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

Case 3:03-cv—00735-JCH Document 27-7 Filed 12/23/2004 Page 1 of 3
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y UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
. y PRISONER
. MICHAEL HARTSOCK : CIVIL NO. 3 :03CV735 (J CH)(HBF)
v. I :
JOHN ARMSTRONG, ET AL. : DECEMBER 22, 2004 U
AFFIDAVIT OF PATRICIA OTTOLINI IN SUPPORT OF
` DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT g
Patricia Ottolini, being first duly sworn, deposes and says:
1. I am currently employed as the Director of Health and Addiction Services for the
S Connecticut Department of Correction. In May, 2002, I held the position of Correctional Health
Services Program Director. _ °
2. My training, experience and job responsibilities are described in my curriculum
z vitae attached hereto as Exhibit A.
. 3. On or about May 1, 2002, Mr. Michael Hartsock sent a letter to myself,
Commissioner John Armstrong, Deputy Commissioner Jack Tokarz, Warden Hector Rodriguez
A and Doctors Blanchette, Dieckhaus, and Maleh requesting treatment for his Hepatitis C. S_g_e I
letter attached hereto as Exhibit B.
_ 4. Commissioner Armstrong asked me to investigate Mr. Hartsock’s Hepatitis C
E treatment status and respond to the letter on behalf of` himself, Deputy Commissioner Tolrarz and
` Warden Rodriguez. l
5. Shortly after our receipt of` this letter, Dr. Jack Maleh at the Cheshire Correctional
Institution ordered a number of lab tests to evaluate Mr. Hartsock’s Hepatitis C status and liver
function.

Case 3:03-cv—00735-JCH Document 27-7 Filed 12/23/2004 Page 2 of 3
6. On May 22, 2002, I sent a letter to Mr. Hartsock noting that his blood had been
` drawn on May 14, 2002 to enable the medical staff at the Cheshire Correctional Institution to I
ascertain his current HepatitisC status. I also assured Mr. Hartsock that the results of the tests
would be reviewed to determine a proper course of treatment. g letter of May 22, 2002
attached hereto as Exhibit C.
7. As discussed in the accompanying affidavits of Dr. Blanchette and Dr. Dieckhaus,
Mr. Hartsock’s Hepatitis C status was reviewed and followed by Dr. Dieckhaus and
I subsequently by Dr. James O’Halloran. Drs. Dieckhaus and O’Halloran are highly regarded
l Infectious Disease Specialists who have considerable experience in evaluating and treating
{ patients with Hepatitis C. It is my understanding that Mr. Hartsock recently completed a forty-
1 eight week treatment period with Pegasys and Ribavirin and that the initial results are quite
P encouraging.
E 8. Following my response to Mr. Hartsock on May 22, 2002, the Commissioner’s
office does not have any record of any further communication from him.
P I, Patricia Ottolini, do hereby swear that the contents of the foregoingaffidavit are true
and accurate to the best of my knowledge and belief
E Patricia Ottolini
Subscribed and sworn to, before me, this M day of December, 2004.
Ljzaffizf J
U Richard T. Couture
Commissioner of the Superior Court
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Case 3:03-cv—00735-JCH Document 27-7 Filed 12/23/2004 Page 3 of 3
l
DEFENDANTS
John Armstrong, et al.
RICHARD BLUMENTHAL
ATTORNEY GENERAL
BY;
Richard T. Couture
· Assistant Attorney General I
110 Sherman Street
Hartford, CT 06105
Federal Bar #ct05480
E—Mail: [email protected]
I Tel.: (860) 808-5450
V Fax: (860) 808-5591
y CERTIFICATION
I I hereby certify that a copy of the foregoing Affidavit of Patricia Ottolini, with attached
exhibits, 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
j Cheshire, CT 06410
f»z.{/
gg Richard T. Couture
g g Assistant Attomey General
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