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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

INMATES OF THREE LORTON FACILITIES, including
INMATES OF THE MEDIUM SECURITY FACILITY JANE DOE I JOHN DOE I Medium Security Facility D.C. Department of Corrections Post Office Box 99 Lorton, VA 22199,
INMATES OF THE MINIMUM SECURITY FACILITY JANE DOE II JOHN DOE II Minimum Security Facility D.C. Department of Corrections Post Office Box 5000 Lorton, VA 22199,
INMATES OF THE YOUTH CENTER JOHN DOE III Youth Center D.C. Department of Corrections Post Office Box 98 Lorton, VA 22199
Individually and on behalf of all other persons similarly situated,
Plaintiffs,
v.
DISTRICT OF COLUMBIA,
SHARON PRATT KELLY, Mayor, The District Building 13 50 Pennsylvania Avenue, N.W. Washington, D.C. 20004
WALTER B. RIDLEY, Director, Department of Corrections 1923 Vermont Avenue, N.W. Suite N-203 Washington, D.C. 20001
Inmates of Three Lorton Facilities v. D.C.

Civil Action No.

3C-DC-005-001

WILLIAM HALL, M.D.

)

Assistant Director for Health

)

Services

)

P.O. Box 25

)

Lorton, Virginia 22079

)

)

GWEN H. WASHINGTON

)

Associate Director for Programs

)

P.O. Box 25

)

Lorton, Virginia 22079

)

)

THOMAS P. GAYDOS, Administrator,

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Medium Security Facility

)

Post Office Box 99

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Lorton, VA 22199

)

)

PAUL KRULL, Administrator,

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Minimum Security Facility

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Post Office Box 5000

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Lorton, VA 22199

)

)

ANGELA BROWN, Acting Administrator, )

Youth Center

)

Post Office Box 98

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Lorton, VA 22199

)

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D.C. GENERAL HOSPITAL

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COMMISSION, an independent agency

)

of the District of Columbia,

)

19th & Massachusetts Ave., S.E.

)

Washington, D.C. 20003

)

)

MARK J. CHASTING,

)

Executive Director,

)

District of Columbia General Hospital )

19th & Massachusetts Ave., S.E.

)

Washington, D.C. 20003

)

)

Defendants.

)

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

I. NATURE OF THE COMPLAINT 1. This is a class action brought by inmates at three facilities of the District of Columbia Department of

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Corrections located at Lorton, Virginia: the Medium Security Facility, the Minimum Security Facility and the Youth Center (collectively, the "Three Lorton Facilities'1) . Defendants, the District of Columbia, the District of Columbia Hospital Commission and named officials with responsibility for the District's prisons and its medical care system, have repeatedly displayed and continue to display a deliberate indifference to the serious medical needs of the plaintiffs. Specifically, defendants provide grossly inadequate medical care and often fail to provide any medical care at all. Defendants' actions and inactions cause the plaintiffs pain and suffering that is significant and avoidable. Defendants' actions and inactions violate plaintiffs' rights under the United States Constitution and the laws of the District of Columbia.
II. JURISDICTION 2. This is a civil action for declaratory and injunctive relief, arising under the Eighth Amendment to the United States Constitution and 42 U.S.C. S 1983. Pendant claims are based on District of Columbia Code §§ 24-106, 24302, 24-442, 24-802, 24-902 and regulations promulgated thereunder. 3. This Court has jurisdiction under 28 U.S.C. §§ 1331, 1343(3), and 1361. Declaratory relief is sought pursuant to 28 U.S.C. §§ 2201 and 2202.
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III. VENUB • 4. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b), (c) and (e).
IV. CLASS ACTION 5. This action is brought, pursuant to Rules 23(a), 23(b)(l) and 23(b)(2) of the Federal Rules of Civil Procedure, by the named plaintiffs on behalf of the class of all inmates who are now or who will later be incarcerated in the Three Lorton Facilities. 6. Members of the class on behalf of whom plaintiffs sue are so numerous that joinder of all members is impracticable. The class members currently incarcerated in the Medium Security Facility number over 800. The class members currently incarcerated in the Minimum Security Facility number over 950. The class members currently incarcerated in the Youth Center number over 550. 7. There are common questions of law and fact affecting the rights of inmates to receive adequate medical care. Common legal issues include the standards of medical care required by the United States Constitution and the D.C. Code. Common issues of fact include defendants' deliberate indifference to the serious medical needs of plaintiffs. Such deliberate indifference includes defendants' uniform failure to provide adequate infirmaries, medical staff, equipment, supplies and medication. Defendants' consistent refusal to
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provide proper treatment and their denial of access by plaintiffs to medical care are also common factual issues that go to the question of defendants' deliberate indifference to plaintiffs' serious medical needs.
8. Plaintiffs' claims are typical of the claims of the class, and plaintiffs fairly and adequately represent and protect the interests of the class.
9. Separate actions maintained by individual members of the class would create a risk of varying adjudications with respect to individual members of the class. Inconsistent adjudications would establish incompatible standards of conduct for the parties opposing the class, and adjudication regarding individual class members would, as a practical matter, be dispositive of, or impair the interests of, other class members not parties to the adjudication.
10. Defendants have acted and/or refused to act on grounds generally applicable to the class that plaintiffs represent, thereby making appropriate final injunctive and/or corresponding declaratory relief with respect to the class as a whole.
11. Accordingly, plaintiffs bring this action for injunctive and declaratory relief on behalf of themselves and other individuals similarly situated.
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V. PARTIES A. Plaintiffs^ 12. Jane Doe I is a female prisoner of the District of Columbia Department of Corrections presently confined in the Medium Security Facility. Jane Doe I, who is HIV positive, suffers from repeated swelling in her neck caused by a broken needle which is lodged inside. At a recent appointment at District of Columbia General Hospital, she was told by a doctor that nothing could be done for this condition. 13. John Doe I is a male prisoner of the District of Columbia Department of Corrections presently confined in the Medium Security Facility. John Doe I, who is HIV positive, suffers from a constantly painful shingles condition that extends from his right buttock to his groin and from other problems, including blood in his urine. These conditions developed after medical personnel discontinued his AZT treatment. In lieu of medical treatment, John Doe I signs up for sick call repeatedly, receives a day or two's supply of Motrin, and takes the pills simultaneously. 14. Jane Doe II is a female prisoner of the District jf Columbia Department of Corrections presently confined in

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The plaintiffs seek to maintain their confidentiality and

have filed this lawsuit under pseudonyms. The plaintiffs' names

have been submitted to the Court along with a motion requesting

that their names be maintained under seal. A list of their names

will be served on Richard Love, Esquire, Chief of the

Correctional Litigation Unit, Office of the District of Columbia

Corporation Counsel along with a copy of this complaint.

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(••/•-•
Women's Annex at the Minimum Security Facility. Jane Doe II is HIV-positive and suffers the concomitant illnesses associated with her poor health status, she also experiences regular breaches of confidentiality regarding her HIV condition and cannot obtain the special diet prescribed for her.
15. John Doe II is a male prisoner of the District of Columbia Department of Corrections presently confined in the Minimum Security Facility. John Doe II suffers from constant headaches and swelling of his extremities. Despite his condition, he has not been able to obtain an appointment with a neurologist. In addition, he has been told by medical personnel that he does not have a medical problem, and he has been berated for seeking medical attention.
16. John Doe III is a male prisoner of the District of Columbia Department of Corrections presently confined in the Youth Facility. John Doe III is HIV-positive and experiences regular breaches of confidentiality with respect to his HIV status. He suffers from a variety of health problems, including a kidney problem that causes him to pass blood in his urine and for which he has received inadequate treatment.
17. Each plaintiff currently suffers from serious medical problems despite repeated efforts to obtain treatment from the medical staff at the Three Lorton Facilities.
18. Each plaintiff currently suffers from systemic failures in the medical care system at the Three Lorton Facilities, including, as more fully described below, problems
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associated with the medical facilities, the medical staff, the training and qualifications of medical personnel, access to medical care and the quality of medical care.
B. Defendants 19. Defendant District of Columbia is a municipal corporation that maintains the Department of Corrections as an agency of government. The Department of Corrections is responsible for the safekeeping, care and protection of all D.C. prisoners. 20. Defendant Sharon Pratt Kelly is the Mayor of the District of Columbia and is responsible for the direction and control of the District of Columbia Department of Corrections. 21. Defendant Walter B. Ridley is the Director of the District of Columbia Department of Corrections. He is responsible for the operation of the District of Columbia Department of Corrections and each institution under its control, including the Three Lorton Facilities. 22. Defendant William Hall, M.D. is the Department of Corrections' Assistant Director for Health Services. Defendant Hall is responsible for the management and supervision of the Department of Correction's health care delivery system. 23. Defendant Gwen H. Washington is the Associate Director of Programs. Defendant Washington is responsible for the management and supervision of the system for the delivery of mental health care.
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24. Defendant Thomas P. Gaydos is the Administrator of the Medium Security Facility and is responsible for its operation.
25. Defendant Paul Krull is the Administrator of the Minimum Security Facility and is responsible for its operation.
26. Defendant Angela Brown is the Acting Administrator of the Youth Center and is responsible for its operation.
27. Defendant D.C. General Hospital Commission is responsible for the direction and control of the District of Columbia General Hospital (MD.C. General Hospital"). By written agreement, the D.C. General Hospital is responsible for providing inmates incarcerated in Department of Corrections facilities with certain categories of medical care, including, but not limited to, emergency treatment, treatment by medical specialists and inpatient hospital care.
28. Defendant Mark J. Chasting is the Executive Director of D.C. General Hospital and is responsible for its operation.
29. Defendants Sharon Pratt Kelly, Walter B. Ridley, William Hall, Gwen H. Washington, Thomas P. Gaydos, Paul Krull, Angela Brown and Mark J. Chasting are sued solely in their official capacity. In all of their actions complained of herein, defendants are acting and have acted under color of state law for purposes of 42 U.S.C. S 1983.
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VI. THE PRISONER POPULATION AT THE THREE LORTON FACILITIES 30. The Medium Security Facility houses approximately
850 male prisoners. It also houses approximately 20 female prisoners who are participating in the Pilot Substance Abuse Treatment Program.
31. The Minimum Security Facility is divided into two sections: the main facility for men and the Annex for women. Approximately 850 men are incarcerated in the main facility and approximately 175 women are incarcerated in the Annex.
32. The Youth Center consists of two separate sections. One section houses approximately 450 male inmates sentenced pursuant to the Youth Rehabilitation Act, D.C. Code § 24-801 et seq. The other section houses approximately 130 misdemeanants.
33. A significant percentage of prisoners incarcerated at the Three Lorton Facilities suffer from serious chronic health problems requiring ongoing medical care. The most common problems include: infection with the Human Immunodeficiency Virus ("HIV"), known to cause Acquired Immune Deficiency Syndrome ("AIDS"), as well as tuberculosis, diabetes, hypertension and seizure disorder.
34. Prisoners at the Three Lorton Facilities frequently experience acute health crises requiring immediate emergency medical treatment. These problems include traumatic injury, heart attack and asthma.
35. Many of the prisoners at the Three Lorton Facilities require occasional medical treatment for other
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health problems including the treatment of influenza and other communicable illnesses. Prisoners often go for days or weeks without receiving any medical attention whatsoever for these conditions.
36. Many prisoners at the Three Lorton Facilities suffer from eye infections, eye injuries or impaired vision. Prisoners often receive no care for these problems for weeks or months.
37. Many of the prisoners confined to the Three Lorton Facilities suffer from serious and painful dental problems. These problems include decaying or broken teeth, gum disease and infections of the mouth. A number of prisoners in these facilities are missing so many teeth that they cannot properly chew their food without dentures, yet dentures, or, alternatively, special meals, are not properly provided to them.
38. A significant number of the prisoners at the Three Lorton Facilities suffer from serious mental illness requiring treatment. These problems include schizophrenia, depression, and disorders related to long-term drug use. Many prisoners suffering from these illnesses go undiagnosed or receive inadequate medical or psychiatric attention.
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VII. THE PRISON INFIRMARIES 39. Each of the Three Lorton Facilities purports to have an infirmary to meet the medical needs of its inmates. These "infirmaries" are grossly inadequate and display the defendants' deliberate indifference to the serious medical needs of the plaintiffs. These "infirmaries" are also designed and used in ways that breach the confidentiality of inmates.
A. The Medium flAcuritv Facility 40. The "infirmary" at the Medium Security Facility is too small, is poorly designed for its function and is poorly maintained. Among the problems at the facility are:
a) The "infirmary" at the Medium Security Facility provides medical services from a trailer at the rear of the facility. The trailer is plagued with maintenance problems, including inadequate heat, water leaks, and sporadic interruptions in electricity.
b) The Medium Security Facility "infirmary" trailer has insufficient examination space. Inmates must therefore frequently discuss their medical problems with medical personnel in the waiting room while other inmates are present. Furthermore, the examination rooms are separated only by movable partitions or by curtains so that inmates' medical consultations and examinations
are easily audible to other inmates.
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c) At the Medium Security Facility "infirmary," inmate medical records are frequently maintained by other inmates. This practice deprives inmates of confidentiality with regard to their medical conditions. The records are stored in the waiting room. This also results in breaches of confidentiality because the records are accessible to any inmates who enter the medical trailer.
B. The Minimum Security Facility 41. There are two infirmaries at the Minimum Security Facility: one in the main facility for men and one in the Annex for women. Neither is properly designed, equipped or maintained for its function. The problems at these facilities include:
a) The infirmary in the main facility for men consists of four small rooms: two examination rooms, an office and a pharmacy. There is no sink in one of the examination rooms. Consequently, medical practitioners frequently do not wash their hands between examinations.
b) One of the two examination rooms at the main facility for men also serves as a file storage area. This arrangement prevents the maintenance of confidentiality of the medical records and requires medical staff to travel through that examination room to
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retrieve and replace records, often while examinations are in progress.
c) The "infirmary" in the Annex for women at the Minimum Security Facility has insufficient space. Female inmates often receive pelvic examinations while other prisoners or correctional staff are in the room. The rooms do not contain sinks. This makes it virtually impossible for medical personnel to wash their hands between examinations of patients.
C. The Youth Center 42. The medical facilities at the Youth Center consist of three examination rooms, a doctor's office, a records room, and a dental office. Problems at this facility include:
a) The dental office is improperly designed, so proper infection control cannot be maintained. The dentist must close the dental office for the rest of the day to be cleaned each time an HIV-infected patient is treated.
b) There is no separate waiting area for misdemeanants and Youth Act prisoners. This restricts access to the infirmary for adult misdemeanants who, by law, must be separated from the Youth Act inmates.
c) One of the examination rooms contains two examining tables, which are frequently used simultaneously. There are no dividers or curtains
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between the two tables so inmates can both see and hear the examinations and consultations of other inmates.
d) None of the examination rooms at the Youth Center infirmary contain sinks, so medical personnel frequently do not wash their hands between examinations of different inmates.
e) Inmates perform medical record filing duties at the Youth Center and, in doing so, frequently breach the confidentiality of other inmates' medical records.
f) Confidentiality is further breached as a result of the practice of leaving the files for all inmates with appointments on a given day unattended and easily accessible in the infirmary waiting area.
VIII. THE LACK OF ADEQUATE MEDICAL STAFF AND 8UPPLIES 43. The staffing levels for medical personnel at the
Three Lorton Facilities are grossly inadequate to provide proper, basic health care for the inmates and to address the inmates' dental, ophthalmologic and psychiatric problems. Moreover, the limited care that is available is frequently dispensed by persons who are unqualified to provide the care, are not licensed as medical practitioners and are inadequately supervised. The medical staff's capabilities are further restricted by a chronic shortage of essential medical supplies.
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A. Size of Medical staff 44. The medical staffs at the Three Lorton Facilities are too small to provide adequate medical care for the inmates at each facility. 45. The Medium Security Facility infirmary is staffed by one physician and two physician assistants who are unable to serve adequately the medical needs of the over 800 inmates incarcerated there. 46. The Minimum Security Facility men's infirmary is staffed with one full-time and one half-time physician, two physician assistants and a pharmacist. The infirmary in the women's Annex at the Minimum Security Facility is staffed by one physician and two physician assistants. This skeletal staff is unable to serve adequately the medical needs of the over 950 inmates in the Minimum Security Facility. 47. The Youth Center infirmary is staffed by three physicians and two physician assistants. This staff is unable to provide adequate medical care to the more than 550 inmates incarcerated in the Youth Center. 48. No medical records clerk is assigned to the Mediur. Security Facility. With assistance from inmates working as records clerks, a clerk working on an overtime basis from another facility performs the function of part-time records clerk. As a result, confidentiality of medical records is
frequently breached and records are regularly lost.

