Free Motion for Summary Judgment - District Court of Arizona - Arizona

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TERRY GODDARD ATTORNEY GENERAL ANNE STRATMAN (022301) Assistant Attorney General 177 North Church Avenue, Suite 1105 Tucson, Arizona 85701-1114 (520) 628-6044 · Fax (520) 628-6050 [email protected] Attorneys for Defendants

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Paul Eugene Rhodes, Plaintiff, v. Quirino Valeros, et al., Defendants. No: CV04-0644-PHX-JAT (MS) DEFENDANTS' STATEMENT OF FACTS IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT

Defendants Terry Allred, Susan Buffington, Gene Greeley, Kim Kumar, Michael Lesac, Gary Pinkstaff, Richard Pratt, David Rivas, Bruce Shiflet, and Vern Strubeck, by and through counsel undersigned, present the following facts from the record in support of their Motion for Summary Judgment filed herewith, as provided under Rule 56 of the Federal Rules of Civil Procedure: 1. Plaintiff Paul Eugene Rhodes is an inmate in the custody of the Arizona

Department of Corrections ("ADC"). (See Complaint at 1.) 2. Since his incarceration in September of 2002, Rhodes has been housed at

several different prisons, including Arizona State Prison Complex ("ASPC")-Florence, ASPC-Safford, and ASPC-Yuma. (See Complaint at 1.)

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Rhodes' Medical Care 3. On January 9, 2002, Rhodes entered ADC and had a physical examination.

It was noted that Rhodes has had Hepatitis-C since 1984, that he had a liver biopsy in 1998, and that he has a long history of drug and alcohol abuse, including the use of methamphetamine and intravenous heroin. attached hereto as Exhibit 1, at ¶ 3.) 4. When he entered ADC in January 2002, Rhodes also had a skin infection that (See Affidavit of Michael Lesac, M.D.,

appeared as papular eruptions on his face. Initially, the skin condition was diagnosed as impetigo, a common and relatively minor bacterial skin infection that produces blisters or sores on the face and hands. He was given a prescription for oral antibiotics. Id. at ¶ 4. 5. On August 26, 2002, Rhodes submitted a Health Needs Request ("HNR") to

prison medical staff complaining of a rash that was itching, spreading, and "getting worse." Id. at ¶ 5. 6. On September 17, 2002, Rhodes was diagnosed with Furunculosis, a skin

condition that causes deep sores of the skin, also known as boils. Rhodes received Ancef injections (an antibiotic used to treat a wide variety of bacterial infections) for two days, oral antibiotics, and an antihistamine to reduce itching and swelling. Id. at ¶ 5. 7. On October 8, 2002, Rhodes had a follow-up examination. His skin

condition had improved, but it was not totally controlled. It was suspected that his skin condition might be attributable in part to pruritus secondary to liver disease, meaning that Rhodes's liver problems were causing him to scratch his skin, causing sores to appear. During this follow-up examination, Rhodes was treated with an antihistamine and a skin ointment intended to reduce his desire to scratch his skin. Id. at ¶ 6. 8. One week after Rhodes' first follow-up examination, he had another follow-

up examination on October 15, 2002. During this visit, Rhodes' skin condition was still

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present, and a request for a dermatologist consultation was submitted. Id. at ¶ 7. 9. For security and operational reasons, requests for visits to off-site medical

specialists such as dermatologists go through a two-step process: first they are reviewed by an on-site Medical Review Committee ("MRC") and then , if approved by the MRC, they are sent for review and approval to the ADC Central Office in Phoenix. Id. at ¶ 8. 10. While awaiting approval for a dermatologist consultation, Rhodes was seen

three more times for his skin condition by prison medical providers, on November 18, 2002, December 13, 2002, and January 8, 2003. Each time, Rhodes was prescribed medications for his skin condition, generally consisting of oral antibiotics to clear up the infection, and antihistamines to reduce itching and swelling. During this period, Rhodes' skin condition improved. Id. at ¶ 9. 11. Between October 17, 2002 and June 12, 2003, Rhodes did not submit any

health needs requests regarding any further problems with his skin condition. Id. at ¶ 10. 12. On June 12, 2003, Rhodes had a consultation with a dermatologist via

