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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

TALLAHASSEE DIVISION

ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. 

HAND, Personal Representative,

Plaintiff,

vs.

CASE NO.: 4:20-CV-66-AW-HTC

FLORIDA DEPARTMENT OF 

CORRECTIONS; CENTURION OF 

FLORIDA; MHM HEALTH 

PROFESSIONALS, INC.; DAVID E. 

RODRIGUEZ-RIVERA, M.D., a/k/a 

DAVID RODRIGUEZ, M.D.; JEAN 

MAX SAINT CHARLES, M.D.; JUAN 

SANTIAGO, M.D. a/k/a JUAN 

SANTIAGO RIVERA, M.D.; PETER 

FABIAN EDEMEKONG, M.D.; 

DRIANNA NISHELL LAW, ARNP,

Defendants.

________________________________/

SECOND AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, the ESTATE OF GLENN MITCHELL HAND, by and through 

PHYLLIS A. HAND, Personal Representative, by and through undersigned counsel, 

hereby sues Defendant FLORIDA DEPARTMENT OF CORRECTIONS, 

Defendant CENTURION OF FLORIDA, Defendant MHM HEALTH 

PROFESSIONALS, INC., Defendant DAVID E. RODRIGUEZ-RIVERA, M.D., 

a.k.a. DAVID RODRIGUEZ, M.D., Defendant JEAN MAX SAINT CHARLES, 

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M.D., Defendant JUAN SANTIAGO, M.D., aka JUAN SANTIAGO RIVERA, 

M.D., Defendant PETER FABIAN EDEMEKONG, M.D., and Defendant 

DRIANNA NISHELL LAW, ARNP, and, in support of this Second Amended 

Complaint, alleges:

INTRODUCTION

1. This Complaint asserts claims pursuant to 42 U.S.C. § 1983, as well as 

claims of state law medical negligence and vicarious liability.

2. Pursuant to § 768.28(6)(a), Fla. Stat., notice of the injuries described in 

this complaint was sent via certified mail to the Department of Financial Service and 

to Governor Rick Scott, Warden Robert E. Smith, Jr. with the Lake Butler Prison –

Reception and Medical Center, Julie L. Jones with Florida Department of 

Corrections, and Jason M. Harrold with Centurion of Florida, LLC on June 27, 2018. 

3. Plaintiff’s claims for relief are also brought herein pursuant to 42 

U.S.C. §§ 1983, 1988.

4. The claims alleged herein are brought within the applicable statute of 

limitations.

5. All conditions precedent to the filing of this action have been 

performed, waived, excused, or otherwise occurred.

/ / /

/ / /

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JURISDICTION AND VENUE

6. This court has federal question jurisdiction, pursuant to 28 U.S.C. §§ 

1331 and 1343, over 42 U.S.C. § 1983 claims. 

7. This Court has jurisdiction over these claims as they arise under the 

Constitution of the United States of America and have been brought before this court 

pursuant to 42 U.S.C. § 1983

8. This Court has supplemental jurisdiction over the related state law 

claims alleged herein pursuant to 28 U.S.C. § 1367, because the alleged claims 

arising under Florida law are so related as to form part of the same case or 

controversy arising under the § 1983 claims. 

9. Venue is proper pursuant to 28 U.S.C. § 1391 because a substantial part 

of the acts and omissions giving rise to Plaintiff’s claims occurred in this District. 

PARTIES

10. PHYLLIS A. HAND is the surviving wife of GLENN MITCHELL 

HAND (“MR. HAND”) and serves as the Personal Representative of the ESTATE 

OF GLENN MITCHELL HAND, having been so appointed on May 22, 2019. 

11. Plaintiff, PHYLLIS A. HAND, as Personal Representative of the Estate 

of GLENN MITCHELL HAND, is entitled to and empowered by the Florida 

Wrongful Death Act to recover the estate, all the damages allowed pursuant to the 

Florida Wrongful Death Act, section 768.16, et. seq.

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12. All potential beneficiaries of a recovery for wrongful death and their 

relationship to the deceased, MR. HAND, are identified as follows:

a. PHYLLIS A. HAND the wife of MR. HAND. 

13. At all times material hereto, MR. HAND was an inmate in the care and 

custody of the Defendant DOC at Lake Butler Prison, Reception and Medical Center 

(“RMC”).

14. At all times material, the Defendant DOC was responsible for the care 

and treatment of MR. HAND at its facility at Lake Butler and had a nondelegable 

duty to use reasonable care in the operation of RMC and the supervision and 

protection of prisoners in its custody.

15. At all times material hereto, Defendant CENTURION OF FLORIDA, 

LLC (“Defendant CENTURION”), was the health care company contracted with 

DOC to provide medical care and treatment to prison inmates.

16. Upon information and belief, Defendant MHM HEALTH 

PROFESSIONALS, INC., (“MHM”) is a foreign corporation, and at all times 

material contracted and/or was otherwise associated with Defendant DOC, 

Defendant CENTURION, Defendant DAVID E. RODRIGUEZ-RIVERA, M.D., 

a.k.a. DAVID RODRIGUEZ, M.D., Defendant JEAN MAX SAINT CHARLES, 

M.D., Defendant JUAN SANTIAGO, M.D., aka JUAN SANTIAGO RIVERA, 

M.D., Defendant PETER FABIAN EDEMEKONG, M.D., Defendant DRIANNA 

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NISHELL LAW, ARNP to provide medical care and treatment to prison inmates, 

including those admitted to RMC

17. Either Defendant DOC, Defendant CENTURION, and/or Defendant 

MHM employed or otherwise contracted with nurses, nursing assistants, physicians 

and nurse practitioners, and correctional officers who cared for and/or supervised 

MR. HAND at RMC.

18. At all times material hereto, Defendant DAVID E. RODRIGUEZRIVERA, M.D. (“Defendant RODRIGUEZ-RIVERA”) was a medical doctor at 

RMC and rendered health care services to MR. HAND while admitted to RMC.

19. At all times material hereto, Defendant JEAN MAX SAINT 

CHARLES, M.D. (“Defendant SAINT CHARLES”) was a medical doctor at RMC 

and rendered health care services to MR. HAND while admitted to RMC.

20. At all times material hereto, Defendant JUAN SANTIAGO RIVERA, 

M.D. (“Defendant SANTIAGO”) was a medical doctor at RMC and rendered health 

care services to MR. HAND while admitted to RMC.

21. At all times material hereto, Defendant PETER FABIAN 

EDEMEKONG, M.D. (“Defendant EDEMEKONG”) was a medical doctor at RMC 

and rendered health care services to MR. HAND while admitted to RMC.

/ / /

/ / /

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22. At all times material hereto, Defendant DRIANNA NISHELL LAW, 

ARNP, (“Defendant LAW”) was a registered nurse at RMC and rendered health care 

services to MR. HAND while admitted to RMC.

FACTS

MR. HAND’S TREATMENT FROM DECEMBER 6, 2016 TO APRIL 13, 

2017

23. On Tuesday, December 6, 2016, MR. HAND was admitted into 

Defendant DOC’s RMC inpatient hospital for treatment of right palatal tonsillar 

cancer, squamous type, which was diagnosed during his incarceration in the fall of 

2016.

24. During his admission, MR. HAND received chemotherapy and 

radiation treatment to treat his cancer diagnosis.

25. On Monday, April 10, 2017, MR. HAND was seen by an ENT 

physician who deemed that MR. HAND did not have cancer and there was no 

evidence of recurrent disease. 

26. On Thursday, April 13, 2017, after receiving chemotherapy and 

radiation treatment, and being deemed cancer free, Defendant SAINT CHARLES 

discharged MR. HAND from the inpatient hospital at RMC and ordered that MR. 

HAND be returned to general population.

/ / /

/ / /

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27. At the time of his discharge on Thursday, April 13, 2017, Defendant 

SAINT CHARLES noted that MR. HAND was afebrile, in stable condition, and did 

not have any acute distress.

28. Defendant SAINT CHARLES discharge order ordered that MR. 

HAND be discharged to the compound, to follow up with an ENT, follow up with a 

plastic surgeon, follow up with his oncologist in three months, and follow up his 

primary care physician in one week. 

29. Defendant SAINT CHARLES discharge plan and respective physician 

orders, however, did not include any plan for infection risk or control, physical 

therapy, or MR. HAND’s nursing needs. 

30. Defendant SAINT CHARLES’s plan also did not address MR. 

HAND’s ability to ambulate, care for himself, or maintain his activities of daily 

living. 

31. Defendant SAINT CHARLES similarly did not mention any deep vein 

thrombosis prevention plan.

32. Upon information and belief, Defendant SAINT CHARLES knew that 

failing to conduct an adequate discharge plan prior to MR. HAND’s transfer to 

general population on Thursday, April 13, 2017 based upon MR. HAND’s recent 

medical history and treat would increase MR. HAND’s risk of developing serious 

illness and infection and Defendant SAINT CHARLES chose to do so anyways.

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THURSDAY, APRIL 13, 2017 TO FRIDAY, MAY 5, 2017 

33. On Wednesday, April 19, 2017, MR. HAND, as advised, followed up 

and presented to his primary care doctor with all normal vital signs and no 

complaints. The health record indicated that MR. HAND stated to his primary care 

physicians that “I am fine. I need dentures.” MR. HAND was advised to return on 

Wednesday, October 4, 2017 for follow up.

34. On Thursday, April 20, 2017, MR. HAND made an inmate request for 

dentures so that he could “eat like he should.” Notably, there were no health 

complaints noted by MR. HAND.

35. On Wednesday, May 3, 2017, MR. HAND, as advised, followed up and 

presented to with the plastic surgeon for a skin lesion on his left ear. After reviewing 

MR. HAND’s medical history with him, the plastic surgeon examined the lesion on 

his ear and determined it needed to be surgically removed. The plastic surgeon was 

unable to perform the procedure that day due to requirements of prior approval 

before scheduling a surgical procedure involving an inmate patient. As such, the 

plastic surgeon completed a Request for Prior Approval of Health Care Services 

form, designating the surgery as "[u]rgent" and requesting that it be scheduled at the 

RMC’s Mobile Surgical Unit in Lake Butler, Florida, and submitted the form on 

May 3, 2017.

/ / /

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36. During his Wednesday, May 3, 2017 appointment, MR. HAND 

presented with normal vital signs and no complaints.

37. On Monday, May 5, 2017, CT scans of MR. HAND’s head, neck, and 

chest were performed in accordance with his discharge on April 13, 2017. 

38. Like all reports for all tests to follow, no follow-up was given, and no 

physician even acknowledged the reports until Thursday, May 11, 2017. 

FRIDAY, MAY 5, 2017

39. On Monday, May 5, 2017, at approximately 12:35 pm, MR. HAND 

was evaluated by Defendant LAW with complaints of nausea, vomiting, and 

diarrhea for the past 15 hours. MR. HAND complained of a frontal lobe headache. 

MR. HAND vitals were charted as follows: blood pressure 105/80, pulse 114, 

oxygenation 95%, and temperature 98.4 degrees Fahrenheit. 

40. Defendant LAW noted MR. HAND’s past medical history of tonsillar 

cancer and recent chemotherapy but failed to include his COPD or hospital-acquired 

pneumonia. 

41. Per Defendant LAW’s documentation, MR. HAND was receiving 

chemotherapy, which he was not at the time.

42. Defendant LAW documented the presence of a PICC line without a 

dressing but did not describe it further other than it had “fell out”. 