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49. There is no ophthalmological care provided on location at any of the Three Lorton Facilities.
50. There is no psychiatric or psychological care for misdemeanants at the Youth Center. There are two "psychologists" at the Medium Security Facility, and one "psychologist" at the Minimum Security Facility. Neither of the "psychologists" at the Medium Security Facility is trained or licensed to practice psychology. These individuals, even if they were properly trained and licensed, which they are not, are too few in number to provide adequate psychological/psychiatric care for inmates at the Three Lorton Facilities.
51. In addition to the small medical staff at the Three Lorton Facilities, the medical personnel at the Three Lorton Facilities are often changed or rotated, thereby depriving inmates of continuity of care — even for relatively brief illnesses.
B. Competency, Qualifications and Training of Medical Staff 52. Many unqualified and unlicensed personnel serve, on
the medical staffs at the Three Lorton Facilities. 53. Members of the medical staff at the Three Lorton
Facilities are insufficiently trained or supervised. Many staff have limited formal training for their position. Moreover, there is little or no continuing medical education available to medical staff.
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54. Most, if not all, of the physician assistants working at the Three Lorton Facilities are unlicensed and, as such, are not properly qualified to administer many of the clinical services they currently attempt to provide. They receive little supervision in their work from qualified and licensed medical staff.
55. Psychiatric care is often administered by unqualified practitioners. The person occupying the "chief psychologist" position at the Medium Security Facility holds only a Bachelor's degree in psychology.
C. Supplies, Equipment and Medication 56. There frequently are inadequate supplies of even the most basic commodities in the "infirmaries" and clinics responsible for treating inmates at the Three Lorton Facilities. The "infirmaries" are often out of stock of the sanitary paper used to cover examination room tables, the bulbs used in ophthalmoscopes and other basic supplies. Replacement supplies often do not arrive for months. 57. The Three Lorton Facilities also lack basic emergency equipment such as oxygen tanks and cardiac defibrillators. 58. The pharmacies at the Three Lorton Facilities are frequently out of stock of medications or have medications which have expired. Some inmates are made to wait weeks to receive, or are denied altogether, medication necessary for the
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treatment of orthopedic injuries, hypertension, infection and HIV. Members of the medical staff occasionally fill one prisoner's prescription by removing pills from another prisoner's sealed prescription packet.
59. The chronic lack of adequate supplies adversely affects the health care available to the prisoners at the Three Lorton Facilities. Occasionally, prisoners are refused dental care due to a lack of surgical gloves, even though inmates have often waited several months for an appointment.
IX. THE LACK OF ADEQUATE ACCE88 TO MEDICAL CARE 60. The prisoners at the Three Lorton Facilities regularly experience significant delays in gaining access to medical care to address their serious medical needs. Inmates often must wait for days or weeks to meet with a medical staff person about their ailments. Access to medical staff is often determined without regard to the degree of seriousness of the different inmates' conditions. Moreover, the medical staff who are accessible often lack basic qualifications, training and licensing. Access to medical personnel who provide dental and ophthalmological care is even more limited, often leading to waits of weeks or months for prisoners at the Three Lorton Facilities. In addition, access to specialty clinics at the District of Columbia General Hospital is severely limited, resulting in months-long waits by inmates in need of care from a specialist. The inaccessibility of health care provided by
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the defendants constitutes deliberate indifference to serious medical needs of plaintiffs.
A. Hours of Operation of the Infirmaries 61. The infirmary at the Medium Security Facility is open from 7:30 a.m. to 4:00 p.m., Monday through Friday. Outside of these times, inmates requiring immediate medical attention must be transported to the Occoquan Facility or the Central Facility for treatment. 62. Both the men's and women's infirmaries at the Minimum Security Facility are open from 8:00 a.m. to 4:00 p.m., Monday through Friday only. During evenings and weekends, inmates must be transported to the Central Facility infirmary for medical treatment. 63. The Youth Center infirmary is open from 7:30 a.m. to 4:00 p.m., Monday through Friday only. Inmates in need of health care outside of these times must be transported to the Occoquan Facility or Central Facility infirmaries for treatment. 64. The facilities at Occoquan and Central where prisoners at the Three Lorton Facilities are sent during offhours have been held to be constitutionally inadequate. Moreover, inadequate transportation and security concerns frequently cause lengthy delays and outright denials of care during the off-hours at the infirmaries at the Three Lorton Facilities.
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B. Access to Medical Care at the Infirmaries 65. Access to the infirmaries at the Three Lorton Facilities during their hours of operation is severely limited. 66. At the Medium Security Facility, those inmates desiring access to sick call must sign up at midnight the night before they want to be seen. During the early morning, inmates are called for sick call by dormitory; there is no triage procedure to ensure that those with the most serious problems are seen first. After the time allotted for sick call has ended, any prisoners in dormitories that have not yet been called are simply not seen, regardless of the seriousness of their ailments. Inmates from those dormitories not seen receive no priority for the next day's sick call. 67. At the Minimum Security Facility, only twenty people are seen at each sick call. The infirmary operates on a first-come, first-served basis, without any priority based on the severity of prisoners' health problems. After it is announced that the morning count has been completed in the dormitories at Minimum, inmates literally race to the infirmary building in an effort to be among the twenty people permitted to see a medical staff person. Under this "system," the inmates who live in dormitories closest to the infirmary and those inmates who are best able to run have the greatest likelihood of being seen by medical personnel on any particular day. This arrangement works to the obvious disadvantage of the inmates who are in the most need of care. After the medical
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0?
staff at the Minimum Security has seen the allotted twenty patients, they often refuse to see any more inmates, regardless of how long it took to see the first twenty and how many serious conditions go untreated. Those inmates not in the first group of twenty have no alternative but to wait until the next race to sick call.
68. At the Youth Center, access to medical care for misdemeanants is a particularly acute problem. Because, by law, adult misdemeanants cannot be mingled with persons sentenced pursuant to the Youth Rehabilitation Act, misdemeanants can attend sick call only if escorted by a correctional officer. Frequently too few officers are on duty to perform this function and misdemeanants are denied access to medical care.
69. Inmates located in "lockdown," a high security confinement area, frequently have even greater difficulty obtaining access to medical care. In many instances, the medical staff ignores the medical condition of inmates in "lockdown"1 for several days.
C. Access to Dental. Ophthalmoloqical, and Psychiatric Care 70. Inmates at the Three Lorton Facilities must
frequently wait for many months to receive dental, ophthalmological, or psychiatric care, which is often administered by unqualified practitioners.
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/;,
71. There are no dentists at the Medium or Minimum Security Facilities. Inmates must be transported to either the Central or Occoquan Facilities in the evening hours to receive dental care. It often takes prisoners months to obtain an appointment for such a transfer.
72. The one dentist employed at the Youth Center cannot meet the dental care needs of over 550 inmates incarcerated there.
73. Inmates typically must wait many months to receive dental care, even in cases where emergency treatment is warranted.
74. Because the dentists rotate throughout the various Lorton facilities, follow-up treatment by the same dentist often does not occur.
75. Many inmates find it particularly difficult to obtain dentures, often waiting many months or even years. This problem is compounded by the unavailability of soft food diets for those inmates in need of dentures. As a result, inmates without teeth or appropriate dentures are forced to chop food into tiny pieces and swallow them whole.
76. Due to the absence of any ophthalmological care at the Three Lorton Facilities, prisoners often wait months to
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obtain even the most rudimentary eye care, such as obtaining glasses.
D. Access to Specialty and Emergency care at D.C. General Hospital
77. Inmates experience long delays before being seen by specialists at the D.C. General Hospital because it takes so long to secure an appointment. These delays occur where prompt — or even emergency — treatment is warranted.
78. Even after inmates have an appointment at D.C. General Hospital, staffs at the Three Lorton Facilities often fail to insure that inmates are transported to the hospital on the date of their appointment, thereby requiring the inmate to secure a new appointment and suffer yet another delay — often of many weeks or months — before receiving any treatment.
X. THE LACK OF ADEQUATE MEDICAL CARE 79. Prisoners at the Three Lorton Facilities who obtain access to treatment for their health problems often are subjected to grossly inadequate medical care. Prisoners often receive "treatment" that fails to correct or alleviate serious medical problems; in many cases, the "treatment" administered actually exacerbates the ailments. Grossly inadequate medical care is administered to the prisoners of the Three Lorton Facilities at the infirmaries, at the dental, ophthalmological and psychiatric units, and at D.C. General Hospital.
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A. Sic* Call 80. Prisoners able to obtain a sick call appointment at the infirmaries at the Three Lorton Facilities often do not receive any treatment for serious medical conditions. Frequently, prisoners suffering from serious maladies are sent away without receiving any therapy or medicine and without any arrangements having been made for a follow-up examination. Prisoners often are "diagnosed" as being healthy without any physical examination, testing or review of medical history. Medical personnel often refuse to conduct probing medical inquiries. 81. John Doe II, a prisoner at the Minimum Facility, has been experiencing continued dizziness, swelling and severe headaches for two months and still has not been seen by a neurologist. On one of John Doe II's recent trips to the infirmary in connection with his continuing symptoms, the doctor with whom he spoke told him that he "looked fine" to her and she did not see why he needed to see a neurologist. 82. John Doe III, an inmate at the Youth Center, went to the infirmary complaining of chest pains and difficulty breathing. He received only Motrin from the health care worker who saw him. Within four days, his illness, later diagnosed as pneumonia, had progressed to the point that he was unable to get out of bed. Because of the inadequate treatment John Doe III received at the Youth Center infirmary, his illness became
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so severe that he was kept at D.C. General Hospital for five weeks before being released.
83. John Doe III also suffers from acute lower back pain and intermittently has blood in his urine. Staff members at the infirmary have taken a blood sample from him, but have never diagnosed or treated his condition. When he gave a urine sample that was free of blood, he was informed that there was probably nothing wrong.
84. Prisoners with a wide variety of serious medical conditions are given the identical, grossly inadequate treatment: a day or two's supply of Motrin. The medical staff at the Three Lorton Facilities dispenses Motrin to prisoners without conducting the medical examinations necessary to determine whether other medical treatment may be required. John Doe I, a prisoner at the Medium Facility, presently suffers from a severe and extremely painful case of shingles that extends from his right buttock around to his groin. He signs up for sick call every day, obtains a day's supply of Motrir and takes the entire supply of pills at once in attempt to staunch the pain. Prisoners with severely painful conditions are often given Motrin in lieu of therapy, examinations or X-rays.
85. Prisoners who return to sick call due to the continuation of serious medical problems often are subject to
hostile, callous responses from medical personnel, and are
frequently denied further medical treatment outright.
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B. Dental, Qphthalmological and Psychiatric Care 86. The dental care administered to prisoners at the
Three Lorton Facilities is grossly inadequate. One Medium Facility prisoner, who has only six teeth, has been fitted in prison with dentures that he cannot use to chew food because of the pain they cause to his gums; instead, he swallows small pieces of food and, as a result, suffers painful stomach and hemorrhoid problems. Repeated return visits to have the dentures adjusted have failed to correct his painful condition. Another inmate waited for over seven months to have a tooth removed; when the tooth was eventually removed, the dentist broke a neighboring tooth. The inmate had to wait another several weeks to have the broken tooth repaired.
87. The ophthalmological care provided to prisoners at the Three Lorton Facilities is seriously deficient. Frequently, prisoners with impaired vision are prescribed and fitted for glasses, but then do not receive them. Efforts to monitor and prevent the eye diseases to which HIV-infected prisoners are particularly susceptible are essentially nonexistent. For example, one woman confined to the Minimum Security Facility had an ulcer of the eye. She required daily medical treatment for this condition, but was frequently denied care.
88. Psychiatric care is seriously lacking for the prisoners at the Three Lorton Facilities. Problems with the quality of care are compounded by inadequate controls on
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psychiatric prescriptions, which are distributed without imposition of any controls to ensure that medication is taken in the proper dosage and over the appropriate period of time.
C. Emergency and Specialty Care 89. Emergency care is severely deficient for the prisoners at the Three Lorton Facilities. When one inmate at the Youth Center received severe stab wounds to his torso, personnel at his facility made no attempt to stop his bleeding. It was only after he arrived at a hospital that someone provided even emergency treatment for his wounds. Also, while this inmate was being transported between hospitals, the medical technician improperly operated an oxygen mask, causing liquid to come through it while the inmate was attempting to breathe. 90. The specialty care provided at D.C. General Hospital is grossly inadequate. Prisoners from the Three Lorton Facilities often do not receive treatment and do not learn the results of ter.ts in the event they are taken. One doctor at D.C. General Hospital recently examined Jane Doe I, a Medium Facility prisoner whose neck swells regularly due to a broken needle that is lodged there. Relying on months-old X-rays, the doctor informed the prisoner that she should simply endure the condition. Another prisoner, who went to the
hospital for back X-rays after collapsing twice following
withdrawal from Methadone, never learned of his diagnosis or
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(^
learned what, if anything, the X-rays indicated about his condition.
91. Treatment for prisoners with AIDS (or HIV positive status), tuberculosis or other infectious diseases is exceptionally inadequate, with these prisoners frequently being denied treatment because of their condition. Even where treatment for disease-infected prisoners is not completely denied, many such inmates experience longer delays than other inmates in obtaining medical care despite their more fragile health. Such delays or denials are particularly acute for those requiring dental care.
92. In instances where an inmate's medical condition requires ophthalmological care, such treatment is frequently not provided. One inmate, who had a severe case of shingles on his face, was in danger of losing his eyesight. The crisis was avoided following a last-minute emergency eye exam, but only after both a significant delay and an initial misdiagnosis by medical personnel at the inmate's prison infirmary.
D. xntaKe Testing. Disease Control and Record-Keeping 93. The grossly inadequate medical care administered to
the prisoners at the Three Lorton Facilities is exacerbated by a seriously deficient system of testing, disease control and medical record-keeping that violates District of Columbia
Department of Corrections regulations.
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8692

94. In contravention of District of Columbia Department of Corrections regulations, health care workers frequently fail to take an inmate's medical history when he or she enters the prison system. As a result, many inmates at the Three Lorton Facilities who have been transferred from the District of Columbia Jail (the institution through which most inmates enter the system) lack any documented medical histories. This systemic deficiency means that those inmates with existing medical problems frequently have their medical conditions ignored.
95. In contravention of District of Columbia Department of Corrections regulations, the medical records of many inmates at the Three Lorton Facilities also do not contain the results of the tests and medical examinations administered to the prisoners — in those cases in which such tests are, in fact, performed. Moreover, inmates are typically not informed of the results of such tests.
96. In contravention of District of Columbia Department of Corrections regulations, tuberculosis or syphilis test results are frequently not read or placed in an inmate's file when he or she enters the District of Columbia prison system.
97. The Three Lorton Facilities do not maintain a medical follow-up system. Medical staffs fail to determine whether inmates have been taken to specialty clinics, whether prescriptions have been filled, whether medications that have been prescribed are available and whether inmates have been
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8692

allowed to return for follow-up visits. Deficiencies in record-keeping preclude inmates from receiving results and necessary follow-up care after being tested for, or diagnosed with, medical problems.
98. The Three Lorton Facilities also lack continuity of care. From visit to visit, inmates do not see the same practitioner. In addition, no mechanism is in place to insure that an inmate's care continues if she or he is transferred to a new facility. Frequently inmates are not taken to specialty appointments, cease to receive medication or are given no follow-up care if they are transferred.
99. Inmates who have tested positive for HIV infection often receive no counseling or education whatsoever about their condition.
100. The inadequate intake, testing and record-keeping procedures pose a health risk for all inmates, placing them at serious risk of having their health deteriorate significantly during incarceration.
XI. THE MEDICAL RESOURCE "SHELL GAME" 101. The District of Columbia also controls five other prison facilities: the District of Columbia Jail, the Maximum Security Facility, the Occoquan Facility, the Central Facility, and the Modular Facility (collectively, the "Other Facilities").
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8692

102. Unlike the Three Lorton Facilities, the Other

Facilities are all subject to Court orders, designed to

eliminate unconstitutional conditions that have been the

subject of previous class-action litigation. See Campbell v.

McGruder, Civ. A. No. 1362-71 (D.D.C.) (regarding D.C. Jail);

John Doe v. District of Columbia. Civ. A. No. 79-1726 (D.D.C)

(regarding Maximum Security Facility); Twelve John Does v.

District of Columbia, Civ. A. No. 80-2136 (D.D.C.) (regarding

Central Facility); Inmates of Occoquan v. Barry. Civ. A. No.

86-2128 (D.D.C); and Inmates of the Modular Facility v.

District of Columbiaf Civ. A. No. 90-727 (D.D.C).

103. As a result of consent decrees and court orders at

the Other Facilities, medical resources at the Three Lorton

Facilities, which are not under Court order, have been

transferred to the Other Facilities in an attempt to meet the

requirements of Court orders. Medical and correctional

personnel, supplies and necessary equipment are routinely

rotated and often entirely dedicated to the facilities that are

currently required to comply with existing court orders.

104. Inmates from the Three Lorton Facilities are also

at a disadvantage in the competition for appointments at

specialty clinics in D.C. General Hospital. B«o«u»« of the

court orders covering th« Other Facilities, inmates at those

facilities receive priority, making it even more difficult for

j

inmates at the Three Lorton Facilities to secure specialty

\

V.

clinic appointments.

£

t,

8692

- 32 -

j£

Si

105. In transferring medical resources to meet existing court orders, defendants District of Columbia, Sharon Pratt Kelly and Walter B. Ridley are rotating and shifting inadequate medical resources to meet whichever court order is the most urgent, to the detriment of the health care of inmates in the Three Lorton Facilities. Defendants use this tactic to avoid providing an adequate health care program for the entire Department of Corrections system, as required by the United States Constitution and numerous provisions of the D.C. Code.
XII. DEFENDANTS' KNOWLEDGE OF THE GROSSLY INADEQUATE MEDICAL SYSTEM 106. Defendants are well aware of the grossly inadequate medical system at the Three Lorton Facilities and the District of Columbia General Hospital, described in paragraphs 1 through 105. Nevertheless, defendants have failed to remedy the gross inadequacies in the quality and access to medical care, specialty care, and emergency care. Nor have defendants improved the quality and availability of facilities, supplies and medications, or provided adequate intake and testing procedures. Such failure and refusal constitute deliberate indifference to the serious medical needs of the inmates at the Three Lorton Facilities.
- 33 -
8692

FIRST CAUSE OF ACTION 107. Paragraphs l through 106 are incorporated herein by reference and realleged. 108. Defendants' deliberately indifferent failure to provide plaintiffs with basic medical care resulting in the wanton and unnecessary infliction of pain violates the rights of plaintiffs to be free from cruel and unusual punishment under the Eighth Amendment to the United States Constitution, •»nd 42 U.S.C. § 1983.
SECOND CAUSE OF ACTION 109. Paragraphs 1 through 106 are incorporated herein by reference and realleged. 110. Defendants' failure to provide plaintiffs with basic medical care violates defendants' duties under the District of Columbia Code SS 24-106, 24-302, 24-425, 24-442, 24-802 and 24-902, which require defendants to provide plaintiffs with a health care delivery system that meets their basic medical needs.
REQUEST FOR RELIEF WHEREFORE, plaintiffs request this Court to grant the following relief:
a. Declare that the actions and inactions of the defendants described herein have violated and continue to violate the plaintiffs' rights under the Eighth Amendment to
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8692

the United States Constitution, 42 U.S.C. S 1983, and the District Of Columbia Code §§ 24-106, 24-302, 24-425, 24-442, 24-802 and 24-902;
b. Enjoin the defendants from engaging in any action or conduct, or from failing to act in any way, that •iolates the plaintiffs' above-mentioned rights;
c. Order the defendants to take all action necessary to remedy the violations of the plaintiffs' abovementioned rights;
d. Award plaintiffs the cost of this suit, and reasonable attorneys' fees; and
e. Award plaintiffs all further relief that this Court deems just and proper.
Respectfully submitted, ROSS, DIXON & MASBACK
(#913228) Martin 57"""ilacala (#421312) Jeffrey H. Dygert /Thomas H. Howlett Seth D. Berlin ROSS, DIXON & MASBACK 601 Pennsylvania Avenue, N.W North Building Washington, D.C. 20004-2688 (202) 662-2000 Attorneys for Plaintiffs
- 35 -
8692

Of Counsel: Jonathan M. Smith (#396598) Marie Hall (#420157) D.C. Prisoners' Legal Services Project, Inc. 1400 20th Street, N.W. Suite 117 Washington, D.C. 20036 (202) 775-0323
Dated: May 20, 1992
- 36 -
8692

 
 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

INMATES OF THREE LORTON

)

FACILITIES, et al.,

)

)

Plaintiffs,

)

)

v.

)

)

DISTRICT OF COLUMBIA, et al. .

)

Defendants.

)

)

CONSENT DECREE

Civil Action No. 92-1208 JLG
p». ^

m 22 m

CL^DK' S

U.S.
TR/

Dls
cfOF

c

o

g

J

p

The parties to this class action agree, and the Court hereby

orders, that the action shall be settled as follows:

I. PURPOSE OF THIS CONSENT DECREE

A. This Consent Decree is intended to be a resolution of the

essential elements of this class action and is not intended to be a

complete settlement of all issues raised in the Complaint. The

parties agree to this resolution in the broader context of ongoing

negotiations to consolidate all issues concerning health care

provided to inmates of all District of Columbia Department of

Corrections' facilities under the terms of a single court order.

The specific purpose of this Consent Decree is to provide immediate

relief to the plaintiffs in this action with regard to the most

serious conditions affecting the health care that is provided to

them pending the outcome of these ongoing negotiations. In'the

event the parties cannot agree to a full settlement of all issues

in this action, this Consent Decree shall terminate as set forth

Inmates of Three Lorton Facilities v. D.C.
•Illllllllll PC-DC-005-002

below. This Consent Decree shall supersede the Consent Decree signed by the Court on November 7, 1994, which is hereby vacated. II. MEDICAL, DENTAL AND PSYCHOLOGICAL CARE
A. Medical Staffing 1. The defendants shall, within sixty (60) days,
include the following staff on the below-referenced shifts at the health services units at the Medium Security Facility ("Medium"), Minimum Security Facility ("Minimum") and Youth Center Facility ("Youth Center"):

WEEKDAY: 6:00am - 2:30pm
Minimum
Med. Off. Lie. P.A. 2 Nurses
Medium
Med. Off. Nurse
Youth Center
Charge Med. Off. Lie. P.A. Nurse

9:00am - 5:30pm
Charge Med. Off. Pharmacist Med. Rec. Tech.
Charge Med. Off. Pharmacist Med. Rec. Tech.
Dentist Dental Asst. Med. Rec. Tech.

2:00pm -
Med. Off. Lie. P.A.
Med. Off. Nurse
Med. Off. Lie. P.A. Nurse

10:00pm - 6:30am
Licensed P.A or Registered Nurse
Licensed P.A. or Registered Nurse
Licensed P.A. or Registered Nurse

WEEKEND: Minimum. Medium and Youth Center

6:00am - 2:30pm

2:00pm - 10:30pm

10:00pm - 6:30am

Licensed P.A. or Licensed P.A. or Registered Nurse Registered Nurse

Licensed P.A. or Registered Nurse

2. The purpose of this staffing plan is to ensure

that inmates at Medium, Minimum and the Youth Center are provided

adequate medical care, including, but not limited to access to

sick call, chronic care, access to specialty clinics, and

emergency care. The defendants assure the plaintiffs that the

53750.4

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staffing plan contained in this Consent Decree is adequate to comply with all the terms of this Consent Decree. The defendants agree, however, that the plaintiffs' experts shall be permitted to evaluate the sufficiency of the staffing plan, at defendants' expense, one hundred twenty (120) days after the date of entry of this Order. If the plaintiffs upon motion can demonstrate that the staffing plan is inadequate to provide necessary medical care, or to otherwise comply with this Consent Decree, the Court may modify the staffing plan as appropriate.
3. Defendants shall ensure that staffing of at least one health care provider on the evening, night and weekend shifts shall be maintained at all times regardless of annual, administrative or sick leave or any other planned or unplanned occurrence.
4. Defendants shall develop and implement a system, within thirty (30) days of the date of entry of this Consent Decree, to ensure that all prescriptions are filled within twenty-four (24) hours of the prescription date and that inmates receive all medications that have been prescribed for them seven days per week.
5. If defendants choose to staff the night and weekend shifts at Medium, Minimum and the Youth Center with appropriately qualified registered nurses, such nurses shall work under the supervision of a physician stationed at the Lorton Reservation. The physician at the Lorton Reservation shall be on call at all times during the shift of any registered nurse

63750.4

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working the night or weekend shift. Inmates being treated by such nurses shall be capable of being transported promptly and in a clinically appropriate period of time to the Central Facility when appropriate. With respect to each inmate transported to the Central Facility, defendants shall maintain, and make available to plaintiffs as reasonably required, records containing the time of the call to the physician at the Central Facility and the time that the inmate arrives at the clinic at the Central Facility. Within sixty (60) days of the date of entry of this Consent Decree, the defendants shall adopt and implement medicallyappropriate policies and procedures to govern the physician's medical supervision of any such registered nurses. These procedures shall provide that the registered nurses immediately contact the physician if confronted with any of the following circumstances: blunt or penetrating trauma to the head, chest or abdomen; abnormal vital signs, including temperature, pulse, respiratory rate, or blood pressure; and loss of consciousness or dizziness with a documented or reported history of loss of consciousness. Defendants shall develop and implement policies and procedures to ensure that such registered nurses are able to establish prompt and unobstructed telephone, or some other form of voice, contact with the physician, as necessary. Defendants also shall develop and implement procedures to ensure that Department of Corrections' ingress and egress procedures at Medium, Minimum and the Youth Center do not unduly delay emergency medical services ("EMS") being provided to inmates.

