Free Response to Motion - District Court of Arizona - Arizona

EXHIBITG
Case 2:04-cv-00644-JAT-LOA Document 64-8 Filed 02/13/2006 Page 1 of 3

.

~-

STATE OF ARIZONA) ) ss. COUNTYOF MARICOPA) AFFIDAVITOF MARILYNM. WAND

MAR1LYN M. WAND, being first duly sworn, upon .says:

her oath deposes and

1. ! have been employed as a SupeNisingPharmacistby the Arizona Departmentof Corrections(ADC) for ten years, and am currentlyassignedat the Lewis Facility of the Arizona State PrisonComplexin Buckeye,Arizona. 2. My duties include, but are not limitedto, providingpharmacy services at the Lewis Facility as well as at the Yuma Facilityof the Arizona State Prison Complexin Yuma, Arizona.
3. I make this affidavit based upon my personal knowledge, experience and expertise, with respect to the procedures maintained and adhered to regarding drug prescriptions. 4. Manufacturer's information guides provided in over~the-counter medication are not available by the prison pharmacy because they are sealed and pre-packaged on an individual basis by the manufacturer prior to delivery to the pharmacy. Therefore, any and all information accompanying an over-the~ counter medication is passed directly to the patient receiving the medication. 5. For prescription medications, most are received in volume by the prison pharmacy, and are generally accompanied by only one drug information guide for each volume shipment received, which is not available or provided to an inmate. If an inmate wants drug information for a prescribed drug filled by the pharmacist, the inmate must fill out a Health Needs Request form. Through this method, the pharmacist will provide the requested drug informationin a print out generated from a computer, which is referred to as a .patient education sheet." The patient education sheets contain substantially the same information received by the prison pharmacy.

6. The patient education sheets that inmatesreceive are similarto the drug informationreceived by patientsfrom pharmaciesoutside of the prison system. 7. The ADC contractswith vendors for over-th~counter drugs and for prescribed drugs received in volume. ADC has used several different vendors over the years, and these vendors use several different drug manufacturersfrom which to supply drugs. Therefore, obtaining manufacturer'sinformation guides for medicationsprovided in prison would require a determinationof which vendor was used during the relevanttime period at the relevant prison unit, and which

Case 2:04-cv-00644-JAT-LOA

1 Document 64-8

Filed 02/13/2006

Page 2 of 3

-",

manufacturer that vendor used to supply the medication for each drug during that time. Even if this could be determined, if the vendor or manufacturer was no longer being used by ADC, ADC may no longer have a copy of the manufacturer's guide for that drug since it would not be currently prescribing medications by that manufacturer.

-/~-'1 YA
SUBSCRIBED AND SWORN TO before me this 2006, by MARILYNM. WAND.
94.1569

MARILYN M. WAND

"dl U~
day of January,

J.L

NOTARY PUBLIC

~Jxn!f -- ~ tI
~'

'

~~

e
.
'-.
~

O;:r-ICIALS",AI.

TERRILYNNWHITE
NOTI\RYPU8UC-ARIZONA

-

-'";11

'+0;; , ,,'

My Comm.ExplrQ~ ~pt. S 25,2008
s:::: ;:: ~--

MARICOPA COUNTY

Case 2:04-cv-00644-JAT-LOA

Document 64-8 2

Filed 02/13/2006

Page 3 of 3