/ / /

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43. Defendant LAW assessed MR. HAND as having gastroenteritis, 

without addressing the headache etiology, or prior hospital-acquired pneumonia. 

44. Defendant LAW failed to address any source of potential infection.

45. Defendant LAW’s treatment plan included Zofran and Ibuprofen, a 

medication known to cause/exacerbate gastrointestinal problems that is 

contraindicated in a patient with stomach problems.

46. Despite his history and the development of a serious medical condition 

that required urgent medical treatment and evaluation, MR. HAND was discharged 

to the compound without any assessment of investigation as to any source of 

potential infection.

47. No antibiotics were ordered for or administered to MR. HAND.

48. Despite seeing MR. HAND on Friday, May 5, 2017, Defendant LAW 

did not write any orders until Monday, May 8, 2017.

MONDAY, MAY 8, 2017

49. On May 8, 2017, at approximately 10:12 a.m., MR. HAND was seen 

by K. Ginn, RN.

50. Nurse Ginn completed an "Abdominal Pain Protocol" and “Vomiting 

Diarrhea Protocol.” 

51. MR. HAND’s medical history was left incomplete and did not include 

his COPD or previously acquired hospital-acquired pneumonia. 

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52. The nurse documented MR. HAND’s chief complaint of nausea, 

vomiting, and severe abdominal pain that was documented to have begun on May 4, 

2017.

53. MR. HAND explained that he was experiencing crampy pain, and 

green, watery, and acidic smelling stools.

54. MR. HAND explained that he had a decreased appetite and it was noted 

that he was experiencing hypoactive bowel sounds in all four quadrants. 

55. MR. HAND’s vitals were listed as: blood pressure 132/79, pulse 102, 

respirations 16, oxygenation 96%, and temperature 98.4 degrees Fahrenheit. 

56. MR. HAND was unable to stand for Nurse Ginn to take his blood 

pressure.

57. Nurse Ginn charted skin tenting and that the mucous membranes in his 

mouth were dry. These signs are indicative of dehydration, but Nurse Ginn nor 

Defendant LAW, who co-signed the treatment orders on Monday, May 8, 2017, 

treated the dehydration. 

58. According to the Abdominal Pain Protocol and MR. HAND’s 

complaints of severe pain and vomiting a clinician was to be notified immediately. 

59. Also, according to the Vomiting/Diarrhea Protocol and MR. HAND’s 

complaints of severe pain, skin tenting, and dry mucous membranes in his mouth a 

clinician was to be notified immediately.

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60. On Monday, May 8, 2017, there are orders by Nurse Ginn, also signed 

by Defendant LAW, for Ibuprofen and Zofran and to pull the PICC line, but no 

further care is documented until he was admitted to RMC on Thursday, May 11, 

2017.

61. Despite his history and the development of a serious medical condition 

that required urgent medical treatment and evaluation, MR. HAND was discharged 

to the compound without any assessment or investigation as to any source of 

potential infection.

62. No antibiotics were ordered for or administered to MR. HAND.

63. Based upon his symptoms and complaints of severe pain and vomiting 

for over four days and his development of a serious medical condition, a physician 

was to be notified immediately. 

64. Nursing staff documented the Defendant EDEMEKONG was notified, 

but the time at which that occurred was blank. 

65. There are no orders documented from Defendant EDEMEKONG in the 

health record, and nursing staff did not initiate any nursing protocol orders for MR. 

HAND. 

66. It does not appear that Defendant EDEMEKONG was notified and no 

physician ever reviewed the chart and no follow-up or medical treatment was given. 

/ / /

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67. If nursing staff did contact Defendant EDEMEKONG, then he/she 

should have noted the time on the nursing protocol, along with the provider's orders 

(or "no orders given"). 

68. In the alternative, if nursing staff were not able to contact Defendant 

EDEMEKONG, then that should have been noted in the health record, and MR. 

HAND should have had an urgent referral to a provider on May 8, 2017, due to his 

symptoms of severe abdominal pain, nausea, vomiting, diarrhea, headache and 

dehydration, especially with his cancer history. 

69. Bottom line, MR. HAND was neither seen by Defendant 

EDEMEKONG nor seen by any other physician until he was admitted to RMC on 

Thursday, May 11, 2017, as an inpatient. 

70. MR. HAND’s presentation on May 8, 2017 mandated treatment and 

was so obvious that even a lay person would easily recognize the necessity for a 

doctor’s attention, that, if left unattended, posed a substantial risk of serious harm to 

MR. HAND. 

71. Defendant LAW had knowledge of MR. HAND’s serious medical 

condition as indicated by his presentation on May 5, 2017 and worsening condition 

and presentation on May 8, 2017 but clearly disregarded the risks associated with 

the serious medical condition based upon her diagnosis and orders.

/ / /

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72. Defendant LAW’s treatment plan of MR. HAND included a follow-up 

appointment with his primary care doctor in a week, but Defendant LAW failed to 

order that appointment. 

73. Despite MR. HAND’s presentation with a multitude of symptoms 

indicating a serious medical condition and infection, Defendant LAW ignored the 

signs and symptoms and chose not to perform a potential infectious disease 

assessment and chose not to prescribe any antibiotics to treat MR. HAND’s serious 

medical condition.

THURSDAY, MAY 11, 2017

74. From May 8, 2017 through May 11, 2017, MR. HAND’s serious 

medical condition was ignored by Defendants and MR. HAND continued to 

significantly deteriorate, such that he was unresponsive and/or unable to leave his 

bunk and/or unable to ask for help. 

75. During this time, Defendant LAW, Defendant EDEMEKONG, 

Defendant DOC’s employees, agents, and staff, Defendant CENTURION’s 

employees, agents, and staff, and Defendant MHM’s employees, agents, and staff 

knew of MR. HAND’s serious medical condition and his deterioration but acted with 

deliberate indifference and failed to do anything to treat the worsening serious 

medical condition.

/ / /

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76. Sometime on or about May 11, 2017, MR. HAND’s bunkmate notified 

a Defendant DOC employee and/or Defendant CENTURION and/or Defendant 

MHM agent or employee that MR. HAND had been unresponsive in his bed for 

approximately a day to two days.

77. On Thursday, May 11, 2017, at approximately 9:26 p.m., MR. HAND 

was admitted to the RMC, as an inpatient, by Defendant RODRIGUEZ-RIVERA, 

with a serious medical condition, critically ill with alleged diagnoses of acute 

dehydration and failure to thrive. 

78. There is no documentation in the health record regarding how or why 

MR. HAND came to be admitted to the hospital, only that he arrived via wheelchair 

with an IV placed in his wrist.

79. MR. HAND’s admitting vitals were temperature 99.3 degrees 

Fahrenheit, pulse 100, respirations 17, and blood pressure 109/70. 

80. MR. HAND’s vital signs during this time and medical history reflect 

that MR. HAND had a serious medical condition with an ongoing fever and 

infection.

81. MR. HAND disclosed in his admission history and physical that he had 

not eaten in two days and that he was not able to eat.

/ / /

/ / /

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82. At that time of his admission, MR. HAND was unable to legibly sign 

his name for admission, was in a severely weak and guarded condition and unable 

to use the urinal. 

83. This is MR. HAND’s signature upon admission to RMC on May 11, 

2017:

84. This is MR. HAND’s signature on May 12, 2017, the day after 

admission:

85. For comparison, this is MR. HAND’s signature on May 5, 2017, less 

than one week before his admission:

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86. For further comparison, this is MR. HAND’s signature on April 20, 

2017:

87. MR. HAND’s presentation on Thursday, May 11, 2017 mandated 

treatment and was so obvious that even a lay person would easily recognize the 

necessity for a doctor’s attention, that, if left unattended, posed a substantial risk of 

serious harm to MR. HAND.

88. On Thursday, May 11, 2017, Defendant RODRIGUEZ-RIVERA had 

knowledge of MR. HAND’s serious medical condition as indicated by his admission 

to RMC but clearly disregarded the risks associated with the serious medical 

condition based upon his admitting diagnosis and physician orders.

89. Despite MR. HAND’s presentation with a multitude of symptoms 

indicating a serious infection, Defendant RODRIGUEZ-RIVERA with deliberate 

indifference to the known risks of serious harm to MR. HAND, ignored the signs 

and symptoms of a worsening infection and chose not to perform a potential 

infectious disease assessment and chose not to prescribe any antibiotics to treat the 

infection.

/ / /

/ / /

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90. The nursing staff indicated upon admission at approximately 11:00 

p.m. on Thursday, May 11, 2017, that MR. HAND was continent of both bowel and 

bladder.

91. At 11:45 p.m., Defendant RODRIGUEZ-RIVERA was notified that his 

fever reached 101.9 degrees Fahrenheit. 

92. Defendant RODRIGUEZ-RIVERA chose not to return to see MR. 

HAND, but rather decided to take an easier course of treatment and simply ordered 

Tylenol to be administered. 

93. Even at this time, Defendant RODRIGUEZ-RIVERA continued to 

choose not to consider any source of potential infection and choose not to order 

antibiotics to treat MR. HAND’s worsening serious medical condition. Again, 

Defendant RODRIGUEZ-RIVERA with deliberate indifference to the known risks 

of serious harm to MR. HAND, ignored the signs and symptoms of a worsening 

infection and chose not to perform a potential infectious disease assessment and 

chose not to prescribe any antibiotics to treat the infection.

94. On Thursday, May 11, 2017, MR. HAND was only administered 

medications for nausea, but no other medications were provided.

95. MR. HAND was only seen by a physician one time on Thursday, May 

11, 2017 despite his severely worsening condition.

/ / /

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FRIDAY, MAY 12, 2017

96. At 5:30 a.m. the next day on Friday, May 12, 2017, MR. HAND’s blood 

was collected for a CBC panel, which would allow the health care providers, if 

reviewed, an opportunity to further evaluate MR. HAND’s overall health and detect 

a variety of diseases and conditions, such as infections.

97. Between 6:00 a.m. and 8:00 a.m., the nursing staff notated on two 

separate occasions that MR. HAND’s serious medical condition continued to worsen 

and that he was incontinent of bowel and that MR. HAND explained that he was too 

weak to get out of bed.

98. At approximately 8:47 a.m., MR. HAND was seen by Defendant 

SAINT CHARLES who without addressing any source for potential infection, other 

than suspecting gastroenteritis, diagnosed him as being dehydrated. 

99. Like Defendant RODRIGUEZ-RIVERA, Defendant EDEMEKONG 

and Defendant LAW before him, Defendant SAINT CHARLES ignored the signs 

and symptoms of MR. HAND’s worsening infection and serious medical condition, 

chose not to perform a potential infectious disease assessment to identify why MR. 

HAND’s condition had significantly worsened over the past week, and chose to 

address MR. HAND’s serious medical condition by pursuing easier but less effective 

treatment (i.e. adopting the prior health care providers diagnoses and treatment plan 

despite the worsening condition).

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100. Per the nursing notes, no antibiotics were administered to MR. HAND 

because they were awaiting PICC line placement.

101. At approximately 12:00 p.m., MR. HAND’s fever rose to about 101 

degrees Fahrenheit. There is no record indicating a physician follow up on this.

102. At approximately 3:38 pm, MR. HAND’s blood test results were 

available for all health care workers providing care to MR. HAND. 

103. The CBC blood results indicated elevated white blood cell count, 

elevated POLYS, and reduced LYMPHS objectively identifying a serious infection 

and serious medical condition.

