valentirte's Day Card
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Date: June 14, 2016

Attn: Clerk
United States District Court
Western District of Ol<lalioma
200 NW4'" St.
01<lahoma City, OK 73102

From; Michael D. Leatherwood
DOC NO. 595058
8607 S.E. Flowermound Rd.
Lawton, OK 73501
Re:
Case No. CIV-15-767-C - Michael D. Leatherwood v. Hector Rios, et al.
Dear Clerk,
Enclosed please find the following document which I am submitting to be filed by your
office.
MOTION FOR PRELIMINARY INJUNCTION
I have included an additional copy of the first page of the document to be file-stamped and
returned to me. Please include the document filing number at the bottom of the page
being returned to me.
Your assistance in this matter is greatly appreciated.
Respectfully,
DOC NO.
595058
MICHAEL D. LEATBESWOOD
LAWTON,
OK
73501
8607 SB FLOWERHOUND RD.
LEGAL MAIL
s \
I :) 'S
USDC. WESTERN DIST. OF OKLABOMA
CLERK
73102
200 NW 4th STREET

OKLAHOMA CITY. OK

Michael Leatherwood Motion

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Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 1 of 14

HECTOR RIOS, WARDEN, et. al.,

CARMELii/\..ccucR SHINN, CLERK

MOTION FOR PRELIMINARY INJUNCTION

preliminary injunction issued to prevent Defendants from continuing to violate Plaintiffs

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 2 of 14

at DOC operated facilities pay. As a medium security inmate Plaintiff is similarly-situated as

Keefe Commissary Network. L.L.C. an affiliate of The Keefe Group

Plaintiff has also learned that the menu

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 3 of 14

While Ranien soups are at

April 18. 2016. Price Increase of commissary items at LCF:

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 4 of 14

Okay. And who authorized that? Did you authorize that?

Okay. Did Warden Rios authorize that?

(Attach. No. 5, p. 19, 6-14)

Mr, Berg further testified as follows:

Okay. So if the commissary items are found to be unreasonable, then you

(Attach. No. 5, p. 21, 20-25; p. 22, 1-2)

Variety Of Commissary Items:

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 5 of 14

be used as cutting-weapons and can be swung in sheets or towels as weighted-weapons).

Okay. One. And on exhibit Number 7, which is Department of Corrections'

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 6 of 14

Plaintiffs lack of Irreparable Iniurv:

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 7 of 14

regardless of vendor contracts or price-structures. And, Defendants would have to order

a significant impact on LCF's prison operations." Doc. 29 at 5. (Emphasis added)

PLAINTIFF IS ENTITLED TO A PRELIMINARY INJUNCTION

In determining whether a party is entitled to a temporary restraining order or a

Plaintiff Is Threatened With Irreparable Harm:

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 8 of 14

As a matter of law, the continuing deprivation of constitutional rights constitutes

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 9 of 14

In deciding whether to grant apreliminary injunction, courts ask whether'the suffering of

scheme of commissary is not even remotely related to a security, rehabilitative or

When asked if the pricing of commissary items serve any

rehabilitative objective - meaning is commissary at LCF priced higher to help rehabilitate

(Attach. No. 1, p. 73, 19-23)

When asked if pricing

(Attach. No. 1, p. 73, 24-25; p. 74, 1-5)

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 10 of 14

But, LCF does not

operate the commissary - they have contracted commissary sen/ices to Keefe.

In the context of prisons, security,

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 11 of 14

Plaintiff is subject to the unequal treatment due

commissary price scheme is totally unrelated to any legitimate governmental interest -

If the inmates are able to purchase more commissary

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 12 of 14

In the prison context, the Equal Protection Clause of the Fourteenth

WHEREFORE, Plaintiff requests a preliminary injunction requiring the'Defendants to

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 13 of 14

Additionally, Plaintiff requests an injunction freezing any future price increases of

8607 S.E. Flowermound Rd.

Subscribed and sworn to before me this

My Commission Expires: O/r^ '/)^/-2^/?

Case 5:15-cv-00767-C Document 104 Filed 06/16/16 Page 14 of 14

611 SW24thAve. #102

Assistant Attorney General

313 NE 21st Street

Keefe Commissary Network, L.L.C.

Kutak Rock LLP