telemedicine. Using the telemedicine system, images of Rhodes' skin condition were taken and sent electronically to Dr. Norman Levine, a dermatologist at Carondelet Heath Network in Tucson, AZ. Dr. Levine reviewed the images of Rhodes' skin condition and Rhodes' relevant prison medical records. Id. at ¶ 11. 13. Dr. Levine diagnosed Rhodes' condition as most likely prurigo nodularis

secondary to liver insufficiency. Thus, Dr. Levine believed Rhodes' skin condition was the result of his scratching his skin, and the desire to scratch was a result of his liver disease. Id. 14. Dr. Levine recommended Prednisone, an anti-inflammatory medication to

relieve some of the itching, and a skin ointment. Dr. Levine also recommended that Rhodes try a different antihistamine (doxepin), since the previously prescribed

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antihistamines had not been effective. Rhodes was prescribed medications consistent with all of Dr. Levine's recommendations. Id. 15. During the next eight months, Rhodes submitted approximately eight HNRs

related to ongoing problems with his skin. On each occasion, Rhodes was seen by a medical provider and prescribed medications to improve his skin condition, including antibiotics, antihistamines and skin ointments. Different forms of each of these

medications were prescribed by medical providers when the previous form of the medication proved ineffective. Rhodes' skin condition fluctuated in severity during this time. Id. at ¶ 12. 16. Since no treatment had proved entirely effective in treating Rhodes' skin

condition, ADC medical providers requested another consultation with a dermatologist. He received the consultation on April 7, 2004. Rhodes was again seen by Dr. Norman Levine, who viewed images of Rhodes' skin condition electronically through the telemedicine system. Dr. Levine noted all the medications that Rhodes had previously received for his skin condition, and noted his earlier diagnosis of prurigo nodularis in June 2003. At this time, Dr. Levine believed Rhodes' skin condition was probably caused by two separate ailments ­ seborrheic dermatitis, commonly known as dandruff, and folliculitis, a superficial infection of the hair follicle. Dr. Levine recommended that

Rhodes continue to use the skin cream he was currently using, but to try a different antibiotic that is sometimes effective as an alternative to the previous antibiotics The prison medical providers prescribed medications consistent with all of Dr. Levine's recommendations. Id. at ¶ 13. 17. Dr. Levine noted in his consultation report that if the recommended

medications did not improve the situation, he may consider other diagnostic options such as cutaneous lupus erythematosus, a skin disorder that can last for years and recur. Dr.

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Levine noted that a diagnostic biopsy would be needed to confirm this diagnosis. Dr. Levine emphasized that the skin condition was not a "major concern for [him] at this time." Id. at ¶ 14. 18. During the months after his dermatologist consultation, Rhodes was treated

with several different anti-itch medications because he was scratching and excoriating his skin, worsening the problem and increasing the risk for bacterial infection. Id. at ¶ 15. 19. Shortly after the dermatologist consult, Rhodes had a follow-up examination. Rhodes insisted that the dermatologist-

Rhodes' skin condition was still present.

recommended antibiotic was worsening his skin condition, but Dr. Lesac did not note any change in his skin condition at all, good or bad. Rhodes requested a different antibiotic, Erythromycin, because he previously had good results with this medication. He received it. In a follow-up visit on June 16, 2004, Rhodes's skin condition had improved. Id. at ¶ 16. 20. On August 3, 2004, in accordance with Dr. Levine's recommendation, a

biopsy was taken from a portion of one of the sores on Rhodes' skin. The pathologist noted that Rhodes had an acute (rather than chronic) skin reaction that had localized inflammation and scar tissue that extended to the fat layer of his skin. The pathologist did not note any evidence of cutaneous lupus erythematosus, the alternative diagnosis considered by Dr. Levine. This result indicated that the current treatment of antibiotics and antihistamines was still the proper course of treatment for Rhodes' skin condition. No treatment changes were suggested. Id. at ¶ 17. 21. After the biopsy, Rhodes submitted numerous HNRs regarding his skin

condition and received prescribed medications on numerous occasions. Id. at ¶ 18. 22. Starting on approximately March 3, 2004, Rhodes received Interferon

injections and oral Ribavirin for his Hepatitis-C. These medications can suppress the

