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

. Case 3:03-cv-00735-JCH Document 27-4 Filed 12/23/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
PRISONER . gg
MICHAEL HARTSOCK . : CIVIL NO. 3:03CV735 (J CH)(HBF)
A v. :
A JOHN ARMSTRONG, ET AL. : DECEMBER 22, 2004 A
. AFFIDAVIT OF KEVIN DIECKHAUS, M.D., IN SUPPORT OF
, DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT
Kevin Dieckhaus, M.D., being first duly sworn, deposes and says:
1. I am a physician licensed to practice Medicine in the State of Connecticut since
h 1992.
2. I am Board Certified in Internal Medicine and Infectious Diseases. i
3. My education, training and work experiences are summarized in my curriculum
vitae attached hereto as Exhibit A. A
4. I was employed part-time as an Infectious Disease Consultant with the
Connecticut Department of` Correction from January, 1998 to September, 2002. During that
period of time, I conducted Infectious Disease Clinics at the Cheshire Correctional Institution
4 ("Cheshire C.I.").
5. On June 13, 2002, I reviewed the results of lab studies that had been ordered for
Mr. Michael Hartsock who was an imnate at Cheshire C.I. g attached Exhibit B.
6. At that time, I noted that Mr. Hartsock’s ALT level of 52 was only slightly above
normal and that he did not meet the Correctional Managed Health Care guidelines for referral for
Hepatitis C treatment. S; Guidelines attached hereto as Exhibit C. I noted my findings in
Mr. Hartsock’s chart and wrote an order for the lab tests to be repeated in December, 2002 in

Case 3:03-cv—00735-JCH Document 27-4 Filed 12/23/2004 Page 2 of 3
{ .
accordance with accepted protocol. g chart entry and physician order dated 6/13/02 attached
hereto as Exhibit D.
7. I ended my affiliation with the Department of Correction in September, 2002 so
that I could devote more time to my practice and other duties at the University of Connecticut
Health Center. Except for my review of Mr. Hartsock’s lab test results on June 13, 2002, I did
not have any further involvement with Mr. Hartsock’s care. I
A 8. When I scheduled Mr. Hartsock for repeat lab tests to be done in six months, I
l was following standard protocol which required at least two transaminase values separated by at
I least six months which show a level at least 1.5 times the upper normal level. _Sg_e Exhibit C.
I _ While my involvement with Mr. Hartsock’s care was very brief, my actions were appropriate and
within the standard of care.
_ I, Kevin Dieckhaus, M.D., do hereby swear that the contents of the foregoing affidavit
are true and accurate to the best of my knowledge and belief
/. gov; B _Dtat{a6»»»-. WC;
Kevin Dieckhaus, M.D.
to Subscribed and swom to, before me, this 5}/ "day of December, 2004. i
Q2;/Q./( .» V _
Richard T. Couture —
Commissioner of the Superior Court
2

l Case 3:03-cv—00735-JCH Document 27-4 Filed 12/23/2004 Page 3 of 3
DEFENDANTS
John Armstrong, et al.
RICHARD BLUMENTHAL
ATTORNEY GENERAL
BY: ZZ;/%2g,f
A Richard T. Couture "
Assistant Attorney General
110 Sherman Street
Hartford, CT 06105
Federal Bar #ct05480
t _ E-Mail: [email protected]
V Tel.: (860) 808-5450
* Fax: (860) 808-5591
CERTIFICATION
I hereby certify that a copy of the foregoing Affidavit of Kevin Dieckhaus, M.D., with
attached exhibits, was sent by first class mail, postage prepaid, this 22nd day of December, 2004,
? to:
Michael Hartsock, Inmate N0. 128651
Cheshire Correctional Institution
900 Highland Avenue
Cheshire, CT 06410
I LQ;/g,{_ 6;;;.»?;2a;`>
A . Richard T. Couture
Assistant Attorney General