Inside FCI Fairton

Gerhard, Jason

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Inside FCI Fairton Jason Gerhard An enormous amount ofmoney is spent on the federal prison system. In 2013, it was calculated at $29,291 per year, or $80.25 every day for every prisoner, all 210,000 of them.1 The billion dollar question then becomes whether this money is being spent judiciously or like the vast majority of federal programs is being misappropriated. After having spent the last six years at Federal Correctional Institution Fairton, New jersey, it has become obvious to me that there is the rosy story sold to the public and the very different reality that exists just beyond the razor wire. The A C 11. ARCS Every three years, the Amei ican Correctional Association, a private, non—profit organization, conducts an audit at Fairton in order to re—accredit the facility. Though voluntary and non—binding, the process is taken quite serious issue by prison staff. There are a number of industry standards, yet failure to meet these standards is acceptable if transgressions do not "adversely affect the life, health, and safety ofstaff or inmates"? Through the Freedom of Information Act, I was able to obtain copies ofthe 2007, 2010, and 2013 ACA audits. Curiously, all accounts documenting the various ways in which the institution was noncompliant were redacted from the 2013 report. Previously, in the 2010 audit, names of the staff were redacted in accordance with "5 USC 552 (b) (6) -- personnel and medical files and similar files the disclosure ofwhich would constitute a clearly unwarranted invasion ofpersonal privacy." Using this loophole the names ofthe warden, assistant wardens, and other personnel at the administrative and staff levels were redacted despite the fact their names appear on countless memorandums and are well known to all inmates. In 2010, Fairton was in violation ofseveral standards ofserious importance. Standard 4-4129, "The number c-finmates -oes not exceed the facility‘: rated bed capacity," is way out ofwhack. From the waiver request we learn that, "The designated capacity for FCI Fairton is 1264 (FCI 1110; FPC 100; PCU 54), with a current population of 1511 (FCI1316;FPC 128; PCU 67)." (There are three separate facilities on the same plot of land though fenced off from one another. FCI stands for Federal Correctional Institution—— medium security. FPC is the Federal Prison Camp——no fences, the lowest security level. PCU is a small fortress located next to the FCI's recreation yard and is the Protective Custody Unit where high profile informants find refuge. Government documents refer to this facility by the moniker "Sierra.") Standard 4-4132 requires a minimum of 25-square feet ofunencumbered space per occupant in a cell. In the FCI's 3—man cells [retro fitted 2~man cells) the ACA claims only 17.08 feet is available per inmate. Yet this is not accurate. The standard’s instruction is as follows: "In determining unencumbered space in the cell or room, the total square footage is obtained and the square footage of fixtures and equipment is subtracted. All fixtures and equipment must be in operational position and must provide the following minimums per person: Bed, Plumbing Fixtures (ifinside the cell/room), Desk, Locker, Chair, or Stool." My results were only 47 square feet in the 3—man cell. This equates to only 15.7 square feet per occupant. (This is easily calculated, as each floor tile is one square foot.) Standard 4-4134 deals with the amenities that each inmate is to have in their cell. If one is confined to a cell for less than 10 hours daily (as general population is at the FCI), he is to have a "sleeping surface at least 12 inches off the floor; storage for personal items; adequate storage space for clothes and personal belongings." The FCI was found to be in non—compliance because, "The bottom bunk in the 166 3- man cells in the FCI units is only eight and nine inches from the floor." While three to four inches is n.ot much to complain about (or conversely, to brag about), the administration's response is of most interest. "Currently, FCI has 166 3—man cells with prefabricated 3—man bunk beds. Each inmate in the 3—man cells is provided with a storage bin and locker for their personal effects. Our current housing plan is to not assign the lower bunks, however that varies with the population that is assigned to FCI Fairton from the Bureau's designation center in Texas. At this time funds are not available to re-do the pre—fabricated bunks." For starters, no one was ever issued a storage bin in the 3—man cells. They were available for sale in the Commissary for about $80.00, though. Then, on May 28,2013, the Captain issued a memorandum forbidding them for anything but legal materials. Secondly, I find it odd that funds were not available to redo the prefabricated bunks in the 3—man cells, but there was money a couple years ago to change 10 cells on C-Unit from 2—mans into 3—mans. Always seems to be money available to squeeze in more prisoners. Standard 4-4139 concerns showers. At a minimum there is supposed to be one shower for every eight inmates. During the 2010 audit, shower ratios were found to be one shower per 21 inmates. We were assured by the institution