63750.4

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All registered nurses working night and weekend shifts at Medium, Minimum and the Youth Center shall be required to be capable of administering advanced cardiac life support ("ACLS") without a physician present, including but not limited to intubation and administration of ACLS medications. ACLS medications and equipment shall be made available at Medium, Minimum and the Youth Center.
B. Sick Call 1. Sick call shall be conducted five times per week
for each housing unit at Minimum, Medium and the Youth Center, except in urgent and unforeseen circumstances. Urgent and unforeseen circumstances shall not include position vacancies or annual, administrative or sick leave. Sick call shall be conducted by a physician or a licensed physician assistant. Each inmate, including but not limited to inmates confined to the control cells at Medium and the maximum security unit lock down, protective custody and control cells at the Youth Center, who requests to be seen at sick call, whether by signing a sick call list or otherwise notifying the medical or corrections staff, shall be seen at the next available sick call session for his or her facility. Sick call for inmates confined to the control cells at Medium and the maximum security unit, lock down, protective custody and control cells at the Youth Center shall be accomplished by a physician or licensed physician assistant making rounds, or by a comparable method. Within ninety days of the date of entry of their Consent Decree, defendants shall

63750.4

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provide a precipitation barrier to ensure that inmates are not exposed to rain or other forms of precipitation while waiting to be seen at sick call, and further, defendants shall develop and implement a system to ensure that inmates are not required to wait outside, exposed to extremes of heat or cold for unreasonable periods of time in order to be seen at sick call. Defendants shall ensure that the necessary equipment and medication is maintained at Medium, Minimum and the Youth Center so that a health care provider is able to diagnose and treat suspected cardiac and asthma problems during sick call or during an emergency, as appropriate. Nothing in this paragraph shall be construed to allow the defendants to refrain from administering appropriate evening, night or weekend medical treatment, as set forth herein, until the next available sick call.
2. The defendants shall establish and follow suitable triage procedures in order to ensure that those inmates most in need of medical care receive priority treatment during sick call.
C. All medical services shall be provided in a manner that preserves inmate confidentiality.
D. Access to Specialty Clinics 1. Inmates at Medium, Minimum and the Youth Center
shall be provided with access to necessary specialty clinics, including those at D.C. General Hospital, within four weeks of referral, at the latest, or sooner in the case of a medical emergency. If a physician makes an explicit written determination that an inmate will not suffer any adverse medical

63750.4

- 6-

consequences from a wait of longer than four weeks, access to specialty clinics may be delayed, provided that the physician specifies the maximum period of time for which access to the specialty clinic may be delayed without adverse medical consequences to the inmate and provided further that the inmate receives specialty clinic care on or before expiration of that period of time.
2. The defendants shall develop and implement an appropriate tracking and tickler system with respect to specialty clinic appointments.
3. The defendants shall maintain a log identifying inmates who have been referred to a specialty clinic, the date of referral, the date of the specialty clinic appointment, or appointments if more than one, and the date upon which the inmate was actually seen by the specialty clinic.
E. Medical Record Review 1. Within sixty (60) days of the date of entry of
this Consent Decree, the defendants' qualified medical personnel shall review the medical records of newly-arrived inmates within 12 hours for medication requirements and within 24 hours for chronic conditions, pending specialty clinic appointments, follow-up care, pending laboratory tests and other medical matters.
2. The defendants shall maintain logs demonstrating the extent of their compliance or non-compliance with the two foregoing record review requirements.

63750.4

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F. Quality Assurance 1. The defendants shall develop and implement a
suitable medical quality assurance program by no later than October 30, 1994. The defendants shall implement a quality assurance program that contains at least the same elements that are required to be implemented pursuant to court order at the Central Facility.
2. The defendants shall maintain records of all quality assurance activities. These records shall be made available to the plaintiffs' counsel upon reasonable request.
G. Chronic Care/Tuberculosis Tracking And Treatment 1. The defendants shall establish and implement an
appropriate system for the tracking and treatment of inmates at Medium, Minimum and the Youth Center with chronic illnesses, including but not limited to: diabetes, hypertension, cardiac illnesses, HIV, asthma, seizures and, as set forth below, tuberculosis. This system shall include a means whereby the pharmacy tracks all inmates on medication for chronic illnesses. This system shall permit the pharmacy to retrieve inmate identity, all medication being used, date of prescription and date of renewal. The system also shall identify any allergies and potential adverse drug interactions.
2. The defendants shall establish and implement a program for the treatment and prevention of TB. The program shall include:

637S0.4

- 8-

a... development and implementation of a system for annual screening by means of PPD and x-ray of all inmates within sixty (60) days of entry of this order;
b. isolation of infectious or suspected cases according to the TB protocol implemented pursuant to court order at the D.C. Detention Facility;
c. appropriate prophylaxis therapy in accordance with the TB protocol implemented pursuant to court order at the D.C. Detention Facility;
d. contact investigation for all active cases in accordance with the TB protocol implemented pursuant to court order at the D.C. Detention Facility;
e. implementation of an appropriate system for the tracking of all inmates on medications for the treatment of TB or who are on TB prophylaxis in accordance with the TB protocol implemented pursuant to court order at the D.C. Detention Facility;
f. referrals for the continuation of therapy for prisoners being released who are on medications for the treatment of TB or who are on TB prophylaxis in accordance with the TB protocol implemented pursuant to court order at the D.C. Detention Facility; and
g. availability of TB education materials to prisoners.

63750.4

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H. Special Medical Diets 1. The defendants shall ensure that inmates at
Medium, Minimum and the Youth Center who are placed on special diets for medical or dental reasons receive such diets on a daily basis.
2. For each inmate at Medium, Minimum and the Youth Center who is placed on a special diet for medical or dental reasons, the defendants shall maintain records showing the prescribed special diet and the inmate's receipt of such diet. These records shall be made available to the plaintiffs' counsel upon request.
I. Dental Care 1. The defendants shall adopt and implement a system
to ensure prompt dental triage and to ensure that inmates who require the treatment of painful dental conditions are treated promptly. Defendants shall ensure that inmates shall be seen by an appropriately-licensed health care provider for the purposes of dental triage within one working day of making a request for dental care. Inmates experiencing painful dental conditions shall be seen within twenty-four (24) hours, or at the latest by the next weekday (excluding legal holidays), except in urgent and unforeseen circumstances. Urgent and unforeseen circumstances shall not include position vacancies or annual, administrative or sick leave. Dental emergencies shall be treated as medical emergencies. The defendants shall commence treatment of dental conditions as quickly as practical, and shall ensure that

63750.4

- 10 -

treatment commences no more than twenty-one (21) days following an inmate's request for treatment.
2. Within forty-five days of entry of this Consent Decree, the defendants shall adopt and implement procedures for ensuring that an inmate in need of a dental prosthesis receives it within an appropriate period of time.
3. The defendants shall maintain written inmate dental records that contain sufficient information to determine the extent of their compliance or noncompliance with these dental care provisions.
J. Mental Health Care 1. The defendants shall provide adequate mental
health treatment by licensed mental•health providers to inmates at Medium, Minimum and the Youth Center. Such licensed mental health providers shall be either a psychiatrist, psychologist, licensed social worker or licensed psychiatric nurse. No inmate who is stabilized on psychotropic medications shall be denied access to work details, work release, community release or other programs solely on the basis that she or he is taking psychotropic medication. Nothing in this paragraph shall prevent the Department of Corrections from denying a prisoner participation in any program where the denial is based on appropriate classification criteria.
2. All inmates who have been prescribed psychotropic medications shall be seen by a psychiatrist at least once every two weeks unless a psychiatrist records in the inmate's medical

S37S0.4

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record that in his or her clinical judgment, the inmate may be seen less frequently, but in no event less than every four weeks.
3. There shall be one psychiatrist, psychologist, or licensed social worker who will provide treatment for prisoners at Medium, Minimum and the Youth Center at least three-fourths time. Evaluations for classification or the Parole Board, participation in classification or adjustment proceedings and administrative responsibilities shall not constitute such treatment.
K. Basic Life Support And Emergency Response 1. The defendants shall provide basic life support
and emergency response services at Medium, Minimum and Youth Center facilities twenty-four hours per day seven days per week. To this end, within five (5) months of entry of this Consent Decree 1/3 of the correctional staff at Medium, Minimum and the Youth Center shall be trained in cardiopulmonary resuscitation ("CPR") and basic first aid, within ten (10) months of entry of the Consent Decree 2/3 of the correctional staff shall be sotrained, and within fourteen (14) months all correctional staff shall be so-trained. Ambubags shall be purchased and stored in each housing unit and correctional staff shall be trained in their proper use on the same schedule applicable to CPR and basic first aid training.

63750.4

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III. REPORTING, MONITORING, MODIFICATION AND TERMINATION A. Monthly Reports 1. The plaintiffs' counsel shall have the right to
receive from the defendants reasonable information on a monthly basis concerning compliance with the requirements of this Consent Decree. The type and form of reports to be provided shall be negotiated by counsel for the plaintiffs and defendants with due regard for the burdens caused by the reporting process and the need to ensure accountability for compliance with this Consent Decree.
B. Facilities Access 1. The defendants shall permit the plaintiffs'
counsel and experts to have access to Medium, Minimum, the Youth Center and to those areas of D.C. General Hospital providing services to members of the plaintiff class, at reasonable times and upon reasonable notice, so that plaintiffs' counsel can monitor the defendants' compliance with the terms of this Consent Decree.
C. Modification 1. The plaintiffs and defendants shall retain all of
their rights under applicable law to modify or to seek relief from any or all provisions of this Consent Decree.
D. Termination 1. This Consent Decree shall remain in effect until: a. a successor decree is entered effecting a
complete resolution of the medical care issues affecting the

S3750.4

- 13 -

entire Department of Corrections, including Medium, Minimum and the Youth Center; or
b. six months after a party to this Consent Decree informs the Court that the negotiations for a successor decree have terminated unsuccessfully, or upon the entry of an order following the trial of this matter, whichever occurs first. Such party must provide the opposing party reasonable advance notice of at least sixty (60) days of its intention to file such notice with the Court. IV. RETENTION OF JURISDICTION AND FURTHER PROCEEDINGS
A. The Court shall retain jurisdiction of this action during the life of this Consent Decree and through any trial in the event of the termination of this Consent Decree as set forth above.
B. Upon entry of this Consent Decree, all discovery in this action shall be stayed and the trial scheduled for November 14, 1994, shall be continued indefinitely. Upon notice from either plaintiffs or defendants that negotiations, concerning a comprehensive resolution of all prison health care litigation aimed at agreement to a successor decree have broken down, the stay shall be lifted automatically. The Court shall schedule trial as soon as possible after receiving such notice from either plaintiffs or defendants.

63750.4

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V. CONSENT DECREE TO BE POSTED A. The defendants shall ensure that a copy of this Consent
Decree is posted in each the medical unit and law library at Medium, Minimum and the Youth Center. SEEN AND AGREED TO:

Johji/K. Gerstein Mactin G. Hacala raomas H. Howlett Jeffrey H. Dygert Seth D. Berlin ROSS, DIXON & MASBACK 601 Pennsylvania Ave., N.W. Washington, D.C. 20004-2688
(202) 662-2000
OF COUNSEL: Jonathan M. Smith Aurie T. Hall D.C. Prisoners' Legal
Services Project, Inc. 1400 20th Street, N.W. Suite 117 Washington, D.C. 20036
(202) 775-0323
ATTORNEYS FOR PLAINTIFFS

Vanessa

,

Corporation Counsel, D.C.

Michael E. Zielinski,

Assistant Deputy

Corporation Counsel, D.C.

Richard S. Love,

Assistant Corporation

Counsel, D.C.

Chief, Correctional

Litigation Section

Maria Amato, Assistant Corporation Counsel, D.C. 441 Fourth Street, N.W. Sixth Floor South Washington, D.C. 2 0011 (202) 727-6295

ATTORNEYS FOR DEFENDANTS

SO ORDERED DATE

-E 0
me L. Green lited States District Court Judge

63750.4

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 Inmates of Three Lorton Facilities v. D.C.

DC-DC-005-005

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

INMATES OF THREE

)

LORTON FACILITIES, e_£ al. . )

Plaintiffs, )

v. DISTRICT OF COLUMBIA, et

) Civil Action No. 92-1208 ) (JLG)

Defendants.

PRAECIPE
To the Clerk of the Court: Please accept for filing
Defendants• plan by the Medical Administrator of the Three Lorton
Facilities to acheive and maintain compliance with the Court's
Orders in this case, required under this Court's Order dated
February 29, 1996.
Respectfully submitted,
JO ANNE ROBINSON Interim Corporation Counsel, D.C.
MICHAEL E. ZIELINSKI Deputy Corporation Counsel, D.C. Special Litiqation Division
WILLIAM EARL Assistant Deputy Corporation Counsel, D.C. Special Litigation Division

MARIA AMATO (414935) Assistant Corporation Counsel, D.C. Correctional Litigation Section 441- 4th St., N.W. 6th Floor, South Washington, D.C. 20001 (202) 727-6295

CERTIFICATE OF SERVICE I hereby certify that a copy of the defendants1 plan by the Medical Administrator of the Three Lorton Facilitieswas mailed, postav,^ «^c<»Daid, to Martin Hacala, et al, Ross, Dixon & Masback, 601 Pennsylvania A w . N W > / N o r t h Building, Washington, D.C. 20004-2688, Jonathan Smith, et al, n_c. Prisoner Legal Services, 1400 20th Street, N.W., Suite 117, Washington, D . C , and Grace Lopes, Special Officer of the U.S. District Court for D.c., 1130 17th Street, N.W., Suite 400, Washington, D.c. 20036, on this _ day of A/.-Tz-Ox^/i^W' , 1997.
; MARIA AMATO (414935) Assistant Corporation Counsel, D.C. Correctional Litigation Section 441 Fourth St., N.W. Sixth Floor/So"*^ W^-iiXngton, D.C. 20001 (202) 727-6295/ext.3469
T"

COMPLIANCE FLAN FOR HEALTH SERVICES AT MINIMUM, MEDIUM AND YOUTH CENTER
I. INTRODUCTION:
This Compliance Plan for Health Services at the Minimum, Medium and Youth Center facilities (Three Lorton Facilities) is submitted in accordance with Court-ordered requirements in Inmates of Three Lorton Facilities v. D.C., Civil Action Number 92-1208 (JUG) .
The Plan sets forth action the Department of Corrections will take to correct the non-compliance with the Court's orders identified in the February 29, 1996 Order addressing medical, mental health and dental care.
II. COMPLIANCE PLAN OBJECTIVES:
The objectives of the plan are the following:
A. Staffing: Appropriately staff each facility with credentialed health care providers who are appropriately trained and supervised.
B. Access to Health Care: Provide inmates, (including working inmates at Minimum, inmates in dormitories, maximum security and segregation units) with access to sick call, chronic disease clinic, dental care, mental health care and specialty clinics, and maintain appropriate tracking and statistical information regarding access to health care.
C. Dental Care: Provide timely dental care by an appropriately credentialed dental care provider and provide dental triage and/or treatment of painful dental conditions.
D. Mental Health Care: Inmates prescribed psychotropic medications will he seen at the required intervals, In accordance with tir i Court's order and inmates stabilized on medication will not be denied access to work details, work release or community correctional facilities solely because they have been prescribed psychotropic medication.
E. Pharmacy: Provide prescribed medication to all inmates, including those in lock-down units, within 24 hours of the prescription; provide a substitute for out-of-stock medication without requiring the inmate to return to sick call; and, maintain appropriate documentation of an inmate's medication history in his/her medical record.
F. Emergency care: Provide emergency care, including emergency equipment, appropriately stocked and inspected crash carts, trained staff and an appropriate emergency care space.

G. Tuberculosis Screening & Treatment Plan: Establish and implement a program for the treatment and prevention of TB at the Three Lorton Facilities that includes staff training and a tracking procedure.
H. Quality Assurance/Improvement: Develop and implement a suitable medical quality assurance/improvement program. Maintain records of all quality assurance/improvement activities.
I. Special Medical Diets: Provide inmates with appropriate special diets prescribed for medical or dental reasons.
J. Advanced Cardiac Life Support (ACLS): Develop a proposal to modify the original decree requirement that all nursing staff working on single provider shifts have ACLS certification. Ensure that all nursing staff working on single provider shifts have the requisite skill and experience to appropriately handle emergencies.
K. Basic Life Support and Emergency Response: Provide basic life support and appropriate emergency response services at the Three Lorton Facilities twenty-four (24) hours per day, seven (7) days per week.
L. Abatement of non-compliance with the Court's Orders: Develop and implement a procedure to identify and remedy noncompliance with the Court's orders which includes the following: procedures to identify non-compliance, plans to remedy non-compliance, identification of individual(s) who will implement corrective action, specific timetable for achieving compliance, and review of the results of the corrective action.
M. Policies and Procedures to Implement the Compliance Plan: Develop, disseminate and post written policies and procedures consistent with this Compliance Plan.
N. Training and Education of Staff: Develop and implement education and training for all health care staff providing care to the inmates at the Three Lorton Facilities regarding the Court's orders in the Three Lorton Facilities litigation as well as this Compliance Plan.

obtain a renewal in a timely manner, or be suspended or terminated.

d. The Health Services Administrator shall identify staff or contract employees to temporarily replace any staff member whose license has expired until the license is renewed, if indicated. This activity will take place 30 days prior to the expiration of a staff member's license. The Health Services Administrator will arrange relief coverage through overtime, reassignment or contractors.

2. Provide clinical supervision of all staff on all shifts.

a. Appoint Chief Medical Officer for clinical management who has the following duties and responsibilities: (Completed)

i. Provide supervisory authority over all staff (including medical officers, dentists, physician assistants, chief supervisory nurses, clinical nurses, chief pharmacist, line pharmacists, infection control officers, medical record librarian, medical record technicians, and quality assurance specialist for the Three Lorton Facilities) as appropriate, in matters relating to clinical care; (Ongoing)

ii. Participate in the achievement and maintenance of compliance with the Court's orders.

iii.

Initiate meetings with wardens, perform monthly chart review at each of the Three Lorton Facilities, participate in the development of treatment protocols in conjunction with the He \lth Services Coordinator, and other duti'.s as assigned; (Ongoing)

iv. Maintain open and frequent communication with all health care staff and be accessible for consultation with health care staff; (Ongoing)

See sample notice, attached as Exhibit 1.
3 A Chief Medical Officer was appointed in October 1996 who has supervisory authority over the staff of the Three Lorton Facilities.

v. Review monthly reports from the charge medical officers of each institution and the monthly court-ordered report, and take corrective action where appropriate; (Ongoing)

vi. Co-chair the Compliance Task Force's bi-weekly meeting with the Health Services Administrator; (Ongoing)

vii.

Provide 24 hours a day, seven days a week oncall coverage for emergencies, or designate responsibility to appropriately trained and licensed staff; (Ongoing)

viii.

Conduct regular unscheduled inspections of all areas where health care is delivered, including medical units, lock down units, and dental units ; (Ongoing)

ix. Hold monthly meetings with the medical officers, the Health Services Administrator, Data Control Technician, Lorton supervisory nurses, clinical nurses, medical record librarian, Chief of Mental Health and Chief of Dental Services, the quality assurance specialists, and the acting chief pharmacist ; (Ongoing)

x. Encourage open communication amongst employees at staff meetings; (Ongoing)

xi. Report directly to the Health Services Administrator. (Ongoing)

b. The Health Services Administrator shall have the following duties and responsibilities:

i. Supervise the administration of health care at the Three Lorton Facilities to comply with the

4 Several inspections were conducted by the Chief Medical Officer of the Three Lorton Facilities, commencing in September of 1996. On some of the inspections, the Chief Medical Officer was accompanied by the Wardens and/or facilities management staff.
5 The Compliance Task Force for the Three Lorton Facilities began to meet on August 8, 1996. Meetings have been held biweekly. The meetings have served as an interdisciplinary forum for discussions, problem resolution, brain-storming, and as an opportunity for staff input in the Compliance Plan.

