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gave sworn testimony. Your Affiant, as a result, became aware
that Lisa had been severely psychotic by at least the second day
of her stay and continued to be psychotic until .her death; she
was viewed by her caretakers as someone who was unable to care
for herself, talk coherently or make logical decisions; she was
watched by employees on a round-the-clock basis, was
intentionally isolated by employees who removed the phone from
Lisa’s room and avoided talking to her or in her presence, never
attempted to contact Lisa’s next-of-kin, repeatedly prevented
Lisa from leaving the premises, and held Lisa down for periods of
as much as an hour because she became violent or
self—destructive. Your Affiant also learned that employees
attempted to treat Lisa’s condition by inducing sleep and, in
order to accomplish this, medicated her without her consent and
without appropriate medical supervision or authorization. All
CSFSO employees were represented by counsel and had refused to
give sworn testimony before the State Attorney’s Office until
they were granted use immunity pursuant to Chapter 914. Your
Affiant states that he has reviewed records subpoenaed from
CSFSO, and was present during the testimony of CSFSO employee and
custodian of records Glenn Steilo who indicated that the Ft.
Harrison Hotel is owned by CSFSO, and that all the caretakers,
Medical Liaison Office employees and Alain Kartuzinski, with the
possible exception of Sylvia DelaVega are staff members and paid
employees of the CSFSO.


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