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immune system, and ADC health providers monitor for this problem. When Rhodes started the treatment for Hepatitis-C, he already had chronic skin problems, which were not caused by Interferon and/or Ribavirin. Rhodes' immune system did weaken on the Heptatitis-C treatment and the doses of medications were appropriately reduced, and eventually were discontinued. Id. at ¶ 19. 23. Rhodes' skin problem persisted during and after Rhodes was on the

Hepatitis-C treatment. The Interferon and Ribavirin had no substantial effect on Rhodes' pre-existing skin condition. Id. 24. Dr. Lesac's opinion is that it was medically appropriate to treat Hepatitic-C

condition, even given Rhodes' skin condition. Starting Rhodes on this treatment with his pre-existing skin condition was a considered medical decision that did not cause Rhodes any serious side effects or harm. Id. at ¶ 20. 25. Rhodes has a recurring, minor, skin condition that fluctuates in severity

depending on numerous factors, including how much he aggravates the condition by scratching it. Rhodes' skin condition is possibly related to his liver insufficiency or one of the various other recurring health issues he has. It is likely bacterial in nature. Although Rhodes has minor scarring in some places on his body, Rhodes does not have any physical limitations or disabilities resulting from his skin condition. Rhodes skin condition is not a major health concern. Id. at ¶ 21. 26. There is no simple "cure" for Rhodes' skin condition. Rhodes will likely

have recurrences of his skin condition regardless of what types of treatment he receives. Treatments are an attempt to keep the condition in remission. Id. at ¶ 22. 27. It is the opinion of Dr. Lesac that Rhodes received appropriate medical care

for his skin condition. Id. at ¶ 23. 28. In his deposition, Rhodes stated that his skin condition goes through stages.

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He stated that "[i]t's minor now. (See Deposition of Paul Eugene Rhodes at p. 11, lines 1517, attached hereto as Exhibit 2.) 29. In his deposition, when he was asked how many times he was seen by prison

medical staff about his skin condition, he agreed that it was at least thirty times. (Rhodes Deposition at pp. 15-16, lines 23-8, attached hereto as Exhibit 3.) 30. Rhodes stated in his deposition that: "Normally, you go to a dermatologist,

and basically you get a skin condition taken care of. Sometimes you have to go for repeated visits, but basically a dermatologist can take care of a skin condition . . . it can be controlled or cured." (Rhodes Deposition at p. 29, lines 15-20, attached hereto as Exhibit 4.) 31. In his deposition, Rhodes stated that the bases for his lawsuit included not

having an adequate dermatologist consultation, taking the Interferon with an existing skin infection, not being prescribed medications that adequately controlled the skin condition, and not being provided adequate follow-up care. (Rhodes Deposition at p. 32, line 17 to p. 36, line 16, attached hereto as Exhibit 5.) Complaints and Responses Regarding Rhodes' Medical Care Allred 32. On July 1, 2003, while he was housed at ASPC-Safford/Ft. Grant, Rhodes

wrote an Inmate Letter complaining that he had been approved to see a dermatologist in October 2002 at Yuma, but had not yet been seen. He stated that he had sores all over his face, neck, chest and back and that he had "holes eaten in his body." (See Inmate Letter dated July 1, 2003, attached hereto as Exhibit 6.) 33. Terry Allred, the Facility Health Care Manager at ASPC-Safford/Ft. Grant,

responded by informing Rhodes that his medical records indicated that he had visited with prison medical providers on two occasions regarding his skin condition, and that his

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medical needs were being and would continue to be met. (See Inmate Letter Response dated July 14, 2003, attached hereto as Exhibit 7.) 34. On July 6, 2003, Rhodes wrote an Inmate Letter complaining that the

medications he was taking weren't working, and that his skin condition was getting worse and spreading. He claimed he was being denied medical treatment. (See Inmate Letter dated July 6, 2003, attached hereto as Exhibit 8.) 35. Allred responded by noting that Rhodes had been seen on July 2, July 8, and