Court's orders in Inmates of Three Lorton facilities, et al v. D.C.. et al. C.A. No 921208 (JLG);

ii. Provide administrative supervision of all health care staff at the Three Lorton Facilities;

iii.

Develop and implement procedures for the delivery of care, tracking the delivery of care, identifying noncompliance with the Court's orders and coordinating corrective action to achieve compliance.

c. The Chief Supervisory Nurse, Lorton Complex, shall supervise the clinical practice of nurses throughout the Lorton Complex, including the Three Lorton Facilities, in conjunction with the Chief Medical Officer for the Three Lorton Facilities and the Interim Assistant Director of Health Services.

3. Monitor staffing and workload on a monthly basis.

a. Develop tracking form called the "Daily Accountability Form" which records daily the number of staff present for each shift. (Completed)

b. Implement a periodic reporting procedure to compare
staffing in the "Daily Accountability Form" with
the number of inmates seen6on the sick call summary and respond appropriately. (Ongoing)

4. Sick Call shall be conducted by a physician or physician assistant.

a. Assign physicians and/or physician assistants to conduct sick call daily at the Three Lorton Facilities. (Completed)

b. Issue a written directive that only a physician and/or physician assistant can conduct sick call at the Three Lorton Facilities. (Completed)

c. Develop a procedure for staff at the Three Lorton

\

Facilities to immediately report the absence of

The periodic reporting procedure monitors compliance with Court-ordered staffing requirements on a daily basis on all shifts. The report is completed by the charge nurse and forwarded to the Health Services Administrator on a daily basis. See Exhibit 2.

©
staff to conduct sick call due to sick leave, annual leave, emergency leave, administrative leave, AWOL or furlough. (Ongoing)
5. Develop and implement procedure to identify and assign qualified staff to conduct chronic disease clinic when health care staff are on sick leave, annual leave, emergency leave, administrative leave, AWOL or furlough. (Completed)
6. The Health Service Administrator shall promptly prepare and submit personnel actions to the Office of Human Resources requesting immediate recruitment of candidates to fill any vacant physician positions. (Ongoing)
7. The Health Services Administrator will request physician assistants from the contractor in a timely manner after notice that a physician assistant position is or will be vacant. (Ongoing)
B. ACCESS TO HEALTH CARS
1. Sick call shall be held at the Three Lorton Facilities five days each week. Inmates shall be seen at the next available sick call after signing the sick call list or notifying staff of the need for medical attention.
a. Hold sick call in individual examination rooms to maintain patient confidentiality. (Ongoing)

On shifts two and three, the Chief and/or charge medical

officers will review the staffing level at the start of each shift.

If the staffing level is not consistent with the Court's orders,

the charge medical officer will immediately contact the Chief

\

Medical Officer who will advise the Health Services Administrator.

[

The Health Services Administrator will arrange relief coverage

t

through overtime, reassignment or contractors.

I

On shift number one, the contractor will notify the

?•

Supervisory Nurse when a night nurse is absent. The supervisory

)

nurse will arrange for relief coverage from the contractor.

\

o
See procedures described in paragraph one of footnote 7.

b. Develop uniform sick call sign-up sheet.9 (Completed)
c. Distribute and use the uniform sick call sign up sheet at the Three Lorton Facilities. (Ongoing)
d. Develop a "Sick Call Summary" sheet filled out by each medical unit which tracks the following: the number of individuals who sign up for sick call, the number seen, the number who refuse care or fail to appear, the number of individuals who go to sick call and are not seen, and the number of inmates who are not seen due to the lack of transportation/escort.
e. Analyze the "Sick Call Summary11 sheets quarterly to identify the number of inmates seen at sick rail, the reasons inmates are not seen and barriers to the access to health care. Take remedial action, as necessary.
f. Develop a procedure by which statistical information tracking sick call is periodically compiled, reviewed and reported to the Interim Assistant Director for Health Services and the Health Services Coordinator. (Completed)
i. The Health Services Administrator, in concert with the Data Control Technician, will compile the statistics from the "Sick Call Summary Statistics", the "Specialty Clinic Tracking Form", the "CDC Listing" form, the "CDC Monthly Summary" form, the "Weekly Dental Report", and the "Dental Sick Call Summary" form.
9 A sick call sign-up sheet was distributed to the Wardens of each facility on October 22, 1996. Subsequently the sick call sign-up sheet was revised in format only. The revised Medical Request Sign Up Form is attached as Exhibit 3. This sick call sign-up sheet is used in all housing units, including lockdown and segregation units.
10 See form entitled "Sick Call Summary Statistics," attached as Exhibit 4. The charge nurse fills out this form after obtaining information from the escort officers who bring the inmates to the sick call unit, the "Sick Call Sign Up and Tracking Form" completed by the physician, attached as Exhibit 5, and the Master Sick Call Sign Up and Tracking Form completed by the nurses, also attached as Exhibit 5.
8

(•

ii. The data will b.e compiled on a daily and a monthly basis. Commencing April 1997, the data will be analyzed quarterly to assess the delivery of care in accordance with the Court's orders, identify noncompliance, and implement corrective action.

iii.

The Health Services Administrator and the Data Control Technician will prepare a memorandum analyzing the information which shall be forwarded to the Health Services Coordinator, through the Interim Assistant Director for Health Services, with a copy to the Chief Medical Officer, the charge medical officers, the charge nurses, the wardens, and the Quality Assurance Specialist.

iv. The Quality Assurance Specialist shall make recommendations for corrective action, where applicable.

v. Remedial action will be taken if indicated, consistent with the Section L of this plan regarding abatement.

2. Provide access to sick call to inmates who work or are in lock-down and segregation units.

a. Hold sick call for inmates who work at Minimum Security Facility on the evening shift, 2:00 p.m. to 10:00 p.m. (Ongoing)

b. Assign a PA or physician to conduct sick call daily in the lock down and segregation units at the Youth Center and Medium Security Facility. (Ongoing)

c. Track daily transport/escort to the healt'. care

"^

unit of inmates in the lock down and segregation

}

units at the Youth Center and Medium Security

\

Facility, where appropriate, through the "Sick Call

Summary Statistics" described above. (Ongoing)

3. The precipitation barriers at the Minimum and Medium

facilities shall be properly maintained. Any problem

with the precipitation barrier shall be immediately

*

reported to the Warden of the facility who shall make

every reasonable effort to make immediate repairs.

11

.

See the "Monthly Statistics Form," attached as Exhibit 6.

4. Inmates will be seen in specialty clinics within four weeks from the date of referral or sooner in case of medical emergencies.

a. Implement a manual tracking log at each facility which will be maintained by the Specialty Clinic Nurse. (Ongoing)

b. The Specialty Clinic Nurse will compile a list of referrals daily and fax the list to the Trip Coordinator at D.C.G.H. (Ongoing)

c. Develop a tickler system to alert the Specialty

Clinic Nurse scheduling the appointments of the

approaching deadlines for compliance.

(60

days*2) *^

d. If an appointment cannot be scheduled within the Court-ordered time frame, the Specialty Clinic Nurse will notify the referring physician and the Health Services Administrator. (Ongoing)

e. The Health Services Administrator will monitor, review, and evaluate, as well as track statistically, all referrals to the Specialty Clinics, intervening when indicated to meet the Court-ordered time frame. (60 days)

f. Develop and implement forms and procedures to track the following: the number of individuals referred to specialty clinics, the timeliness of actual appointments, the number who are not seen within the Court-ordered time frame, the reason the inmate was not seen (including no/show or refusal), no transport, DCGH cancellation or delay. (Completed)

g. Develop a procedure by which statistical information tracking specialty clinic referrals is periodically compiled, reviewed, and reported to

The time for this deadline, and all other deadlines established in this plan, will commence on the date of the filing of the plan.
See Section O, on page 21, for an explanation of the asterisks.
See Specialty Clinic Tracking Form, attached as Exhibit 7. 10

the interim Assistant Director for Health Services and the Health Services Coordinator.
4. Appropriately follow, refer and see inmates who have chronic diseases.
a. Inmates diagnosed with chronic diseases16 identified during the intake review of medical records, or diagnosed during a health services encounter, are recorded by name and illness into a manual tracking log, maintained by a chronic disease nurse. (Ongoing)
b. Inmates identified with chronic diseases are referred for follow-up chronic disease clinic (CDC) appointments which are recorded in the CDC log. (Ongoing)
c. The Chronic Disease Nurse compiles a list of referrals for CDC daily, and a call out pass is issued to bring the inmate to the health care unit. (Ongoing)
d. Develop and implement the "CDC Listings" form prepared daily by each medical unit which tracks the following: individuals referred to chronic disease clinics; nature of illness; treatment; and return appointment to CDC. (Completed)
e. Develop and implement the "CDC Summary Statistics Form" prepared monthly which tracks the following: number of individuals scheduled for CDC; the number of inmates seen; the number who refused care or failed to appear; the numbers who are referred to CDC and are not seen; and the number of inmates who are not seen due to the lack of transportation/escort. (Complex ed)
1 See the procedures outlined above in sections
16 The chronic disease category includes, but is not limited to the following: tuberculosis, heart disease, asthma, AIDS, hypertension, diabetes, seizure disorder, hepatitis, renal disease, post surgery patients, and certain gynecological problems.
17 See Exhibit 8.
See Exhibit 9.
11

f. Implement Monthly Statistical Form by which statistical information tracking CDC clinic referrals is periodically compiled, reviewed and reported to the Interim Assistant Director for Health Services and Health Services Coordinator. (Completed)

C. DENTAL CARE

1. Provide timely dental care by providing inmates with dental triage within 24 hours of signing a dental sick call list or of referral.

a. Develop uniform fj-ck call sign up sheet for medical and dental care. (Completed)

b. Distribute and implement use of the uniform sick call sign up sheet at the Three Lorton Facilities. (Ongoing)

c. The Minimum Facility inmates will be seen by a dentist for the purpose of triage on Thursdays and Fridays at the Minimum Facility. The dentist will review the dental sick call list, call out inmates to conduct triage, and schedule inmates for treatment according to level of acuity. The inmates will be seen for dental treatment at the Central Facility on Mondays, Tuesdays and Wednesdays. (Ongoing)

d. The Medium Facility inmates will be seen by a

dentist for the purpose of triage on Mondays and

Wednesdays at the Medium Facility. The dentist

will review the dental sick call list, call out

inmates to conduct triage, and schedule inmates for

treatment according to level of acuity. The

inmates will be seen for dent 1 treatment at the

Occoquan Facility on Tuesdays, Thursdays and

Fridays. (Ongoing)

\

e. At Youth Center, dental treatment will be provided

I

five days each week. The dentist will review the

\

dental sick call list daily, call out inmates to

\

I

19

•>'

See the procedures outlined above in sections

f-

III(B)(1)(f)(i-v).

i

20 See Exhibit 3.

\

r;

12

»

conduct triage, and schedule inmates for treatment according to level of acuity. (Ongoing)
2. Provide transport and dental care as soon as practical, but in no event more than twenty-one (21) days following an inmate's request for treatment.
3. Appoint a Chief Dental Officer for clinical management with the following duties and responsibilities:
a. Review monthly reports from the dental officers of each institution and the monthly Court-ordered report, and take action where appropriate; (Ongoing)
b. Post written notification to staff that the Chief Dental Officer, or designee, is available 24 hours a day, seven days a week for emergencies; (Completed)
c. Maintain open and frequent communication with the health care staff at the Three Lorton Facilities; (Ongoing)
d. Conduct regular unscheduled inspections of all areas where dental health care is delivered, including medical units, lock down and segregation units, and dental units; (Ongoing)
e. Attend monthly meetings with the Chief Medical Officer, the Health Services Administrator, the Data Control Technician, charge medical officers, Lorton Supervisory Nurses, Clinical Nurses, Record Librarians, Chief of Mental Health, the Quality Assurance Specialists, and the acting Chief Pharmacist; (Ongoing)
f. Hold mandatory periodic meetings with dental staff, and maintain documentation regarding attendance; (Ongoing)
g. Periodically review the attendance records of the mandatory dental staff meetings, and take appropriate action when necessary; (Ongoing)
21 A new operatory was installed at the Youth Center in November 1996.
22 A Chief Dental Officer with supervisory authority over all dentists and dental assistants was appointed in August 1996 to supervise dental care at the Three Lorton Facilities.
13

ii?*
h. Encourage open communication amongst employees at staff meetings;
i. The dental assistant assigned to provide services for each of the Three Lorton Facilities shall schedule dental appointments and arrange transport to bring the inmate to the dental unit; (Ongoing)
j. Develop and implement dental tracking forms prepared daily by each dental unit which tracks the following: individuals referred for dental care; nature of problem; treatment; and date of return appointment, if any; (Ongoing)
k. Develop and implement the "Dental Summary Statistics Form" prepared monthly which tracks the following: number of individuals scheduled for dental care; the number of inmates seen; the number who refuse care or fail to appear; the numbers who are referred to dental and are not seen; and the number of inmates who arg not seen due to lack of transportation/escort; (Completed)
1. Implement Monthly Statistical Form by which statistical information tracking dental care is periodically compiled, reviewed and reported to the Interim Assistant Director for Health Services and Health Services Coordinator. (Completed)
D. MENTAL HEALTH CARS
Develop and implement procedures whereby inmates prescribed psychotropic medication are evaluated by a psychiatrist at least .mce every two weeks, unless a psychiatrist notes in t-ie medical record that, in her/his clinical judgment, the inmate may be seen less frequently, but in no event less than every four weeks.
a. Maintain a psychiatric clinic logbook for each facility indicating the inmate's name, DCDC number, reason for referral and the clinic return date. (Ongoing)
23 see "Weekly Dental Report," attached as Exhibit 10 and "Dental Summary Statistics Form," attached as Exhibit 11.
24 See the procedures outlined above in sections III(B)(1)(f)(i-v).
14

b. The psychiatric clinic nurse will review the logbook, schedule the follow up appointment and arrange transport. (Ongoing)
c. Develop and implement a tracking and recall plan consistent with the procedures used at the Occoquan Facility. (60 days)*
E. PHARMACY
1. Ensure the availability of medication to all inmates, including those in lock-down and segregation units, within 24 hours of the prescription, and ensure that the pharmacists advise the physicians of out-of-stock medications.
a. Develop and implement a form for the Acting Chief Pharmacist to send to the medical officers notifying them of out-of-stock medications. (Completed)
b. Inmates who need medication for chronic diseases shall be seen in the Chronic Disease Clinic at least once every 15 days to renew prescriptions for medication. (Ongoing)
c. Each pharmacist will contact the Acting Chief Pharmacist to inform him of out-of-stock medication within her/his assigned area. (Ongoing)
2. Substitute prescribed out-of-stock medication with instock medication without requiring the inmate to return to sick call.
25 See Exhibit 12, "bracking and Recall System for Inmates Receiving Psychiatric Care at the Occoquan Facility."
26 See "Pharmacy Alert Form", attached as Exhibit 13. The form will be faxed to the medical units upon notice to the pharmacist that a medication is out of stock.
27 For the CDC tracking procedure, see III(B)(4), supra.
28 When the pharmacist notifies the Chief Pharmacist that medication is out of stock at one of the Three Lorton Facilities1 pharmacy, the Chief Pharmacist shall check the Central Pharmacy Warehouse to determine if the medication is in stock. If it is in stock, a Health Service courier shall deliver it to the facility immediately.
15

r - ••
a. The pharmacist will contact the medical officer by telephone to request an appropriate substitute for the out-of-stock medication. (Ongoing)
b. Develop and implement a log to record substitutions of temporarily out-of-stock medications. (Ongoing)
c. The physician shall use the Doctor's Order Sheets to prescribe all medication, and the Doctor's Order Sheets Shall be maintained in the inmate's medical record.
d. Develop a log which appropriately and expeditiously records the distribution of over-the-counter medications (OTCs). (Completed)
e. Identify staff and implement procedures ta periodically review and evaluate the OTC log. (Ongoing)
F. Emergency care
1. Provide organized and properly maintained emergency equipment.
a. Develop and implement procedures for routine periodic inspections and surveys of all emergency equ ipment. (Ongoing)
b. The Health Services Administrator and the Chief Medical Officer will conduct quarterly, unannounced surveys of the entire emergency area of each facility. The Health Services Administrator will also invite the following personnel (or a
29 See "Three lorton Facilities Temporarily Out of Suock Medications" form, attached as Exhibit 14.
30 See Doctor's Order Sheet, attached as Exhibit 15.
31 Attached as Exhibit 16 is a sample "Over the Counter Medication Log" which will be maintained by the LPN distributing the OTCs.
32 The OTC log is reviewed and evaluated monthly by the Supervisory Nurse, Lorton Complex and the Acting Chief Pharmacist in consultation with the Chief Medical and Dental Officers, Three Lorton Facilities. The team will make recommendations to the Health Services Administrator regarding their findings.
16

m

t

designee): Chief Medical and Dental Officer, Supervisory Nurses, and the Wardens.
c. Identify staff and implement procedures to record results of each survey and review for immediate corrective action. (40 days)
2. Provide a uniformly stocked crash cart which is inspected each shift. Develop and implement a procedure for routine inspections and surveys of crash carts, including verification that they are folly stocked with current medications, and maintain appropriate documentation. (40 days)*
3. Provide a sanitary and organized emergency care unit.
a. Organize and clean all emergency units, removing unnecessary items, arranging emergency eguipment so that it is readily accessible, and clearing ingress and egress to the unit. (Completed)
b. Establish a routine and periodic schedule for the maintenance of the emergency units which contains procedures for cleaning and organization daily and after each use. The daily cleaning and maintenance shall be monitored by the charge nurse.
c. Identify staff and implement procedures to inspect the emergency units monthly, record the results and review each survey for immediate corrective action. (Ongoing)
4. Develop and implement procedures to ensure that all staff are prepared to handle emergencies appropriately. Periodically conduct emergency drills on each shift at

The target date for the first survey is April 1997. The survey will be reviewed and recommendations will be forwarded to the Chief Pharmacists, Supervisory Nurses, Charge Medical Officers and Charge Nurses and the Interim Assistant Director of Health Services. The Health Services Administrator will oversee correction of deficiencies.
The Crash Cart is checked by the nursing staff at the beginning of each shift and at the end of each shift. This task is monitored by the Chief Supervisory Nurses.
17

each of the Health Care units at the Three Lorton Facilities. (Ongoing)
G. Tuberculosis Screening & Treatment Plan
1. Develop and implement the Tuberculosis Screening and Treatment Plan. (40 days)*
2. Identify ^ind implement a tuberculosis tracking procedure. (40 days)*
3. Commencing April 1997, the Health Services Administrator will analyze the data relating to TB prevention and treatment on a quarterly basis. The Health Services Administrator and the Data Control Technician will forward a memorandum containing this analysis to the Health Services Coordinator, through the Interim Assistant Director for Health Services, with a copy to the Chief Medical Officer, the charge medical officers, the charge nurses, the wardens, and the Quality Assurance Specialist. The Quality Assurance Specialist shall make recommendations for corrective action, where applicable.
H. Quality Assurance/Improvement
1. Design and implement a Quality Assurance/Improvement program that contains at least the same elements that are required to be implemented pursuant to the Court's order at the Central Facility.
a. The plan shall include, but is not limited to: authority for the plan; monitoring and evaluating
Emergency drills were conducted at the Three Lorton Facilities during January 1997. The assessments of the emergency drills were forwarded to the Health Services Coordinator for recommendation and action.
The Department has developed and implemented a "TB Tracking Form" which tracks PPD and chest x-ray results and follow-up, attached as Exhibit 17.
37 A proposed plan was submitted during the week of January 7, 1997 to the Three Lorton Facilities' supervisory staff for review and approval. Upon review and approval, it will be submitted to the Interim Assistant Director for Health Services and the Health Services Coordinator. A finalized plan is anticipated by February 28, 1997 and will be filed with the Court as a supplement to this Compliance Plan.
18

e:

m

all aspects of health services; focused studies on aspects of care at each facility; bi-weekly meetings; and identity of the person responsible for each activity.
2. Assign a Quality Assurance/Improvement Specialist to the Three Lorton Facilities. (Completed)
3. Develop and implement a tracking mechanism for the activities of the Quality Assurance/Improvement Program.
a. The Quality Assurance/Improvement Specialist shall prepare a monthly report to the Health Services Administrator and meet regularly to discuss quality assurance findings and determine appropriate action. (Ongoing)
I. Advanced Cardiac Life Support (ACLS)
1. Develop a proposal to modify the requirement in the November 22, 1994 Consent Decree that all nursing staff working on single provider shifts have ACLS certification.
a. Develop and submit a proposal to plaintiffs' counsel establishing the requisite skill and experience for nurses on single provider shifts to appropriately handle emergencies. (40 days)
2. Petition the Court to modify the requirement in the November 22, 1994 Consent Decree that all nurses on single provider shifts be ACLS certified. (60 days)
J. Special Medical Diets
1. Provide inmates with appropriate special diets prescribed for medical or dental reason...
a. Physicians will order special medical diets in writing. The physician's order sheet will be revised in consultation with the Special Officer and her expert. (60 days)
b. The physician will provide the special diet order to the food service contractor on a timely basis.
A Quality Assurance/Improvement Specialist was assigned exclusively to the Three Lorton Facilities on October 28, 1996 and reports to the Health Services Administrator.
19

m
c. The food service contractor, the Health Services unit and the Warden's office will maintain a list of the inmates ordered special diets and the types of diets ordered. (Ongoing)
d. The inmate will be provided with the special diet within 24 hours of the order. (Ongoing)
2. Monitor the provision of special diets.
a. An assessment of the adequacy of special diets at other DOC facilities is being conducted by the Special Officer and her expert. Those findings and recommendations will be addressed and serve as a basis for improving the preparation and delivery of therapeutic diets. (Ongoing)
K. Basic Life Support and Emergency Response
1. Train all correctional staff at the Three Lorton Facilities in CPR and basic first aid procedures.
a. In coordination with the Wardens, audit basic first aid and CPR training of all correctional staff at the Three Lorton Facilities to determine the identities of staff members who require training and/or re-certification. (Completed)
b. Conduct CPR training for all correctional staff at the Three Lorton Facilities who require recertification, and maintain appropriate documentation. (240 days)
c. Conduct CPR training for all correctional staff at the Three Lorton Facilities who have never received CPR training, and maintain appropriate documentation. ^30 days)
L. Abatement of Non-compliance with the Court Orders
1. Develop and implement a procedure to identify and remedy non-compliance with the Court's orders which will include the following: procedures to identify non-compliance, identification of obstacles to achieving compliance, plan to remedy non-compliance and overcome obstacles, the identity of individual(s) who will implement corrective action, the specific timetable for achieving compliance, and review of the results. (60 days)*
20

