•"Rats climb over prisoners' beds in the dark and mice crawl out of broken toilets."
•"Rapes, stabbings, beatings, and other acts of violence are rampant."
•"The air is so contaminated from frequent fires that some prisoners expel black mucous from their noses."
•"Medical staff has ignored gangrenous wounds. One prisoner's scrotum swelled to the size of a softball before revealing a hard knot on his testicle. he was denied timely proper care for weeks and was later diagnosed with testicular cancer that had spread to his abdomen."
•"Suicide attempts are frequent; some are successful. Other prisoners engage in gross acts of self-mutilation, including electrocution, swallowing shards of glass and razors, and tearing into their flesh with sharp objects. Defendants deny prisoners even rudimentary mental health treatment and, last year, reduced access to psychiatric care."
•"Because there is insufficient officer staffing, prisoners are frequently left in the grime-covered shower stalls, wet, naked and cold for hours at a time."
•"Many cells lack functioning toilets; prisoners defecate into Styrofoam trays or plastic trash bags and have no way of ridding their cells of the waste other than tossing it onto the housing unit through the slots in their cell doors, where it remains."