Then-D.C. Department of Corrections Director Margaret A. Moore knew for months that violent criminals were being housed inappropriately with less violent offenders at a privately run Ohio prison but did nothing to correct the situation until after the deaths of two District inmates, according to a sworn affidavit.

John H. Thomas, the agency's former deputy director, who now works as a warden at a private prison in Southern California, said in the affidavit that Moore was told at least three times that the "wrong mix of prisoners" was at the medium-security Northeast Ohio Correctional Center in Youngstown and that "no classification, movement . . . or separation policies were in place."

"I continuously informed Director Moore about the security issues being raised," said Thomas, who was terminated from the department late last year after allegations that he misused a District government vehicle. "No appropriate action was taken to protect the prisoners."

Thomas did not return calls to his office or his pager.

The eight-page affidavit, provided to The Washington Post, is part of a multimillion-dollar wrongful death lawsuit filed by India Chisley. Chisley's husband, Bryson, was fatally stabbed in March 1998, allegedly by inmate Alphonso White.

White was serving up to 60 years for murder and armed robbery and had been transferred from the maximum-security prison at the Lorton Correctional Complex in Fairfax County. Chisley was serving a four-to-12-year sentence for drug and weapons convictions.

White was one of more than 200 inmates sent to Ohio without being properly separated from other inmates. He was one of 118 who should not have been sent there because he was not a medium-security inmate, officials said.

India Chisley sent several letters to Moore, the D.C. financial control board and other District officials asking that her husband be transferred back to the Correctional Treatment Facility in Southeast Washington, where he had been housed for drug treatment before being shipped to Ohio. She told officials that her husband had been assaulted by other inmates at the Youngstown prison and said he feared for his life. Officials did not respond to her letters. A few months later, Bryson Chisley was stabbed to death.

Thomas said he had repeatedly asked Moore to send him to the Youngstown facility to "review its policies and procedures, and to assure that the staff had been adequately trained and that the physical plant was secure and complete." Thomas was the contract administrator for that prison.

"Director Moore did not authorize this request," he said.

Moore did not return three telephone calls yesterday seeking a comment. She was removed from her position in October and was reassigned to the office of the District's chief management officer. She now oversees receivership issues for the control board.

Thomas also said in the affidavit that a lawyer with the D.C. corporation counsel's office asked a contract monitor not to report specific damaging information in his monthly reports, "since these actions could result in liability against the [Department of Corrections] in the pending class-action" suit filed in 1997 by inmates housed at the Northeast Ohio Correctional Center in Youngstown.

The lawyer, Paul Klein, said yesterday in an interview that he never asked the monitor to omit disparaging information.

"The litigation strategy is privileged, and I'm not allowed to discuss what happened, but I can tell you Mr. Thomas's assertion is incorrect," said Klein, who is now deputy counsel for Mayor Anthony A. Williams (D).

David Bogard, the monitor whom Klein allegedly asked not to report damaging information, did not dispute Thomas's version yesterday in an interview.

"If you have a sworn affidavit, it sounds to me that you can put some credence in it," said Bogard, who heads a criminal justice consulting firm with offices in New York and Virginia.

Bogard repeatedly warned Moore that "severe security issues existed" at the Youngstown prison and that prisoners were in danger, Thomas said. He developed a plan to improve the safety of the prisoners, including recommendations to remove maximum-security inmates and improve staff training. The plan was not implemented, Thomas said.

Bogard declined to discuss the meetings with Moore and others about the prison, but said, "I would put an awful lot of credibility in what he [Thomas] says."

Thomas's affidavit is the latest in a series of documents detailing management and oversight problems at the 2,000-bed Youngstown prison, which is owned and operated by the Nashville-based Corrections Corp. of America. Since the facility opened in May 1997, more than 40 assaults, two fatal stabbings and the escape of six inmates have occurred.

The violence prompted calls from Youngstown officials and Ohio lawmakers to have the prison closed. Attorney General Janet Reno ordered a review of the facility by D.C. Corrections Trustee John Clark and a team of corrections experts from Maryland, Texas and Florida.

The team found that Moore and other corrections officials failed to monitor the $182 million, five-year contract with CCA until legal problems arose. It also found lax security and inexperienced and poorly trained staff and accused Moore and CCA officials of not carefully selecting inmates for transfer.

"Finally, after numerous incidents of violence, injuries and two murders, Director Moore authorized me to become actively involved," Thomas said.