Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00696-JBA

Document 19-2

Filed 02/25/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ANTHONY TORRES v. "JOHN" TROMBLY : : : FEBRUARY 24, 2004 CIVIL NO. 3:03CV696 (JBA) (JGM)

AFFIDAVIT OF PATRICIA WOLLENHAUPT The undersigned, having been duly sworn, hereby deposes and says: 1. 2. I am over the age of 18 and understand and believe in the obligation of an oath. I am a Correctional Hospital Nursing Supervisor with the State of Connecticut,

Department of Correction. I have been employed by the Department of Correction since 1985 and have held the positions of Correctional Nurse, Correctional Head Nurse, and Correctional Hospital Nursing Supervisor. I have been assigned to Northern Correctional Institution (hereinafter "Northern") and Osborn Correctional Institution since 1999. 3. As part of my duties, I have served as the Medical Grievance Coordinator for

Northern. In my position as supervisor, I currently have access to medical grievances and responsibility for responding to medical grievances. 4. complaint. 5. I have reviewed the plaintiff's medical records for the period from March 16, I am a defendant in this case and I am familiar with the allegations of the

2003, to the present. 6. The plaintiff is prescribed hydrochlorothiazide, 25 mg, which is a mild diuretic

for high blood pressure.

Case 3:03-cv-00696-JBA

Document 19-2

Filed 02/25/2004

Page 2 of 2

7.

The medical records show that the plaintiff received this medication every day

during the month of March 2003, including March 16, 2003. 8. According to the kardex, on March 16, 2003, this medication was dispensed by

Nurse Lynn Nordell, not Nurse Kindness as alleged by the plaintiff. 9. A review of the plaintiff's medical records confirms that he has received and

continues to receive appropriate medical care. 10. Nurse Kindness as well as the other nurses does not appreciate inmates being

scantly, if at all, dressed when medication is dispensed at their cell doors.

_________________________ Patricia Wollenhaupt

Subscribe and sworn to before me this _____ day of February, 2004.

__________________________ Henri Alexandre Commissioner of the Superior Court