Free Statement - District Court of Arizona - Arizona

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ANDREW P. THOMAS MARICOPA COUNTY ATTORNEY By: MARIA R. BRANDON State Bar No. 004249 Deputy County Attorney MCAO Firm No. 00032000

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CIVIL DIVISION Security Center Building 222 North Central Avenue, Suite 1100 Phoenix, Arizona 85004-2206 Telephone (602) 506-8541 Attorneys for Defendants Maricopa County, IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA James John Hadges, NO. CIV 04-0259-PHX-EHC Plaintiff, STATEMENT OF FACTS IN SUPPORT OF DEFENDANTS' MOTION TO FOR SUMMARY JUDGMENT

Maricopa County, a political subdivision of the State of Arizona; Sheriff Joseph Arpaio, as elected representative and as acting director of Maricopa County Sheriff's Office; Maricopa Medical Center, an administrative agency of Maricopa County; Correctional Health Services, an administrative agency of Maricopa County; Does 1-10 inclusive; Roe Corporations 1-10 inclusive, Defendants.

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Inmate medical care is provided by Maricopa County acting through

employees of Correctional Health Services (CHS), a subdivision of Maricopa Case 2:04-cv-00259-EHC-DKD Document 34 1 Filed 01/30/2007 Page 1 of 3

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County. CHS provides medically necessary health care to persons incarcerated in the Medical County Jails. In Maricopa County, the Sheriff's Office is a

separate constitutional office charged with operating the jails, but the Sheriff's Office does not supervise CHS employees who provide inmate medical care, nor is the Sheriff's Office responsible for providing medical care to inmates. (Exhibit A, Affidavit of Todd Wilcox, M.D.) 2. Todd Wilcox, M.D., reviewed the CHS medical records for James

John Hadges (DOB: 8/2/61 MCSO Booking # A851943.)The medical records indicate that James John Hadges was provided appropriate medical care in a timely fashion that the standard of care for medical treatment and practice. (Exhibit A, Affidavit of Todd Wilcox, M.D.) RESPECTFULLY SUBMITTED this 30th day of January 2007.

ANDREW P. THOMAS MARICOPA COUNTY ATTORNEY

BY:

s/Maria R. Brandon MARIA R. BRANDON Deputy County Attorney Attorneys for Defendants Maricopa County and Sheriff Joseph Arpaio

ORIGINAL of the foregoing E-FILED and copies MAILED this 30th day of January 2007 to: Honorable Earl H. Carroll United States District Court Judge Sandra Day O'Connor U.S. Courthouse 401 West Washington Street, SPC 48 Phoenix, Arizona 85003
Document 34 2 Filed 01/30/2007 Page 2 of 3

Case 2:04-cv-00259-EHC-DKD

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and copy mailed to: Philip A. Seplow Law Offices of Philip A. Seplow 2000 North 7th Street Phoenix, Arizona 85006 Attorney for Plaintiff

s/Lea Wink 6
CJ 03-040

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S:\COUNSEL\civil\Matters\CJ\2003\Hadges CJ03-040\Pleadings\MTD.doc

Case 2:04-cv-00259-EHC-DKD

Document 34 3 Filed 01/30/2007

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