Free Motion for Order - District Court of Connecticut - Connecticut

‘ /2007 Pa e1 of3
Case 2:89-ov—00570-PCD Document 120 Fnled 08/20 Q
WILLIAM ROE, et al., on behalf of ;
Themselves and all others :
Similarly situated :
Plaintiffs : CIVIL NO. H89—570 (PCP)
v. :
Mrcnatt Hosam, et ai. ; t , E
. 1 c:
Defendants Ei lQ?* as “'?'I
SUPPLEMENTAL MOTION FOR ORDER OF COMPLIANCEtA` ii :::
ii CJ ‘
HISTORY Tg; TJ §?j
The plaintiff, Roy Sastrom brought a Motion for é&§?r B$ Q:]
—+ 5:
Compliance in this matter in May of 2007, alleging that the
defendant’s were in violation of the Settlement of Agreement.
In July of 2007, the defendant’s opposed the plaintiffs’
motion claiming that they were not in violation of the
Settlement of Agreement. Also in July of 2007, the defendant’s
filed a Motion for a Protective Order seeking to circumvent the
plaintiff’s request for Interrogatories and Production of
Documents.
The plaintiff is alleging that since the filing of his
original Motion for Order of Compliance that the defendant’s
have violated the Agreement of Settlement.
SUPPLEMENTAL ALLEGATIONS

The defendant’s failed to review and update the plaintiffs’
Master Treatment in June of 2007.

Case 2:89-cv—00570-PCD Document 120 Filed 08/20/2007 Page 2 of 3
The defendant’s scheduled a Master Treatment Plan Review
for June 25w, 2007, for the purposes of reviewing the
plaintiffs’ Master Treatment Plan, but then they failed to
conduct that review pursuant to paragraph (17) of the Agreement
of Settlement.
Paragraph {17) of the Agreement of Settlement requires
that, “Each master treatment plan shall be reviewed and updated
at least every sixty days during the patient’s first year of
treatment, and at least every ninety days thereafter, in
accordance with the current a licable JCAHO standards. A co

of the updated treatment plan shall be forwarded to the
Assistant Superintendent of Clinical Services.”
WHERFORE, the plaintiff motions this Court to enter a
Supplemental Order of Compliance compelling the defendant’s to
comply with the Agreement of Settlement in this matter.
{#,Si3ned this 16m day of August, 2007,
Whiting Forensic Division
Connecticut Valley Hospital
P.O. Box 70, O’Brien Dr.
Middletown, Connecticut 06457

‘ 007 Pa e3of3
Case 2:89-ov—00570-PCD Document 120 Fnled 08/20/2 Q
CERTIFICATION
I hereby certify that the attached Supplemental Motion for
Order of Compliance was mailed to counsel for the defendant's,
Thomas Ring, Assistant Attorney General, 55 Elm St., Hartford,
Connecticut 06106, on August I6"§ 2007.
s‘ ea 1;hiS\16t" day of August, 2007,
·••_ in /r\\
Roy Sast om
Whiting Forensic Division
Connecticut Valley Hospital
P.O. Box 70, O'Brien Dr.
Middletown, Connecticut 06457