104. The results were available for review from Friday, May 12, 2017 but 

no physician reviewed the records until three days later, after the weekend on 

Monday, May 15, 2017 when it was too late. During these three days, MR. HAND’s 

serious medical condition substantially worsened, but his treatment plan remained 

the same as when he was admitted.

105. Defendant EDEMEKONG, Defendant LAW, Defendant SAINT 

CHARLES, and Defendant RODRIGUEZ-RIVERA did not review the CBC blood 

test results when they were made available on Friday, May 12, 2017. Accordingly, 

they ignored vital information that would have helped them update their diagnosis 

and treatment plan of MR. HAND, and/or transfer MR. HAND, and/or to provide 

adequate treatment for MR. HAND’s serious medical condition.

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106. Rather, Defendant EDEMEKONG, Defendant LAW, Defendant 

SAINT CHARLES, and Defendant RODRIGUEZ-RIVERA acted with deliberate 

indifference to MR. HAND’s serious medical condition, and ignored the substantial 

risks associated with their failure to read the CBC test results and accurately 

diagnosis MR. HAND, their failure to provide adequate medical treatment to treat 

the worsening serious medical condition. Each Defendant totally failed to diagnose 

MR. HAND and update his treatment plan, and/or transfer MR. HAND, and/or to 

provide adequate treatment for MR. HAND’s serious medical condition.

107. At 8:45 p.m., four days after originally ordered, a replacement PICC 

line was attempted to be placed in MR. HAND’s right arm. Placement in his right 

arm, however, was aborted due to occlusion and instead placed in his left brachial 

vein.

108. MR. HAND was only seen by a physician one time on Friday, May 12, 

2017 despite his severely worsening condition.

SATURDAY, MAY 13, 2017

109. On Saturday, May 13, 2017, at 12:00 am, MR. HAND’s fever was still 

present and was nearly 101 degrees Fahrenheit. But MR. HAND was not seen by a 

physician to address his worsening condition.

110. The nursing staff noted that MR. HAND continued to be incontinent of 

bowel and bladder, now for at least 24 hours.

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111. The nursing staff noted that MR. HAND had very limited sensory 

perception, was bedrest with very limited mobility, and suffered from inadequate 

nutrition.

112. The nursing staff noted that MR. HAND now required assistance with 

all activities of daily living. 

113. At 1:30 pm. Defendant SANTIAGO saw MR. HAND one time at 1:30 

pm. MR. HAND’s vital signs were blood pressure 127/82, pulse 116, respirations 

19, temperature 103, oxygenation 96%.

114. MR. HAND’s vital signs during this time reflected an obvious serious 

medical condition with an ongoing fever and infection that was worsening as time 

progressed.

115. However, Defendant SANTIAGO, without looking at the CBC test 

results that had been available to him for one day simply ordered to maintain the 

same treatment protocol as ordered upon admission and to administer Tylenol for 

the worsening fever. He did not address the worsening symptoms, identify the 

source of the infection, or treat the infection.

116. At 3:00 p.m., the nursing staff noted that MR. HAND’s PICC line 

fluttered indicating incorrect placement of the PICC line. 

117. At 7:00 p.m., MR. HAND’s vital signs were blood pressure 125/98, 

pulse 102, respirations 22, temperature 102.9, and oxygenation 97%, however, there 

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was no physician response to MR. HAND’s worsening serious medical condition 

and MR. HAND did not see a physician until 1:40 p.m. the next day consistent with 

his one doctor visit each day during his admission.

118. Further on Saturday, May 13, 2017, per the nursing notes, no antibiotics 

were administered to MR. HAND because they were awaiting PICC line placement.

119. Despite MR. HAND’s rapid deterioration and worsening serious 

medical condition, as obviously indicated by MR. HAND’s presentation and the 

nursing notes, Defendant SANTIAGO failed to address any source of potential 

infection. Defendant SANTIAGO failed to review the CBC blood results that 

clearly and objectively identified that MR. HAND was suffering from a serious 

infection and serious medical condition and required immediate help.

120. Like Defendant RODRIGUEZ-RIVERA, Defendant EDEMEKONG, 

Defendant LAW, and Defendant SAINT CHARLES before him, Defendant 

SANTIAGO chose to ignore MR. HAND’s serious medical condition and chose to 

address MR. HAND’s serious medical condition by pursuing easier but less effective 

treatment. 

121. Further, on Saturday, May 13, 2017, Defendant EDEMEKONG, 

Defendant LAW, Defendant SAINT CHARLES, and Defendant RODRIGUEZRIVERA, like Defendant SANTIAGO, failed to review the CBC blood test results 

that had been available since Friday, May 12, 2017, and totally failed to diagnose 

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MR. HAND and update his treatment plan, and/or transfer MR. HAND, and/or to 

provide adequate treatment for MR. HAND’s serious medical condition. 

122. As of Saturday, May 13, 2017, Defendant EDEMEKONG, Defendant 

LAW, Defendant SAINT CHARLES, Defendant RODRIGUEZ-RIVERA, and 

Defendant SANTIAGO, all chose to ignore the obvious worsening of MR. HAND’s 

serious medical condition and the objective test results identifying a clear infection, 

and therefore did not provide MR. HAND any treatment for his serious medical 

condition that was killing and eventually killed MR. HAND.

123. MR. HAND was only seen by a physician one time on Saturday, May 

13, 2017 despite his severely worsening condition.

SUNDAY, MAY 14, 2017

124. On Sunday, May 14, 2017, the nursing staff noted that MR. HAND’s 

speech was slurred, and that MR. HAND remained incontinent of bowel and bladder, 

now for at least 48 hours.

125. The nursing staff noted that MR. HAND required assistance with all 

activities of daily living and a continued generalized overall weakness.

126. Defendant SANTIAGO’s progress note at 1:40 p.m. indicated that 

despite the clear deterioration of MR. HAND’s health and serious medical condition, 

Defendant SANTIAGO’s plan remained the same “to follow current treatment and 

follow close for any changes”. Still Defendant SANTIAGO failed to address or 

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consider any type of infection and chose to ignore the obvious changes noted by the 

nursing staff. 

127. Defendant SANTIAGO did not write any physician orders on Sunday, 

May 14, 2017.

128. Again, Defendant SANTIAGO failed to review the CBC blood results 

that clearly and objectively identified that MR. HAND was suffering from a serious 

infection and serious medical condition.

129. Despite MR. HAND’s even more rapid deterioration and worsening 

serious medical condition, as obviously indicated by MR. HAND’s presentation and 

the updated nursing notes and observations, Defendant SANTIAGO failed to 

address any source of potential infection. Defendant SANTIAGO failed to review 

the CBC blood results that clearly and objectively identified that MR. HAND was 

suffering from a serious infection and serious medical condition. 

130. Further, on Sunday, May 14, 2017, Defendant EDEMEKONG, 

Defendant LAW, Defendant SAINT CHARLES, and Defendant RODRIGUEZRIVERA, like Defendant SANTIAGO, failed to review the CBC blood test results 

that had been available since Friday, May 12, 2017, and totally failed to diagnose 

MR. HAND and update his treatment plan, and/or transfer MR. HAND, and/or to 

provide adequate treatment for MR. HAND’s serious medical condition. 

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131. As of Sunday, May 14, 2017, Defendant EDEMEKONG, Defendant 

LAW, Defendant SAINT CHARLES, Defendant RODRIGUEZ-RIVERA, and 

Defendant SANTIAGO, all chose to ignore the obvious worsening of MR. HAND’s 

serious medical condition and the objective test results identifying a clear infection, 

and therefore did not treat the serious medical condition that was killing and 

eventually killed MR. HAND.

132. Despite the rapid deterioration of MR. HAND’s serious medical 

condition, Defendant SANTIAGO’s plan remained the same “to follow current 

treatment and follow close for any changes”.

133. Defendant SANTIAGO continued to ignore MR. HAND’s serious 

medical condition and his worsening symptoms and chose to address MR. HAND’s 

serious medical condition by pursuing easier but less effective treatment. 

134. Again, MR. HAND was only seen by a physician one time on Sunday, 

May 14, 2017 despite his severely worsening condition.

MONDAY, MAY 15, 2017

135. On Monday, May 15, 2017, the nursing staff noted that MR. HAND 

was now disoriented to person, place, thing, time, and situation and lethargic.

136. The nursing staff noted that MR. HAND’s speech was slurred, now for 

at least 24 hours, and inappropriate.

/ / /

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137. The nursing staff noted that MR. HAND continued to be incontinent of 

bowel and bladder, now for at least three days, with hypoactive bowel sounds. 

138. The nursing staff continued to note that MR. HAND was suffering from 

a generalized weakness overall.

139. The nursing staff noted that MR. HAND was now total care and 

assistance was required with all activities of daily living. 

140. The nursing staff noted that MR. HAND is on total parenteral nutrition 

with difficulty swallowing.

141. The nursing staff noted that MR. HAND’s condition continued to 

deteriorate, as he was agitated, restless, had slurred speech, was immobile, and he 

was found to be at high risk for falls even though he was assessed only three days 

before as being a low risk. MR. HAND was assessed as needing “total care.” 

142. The nursing staff also noted diminished breath sounds in the lung exams 

and he needed additional oxygen.

143. A scab was noted on MR. HAND’s right hip for the first time, 

indicating a skin breakdown and/or pressure wound had developed.

144. The nursing staff noted that at 9:00 a.m., MR. HAND’s worsening 

condition was communicated to Defendant SANTIAGO.

145. At 10:30 a.m., Defendant SANTIAGO noted reviewing the Friday, 

May 12, 2017 CBC laboratory results, but he did not mention the abnormal values 

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or elevated white blood cell count and did not change MR. HAND’s treatment plan 

other than to treat a newly acquired pressure sore. 

146. MR. HAND’s vital signs during this time reflect a serious medical 

condition with an ongoing fever and infection.

147. Elsewhere in the records, is another copy of CBC laboratory results, 

which included a handwritten note by Defendant EDEMEKONG on Monday, May 

15, 2017 that the results were OK to file and to follow up with Defendant LAW on 

Tuesday, May 16, 2017. Defendant EDEMEKONG did not write any physicians 

orders for follow up.

148. No follow-up was ever done by any medical staff at RMC. 

149. A new dual lumen PICC line was placed in the afternoon of Monday, 

May 15, 2017, but there is no mention of any testing of the original PICC line for 

infection.

150. The only modifications Defendant SANTIAGO made in MR. HAND’s 

treatment plan on Monday, May 15, 2017, was to treat a newly developed pressure 

sore on his right hip. He continued to ignore the glaring and obvious infection that 

was killing MR. HAND.

151. Despite MR. HAND’s even more rapid deterioration and worsening 

serious medical condition, as obviously indicated by MR. HAND’s presentation and 

the updated nursing notes and observations, Defendant SANTIAGO failed to 

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address any source of potential infection. Defendant SANTIAGO failed to review 

the CBC blood results that clearly and objectively identified that MR. HAND was 

suffering from a serious infection and serious medical condition. 

152. Further, on Monday, May 15, 2017, Defendant EDEMEKONG, 

Defendant LAW, Defendant SAINT CHARLES, and Defendant RODRIGUEZRIVERA, and Defendant SANTIAGO failed to acknowledge the significant 

findings of the CBC blood test results that had been available since Friday May 12, 

2017, and totally failed to diagnose MR. HAND and update his treatment plan, 

and/or transfer MR. HAND, and/or to provide adequate treatment for MR. HAND’s 

serious medical condition. 

