"...14. Defendants have failed and continue to fail to
provide adequate medical, nursing, neurological,
psychological, nutritional, habilitation, therapy, and
psychiatric care services to Glenwood and Woodward
residents, to ensure that these residents are free from
undue and unreasonable restraint, and to otherwise protect
Glenwood and Woodward residents from harm.
"...15. Defendants have failed and continue to fail to
assess Glenwood and Woodward residents to ascertain whether
residents of these facilities are receiving adequate
treatment, supports, and services in the most integrated
setting appropriate to their individual needs; that those
individual residents whom professionals determine should be
placed in community programs are placed in such programs,
when appropriate; and that the institution’s residents are
served in the most integrated setting appropriate to each
resident's individual needs. ..."