Legal Document: ROLAND GILBERT vs. SALVATION ARMY HARBOR LIGHTS COMPLEX

On March 31, 2023 a CIVIL ACTION APP.R. 26(B)(2)(E) . PRO SE (9999999) - OT was filed involving a dispute between and for MISCELLANEOUS - OTHER in the District Court of Cuyahoga County.

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CV23977379 147150647
147150647

qpURT OF CLAIMS
^COUNTY OHIO

■n HAY H A II- 25
Incarcerated Inmate:
Roland Gilbert
NCCC #257554
P.O.B. 1812 Case No.
Marion Ohio 43301
Plaintiff
v. Case No. 22CV008221

Agency: COC No. 2022-00649AD
Salvation Army Harbor Lights Complex
1701 Prospect Ave. Cleveland Ohio 44115 COMPLAINT
Defendants

STATE OF OHIO |
County ofCu^Gvlio^J CIVIL ACTION App.R. 26(B)(2)(e)
ss.

Now comes the Plaintiff pursuant to App. R. 26(B), Roland Gilbert, Hereinafter the "Plaintiff' who

claims the following reasons for this action. The Salvation Army, Harbor Lights Complex, hereinafter, "the

Harbor Lights Complex." Does hereby claim the following testimony(s) to be true. Pursuant to 28 USCS

1746, I the undersigned do hereby certify under penalty of perjury that as stated in this Affidavit to the

court is a material issue of fact and is accurate, Further sayeth naught of the affiant that the above

statements are true and accurate under the penalty of perjury (ORC Ann 2921.11). The Plaintiff has filed

affidavits of the following:

1. John Tsiaronas

2. Audrey Silver-Black

3. CyndiJackson

4. John Hill

5. Deb Winston

6. Mrs. Davis (Jehovah's Witness)

7. Matt Bechtold

8. John Griffin (Field Officer)

9. Roland Gilbert (Jehovah's Witness)
CONCLUSION

The free exercise of religious practices and to educate one's self under COVID-19

protocols where electronic equipment is necessary for this task should not be denied any

participant of the Salvation Army Harbor Lights Complex program. I should not have been forced

to go to the college that is contracted with the halfway house or follow the religion of that

halfway house in the in-house chapel. It was appalling and shocks the conscious with the

treatment that I received there just for standing up as a man of reasonable firmness as to my

religious and educational Rights/Privileges. The degree from Sinclair would have made sure that

my applications for work would be sound and that I would have re-integrated well back into
society as one of Jehovah's Witnesses.

CERTIFICATE OF SERVICE
A copy of this above captioned motion was served upon by regular U.S. Mail at the office of:

Nailah K. Byrd Clerk of Courts Cuyahoga County Ohio

1200 Ontario Street, Cleveland, Ohio 44113

On this the of , 2023

Roland Gilbert in Pro Se
NCCC# 257554
P.O. Box 1812
Marion, OH 43301
AFFIDAVIT IN SUPPORT OF ROLAND GILBERT

I the affiant, Roland Gilbert, being of sound mind duly sworn deposes and says:

The culmination of events stems from constant stonewalling by Mrs. Audrey Silver-Black as my
case worker who rebelled against her boss who had told her that I had permission for the usage of my
equipment in the halfway house. Complaint was filed by grievance for the stonewalling and denial of use
for college and religious reason. Multiple times I had to do a work around by having other staff at the
halfway house do her job when she failed or outright refused to do so. I had asked many times for a new
case worker.

On or about 08/24/21 Mrs. Silver said, “I don’t want you putting out my clients any more. Because
you don’t know what I am doing with them.” I was standing outside of her door when she said this on the
phone, (assumed to Mr. Hill) He would put me out when I needed to go to the hospital, to the dentist for
shopping and was the one who gave me permission to put my laptop in the locker downstairs as he didn’t
want people going in and out of his office to get it on the weekends when he was at home.

On or about 08/24/21 Both Mrs. Silver and myself went to Mrs. Winston’s office in order to get
the record straight about the use of my laptop. Mrs. Winston told me that she was not going to give me
permission to use it every day. Put in an itinerary to Mrs. Silver.” I did the same day as she asked and Mrs.
Silver just tucked it under her blotter and never entered it into the computer. The times of usage for the
laptop was at 8:00 am to 12:30 pm Tues. thru. Sat. with one day for study on Sun.

On or about 08/25/21 at approx. 1:15 1 poked my head into Mrs. Silvers office and said that I am
negotiating for the use of my laptop. She replied, “I will make so that you can never use your laptop!”

On or about 08/26/21 I wanted my laptop from Mr. Hills office and it was not there, it had been
taken by Mrs. Audrey Silver-Black.

At approx. 1:10 pm Mr. Hill said, “She came and got you laptop!”