153. As of Monday, May 15, 2017, Defendant EDEMEKONG, Defendant 

LAW, Defendant SAINT CHARLES, Defendant RODRIGUEZ-RIVERA, and 

Defendant SANTIAGO, all chose to ignore the obvious worsening of MR. HAND’s 

serious medical condition and the objective test results identifying a clear infection, 

and therefore did not treat the serious medical condition that was killing and 

eventually killed MR. HAND.

154. There were no changes to the treatment of MR. HAND’s significantly 

worsening serious medical condition. The serious medical condition was ignored, 

and GLENN MICHELL HAND was left to deteriorate further, to the point of no 

return on the morning of Tuesday, May 16, 2017.

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TUESDAY, MAY 16, 2017

155. At 8:30 am, the nursing staff notes that MR. HAND is disoriented and 

unresponsive. His vital signs were 56% oxygenation, blood pressure 130/81, pulse 

120, 35 respirations, and a temperature of 100 degrees Fahrenheit.

156. The nursing staff notes that MR. HAND had an abnormal heart rate and 

rhythm and bilateral calf redness, tenderness, and swelling.

157. The nursing staff, again, noted diminished breath sounds.

158. MR. HAND was placed on a ventilator, the code team was called, and 

MR. HAND was sent via EMS to UF Health Shands Hospital (“Shands”) in 

Gainesville, Florida with a stroke alert and observed “seizure like activity”.

WEDNESDAY, MAY 17, 2017 – THURSDAY, JUNE 1, 2017

159. At Shands, MR. HAND underwent several diagnostic and laboratory 

tests that indicated that MR. HAND was suffering from extensive colonization of 

his body by Pseudomonas, one of the most common hospital-acquired bacteria and 

that his heart, brain, liver, and other vital organs had been seeded with septic emboli. 

MR. HAND was in respiratory failure and required intubation. MR. HAND was 

diagnosed with a large middle cerebral artery (MCA) infarct on the left side with 

multiple bilateral infarcts, endocarditis with mitral valve vegetation, pseudomonas, 

bacterial meningitis, ventriculitis, and sepsis with multiple organ dysfunction. 

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160. The physicians at Shands determined that the source of the infection 

that caused MR. HAND’s serious medical condition was the PICC line. 

161. This was the source of the infection that Defendant LAW, Defendant 

EDEMEKONG, Defendant SANTIAGO, Defendant SAINT CHARLES, and 

Defendant RODRIGUEZ-RIVERA totally failed to diagnose or consider despite the 

glaring and obvious signs, symptoms, and the unread and ignored diagnostic tests 

clearly indicated.

162. On or about Wednesday, May 31, 2017, upon consultation with MR. 

HAND’s medical team at Shands, his family decided on a withdrawal of care based 

on his poor prognosis.

163. MR. HAND was extubated and was transferred back to RMC on 

Wednesday, May 31, 2017 with comfort care goals only. 

164. On or about Thursday, June 1, 2017, at 1:35 a.m., MR. HAND died and 

was pronounced dead by Defendant RODRIGUEZ-RIVERA at RMC.

165. On Thursday, June 1, 2017, Defendant RODRIGUEZ-RIVERA 

determined MR. HAND’s cause of death was sepsis and respiratory failure.

166. MR. HAND’s death came just approximately three months before his 

release from his eighteen-month prison sentence.

/ / /

/ / /

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COUNT I

NEGLIGENCE v. DOC

167. Plaintiff realleges and incorporates by reference paragraphs 1-165 as 

if set forth fully herein and further states:

168. This claim is brought pursuant to Florida’s Wrongful Death Act, 

section 768.16, et. seq., Florida Statutes.

169. At all times relevant hereto, MR. HAND was in the custody and 

control of the Defendant DOC, as an inmate at RMC.

170. At that time and place the Defendant DOC had in its employment 

Correctional Officers and other staff, who were at all times material herein working 

within the course and scope of their employment with the Defendant DOC.

171. From approximately May 9, 2017 until May 11, 2017, MR. HAND was 

unresponsive and unable to care for himself and/or ask for any type of medical 

assistance. 

172. On or about May 11, 2017, MR. HAND’s bunk mate alerted DOC staff

that he was unresponsive and had been unresponsive for a significant period of time. 

173. At all times material hereto, Defendant DOC had a non-delegable duty 

to use reasonable care in the operation of its facility and to use reasonable care in 

providing for the care, treatment and supervision of the inmates in its custody. 

174. Defendant DOC is vicariously liable for the negligence of its 

employees, agents, and/or servants.

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175. Defendant DOC is directly liable for its failure to screen, train, retrain, 

supervise, discipline and terminate its employees, agents, and/or servants.

176. During said period of time, DOC staff failed to properly monitor, 

supervise and/or assess MR. HAND and failed to call for medical staff of any sort 

to check on MR. HAND’s condition and/or failed to timely transfer MR. HAND to 

be evaluated and/or failed to see that MR. HAND receive any care or treatment, 

during which time he was incapacitated and unable to request or ask for help and/or 

aid and/or medical assistance, which said failures did cause and contribute to MR. 

HAND’s death. 

177. As a direct and proximate result of Defendant DOC’s negligence and 

that of its employees, MR. HAND died on or about June 1, 2017. 

178. WHEREFORE, Plaintiff, the ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. HAND, Personal Representative seeks relief 

as noted below. 

COUNT II

DELIBERATE INDIFFERENCE & FAILURE TO TREAT UNDER 42 

U.S.C. § 1983 v. CENTURION

179. Plaintiff realleges and incorporates by reference paragraphs 1-165 as 

if set forth fully herein and further states:

180. Plaintiff is entitled to relief against Defendant CENTURION for a 

systemic failure to treat known serious medical conditions in violation of the Eighth 

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Amendment to the U.S. Constitution, as further set out in the General Allegations, 

above.

181. Plaintiff is entitled to relief against Defendant CENTURION because 

it was deliberately indifferent in maintaining policies and procedures, customs and 

practices that made constitutional violations such as those suffered by MR. HAND 

substantially certain to happen and ignored a history of known such abuses.

182. Defendant CENTURION had a duty to provide medical treatment for 

a known serious medical condition under the Eighth Amendment to the U.S. 

Constitution.

183. Defendant CENTURION was also deliberately indifferent in failing to 

treat a known serious medical condition in that it also had a custom and practice of 

delaying and denying care to maximize its profits and of demanding that its 

employees make decisions calculated to save money rather than to provide needed

medical care, including decisions that delayed or denied care, resulting in more 

serious injuries than otherwise would have been suffered and/or death.

184. Defendant CENTURION took over the contract for prisoner health 

care from Corizon, LLC in 2016 and hired most of Corizon’s medical staff, medical 

department organization and continued the former health care contractor’s denial 

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and delay of care. Corizon’s prior policy and practice of denying prisoners 

medical care is evidenced by the following: 

a. The Corizon contract became operational in 2013. As early as 

2014, the DOC expressed concern that audits showed Corizon failing to provide 

care to prisoners.

b. In 2015, DOC Secretary Julie Jones reported that private health 

care providers, including Corizon, were not performing “at the level that’s covered 

by their contracts.” By late 2015, Corizon was being fined by the State of Florida 

for failure to live up to its contract obligations to provide adequate health care to 

prisoners.

c. Corizon failed to provide, or cooperated in, maintained, 

enforced, tolerated, or condoned, the failure to provide timely and adequate 

medical care to an inmate suffering a life-threatening medical condition.

d. Corizon had a custom of basing medical care on cost rather than 

medical judgment in deciding what treatment to provide and when it should be 

provided, and a custom of not providing more expensive care to prisoners except 

when the condition had reached an emergency stage and sometimes not even then.

/ / /

/ / /

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e. As a matter of policy, costly care was generally provided, if 

ever, only in life- threatening situations without regard for the pain and debilitation 

to the patient.

f. Corizon has enforced this policy, practice, and custom around 

the nation so that Corizon has been terminated as a prison health care provider in 

several states.

g. In Florida, one year after Corizon took over prisoner medical 

care, then-DOC Secretary Michael Crews sent a letter to Corizon threatening to 

withhold payment and remove facilities from Corizon control if improvements 

were not made to the level of care being provided to Florida prisoners.

h. The letter stated that Corizon’s “level of care continues to fall 

below the contractually required standard.” Specifically, Crews identified failures 

in patient care issues, utilization management, and communication.

185. Defendant CENTURION has a policy and custom of failing to provide 

medical care and medical treatment for serious medical conditions as follows:

a. Defendant CENTURION has continued the Corizon policy of 

denying and delaying health care to prisoners – as little care as possible, as late as 

possible, as is evidenced by the fact that MR. HAND was not transferred to a facility 

to address his serious medical condition until he was having seizures and was 

completely unresponsive and in a vegetative state, after approximately two weeks 

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of severely deteriorating condition;

b. Defendant CENTURION has a national corporate policy to 

provide prisoners as little care as possible as late as possible in order to maximize 

profits;

c. Because Defendant CENTURION encourages employees to

minimize health care cost even when it put prisoners at risk, medical staff felt free 

to deny care;

d. Defendant CENTURION short-staffs medical positions so 

inmates, such as MR. HAND, are forced to wait hours or are never seen by a 

medical physician;

e. Defendant CENTURION has a practice of denying care then 

fabricating a “refusal of care,” writing “refused to sign” where the inmate’s 

signature should be.

f. Defendant CENTURION fails to discipline medical staff for 

withholding medical care; and

g. Defendant CENTURION has a practice of under-paying 

medical doctors but permitting them to work short hours, so they are rarely 

available to inmates.

186. That during the period of time that MR. HAND was a patient of the 

Defendant CENTURION, Defendant CENTURION was deliberately indifferent in 

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failing to provide needed medical care for a known serious medical condition. Said 

deliberate indifference included, but is not limited to the commission and/or 

omission of the following acts:

a. Maintaining policies of denial, delay, and minimization of care 

in order to cut costs and maximize profits in its Florida contracts and across the 

nation.

b. Short-staffing medical positions needed for timely care and 

treatment;

c. Failure to provide MR. HAND timely treatment for infection or 

to take him to a medical facility or to medical providers who could provide 

treatment;

d. Failure to ensure that MR. HAND provide proper treatment and 

health care follow-up of a serious medical condition, such that he lay unresponsive 

and unattended to for over two days in his cell;

e. Failure to maintain policies and protocols to make sure that 

prisoners with serious chronic and acute medical conditions were timely treated;

f. Failure to timely respond to changes in MR. HAND’s medical 

condition resulting widespread infection including pseudomonas, bacterial 

meningitis, ventriculitis, and sepsis with multiple organ dysfunction, which caused 

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and lead to his death;

g. Failure to maintain accurate records to provide a guide for 

treatment.

187. That as a direct and proximate result of any of the above acts of deliberate 

indifference and Defendant’s denial of care, MR. HAND was killed.

188. As it was necessary for Plaintiff to hire the undersigned attorney to 

represent Plaintiff, Plaintiff is entitled to an award of attorneys’ fees and costs. 

189. WHEREFORE, Plaintiff, the ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. HAND, Personal Representative seeks relief 

as noted below.