thatthere are no complaints because "inmates have access to showers 15.5 hours per day, seven days per week at the FCI." But wait, on March 3, 2009, a memo, "Water Conservation "was put out by the Warden. "In the general population units, showers will be open from 6:00 AM until 9:00 AM. Once cleaned, the showers will remain secured with the exception of one shower open upstairs and one downstairs. On Friday before Iumah [Muslim] prayer, an additional shower will be open from 10:30 AM to 12:30 PM. After the 4:00 PM count clears, all showers will be open." If that memo was issued in March 2009 and the auditors came in September of 2010 that means there was roughly 18 months during which this policy was in effect prior to their visit. Later, in 2011, the Warden confirmed that the policy was still in effect. In a written response, he passed off the blame to the White House because the, "Bureau of Prisons has been mandated by the President ofthe United States to reduce water consumption by 2%." In true Orwellian style, he added, "The information utilized for the ACA report is an accurate account of the shower availability at FCI Fairton." Ironically, about 15 months after the water conservation plan went into effect, the Health Services department released a memo oftheir own. The topic: MRSA. For those unaware, MRSA is a strain of staph that is resistant to antibiotics and causes nasty skin infections. Thankfully, several tips were provided within this memo to reduce the risk of contracting the nebulous MSRA. Inmates were to, "Maintain excellent hygiene through regular showers..." and to "Shower after participating in close Contact recreational activities, wliezzever _Well, with about .170 people on each unit and only two showers open, it might not be all that possible. My attempts to determine how much money the taxpayers spend for these phony audits have been predictably stonewalled by the BOP. An article by Alex Friedman, in the October 2014 edition of Prison Legal News, "How the Courts View ACA Accreditation," sheds some light on the issue. Friedman writes, "The organization basically sells accreditation by charging fees ranging from $8,100 to $19,500 depending on the number of days and auditors involved and the number of facilities being accredited." He goes on to write, "The ACA relies heavily on such fees; it reported receiving more than $4.5 million in accreditation fees in 2011-almost half its total revenue that year." Not bad for typing up 50 or so pages and walking around a prison for a couple days—-every three years. [Updatez As this essay was being edited for the umpteenth time (what, you can't tell?) the BOP decided to finally fulfill my FOIA request-—filed nearly 11—months ago--that requested information concerning how much money the ACA has been paid over the last 10-years. True to form, the government only released one year's worth of records-—fiscal year 2013. And to think this is the most transparent administration in history. For fiscal year 2013, the American taxpayers were swindled out of $344,536.00 for pseudo audits, courtesy ofthe ACA. Audits were "performed" at 32-institutions for $9,374.00 a pop and 'C‘v‘v"(-3 cornplexes (Alleici.-Wood in Pennsyl-Vania and Terre Haute Indiana) for $22,268.00 each.] Riding into the Red One day, in 2012, I was handed an interesting document. It was a proposal from the Supervisor of Recreation at the time, T. Brown, to purchase 10 exercise bikes. Why would the institution need more stationary bikes given that there are over a dozen stationary bikes? Because these new ones generate electricity! The PlugOut Cycle is simply a stationary bike with a generator and invertor attached, all for a mere $1,399 each. Brown figured it would cost another $776.45 for installation materials, bringing the grand total to $14,776.45. Fortunately, this project fell through, or so it seems. A Freedom of Information Act request to the BOP asking for details about the project, such as to who was to fund it, resulted in their claiming on March 5, 2013 that no documents existed. The one bike that was in the gym for several weeks (until it broke) disappeared one day and never returned. Brown's rationale for the project is enlightening as to the prevailing bureaucratic mentality. Under the heading, "How Much Money Can You Save," he writes, "lfyou assume that most adults will generate 100 Watts continuously and work out for 1/2 hour on average, then they will have generated .05 kwh (100 Watts * .5 hours = 50 Watt- hours/1000 Watts=.05 kilowatt-hours}. This equates to only 1/2 cent per workout, assuming the utility is charging 10 cents per kwh and illuminates the biggest reason why this technology is not more widely used." Using his figures, it would take running the bike 24 hours per day, seven days per week, for 5,829 days to break even on its $1,399 price tag. That is nearly 16 years. Mind you, they only come with a one-year warranty. He also claimed the bikes could "be used as a job description while being employed in Recreation." Guess the bikes weren't a big enough waste of money, it was necessary to compound the damage by paying people to use them. Distrust Fund According to the BOP Program Statement, 4500.10 the Trust Fund/Deposit Fund Manual, Trust