&
M. Polioies and Protocols to Implement the Compliance Plan
1. Develop written poli ies and procedures consistent with this Compliance Plan
The Department shall develop written policies and procedures consistent with this plan. They will
address, but are not limited to, the following topics: credeni:ials; sick call; specialty clinics; chronic diseas clinic; dental care; quality assurance/impro ement, and other parts of this Plan as deemed appro riate. (180 days)*
b. The policies an procedures will be circulated to all staff anc posted in the Three Lorton Facilities. (18 days)
2. Develop written tre tment protocols for the clinical management of the fol .owing areas of care, including, but not limited to: ch onic diseases, common illnesses, emergencies, dental are and mental health care.
a. Identify the sp scific areas of care which require treatment proto ols. (60 days)*
b. Develop and implement the identified treatment protocols. (180 days)*
c. Review all treat ment protocols on an annual basis,
N. Training and Education of £ taff
1. Develop and conduct e ucation and training of all health care staff regarding the Court's orders relating to the Three Lorton Facilities and this Compliance Plan.
a. Develop a :ra ining curriculum regarding the mandates of '.-he Court's orders and this Compliance Plan for train ng of all present employees and contract staff, and for inclusion in orientation curricula for incoming employees and contract staff. (60 days)
b. Schedule and co duct training of Health Services DOC staff and contract employees. (90 days)
Provision of Future Plans, Procedures
1. All items included in this plan which are marked with an asterisk shall be pr jvided to plaintiffs' counsel for review and approval oi e week prior to the deadline. The parties shall endeav r, in good faith, to resolve any
21

disputes regarding these matters prior to the expiration of the deadline. If the parties cannot agree, the Special Officer will assist with the resolution of this matter consistent with the provisions of the February 29, 1996 Order.
22

Government of the District of Columbia DEPARTMENT OF CORRECTIONS
Health Services Lorton, Virginia 22079
Office of the Administrator

MEMORANDUM TO

Date

Exhibit 1

FROM : Lorella B. Willis, CHE Administrator for Three Lorton Facilities

RE

: Pending Expiration of License

According to our records your license will expire within 60 days You are hereby directed to renew your license.
If you do not renew your license prior to expiration, you will not be allowed to practice for the District of Columbia Department of Corrections. Appropriate administrative actions, inclusive of termination will be initiated for failure to comply.
Should there be questions regarding this letter, do not hesitate to call me. The telephone number is 703-643-6012.

Distribution:
P. Broadnax, Interim Assistant Director of Health Services H.E. Branson, MD J.F. Coley, DDS

Government of the District of Columbia DEPARTMENT OF CORRECTIONS
Health Services Lorton, Virginia 22079

Exhibit 2

THREE LORTON FACILITIES DAILY SIGN IN/OUT ACCOUNTABILITY LOG
PAY PERIOD ENDING:

DATE:

NAME

TIME-IN

WORK AREA:

SIGNATURE

TIME-OUT

COMMENTS

ft

I HAVE REVEIWED THE ABOVE INFORMATION AND VERIFIED ACCURACY. SUPERVISOR

FACILITY

TIME

NAME

THREE LORTOM FACILITIES MEDICAL SICK CALL REQUEST
DORM #
DATE

Exhibit 3

DCDC#

MEDICAL

DENTAL

PLEASE CONTACT YOUR DORM OIC IF YOU ARE UNABLE TO KEEP YOUR MEDICAL/DENTAL APPOINTMENT. DO NOT WRITE MEDICAL PROBLEM ON THIS FORM. SBS/96
CHARGE OFFICER

DATE

/r -

{••••

••••

Exhibit 4

THRU LORTOM TXCILITISS SICK CALL SUMMARY STATISTICS

FACILITY

# SIGNED

/ SEEN

/ NOT SEEN

MONTH
A B C DEF

REASONS;

DATE

A. INMATE DECLINED B. CANCELLED (INSTITUTION) C. CANCELLED (HEALTH SERVICES) D. NOT COMPLETED E. NO TRANSPORTATION/ESCORT F. NO SHOW

LBW:l/97

REVIEWED BY CHIEF MEDICAL OFFICER

FACILITY: MEDICAL PROVIDER:
NMATE NAME
1

GOVERNMENT OF DISTRICT OF COLUMBIA DEPARTMENT OF CORRECTIONS HEALTH SERVICES

DCDC#

SICK CALL SIGN-UP AND TRACKING FORM

DORM

TIME TREATMENT PROVIDED

WALK- IN COMPLAINT

DISPOSITION

DATE: PAGE:

W
X
3*
H-
m
OF

A B C D E I--.:

I
1
-1 \
A INMATE DECLINED B CANCLLl f.D iniblili.lu C CANLUUD iHiuiih
I I)'/; 1 J /

D. NOT COMPLElfcD E NO TRANSPORTATION/ESCORT F NO SHOW

FACILITY: MEDICAL PROVIDER:
INMATE NAME

GOVERNMENT OP DISTRICT OP COLOMBIA DEPARTMENT OF CORRECTIONS HEALTH SERVICES

DCDC*

MASTER SICK CALL SIQN-UP AND TRACKING FORM

DOflM

TME TREATMENT PROVIDED

WALK M

COMPLAMT

DATE: PAQE:
DtSPOSCTION

OF
•7=5
A B C D E';;?_ •t

\

INMAIt Utl-LINtU
B CANCELLED lln&IHulionl C CANCELLED IHealth Smvir.esI
I BW 1.9 7

U. PJU I LUMrLt I t U
E. NO TRANSPORTATION/ESCORT F NO SHOW

Exhibit 6

THREE LORTON FACILITIES MONTHLY STATISTICS

GENERAL POPULATION; SICK CALL
a. SCHEDULED b. NO SHOW/W.O. C. NOT SEEN d. NO TRANSPORT
e. WALK-IN
TOTAL SEEN
** JPPD TESTING
SEGREGATED POPULATION: SICK CALL
a. SCHEDULED b. NO SHOW/W.O. c. NOT SEEN d. NO TRANSPORT
TOTAL SEEN
INTERNAL CLINICS: 1. SPECIALITY
a. SCHEDULED b. NO SHOW/W.O. c. NOT SEEN d. NO TRANSPORT
TOTAL SEEN
2 . JCHRONIC DISEASE (CDC)
a . SCHEDULED b . NO SHOW/W.O. C. NOT SEEN d . NO TRANSPORT
TOTAL SEEN

MONTH

19

MINIMUM MEDIUM

YOUTH CENTER

TOTAL

Three Lorton Facilities Statistical Report Pajje Two

EXfrERNAL CLINICS:
T7FSPECIALITY
a. SCHEDULED b. NO SHOW/W.O. c. NOT SEEN d. NO TRANSPORT
TOTAL SEEN

Minimum Medium

Youth Center

2. INFECTIOUS DISEASE (IDC)
a. SCHEDULED b. NO SHOW/W.O. c. MOT SEEN d. NO TRANSPORT

TOTAL SEEN

DENTAL CLINIC:
a. SCHEDULED b. NO SHOW/W.O. I c. NOT SEEN d. NO TRANSPORT
TOTAL SEEN
PHARMACY
a. RX ORDERED b. RX FILLED
W/I 24 hrs.
EMERGENCY TRANSFER
a. DCGH b. HUH c. OTHER
INTAKE

Total

sba

Prepared by:

FACILITY

NAME

SPECIALTY CLINIC TRACKING FORM

DCDC#

CLINIC

ORDERED BY

ORDER DATE

APPT. DATE

MONTH
+ /-
COMPLIANCE

X
tr
F/U

*

DCDC#

DATE

NAME

COC LISTINGS CODE

PROBLEM

w
X
H-
tr
HCO
RETURN

LBW

Exhibit
CHRONIC DISEASE CLINIC: MONTHLY SUMMARY

FACILITY

DATE

CDC CLINIC HELD

YES

NO

MONTH REASON IF NOT HELD

CHIEF OR SENIOR PHYSICIAN

DATE

REASONS:

A.

Doctor not available (sick, snow, furlough, etc.)

B.

No patients scheduled

C.

Institution operational priorities (riot, lockdown, etc!

LBW

Exhibit 10

STAFF
DENTIST
DENT. AS ST.

MOM.

THREE LORTON FACILITIES WEEKLY DENTAL REPORT

STAFF

DATS:

TUBS. WED.

THURS.

FRI.

MINIMUM

"^—

TOTAL |
1

SCHED.

—I

NO SHOW

NOT

-

SEEN

NO TRANSP.

SEEK

SCHED. NO SHOW
NOT SEEN
NO TRANSP.
SEEN

MEDIUM YOUTH CENTER

SCHED.
NO SHOW
NOT SEEN NO TRANSP SEEN
SBS/97

1
PMFAMD IT I

(:•'"•>

Exhibit 11

DATE

THREE LORTOV JACILITIBS
sxcx CALL SUMMARY STATISTICS - DSMTAL

PACILITY

# SIGNED

/ SEEN

/ NOT SEEN

MONTH ABC DEF

REASONS:

DATE

A. INMATE DECLINED B. CANCELLED (INSTITUTION) C. CANCELLED (HEALTH SERVICES) D. NOT COMPLETED E. NO TRANSPORTATION/ESCORT F. NO SHOW

REVIEWED BY CHIEF MEDICAL OFFICER
lbw:1/97

FEB 15 '96 12: I I FROM SPC OFFICER OF COURT
r

Exhibit 12 PAGE

TRACXINO AND RECALL 8Y8TEX FOR ZXMATS8 RECBIVIMO P8YCHXATKXC CASH AT 1KB OCCOQUAV FACILITY

This system is designed to facilitate the orderly tracking and recall of inmates receiving psychiatric care at the Occoquan Facility. The procedure will be as follows:

1. A clinic logbook will be maintained so that all clinic appointments are recorded in a central location. The dates when a screening clinic will take place at Occoquan, for a three mont period, will be noted in the logbook.

2. Each sheet in the logbook will contain the following information for each clinic date: Name, DCDC, reason for referral, date to return to clinic and recommendation.

3. The nurse who notes a psychiatrist's order for a clinic appointment on the Psychiatric Consultation Sheet shall record the inmate's name, DCDC and reason for referral in the clinic logbook on the appropriate date in accordance with the psychiatrist's order. If the order is a medication order, the nurse shall also transcribe the order to the Patient Drug Administration Record.

4. At the end of each week, the weekend nurse shall reviei the clinic logbook for the prior week to verify that all "Retur To Clinic" dates have been transcribed in the logbook on the appropriate date in accordance with the psychiatrist• a order. The weekend nurse shall also verif' that any inmate who has missed an appointment has been rescheduled for the next availab clinic.

5. Any nurse who receives a referral for a new intake or request for an urgent assessment shall place th« Inmate's name, DCDC and reason for referral in the logbook on the next availab clinic date. If an emergency assessment is necessary, the nurs shall immediately contact the psychiatrist on call.

6. The logbook shall be reviewed by the nunse assisting with the clinic prior to each screening clinic. Each logbook entry will be used as the basis for the schedule of appointment on that date. A list containing the inmate's na»m, DCDC and location shall be submitted to the transport officer and th« medical records clerk.

\

7. If an inmate's clinic appointment is Biased due to

cancellation, the inmate's refusal, or any other reason, th«

inmate shall be rescheduled for the next available clinic dat

or earlier if clinically indicated.

INTAKE* MErVAL HEALTH 8 C R B B K . » _ ,

NAME: ALLERGIES:

DCDCf:

•vTE OF BIRTH:

A. MENTAL HEALTH HISTORY: (Check P o s i t i v e Response) ( ) Previous Mental Health Treatment:

( ) Previous Psychiatric Diagnosis:

( ) History of Depression/Suicidal/Self Injurious Behavior:

( ) Substance Abuse History;

( ) Eating Disorder:

__

( ) Psychiatric Medication/Dosage:

Anorexia Current

Bulimia

B. MENTAL STATUS ASSESSMENT: (Check All That Are Appropriate)

Orientation

Thought Disorder

Time

Disorganized

Paranoid/Delusional

Place

Incoherent

Hallucinations

Person

Impaired Concentration

No Abnormality

.Inappropriate Cooperative Talkative
Suicidal Ideation .Yes No Intent Plan:
Good Fair Poor

Anxious "Blunted "Tearful

_Withdrawn ^Depressed "Labile Euphoric

_Suspicious Aggressive

Homicidal Ideation

No Intent
Plan:

posture Good
pF°aoirr

Motor A c t i v i t y Agitated
Restless Slowed Normal

C. IMPRESS ION/EVALUATION.:

D. ELAN.:

continue Medication Type:

Refer to Psychiatrist

Consultation Completed: _Yes

Other:

E.

E2FVMZ)JmsWGi>
] Special Housing

.
[_ J Open Population

f [

, ^
] Other

INTERVIEWER/TITLE

DATE

y

FEB 15 ' 9 6 1 2 : l i

FROM SPC OFFICER OF COURT

PAGE.865

8. If an inmate misses two consecutive clinic appointments, mental health staff will interview the inmate to explain to hi» the importance of attending clinic appointments. If the inmate states that he does not intend to attend screening clinic, he will be asked to sign a medical refusal fora. If the inmate states that he intends to attend clinic but fails to do so, the information will be referred to the chief Psychiatrist for disposition.

J

(.;'

@!

Exhibit 13

PHARMACY ALERT***********
(DATE)
THE PHARMACY IS CURRENTLY OUT OF THE FOLLOWING:

Please call your designated pharmacist to discuss available substitutions.
The anticipated delivery date is:
Your will be notified upon its arrival.
Chief Pharmacist

FACILITY:
PATIENT'S NAME

Government of The District of Columbia Department of Corrections
THREE LORTON FACILITIES
TEMPORARILY OUT OF STOCK MEDICATIONS

MONTH

YEAR

DCDC NO.

MEDICATION

FORMULARY/ NON FOMULARY

DATE PRESCRIBED

DATE FILLED

SUBSTITUTE GIVEN

DATE GIVEN

I

DOCTOR'S ORDERS

Exhibit 15

THE DOCTOR SHALL RECORD DATE. TIME AND SIGN EACH SET OF ORDERS. IF PROBLEM ORIENTED MEDICAL RECORD SYSTEM IS USED. WRITE PROBLEM NUMBER IN COLUMN INDICATED BY ARROW BELOW.

PATIENT IDENTIFICATION NAME

OATE OF ORDER

TIME OF ORDER

HOURS

LIST TIME ORDER
NOTED AND SIGN

DOB

DCDC#

NURSING UNIT

ROOM NO.

BED NO.

PATIENT IDENTIFICATION
NAME DOB DCDC#

DATE OF ORDER

TIME OF ORDER

HOURS

NURSING UNIT

ROOM NO.

BED NO.

PATIENT IDENTIFICATION
NAME DOB DCOCi

DATE OF ORDER

TIME OF ORDER

HOURS

NURSING UNIT

ROOM NO.

BED J.

PATIENT IDENTIFICATION

DOB OCOC#

OATE OF ORDER

TIME OF ORDER

HOURS !

(

NURSING UNIT

ROOM NO.

BED NO

18*4

"I JSF R A M

DATE: PROVIDER:
INMATE NAME

OVER THE COUNTER MEDICATION LOG GENERAL POPULATION MINIMUM SECURITY FACILITY

w

ACETAMINOPHEN (12 TABLETS)
START TIME:

END TIME:

DCDC#

REFERRAL/COMMENT

INMATE SIGNATURE

t -•'•'"•

Reviewed by: LBW

Date:

'4 s'+ • 'J

DATE: i PROVIDER:
INMATE NAME

OVERTHE COUNTER MEDICATION LOG GENERAL POPULATION MINIMUM SECURITY FACILITY
HOLD TABLETS (12 TABLETS)

START TIME: END TIME:

DCDC#

REFERRALjCOMMENT

IMMATE SIGNATURE g }

w

DATE: PROVIDER:
(PRINT) INMATE NAME

OVERTHE COUNTER MEDICATION LOG GENERAL POPULATION MINIMUM SECURITY FACILITY
LAXATIVES (2 TABLETS)

START TIME: END TIME:

DCDC#

REFERRAL/COMMENT

INMATE SIGNATURE

Reviewed by:_ LBW

DATE: PROVIDER:
(PRINT) INMATE NAME

OVER THE COUNTER MEDICATION LOG GENERAL POPULATION MINIMUM SECURITY FACILITY
DENTAL DAMS (5 ITEMS)

START TIME: END TIME:

DCDC#

REFERRAL/COMMENT

INMATE SIGNATURE

Reviewed by:_

Date:

LBW

DATE: PROVIDER:
(PRINT) INMATE NAME

OVER-THE-COUNTER MEDICATION LOG GENERAL POPULATION MINIMUM SECURITY FACILITY
CONDOMS (5 ITEMS)

START TIME: END TIME:

DCDC#

REFERRAUCOMMENT

INMATE SIGNATURE

Reviewed by:_ LBW

Date:

DATE: PROVIDER:
INMATE NAME

OVER-THE COUNTER MEDICATION LOG GENERAL POPULATION MINIMUM SECURITY FACILITY
MENSTRUAL PAIN RELIEVER (4 TABLETS)
START TIME:
END TIME:

DCDCl

REFERRAL/COMMENT

INMATE SIGNATURE

Reviewed by: LBW

Date:

DATE: PROVIDER:
INMATE NAME

OVER THE COUNTER MEDICATION LOG GENERAL POPULATION MINIMUM SECURITY FACILITY
ANTACIDS (1 ROLL)

START TIME: END TIME:

DCDC#

REFERRAL/COMMENT

INMATE SIGNATURE

Reviewed by:. LBW

Date:

Hi •:• A

DCDC#

NAME

HEALTH SERVICES TB TRACKING FORM

FACILITY

AGE SENDING PPD DATE PPD DATE

CXR

INST.

DONE

READ

CXR RESULTS

COMMENTS

FOLLOW-UP

! \ \
LBW

 
 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

INMATES OF THREE LORTON FACILITIES,)

Plaintiffs,

)

) CA 92-1208

v.

)Judge June L. Green

)

DISTRICT OF COLUMBIA, et al.,

)

Defendants.

