STATE OF NORTH CAROLINA

IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION

COUNTY OF WAKE

NORTH CAROLINA STATE
CONFERENCE OF THE NAACP,
DISABILITY RIGHTS NORTH
CAROLINA, AMERICAN CIVIL
LIBERTIES UNION OF NORTH
CAROLINA LEGAL FOUNDATION,
KIM T. CALDWELL, JOHN E.
STURDIVANT, SANDARA KAY
DOWELL, and
CHRISTINA RHODES,
Plaintiffs-Petitioners,
v.
ROY COOPER, in his official capacity
as Governor of North Carolina,
ERIK A. HOOKS, in his official
capacity as Secretary of the North
Carolina Department of Public Safety, and
BILL FOWLER, ERIC MONTGOMERY,
ANGELA BRYANT, and GRAHAM
ATKINSON, in their official capacities as
Post-Release Supervision and Parole
Commissioners,
Defendants-Respondents.

No. 20 CVS 500110

AFFIDAVIT OF
NACOLA WILLIAMS

 AFFIDAVIT OF NACOLA WILLIAMS

1. My name is Nacola Williams. I am a 52-year-old African American woman,
born and raised in North Carolina.

2. I am currently living in the custody of the North Carolina Department of Public
Safety, under extended confinement at Leading Into New Communities, Inc. (LIN C)
in Wilmington, NC.

3. I was released from the North Carolina Correctional Institute for Women
(NCCIW) on April 17, 2020. On April 16, 2020, I was told by the NCCIW staff that
the facility confirmed its first case of coronavirus.

4. I have been diagnosed with hypertension and take medication for it on a daily
basis. However, during my time in NCCIW I was not separated from any other women
in the facility due to my underlying medical condition. There is not enough space to
effectively separate people in the facility.

5. I was assigned to the Canary Unit, or the minimum-security unit, at NCCIW.
It was not possible to practice social distancing in this unit. There are 36 women in
each quad in the Canary Unit. We had bunk beds that were less that were six feet
apart from one another.

6. While I was at NCCIW, we were asked to sit in every other seat in the dining
hall. However, even by sitting in every other seat, women in the unit were still less
than six feet apart from one another. On the day I left the facility, they began a new
practice of bringing meal trays to the units instead of allowing people to eat in the

dining hall, but our beds are not 6 feet apart either.

7. We started making our own masks by crocheting t?shirts to try to prevent
ourselves from contracting the Virus. The prison staff took these masks away from us
and told us we were not allowed to have them. The next day, everyone received a cloth
mask from the prison staff.

8. There were not sufficient amounts of hygiene and cleaning products available
to the women in NCCIW. Women began hoarding the bleach because they knew that
there would be a shortage.

9. I asked for hand sanitizer and was told that we were not able to have it. I even
suggested that they add a base station for hand sanitizer, rather than a personal
supply for each of the women. I was told that hand sanitizer was considered
contraband and we could not have it.

10. The amount of movement in and out of NCCIW during this time is very
concerning. Some women at NCCIW were still allowed to leave the unit to go to work
through work-release programs as recent as last week. They also allowed people to
come from the larger unit of NCCIW to the Canary Unit.

11. There were many women with low-grade fevers, but the prison staff did not
appear to see this as an issue. We were required to report to a medical technician if
we had any concerning The protocol was for the medical technician to take
the person?s temperature so that they could then make a decision to determine next
steps. The overwhelming response from the medical technicians was not to refer

women to the nurse on staff, but instead, told the women that they just had allergies.

12. I went to the sergeant and told her I believed the virus was in our facility and
she told me that it was not.

13. I witnessed one lady lay in her bed for four days. She could not get up to get
her medication. She could not get up to eat. Other women were bringing her water so
that she would not become dehydrated. When they eventually took her temperature
and the sergeant walked her out on Wednesday, April 15, 2020, it is my
understanding that she had a temperature of 105 degrees.

14. On Thursday, April 16, 2020, we were notified by the prison staff that there
was a confirmed case of COVID-19 within our facility. We were not told who tested
positive for the Virus.

15. Our unit was then placed on lockdown, and they began taking everyone?s
temperature twice daily. Women were no longer allowed to leave the quad. We were
not allowed to use the dining hall. We were not allowed to use the phone.

16. Upon my release on Friday, April 17, 2020, I asked ifI could be tested to ensure
that I did not contract the virus. Prison administrators told me that I could not be
tested. I believe I should have had the option to be tested before I left the facility.
17. There are many women inside of NCCIW that are terrified that they will not
make it home. Being in prison during this coronavirus pandemic was terrifying. The
conditions in which we were forced to live were not consistent with the CDC
guidelines around social distancing.

18. I hope that my contributions may play a small role in convincing those with

the power that prisons are not safe environments during the coronavirus. I hope that

 

those in power have the compassion to intervene so that the lives of people who are

incarcerated like I was, are valued like everyone else?s, as our nation and our world

face this dangerous and terrifying disease.

VERIFICATION

I affirm, under the penalties for perjury, that the foregoing representations are true.

Atari. [aw/mo

Nacola Williams

April ll 2020