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DECLARATION OF MARCY SIZEMORE

    I, Marcy Sizemore hereby state as follows:

    1. I am a 17 year old resident of the State of Virginia, residing in Chantilly, Virginia.. I presently attend Fairfax Baptist Temple Academy.

    2. From December 27, 1980 until March 1982, I was enrolled in the Straight Inc. drug rehabilitation program in St. Petersburg, Florida.

    3. I traveled to St. Petersburg Florida with my mother to enroll in the program. When I arrived at the Straight, Inc. headquarters in St. Petersburg, I was taken into a room by two other teenagers for intake. I was kept in the room for approximately five hours, and couldnít eat or use the bathroom during those five hours. Two girls sat in front of the exit door to the room . I couldnít leave, and I was told that it I didnít enroll in the program that they would put me in a mental institution. They also told me that if I didnít sign myself into the program that I would be put into the program by court order for a period of two years. I eventually signed myself into the program, was strip searched, and then entered into the Straight program.

    4. During my 14 months in the program. I witnessed the types of abuses as set forth in the complaint in Collins v. Straight, Inc. Enrollees on first phase were not allowed to make any movement or to even use the bathroom without someone holding on to them, and they were kept under guard 24 hours a day. Individuals who did not cooperate were placed on prolonged diets of peanut butter sandwiches and water "choker sandwiches" and were placed in punitive isolation for weeks and months at a time. This was known as the time out room.  The treatment consisted of 12 hours a day of sitting in straightback chairs, participating in rap sessions, which amounted basically to being confronted by other teenagers  concerning drug and alcohol use. When I was in the program, the only exercise we got was once a week, which consisted of forced exercises, usually consisting of 100 pushups and other strenuous exercises.

    5. The standard practice of Straight, Inc. is to prevent any individual who misbehaves in any way from progressing in the program. During my 14 months in the program, I was put back to the beginning of the program at least four times. Each time I was put back to the beginning of the program I was put on "first phase, newcomer status" which meant that I was under guard 24 hours a day, and was in physical contact at all times with another enrollee.

    6. Another standard practice of Straight, Inc. to punish those participants who "misbehave", was to subject the enrollee to a "marathon". In December of 1981, I had been placed on "no phase", which was meant I was frozen in the program and could not make any progress. I was accused of "misbehaving", because I simply sat in the rap session and did not participate. As punishment for this nonparticipation, I was taken into a bathroom by six or seven other girls, and I was kept in the bathroom from 12 noon until 9:30 that night. In the bathroom, the girls beat me, punched me, placed their fingers under my collar bone and twisted the bone, and verbally abused me for 9 1/2 hours. The girls would hold my arms out at the sides, while another girl would run across the room and ram her head into my stomach, and this was done continuously. I was thrown up against the wall, pushed back and forth, and was made to stand on my feet the entire 9 1/2 hours. I was told that I was crazy, that I would be put into a mental institution, and that if I did not participate I would be taken to a program where lesbians would get me and I would have to work in the fields.

    7. During this marathon, I was so physically exhausted that I passed out twice. Whenever I passed out, the girls kicked me, pulled at me and made me get to my feet and again continued to subject me to the beating. When I asked for water, I was told I could have water, and then they poured it on my head. The girls worked in shifts, and always kept at least six to eight girls in the room with me at all times. After 9 1/2 hours, the marathon stopped, and I was taken to my "foster home". At that point, my entire body was covered with bruises.

    8. This type of marathon is done regularly on the Straight, Inc. enrollees if they "misbehave." The other teenagers who carry out the punishment are "staff" or "trainees", who are former participants in the program.

    9. Another type of punishment imposed on Straight, Inc. enrollees if they "misbehave"  or do not do what they are told is to sleep-deprive the enrollees. We would be made to stay up until 3 a.m. on Friday night, participating in open session, stay awake all day Saturday, all day Saturday night and all of Sunday night. I once observed one enrollee who was subjected to this type of sleep deprivation, and on Sunday night she fell on the floor and went into convulsions. Other enrollees were used to curse us and prod us to keep us awake so that we were unable to sleep during periods of 48 hours or more.  

    10. During my 14 months in Straight, I also suffered from specific medical problems. At that time I suffered from allergies, and I needed shots every two weeks in order to treat the allergies. The Straight, Inc. people denied me access to these shots, and I received them only occasionally while I was in the program. In fact, I only saw a doctor once in the entire 14 months I was in the program.

    11. While in the program, I also had a serious I fungus problem with my feet. The fungus was so bad that my feet were swollen to the point where I couldnít walk and they also smelled very bad. I told my "foster mother" that I needed medical attention, but I received none. I was unable to wear my shoes, and I received no medical care until my mother took me to a doctor.

    12. By the time I got out of the program in March of 1982, my physical condition had completely deteriorated.  I had developed open sores all over my back and arms, and I am informed by my pediatrician that this condition is caused by the mental and physical debilitation I suffered while in the Straight, Inc. program.  

    I hereby affirm under penalty of perjury that the above statement is true and accurate.

Date: 12/5/82

                                                                   Marcie Sizemore