At approx. 1:151 saw Mrs. Silver in the elevator and demanded my laptop. I went to Mr. Bechtold’s
office and she said, “Mr. Hill brought it to me.” I told him that she would never be in her office for rhe to
get it as she is gone on Friday (Her day off)” He said, “This is the first time I have heard about a laptop.” I
revealed, “Her (Mrs. Silver and Mrs. Jackson leave out of the back way of the halfway house taking breaks
and you can’t find her at her office as she is never there.” He called Mrs. Winston and she was in the middle
of a zoom meeting and would address the situation once it was over.

At approx. 1:271 spoke to Mr. Hill again and told him what Mrs. Silver had said, and he said, “She
called me and so I took it to her. If you show her paperwork from your elders what can she say.”

At approx. 1:301 stood outside of her office looking out of the window as I usually do when she is
on the phone but this time the door was locked. I know this because I looked at my watch to see if I still
had time to retrieve my laptop and make it to work. As I waited for her to get off the phone her friend
(Cyndi Jackson) came to the office in a rush. She didn’t speak to me as usual and so I said, “Hi Ms. J! You
are not going to say anything?”
I leave for work Mon. - Thru. @1:15pm. and return at 2:00am. Fri. - Sun. @4:30am to 4:00pm.
The labor pool bus leaves at 1:45pm. The halfway house has a policy that if you try to exit the building
later than 30 mins, you cannot leave on pass.

She said, “Oh, Hi Mr. Gilbert.” and went into the office. We usually speak to one another.

When the two of them came out of the door several minutes later, I showed Mrs. Silver-Black my
paperwork for the use of the lap top and she said, “I don’t want to see that!” And pushed at the paper with
her right hand palm forward. I placed my foot in door and demanded that she do her job, she said, “You
know this is on camera!” I said “I know; I am not doing anything wrong.” She then began to pull on the
door with all her strength going so far as to put her foot on the wall to close it and said, “Help! Assault!
Help! Assault!” I was shocked as I had not touched her.

Approx. 1:44pm. Mr. Tsiaronis came out of his office and just stood there frozen manner looking
at her hanging from the door handle. Mrs. Silver-Black said, “Aren’t you going to help?” He just stood
there and said nothing. She then took her leg down and stood in front of me with her back to me. I was
able to remove my foot from the door after she released the pressure and she then pulled the door shut.

I then followed he down to the security office. Everyone had come down and everyone was talking
about the situation and both of the ladies were saying that I had assaulted them. I went out after Ms. Silver
said that “You have to go out!” I went out of the building and used my cell phone to call my P.O. Mr.
Gannon about the situation.

On ll-10-21about 1:25pm. Using computer equipment at Lorain Correction Institution. Mrs.
Audrey Silver-Black’s testimony at the hearing “I was on the phone and saw Mr. Gilbert in the hall.” “He
was up to something.”, “I never touched Mr. Gilbert or pushed him.”, “He didn’t knock on the door.”, “Me
and Mrs. Jackson tried to secure the door.”, “I don’t remember how I got the scratch.”, “I don’t prop my
door open (it remains locked when I am in my office).”, “I called for security on my radio.”, “I never
photographed the scratch on her right arm.”, “I did not know he wanted his laptop”, (This after we were in
Mr. Bechtold’s office just prior approx. @ 1:20pm), “I never received an itinerary from Mr. Gilbert.”, “I
never touched Mr. Gilbert.” This information was given at the hearing.

The original document was deleted from the computer file by Stacy L. Wicks Library Administrator
1, OSC/Ohio Central School System, 4545 Fisher Rd., Columbus, Ohio 43218 on 11/23/2022. There is a
policy that all files that are older than 30 days will be deleted from the system. The deletion happened on
Dec. 1,2022. It was one of the documents searched for content and then deleted from the system supposedly
by accident along with Parole Board Documents, Grievances, Mandamus, and Habeas pending litigation in
the courts that was updated on 11/23/2022 and should not have been deleted until 12/23/2022. I have had
to retype it as the original was sent to the court and I have not yet received the original copy but it is
amended with inclusive language and is true and accurate.
Pursuant to 28 USCS 1746,1 Roland Gilbert do hereby certify under penalty of perjury that as stated in this
Affidavit to the court is a material issue of fact and is accurate, Further sayeth naught of the affiant that the
above statements are true and accurate under the penalty of perjury (ORC Ann 2921.11). Corroborating
signatures in affidavits are not possible as once it is sent to a second party the notary will not place a jurat
on as the signature is not witnessed. The affiant had placed with in the document phone numbers for
verification and authentication of the documents as true and fact.