July 14, 2003 by "mid-level providers," and that on July 15, 2003, Rhodes was seen by a physician. He noted that on these occasions, Rhodes received either prescriptions for new medications or refills of existing medications. Allred also informed Rhodes that prison health unit was aware of his treatment needs and concerns, and would attend to them appropriately. (See Inmate Letter Response dated July 17, 2003, attached hereto as Exhibit 9.) 36. On July 12, 2003, Inmate Paul Rhodes wrote an Inmate Letter requesting a

print-out of "uses and effects" for prescription information on seven drugs. (See Inmate Letter dated July 12, 2003, attached hereto as Exhibit 10.) 37. Allred responded informing Rhodes that the prison pharmacist had submitted

the prescription information. (See Inmate Letter Response dated July 28, 2003, attached hereto as Exhibit 11.) 38. On July 13, 2003, Rhodes wrote an Inmate Letter complaining about various

issues related to the medical care he had received for his skin condition. (See Inmate Letter dated July 13, 2003, attached hereto as Exhibit 12.) 39. Allred responded that the issues Rhodes complained of were currently being

investigated and that a response would be provided shortly. (See Inmate Letter Response dated August 15, 2003, attached hereto as Exhibit 13.)

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40.

On August 1, 2003, Inmate Paul Rhodes wrote an Inmate Letter requesting

drug descriptions for "prescription uses and effects" to six drugs. (See Inmate Letter dated August 1, 2003, attached hereto as Exhibit 14.) 41. Allred responded referring Rhodes to his Inmate Letter of July 12, 2003,

which was responded to on July 28, 2003, requesting the same information. (See Inmate Letter Response dated August 15, 2003, attached hereto as Exhibit 15.) 42. On August 6, 2003, Rhodes wrote an Inmate Letter complaining that his

grievance regarding substandard medical treatment concerning his ongoing skin irritation had been returned unanswered after two weeks with no explanation. (See Inmate Letter dated August 6, 2003, attached hereto as Exhibit 16.) 43. Allred responded by stating that he was unaware of the medical grievance

Rhodes was referring to, and indicated that the issue would be investigated and an appropriate response would be provided. He also recommended that Rhodes attach a copy of the grievance he was referring to. (See Inmate Letter Response dated August 15, 2003, attached hereto as Exhibit 17.) Pinkstaff 44. On October 19, 2003, Rhodes wrote an Inmate Letter complaining that he

had sores on his face, chest and back, that a dermatologist consultation that had been approved for over a year, and that the pictures taken for the consultation were not taken of the right area of his body. (See Inmate Letter dated October 19, 2003, attached hereto as Exhibit 18.) 45. On October 27, 2003, Gary Pinstaff, the Medical Services Administrator for

ADC, informed Rhodes that he had investigated his concern regarding the treatment for his skin condition, and learned that Rhodes was seen by prison health care providers on October 20, 2003 regarding his sores to his body, which appeared at that time to be

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Methicillin Resistant Staphylococcus Aureus (MRSA). Rhodes was placed on Bacterium and Rifampin antibiotics for the infection. Pinstaff instructed Rhodes to take the

medications until finished, and told him that he would be seen for a follow-up examination. (See Inmate Letter Response dated October 27, 2003, attached hereto as Exhibit 19.) 46. On October 21, 2003, Rhodes wrote an Inmate Grievance complaining that

he still had open sores from his staph infection, and that his face, neck back, chest and arms were covered with permanent scars. (See Inmate Grievance dated October 21, 2003, attached hereto as Exhibit 20.) 47. Pinkstaff responded informing Rhodes that although his medical records

contained numerous entries noting "probable methicillin resistant staph aureus (MRSA)," the dermatology telemedicine consult that he received in June 2003 indicated that Rhodes did not have a staph infection. Pinkstaff explained to Rhodes that the dermatologist had diagnosed his skin condition as prurigo nodularis, most likely secondary to chronic liver insufficiency, and had recommended an oral course of prednisone and a steroid cream, both of which Rhodes received. Pinkstaff informed Rhodes that he would direct prison health care providers to see him without charge to determine the need for another course of oral prednisone and to make sure he had the steroid cream for daily use. (See Inmate Grievance Supplement dated October 5, 2003, attached hereto as Exhibit 21.) 48. On December 13, 2003, Rhodes appealed the Pinkstaff's decision. (See

Inmate Grievance Appeal dated December 13, 2003, attached hereto as Exhibit 22.) 49. On April 28, 2004, Director Dora B. Schriro responded to Rhodes' Rhodes was informed that he was approved to be seen by a

Grievance Appeal.

dermatologist, and if the dermatologist determines it is necessary to see Rhodes in person rather than use the telemedicine system, the request will be considered. Rhodes was also

