| DECLARATION
                                                OF MARCY SIZEMORE    
                                                I,
                                                Marcy Sizemore hereby state as
                                                follows:
                                                    
                                                1. I am a 17 year old resident
                                                of the State of Virginia,
                                                residing in Chantilly,
                                                Virginia.. I presently attend
                                                Fairfax Baptist Temple Academy.    
                                                2. From December 27, 1980 until
                                                March 1982, I was enrolled in
                                                the Straight Inc. drug
                                                rehabilitation program in St.
                                                Petersburg, Florida.    
                                                3. I traveled to St. Petersburg
                                                Florida with my mother to enroll
                                                in the program. When I arrived
                                                at the Straight, Inc.
                                                headquarters in St. Petersburg,
                                                I was taken into a room by two
                                                other teenagers for intake. I
                                                was kept in the room for
                                                approximately five hours, and
                                                couldn’t eat or use the
                                                bathroom during those five
                                                hours. Two girls sat in front of
                                                the exit door to the room . I
                                                couldn’t leave, and I was told
                                                that it I didn’t enroll in the
                                                program that they would put me
                                                in a mental institution. They
                                                also told me that if I didn’t
                                                sign myself into the program
                                                that I would be put into the
                                                program by court order for a
                                                period of two years. I
                                                eventually signed myself into
                                                the program, was strip searched,
                                                and then entered into the
                                                Straight program.    
                                                4. During my 14 months in the
                                                program. I witnessed the types
                                                of abuses as set forth in the
                                                complaint in Collins v.
                                                Straight, Inc. Enrollees on
                                                first phase were not allowed to
                                                make any movement or to even use
                                                the bathroom without someone
                                                holding on to them, and they
                                                were kept under guard 24 hours a
                                                day. Individuals who did not
                                                cooperate were placed on
                                                prolonged diets of peanut butter
                                                sandwiches and water
                                                "choker sandwiches"
                                                and were placed in punitive
                                                isolation for weeks and months
                                                at a time. This was known as the
                                                time out room.  The
                                                treatment consisted of 12 hours
                                                a day of sitting in straightback
                                                chairs, participating in rap
                                                sessions, which amounted
                                                basically to being confronted by
                                                other teenagers  concerning
                                                drug and alcohol use. When I was
                                                in the program, the only
                                                exercise we got was once a week,
                                                which consisted of forced
                                                exercises, usually consisting of
                                                100 pushups and other strenuous
                                                exercises.    
                                                5. The standard practice of
                                                Straight, Inc. is to prevent any
                                                individual who misbehaves in any
                                                way from progressing in the
                                                program. During my 14 months in
                                                the program, I was put back to
                                                the beginning of the program at
                                                least four times. Each time I
                                                was put back to the beginning of
                                                the program I was put on
                                                "first phase, newcomer
                                                status" which meant that I
                                                was under guard 24 hours a day,
                                                and was in physical contact at
                                                all times with another enrollee.    
                                                6.
                                                Another standard practice of
                                                Straight, Inc. to punish those
                                                participants who
                                                "misbehave", was to
                                                subject the enrollee to a
                                                "marathon". In
                                                December of 1981, I had been
                                                placed on "no phase",
                                                which was meant I was frozen in
                                                the program and could not make
                                                any progress. I was accused of
                                                "misbehaving", because
                                                I simply sat in the rap session
                                                and did not participate. As
                                                punishment for this
                                                nonparticipation, I was taken
                                                into a bathroom by six or seven
                                                other girls, and I was kept in
                                                the bathroom from 12 noon until
                                                9:30 that night. In the
                                                bathroom, the girls beat me,
                                                punched me, placed their fingers
                                                under my collar bone and twisted
                                                the bone, and verbally abused me
                                                for 9 1/2 hours. The girls would
                                                hold my arms out at the sides,
                                                while another girl would run
                                                across the room and ram her head
                                                into my stomach, and this was
                                                done continuously. I was thrown
                                                up against the wall, pushed back
                                                and forth, and was made to stand
                                                on my feet the entire 9 1/2
                                                hours. I was told that I was
                                                crazy, that I would be put into
                                                a mental institution, and that
                                                if I did not participate I would
                                                be taken to a program where
                                                lesbians would get me and I
                                                would have to work in the
                                                fields.    
                                                7. During this marathon, I was
                                                so physically exhausted that I
                                                passed out twice. Whenever I
                                                passed out, the girls kicked me,
                                                pulled at me and made me get to
                                                my feet and again continued to
                                                subject me to the beating. When
                                                I asked for water, I was told I
                                                could have water, and then they
                                                poured it on my head. The girls
                                                worked in shifts, and always
                                                kept at least six to eight girls
                                                in the room with me at all
                                                times. After 9 1/2 hours, the
                                                marathon stopped, and I was
                                                taken to my "foster
                                                home". At that point, my
                                                entire body was covered with
                                                bruises.    
                                                8. This type of marathon is done
                                                regularly on the Straight, Inc.
                                                enrollees if they
                                                "misbehave." The other
                                                teenagers who carry out the
                                                punishment are "staff"
                                                or "trainees", who are
                                                former participants in the
                                                program.    
                                                9. Another type of punishment
                                                imposed on Straight, Inc.
                                                enrollees if they
                                                "misbehave"  or
                                                do not do what they are told is
                                                to sleep-deprive the enrollees.
                                                We would be made to stay up
                                                until 3 a.m. on Friday night,
                                                participating in open session,
                                                stay awake all day Saturday, all
                                                day Saturday night and all of
                                                Sunday night. I once observed
                                                one enrollee who was subjected
                                                to this type of sleep
                                                deprivation, and on Sunday night
                                                she fell on the floor and went
                                                into convulsions. Other
                                                enrollees were used to curse us
                                                and prod us to keep us awake so
                                                that we were unable to sleep
                                                during periods of 48 hours or
                                                more.      
                                                10. During my 14 months in
                                                Straight, I also suffered from
                                                specific medical problems. At
                                                that time I suffered from
                                                allergies, and I needed shots
                                                every two weeks in order to
                                                treat the allergies. The
                                                Straight, Inc. people denied me
                                                access to these shots, and I
                                                received them only occasionally
                                                while I was in the program. In
                                                fact, I only saw a doctor once
                                                in the entire 14 months I was in
                                                the program.    
                                                11. While in the program, I also
                                                had a serious I fungus problem
                                                with my feet. The fungus was so
                                                bad that my feet were swollen to
                                                the point where I couldn’t
                                                walk and they also smelled very
                                                bad. I told my "foster
                                                mother" that I needed
                                                medical attention, but I
                                                received none. I was unable to
                                                wear my shoes, and I received no
                                                medical care until my mother
                                                took me to a doctor.    
                                                12. By the time I got out of the
                                                program in March of 1982, my
                                                physical condition had
                                                completely deteriorated.  I
                                                had developed open sores all
                                                over my back and arms, and I am
                                                informed by my pediatrician that
                                                this condition is caused by the
                                                mental and physical debilitation
                                                I suffered while in the
                                                Straight, Inc. program.      
                                                I hereby affirm under penalty of
                                                perjury that the above statement
                                                is true and accurate. Date:
                                                12/5/82                                                                   
                                                Marcie Sizemore |