Free Response to Motion - District Court of Arizona - Arizona

EXHIBIT E
Case 2:04-cv-00644-JAT-LOA Document 64-6 Filed 02/13/2006 Page 1 of 3

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Terry Goddard Attorney General

Office of the Attorney General State of Arizona Liability Management Section
December 5,2005

Writer's Direct Line: (520) 388-7138 [email protected]

Paul Eugene Rhodes ASPC- Florence-Central Post Office Box 8200 Florence, Arizona 85232

Re:

Paul Eugene Rhodes v. Quirino Valeros, et al., USDC No. CV04-0644-PHXJAT (MS), IDS05-0 164

Dear Mr. Rhodes: This letter is in response to the discovery matters you raised at your deposition. As promised, I have investigated these matters and have the following information for you.

1.

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Persons Responsihlf!.for Telemed C.onsults '''..

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There are several people who are responsible for different aspects of telemed consults, so it is very difficult to accurately answer this question. To the best of my knowledge, you want to know who is responsible for setting up the consult once it has been recommended and approved. Upon notification of an approval for a telemed consult, the Clinical Coordinator at the prison complex where the inmate resides is responsible for setting up the telemed consult; i.e., having images of the inmate taken and sending those images via computer to specialist, who views them on a computer. The Clinical Coordinator at ASPC-Florence is Judy Aguilar. The Clinical Coordinator at ASPC-Yuma is Carrie Feehan.

2.

Pictures for Telemed Consults.

You want hard copy versions of the, images that were taken for your telemed consults. Unfortunately, there are no hard copy versions of these images. The telemed consult process is all electronic. For your dermatology consult, images were taken via ~ digital camera that contained no film. The digital camera was attached to a computer where the images were sent to the doctor performing the consult, who viewed them on a computer

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

Document 64-6

Filed 02/13/2006

Page 2 of 3

177 N. Church Ave., Ste. 1105, Tucson, Arizona 85701-1114. Phone 520-628-6044. Fax 520-628-6050

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Mr. Rhodes Eugene Rhodes v. Quirino Valeros, et al December 5, 2005 Page 2 of2

at his location. The images were never printed out and, due to space limitations, since neither the dermatologist performing the consult nor you requested these images, they were deleted. Furthermore, my understanding is that even if printed copies of the images were available, they would be of poor quality in comparison to the digital images actually viewed by the specialist, and would therefore not accurately represent what the specialist viewed.

3.

Manufacturer's Information Guides

You want the manufacturer's information guides for 18 listed medications you received for your skin condition. For over-the-counter drugs available without a prescription, the prison pharmacy does not keep a copy of the accompanying drug information as it is already sealed and pre-packaged on an individual basis by the manufacturer prior to delivery to the pharmacy. Prescribed drugs that are received in volume are generally accompanied by only one drug information insert for each volumeshipment received, and therefore are not provided to inmates. Any inmate may request drug information for a prescribed drug filled by the prison pharmacist by filling out a Health Needs Request, and will receive a''''patient education sheet," which contains the same information that the prison pharmacy rec.eives. These patient education sheets are also similar to the information you would receive from a pharmacy outside of prison. Copies of the patient education sheets for prescription drugs you requested are attached, as well as additional patient education sheets for other drugs you were prescribed while in prison. The patient education sheets contain comprehensive information regarding the drug, including.. contraindications and possible side effects. This information should qe sllffici~ntfor YOllr, ~ statedneeds.' --

Anne Stratman Assistant Attorney General
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Filed 02/13/2006 Page 3 of 3

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

Document 64-6