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AY a ee ee gr . i) ) | 16 o . fhe systematic pattern of conduct complained of . herein and committed by defendants, includes but is not limited to the following: From the moment John V. Mills was found dying on January 16, 1979, approximately 165 inmates of the California Training Facility where Mills worked as a guard and where he received his injuries, were subjected to humillating and . badgering interrogation without the benefit of advice by counsel, family, or friends; such conduct by defendants continued for approximately one full week, during which time plaintiffs were placed in isolation and they were charged in the Indictment as is hereinabove set forth. | 16 Several alleged and prospective witnesses for the prosecution against the plaintiffs, “have been and are recei- ving special and favered treatment, and they have been pro- mised special ari favored treatment by defendants if they offer testimony against the plaintiffs at their trial. - “16¢ Plaintiffs and their counsel have sought to question and interview persons who were at the Correctional” Training Facility at Soledad at the time of the death of John V. Mills; their efforts were early met by refusals by d@efendants to allow them to do so and later by difficulties hereinafter described; py transferring prospective witnesses to facilities scattered throughout the State of California, and by threats and intimidation of such prospective witnesses. When plaintiffs obtained a court order to interview said inmates, defendants ordered, encouraged or pernitted = forn -~€- een rr Oe ola toe