Free Motion for Summary Judgment - District Court of Connecticut - Connecticut


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Date: December 22, 2004
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State: Connecticut
Category: District Court of Connecticut
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Case 3:03-cv—00735-JCH Document 27-9 Filed 12/23/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
PRISONER
MICHAEL HARTSOCK . : CIVIL NO. 3:03 CV735 (J CH)(HBF)
v. :
JOHN ARMSTRONG, ET AL. : DECEMBER 22, 2004 I
AFFIDAVIT OF PATRICIA WOLLENHAUPT IN SUPPORT OF
_ DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT `
; Patricia Wollenhaupt, being tirst duly swom, deposes and says:
i 1. I have been licensed as a Registered Nurse in the State of Connecticut since 1984
and have held various nursing positions with the State of Comiecticut Department of Correction
since November, 1985.
2. Mr. Michael Hartsock was an inmate at the Northem Correctional Institution
("NCI") during the period March 5, 1999 to Ap1il4, 2000. E Exhibit A to the Affidavit of
Dr. Edward Blanchette.
3. In paragraph 22 of his Amended Complaint, Mr. Hartsock alleges that on one
occasion when I was touring NCI in November, 1999, I stated to him that he did not look like a
candidate to be treated for the Hepatitis C virus. I.
4. I began working at NCI in August, 1999 and would make weekly tours of the
gl facility. I do not recall Mr. Hartsock or having any conversations with him regarding Hepatitis
C. A review of the few medical chart entries that were made during the time that Mr. Hartsock
was an inmate at NCI reveals that I did not make any entries in his chart. This would indicate

_ Case 3:03-cv—00735-JCH Document 27-9 Filed 12/23/2004 Page 2 of 3
that I never saw Mr. Hartsock during any formal visit to the medical unit in connection with any
A medical issue. E NCI chart entries attached hereto as Exhibit A.
5. During the period October 29, 1999 to December 3, 1999, I was on a five week
leave of absence from work. I could not have run into Mr. Hartsock at NCI during the month of
November, 1999.
6. The management and treatment of Hepatitis C has been an evolving process over
the years. It is a fairly complex undertaking. Only a physician can determine a patient’s p
eligibility for Hepatitis C treatment. Since December, 2002, Hepatitis C treatment issues must
Â¥ be reviewed by a panel of three Infectious Disease Specialists. As a Registered Nurse, I do not
l have the training or the authority to make any treatment decisions regarding Hepatitis C.
I, Patricia Wollenhaupt, do hereby swear that the contents of the foregoing affidavit are
true and accurate to the best of my knowledge and belief.
éigatricia Wollenhaupt y
A . Subscribed and sworn to, before me, this of JQ of December, 2004.
Richard T. Couture
. Commissioner of the Superior Court
2

i Case 3:03-cv—00735-JCH Document 27-9 Filed 12/23/2004 Page 3 of 3
l
DEFENDANTS
John Armstrong, et al.
J RICHARD BLUMENTHAL
1 ATTORNEY GENERAL
BY: g.{2;,,L/ /’/4/7/Q”·>
Richard T. Couture
Assistant Attorney General
110 Sherman Street
Y Hartford, CT 06105
’ Federal Bar #ct05480
5 E-Mail: [email protected]
; Tel.: (860) 808-5450
Fax: (860) 808-5591
CERTIFICATION
I hereby certify that a copy of the foregoing Affidavit of Patricia Wollenhaupt, with
attached exhibit, was sent by first class mail, postage prepaid, this 22nd day of December, 2004,
to:
Michael Hartsock, Inmate No. 128651
Cheshire Correctional Institution
900 Highland Avenue
Cheshire, CT 06410
Richard Couture U
Assistant Attorney General
3