COUNT III

DELIBERATE INDIFFERENCE & FAILURE TO TREAT UNDER 42 

U.S.C. § 1983 v. FRANCIS DUCOSIN ONG, M.D.; DAVID E. RODRIGUEZRIVERA, M.D., a.k.a. DAVID RODRIGUEZ, M.D.; JEAN MAX SAINT 

CHARLES, M.D.; JUAN SANTIAGO, M.D. a.k.a JUAN SANTIAGO

RIVERA, M.D.; PETER FABIAN EDEMEKONG, M.D.; DRIANNA 

NISHELL LAW, ARNP (individual capacity claims)

(COUNT DISMISSED, SEE COUNTS XIII - XVII)

COUNT IV

MEDICAL NEGLIGENCE v. CENTURION OF FLORIDA 

190. Plaintiff realleges and incorporates by reference paragraphs 1-165 as if 

set forth fully herein and further states:

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191. Defendant CENTURION had a duty to properly evaluate, diagnose, 

manage, monitor and treat its patient, Plaintiff, MR. HAND.

192. Defendant CENTURION had a duty to hire qualified employees, 

servants, and/or agents, train and retrain their employees, servants, and/or agents, 

and supervise their employees, servants, and/or agents to properly evaluate, 

diagnose, manage, monitor and treat its patient, Plaintiff, MR. HAND.

193. Defendant CENTURION, through its employees, servants and agents 

(actual and/or apparent), including nurses, clerks, doctors and/or ancillary staff at 

RMC, breached that duty and were negligent for at least the following reasons:

a. Failing to adequately inform MR. HAND;

b. Failing to adequately recognize, timely diagnose, and treat MR. 

HAND;

c. Failing to conduct adequate discharge planning prior to MR. 

HAND transfer to general population on April 13, 2017, which increased his risk of 

developing serious illness and infection;

d. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s symptoms and abnormal vital signs;

e. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s worsening condition during his RMC admission;

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f. Failing to timely order and review appropriate diagnostic and 

laboratory tests to further evaluate and assess MR. HAND’s condition;

g. Failing to timely administer antibiotics to treat MR. HAND’s 

infection;

h. Failing to coordinate care between health care providers and 

advocate for MR. HAND;

i. Failing to timely provide for a transfer to a different facility for 

appropriate care and/or intensive care with constant medical monitoring;

j. Failing to timely, accurately, and appropriately document MR. 

HAND;

k. Failing to ensure that MR. HAND was evaluated by his primary 

care provider;

l. Prescribing ibuprofen for MR. HAND, a mediation known for 

causing GI problems;

m. Failing to address MR. HAND’s serious complaints of 

abdominal pain, nausea, vomiting, and diarrhea;

n. Falsifying health records;

o. Failing to timely notify physicians of MR. HAND’s abnormal 

assessments, and failing to document any follow-up assessments; and

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p. Failing to timely, accurately, and appropriately document MR. 

HAND’s condition in his medical records.

q. Failing to timely examine and see MR. HAND.

r. Failing to have appropriate personnel who could properly 

diagnose, care, and treat MR. HAND’s condition;

s. Failing to fully or sufficiently inform MR. HAND or his wife, 

PHYLLIS A. HAND, that she was suffering from a severe medical condition;

t. Failing to inform MR. HAND or his wife, PHYLLIS A. HAND, 

of any medically acceptable alternative diagnostic procedures that could confirm his 

condition;

u. Failing to inform MR. HAND or his wife, PHYLLIS A. HAND, 

of any medically accepted alternative treatments or procedures, and of the substantial 

risks and hazards inherent in the conditions he was suffering from;

v. Failing to properly communicate and/or provide continuity of 

care with regard to MR. HAND’s condition;

w. Failing to timely and properly interpret MR. HAND’s diagnostic 

test results; 

x. Failing to properly order follow up and provide appropriate care 

to MR. HAND following diagnostic test results;

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y. Failing, pursuant to common law and pursuant to Florida Statutes 

§766.110, to ensure that the physicians and other health care providers who treated 

MR. HAND, including but not limited to the those who issued physician orders and 

failed to follow and complete the physician orders necessary to properly diagnose 

and treat patients, were qualified and had sufficient knowledge and training in the 

treatment of MR. HAND’s condition;

z. Failing to perform diagnostic tests necessary to diagnose MR. 

HAND and to formulate and institute a proper treatment plan for him;

aa. Failing to timely recognize, document, identify and/or diagnose 

MR. HAND;

bb. Failing to take all other appropriate steps to ensure that MR. 

HAND had a proper course of treatment that met the applicable standard of care; 

and;

cc. Failing to timely transfer MR. HAND to a facility with a higher 

level of care necessary to adequately treat and care for MR. HAND;

dd. Failing to maintain adequate policies and procedures, or if there 

were, failing to follow the policies and procedures.

194. As a direct and proximate result of the negligence described in this 

Count, MR. HAND died and his Estate, his surviving wife, PHYLLIS A. HAND 

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have suffered damages in the past and will continue to suffer in the future damages 

and seeks relief as noted below.

195. Plaintiff has complied with all common law and statutory conditions 

precedent to bringing this action, including but not limited to all applicable 

provisions of the Florida Medical Malpractice Act found in Chapter 766, Florida 

Statutes, and all applicable provisions of Florida Statute §768.28, including timely 

providing the required written notice to Defendant CENTURION OF FLORIDA.

196. Undersigned counsel for Plaintiff hereby certifies that a reasonable 

investigation has been undertaken in connection with this case and said investigation 

has given rise to a good faith belief that grounds exist for a medical negligence action 

against Defendant CENTURION OF FLORIDA.

COUNT V

MEDICAL NEGLIGENCE v. FRANCIS DUCOSIN ONG, M.D.

(COUNT DISMISSED)

COUNT VI

MEDICAL NEGLIGENCE v. DAVID E. RODRIGUEZ-RIVERA, M.D., 

a.k.a. DAVID RODRIGUEZ, M.D.

197. Plaintiff realleges and incorporates by reference paragraphs 1-165 as if 

set forth fully herein and further states:

/ / /

/ / /

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198. Defendant RODRIGUEZ-RIVERA had a duty to render proper care 

and treatment to MR. HAND in accordance with the prevailing standard of care for 

similar health care providers under similar circumstances.

199. Defendant RODRIGUEZ-RIVERA breached that duty and was 

negligent for at least the following reasons:

a. Failing to adequately inform MR. HAND;

b. Failing to adequately recognize, timely diagnose, and treat MR. 

HAND;

c. Failing to conduct adequate discharge planning prior to MR. 

HAND transfer to general population on April 13, 2017, which increased his risk of 

developing serious illness and infection;

d. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s symptoms and abnormal vital signs;

e. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s worsening condition during his RMC admission;

f. Failing to timely order and review appropriate diagnostic and 

laboratory tests to further evaluate and assess MR. HAND’s condition;

g. Failing to timely administer antibiotics to treat MR. HAND’s 

infection;

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h. Failing to coordinate care between health care providers and 

advocate for MR. HAND;

i. Failing to timely provide for a transfer to a different facility for 

appropriate care and/or intensive care with constant medical monitoring; and

j. Failing to timely, accurately, and appropriately document MR. 

HAND.

200. The actions and omissions of Defendant RODRIGUEZ-RIVERA, 

described above, were negligent and below the applicable standards of care for 

physicians practicing the specialty of correctional health services pursuant to Florida 

Statutes section 766.102, i.e., below that level of care, skill, and treatment which, in 

light of all relevant surrounding circumstances, is recognized as acceptable and 

appropriate by reasonably prudent similar healthcare providers.

201. As a direct and proximate result of the negligence described in this 

Count, MR. HAND died and his Estate, his surviving wife, PHYLLIS A. HAND 

have suffered damages in the past and will continue to suffer in the future damages 

and seeks relief as noted below.

202. Plaintiff has complied with all common law and statutory conditions 

precedent to bringing this action, including but not limited to all applicable 

provisions of the Florida Medical Malpractice Act found in Chapter 766, Florida 

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Statutes, and all applicable provisions of Florida Statute §768.28, including timely 

providing the required written notice to Defendant RODRIGUEZ-RIVERA.

203. Undersigned counsel for Plaintiff hereby certifies that a reasonable 

investigation has been undertaken in connection with this case and said investigation 

has given rise to a good faith belief that grounds exist for a medical negligence action 

against Defendant RODRIGUEZ-RIVERA.

COUNT VII

MEDICAL NEGLIGENCE v. JEAN MAX SAINT CHARLES, M.D.

204. Plaintiff realleges and incorporates by reference paragraphs 1-165 as if 

set forth fully herein and further states:

205. Defendant SAINT CHARLES had a duty to render proper care and 

treatment to MR. HAND in accordance with the prevailing standard of care for 

similar health care providers under similar circumstances.

206. Defendant SAINT CHARLES breached that duty and was negligent for 

at least the following reasons:

a. Failing to adequately inform MR. HAND;

b. Failing to adequately recognize, timely diagnose, and treat MR. 

HAND;

/ / /

/ / /

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c. Failing to conduct adequate discharge planning prior to MR. 

HAND transfer to general population on April 13, 2017, which increased his risk of 

developing serious illness and infection;

d. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s symptoms and abnormal vital signs;

e. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s worsening condition during his RMC admission;

f. Failing to timely order and review appropriate diagnostic and 

laboratory tests to further evaluate and assess MR. HAND’s condition;

g. Failing to timely administer antibiotics to treat MR. HAND’s 

infection;

h. Failing to coordinate care between health care providers and 

advocate for MR. HAND;

i. Failing to timely provide for a transfer to a different facility for 

appropriate care and/or intensive care with constant medical monitoring; and

j. Failing to timely, accurately, and appropriately document MR. 

HAND.

207. The actions and omissions of Defendant SAINT CHARLES, described 

above, were negligent and below the applicable standards of care for physicians 

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49

practicing the specialty of specialty of correctional health services pursuant to 

Florida Statutes section 766.102, i.e., below that level of care, skill, and treatment 

which, in light of all relevant surrounding circumstances, is recognized as acceptable 

and appropriate by reasonably prudent similar healthcare providers.

208. As a direct and proximate result of the negligence described in this 

Count, MR. HAND died and his Estate, his surviving wife, PHYLLIS A. HAND 

have suffered damages in the past and will continue to suffer in the future damages 

and seeks relief as noted below.

209. Plaintiff has complied with all common law and statutory conditions 

precedent to bringing this action, including but not limited to all applicable 

provisions of the Florida Medical Malpractice Act found in Chapter 766, Florida 

Statutes, and all applicable provisions of Florida Statute §768.28, including timely 

providing the required written notice to Defendant SAINT CHARLES.

210. Undersigned counsel for Plaintiff hereby certifies that a reasonable 

investigation has been undertaken in connection with this case and said investigation 

has given rise to a good faith belief that grounds exist for a medical negligence action 

against Defendant SAINT CHARLES.

/ / /

/ / /

/ / /

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COUNT VIII

MEDICAL NEGLIGENCE v. JUAN SANTIAGO, M.D. a.k.a. JUAN 

SANTIAGO RIVERA, M.D.

211. Plaintiff realleges and incorporates by reference paragraphs 1-165 as if 

set forth fully herein and further states:

212. Defendant SANTIAGO had a duty to render proper care and treatment 

to MR. HAND in accordance with the prevailing standard of care for similar health 

care providers under similar circumstances.

213. Defendant SANTIAGO breached that duty and was negligent for at 

least the following reasons:

a. Failing to adequately inform MR. HAND;

b. Failing to adequately recognize, timely diagnose, and treat MR. 