Roland Gilbert Affiant

Sworn and subscribed before me on this day of

[PLACE SEAL HERE]

Tonya Michelle Thompson
Notary Public, State of Ohio
My Commission Expires;
A Notary Public of Ohio Sept 13,2027
My Commission Expires on / / /
AFFIDAVIT IN SUPPORT OF AUDREY SILVER-BLACK

I the affiant, Roland Gilbert, being of sound mind duly sworn deposes and says:

Mrs. Silver-Black’s office hours at the Harbor Light Complex are posted 9:00am to 5:00pm Sunday
thru Thursday. Mrs. Silver-Black’s open office hours as I have found them when on the 4th floor in room
456, for the number of clients on the floor approx. 40 (not all hers). The primary function of a case manager
is to place into the central computer information necessary for each client to reintegrate back into society
at the Harbor Lights. This includes ORAS, AA and NA, participation in classes that are mandatory.
Orientation, Job Readiness which includes itineraries for work, active searches for living quarters for those
transitioning back into society, cell phone registry, and other provisions necessary for reintegration back
into society such as banking and participation with family.

Sunday Working the security office window of desk or at orientation in the
cafe
Monday 12:00pm to 1:00 pm not regularly
Tuesday 10:00am to 10:30am not regularly
Wednesday 10:00am to 11:00am not regularly
Thursday 1:45pm to 2:00pm not regularly
Friday Off
Saturday Off
Sunday 10:00am to 11:00am not regularly

I worked evening on second shift at Custom Products as a key operator to be hired in as a setup
man for the equipment. I have worked hard at this job for the 14 weeks missing one day due to Mrs. Silver-
Black not putting me out because of subsistence fee (rent) and once because of illness. My job starting at
1:15pm to 2:30 am in the morning and I have no knowledge of Mrs. Silver’s being in her office after this
time. I had asked to go out to the library to zoom for my Jehovah’s Witness meetings but she denied it.

The time when I needed to see my case worker was in the morning. I was able to observe her
arrival and departure by sitting in the cafeteria when I Zoomed for the Jehovah Witness meetings and when
I used my cell phone and laptop for Sinclair. The cafeteria is usually devoid of staff and clients
(PRC/TC/PAROLE). She would “Break when the women ate first at 11:45am. Her arrival at the Harbor
Lights was at 8:45 to 9:10 m several times I noticed her enter the building while in my Zoom meetings that
I began to attend every Saturday at 10:00am to 12:30pm in the cafeteria as the employee door is adjacent
to this room. I would be there early in order to study the Daily Text, and the Watchtower as these
publications are all on line.

I would try to compensate for my inability to access my equipment daily for the reading of the
Daily Text and study of literature published by Jehovah’s Witnesses in order to fulfill this need at this time
in the morning it was all on-line in the JW.org library app to study for my Watchtower meeting to read the
Current Awake magazine and for field service on line through letter writing. 1 did get some information
from another Jehovah’s Witness that worked there, Mrs. Davis. I met her when I had an interview for court
and used my phone to zoom as theirs didn’t work.
I had to ask to use my phone initially for this purpose then once I purchased a laptop I used it in the
mornings after breakfast in the dining room in the back comer and before lunch (7:45am to 11:45am) for
studies of the Watchtower and for college classes. I observed Mrs. Silver and Mrs. Jackson would leave
out of the back way while I sat in the dining room and would not return the whole time I was there. She
was not in her office in order to take care of the needs of her clients. (See Diagram Exhibit)

She was on “Break” under testimony on Nov. 10, 2021 this area the dining room was deemed an
inappropriate area at the hearing. This is the place where I asked to use my phone on the first floor. We
are not allowed to linger in the security office of the halfway house, there are two dining rooms available
and empty, as it was not allowed for use on the 4th floor in my room per Mrs. Winston’s order to use it on
the first floor.

On or about 7-11-21 both Mrs. Silver and myself went before Mrs. Winston in her office on the 6th
floor in dispute about the use of a laptop and my cell phone, this was an ongoing situation and the itinerary
that I had placed at the security desk was missing when I went to pick up my phone. I know that Mrs.
Silver sometimes works security and we had been going back and forth about it (Usage of my equipment).
I said, “I keep having problems with Mrs. Silver about the use of my laptop and cell phone.” Her claim
(Silver) was to Mrs. Winston. “We talked and I thought Mr. Gilbert was not going to be able to use a
laptop!”

“He can use it for college” Mrs. Winston said, “What days are you trying to use your computer?”

1 said, “Tuesday through Sunday morning 7:30am to 12:20pm and Mrs. Winston said,

“I can’t let you use your computer every day. You will have to pick your days.”

I explained, on November 13, 2021 “That my two classes at Sinclair are on Tuesday thru Friday at
8:00am but I need study time and time to use it for my Sunday meetings of the Jehovah’s Witnessed Book
study and for field service.” I explained that it included the use of my phone as I have a Chrome book and
the phone is linked and used as a mobile hotspot.

Mrs. Silver said, “I’m not letting you use your phone and your laptop together!”

I said, “It is not up to you, it is up to your boss,” When we left her office.

I was allowed to use my computer for college (Per Winston) but not for my religion and upon
leaving her office she (Silver) told me that, “You are very manipulative!”, once we went to her office to fill
out another itinerary.

On Nov. 14 or somewhere there about, she asked, “Mr. Gilbert, when are you going to move?”