Fund is defined as, "The 15X8408 Account designated by the U.S. Treasury for programs, goods, and services for the benefit of inmates (e.g. Commissary)." Prisoners at Fairton are able to purchase various products (food, clothing, stamps, etc.) at the Commissary once a week. While selection of merchandise and availability lies somewhere between a Soviet—era grocery store and Monty Python's Cheese Shop, they do quite well, thanks to the power of monopoly [where else are you going to go?). Since the Trust Fund is supposed to fund a variety of endeavors, they are allowed to charge a 30% markup on nearly all the items sold through the Commissary. The list of goods not marked up is quite short: Postage; Self—improvement textbooks; Correspondence Courses; Tools and Materials for Education/Vocational Training; Law Books or Other Legal Materials; Religious Articles; Smoking Cessation Program Materials; and Passover Meals during Passover. In 2013, the Commissary sold $2,180,197.56 worth ofgoods. Ofthat, $74,031.45 was stamps, which cannot be marked-up. This leaves us with $2,106,166.11, 30% ofwhich is Trust Fund profit: $631,849.83. It should be noted that the Commissary figures provided to me did not specify which sales were exempted from the 30% mark up, besides the stamps, of course. Therefore, this Trust Fund profit figure may be slightly off. However, it is difficult to imagine that more than a few thousand dollars of Passover meals, prayer rugs, and the like, being sold in one year. According to policy, this money may be spent on a variety of items: Arts and Crafts Activities; Recreation Programs, Equipment, Supplies, and Repairs; Educational Programs and Supplies; Inmate Service Items [such as microwaves]; etc. What is troubling is that prisoners are not provided with even the most rudimentary accounting ofhow ‘their’ money is being spent. Rumors are numerous, facts are not. The whole process is shrouded in mystery. Reassuring words are contained in the program statement through: "Principal financial statements and an annual report are prepared by BOP staff. The final report is available to the public. Trust fund financial records are audited or reviewed in accordance with Department oflustice and Bureau of Prisons requirements." Ifthe BOP blatantly lied to the ACA, as noted previously, why would anyone trust them to audit themselves? This is the very definition ofthe fox guarding the henhouse. Concerning the report being available to the public, why would anyone care, and ifthey did, how would they know ifthe items claimed were ever purchased ifthey've never stepped inside the prison in question? After all, where are those 498 gray storage bins that were supposedly purchased for inmates living in 3—man cells? Phantom of the Laundromat At Fairton, washers and dryers are provided to prisoners by the New Iersey Commission for the Blind and Visually Impaired (they're under the auspices of the Department of Human Services) for a fee. Currently, it costs $.65 per wash and $.65 per 45- minute dry. For this privilege, CBVI gives 15% ofthe proceeds to the feds. This partnership began in 1999. The institution provides free laundry services, but there are restrictions on what may be washed: only issued clothing. Nothing purchased off Commissary is accepted such as sweatshirts, shorts, thermals, etc. Further reducing the services popularity is the fact that all institutional laundering is done there. This includes greasy kitchen rags and aprons, mop-heads that cleaned God only knows what, and other questionable articles of clothing. In the past CBVI employees were required, once a month, to visit all nine locations where their equipment was located and download usage data from the debit card readers, "to ensure the correct percentage of profits is paid," according to their contract. On December 21, 2009, CBVI employees managed to download usage data from two separate locations that stand several hundred feet apart, at exactly the same time-—8:27:00 A.M. Given the fact that they are required to move with an escort while on the compound, it is difficult to see how they managed this feat. Efforts to obtain the visitor log for the day in question proved futile as it was completely redacted. The officer log books for three units (including the two where this occurred) has routine activities listed in them such as ‘work call,’ ’count time,’ and 'released unit for chow,’ but no mention ofCBVl's visit that day. On February 23, 2011, roughly 14 months after I first started asking questions, the contract with CBVI was modified. Previously, inmates would go to the Commissary and place money onto their identification cards, which contain a magnetic strip, like a credit card. They could either use the ID card to purchase copies or utilize the washers and dryers (at $.50 per wash and $.25 per 30-minute dry). Now the feds buy pre~loaded laundry debit cards at $5 each from CBVI that have "a value of 10 laundry cycles," with each cycle being either a wash or dry. While this greatly increases accountability,., there is no need to rely on monthly usage data from all the individual machines, inmates for the first time are being subjected to the 30% mark-up for laundry services. Readin' Ritin' Rithmetic and Recidivism