Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00400-CFD

Document 44-5

Filed 10/21/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SAMUEL BOWENS V. MARK STRANGE, ET AL OCTOBER 14, 2004 3:03CV400(CFD)

AFFIDAVIT OF DR. EDWARD BLANCHETTE 1. 2. 1975. 3. I completed my residency in medicine at Saint Francis Hospital, Hartford, I am over the age of 18 and understand and believe in the obligations of an oath: I am a physician licensed to practice medicine in the State of Connecticut since

Connecticut, in 1977, and completed a Fellowship in Infectious Disease and Microbiology from the University of Connecticut School of Medicine in 1979. 4. I have held various positions with the State of Connecticut Department of

Correction (hereinafter "DOC") since 1984, including Hospital Clinical Director at Osborn Correctional Institution, Medical Director at the MacDougall Correctional Institution (hereinafter "MacDougall"), and Acting Director of Health Services and Clinical Practice Coordinator. I am currently the Director of Professional and Clinical Services for the Department of Correction. 5. Correction. 6. When the plaintiff entered DOC custody the last time, he already had advanced I have reviewed the medical records of the plaintiff from the Department of

glaucoma in his left eye which had gone untreated. The plaintiff entered DOC custody on June

Case 3:03-cv-00400-CFD

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16, 2000. The plaintiff had suffered from symptomatic glaucoma in left eye since at least 1996. As early as January of 2001, even with eye drop treatment for the six months preceding while incarcerated, the plaintiff complained of "almost complete loss of vision." Ex. B 185. 7. While he was incarcerated, the plaintiff had issues complying with medication of

various sorts, including his eye drops. Ex. B 8. When Dr. Serafini saw the plaintiff in June of 2001, he noted that the plaintiff's

left eye only responded to movement, and there was no numerical value he could put on the plaintiff's sight in his left eye. 9. The inter-ocular pressure in the plaintiff's left eye was very high as early as

October of 2000, even with eye drops. Ex. B 238. After several more months of eye drops, it continued to be "too high" as per the treating ophthalmologist. Ex. B 340. 10. As far back as May 2000, it was noted that the plaintiff had a severely damaged

optic nerve in his left eye. Ex. B 152. 11. Given the inter-ocular pressure in the plaintiff's left eye, given the advanced stage of the glaucoma, and given the irreversible damage to the optical nerve, either traditional or laser surgery to treat the plaintiff's glaucoma during his last period of incarceration would have been unsuccessful. The attendant risks of the surgery would have outweighed any potential benefit.

Case 3:03-cv-00400-CFD

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Filed 10/21/2004

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__/s/____________________________ Dr. Edward Blanchette Subscribed and sworn to before me this 14th day of October, 2004.

__/s/____________________________ Lynn D. Wittenbrink Commissioner of the Superior Court/