I said, “At the end of the year, I want to save up enough money to purchase a house.” She knew
that I had to have permission in order to move per my Parole Officer Mr. Gannon

The next day I was using my laptop and phone in the cafeteria, Mrs. Silver had a problem with me
being there as the women were coming in and getting their lunch. (They eat in the other dining room not
the men’s dining room) I had seen Mrs. Winston this morning and I had asked her to come over and look
at what I was doing on the computer so that she would have no problem with seeing the usage of the
computer. Mrs. Silver came over and had one of the security with her, and he said, “Mr. Gilbert, you will
have to go to the computer lab and use your equipment.
I had a problem with Mrs. Silver about putting my laptop in one of the lockers she claimed that they were
only for visitors to use but others were using them. I was not told that the lockers could not be used for
storing personal items. She was upset because I used one of the lockers that didn’t have a pay slot and I
used a personal lock. I was willing to give the staff a key if it was necessary and I should have given it to
Mr. Hill now in retrospect.

I said, “That is a characteristics of a sociopath, I and not a sociopath.” It was one of the
characteristics that I learned in a psychology class. It is one of the classes they offer at Sinclair, then went
to my room in order to give her the itinerary for the use of both the computer and the laptop once more as
Mrs. Winston had instructed. She then tucked it under her desk blotter rather than entering the information
into the computer. (This is the only way that a client can perform duties outside of the halfway house.)

I saw Mrs. Silver on the morning of Aug. 25, 2021 and I said to her after I had finished washing
my clothes, “You look stressed out, you need to not let this job get the best of you.” I had always tried to
keep the relationship between us friendly as she was the official gate keeper and I was her “Client.”

The next day when I was going to leave for work, I went past her office and she had a client there
who lived in the room across from her door. He was sitting in the chair in front of her desk so I reminded
her that I am using “Negotiation and Dispute resolution” in order to make a way for me to use my laptop.

She Yelled from her seat, “I will make it so that you can never use your laptop!”

I said that, “I am allowed to use it in the computer lab.”

She said, “He is not allowed to give you permission for that!”

I said, “Mrs. Winston gave me permission to use it there.”

I hurried away from her door and went to the elevator and went to work. On 8-25-21.

The next day on Aug. 26, 2021, I met Mrs. Silver in the elevator after searching for her in the
building at her office then at the security desk downstairs, I asked her,

“Why had she taken my laptop? You know that you will not be here on Friday to give it to me and
I have an important test with Sinclair in the morning at 8:00! I said with emphasis.

She did the following, she tipped her head to the side, then put her hands upon her hips and said
nothing. I got off at the second floor as soon as the doors to the elevator opened.

I told her that “I was going to see her boss and get this settled one way or another.”

I got off of the elevator on the second floor and went to Mr. Bechtold’s office and knocked on the
door and he waived me in. he usually says, “Mr. Gilbert you know that you just can’t come to my office,
but this time he saw Mrs. Silver.

I said to Mr. Bechtold, “Mrs. Silver has my taken my laptop and put it somewhere. I want to take
it to work with me. 1 have to take a test in the morning at Sinclair College and she took it to keep me from
having it to use.”

She said, “I got the laptop from Mr. Hill who gave it to me.” She never gave a reason for the
confiscation.
She never gave any reason for having the laptop to Mr. Bechtold the whole time we were in the
office. She never indicated that it was being used in an inappropriate area.

I asked Mr. Bechtold to do something about it. I said, “This woman keeps stonewalling me when
it comes to my religion and the use of my equipment. She never puts it down in her computer. Yesterday
she said that she would make it so that I could never use it!”

Bechtold said, “Her name is Mrs. Silver and not ‘This Woman. Mr. Gilbert.’ This is the first time
that I have heard anything about the use of a laptop. He called Mrs. Winston who was in a Zoom meeting
and she said that she would handle it once the meeting was over. He had seen me using it in the dining
room when he came to eat lunch.

I explained to him that Mrs. Silver and Mrs. Jackson are always taking a break and leaving out of
the back way and she is never in her office when I need her. (Her hours are very irregular) She will not file
the itinerary into the computer so that I will not have trouble using it.

I went back to Mr. Hill’s office and told Mr. hill what she said about how she got the laptop. He
then changed his story and said, “She called me and I took it to her office. If you just get permission from
your elders what can she say about it.” I told him that I do have paperwork from the elders that included
dates and time for the Zoom meetings of Jehovah’s Witnesses.

I then went to Mrs. Silver’s office and showed her the paperwork for her to enter it into her
computer so that we could finish this petty bickering about the use of my laptop and cell phone. She was
on the phone when I came to her so I went and stood looking out of the window at the cars in the parking
lot and the people down there on a smoke break.

(From this window with her door closed she cannot see me and I cannot see her because of
the way the door is made and distance for the window in her door.) Periodically I would look into her
office at her to see if she got off of the phone. Her friend, Cyndi Jackson came to her office and almost
moved me out of the way with a large beige purse she had on her shoulder.

