Free Declaration in Support - District Court of California - California

Case 3:07-cv-02928-JSW

Document 29

Filed 06/23/2008

Page 1 of 3

1 EDMUND G. BROWN JR. Attorney General of the State of California 2 DAVID S. CHANEY Chief Assistant Attorney General 3 FRANCEST.GRUNDER Senior Assistant Attorney General 4 MICHAEL W. JORGENSON Supervising Deputy Attorney General5 LISA SCIANDRA, State Bar No. 246532 Deputy Attorney General 6 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 7 Telephone: (415) 703-5846 Fax: (415) 703-5480 8 Email: [email protected] 9 Attorneys for Defendants Curry, Chudy, Hill, Hedrick, Raghunath, Grannis, Aboytes, and Klein 10
11

IN THE UNITED STATES DISTRICT COURT 12 FOR THE NORTHERN DISTRICT OF CALIFORNIA
13

SAN FRANCISCO DIVISION 14 15 16 17 18 - ' 19 20 21 I, J. CHUDY, declare as follows: 22 23 24 1. I am the Chief Medical Officer and Health Care Manager for the Correctional Training

RONALD BRATTON,
Plaintiff,
-.J

Case No. C 07-2928 JSW

v. BEN CURRY,
Defendants.

DECLARATION OF J. CHUDY IN SUPPORT OF DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

Facility (CTF). As the Chief Medical Officer and Health Care Manager, I direct all medical care at CTF and oversee the operation of the medical, mental health, and dental programs as well as

25 the infirmary. I have been licensed to practice medicine in the state of California since 1982, and 26 board certified in Family Medicine since 1984. I have been employed by the California 27 28 Department of Corrections and Rehabilitation (CDCR) since 2001 and have been Chief Medical Offiger at CTF since 2006. I am competent to testify to the matters set forth in this declaration,
Dec!. J. Chudy in Support of Defs.' Mot. Summ. J.

R. Bratton v. B. Curry, et al. C 07-2928 JSW

1

Case 3:07-cv-02928-JSW

Document 29

Filed 06/23/2008

Page 2 of 3

1 and if called upon to do so, I would and could so testify. I submit this declaration in support of 2 Defendants' Motion for Summary Judgment. 3 2. I have reviewed the medical records for inmate Ronald Bratton, CDCR number J-

4 45341. Inmate medical records are kept in the course of regularly conducted business activity 5 and every effort is made to maintain the accuracy and integrity of each record. 6 3. Inmate Bratton's medical records show that his blood chemistry is consistent with

7 chronic lymphocytic leukemia (CLL) because his white blood count and particularly his 8 lymphocytes have been elevated. His recommended treatment plan has been to monitor his white 9 blood count by taking a complete blood count about every four months. He might require 10 additional treatment ifhe had a rapid rise in white blood count, decrease in performance status, . 11 or decreased hemoglobin or platelet count. Inmate Bratton's medical records do not show that he 12 has exhibited any of these symptoms or requires additional treatment.
13

a.

Attached as Exhibit A is a true and correct copy of a report from Dr. Sanjay R.

14 Ganpule dated November 8, 2006, and a flow cytometry interpretation dated November 8, 2006, 15 which document the medical information in the paragraph above. 16 4. Laboratory analyses of inmate Bratton's blood demonstrate that his liver, kidney, blood

17 sugar, albumin, iron, cholesterol, and triglycerides are all within normal range. This indicates 18 that he does not have any nutritional deficiencies and is consuming adequate amounts of protein 19 and iron, among other nutrients. This further indicates that his vegetarian diet is not adversely 20 21 affecting him. a. His laboratory results also demonstrate that his white blood count has remained

22 elevated but stable since 2002. This is consistent with his diagnosis of CLL but shows that his 23 CLL is not worsening. 24 b. Attached as Exhibit B are true and correct copies of laboratory results dated:

25 October 7,2002; October 9, 2002; September 15, 2006; March 12, 2008; and March 18,2008, 26 which document the medical information in the paragraph above. 27 5. Inmate Bratton was has been diagnosed with thalassemia trait. Individuals who have

28 the thalassemia trait generally have a low to normal iron level that is considered adequate. If
Dec!. 1. Chudy in Support of Defs.' Mot. Summ. 1.
R. Bratton v. B. Curry, et al. C 07-2928 JSW

2

Case 3:07-cv-02928-JSW

Document 29

Filed 06/23/2008

Page 3 of 3

1 those individuals take iron supplements, then periodic blood tests are needed to monitor their 2 3 4

iron levels so that excessive iron does 110t lead to liver toxicity.
a. Attached as Exhibit C is a true and correct copy of laboratory results dated

September 18,2007, which document inmate Bratton's thalassemia trait.

S

Tdeclare under penalty of perjury that the foregoing is true and correct, Executed at
~

6 Soledad, California, on 7

tj/A.1t.- 2iJ-

..

,2008.

.

8

9
10

J. Chud
Chief Medical Officer & Heal
201 I7597.wpd

Care Manager

11

12
13

sr2oa~'I004(r2

lA
15

16
17

18
19

20
21

22
23

24
25
26

27
28
Dec1. J. Chudy in Support of Defs.' Mot. Surnrn. .T.

R. Brattonv. B. Curry, et al.
C 07·2928 JSW

3