)

)
) SEP 2

ORDER ..„„„

Upon consideration of Plaintiffs' Motion for an Order to Show Cause Why the Defendants Should Not Be Held in Contempt, the Defendants' Opposition thereto, the Plaintiffs' Reply, and the
C7trecord herein, it is by the Court this Q^"" day of September, 1997
ORDERED that Plaintiffs' Motion is GRANTED; and it is further ORDERED that the Defendants shall show cause on or before the 2lst day of November, 1997, why they should not be held in contempt of Court for failure to comply with the terms of the remedial plan they filed February 21, 1997. The remedial plan was filed in response to this Court's Order of February 29, 1996, following Defendants' failure to implement the provisions of two consent decrees involving Plaintiffs' medical and mental health care needs. Today's Order gives Defendants nine months from the date they filed their remedial plan to comply with its provisions under both its terms and this Court's Order; and it is further

Inmates of Three Lorton Facilities v. D.C. PC-DC-005-006

ORDERED that the Clerk shall mail copies of this Order to:

Martin G. Hacala, Esq. Ross, Dixon & Masback, LLP 601 Pennsylvania Ave., N.W. North Building Washington, D.C. 20004-2688

Maria Amato, Esq. D.C. Corporation Counsel 441 Fourth Street, N.W. 6th Floor/South Washington, D.C. 20001

Grace M. Lopes, Esq. 1130 17th Street, N.W. Suite 400 Washington, D.C. 20036

Jonathan M. Smith, Esq. 1400 - 20th Street, N.W. Suite 117 Washington, D.C. 20036

JUNE L. GREEN United States District Cou , Judge

Cft/it

 
 District of Columbia live database - Docket Report

Page 1 of 24

CLOSED, TYPE-E
U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:92-cv-01208-JLG

DOE, et al v. DC, et al Assigned to: Judge June L. Green Demand: $0 Cause: 42:1983 Prisoner Civil Rights Plaintiff JANE DOE Inmates of the Medium Security Facility
Plaintiff ANTONIO SANTOS Inmates of the Medium Security Facility
V. Defendant DISTRICT OF COLUMBIA

Date Filed: 05/20/1992 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
represented by John Richard Gerstein, I ROSS, DIXON & BELL, LLP 2001 K Street, NW Washington, DC 20006-2688 (202) 662-2000 Fax: 202-662-2190 Email: jgerstein@rdblaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eric Robert Lotke 253 North Columbus Street Arlington, VA 22203-2648 (202) 276-9046 ATTORNEY TO BE NOTICED
represented by John Richard Gerstein, I (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eric Robert Lotke (See above for address) ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato CORPORATION COUNSEL FOR THE DISTRICT OF COLUMBIA 441 Fourth Street, NW Sixth Floor Washington, DC 20011 (202) 724-6642

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Defendant SHARON PRATT KELLY
Defendant WALTER B. RIDLEY Director, D.C. Department of Corrections
Defendant WILLIAM HALL Assistant Director for Health Services
Defendant GWEN H. WASHINGTON Associate Director for Programs
Defendant THOMAS P. GAYDOS Administrator, Medium Security Facility
Defendant PAUL KRULL Administrator, Minimum Security Facility
Defendant ANGELA BROWN Acting Administrator, Youth Center
Defendant DISTRICT OF COLUMBIA

Fax: (202) 727-3625 Email: maria.amato@dc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato

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GENERAL HOSPITAL COMMISSION an independent agency of the District of Columbia
Defendant
MARK CHASTING Executive Director, District of Columbia General Hospital

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Maria-Claudia T. Amato (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 05/20/1992
05/20/1992
05/20/1992 05/27/1992 06/10/1992 06/17/1992
06/17/1992
06/24/1992 06/24/1992 06/24/1992 07/06/1992 07/09/1992 07/09/1992

#

Docket Text

1 MOTION filed by plaintiffs for leave to file under seal an affidavit providing names of individual plaintiffs, and to permit use of pseudonyms in future filings Exhibit (ajr) (Entered: 05/21/1992)

2 ORDER by Judge John G. Penn : granting motion for leave to file under seal an affidavit providing names of individual plaintiffs, and to permit use of pseudonyms in future filings [1-1] by JOHN DOE, JOHN DOE, JANE DOE, JOHN DOE, JANE DOE (N) (ajr) (Entered: 05/21/1992)

3 COMPLAINT filed summons issued. Affidavit (affidavit filed under seal in Room 1800, per order of 5/20/92) (ajr) (Entered: 05/21/1992)

CASE REASSIGNED to Judge June L. Green (mw) (Entered: 06/02/1992)

4 MOTION filed by defendants to extend time to 6/24/92 within which to respond to plaintiffs' complaint (sm) (Entered: 06/11/1992)

5 ORDER by Judge June L. Green : granting motion to extend time to 6/24/92 within which to respond to plaintiffs' complaint [4-1] by defendant (N) (bjl) (Entered: 06/18/1992)

6 AFFIDAVIT OF SERVICE of summons and complaint upon Angela Brown, Sharon Pratt Kelly, Mark J. Chasting, John Payton, William Hall, M.D., DC, Mark J. Chasting, Gwen H. Washington, Thomas P. Gaydos, Paul Krull 5/20/92 (lpp) (Entered: 06/18/1992)

7 ANSWER for defendants, (lpp) (Entered: 06/30/1992)

CALENDARED (lpp) (Entered: 06/30/1992)

8 RESPONSE (OPPOSITIONS) by defendant to plaintiffs' suggestion of related case (lpp) (Entered: 06/30/1992)

9 REPLY by plaintiff(s)to response to response order [8-1] by defendant (lpp) (Entered: 07/07/1992)

10 MEMORANDUM (N) (bjl) (Entered: 07/09/1992)

11 ORDER by Judge June L. Green denying defts' request that this case be

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07/24/1992 07/24/1992 07/24/1992 07/24/1992 07/24/1992 07/24/1992 08/06/1992 08/12/1992
08/21/1992 08/25/1992
08/25/1992 08/25/1992 10/02/1992 10/02/1992 11/05/1992

randomly reassigned to another judge of the United States District Court for the District of Columbia. : (N) (bjl) (Entered: 07/09/1992)
12 MOTION filed by plaintiff(s) to appoint an independent expert witness (ks) (Entered: 07/27/1992)
13 NOTICE TO TAKE DEPOSITION by plaintiff(s) of defendant DC (ks) (Entered: 07/27/1992)
14 INTERROGATORIES filed by plaintiff(s) to all defendants (ks) (Entered: 07/27/1992)
15 REQUEST by plaintiff(s) to all defendants for production of documents (ks) (Entered: 07/27/1992)
16 MOTION filed by plaintiff(s) for class certification (ks) (Entered: 07/27/1992)
17 MOTION filed by plaintiff(s) to file under seal plaintiffs' applications to proceed in forma pauperis (ks) (Entered: 07/27/1992)
18 MOTION filed by defendant to extend time to 8/21/92, to respond to Plaintiffs' Motion to appoint an independent expert witness (lpp) (Entered: 08/07/1992)
19 ORDER by Judge June L. Green granting motion of defendants for enlargement of time to August 21, l992, but not beyond, to respond to plaintiff's motion to appoint an independent expert witness. : (N) (bjl) (Entered: 08/12/1992)
20 RESPONSE by defendant in opposition to motion to appoint an independent expert witness [12-1] by JOHN DOE, JOHN DOE, JANE DOE, JOHN DOE, JANE DOE (lpp) (Entered: 08/24/1992)
21 ORDER by Judge June L. Green : granting motion to file under seal plaintiffs' applications to proceed in forma pauperis [17-1] by JOHN DOE, JOHN DOE, JANE DOE, JOHN DOE, JANE DOE (N) (bjl) (Entered: 08/26/1992)
22 ORDER by Judge June L. Green : denying motion to appoint an independent expert witness [12-1] by JOHN DOE, JOHN DOE, JANE DOE, JOHN DOE, JANE DOE (N) (bjl) (Entered: 08/26/1992)
23 ORDER by Judge June L. Green : granting motion for class certification [16-1] by JOHN DOE, JOHN DOE, JANE DOE, JOHN DOE, JANE DOE (N) (bjl) (Entered: 08/26/1992)
24 ANSWER by defendant to first set of interrogatories (lpp) (Entered: 10/06/1992)
25 RESPONSE by defendants to request for production of documents (lpp) (Entered: 10/06/1992)
26 STIPULATED ORDER by Judge June L. Green : regarding discovery (N) (lpp) (Entered: 11/06/1992)

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11/23/1992 11/25/1992 11/25/1992 12/07/1992
12/31/1992 01/12/1993 01/13/1993 01/25/1993 02/10/1993 02/10/1993 02/12/1993 02/18/1993
03/02/1993
03/05/1993 03/05/1993
03/15/1993 03/17/1993

27 STIPULATED ORDER by Judge June L. Green regarding confidential information. : (N) (bjl) (Entered: 11/23/1992)
28 SUPPLEMENTAL RESPONSE by defendant to request for production of documents (lpp) (Entered: 11/27/1992)
29 SUPPLEMENTAL ANSWERS by defendant to interrogatories (lpp) (Entered: 11/27/1992)
30 NOTICE TO TAKE DEPOSITION by plaintiff(s) of defendant THOMAS P. GAYDOS, defendant PAUL - KRULL, defendant ANGELA - BROWN and DOUGLAS STEMPSON (lpp) (Entered: 12/08/1992)
31 MOTION filed by defendant DC for discovery sanctions Exhibits: 1-10 (lpp) (Entered: 01/04/1993)
32 RESPONSE by defendants in opposition to motion for discovery sanctions [31-1] by DC; Exhibits (5) (ks) (Entered: 01/14/1993)
33 NOTICE TO TAKE DEPOSITION by plaintiff(s) of Vince Gibbons (dmb) (Entered: 01/14/1993)
34 REPLY by plaintiff(s)to response to motion for discovery sanctions [311] by DC, Exhibit (6) (lpp) (Entered: 01/26/1993)
35 NOTICE TO TAKE DEPOSITION by plaintiffs of Raymond Preston (lpp) (Entered: 02/11/1993)
36 NOTICE TO TAKE DEPOSITION by plaintiffs of Jack Lawlah (lpp) (Entered: 02/11/1993)
37 INTERROGATORIES and request to produce documents filed by defendant to plaintiff(s) , (lpp) (Entered: 02/16/1993)
38 ORDER by Judge June L. Green setting a hearing on motion for discovery sanctions for March 2, l993 at l0:00 A.M. : (N) (bjl) (Entered: 02/19/1993)
MOTION by plaintiffs for sanction heard and taken under advisement, before Judge June L. Green Reporter: Harry Deutsch (bjl) (Entered: 03/02/1993)
39 NOTICE by defendant of Discovery statement pursuant to this Court's Order on 3/2/93 (lpp) (Entered: 03/08/1993)
40 NOTICE by plaintiff(s) to the Court pursuant to the Court's request 3/2/93, of Plaintiffs' list of documents and categories of documents not produced by the District of Columbia defendants (lpp) (Entered: 03/08/1993)
41 ANSWER by plaintiff(s) to interrogatories and response to request for production of documents [37-1] (lpp) (Entered: 03/16/1993)
42 NOTICE TO TAKE DEPOSITION by plaintiff(s) of Humaira Ali,

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04/19/1993 04/19/1993 05/11/1993 05/11/1993 05/25/1993
06/11/1993 06/15/1993
06/16/1993 06/16/1993 06/25/1993 06/25/1993 06/25/1993
06/29/1993 07/13/1993
07/28/1993 07/28/1993

Paulos Kidane, Sunday Nuwasu, Kamal Ghaemi, Rufus Jones (lpp) (Entered: 03/18/1993)
43 NOTICE TO TAKE DEPOSITION by plaintiff(s) of Paula RobinsonArrieta (lpp) (Entered: 04/20/1993)
44 NOTICE TO TAKE DEPOSITION by plaintiff(s) of Angela Brown (lpp) (Entered: 04/20/1993)
MOTION HEARING held before Judge June L. Green Reporter: Vernell Marshall (bjl) (Entered: 05/11/1993)
45 STIPULATED ORDER by Judge June L. Green to take video deposition of Dr. Paula Robinson-Arrieta. : (N) (bjl) (Entered: 05/11/1993)
46 ORDER by Judge June L. Green : denying motion for discovery sanctions [31-1] by pltffs; setting forth instructions for the parties; directing parties to file notices of outstanding discovery requests with the Court by 6/14/93. (N) (bjl) (Entered: 05/25/1993)
47 JOINT MOTION by plaintiff(s), defendant to extend time to 6/25/93, to file notices of outstanding discovery requests (lpp) (Entered: 06/14/1993)
48 ORDER by Judge June L. Green : granting joint motion to extend time to 6/25/93, to file notices of outstanding discovery requests [47-1] by defendants,and plaintiff(s) (N) (bjl) (Entered: 06/15/1993)
49 RESPONSE by defendant to request for production of documents (lpp) (Entered: 06/17/1993)
50 SUPPLEMENTAL ANSWER by defendant to interrogatories (lpp) (Entered: 06/17/1993)
51 NOTICE by plaintiff(s) of outstanding discovery requests (lpp) (Entered: 06/29/1993)
52 NOTICE by defendant of outstanding discovery requests (lpp) (Entered: 06/29/1993)
53 THIRD SUPPLEMENTAL ANSWER by defendant to interrogatories and response to request for production of documents [15-1], [14-1] (lpp) (Entered: 06/29/1993)
54 NOTICE to the Court by defendant of Outstanding Discovery Request (lpp) (Entered: 07/01/1993)
55 NOTICE OF FILING by defendant of a copy of a sample shift report referenced Defendant's Notice of Outststanding Discovery Requests (lpp) (Entered: 07/16/1993)
56 NOTICE TO TAKE DEPOSITION of Dalton C. Allen by plaintiff(s). (pm) (Entered: 07/29/1993)
57 NOTICE TO TAKE DEPOSITION of Herman E. Branson by plaintiff(s). (pm) (Entered: 07/29/1993)

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07/28/1993 07/28/1993 07/28/1993 07/28/1993 07/28/1993 07/28/1993 07/28/1993 07/29/1993 08/01/1993
08/17/1993 08/25/1993 08/31/1993 09/07/1993
09/21/1993
10/05/1993 10/12/1993 10/12/1993

58 NOTICE TO TAKE DEPOSITION of Anthony Butler by plaintiff(s). (pm) (Entered: 07/29/1993)
59 NOTICE TO TAKE DEPOSITION of Nader Marzban by plaintiff(s). (pm) (Entered: 07/29/1993)
60 MOTION filed by defendant DC GENERAL HOSP. COM for protective order (pm) (Entered: 07/29/1993)
61 NOTICE TO TAKE DEPOSITION of Arthur Graves by plaintiff(s). (lpp) (Entered: 07/29/1993)
62 NOTICE TO TAKE DEPOSITION of William Plaut by plaintiff(s). (lpp) (Entered: 07/29/1993)
63 NOTICE TO TAKE DEPOSITION of William H. Hall by plaintiff(s). (lpp) (Entered: 07/29/1993)
64 NOTICE TO TAKE DEPOSITION of Henry Edwards by plaintiff(s) (lpp) (Entered: 07/29/1993)
65 MOTION filed by defendant DC GENERAL HOSP. COM for protective order (lpp) (Entered: 07/30/1993)
66 RESPONSE by plaintiff(s) in opposition to motion for protective order [65-1] by DC GENERAL HOSP. COM, Exhibits (13) (lpp) (Entered: 08/12/1993)
67 REPLY by defendant DC to response to motion for protective order [651] by DC GENERAL HOSP. COM (lpp) (Entered: 08/18/1993)
68 NOTICE TO TAKE DEPOSITION of District of Columbia by plaintiff (s). (lpp) (Entered: 08/26/1993)
69 NOTICE OF FILING by defendant DC GENERAL HOSP. COM of Affidavit of Vivian Iglehart, M.D. (lpp) (Entered: 09/01/1993)
70 MOTION filed by defendant MARK CHASTING, defendant DC GENERAL HOSP. COM, defendant ANGELA BROWN, defendant PAUL - KRULL, defendant THOMAS P. GAYDOS, defendant GWEN H WASHINGTON, defendant WILLIAM HALL, defendant WALTER B. RIDLEY, defendant SHARON PRATT KELLY, defendant DC to compel Discovery , Exhibit (2) (lpp) (Entered: 09/08/1993)
71 RESPONSE by plaintiffs in opposition to motion to compel Discovery [70-1] by defendants, Exhibit: (7) bulky pleading (lpp) (Entered: 09/22/1993)
72 REPLY by defendant to response to motion to compel Discovery [70-1] by defendants (lpp) (Entered: 10/06/1993)
73 NOTICE TO TAKE DEPOSITION of Jane Doe I by defendant. (bjl) (Entered: 10/12/1993)
74 NOTICE TO TAKE DEPOSITION of John Doe II by defendant. (bjl)

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10/12/1993 10/12/1993 10/12/1993 11/09/1993 11/23/1993 12/15/1993 12/15/1993
12/17/1993 01/13/1994 01/14/1994 01/14/1994 01/14/1994 01/26/1994
02/07/1994
02/18/1994

(Entered: 10/12/1993)
75 NOTICE TO TAKE DEPOSITION of Jane Doe II by defendant. (bjl) (Entered: 10/12/1993)
76 NOTICE TO TAKE DEPOSITION of John Doe I by defendant. (bjl) (Entered: 10/12/1993)
77 NOTICE TO TAKE DEPOSITION of John Doe III by defendant. (bjl) (Entered: 10/12/1993)
78 MOTION filed by defendant for protective order , attachment (2) (lpp) (Entered: 11/10/1993)
79 RESPONSE by plaintiff(s) in opposition to motion for protective order [78-1] by defendants (lpp) (Entered: 11/26/1993)
80 MEMORANDUM by Judge June L. Green (N) (bjl) (Entered: 12/15/1993)
81 ORDER by Judge June L. Green : granting motion for protective order [60-1] by DC GENERAL HOSP. COM; directing that the minutes, records and reports generated in "peer review" meetings at D.C. General Hospital are privileged and shall not be produced for purposes of discovery; further directing that defendant must produce all "quality assurance records" that are not "pper review" meeting documents to the plaintiffs forthwith.(N) (bjl) (Entered: 12/15/1993)
82 REPLY by defendants to response to plaintiffs' opposition to defendants' motion for a protective order. (bjl) (Entered: 12/20/1993)
83 MOTION filed by plaintiff(s) for entry of a scheduling order and trial date (lpp) (Entered: 01/14/1994)
84 NOTICE TO TAKE DEPOSITION of Kathy Byrnes by plaintiff(s). (bjl) (Entered: 01/24/1994)
85 NOTICE TO TAKE DEPOSITION of Walter Ridley by plaintiff(s). (bjl) (Entered: 01/24/1994)
86 NOTICE TO TAKE DEPOSITION of Tom Carter by plaintiff(s). (bjl) (Entered: 01/24/1994)
87 RESPONSE by defendant in opposition to motion for entry of a scheduling order and trial date [83-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE, Exhibit (4) . (lpp) Modified on 01/29/1994 (Entered: 01/29/1994)
88 REPLY by plaintiff(s) JOHN DOE, plaintiff(s) JOHN DOE, plaintiff(s) JANE DOE, plaintiff(s) JOHN DOE, plaintiff(s) JANE DOE to response to motion for entry of a scheduling order and trial date [83-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE, Exhibit (1) (lpp) (Entered: 02/09/1994)
89 PURSUANT TO COURT ORDER DATED 2/24/94, THIS PLEADING

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02/24/1994 02/24/1994 02/24/1994
02/24/1994 03/08/1994 03/09/1994 03/11/1994
03/11/1994 03/15/1994 04/07/1994 04/14/1994 04/26/1994 05/04/1994 05/04/1994

IS STRICKEN: REPLY by defendant reply [88-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE (lpp) Modified on 03/01/1994 (Entered: 02/23/1994)
90 ORDER by Judge June L. Green : denying motion for entry of a scheduling order and trial date [83-1] by plaintiffs; status hearing set for 2:00 3/11/94 ; (N) (bjl) (Entered: 02/24/1994)
91 MEMORANDUM (N) (bjl) (Entered: 02/24/1994)
92 ORDER by Judge June L. Green : granting motion to compel Discovery [70-1] by defendants; directing plaintiffs supplement their response to defendants' interrogatories and provide responses to defendants' "contention interrogatories" on or before 3/8/94; directing that defendants' Reply to plaintiffs' Opposition is stricken from the record of this case.. (N) (bjl) (Entered: 02/24/1994)
Text not available. (Entered: 02/24/1994)
93 MOTION filed by defendant to extend time to to file a joint stipulation (lpp) (Entered: 03/09/1994)
94 ORDER by Judge June L. Green : granting motion to extend time to March 14, 1994, to file a joint stipulation [93-1] by defendants (N) (bjl) (Entered: 03/09/1994)
95 ORDER by Judge June L. Green : striking defendants' reply to plaintiffs' reply to defendants' opposition to plaintiffs' motion for entry of a scheduling order and establishment of a trial date (N) (lpp) (Entered: 03/15/1994)
STATUS HEARING before Judge June L. Green : defendant shall submit certain documents to Chambers by 5/11/94; status hearing set for 10:00 6/3/94 ; Reporter: Laura Beasley (bjl) (Entered: 03/16/1994)
96 CONFIDENTIALITY STIPULATION AND ORDER by Judge June L. Green setting forth instructions.: (N) (bjl) (Entered: 03/16/1994)
97 MOTION filed by plaintiff(s) for preliminary injunction Exhibits (4) (lpp) (Entered: 04/08/1994)
98 RESPONSE by defendant in opposition to motion for preliminary injunction [97-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE, Declaration (1) (lpp) (Entered: 04/15/1994)
99 REPLY MEMORANDUM by plaintiffs in support of their motion for preliminary injunction; attachments A through J. (bjl) (Entered: 04/28/1994)
100 INTERROGATORIES (second) filed by plaintiffs to defendants. (bjl) (Entered: 05/05/1994)
101 REQUEST by plaintiffs to defendants for production of documents (bjl) (Entered: 05/05/1994)