When Mrs. Silver came out of the office first with Mrs. Jackson leaving second. I showed her the
paperwork and she pushed her hand at it and said, “I don’t want to see that!” I then waited until Mrs. Jackson
was completely out of the way and I put “my foot-in-door” with my hands to it. I didn’t push hard enough
to enter the office just enough so that she couldn’t close the door. My reasoning was that her and Mrs.
Jackson were going to conveniently leave for the day and I would be without my computer in order to take
the class per her words the previous day.

Mrs. Silver pulled on the handle with both hands and said, “You know this is on camera”

I said, I know that it is.” I was not doing anything and I was not in contact with her person.

She then put her foot against the wall and leaned back so as to use maximum force in order to close
the door but my foot was caught under the door partially by the shoe (Nike Air Mesh) and it was squeezing
my toe.

Mrs. Silver then said, “Help, I’m being assaulted. Help, I’m being assaulted.”
Mr. Tsiaronis came out of his office and just stood there in a frozen manner looking at her hanging
from the door handle. Mrs. Silver-Black said, “Aren’t you going to help?” He just stood there and said
nothing with his hands as if he was going to catch her and his mouth open as if astonished. She then took
her leg down from the wall and stood there in front of me for several minutes while she spoke to Mr.
Tsiaronis then I pointed down at my foot in the door and when she felt it closed pulled the door shut.

She then said, “Come on, you got to go out of here!” she then went to the door that leads to the
stairwell and slung the door open with her right arm and gestured for me to go down the stairs to the security
office. This door has a face plate that was originally mate of plastic but now only has the screws with some
of the plastic remaining. I have gone through this door and have “scratched” myself on it several times.

I then went out of the building to use my cell phone and call my P.O. and let him know what was
happening. I have always called him whenever there was a problem in anything that I was doing and I kept
him appraised of any progress on a weekly basis.

One thing that Mrs. Silver liked was to always say “You call your P.O. and ask him” when I did
and tell her she would say, “I need to hear it from him!” I told her that instead of you ping ponging me
back and forth I want the two of you to meet face to face and get that understanding.” It is not my place to
be in the middle of decisions. I found that many of the decision made in the halfway house are that way
back and forth between staff members, and it causes confusion in an administrative way.

On the day of her testimony on Nov. 10 2021, Field Officer John Gannon then proceeded to present
the evidence he had recorded from the Harbor Lights Complex. On the screen in the office of the
administrator’s for Lorain Correctional Institution her laptop that was facing me (a Think Pad) showed a
picture of Mr. Gannon’s computer screen. There were icons scattered all over the screen but most were to
the left and the mouse clicked on the one that was in the middle. Window’s video player opened and the
CCTV video from the halfway house began to play. It showed myself standing in the widow then it showed
Mrs. Jackson briefly speaking then entering the door. As the two of them came out it show myself with the
papers necessary to show reason for the use of my laptop and to have it approved. The video shows that
Mrs. Jackson moved out of the way then once I placed my foot and hands against the door. Mrs. Silver-
Black pulling with all of her might against my foot-in-door. She just hung there using her leg against the
door frame pulling it but my foot was stuck. This is where officer Gannon paused the video with Mrs.
Silver-Black hanging there. I was standing facing her while she just hung there in the video. Her statement,
“You know this is on camera.” as she just hung there. Further video evidence shows that Mr. Tsiaronis
then came and just stood there. She said under oath when asked,

“Are you talking about his little Jumna that he wanted to attend.” She was corrected by my attorney
as to my faith, “Yes he wanted to attend his little, Gee-Hovah Witness meetings on his laptop.” This slur
was intentional as this was a particular problem with me getting permission to use my equipment. My
attorney said, “Jehovah’s Witness is the term, Mr. Gilbert is a Jehovah’s Witness, do you have anything
against the Jehovah’s Witnesses. She said, “No I don’t.” My attorney then began to badger her about the
testimony forgetting that she was one of the witnesses that I had subpoenaed to support my clam of
innocence of the allegation of assault. It was so bad that it made tears come to my eyes and she exclaimed,
“Look! I am not the one on trial here, Mr. Gilbert is!!”
6. On 11-10-21 about 1:25pm. Mrs. Audrey Silver-Black’s testimony at the hearing “I was on the
phone and saw Mr. Gilbert in the hall.”, “He was up to something.”, “I never touched Mr. Gilbert
or pushed him.”, “He didn’t knock on the door.”, “Me and Mrs. Jackson tried to secure the door.”,
“I don’t remember how I got the scratch,”, “I don’t prop my door open (it remains locked when I
am in my office).”, “I called for security on my radio.”, “[She] never photographed the scratch on
her right arm.”, “I did not know he wanted his laptop, (This after we were in Mr. Bechtold’s office
just approx. @ 1:20pm), “I never received an itinerary form Mr. Gilbert.”, “I never touched Mr.
Gilbert.” This information was given at the hearing and is contrary to her statement given to Mr.
John Griffin My attorney and Mr. John Gannon my Parole Officer.