HAND;

c. Failing to conduct adequate discharge planning prior to MR. 

HAND transfer to general population on April 13, 2017, which increased his risk of 

developing serious illness and infection;

d. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s symptoms and abnormal vital signs;

e. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s worsening condition during his RMC admission;

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f. Failing to timely order and review appropriate diagnostic and 

laboratory tests to further evaluate and assess MR. HAND’s condition;

g. Failing to timely administer antibiotics to treat MR. HAND’s 

infection;

h. Failing to coordinate care between health care providers and 

advocate for MR. HAND;

i. Failing to timely provide for a transfer to a different facility for 

appropriate care and/or intensive care with constant medical monitoring; and

j. Failing to timely, accurately, and appropriately document MR. 

HAND.

214. The actions and omissions of Defendant SANTIAGO, described above, 

were negligent and below the applicable standards of care for physicians practicing 

the specialty of specialty of correctional health services pursuant to Florida Statutes 

section 766.102, i.e., below that level of care, skill, and treatment which, in light of 

all relevant surrounding circumstances, is recognized as acceptable and appropriate 

by reasonably prudent similar healthcare providers.

215. As a direct and proximate result of the negligence described in this 

Count, MR. HAND died and his Estate, his surviving wife, PHYLLIS A. HAND 

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52

have suffered damages in the past and will continue to suffer in the future damages 

and seeks relief as noted below.

216. Plaintiff has complied with all common law and statutory conditions 

precedent to bringing this action, including but not limited to all applicable 

provisions of the Florida Medical Malpractice Act found in Chapter 766, Florida 

Statutes, and all applicable provisions of Florida Statute §768.28, including timely 

providing the required written notice to Defendant SANTIAGO.

217. Undersigned counsel for Plaintiff hereby certifies that a reasonable 

investigation has been undertaken in connection with this case and said investigation 

has given rise to a good faith belief that grounds exist for a medical negligence action 

against Defendant SANTIAGO.

COUNT IX

MEDICAL NEGLIGENCE v. PETER FABIAN EDEMEKONG, M.D.

218. Plaintiff realleges and incorporates by reference paragraphs 1-165 as if 

set forth fully herein and further states:

219. Defendant EDEMEKONG had a duty to render proper care and 

treatment to MR. HAND in accordance with the prevailing standard of care for 

similar health care providers under similar circumstances.

220. Defendant EDEMEKONG breached that duty and was negligent for at 

least the following reasons:

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a. Failing to adequately inform MR. HAND;

b. Failing to adequately recognize, timely diagnose, and treat MR. 

HAND;

c. Failing to conduct adequate discharge planning prior to MR. 

HAND transfer to general population on April 13, 2017, which increased his risk of 

developing serious illness and infection;

d. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s symptoms and abnormal vital signs;

e. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s worsening condition during his RMC admission;

f. Failing to timely order and review appropriate diagnostic and 

laboratory tests to further evaluate and assess MR. HAND’s condition;

g. Failing to timely administer antibiotics to treat MR. HAND’s 

infection;

h. Failing to coordinate care between health care providers and 

advocate for MR. HAND;

i. Failing to timely provide for a transfer to a different facility for 

appropriate care and/or intensive care with constant medical monitoring; and

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j. Failing to timely, accurately, and appropriately document MR. 

HAND.

221. The actions and omissions of Defendant EDEMEKONG, described 

above, were negligent and below the applicable standards of care for physicians 

practicing the specialty of specialty of correctional health services pursuant to 

Florida Statutes section 766.102, i.e., below that level of care, skill, and treatment 

which, in light of all relevant surrounding circumstances, is recognized as acceptable 

and appropriate by reasonably prudent similar healthcare providers.

222. As a direct and proximate result of the negligence described in this 

Count, MR. HAND died and his Estate, his surviving wife, PHYLLIS A. HAND 

have suffered damages in the past and will continue to suffer in the future damages 

and seeks relief as noted below.

223. Plaintiff has complied with all common law and statutory conditions 

precedent to bringing this action, including but not limited to all applicable 

provisions of the Florida Medical Malpractice Act found in Chapter 766, Florida 

Statutes, and all applicable provisions of Florida Statute §768.28, including timely 

providing the required written notice to Defendant EDEMEKONG.

224. Undersigned counsel for Plaintiff hereby certifies that a reasonable 

investigation has been undertaken in connection with this case and said investigation 

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55

has given rise to a good faith belief that grounds exist for a medical negligence action 

against Defendant EDEMEKONG.

COUNT X

MEDICAL NEGLIGENCE v. DRIANNA NISHELL LAW, ARNP

225. Plaintiff realleges and incorporates by reference paragraphs 1-165 as if 

set forth fully herein and further states:

226. Defendant LAW had a duty to render proper care and treatment to MR. 

HAND in accordance with the prevailing standard of care for similar health care 

providers under similar circumstances.

227. Defendant LAW breached that duty and was negligent for at least the 

following reasons:

a. Failing to adequately inform MR. HAND;

b. Failing to adequately recognize, timely diagnose, and treat MR. 

HAND;

c. Failing to conduct adequate discharge planning prior to MR. 

HAND transfer to general population on April 13, 2017, which increased his risk of 

developing serious illness and infection;

d. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s symptoms and abnormal vital signs;

/ / /

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e. Failing to timely, appropriately, and adequately assess and treat 

MR. HAND’s worsening condition during his RMC admission;

f. Failing to timely order and review appropriate diagnostic and 

laboratory tests to further evaluate and assess MR. HAND’s condition;

g. Failing to timely administer antibiotics to treat MR. HAND’s 

infection;

h. Failing to coordinate care between health care providers and 

advocate for MR. HAND;

i. Failing to timely provide for a transfer to a different facility for 

appropriate care and/or intensive care with constant medical monitoring;

j. Failing to timely, accurately, and appropriately document MR. 

HAND;

k. Failing to ensure that MR. HAND was evaluated by his primary 

care provider after her encounter with MR. HAND on May 5 or May 8, 207, for 

follow-up per her treatment plan;

l. Prescribing ibuprofen for MR. HAND, a mediation known for 

causing GI problems;

m. Failing to address MR. HAND’s serious complaints of 

abdominal pain, nausea, vomiting, and diarrhea;

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n. Falsifying health records;

o. Failing to timely notify physicians of MR. HAND’s abnormal 

assessments, and failing to document any follow-up assessments; and

p. Failing to timely, accurately, and appropriately document MR. 

HAND’s condition in his medical records.

228. The actions and omissions of Defendant LAW, described above, were 

negligent and below the applicable standards of care for physicians practicing the 

specialty of specialty of correctional health services pursuant to Florida Statutes 

section 766.102, i.e., below that level of care, skill, and treatment which, in light of 

all relevant surrounding circumstances, is recognized as acceptable and appropriate 

by reasonably prudent similar healthcare providers.

229. As a direct and proximate result of the negligence described in this 

Count, MR. HAND died and his Estate, his surviving wife, PHYLLIS A. HAND 

have suffered damages in the past and will continue to suffer in the future damages 

and seeks relief as noted below.

230. Plaintiff has complied with all common law and statutory conditions 

precedent to bringing this action, including but not limited to all applicable 

provisions of the Florida Medical Malpractice Act found in Chapter 766, Florida 

Statutes, and all applicable provisions of Florida Statute §768.28, including timely 

providing the required written notice to Defendant LAW.

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58

231. Undersigned counsel for Plaintiff hereby certifies that a reasonable 

investigation has been undertaken in connection with this case and said investigation 

has given rise to a good faith belief that grounds exist for a medical negligence action 

against Defendant LAW.

COUNT XI

VICARIOUS LIABILITY v. MHM HEALTH PROFESSIONALS

232. Plaintiff realleges and incorporates by reference paragraphs 1-165 as if 

set forth fully herein and further states:

233. Defendant MHM is vicariously liable to the ESTATE OF GLENN 

MITCHELL HAND, and PHYLLIS A. HAND, his surviving wife, for the harms 

and damages sustained as a result of the medical negligence of Defendant 

RODRIGUEZ-RIVERA, Defendant SAINT CHARLES, Defendant SANTIAGO, 

Defendant EDEMEKONG, Defendant LAW, and the nursing staff, in that, 

Defendant RODRIGUEZ-RIVERA, Defendant SAINT CHARLES, Defendant 

SANTIAGO, Defendant EDEMEKONG, Defendant LAW, and the nursing staff 

were either employees, agents and/or borrowed servants of Defendant MHM, and at 

all times material, Defendant RODRIGUEZ-RIVERA, Defendant SAINT 

CHARLES, Defendant SANTIAGO, Defendant EDEMEKONG, Defendant LAW, 

and the nursing staff were acting within the course and scope of his/her/its/their 

employment and/or agency relationship with Defendant MHM.

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234. As a direct and proximate result of the medical negligence described in 

this Count, MR. HAND died and his Estate, his surviving wife, PHYLLIS A. HAND 

have suffered damages in the past and will continue to suffer in the future damages 

and seeks relief as noted below.

COUNT XII

VICARIOUS LIABILITY v. FRANCIS D. ONG, M.D., P.A. 

(COUNT DISMISSED)

COUNT XIII

DELIBERATE INDIFFERENCE & FAILURE TO TREAT UNDER 42 

U.S.C. § 1983 v. DAVID E. RODRIGUEZ-RIVERA, M.D., a.k.a. DAVID 

RODRIGUEZ, M.D. 

(individual capacity claim)

235. Plaintiff realleges and incorporates by reference all prior paragraphs 

as if set forth fully herein and further states:

236. MR. HAND was a patient in the care of Defendant RODRIGUEZRIVERA while incarcerated at RMC.

237. At all times relevant to this lawsuit, Defendant RODRIGUEZ-RIVERA 

was acting under the color of statute, ordinance, custom, or usage in his individual 

capacity as a medical doctor at RMC.

238. Plaintiff is entitled to relief against Defendant RODRIGUEZ-RIVERA 

for violation of the Eighth Amendment to the U.S. Constitution.

/ / /

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60

239. Defendant RODRIGUEZ-RIVERA acted with deliberate indifference 

included, but not limited to the commission and/or omission of the following acts:

a. Failing to timely diagnose MR. HAND;

b. Ignoring and failing to review critical test results indicating a 

serious infection;

c. Failing to address the source of MR. HAND’s infection;

d. Failure to provide MR. HAND timely treatment for infection or 

to transfer him to medical providers or a medical facility that could provide 

treatment;

e. Unconscionable adherence to a medical provider who 

consistently failed to provide needed care to prisoners to save costs and maximize 

profit;

f. Failure to ensure that MR. HAND received follow-up evaluation 

and treatment;

g. Failure to maintain policies and protocols to make sure that 

prisoners, such as MR. HAND, with serious chronic and acute medical conditions 

are timely treated;

/ / /

/ / /

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h. Continual and systematic failure to respond to MR. HAND’s 

changing medical condition in a timely manner, over a period of approximately two 

weeks, resulting his death;

240. Defendant RODRIGUEZ-RIVERA knew about MR. HAND’s 

documented medical needs and symptoms, knew that MR. HAND’s basic medical 

needs were not being met and that the treatment offered was totally insufficient in 

addressing his symptoms and serious medical condition. 

241. Defendant RODRIGUEZ-RIVERA totally failed to diagnose MR. 

HAND and allowed him to become septic and sustain and suffer from multi-organ 

failure while being admitted at RMC without any meaningful plan to diagnose, 

monitor, or treat his rapidly deteriorating medical condition.