It would seem pretty obvious that education is essential for successful rehabilitation. Numerous studies have shown just that——education reduces recidivism. While I do agree with the Disraeli et al quote, "there are lies, damn lies, and then statistics" (the ever —manipulated unemployment numbers are a good example) a study done by the Texas Department ofCriminal Justice in 1993 is worth noting. They found that 60% of individuals released from prison were re—incarcerated, but for those with an associate's degree, the rate was 13.7%, and for those with a bachelor's degree, it was S.6%.3 [Fun Fact: Fairton eliminated their partnership with Cumberland Community College which provided college courses in 2010.] Several years ago, I decided to fill out a three page, official looking, survey while in the library at Fairton. The "Department oflustice Federal Prison System Annual Education, Recreation and Library Survey," to be exact. A program statement number.5350.12 was written on it along with the date September 8, 1981. For one reason or another, I never did turn it in, choosing instead to file it away. While researching various aspects of the education department, I figured it would be interesting to see the results ofthese surveys; and ifanyone ever actually filled them out. After asking numerous times over the course of several years, via the FOIA for the last 10 years ofthese survey results, I was told on March 25, 2014 by the BOP that, ''In response to your request for the ‘last 10 years ofAnnual Education, Recreation, and Library Surveys.’ Please be advised the policy number cited, does not exist." Really makes you wonder why someone went through the effort to create a fake survey in the first place. Or perhaps the results were so bad that they were 'disappeared?' Requests for Bequests Soon after arriving at Fairton, one of my goals was to have documentaries donated to the library. They are an excellent way to convey information, especially to those who have difficulty reading as a lot of prisoners do. Although the DVD collection has expanded since I first came here in 2008, a good deal of it is National Geographic titles that are not exactly pertinent to the concerns ofthe average prisoner. Unfortunately, the Bureau of Prisons only allows donations from "religious or educational groups or entities, provided such donations are valued at $250 or less." This falls under statement 1350.02. On March 8, 2012, I filed a FOIA for the last 10 years of records pertaining to what items were donated to Fair.'ton’s library. The answer arrived Se__otemb»er 19: "Please be advised, a search was conducted for quarterly reports for the past 10 years. As a result, only records for the past three years were found." Yet this wasn't entirely true. Each quarter, or three months, a donation report is generated. The reports given to me began with January to March 2012, and ended with January to March 2008. Missing during this time span was October 2009 through December 2010, over an entire year's worth of reports. This may have simply been an oversight during the collection of the records as I was given identical copies for five ofthe quarters, and for another, July to September 2008, three copies. Among the records given to me, there was only one mention ofa possible library donation (there is no designation as to which department items are donated to——library or chapel). On November 5, 2008, International Prison Ministries donated 250 greeting cards and 80 paperback books. Except for that possible donation, religious services took the rest. Among the items they received were: Abalone Shells; Christian DVDs; four Sermon CDs; 500 Christian testimony pamphlets; 2 Tefillin; 6 Nation oflslam DVDs; and 1 DVD featuring a Rastafarian concert. The current policy on donations is outdated and counterproductive to the true aim of education. Allowing a virtually free-market for ideas (obviously material detailing pornography and escape might not be the best choice of material for a prison environment) ought to be the goal. The idea that someone cannot buy an educational DVD from Amazon and donate it to the library makes no sense since they can buy a book and have it sent to the prison from the same website. Besides, why should the taxpayers be on the hook for yet another global-warming documentary? MP3 Players: More than Tunes Over two years ago, MP3 players were first sold to the inmate population at Fairton. As can be imagined, they were a big hit. Songs were available in three price brackets: $1.55, $1.20, and $0.80. Soon thereafter prisoners started asking about making foreign language material and audiobooks available for the MP3 players, myself included. The standard reply was that the local administrators had no control over that; it was in fact up to the big shots in Washington, D.C. Years later, the same tired line is still being used. Apparently, the big shots in D.C. believe that such material is already available. Within the previously mentioned trust fund program statement the following can be found: "MP3 Players. In order to provide an additional method to disseminate information, provide educational materials. provide access to music at remote locations and provide access to culturally diverse