She also testified that, “I looked like I was up to something.” when I looked into her door from
standing in the window sitting at her desk you cannot see me so as to know if I looked like I was up to
something or not through the slot in her door as she was behind her desk when I looked into her office door
that is usually open. This inclusive testimony was from a review or the CCTV footage and comments were
made to that fact. Unnecessary friction was caused because her superiors would not order her to complete
her job. Mrs. Silver when I asked for a new case manager should have allowed me to transfer to another
person if she didn’t like me as a client. For times and dates see the document Harbor Light Grievance listed
in chronological order (amended) and the original.

Pursuant to 28 USCS 1746,1 Roland Gilbert do hereby certify under penalty of perjury that as stated in this
Affidavit to the court is a material issue of fact and is accurate, Further sayeth naught of the affiant that the
above statements are true and accurate under the penalty of perjury (ORC Ann 2921.11). Corroborating
signatures in affidavits are not possible as once it is sent to a second party the notary will not place a jurat
on as the signature is not witnessed. The affiant had placed with in the document phone numbers for
verification and authentication of the documents as true and fact.

Roland Gilbert Affiant

,20 <9
Sworn and subscribed before me on this

MELINDA TAYLOR
Notary Public
State of Ohio
My Comm. Expires
May 17, 2027
AFFIDAVIT IN SUPPORT OF DEB WINSTON

I the affiant, Roland Gilbert, being of sound mind duly sworn deposes and says:

My first seeing Mrs. Winston she was across from my room on the sixth floor and she stayed in her
office. She would give the men money from her safe and make change and I had 20 dollars and needed
some change. I noticed that she had two computers one a grey laptop, and the standard one at her desk.

My first meeting with Mrs. Winston was when she personally gave a class of orientation. I
remember this because she gave me two dollars for getting an answer right. (I had just lost the exact amount
from my pocket, it was my last money) She introduced herself as one of the Directors of the Harbor Lights
Complex and that there was online person above her. We had asked her why she didn’t allow the floors
with transitional control to have the use of a phone when the women’s floor did and the homeless shelter
floor had usage.

She explained, “One of the clients used their cell phone to document the overdose of one of the
clients and to show the degrading condition of the building putting it on some website,” that is out there I
can’t remember the name, “and so we decided not to allow them on the floors that we were on.” This had
just been implemented prior to my arrival there.

I would talk to Mrs. Winston casually whenever we met. Her office is on the Sixth floor and I was
in the room across from her office when I was in quarantine for the first two weeks that I was at Harbor
Lights Complex.

She took the fourth floor out on a walk once I moved down there so that we could get out of the
building and for those who smoked to do so and we were able to walk single file down town and back to
the halfway house stopping at the store to purchase necessary items. She is a very fast walker for a woman
with short legs.

I had talked to Mrs. Winston about having visitors come to the halfway house as my Son had come
from New York and I wanted to see my grandchildren she said,

“Under COVID we have to shut down, there are no visit here.”

I asked, “Am I allowed to visit my family for the weekends?”

She said, “If you have finished orientation then you can go out if you are not a TC
(TRANSITIONAL Control).”

I said, “I am on parole.”

She said, “Who is you case worker?”

I said, “Mrs. Silver.”

She said, “Have her fill out the paperwork and you can go out.”

I asked, “What if I want to go and say at a hotel. I have not been out in 30 years and all I want to
do is soak my body in bath water until I prune up. I want a bubble bath!”

She just laughed and walked away.
I asked Mrs. Winston to approve my use of a cell phone personally on the day I had a violation for
the use of it. She took it to Mr. Bechtold with me and it was registered in the log. She stated that, “Mr.
Gilbert has been locked up for some 30 years and Mrs. Silver is giving him a hard time. (She (Silver) had
stated once I paid the fine that, “You always get what you want!” as if it was personal about my phone and
now the use of my laptop), I now understand why she was this way as I was working around her
stonewalling with Mr. Hill, Mrs. Winston and Mr. Bechtold.

I told her about my service as one of Jehovah’s Witnesses, and how under COVID the Kingdom
Halls were shut down. She told me about the how the Harbor Lights was on a lockdown because of the
COVID. I asked her, “I need to zoom for the meetings of the Jehovah’s Witnesses because my sisters who
are Jehovah’s Witnesses have told me everything is on line until the COVED is over with. She said that
you can use the computers in the computer lab. I said, I have already checked out the computers ant they
have no microphone to answer the questions.

I can use my phone as I have downloaded the zoom app. (My sister had shown me how to use it
when I first bought my phone and how to use the JW.org library app before I had arrived at the halfway
house. She asked me do you have a locker? I said yes Mr. Hill got one for me.

She said, “Why didn’t Mrs. Silver get you a locker?”