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told to contact his health services unit for any further assistance. (See GF Supplement Grievance dated April 28, 2004, attached hereto as Exhibit 23.) 50. On January 26, 2004, Rhodes wrote an Inmate Letter complaining of

substandard medical treatment for his skin condition. He stated that he was constantly itching and scratching. (See Inmate Letter dated January 26, 2004, attached hereto as Exhibit 24.) On February 4, 2004, Rhodes wrote another Inmate Letter regarding medical treatment for his skin condition, and requesting a dermatologist. (See Inmate Letter dated February 4, 2004, attached hereto as Exhibit 25.) 51. On February 11, 2004, Pinkstaff responded to Inmate Letters of January 26,

2004 and February 4, 2004 explaining again that Rhodes had a dermatologist consult in June 2003 and that since the medications he was provided pursuant to the dermatologist's recommendations did not seem to work, he would be receiving another dermatologist consultation soon. (See Inmate Letter Response dated February 11, 2004, attached hereto as Exhibit 26.) 52. On February 24, 2004, Rhodes wrote another Inmate Letter to Pinkstaff

regarding his skin infection. (See Inmate Letter dated February 24, 2004, attached hereto as Exhibit 27.) 53. Pinkstaff researched Rhodes' issues and again informed Rhodes that he had

been seen by a dermatologist on June 12, 2003, that although the medical department had given him all the medications recommended by the dermatologist, they did not work, and that he was scheduled to see the dermatologist again in the near future. (See Inmate Letter Response dated March 12, 2004, attached hereto as Exhibit 28.) 54. On April 18, 2004, Rhodes wrote Inmate Letters to Pinkstaff and Dr. Lesac,

complaining about never having seen a dermatologist for his condition. He complained that some of the medications he was prescribed aggravated his condition, and noted that

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there were several different types of sores on his body. He complained that his sinus cavity and throat were filled with sores and bleeding, and that he constantly scratched which caused scars and spread infection. (See Inmate Letters dated April 18, 2004, attached hereto as Exhibit 29.) 55. Pinkstaff researched Rhodes' issues and informed Rhodes of the process in

which he would be seen by the dermatologist. He also noted that on May 5, 2004 he was seen by Dr. Lesac, who explained his treatment plan to him. (See Inmate Letter Response dated May 10, 2004, attached hereto as Exhibit 30.) 56. On July 28, 2004, Rhodes wrote an Inmate Letter to Pinkstaff regarding a

rash which he thought might be scabies. (See Inmate Letter dated July 28, 2004, attached hereto as Exhibit 31.) 57. Pinkstaff directed a heath care provider to investigate and informed Rhodes

that a biopsy of Rhodes' rash has been done to determine the cause or give a diagnosis. (See Offender Letter Response dated August 27, 2004, attached hereto as Exhibit 32.) Greeley 58. On November 14, 2004, Rhodes wrote an Inmate Letter complaining about

having MRSA and another type of infection and about not wanting to take drugs long term that cause liver damages since he has Hepatitis-C. He also requested a dermatologist consultation, explaining that his constitutional rights has been violated by not having seen a dermatologist for over two years with sores all over his body. (See Inmate Letter dated Novebmer 14, 2004, attached hereto as Exhibit 33.) 59. Admin. Service Officer II Sherry L. Goldsmith (on behalf of Gene Greeley,

the Facility Health Care Manager at ASPC-Florence) researched and directed a health care provider to review Rhodes' medical records and on December 6, 2004, provided the following response: she explained that prison health care providers are trained to diagnose

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and treat many skin problems; therefore referrals to a dermatologist occur only if a problem seems beyond their scope of practice. She further explained that Rhodes was referred to dermatology twice. Although he did not personally see the dermatologist on either visit, images were taken of his body and Dr. Levine, a dermatologist, reviewed the images, including his history and rendered his opinion and suggested treatments. She told Rhodes that a skin biopsy was obtained on August 3, 2004, as recommended by the dermatologist. A nonspecific skin abscess was noted, and no treatment changes were suggested. She noted that part of Rhodes' problem was his constant scratching and picking at his skin, which helped get the infections started. She stated that Rhodes' case has been evaluated several times by specialists and is being appropriately treated. She informed him that skin problems can only be controlled, not treated. (See Offender Letter Response dated December 6, 2004, attached hereto as Exhibit 34.) 60. On December 13, 2004, Rhodes wrote an Inmate Letter complaining about