242. Defendant RODRIGUEZ-RIVERA disregarded MR. HAND’s 

symptoms, vital signs, and lab results and failed to treat him, despite knowing that 

he required adequate medical care. 

243. Defendant RODRIGUEZ-RIVERA failed to even acknowledge MR. 

HAND’s symptoms, vital signs, or the critical test results that objectively identified 

a serious infection. 

244. Defendant RODRIGUEZ-RIVERA failed to perform any assessment 

to identify the source of MR. HAND’s infection.

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245. Defendant RODRIGUEZ-RIVERA was obviously indifferent to MR. 

HAND’s serious medical needs and failed to address or attempt to address his 

symptoms in any meaningful way whatsoever. 

246. Defendant RODRIGUEZ-RIVERA provided such cursory treatment to 

MR. HAND that is essentially amounted to no treatment at all. Further, the 

treatment, if any provided at all, was pursued by easier less effective means.

247. Defendant RODRIGUEZ-RIVERA totally failed to acknowledge or 

follow up on MR. HAND’s serious medical needs in any way.

248. Defendant RODRIGUEZ-RIVERA never reviewed the critical lab 

results that indicated a severe infection, that had he reviewed, would have results in 

further physical evaluation and medical treatment and/or a transfer to a different 

facility. Instead, MR. HAND did not receive necessary or thorough evaluations, 

ultimately leading to his death.

249. Defendant RODRIGUEZ-RIVERA was deliberately, recklessly and 

wantonly indifferent to MR. HAND’s health and grossly negligent in the care (or 

lack thereof) provided to MR. HAND.

250. The acts and omissions of Defendant RODRIGUEZ-RIVERA amount 

to deliberate indifference to MR. HAND’s serious medical needs and were a direct 

and proximate cause of MR. HAND’s death.

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251. The acts and omissions of these Defendant RODRIGUEZ-RIVERA 

constitutes willful, wanton, reckless, conscious, and deliberate indifference and 

disregard of MR. HAND’s constitutional rights, such that Plaintiff is entitled to 

recover punitive damages.

252. As it was necessary for Plaintiff to hire the undersigned attorney to 

represent Plaintiff, Plaintiff is entitled to an award of attorneys’ fees and costs. 

253. WHEREFORE, Plaintiff, the ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. HAND, Personal Representative seeks relief 

as noted below.

COUNT XIV

DELIBERATE INDIFFERENCE & FAILURE TO TREAT UNDER 42 

U.S.C. § 1983 v. JEAN MAX SAINT CHARLES, M.D.

(individual capacity claim)

254. Plaintiff realleges and incorporates by reference all prior paragraphs 

as if set forth fully herein and further states:

255. MR. HAND was a patient in the care of Defendant SAINT CHARLES 

while incarcerated at RMC.

256. At all times relevant to this lawsuit, Defendant SAINT CHARLES was 

acting under the color of statute, ordinance, custom, or usage in his individual 

capacity as a medical doctor at RMC.

/ / /

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257. Plaintiff is entitled to relief against Defendant SAINT CHARLES for 

violation of the Eighth Amendment to the U.S. Constitution.

258. Defendant SAINT CHARLES acted with deliberate indifference 

included, but not limited to the commission and/or omission of the following acts:

a. Failing to conduct adequate discharge planning prior to MR. 

HAND transfer to general population on April 13, 2017, which increased his risk of 

developing serious illness and infection;

b. Failing to timely diagnose MR. HAND;

c. Ignoring and failing to review critical test results indicating a 

serious infection;

d. Failing to address the source of MR. HAND’s infection;

e. Failure to provide MR. HAND timely treatment for infection or 

to transfer him to medical providers or a medical facility that could provide 

treatment;

f. Unconscionable adherence to a medical provider who 

consistently failed to provide needed care to prisoners to save costs and maximize 

profit;

g. Failure to ensure that MR. HAND received follow-up evaluation 

and treatment;

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h. Failure to maintain policies and protocols to make sure that 

prisoners, such as MR. HAND, with serious chronic and acute medical conditions 

are timely treated;

i. Continual and systematic failure to respond to MR. HAND’s 

changing medical condition in a timely manner, over a period of approximately two 

weeks, resulting his death;

259. Defendant SAINT CHARLES knew about MR. HAND’s documented 

medical needs and symptoms, knew that MR. HAND’s basic medical needs were 

not being met and that the treatment offered was totally insufficient in addressing 

his symptoms and serious medical condition. 

260. Defendant SAINT CHARLES totally failed to diagnose MR. HAND 

and allowed him to become septic and sustain and suffer from multi-organ failure 

while being admitted at RMC without any meaningful plan to diagnose, monitor, or 

treat his rapidly deteriorating medical condition.

261. Defendant SAINT CHARLES disregarded MR. HAND’s symptoms, 

vital signs, and lab results and failed to treat him, despite knowing that he required 

adequate medical care. 

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262. Defendant SAINT CHARLES failed to even acknowledge MR. 

HAND’s symptoms, vital signs, or the critical test results that objectively identified 

a serious infection. 

263. Defendant SAINT CHARLES failed to perform any assessment to 

identify the source of MR. HAND’s infection.

264. Defendant SAINT CHARLES was obviously indifferent to MR. 

HAND’s serious medical needs and failed to address or attempt to address his 

symptoms in any meaningful way whatsoever. 

265. Defendant SAINT CHARLES provided such cursory treatment to MR. 

HAND that is essentially amounted to no treatment at all. Further, the treatment, if 

any provided at all, was pursued by easier less effective means.

266. Defendant SAINT CHARLES totally failed to acknowledge or follow 

up on MR. HAND’s serious medical needs in any way.

267. Defendant SAINT CHARLES never reviewed the critical lab results 

that indicated a severe infection, that had he reviewed, would have results in further 

physical evaluation and medical treatment and/or a transfer to a different facility. 

Instead, MR. HAND did not receive necessary or thorough evaluations, ultimately 

leading to his death.

/ / /

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268. Defendant SAINT CHARLES was deliberately, recklessly and 

wantonly indifferent to MR. HAND’s health and grossly negligent in the care (or 

lack thereof) provided to MR. HAND.

269. The acts and omissions of Defendant SAINT CHARLES amount to 

deliberate indifference to MR. HAND’s serious medical needs and were a direct and 

proximate cause of MR. HAND’s death.

270. The acts and omissions of these Defendant SAINT CHARLES 

constitutes willful, wanton, reckless, conscious, and deliberate indifference and 

disregard of MR. HAND’s constitutional rights, such that Plaintiff is entitled to 

recover punitive damages.

271. As it was necessary for Plaintiff to hire the undersigned attorney to 

represent Plaintiff, Plaintiff is entitled to an award of attorneys’ fees and costs. 

272. WHEREFORE, Plaintiff, the ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. HAND, Personal Representative seeks relief 

as noted below.

COUNT XV

DELIBERATE INDIFFERENCE & FAILURE TO TREAT UNDER 42 

U.S.C. § 1983 v. JUAN SANTIAGO, M.D. a.k.a JUAN SANTIAGO RIVERA, 

M.D.

(individual capacity claim)

273. Plaintiff realleges and incorporates by reference all prior paragraphs 

as if set forth fully herein and further states:

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274. MR. HAND was a patient in the care of Defendant SANTIAGO while 

incarcerated at RMC.

275. At all times relevant to this lawsuit, Defendant SANTIAGO was acting 

under the color of statute, ordinance, custom, or usage in his individual capacity as 

a medical doctor at RMC.

276. Plaintiff is entitled to relief against Defendant SANTIAGO for 

violation of the Eighth Amendment to the U.S. Constitution.

277. Defendant SANTIAGO acted with deliberate indifference included, but 

not limited to the commission and/or omission of the following acts:

a. Failing to timely diagnose MR. HAND;

b. Ignoring and failing to review critical test results indicating a 

serious infection;

c. Failing to address the source of MR. HAND’s infection;

d. Failure to provide MR. HAND timely treatment for infection or 

to transfer him to medical providers or a medical facility that could provide 

treatment;

e. Unconscionable adherence to a medical provider who 

consistently failed to provide needed care to prisoners to save costs and maximize 

profit;

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f. Failure to ensure that MR. HAND received follow-up evaluation 

and treatment;

g. Failure to maintain policies and protocols to make sure that 

prisoners, such as MR. HAND, with serious chronic and acute medical conditions 

are timely treated;

h. Continual and systematic failure to respond to MR. HAND’s 

changing medical condition in a timely manner, over a period of approximately two 

weeks, resulting his death;

278. Defendant SANTIAGO knew about MR. HAND’s documented 

medical needs and symptoms, knew that MR. HAND’s basic medical needs were 

not being met and that the treatment offered was totally insufficient in addressing 

his symptoms and serious medical condition. 

279. Defendant SANTIAGO totally failed to diagnose MR. HAND and 

allowed him to become septic and sustain and suffer from multi-organ failure while 

being admitted at RMC without any meaningful plan to diagnose, monitor, or treat 

his rapidly deteriorating medical condition.

280. Defendant SANTIAGO disregarded MR. HAND’s symptoms, vital 

signs, and lab results and failed to treat him, despite knowing that he required 

adequate medical care. 

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281. Defendant SANTIAGO failed to even acknowledge MR. HAND’s 

symptoms, vital signs, or the critical test results that objectively identified a serious 

infection. 

282. Defendant SANTIAGO failed to perform any assessment to identify the 

source of MR. HAND’s infection.

283. Defendant SANTIAGO was obviously indifferent to MR. HAND’s 

serious medical needs and failed to address or attempt to address his symptoms in 

any meaningful way whatsoever. 

284. Defendant SANTIAGO provided such cursory treatment to MR. 

HAND that is essentially amounted to no treatment at all. Further, the treatment, if 

any provided at all, was pursued by easier less effective means.

285. Defendant SANTIAGO totally failed to acknowledge or follow up on 

MR. HAND’s serious medical needs in any way.

286. Defendant SANTIAGO never reviewed the critical lab results that 

indicated a severe infection, that had he reviewed, would have results in further 

physical evaluation and medical treatment and/or a transfer to a different facility. 

Instead, MR. HAND did not receive necessary or thorough evaluations, ultimately 

leading to his death.

/ / /

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287. Defendant SANTIAGO was deliberately, recklessly and wantonly 

indifferent to MR. HAND’s health and grossly negligent in the care (or lack thereof) 

provided to MR. HAND.

288. The acts and omissions of Defendant SANTIAGO amount to deliberate 

indifference to MR. HAND’s serious medical needs and were a direct and proximate 

cause of MR. HAND’s death.

289. The acts and omissions of these Defendant SANTIAGO constitutes 

willful, wanton, reckless, conscious, and deliberate indifference and disregard of 

MR. HAND’s constitutional rights, such that Plaintiff is entitled to recover punitive 

damages.

290. As it was necessary for Plaintiff to hire the undersigned attorney to 

represent Plaintiff, Plaintiff is entitled to an award of attorneys’ fees and costs. 

291. WHEREFORE, Plaintiff, the ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. HAND, Personal Representative seeks relief 

as noted below.

COUNT XVI

DELIBERATE INDIFFERENCE & FAILURE TO TREAT UNDER 42 

U.S.C. § 1983 v. PETER FABIAN EDEMEKONG, M.D.