I said, “I have problems with her and she was on vacation for the week. Can you put it into the
computer so that it is official?” I then gave her the document that was printed from the official JW.org
website and gave it to her with the times that is required for our zoom meetings. She then told me to, “Make
up an itinerary and place it down at the desk and Mr. Hardy will give it to you when you need it. You can
only use it on the first floor.” The problem with having Mr. Hardy know this information was that he was
not there when I needed it on the weekends,

I did as she said, then placed it at the desk with Mrs. “A” (I don’t know her full name it is the last
initial) She asked me what was this and I said that Mrs. Winston told me to put it down her so that I can use
my phone for Jehovah Witnesses meetings. She (Ms. “A” placed it in the log book.

On the first floor the same day of the Harbor Lights building I saw Mrs. Winston and asked her for
the use of my laptop for college. She said, “Did the school provide it?”

I said, “No, I purchased it myself.” I had in fact not purchased it yet because I had not been put out
to shop by my case worker.

She said, “You can have one but it has to be approved and it can’t interfere with the equipment
here.”

I explained that it wouldn’t because I knew enough about the computer system that they use and
that it was a LAN system and the one that I purchased would work independently through my cell phone.
Mrs. Silver came over and said, “You are going to let him get a laptop too?”

Mrs. Winston said, “It is for school work.”

Mrs. “All of the clients are going to want to have one.” Mrs. Winston just got on the elevator with
me and we went to Mr. Bechtold’s office. Then Mrs. Silver said, “I’m going to take a sick day!” as threat
to Mrs. Winston for allowing me to pay for my cellphone and giving permission for the use of the laptop.
I purchased an Acer Chromebook laptop for $189.00 At Walmart. I purchased a separate modem
for it because the hotspot on my cell phone was only 10 gigabytes and would run out and I would have to
repurchase the whole plan from Straight Talk for $55 dollars.

I took my laptop to Mr. Hill and when I did, Mrs. Silver was in his office and she asked about it. I
showed her all that it could do and all the apps on it. (A Chromebook is a toy computer compared to the
ones on the market, I just wanted it to be adequate for school and to be cheap.) She saw how it worked and
called Mrs. Winston who was in a meeting. She said, “I have talked to staff and we all agreed that there
will be-no laptops used at the Harbor-Lights. I later found out that it was really her Mrs. Silver who had
been talking about the laptop and not with Mr. Bechtold or other staff members. (See Bechtold Affidavit)

When she came from her office I walked up to her and reiterated the agreement that we had made
and she said, “You can use it but you have to put in an itinerary. And you will have to use it in the computer
lab. I really didn’t want to be in the computer lab because of an allegation of connecting my computer to
their computers could ensue. I was successfully using it in the cafe right under one of the cameras facing
the laptop as it could easily be monitored on the screen and it was on the comer table in the back or the
room away from where everyone ate their meals at.

The next time that I spoke to Mrs. Winston was when she saw me in the cafeteria with my laptop
Mrs. Silver saw that I has a laptop and spoke to me as I was having my service for the Jehovah’s Witnesses
there.

The next time that I saw Mrs. Winston was before the Parole Board when she gave testimony:

6._OnJ.L10z21_abo.ut_L:45_at_the_hearing_Mrs.„Deb_Winston..“Some_of_this_service_[as-a.Jehovahis
Witness] is voluntary and not mandatory, so I was not going to give him permission in order to use his
laptop every day. I had him write an itinerary for the days that he would use it.” She was asked, “Has
anyone ever placed their foot in the door at you halfway house?” She said, “No.” She was asked by
the prosecutor, “Do you think that is appropriate behavior?” She said, “No.”

Because many times that I went to speak to Mrs. Winston about the use of my equipment, Mrs.
Silver was not around to hear the decision she made. She would not transmit this information in a formal
was as an order telling her to stop the harassment, rather she would tell me to tell her, my case manager
what to do and this is not the way to do business as I can’t tell Mrs. Silver to do anything but request her to
fill out the itinerary as provide by the halfway house. This back and forth caused unnecessary friction
between Mrs. Silver and myself and gave her the leeway continue with the harassment and stonewalling.

For all of the assistance that Mrs. Winston gave it was ineffective for several reasons, (1) She didn’t
order her worker to perform her task specifically when it came to placing the information into the computer
and making it official for my usage. (2) I am not authorized to give orders to staff members, her direct
communication with them should have resulted in the problem being eliminated. (3) She has use of the
LAN network the same as Mrs. Silver and could have put it into the computer for others to read.
The original document was deleted from the computer file by Stacy L. Wicks Library Administrator 1,
OSC/Ohio Central School System, 4545 Fisher Rd., Columbus, Ohio 43218 on 11/23/2022. There is a
policy that all files that are older than 30 days will be deleted from the system. The deletion happened on
Dec. 1,2022. It was one of the documents searched for content and then deleted from the system supposedly
by accident along with Parole Board Documents, Grievances, Mandamus, and Habeas pending litigation in
the courts that was updated on 11/23/2022 and should not have been deleted until 12/23/2022. I have had
to retype it as the original was sent to the court and I have not yet received the original copy but it is
amended with inclusive language and is true and accurate.