his skin infection, the inadequate medical care he had received for his infection, and requesting to be isolated from other inmates. (See Inmate Letter dated December 13, 2004, attached hereto as Exhibit 35.) 61. Admin. Service Officer II Sherry L. Goldsmith (on behalf of Greeley),

researched and directed a health care provider to review his medical records and on January 13, 2005, provided the following response: she explained that bacterial infections do not require the patient to be isolated from all outside contact. She noted that Rhodes was last seen on December 6, 2004, and had no active skin infections after finishing a month of oral antibiotics. He had a mild skin rash for which treatment was given. Rhodes was instructed not to scratch the rash, which often is how infection is introduced into the skin, and to always wash his hands frequently, as germs are always in any environment. (See Offender Letter Response dated January 13, 2005, attached hereto as Exhibit 36.)

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Shiflet 62. On July 6, 2003, Inmate Paul Rhodes wrote an Inmate Letter to Assistant

Deputy Warden at ASPC-Safford/Ft. Grant Bruce Shiflet regarding the denial of medical treatment by prison staff for his skin condition. Among other things, Rhodes complained about sores on his body that are open and inflamed, and about being transferred to a different prison unit when he should have been on a medical hold. (See Inmate Letter dated July 6, 2003, attached hereto as Exhibit 37.) 63. On July 16, 2003, Shiflet responded explaining that Rhodes' medical needs He recommended that Rhodes submit a

have been and are currently being addressed

health needs request for any on-going medical needs he may have. (See Inmate Letter Response dated July 16, 2003, attached hereto as Exhibit 38.) Rivas 64. On December 14, 2003, Rhodes wrote an Inmate Letter to Assistant Deputy

Warden Rivas regarding his skin condition. He said that he had had a seizure from the medication he had been prescribed, and complained about the grievances he submitted and that were responded to by Mr. Pinkstaff. He also complained about being given 25 different prescriptions, some with adverse side effects, none of them fixing his skin condition. He requested a dermatology consultation, noting that the one he had already received was inadequate. (See Inmate Letter dated December 14, 2003, attached hereto as Exhibit 39.) 65. On December 15, 2003, Rivas informed Rhodes that he did not have the

authority to address medical issues. However, he explained that Rhodes has the right to appeal Pinkstaff's responses to his grievances to the Director. (See Inmate Letter Response dated December 15, 2003, attached hereto as Exhibit 40.)

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Pratt 66. On February 29, 2004, Inmate Paul Rhodes wrote an Inmate Letter regarding

the lack of response to his grievance appeals. (See Inmate Letter dated February 29, 2004, attached hereto as Exhibit 41.) 67. On March 17, 2004, Medical Services Administrator Richard L. Pratt

informed Rhodes that the grievance appeal responses had been sent to the Director's Office for review and approval, and once they had been signed and returned to health services, they would be forwarded to Rhodes. (See Inmate Letter Response dated March 17, 2004, attached hereto as Exhibit 42.) 68. On April 18, 2004, Rhodes wrote an Inmate Letter complaining about Mr.

Pinkstaff and about the medical care he had received for his skin condition. He requested a dermatologist consultation. (See Inmate Letter dated April 18, 2004, attached hereto as Exhibit 43.) 69. On June 8, 2004, Medical Investigator Sherry Mullen responded to Inmate She informed Rhodes that he had already been seen by a

Letter on Pratt's behalf.

dermatologist twice, in June 2003 and April 2004, and had been given medications in accordance with the dermatologist's recommendations. Rhodes was informed at that time that if no visible improvement was made in three months, Dr. Levine recommended a new photo be sent to him for his review. (See Inmate Letter Response dated June 8, 2004, attached hereto as Exhibit 44.)

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RESPECTFULLY SUBMITTED this __3___ day of February, 2006. TERRY GODDARD ATTORNEY GENERAL

s/Anne Stratman ANNE STRATMAN Assistant Attorney General Attorneys for Defendants

COPY of the foregoing mailed this 3 day of February, 2006 to: Paul Eugene Rhodes, #163870 ASPC-Florence-Central Post Office Box 8200 Florence AZ 85232 s/CBailey Secretary, Attorney General's Office
IDS05-0164 / RSK: G05-20360

945707

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