music, the MP3 Player identified by the Central Office, Trust Fund Branch, is sold in the Commissary." (Emphasis added). Slwrt Circuit In 2015, prisoners are still using electric typewriters. While not every job these days requires word processing skills, possessing such skills would surely increase a prisoner's chances of finding work upon release. The BOP might be on to something, though. According to The Economist "Russia has ordered 20 typewriters, reportedly because ofthe vulnerability of computers" (November 29, 2014. page 56). Why keep using antiquated technology? Could be because it is highly profitable. While the typewriters are free to use, it is up to the inmates to purchase the requisite items to make them work. A typing wheel will set you back $19.99, a typing ribbon is $7.75, and correction tape is another $1.55. Before you type one word it will cost you nearly $30; and don't forget the $5.15 pack of paper. It is stated in the trust fund program statement that trust fund profits may be spent on "typewriters and typewriter supplies." According to fellow prisoners, other prison libraries supply typing wheels, among other items. The warden sees it differently. According to him: "We are providing you with the typewriter and we are providing you with the opportunity to buy everything needed to use the typewriters." Further demonstrating the profit motive behind this set-up is the response that the previous Supervisor of Education, Brian Womack, gave when asked how indigent inmates [one "who has not had a trust fund account balance of $6.00 for the past 30 days" Program statement 6031.02) might access a wheel, ribbon, and correction tape. He stated, "Indigent inmates can hand write legal material." T Adding to the absurdity ofall this is how broke down these typewriters are. The first day that I began typing this essay, I was given a typewriter whose shift key, along with several others, did not work. At the same time that I was removing the $30.00 worth of accessories from the machine (that the Warden so kindly allows me to purchase), so I could trade it in for a less broken one, a loud screeching noise was emanating from another typewriter to the right of me. The older gentleman had no idea why his machine was flat lining, but the noise was so intense that a correctional officer came out of her office to yell, "What's that noise?" This finally prompted someone to unplug it. The next typewriter I was given had a mind of its own. Whenever it felt like it, instead of typing the correct letter, it would print two parallel lines like the letter H without the cross bar and taller. Over the course of typing two pages, it occurred nearly a dozen times. The best part is that you can't erase them due to their not being real characters (when you erase, the ribbon lifts up automatically and the correction tape, taking it place is struck by the typing wheel, lifting the errant letter off the page). A Different Direction? Once Womack left in the spring of 2014, there was hope that perhaps the library would start to resemble a library. In that vein, I approached the new supervisor, Kim Neely, shortly after her arrival in the summer, about a concern of mine. For the whole time that l have been here, no system has existed to return books to the library that are on the various housing units. When Ms. Neely heard how books were being thrown away, as there are no bookshelves in the housing units (or unfortunately in the individual cells) to store them, she appeared to show genuine interest. Several weeks later, I once again asked ifany change would be coming and she assured me of her concern. Finally, on October 31, 2014,] sent her an email, "Several weeks ago you said that you'd be trying to establish some sort of mechanism to have books on the units returned to the library, in lieu ofbeing thrown away. Has there been any progress made in this effort, cause [sic] such a measure is sorely needed. Thanks." And the bureaucratic response was, "Yes, I am looking into this. I am waiting on a budget." To top off the tall glass of indifference, it was signed, "Brian Womack." I guess changing the rubber stamp is too tiring these days. It is difficult to understand about how initiating a system to return books to the library would cost more than a few dollars. All inmates are required to have a job by policy. In general, the lowest pay is $5.25 per month. Compared to some of the other inmate jobs, going to all eight housing units once a week, to pick up library books is a dream job. All you need is to place a cardboard box on each unit and then have a guy go empty it once a week. This isn't difficult to imagine or to execute. No, it isn't about the money at all. The truth was obvious as I walked into the library to type this essay. Iust beyond the main door was a five—foot tall circular stack of books about three feet at the bottom and narrowing towards the top, draped in Christmas tree lights. The juxtaposition of this "tree" with empty bookshelves around it was striking. For this is the essence of our prison library—-a prop, not designed for actual use, besides bilking the taxpayer, of course. Conclusion Before any reforms can be made within the federal prison system there needs to be a thorough