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05/10/1994
06/03/1994 06/10/1994 06/29/1994 07/06/1994 07/11/1994 07/11/1994 07/12/1994 07/13/1994
07/26/1994 07/28/1994 08/02/1994 08/11/1994 08/11/1994 08/11/1994

102 MEMORANDUM by plaintiff(s) JOHN DOE, plaintiff(s) JOHN DOE, plaintiff(s) JANE DOE, plaintiff(s) JOHN DOE, plaintiff(s) JANE DOE regarding the Court's in camera review of documents Exhibits (7), no (h) exhibit (lpp) (Entered: 05/11/1994)
STATUS HEARING before Judge June L. Green : status hearing set for 10:00 7/12/94 ; Reporter: Robert Weber (bjl) (Entered: 06/03/1994)
103 TRANSCRIPT filed for date of 6/3/94. Reporter: Robert M. Weber (Pages 1-30) (bm) (Entered: 06/13/1994)
104 MOTION filed by defendant to extend time nunc pro tunc to 6/13/94 within which to file defendants' redacted documents with Chambers (bm) (Entered: 06/30/1994)
105 ORDER by Judge June L. Green : granting motion to extend time nunc pro tunc to 6/28/94 within which to file defendants' redacted documents with Chambers [104-1] by defendants. (N) (jeb) (Entered: 07/07/1994)
106 STATUS REPORT by defendants (adc) (Entered: 07/12/1994)
107 STATUS REPORT by plaintiffs; attachments (6). (tth) (Entered: 07/12/1994)
STATUS HEARING before Judge June L. Green : Reporter: Vernel Marshall (pm) (Entered: 07/22/1994)
108 ORDER by Judge June L. Green : granting motion for preliminary injunction [97-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE pretrial conference set for 4:00 11/1/94 ; trial set for 10:00 11/14/94 ; , and directing the defendants to provide a memorandum of law explaining the legal grounds for the redactions that the defendants have made on the documents which it has submitted to the Court for in camera review due by 7/26/94; directing the plaintiffs to respond to the defendants' memorandum explaining the redactions which the defendants have made on the documents submitted for in camera review due by 8/2/94 (N) (jeb) (Entered: 07/13/1994)
110 MEMORANDUM/Statement by defendant regarding redacted documents (lpp) (Entered: 08/01/1994)
109 MOTION filed by defendant for order setting a pretrial discovery schedule ; exhibits (5) (cjp) (Entered: 07/31/1994)
111 RESPONSE (OPPOSITIONS) by plaintiff(s) to notice [110-1] by defendant, Attachment (A) (lpp) (Entered: 08/03/1994)
112 NOTICE TO TAKE DEPOSITION of Dr. William Hall by plaintiffs (jeb) (Entered: 08/16/1994)
113 RESPONSE by plaintiff(s) in opposition to motion for order setting a pretrial discovery schedule [109-1] by defendants, Exhibits: (5) . (lpp) (Entered: 08/16/1994)
114 NOTICE TO TAKE DEPOSITION of Margaret Moore by plaintiff(s).

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08/11/1994 08/24/1994
11/02/1994 11/02/1994 11/07/1994
11/18/1994 11/22/1994 11/22/1994 12/02/1994
12/07/1994 12/12/1994

(lpp) (Entered: 08/16/1994)
115 NOTICE TO TAKE DEPOSITION of Nader Marzban, by plaintiff(s). (lpp) (Entered: 08/16/1994)
116 STIPULATED ORDER by Judge June L. Green : withdrawing defendants' 7/28/94 motion to enter an order setting a pretrial discovery schedule and plaintiffs' 8/11/94 response memorandum to defendants' motion for a scheduling order; directing the parties to negotiate an alternative schedule for the completion of discovery before the 11/14/94 trial date. (N) (jeb) (Entered: 08/25/1994)
STATUS HEARING before Judge June L. Green : held status hearing set for 10:00 11/22/94 ; Reporter: Carrie Gansie (lpp) (Entered: 11/02/1994)
117 MOTION filed by plaintiff to issue notice, Attachments: Proposed settlement of class action and consent decree (lpp) (Entered: 11/03/1994)
118 ORDER by Judge June L. Green : granting plaintiffs' motion to issue notice; directing that the attached Notice of Proposed Settlement of Class Action be issued by; 1) posting the Notice in all inmate housing units of the Three Lorton Facilities and 2) making additional copies of the Notice available to inmates at a central location in all housing units of the Three Lorton Facilities; Attachments. (N) , [117-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE (N) (bjl) (Entered: 11/08/1994)
119 MOTION filed by plaintiffs for fees and costs , or, in the alternative for an adjudication of prevailing party status , and for an order pursuant to Local Rule 215 directing the parties to negotiate fees and costs (lpp) (Entered: 11/21/1994)
120 CONSENT DECREE, signed 11/22/94 by Judge June L. Green; Attorneys for plaintiffs and defendants, all discovery in this case shall be stayed and the trial scheduled for 11/14/94, shall be continued idefinitely (lpp) (Entered: 11/23/1994)
STATUS HEARING before Judge June L. Green: held, parties to submit amend decree to Court; Reporter: Vernell Marshall (lpp) (Entered: 11/25/1994)
121 RENEWED MOTION filed by plaintiff JOHN DOE, plaintiff JOHN DOE, plaintiff JANE DOE, plaintiff JOHN DOE, plaintiff JANE DOE for attorney fee and costs or for an adjudication of prevailing party status and an order pursuant to Local Rule 215 directing the parties to negotiate fees and costs (lpp) (Entered: 12/05/1994)
122 MOTION filed by plaintiff JOHN DOE, plaintiff JOHN DOE, plaintiff JANE DOE, plaintiff JOHN DOE, plaintiff JANE DOE to issue notice of amended settlement (lpp) (Entered: 12/09/1994)
123 ORDER by Judge June L. Green directing that the attached Notice of Amended Settlement of Class Action be issued by: (1) posting the Notice in all inmate housing units of the Three Lorton Facilities and (2) making

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12/12/1994 12/13/1994 12/15/1994
12/20/1994 01/25/1995 03/23/1995
04/03/1995
04/12/1995 04/18/1995
04/19/1995
04/28/1995 05/08/1995 05/17/1995 05/18/1995
05/31/1995

additional copies of the Notice available to inmates at a central location in all housing units of the Three Lorton Facilities. ATTACHMENT: Notice of Amended Settlement of Class Action. : (N) (bjl) (Entered: 12/13/1994)
124 CONSENT DECREE (N) (bjl) (Entered: 12/13/1994)
125 NOTICE TO TAKE DEPOSITION of John Thomas by plaintiffs. (bm) (Entered: 12/14/1994)
126 RESPONSE by defendant in opposition to motion for attorney fee and costs [121-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE . (lpp) (Entered: 12/19/1994)
127 Text not available. (Entered: 12/22/1994)
128 NOTICE TO TAKE DEPOSITION of District of Columbia by plaintiffs. (bjl) (Entered: 01/26/1995)
129 NOTICE OF FILING by defendant: medical coverage plan for compliance with section II.A and II.B of the Interim Consent Decree, Attachment (1) (lpp) (Entered: 03/24/1995)
130 STIPULATED ORDER by Judge June L. Green : setting forth instructions to counsel; setting a status conference for 4/19/95 at 10:00 a.m. (N) (bjl) (Entered: 04/04/1995)
131 NOTICE OF FILING by defendants: Documents indicating the status of the defendants' compliance, attachments (2) (lpp) (Entered: 04/13/1995)
132 NOTICE OF FILING by defendants: Supplemental status of Defendants' compliance with paragraphs II(a) and II(b) of the interim consent decree (lpp) (Entered: 04/19/1995)
STATUS HEARING before Judge June L. Green : Oral motion by plaintiff to hold DC in contempt and to appoint Grace Lopes as special master heard and denied. Reporter: Zebhyra Hatcher (ted) (Entered: 04/19/1995)
133 STATUS REPORT by Special Master Grace Lopes (lpp) (Entered: 05/01/1995)
134 STATUS REPORT by Grace M. Lopes (lpp) (Entered: 05/09/1995)
135 MOTION filed by defendant DC to extend time to 5/19/95 to submit proposed supplemental decree (ted) (Entered: 05/18/1995)
136 ORDER by Judge June L. Green : granting motion to extend time to 5/19/95 to submit proposed supplemental decree [135-1] by DC (N) (ted) (Entered: 05/18/1995)
137 STIPULATED ORDER/SUPPLEMENTAL CONSENT DECREE ON STAFFING ISSUES by Judge June L. Green : (N) (bjl) (Entered: 05/31/1995)

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06/13/1995
06/14/1995 06/15/1995 06/26/1995
07/06/1995
07/12/1995 07/12/1995
08/01/1995 08/22/1995 08/29/1995 08/31/1995

140 SUPPLEMENTAL MEMORANDUM to motion for attorney fee and costs [121-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE, or in the alternative, for an adjudication of prevailing party status and an order pursuant to Local Rule 215 directing the parties to negotiate fees and costs (lpp) (Entered: 06/16/1995)
138 MOTION of Special Officer filed to extend time to 7/14/95 to comply with the June 14, 1995 sick call reporting deadline (jeb) (Entered: 06/15/1995)
139 ORDER by Judge June L. Green : granting motion to extend time to 7/14/95 to comply with the June 14, 1995 sick call reporting deadline [138-1] (N) (bjl) (Entered: 06/16/1995)
141 SUPPLEMENTAL MEMORANDUM to defendants opposition to plaintiffs supplement to their renewed motion for fees and costs or, in the alternative, for an adjudication of prevailing party status and an order pursuant to local rule 215 directing the parties to negotiate fees and costs [126-1] by defendants; attachment (1). (jeb) Modified on 06/27/1995 (Entered: 06/27/1995)
142 REPLY MEMORANDUM by plaintiff JOHN DOE, plaintiff JOHN DOE, plaintiff JANE DOE, plaintiff JOHN DOE, plaintiff JANE DOE in support of supplemental memorandum [140-1] to plaintiffs' renewed motion for fees and costs or, in the alternative, for an adjudication of prevailing party status and an order pursuant to Local Rule 215 directing the parties to negotiate fees and costs. (jeb) (Entered: 07/07/1995)
143 MEMORANDUM (N) (bjl) (Entered: 07/12/1995)
144 ORDER by Judge June L. Green : granting motion for an adjudication of prevailing party status and an order pursuant to Local Rule 215 directing the parties to negotiate fees and costs [121-2] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE (N) (bjl) (Entered: 07/12/1995)
145 STIPULATED ORDER by Judge June L. Green extending time to 8/11/95 for filing a status report on the progress of negotiations as required in the Court's July 12, 1995 Order. : (N) (bjl) (Entered: 08/02/1995)
146 STIPULATED ORDER by Judge June L. Green : status hearing set for 8/30/95 to discuss plaintiffs' petition for fees and costs. (N) (ted) (Entered: 08/23/1995)
147 MOTION filed by plaintiff JOHN DOE, plaintiff JOHN DOE, plaintiff JANE DOE, plaintiff JOHN DOE, plaintiff JANE DOE for order to show cause why the defendants' sould not be held in contempt of court ; exhibits (14) (JMF) (Entered: 08/30/1995)
148 STIPULATED ORDER by Judge June L. Green : parties have until 9/15/95 to report to the Court on the status of their discussions (N) (ted) (Entered: 08/31/1995)

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09/12/1995 09/13/1995 09/19/1995 10/02/1995 10/04/1995 10/12/1995 10/16/1995 10/18/1995 10/24/1995 10/24/1995
10/27/1995 11/03/1995 12/04/1995

149 MOTION (UNOPPOSED) filed by defendant to extend time to oppose plaintiff's motion for order to show cause why defendants should not be held in contempt of court filed nunc pro tunc to September 11,1995 (JMF) (Entered: 09/13/1995)
150 ORDER by Judge June L. Green : granting unopposed motion to extend time to oppose plaintiff's motion for order to show cause why defendants should not be held in contempt of court filed nunc pro tunc to September 11,1995 [149-1] by defendants. (N) (bjl) (Entered: 09/13/1995)
151 STIPULATED ORDER by Judge June L. Green : status report due 10/6/95. (N) (bjl) (Entered: 09/22/1995)
152 MOTION filed by defendants' to extend time to 10/16/95 to oppose plaintiffs' motion for order to show cause why defendants should not be held in contempt of court (JMF) (Entered: 10/03/1995)
153 RESPONSE by plaintiff in opposition to motion to extend time to 10/16/95 to oppose plaintiffs' motion for order to show cause why defendants should not be held in contempt of court [152-1] by defendants'; exhibits (7) (JMF) (Entered: 10/05/1995)
154 ORDER by Judge June L. Green : granting motion to extend time to 10/16/95, but no further, to oppose plaintiffs' motion for order to show cause why defendants should not be held in contempt of court [152-1] by defendants (N) (bjl) (Entered: 10/12/1995)
155 RESPONSE by defendants' in opposition to motion for order to show cause why the defendants' should not be held in contempt of court [1471] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE; exhibits (22) . (JMF) (Entered: 10/18/1995)
156 SUPPLEMENTAL MEMORANDUM by defendant in support of in opposition to plaintiff's motion to show cause why defendants should not be held in contempt of Court [155-1] by defendants'; exhibits (3) (JMF) Modified on 10/19/1995 (Entered: 10/19/1995)
157 Text not available. (Entered: 10/25/1995)
158 MOTION filed by plaintiff for joinder in request that the special officer be authorized to conduct an investigation into new enforcement mechanisms that will insure the defendants' compliance with this Court's orders concerning medical and mental health services at lorton (JMF) (Entered: 10/27/1995)
159 REPLY by plaintiffs' in further support of their motion for order to show cause why the defendants' should not be held in contempt of court [1471]; exhibits (6) (JMF) Modified on 10/30/1995 (Entered: 10/30/1995)
160 Text not available. (Entered: 11/03/1995)
162 REPLY by plaintiffs' to defendants' November 24, 1995 notice of filing concerning plaintiffs' joinder in request that the special officer be authorized to conduct an investigation into new enforcement mechanisms

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12/05/1995 12/18/1995 01/02/1996 01/22/1996 01/30/1996
02/07/1996
02/20/1996 02/22/1996 02/26/1996 02/27/1996
02/27/1996
02/29/1996 02/29/1996

that will insure the defendants' compliance with this court's orders concerning medical and mental health services at Lorton. (JMF) (Entered: 12/06/1995)
161 MOTION filed by plaintiff for emergency relief ; exhibits (11) (JMF) (Entered: 12/06/1995)
163 RESPONSE by defendant in opposition to motion for emergency relief [161-1] by plaintiffs; Attachment (ted) (Entered: 12/19/1995)
164 REPLY by plaintiffs' in support of their motion for emergency relief [161-1]; exhibits (6) (JMF) (Entered: 01/03/1996)
165 ORDER (Copy) by Judge June L. Green : motion hearing set for oral argument on 1:30 1/31/96 ; (Original filed in CA 79-1726) (N) (ks) (Entered: 01/23/1996)
166 ORDER by Judge June L. Green : hearing on plaintiffs' motion for order to show cause why defendants should not be held in contempt and plaintiffs' motion for emergency relief, is set for 11:00 2/26/96 ; (N) (bjl) (Entered: 01/31/1996)
167 ORDER by Judge June L. Green directing that defendants shall report to the Court in writing, no later than 4/2/96, on their progress in hiring a correctional health care coordinator with systemwide supervisory authority over the provision of medical and mental health services at Lorton; if a coordinator is not hired by 4/2/96, oral argument is set for 4/10/96 at 1:30 P.M. : (N) (bjl) (Entered: 02/08/1996)
168 MOTION filed by defendant to continue the contempt hearing scheduled February 26, 1996 (JMF) (Entered: 02/21/1996)
169 ORDER by Judge June L. Green : denying motion to continue the contempt hearing scheduled February 26, 1996 [168-1] by defendants. (N) (bjl) (Entered: 02/22/1996)
HEARING on plaintiffs motion for contempt and for emergency relief begun and continued to 9:30 A.M. on 2/27/96. Reporter: Susan Tyner (bjl) Modified on 02/27/1996 (Entered: 02/27/1996)
HEARING before Judge June L. Green on plaintiffs' motion for contempt and for emergency relief resumes and concluded and taken under advisement by the Court. Reporter: Phyllis Merana (bjl) (Entered: 02/27/1996)
170 NOTICE OF FILING by defendants' of request to file proposals to remedy or address any findings as a result of plaintiffs' motion to show cause why defendants' should not be held in contempt of court. (JMF) (Entered: 02/28/1996)
ENTERED IN ERROR (See No. 173) (bjl) Modified on 04/02/1996 (Entered: 02/29/1996)
173 ORDER by Judge June L. Green : setting forth a schedule to remedy the

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03/13/1996 04/01/1996
04/01/1996 04/02/1996 04/11/1996 04/17/1996 04/29/1996 04/30/1996
05/03/1996 05/06/1996

District's noncompliance; setting a status conference on 6/5/96 to report on the progress made in implementing this Order. (N) implementing this order. (N) (bjl) Modified on 04/02/1996 (Entered: 04/02/1996)
171 MOTION filed by plaintiff awarding costs to plaintiff JOHN DOE , or, in the alternative, for order pursuant to Rule 215 directing the parties to negotiate fees and costs (JMF) Modified on 03/14/1996 (Entered: 03/14/1996)
172 STIPULATED ORDER by Judge Joyce Hens Green for Judge June L. Green : allowing the parties 30 days from the date of this order to negotiate plaintiffs' claim for fees at which time the parties shall submit a status report advising the Court of the progress of their fee negotiations. (N) (bjl) (Entered: 04/02/1996)
174 NOTICE OF APPEAL by defendant from order [173-2] , entered on: April 02, 1996. No fee paid/D.C. Gov't; Copies mailed to Maria C. Amato and John R. Gerstein I. (JMF) (Entered: 04/02/1996)
TRANSMITTED PRELIMINARY RECORD on appeal [174-1] by defendants' to U.S. Court of Appeals (JMF) (Entered: 04/02/1996)
USCA # 96-7074 assigned for appeal [174-1] by defendants (JMF) (Entered: 04/12/1996)
STATUS HEARING before Judge June L. Green : status hearing set for 2:00 5/29/96 for the parties to return to court for an update of report and recommendations of Grace Lopes on the facilities; , and status hearing set for 2:00 6/19/96 ; Reporter: Frank Rangus (JMF) (Entered: 04/26/1996)
175 MOTION (EMERGENCY) filed by plaintiff for the court appointment of Grace M. Lopes as an expert witness under F.R. of evidence 706 (JMF) (Entered: 05/01/1996)
180 ORDER by Judge June L. Green : granting motion for the court appointment of Grace M. Lopes as an expert witness under F.R. of evidence 706 [175-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE; Directing that the orders of the court appointing Ms. Lopes as the special officer of the Court FRCvP 53 are stayed pending further order of the Court; Setting forth instructions regarding Ms. Lopes appointment; Directing defendants' to file and hand serve response to plaintiffs' motion for appointment of Ms. Lopes as expert by 12:00 noon May 15, 1996; Plaintiffs' shall file and hand serve their reply thereto by 2:00p.m. May 16, 1996; Setting argument on the motion on 4:00p.m. May 16, 1996 (N). (JMF) (Entered: 05/09/1996)
176 STATUS REPORT by plaintiffs' on fee negotiations; exhibits (5) (JMF) Modified on 05/06/1996 (Entered: 05/06/1996)
177 ORDER by Judge June L. Green : allowing defendants to file any memorandum of points and authorities in opposition to plaintiffs' motion by 5/22/96; plaintiffs shall reply by 5/31/96; status conference set for 6/5/96. (N) (bjl) (Entered: 05/07/1996)