Roland Gilbert Affiant

Sworn and subscribed before me on this day of

[PLACE SEAL HERE]

A Notary Public of Ohio ^Wly wfnmlssion Express
My Commission Expires on / / /

Tonya Michelle Thompson
Notary Publ ic, State of Ohio
My Commission Expires:
Sept 13,2027
AFFIDAVIT IN SUPPORT OF MRS. DAVIS (A Jehovah's Witness)

I the affiant, Roland Gilbert, one of Jehovah’s Witness being of sound mind duly sworn deposes and says:

When I met Mrs. Davis, I was told by security who came to my room 456 on the fourth floor of the
Harbor Lights Complex, to go to her office on the other side you have a zoom meeting. You have to exit
the security office and be buzzed in to the other side. She was sitting at her office and I had a Zoom meeting
that was set up by the Lorain County Courts for a Detainer that was still pending. The reason that I was
there was for a competency hearing that was set up by the Lorain County Court.

I was supposed to be transferred to their mental health facility from prison, but the detainer was
dropped by some means and I was released into the halfway house. I had gone to court the previous month
to have the detainer removed as the Parole Board had sanctioned me for the commission of a crime and it
amounted to nine years before it was no longer used as a rationale in order to further sanctions. I had
discovered through my due diligence that the statute has a built in limitation that of punishment for the
worse offense could be implemented and so I had written out a draft on my Jp5 device to show to the court
but instead they assigned an attorney Denise Wilmns who assured me that she could handle everything.

He informed me that, this proceeding is beyond that statute of limitation for this type, and I
informed him that I already knew this because of the limitation set in the statute has expired. The Parole
Board had given me so much time for it that the time limit was over as the limit of prosecution had been
reached.

We proceeded to zoom on my personal cell phone because the computer in her office could zoom
but there was no way to speak to one another and it didn’t have a microphone.

Afterward I had found out that Mrs. Davis was one of Jehovah’s Witnesses and that she was active
in her ministry. This means that she is serving God and not in a disapproved state.

She asked me, “How long I had been one of Jehovah’s Witness?”

I told her, “I was baptized in 1997.”

She asked me “What congregation I was affiliated with?”

I told her, “It is the one around the comer as the closest, but all I get is an answering machine. I
am zooming with my sister’s congregation as I have their password and a phone.”

I informed her, “I still get in plenty of hours of field service even though I can’t get out and go door
to door.”

She said, “We don’t do that now that the COVID has happened. We all do letter writing on Zoom.”

I said, “I have asked for permission from Mrs. Winston in order to use my phone for that purpose.
I may need a laptop in order to write. I have a keyboard that came with my Jp5 device and I can hook it up
to my phone and turn it into a laptop of sorts.

She asked me, “If I needed some literature.”

I said, “Yes I do because I only brought some with me from the prison some and I am running out
as I daily search for those who want to know the truth. I have several interested ones on my floor.”
She brought me some the next time that I saw her. She was in the security office when I had seen
her to get the Watchtowers and Awake Magazines. I had received a phone violation as I had it in the bottom
of a box. I had to sneak it sometimes to my room in order to have the meeting as I was having problems
with the staff (Silver) about using it for those reasons. It was the primary way of keeping in touch with my
family, my daughter and my son who were on social media and had not seen me in a decade. I would then
afterward take it back to the security have them place it in my locker when I was through with the meeting.

I had always for the last decade preached in this manner by setting up a table and placing Jehovah’s
Witness literature and displaying it for any one that wanted to know the truth it is the primary way that I
did it in the penitentiary. Proselytizing is prohibited in the institution and I didn’t want to cause any trouble
so I did it discretely in the halfway house because it is a Christian organization as well and has its own
practices.

When in a hostile territory. Witnesses must conduct their business “underground” as we must obey
God as ruler rather than men (Acts 5:29). Proselytizing is prohibited in prison and places under ban to the
world wide preaching work. We allow people to be exposed by advertising our religion in public. I was
not allowed to leave the halfway house to zoom.

In the halfway house the first person that I met was Gary and we talked about being in the halfway
house all the time. He was one of the first ones that I gave an Awake magazine to. Then there was another
man that moved in and when he saw me at the table in a Zoom meeting, he came over and began to ask
what I was doing. I told him about being a Jehovah’s Witness and that I was in class. I didn’t have my
laptop at the time and so I showed him about the split screen usage of the Android that I had zoom on one
side and the JW.org library on the other side.

Another person whose name I cannot remember at this time began to tell me about his mother and
that she was always trying to get him to read his bible and I was able to give him some literature from my
backpack that was with me. I had just gotten it from Mrs. Davis. He would eat meals with me and talk
about becoming a Witness.

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Document for ROLAND GILBERT vs. SALVATION ARMY HARBOR LIGHTS COMPLEX

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