(individual capacity claim)

292. Plaintiff realleges and incorporates by reference all prior paragraphs 

as if set forth fully herein and further states:

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293. MR. HAND was a patient in the care of Defendant EDEMEKONG 

while incarcerated at RMC.

294. At all times relevant to this lawsuit, Defendant EDEMEKONG was 

acting under the color of statute, ordinance, custom, or usage in his individual 

capacity as a medical doctor at RMC.

295. Plaintiff is entitled to relief against Defendant EDEMEKONG for 

violation of the Eighth Amendment to the U.S. Constitution.

296. Defendant EDEMEKONG acted with deliberate indifference included, 

but not limited to the commission and/or omission of the following acts:

a. Failing to timely diagnose MR. HAND;

b. Ignoring and failing to review critical test results indicating a 

serious infection;

c. Failing to address the source of MR. HAND’s infection;

d. Failure to provide MR. HAND timely treatment for infection or 

to transfer him to medical providers or a medical facility that could provide 

treatment;

e. Unconscionable adherence to a medical provider who 

consistently failed to provide needed care to prisoners to save costs and maximize 

profit;

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73

f. Failure to ensure that MR. HAND received follow-up evaluation 

and treatment;

g. Failure to maintain policies and protocols to make sure that 

prisoners, such as MR. HAND, with serious chronic and acute medical conditions 

are timely treated;

h. Continual and systematic failure to respond to MR. HAND’s 

changing medical condition in a timely manner, over a period of approximately two 

weeks, resulting his death;

297. Defendant EDEMEKONG knew about MR. HAND’s documented 

medical needs and symptoms, knew that MR. HAND’s basic medical needs were 

not being met and that the treatment offered was totally insufficient in addressing 

his symptoms and serious medical condition. 

298. Defendant EDEMEKONG totally failed to diagnose MR. HAND and 

allowed him to become septic and sustain and suffer from multi-organ failure while 

being admitted at RMC without any meaningful plan to diagnose, monitor, or treat 

his rapidly deteriorating medical condition.

299. Defendant EDEMEKONG disregarded MR. HAND’s symptoms, vital 

signs, and lab results and failed to treat him, despite knowing that he required 

adequate medical care. 

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300. Defendant EDEMEKONG failed to even acknowledge MR. HAND’s 

symptoms, vital signs, or the critical test results that objectively identified a serious 

infection. 

301. Defendant EDEMEKONG failed to perform any assessment to identify 

the source of MR. HAND’s infection.

302. Defendant EDEMEKONG was obviously indifferent to MR. HAND’s 

serious medical needs and failed to address or attempt to address his symptoms in 

any meaningful way whatsoever. 

303. Defendant EDEMEKONG provided such cursory treatment to MR. 

HAND that is essentially amounted to no treatment at all. Further, the treatment, if 

any provided at all, was pursued by easier less effective means.

304. Defendant EDEMEKONG totally failed to acknowledge or follow up 

on MR. HAND’s serious medical needs in any way.

305. Defendant EDEMEKONG never reviewed the critical lab results that 

indicated a severe infection, that had he reviewed, would have results in further 

physical evaluation and medical treatment and/or a transfer to a different facility. 

Instead, MR. HAND did not receive necessary or thorough evaluations, ultimately 

leading to his death.

/ / /

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306. Defendant EDEMEKONG was deliberately, recklessly and wantonly 

indifferent to MR. HAND’s health and grossly negligent in the care (or lack thereof) 

provided to MR. HAND.

307. The acts and omissions of Defendant EDEMEKONG amount to 

deliberate indifference to MR. HAND’s serious medical needs and were a direct and 

proximate cause of MR. HAND’s death.

308. The acts and omissions of these Defendant EDEMEKONG constitutes 

willful, wanton, reckless, conscious, and deliberate indifference and disregard of 

MR. HAND’s constitutional rights, such that Plaintiff is entitled to recover punitive 

damages.

309. As it was necessary for Plaintiff to hire the undersigned attorney to 

represent Plaintiff, Plaintiff is entitled to an award of attorneys’ fees and costs. 

310. WHEREFORE, Plaintiff, the ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. HAND, Personal Representative seeks relief 

as noted below.

COUNT XVII

DELIBERATE INDIFFERENCE & FAILURE TO TREAT UNDER 42 

U.S.C. § 1983 v. DRIANNA NISHELL LAW, ARNP 

(individual capacity claim)

311. Plaintiff realleges and incorporates by reference all prior paragraphs 

as if set forth fully herein and further states:

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312. MR. HAND was a patient in the care of Defendant LAW while 

incarcerated at RMC.

313. At all times relevant to this lawsuit, Defendant LAW was acting under 

the color of statute, ordinance, custom, or usage in his individual capacity as a 

medical doctor at RMC.

314. Plaintiff is entitled to relief against Defendant LAW for violation of the 

Eighth Amendment to the U.S. Constitution.

315. Defendant LAW acted with deliberate indifference included, but not 

limited to the commission and/or omission of the following acts:

a. Failing to timely diagnose MR. HAND;

b. Ignoring and failing to review critical test results indicating a 

serious infection;

c. Failing to address the source of MR. HAND’s infection;

d. Failure to provide MR. HAND timely treatment for infection or 

to transfer him to medical providers or a medical facility that could provide 

treatment;

e. Unconscionable adherence to a medical provider who 

consistently failed to provide needed care to prisoners to save costs and maximize 

profit;

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f. Failure to ensure that MR. HAND received follow-up evaluation 

and treatment;

g. Failure to maintain policies and protocols to make sure that 

prisoners, such as MR. HAND, with serious chronic and acute medical conditions 

are timely treated;

h. Continual and systematic failure to respond to MR. HAND’s 

changing medical condition in a timely manner, over a period of approximately two 

weeks, resulting his death;

316. Defendant LAW knew about MR. HAND’s documented medical needs 

and symptoms, knew that MR. HAND’s basic medical needs were not being met and

that the treatment offered was totally insufficient in addressing his symptoms and 

serious medical condition. 

317. Defendant LAW totally failed to diagnose MR. HAND and allowed 

him to become septic and sustain and suffer from multi-organ failure while being 

treated at RMC without any meaningful plan to diagnose, monitor, or treat his 

rapidly deteriorating medical condition.

318. Defendant LAW disregarded MR. HAND’s symptoms, vital signs, and 

lab results and failed to treat him, despite knowing that he required adequate medical 

care. 

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319. Defendant LAW failed to even acknowledge MR. HAND’s symptoms, 

vital signs, or the critical test results that objectively identified a serious infection. 

320. Defendant LAW failed to perform any assessment to identify the source 

of MR. HAND’s infection.

321. Defendant LAW was obviously indifferent to MR. HAND’s serious 

medical needs and failed to address or attempt to address his symptoms in any 

meaningful way whatsoever. 

322. Defendant LAW provided such cursory treatment to MR. HAND that 

is essentially amounted to no treatment at all. Further, the treatment, if any provided 

at all, was pursued by easier less effective means.

323. Defendant LAW totally failed to acknowledge or follow up on MR. 

HAND’s serious medical needs in any way.

324. Defendant LAW never reviewed the critical lab results that indicated a 

severe infection, that had he reviewed, would have results in further physical 

evaluation and medical treatment and/or a transfer to a different facility. Instead, 

MR. HAND did not receive necessary or thorough evaluations, ultimately leading 

to his death.

/ / /

/ / /

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325. Defendant LAW was deliberately, recklessly and wantonly indifferent 

to MR. HAND’s health and grossly negligent in the care (or lack thereof) provided 

to MR. HAND.

326. The acts and omissions of Defendant LAW amount to deliberate 

indifference to MR. HAND’s serious medical needs and were a direct and proximate 

cause of MR. HAND’s death.

327. The acts and omissions of these Defendant LAW constitutes willful, 

wanton, reckless, conscious, and deliberate indifference and disregard of MR. 

HAND’s constitutional rights, such that Plaintiff is entitled to recover punitive 

damages.

328. As it was necessary for Plaintiff to hire the undersigned attorney to 

represent Plaintiff, Plaintiff is entitled to an award of attorneys’ fees and costs. 

329. WHEREFORE, Plaintiff, the ESTATE OF GLENN MITCHELL 

HAND, by and through PHYLLIS A. HAND, Personal Representative seeks relief 

as noted below.

DAMAGES AND PRAYER FOR RELIEF

WHEREFORE, the Plaintiff, the ESTATE OF GLENN MITCHELL HAND, 

by and through PHYLLIS A. HAND, Personal Representative, prays for relief and 

demands judgment against Defendant FLORIDA DEPARTMENT OF 

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CORRECTIONS; Defendant CENTURION OF FLORIDA; Defendant MHM 

HEALTH PROFESSIONALS; Defendant DAVID E. RODRIGUEZ-RIVERA, 

M.D., a.k.a. DAVID RODRIGUEZ, M.D.; Defendant JEAN MAX SAINT 

CHARLES, M.D.; Defendant JUAN SANTIAGO RIVERA, M.D.; Defendant 

PETER FABIAN EDEMEKONG, M.D.; Defendant DRIANNA NISHELL LAW, 

ARNP for damages in excess of Seventy Five Thousand Dollars ($75,000.00) as 

follows:

A. Wrongful death damages including: (1) survivor PHYLLIS A. HAND, 

MR. HAND’s surviving wife - loss of her husband’s support and services, the loss 

of his companionship and protection, and mental pain and suffering as a result of the 

injury and subsequent death of her husband; (2) Estate of GLENN MITCHELL 

HAND – loss of net accumulations, medical, nursing, and funeral expenses; and (3) 

all other damages allowed by law.

B. Attorney’s fees and costs as permitted by law;

C. Punitive damages as permitted by law;

D. Pre-judgment and post-judgment interest as permitted by law;

E. A jury trial on all Counts; and

F. Any such further and additional relief as this Court deems proper.

/ / /

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TRIAL BY JURY IS AND HAS BEEN DEMANDED.

Dated this 28th day of July 2020.

/s/ Adam Anderson

Adam C. Anderson, Esq.

Florida Bar No. 125640

ADAM ANDERSON LAW FIRM

5 Miracle Strip Loop, Suite 7

Panama City Beach, FL 32407

Phone: (850) 588-3288

Fax: (850) 588-3287

Email: adam@winwithadam.com

Attorney for Plaintiff 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 28, 2020, I electronically filed the 

foregoing with the Clerk of the Court by using the CM/ECF system which will send 

a notice of electronic filing to the following: Francis H. Sheppard at 

fsheppard@rumberger.com and Kayla E. Platt Rady at krady@rumberger.com

(counsel for Defendants Centurion of Florida; MHM Health Professionals, Inc.; 

David E. Rodriguez-Rivera, M.D., a/k/a David Rodriguez, M.D.; Jean Max Saint 

Charles, M.D.; Juan Santiago, M.D. a/k/a Juan Santiago Rivera, M.D.; Peter Fabian 

Edemekong, M.D.; Drianna Nishell Law, ARNP), Thomas R. Thompson at 

tom@tcslawfirm.net and Mallory R. Bennett at mallory@tcslawfirm.net (counsel 

for Defendant Florida Department of Corrections).

DATED this 28th day of July 2020.

/s/ Adam Anderson

Adam C. Anderson, Esq.

Florida Bar No. 125640

ADAM ANDERSON LAW FIRM

5 Miracle Strip Loop, Ste. 7

Panama City Beach, Florida 32407

Phone: (850) 588-3288

Fax: (850) 588-3287

Email: adam@winwithadam.com

Attorney for Plaintiff

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