Free Response to Motion - District Court of Arizona - Arizona

1 Arizona Department of Corrections` treatment of I-Iampton’s condition has been
s deliberately indifferent.
3 3. In addition, Hampton had undergone esophageal duodenoseopy {EGD),
4 a procedure which identified a condition called Barretlfs esophagitis, known in
5 common language as peptic ulcer disease. I note from the record that subsequent to
6 this diagnosis he was then medicated with Ibuprofen which is non steroidal anti-
7 inflammatory medication. Typically, this class of medications is contraindicated in
3 patients with Barretfs esophagitis after EGD as they can lead to ulceration and in
9 worse case scenario bleeding which may be eflife threatening nature.
10 9. The continual and ongoing refusal to treat this potentially life-
threatening condition demonstrates deliberate indifference by I-Iampton’s medical
H providers.
12 l0. To summarize therefore Hampton appeared to receive community
H standard of care for this medical conditions with the exception of those issues outlined
M above.
I5 l declare under the penalty of perjury the foregoing is true and correct.
Iii DATED THIS ifiday of Dctobcr, 2006.
" J./sa.
W SUBSCRIBE!} AND SWDRINI TD before me by James F. Doris, lvI.D. this
20 _ day of Dctober, 20045.
2I S gr § l E I §___
22
23 My Commission expires: gl _ S _; · '
24 ‘ T · ``‘' "
ss Q g` O ’'’‘ .
is
.3-
Case 2:03-cv—01706—NVW Document 66-6 Filed 10/18/2006 Page1 0f1

Case 2:03-cv-01706-NVW

Document 66-6

Filed 10/18/2006

Page 1 of 1