THE WOMEN OF TUTWILER - THEIR LAWSUIT

THE WOMEN OF TUTWILER - THEIR LAWSUIT

Plaintiff A is currently incarcerated at Tutwiler Prison. She is 51 years old, and has been a prisoner in the Alabama Department of Corrections since 1998. Plaintiff A is approximately five feet tall and weighs around 80 pounds. She has lost approximately 20 pounds since entering prison because she has no teeth and cannot eat enough food to obtain adequate nutrition.

Plaintiff A has been waiting for provided dentures at Tutwiler for three years. She has inquired about her dentures almost every month for the past year, and the only response she has received is that they are in the mail. She has filed numerous complaints about her need for teeth because of the impact on her health of not being able to chew and digest food properly.

After not receiving an adequate response to her complaints, Plaintiff A filed a grievance on December 3, 2002. She has not received any response to this grievance. At 80 pounds, she is severely underweight, lighter than 98% of American women her height.

Plaintiff A also suffers from severe headaches and seizures induced by a brain tumor. She requested treatment for this condition on repeated occasions, but was not referred to the doctor by nurses at sick call screening. It took her having a seizure while the doctor was on duty for
her condition to be brought to the doctor's attention. At the time the doctor saw Plaintiff A, he ordered that an MRI be done to assess her condition. No MRI has been done.

Plaintiff B is currently incarcerated at Tutwiler Prison. She is 50 years old and has been a prisoner in the Alabama Department of Corrections since 2000. Plaintiff B has three ruptured discs in her back, a torn rotator cuff, and serious problems with her knees, for which she had multiple surgeries before coming to prison. Because of these physical problems, Plaintiff B suffers chronic pain and swelling and has difficulty walking. She has filed numerous complaints about inadequate pain control and not being given a pink slip? that excuses her from physical work due to her medical problems. She has also filed several grievances about these
issues, most recently on September 15, September 20, and October 22, 2002. She is not satisfied with the resolution of these grievances. Her pain is debilitating.

Plaintiff C is currently incarcerated at Tutwiler Prison. She is 37 years old and has been a prisoner in the Alabama Department of Corrections since approximately 1998. For two years, Plaintiff C has suffered with serious, extremely painful hemorrhoids. Despite repeated requests
for treatment, the hemorrhoids were allowed to worsen for two years, causing Plaintiff C prolonged, severe pain, and making it impossible for her to sit for any period of time, or to have a bowel movement without a large dose of laxatives. She was finally taken to a specialist the
first week of October 2002. The specialist informed her that the hemorrhoids had become so severe over the 2 year delay that it would require multiple surgeries to remove them. Plaintiff C underwent the first stage of the surgery during the first week of November. She has yet to be
sent for her post-operative evaluation and second stage of the surgery. About a week after she returned from surgery, Plaintiff C got an infection. She still experiences bleeding from her rectum. She continues to be in excruciating pain and has great difficulty with bowel movements.
After an officer recently called the medical unit for help because Plaintiff C was in so much pain, a nurse accused Plaintiff C of not coming to pill call. This is not true. Plaintiff C has not missed a single pill call. In November 2002, Plaintiff C filed a grievance about not being taken
to a specialist for post-surgical follow-up, as the specialist had recommended. She has filed complaints and grievances about not being given laxatives or pain medication since her surgery, as prescribed by a physician. She has also exhausted the grievance procedure about the excessive amount of time it took for her to receive surgery for such a painful and debilitating medical problem that the Department had known about for years. Her medical situation remains unresolved.

Plaintiff D is currently incarcerated at Tutwiler Prison. She is 39 years old and has been a prisoner in the Alabama Department of Corrections since May 2002. She suffers from numerous medical and mental health problems including diabetes, hypertension, and bipolar disorder. In June 2002, Plaintiff D's uterus prolapsed into her vagina, and she began
passing large amounts of blood and experiencing severe cramping. She requested help for the bleeding beginning in June. In response, she was seen at midnight sick call by nurses, but the nurses did not refer her to a physician for evaluation and treatment. In late July 2002, Plaintiff D
filed a complaint about not getting treatment for her bleeding. After not getting a response to her complaint, she filed a grievance in August, and received no response to this either. She bled every day from August to September and consequently became anemic. In October, Plaintiff D was given a pelvic ultrasound at which time she was told she had cysts on her
ovaries, an enlarged uterus, and a bladder problem. She has boils on her thighs and in her genital area that burst and leak malodorous pus and blood. In late November, Plaintiff D was finally seen by a gynecologist at Tutwiler who told her that she had fibroid tumors on her uterus. He recommended surgery but explained that he will need to get approval from NaphCare. She has not yet heard whether her surgery has been approved.

