Free Reply Brief - District Court of Delaware - Delaware

c Case1:06—cv—00011g.R 50#3 Filed 06/23/2006 Page10f1
( y , X · E
administered Dilantinl twice a day. On the same day he was l I
referred to mental health. On November 19, 2005, Baylis made a
request for mental health services and on November 24, 2005, he
received mental health treatment, including the medications
Rrggiisz and Prozac’, and he was scheduled for a follow—up visit
in three months. The medication administration record for
December 2005 indicates that Baylis was administered Dilantin and
Prozac on a daily basis. .
Baylis was next seen on January 11, 2006. At that time, Dr.
J, Anthony Cannuli (“Dr. Cannuli”) discontinued the use of Ritalin
because it is contraindicated in persons with a history of
seizures and Baylis has -·ea a seizure dis5rH€?°histbry: Dr. Cannuli

states that Baylis is being prescribed and administered
U ‘appropriate medication for his conditions and there is no danger
_ of medical/psychiatric harm to Baylis in the administration of
the medications Baylis is currently prescribed or in his current
mental health treatment plan.
` Given the exhibits submitted to the court, Baylis has not l
demonstrated the likelihood of success on the merits. Baylis
alleges that he has not received mental health treatment and l
lnilantin (phenytoin) is indicated for the control of tonic—clonic
(grand mal) seizures and psychomotor(temporal lobe)seizures. www.pfizer.ccm/
pfizerfdownload/uspi_dilantin125.pdf.
2Ritalin is indicated in the treatment of Attention Deficitt
Hyperactivities Disorder. Physicians' Desk Reference 2256 (60m ed. 2006).
3Prozac is indicated in the treatment of major depressive disorder.
Physicians' Desk Reference 1773 (60* ed. 2006).
i /0 (
( I