Case: 4:20-cv-00007-DMB-JMV Doc #: 33-12 Filed: 02/01/20 1 of 4 PageID #: 446

EXHIBIT L
DECLARATION OF MARC STERN, MD MPH
 Case: 4:20-cv-00007-DMB-JMV Doc #: 33-12 Filed: 02/01/20 2 of 4 PageID #: 447

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF MISSISSIPPI
GREENVILLE DIVISION

MICHAEL AMOS, PITRELL BRISTER,

ANTONIO DAVIS, WILLIE FRIEND, CHARLES
GAYLES, DANIEL GUTHRIE, JONATHAN J. Case No. 4:20-CV-007-DMB-JMV
HAM, DESMOND HARDY, BILLY JAMES, JR.,
JUSTIN JAMES, QUENTEN JOHNSON,
DEAUNTE LEWIS, LARRY MAXWELL,
TERRANCE MCKINNEY, DERRICK PAN,
BRANDON ROBERTSON, KURIAKI RILEY,
DERRICK ROGERS, TYREE ROSS, H.D.
ALEXANDER SCOTT, DEANGELO TAYLOR,
LEMARTINE TAYLOR, CONTI TILLIS,
DEMARCUS TIMMONS, CARLOS VARNADO,
PHILLIP DECARLOS WEBSTER, ADRIAN
WILLARD, CURTIS WILSON, CALEB
BUCKNER, WILLIAM GREEN, ARIC
JOHNSON, IVERY MOORE, and KEVIN
THOMAS, on behalf of themselves and all others
similarly situated,
Plaintiffs,
v.
TOMMY TAYLOR, in his official capacity as the
Interim Commissioner of the Mississippi
Department of Corrections, and MARSHAL
TURNER, in his official capacity as the
Superintendent of the Mississippi State
Penitentiary,
Defendants.

DECLARATION OF MARC STERN, MD MPH

 Case: 4:20-cv-00007-DMB-JMV Doc #: 33-12 Filed: 02/01/20 3 of 4 PageID #: 448

On this 31st day of January, 2020, I hereby declare:

1. My name is Marc Stern. I am an Affiliate Assistant Professor at the University of

Washington School of Public Health.

2. I received a Bachelor of Science degree from State University of New York

(Albany) in 1975, a medical degree from State University of New York (Buffalo) in 1982, and a

Master of Public Health from Indiana University in 1992.

3. Over the course of my career, I have visited dozens of prison facilities totaling

thousands of individual visits, both in the capacity of an employee or supervisor, and in

performing inspections or serving as a monitor.

4. In the facilities in which I worked, I generally moved within the facilities

independently without custody escort. Based on this extensive experience, I am highly familiar

with maintaining my own safety and not putting other personnel or the facility at risk. However,

I generally am escorted in facilities with which I am not familiar. Given the extreme problems

Parchman has had maintaining order, I would expect an escort and will be prepared to obey

instructions.

5. As part of my inspection, I require the ability to accompany Madeleine LaMarre

in performing the following actions at the Parchman facility Units 29, 30, 32, and 42:

a. Tour and inspect medical clinics and infirmaries;

b. Tour the housing units, including segregation, and inspect: call lights for
functionality, lockable sick call boxes and sick call request forms, and emergency
equipment and inspection logs;

c. Speak confidentially to inmates in each housing unit, medical clinics and

infirmary, and review those inmates’ full medical records file;

d. Observe medication administration in general population, segregation, and

medical housing or infirmary, in the morning and evenings; and

e. Review current health care systems policy and procedure manual.

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 Case: 4:20-cv-00007-DMB-JMV Doc #: 33-12 Filed: 02/01/20 4 of 4 PageID #: 449

6. I will require approximately four days to perform the actions necessary for a

thorough preliminary inspection, and I will work in conjunction with Madeleine LaMarre to

avoid any stress on prison resources.

7. Finally, I concur with Dr. Eldon Vail’s declaration dated January 31, 2020.

8. I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 31, 2020.

_________________________
Marc Stern, MD MPH