accounting of what is actually going on. This however is nearly impossible under current circumstances. Obtaining information through the Freedom of Information Act and filing grievances is intentionally made slow, grueling, and expensive to discourage any would-be reformers. A good example ofthis would be what happened to my grievance, filed through the BOP administrative remedy system, concerning the storage bins that were never provided to inmates living in 3—man cells. Central office was supposed to provide an answer to my grievance by December 16, 2013. Over a year later I'm still waiting. While I could proceed to the courts (in whom I have about as much faith as the BOP to do the right thing), due to the Prison Litigation Reform Act (PLRA), doing so will cost $350 for the initial filing fee. To appeal costs another $450. Adding yet more bureaucrats to this stew of incompetence that is the BOP will not help, no matter what phony title they are given. Business as usual is simply too profitable. An outside voice is required to amplify the voices ofprisoners who have a vested interest in an efficiently run prison and are intimately aware ofwaste within the system. This can be achieved by creating a Citizen Advocate (CA) position for every federal prison complex. In order to maintain his independence from the BOP, the CA would be selected from amongst all the resident prisoner's approved visitors by those very same visitors through an annual popular vote. Allowing only the visitors to vote for one of their own would prevent prisoners from politicking on the compound yet allow them an indirect voice, through their visitors, to express their approval or disapproval of the CA's job performance. Additionally, the CA should be paid from the inmate trust fund, so as not to burden the taxpayer with another bureaucrat's mouth to feed and further guarantee the CA's independence. The Citizen Advocate's duties would include: 0 Ensuring that all audits, financial records, contracts with outside vendors, trust fund expenditures, etc. are made available to the public and inmate population within 90 days of their publication or acquisition by the BOP. - Attending any public meeting that the prison administration conducts with the community (i.e. Community Relations Board meetings) and making the meeting minutes available to the public and inmate population within 90 days 0 Assisting prisoners in their filing oflegitimate FOIA to ensure the BOP follows the law. Producing an annual report detailing any areas of concern within the prison that would be released to both the public and inmate population. There already is an infrastructure to allow inmates to View digitized documents: the Electronic Law Library that is in each federal prison. Court decisions that are hundreds of years old, various legal assistance books, and the various BOP program statements (they detail how policy is to be enforced) are available at the click ofthe mouse. What is preventing the publishing of audits, trust fund data, etc.? By providing the public access to the exact documents that prisoners see will cut down on the tendency within the BOP to redact information that in actuality is not sensitive. It would be difficult to explain to the average American how the Warden's name is sensitive information. Efficientvprispons do not only benefit prisoners; they benefit the communities that will eventuallyqL’tJhve‘m years down the road. As a Fairton administration official candidly confessed to me recently, "prisons are just schools where [prisoners] learn how to become better criminals." This is true under the current set up where educational opportunities are more readily found amongst fellow prisoners than through official prison programs that are often mere Potemkin Villages, whose sole purpose is to justify the department's bloated budget. A whole slew of unofficial, prisoner taught, classes are available though: Crack Dealing 101; Prostitution 101; Bank Robbery 101, etc. that provide quality guidance for today's up and coming criminals. We can't honestly believe that the very people who are benefitting from the dysfunctional state ofthe BOP will be its saviors. No sane bureaucrat would intentionally derail the gravy train that he's riding to retirement. An outsider, who doesn't take his marching orders from D.C., is needed for any hope of meaningful reform. jason Gerhard is currently serving a 20-year federal prison sentence for assisting a New Hampshire couple during their approximately 8-month standoff with federal authorities over the legality of the federal income tax. For more information, as well asfor documents cited in this essay, visit: AmericanPoliticalPrisonersAlliance.info or email: APPA4‘Freedom@yahoo.com Citations 1 Congressional Research Service; Bureau oflustice Statistics. 2Agency Manual ofAccreditation Policy and Procedure (Revised September 2007). Page 41. 3Gerber, Iurg and Fritsch, Eric]. "Prison Education and Offender Behavior: A Review ofthe Scientific Lit—erature." Texas Department ofCriminal Justice: Institutional Division. July 1993.

Author: Gerhard, Jason

Author Location: New Jersey

Date: October 24, 2016

Genre: Essay

Extent: 11 pages

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