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05/08/1996 05/08/1996 05/15/1996 05/16/1996 05/16/1996
05/20/1996 05/22/1996
06/03/1996
06/03/1996 06/06/1996
06/06/1996
06/07/1996

178 MOTION filed by plaintiffs' for briefing schedule ; exhibits (5) (JMF) (Entered: 05/08/1996)
179 ORDER by Judge June L. Green : re-setting status hearing set for 6/5/96 to 10:30 6/4/96 ; (N) (bjl) (Entered: 05/08/1996)
181 MOTION (COSENT) filed by plaintiff to vacate the Court's Order of April 30, 1996 (JMF) (Entered: 05/16/1996)
MOTION HEARING before Judge June L. Green to vacate the Court's Order of 4/30/96 heard and granted. Reporter: Gordon Slodysko (bjl) (Entered: 05/17/1996)
182 ORDER by Judge June L. Green : granting motion to vacate the Court's Order of April 30, 1996 [181-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE; setting forth new instructions re Ms. Lopes as an expert witness. (N) (bjl) (Entered: 05/17/1996)
183 MOTION filed by plaintiffs' to hold the District of Columbia in contempt for failure to pay accrued fines ; exhibits (6) (JMF) (Entered: 05/24/1996)
184 MOTION filed by defendants' to stay determination of attorney's fees pending resolution of appeal , or, in the alternative to to extend time to respond to plaintiffs' motions for fees and contempt for failure to pay fines (JMF) (Entered: 05/24/1996)
185 MEMORANDUM by plaintiff in opposition to motion to stay determination of attorney's fees pending resolution of appeal [184-1] or, in the alternative, to motion to extend time to respond to plaintiffs' motions for fees and contempt for failure to pay fines [184-2] by defendants' (JMF) (Entered: 06/04/1996)
186 STATUS CONFERENCE REPORT by plaintiffs'; exhibits (13) (JMF) (Entered: 06/04/1996)
187 ORDER by Judge June L. Green : setting forth instructions to defendants regarding compliance with the Court's Orders; setting a further status conference on 7/17/96 at 10:00 a.m.; directing the District to reimburse plaintiffs' expert, Joseph Fowlkes, M.D. in the amount of $8,244.88 forthwith. (N) (bjl) (Entered: 06/06/1996)
STATUS HEARING before Judge June L. Green : defendants shall advise the Court as to status compliance with the 2/29/96 Order and other Orders of this Court in this case; further status call set for 7/17/96 at 10:00 a.m. Reporter: Ben Leesman (Miller) (bjl) (Entered: 06/06/1996)
188 ORDER by Judge June L. Green : denying motion to stay determination of attorney's fees pending resolution of appeal [184-1] by defendants; granting motion to extend time to 7/3/96 to respond to plaintiffs' motions for fees and contempt for failure to pay fines [184-2] by defendants; plaintiffs' replies are due by7/10/96; a hearing on oral argument is set for 7/17/96 at 10:00 a.m. on motion for fees and costs and motion for contempt. (N) (bjl) (Entered: 06/07/1996)

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06/17/1996 06/18/1996 07/03/1996 07/09/1996 07/09/1996 07/10/1996 07/10/1996 07/11/1996
07/11/1996 07/12/1996 07/15/1996 07/16/1996

189 MOTION (CONSENT) filed by defendant DC to continue status conference to July 09, 1996 at 1:30 p.m. and requirements imposed on the Special Officer as set forth in the Court's Order April 18, 1996 (JMF) (Entered: 06/18/1996)
190 ORDER by Judge June L. Green : granting motion to continue status conference to July 09, 1996 at 1:30 p.m. and requirements imposed on the Special Officer as set forth in the Court's Order April 18, 1996 [1891] by DC (N) (bjl) (Entered: 06/20/1996)
191 RESPONSE by defendant DC in opposition to motion to hold the District of Columbia in contempt for failure to pay accrued fines [183-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE .; exhibits (2) (JMF) (Entered: 07/08/1996)
STATUS HEARING before Judge June L. Green regarding the District's hiring of a Health Care Coordinator. : Reporter: Vicky Stallsworth (bjl) (Entered: 07/10/1996)
192 NOTICE OF FILING by defendant DC of opposition to order plaintiffs submitted at hearing on July 09, 1996 (JMF) (Entered: 07/10/1996)
193 REPLY by plaintiffs' in support of their motion to hold the District of Columbia in contempt for failure to pay accrued fines [183-1] (JMF) (Entered: 07/11/1996)
194 STATUS REPORT by defendants'; exhibits (7) (JMF) Modified on 07/12/1996 (Entered: 07/11/1996)
195 CONSENT ORDER by Judge June L. Green; entering judgment in favor of plaintiffs and against the District of Columbia in the amount of One Hundred Sixty-Nine Thousand Four Hundred and Twenty-Two Dollars and Fifty Cents ($169,422.50); this judgment shall bear no interest for a period of 45 days and shall completely resolve all claims for fees, costs and expenses for this litigation from 7/1/95 through 3/31/96; directing the District to pay the Judgment by issuing two checks, 1) in the amount of $110,000.00, plus any accrued interest, made payable to the law firm Ross, Dixon & Masbach and 2) in the amount of $59,422.50, plus any accrued interest, made payable the D.C. Prisoners' Legal Service Project, Inc. : (N) (bjl) (Entered: 07/12/1996)
196 NOTICE OF FILING by defendant DC of redacted exhibits B and C of defendants' status conference report filed on 07/10/96 (JMF) Modified on 07/12/1996 (Entered: 07/12/1996)
197 MOTION filed by defendants' to substitute exhibits b and c (JMF) (Entered: 07/15/1996)
198 ORDER by Judge June L. Green : granting motion to substitute exhibits b and c filed with their Status Conference Report on July 10, 1996 [1971] by defendants' (N) (JMF) (Entered: 07/15/1996)
199 NOTICE OF FILING by plaintiffs' of letter dated May 30, 1996 of Tunde Otubanjo, R.Ph., the pharmacist assigned to the Medium Security Facility

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07/16/1996 07/16/1996 07/17/1996
07/17/1996 07/18/1996
07/26/1996 07/29/1996 08/06/1996 08/13/1996 09/09/1996 09/09/1996 09/10/1996 10/08/1996

(JMF) (Entered: 07/17/1996)
200 RESPONSE by plaintiff to defendants' July 10, 1996 status conference report [194-1] by defendants'; exhibits (4) (JMF) (Entered: 07/17/1996)
201 SUPPLEMENTAL MEMORANDUM by defendant of status report [194-1]; exhibits (3) (JMF) (Entered: 07/17/1996)
202 ORDER by Judge June L. Green : granting motion to substitute exhibits to the Supplement to Defendants' Status Conference Report filed on 7/16/96; directing that the original supplement, filed 7/16/96, shall be removed from the Court's record and returned to counsel for defendants; that the Supplement to defendants' Status Conference Report attached to this Order shall be substituted for the original supplement. (N) (bjl) (Entered: 07/17/1996)
MOTION HEARING before Judge June L. Green regarding Plaintiffs' motion for contempt and sanctions heard and taken under advisement. Reporter: Robert Haines (Miller) (bjl) (Entered: 07/18/1996)
203 ORDER by Judge June L. Green : granting in part, denying in part motion to hold the District of Columbia in contempt for failure to pay accrued fines; [183-1] directing that, pursuant to Section II.D. of the Court's Order of 2/29/96, Defendants shall pay a fine in the amount of $75,000.00. Defendants shall pay $25,000.00 by 8/1/96; the remaining $50,000.00 shall be paid by no later than 10/31/96; directing that all fines assessed pursuant to this Order shall be paid into the Registry of the Court to be held in a special interest bearing account to be managed by the Clerk of the Court. (N) (bjl) (Entered: 07/19/1996)
204 MOTION (CONSENT) filed by plaintiff for adoption of a consent order concerning systemwide medical and mental health care (JMF) (Entered: 07/29/1996)
205 ORDER by Judge June L. Green : status hearing set for 1:30 10/9/96 ; (N) (bjl) (Entered: 07/30/1996)
206 TRANSCRIPT filed for date(s) of 2/26/96. Reporter: Susan Tyner (bjl) (Entered: 08/07/1996)
207 TRANSCRIPT filed for date(s) of 2/27/96. Reporter: Phyllis Merana (bjl) (Entered: 08/14/1996)
208 MOTION filed by defendant to extend time to 10/9/96 (bjl) (Entered: 09/10/1996)
209 STATUS REPORT by defendants. (bjl) (Entered: 09/10/1996)
210 ORDER by Judge June L. Green : granting defendants' motion to extend time to 10/9/96 [208-1] for filing their Plan by the Medical Administrator of the Three Lorton Facilities to Comply with the Consent Decrees. (bjl) (Entered: 09/10/1996)
211 MOTION (CONSENT) filed by defendant to extend time to 10/25/96 to

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10/09/1996 10/09/1996 10/10/1996 12/19/1996 12/23/1996 01/03/1997
01/04/1997 01/17/1997 01/17/1997 01/21/1997 01/31/1997

file a plan by the medical administrator of the three lorton facilities to comply with the consent decrees in this action (JMF) (Entered: 10/09/1996)
HEARING before Judge June L. Green : regarding the hiring of a system wide medical health care coordinator held; Progress Report hearing set for 12/17/96 at 10:00 A.M. Reporter: Susan Tyner (bjl) (Entered: 10/10/1996)
212 ORDER by Judge June L. Green : granting oral motion of plaintiffs for additional relief concerning improved medical leadership within Dept. of Corrections; setting a Progress Report hearing on 12/17/96 at 10:00 A.M. (N) (bjl) (Entered: 10/10/1996)
213 ORDER by Judge June L. Green : granting motion to extend time to 10/25/96 to file a plan by the medical administrator of the three lorton facilities to comply with the consent decrees in this action [211-1] by defendants. (N) (bjl) (Entered: 10/11/1996)
COMPLIANCE HEARING before Judge June L. Green status hearing set for 1:15 2/5/97 ; Reporter: Wm. McAllister (bjl) (Entered: 12/20/1996)
214 MOTION (CONSENT) filed by defendant to extend time to 1/17/97 to file a plan by the medical admininstrator of the Three Lorton Facilities to comply with the consent decrees in this action, filed nunc pro tunc to October 25, 1996 (JMF) (Entered: 12/24/1996)
215 ORDER by Judge June L. Green : granting motion to extend time to 1/17/97 to file a plan by the medical of the Three Lorton Facilities to comply with the consent decrees in this action, filed nunc pro tunc to October 25, 1996 [214-1] by defendants; extending deadline for filing defendants' plan by the Medical Administrator of the Three Lorton Facilities to Comply with the Consent Decrees to 1/17/97 (N) (dbw) (Entered: 01/03/1997)
220 CERTIFIED COPY of judgment filed in USCA dated 12/20/96, on appeal [174-1] , affirming the judgment of USDC . USCA # 96-7074 (cjp) (Entered: 02/05/1997)
216 MOTION filed by defendants' to stay payment of fines filed nunc pro tunc to October 31, 1996 (JMF) (Entered: 01/22/1997)
217 MOTION (SECOND CONSENT) filed by defendant to extend time to 1/31/97 to file a plan by the medical administrator of the Three Lorton Facilities to comply with the consent decrees in this action (JMF) (Entered: 01/22/1997)
218 ORDER by Judge June L. Green : granting motion to extend time to 1/31/97 to file a plan by the medical administrator of the Three Lorton Facilities to comply with the consent decrees in this action [217-1] by defendants (N) (dbw) (Entered: 01/22/1997)
219 MEMORANDUM by plaintiffs' in opposition to motion to stay payment

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02/04/1997 02/05/1997 02/05/1997
02/07/1997 02/07/1997 02/20/1997 02/21/1997 02/24/1997 03/27/1997

of fines filed nunc pro tunc to October 31, 1996 [216-1] by defendants' (JMF) (Entered: 02/03/1997)
221 MOTION (THIRD UNOPPOSED) filed by defendant to extend time to 2/7/97 to file a plan by the medical administrator of the Three Lorton Facilities to omply with the cosent decrees (JMF) (Entered: 02/05/1997)
222 ORDER by Judge June L. Green : granting motion to extend time to 2/7/97 to file a plan by the medical administrator of the Three Lorton Facilities to comply with the consent decrees [221-1] by defendants (N) (dbw) (Entered: 02/05/1997)
223 ORDER by Judge June L. Green : directing Dr. Armand H. Start to submit to the Court by 2/19/97 a written summary briefly outlining steps that have been taken and that will be taken by defendants in the future to retain services of a full-time systemwide medical director and measures that Dr. Start has taken and intends to take in the future to improve state of defendants' medical compliance under Court's Orders and Consent Decrees ; Dr. Start will appear before the Court on 2/24/97 10:00 to testify more fully as to the defendants' efforts in these areas (N) (dbw) (Entered: 02/05/1997)
224 REPLY by defendant to plaintiffs' opposition to defendants' motion to stay payment of fines filed nunc pro tunc to October 31, 1996 [216-1] (JMF) (Entered: 02/10/1997)
225 MOTION (FOURTH) filed by defendant to extend time to 2/21/97 to file a plan by the medical administrator of the Three Lorton Facilities to comply with the consent decrees in this action (JMF) Modified on 02/10/1997 (Entered: 02/10/1997)
226 ORDER by Judge June L. Green : granting motion to extend time to 2/21/97 to file a plan by the medical administrator of the Three Lorton Facilities to comply with the consent decrees in this action [225-1] by defendants (N) (jeb) (Entered: 02/20/1997)
227 NOTICE OF FILING by defendants' plan by the Medical Administrator of the Three Lorton Facilites to acheive and maintain compliance with the Court's orders dated 02/29/96 (JMF) (Entered: 02/24/1997)
STATUS HEARING before Judge June L. Green : testimony of Dr. Armond H. Start heard; parties to notify Court of progress, in writing, in two months Reporter: Phyllis Merana (dbw) (Entered: 02/24/1997)
228 ORDER by Judge June L. Green : denying motion to stay payment of fines filed nunc pro tunc to October 31, 1996 [216-1] by defendants; directing that pursuant to the Court's orders of 2/29/96 and 7/18/96, the defendants shall pay the outstanding fine amount of $50,000.00 by 6/9/97; directing that all fines assessed pursuant to this orders shall be paid into the Registry of the Court to be held in a special interest-bearing account to be managed by the Clerk of the Court. (N) (jeb) (Entered: 03/27/1997)

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05/19/1997 05/30/1997 06/04/1997 06/11/1997 06/13/1997 06/16/1997 06/16/1997 07/11/1997 07/28/1997 09/25/1997
09/25/1997

229 MOTION filed by plaintiff for order to show cause why the defendants should not be held in contempt of the Court's February 29, 1996 Order (JMF) (Entered: 05/20/1997)
230 MOTION (CONSENT) filed by defendant to extend time to 6/13/97 to respond to plaintiffs' motion for an order to show cause why the defendants should not be held in contempt of the Court's February 29, 1996 order (JMF) (Entered: 06/02/1997)
231 ORDER by Judge June L. Green : granting motion to extend time to 6/13/97 to respond to plaintiffs' motion for an order to show cause why the defendants should not be held in contempt of the Court's February 29, 1996 order [230-1] by defendants. (N) (jeb) (Entered: 06/04/1997)
DEPOSIT into the registry pursuant to Court order dated 07/18/96 in the amount of $50,000.00. (JMF) (Entered: 06/12/1997)
232 MOTION (SECOND) filed by defendants' to extend time to 07/11/97 to respond to plaintiffs' motion for an order to show cause why the defendants should not be held in contempt of the Court's February 28, 1996 order (JMF) Modified on 06/17/1997 (Entered: 06/16/1997)
233 STATUS REPORT by defendants' (JMF) (Entered: 06/17/1997)
234 ORDER by Judge June L. Green : granting motion to extend time to 07/11/97 to respond to plaintiffs' motion for an order to show cause why the defendants should not be held in contempt of the Court's February 28, 1996 order [232-1] by defendants (N) (JMF) (Entered: 06/17/1997)
235 RESPONSE by defendants' in opposition to motion for order to show cause why the defendants should not be held in of the Court's February 29, 1996 Order [229-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE .; exhibits (10) (JMF) (Entered: 07/14/1997)
236 REPLY by plaintiffs' to defendants' opposition to motion for order to show cause why the defendants should not be held in contempt of the Court's February 29, 1996 Order [229-1] (JMF) (Entered: 07/29/1997)
237 ORDER by Judge June L. Green : granting motion for order to show cause why the defendants should not be held in contempt of the Court's February 29, 1996 Order [229-1] by JANE DOE, JOHN DOE, JANE DOE, JOHN DOE, JOHN DOE; directing defendants to show cause by 11/21/97 why they should not be held in contempt of Court for failure to comply with the terms of the remedial plan they filed 2/21/97. (N) (mlp) (Entered: 09/25/1997)
238 CONSENT JUDGMENT by Judge June L. Green in favor of plaintiff JOHN DOE, plaintiff JOHN DOE, plaintiff JANE DOE, plaintiff JOHN DOE, plaintiff JANE DOE against defendant DC, in the amount of One Hundred Fifty Thousand Dollars for attorney fees, expenses and costs to be awarded to plaintiffs for litigation of this action between 4/1/96 through 9/10/97; defendants shall make payment to the plaintiffs no later than the last day of the first quarter for D.C.'s fiscal year 1998, 12/31/97;

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10/31/1997 11/04/1997
11/21/1997 01/29/1999 02/02/1999 02/02/1999 05/10/2000 05/11/2000

this judgment will bear no interest, unless payment is not made before 1/1/98, in which case interest shall accrue at the judgment rate thereafter; D.C. shall pay the judgment by issuing a check made payable to Ross, Dixon & Masback, L.L.P. (N) (mlp) (Entered: 09/25/1997)
239 JOINT MOTION by defendants and plaintiffs for entry of consent Orders modifying appointment of Special Officer. (ks) (Entered: 11/04/1997)
240 ORDER by Judge June L. Green : granting joint motion for entry of consent Orders modifying appointment of Special Officer [239-1] by JOHN DOE, MARK CHASTING effective 11/1/97, the Court's Order appointing Special Officer of 8/15/91 with respect to Case Numbers 791726, 80-2136, and 90-727, is modified to provide that the duties previously assigned to Grace M. Lopes are assigned to Karen M. Schneider; the Court's Orders dated 2/29/96 and 7/18/96 in Case Number 92-1208, is modified to provide that the duties previously assigned to Grace M. Lopes are assigned to Karen M. Schneider; the foregoing Orders otherwise shall continue in full force and effect; Ms. Schneider is authorized to consult with and seek assistance from Ms. Lopes with regard to any matter within the scope of the Special Officer's duties; the Court's Order appointing Special Officer of 8/15/91 in Case Number 862128, shall continue in full force and effect, except that Ms. Schneider shall perform all monitoring functions in Case Number 86-2128; upon notice of resignation by Ms. Lopes to the Court, Ms. Schneider shall assume all the duties assigned to the Special Officer as set forth in the Court's Order appointing Special Officer of 8/15/91 in Case Number 862128. (N) (mlp) (Entered: 11/05/1997)
241 RESPONSE by defendant to order directing defendants to show cause by 11/21/97 why they should not be held in contempt of Court for failure to comply with the terms of the remedial plan they filed 2/21/97. [237-1]; attachments (1) (JMF) (Entered: 11/24/1997)
242 RESPONSE by defendant to court's order dated 02/29/96 setting forth a schedule to remedy the District's noncompliance; to report on the progress made in implementing this Order. (N) [173-1], order [173-2] (jf) (Entered: 02/01/1999)
243 REPLY by plaintiffs' to defendants' submission of remedial plan [242-1] by defendant . (jf) (Entered: 02/03/1999)
244 ATTORNEY APPEARANCE for plaintiffs' by Eric Robert Lotke (jf) (Entered: 02/12/1999)
246 MOTION filed by defendant for adoption of consent order regarding attorney's fees and costs (jf) (Entered: 05/12/2000)
245 CONSENT ORDER by Judge June L. Green: awarding plaintiff attorney fees and costs associated with monitoring compliance with the Court's orders entered in this action and for payment of plaintiff's expert's outstanding invoice by agreement of counsel (N) (jeb) (Entered: 05/12/2000)

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12/15/2000 12/19/2000

248 MOTION filed by defendants for adoption of consent order (cdw) (Entered: 12/19/2000)
247 CONSENT ORDER by Judge June L. Green : That the orders entered in this civil action be and hereby are vacated; and that this action is hereby dismissed. (N) (zz) (Entered: 12/19/2000)

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