Plaintiff E is currently incarcerated at Tutwiler Prison. She is 48 years old and has been a prisoner in the Alabama Department of Corrections since May 2001. She has a history of ovarian cancer and breast cancer. In November 2000, prior to coming to prison, Plaintiff E had surgery for breast cancer, and was scheduled to undergo chemotherapy, but did not receive chemotherapy because she was arrested and placed in jail. Her sentencing judge assured her she would receive chemotherapy treatment at Tutwiler, but she still has not received chemotherapy at Tutwiler during the past 18 months that she has been in prison. Plaintiff E has
had three mammograms since coming to prison. The mammogram in September 2001 showed there was an abnormality that needed immediate attention. Rather than order a biopsy, NaphCare chose to wait six months to perform another mammogram. In April 2002, after another mammogram, a specialist requested NaphCare's approval to obtain a sonogram and biopsy of Plaintiff E's breast because the mammogram showed changes suggestive of cancer. These were of special concern because of her personal history and family history of cancer. This request was denied by NaphCare in favor of obtaining a second opinion by
another physician chosen by NaphCare, who said that the abnormality might be scar tissue. She has still not had a biopsy. Plaintiff E experiences frequent pain and discharge from her breast. Beginning in October 2001, Plaintiff E has filed at least five complaints about the medical staff's failure to provide proper diagnosis and follow-up of the abnormality in her breast â€" in particular, their refusal to biopsy her breast. When she asked in October 2001 if she could file a grievance, she was informed that there were no grievance forms and no longer a grievance procedure. This is consistent with the Access to Health Care Services? form that she was provided during intake in May 2001, which does not make mention of any
complaint or grievance procedure. During her cancer surgery two years ago, all of the lymph nodes were removed from under Plaintiff E's left arm. In August 2001, the health care staff at Tutwiler ordered a pressure cuff to keep the fluid from collecting in her arm causing severe swelling and pain. The cuff has still not arrived. Plaintiff E has submitted several complaint forms about this, and the response of the medical staff, beginning in January 2002, is that NaphCare is trying to get the proper cuff and will call her into the health care unit as soon as they get it. Since grievance forms have become more available (in September 2002), Plaintiff E has filed and exhausted two grievances. Most recently, she filed a complaint on October 31 and a grievance on about November 16, 2002 concerning the failure to biopsy her breast, the soreness and itching in her breast, and the failure to provide her with the pressure cuff that was ordered 16 months ago.

Plaintiff F is currently incarcerated at Tutwiler Prison. She is 48 years old and has been a prisoner in the Alabama Department of Corrections since March 2001. Plaintiff F is on dialysis because she suffers from end-stage renal disease (kidney failure). During the first year of her
incarceration, Plaintiff F was taken off-site for dialysis. Beginning May 3, 2002, defendants stopped taking Plaintiff F off-site for dialysis and instead required her to perform dialysis in the dental room at Tutwiler. In August 2002, Plaintiff F's left arm became severely infected, swollen, painful, and she developed a hematoma where the needles were inserted into her arm to do dialysis. On August 3, the painful, infected wound burst open while she was in the shower and she was taken to a hospital where she required numerous stitches on her arm and a catheter was placed in her chest so that dialysis could be performed through her chest. She can no longer use her left arm for dialysis.

On October 7, Plaintiff F filed a grievance about the fact that she could not get treatment for her severely infected arm until the infection burst open. In her October 7th grievance, she also complained that she has trouble getting back to health care for dialysis and does not get a
proper renal diet. She is not satisfied with the resolution of her grievance.

Plaintiff G is currently incarcerated at Tutwiler Prison. She is 44 years old and has been a prisoner in the Alabama Department of Corrections since 1995. Plaintiff G was diagnosed with tumors in her uterus in approximately August 2002. Prior to her diagnosis, Plaintiff G had bled
heavily over a period of two years, often for many days at a time. A doctor at Tutwiler told her several months ago that she needs a hysterectomy, and placed her on the surgical list. As far as she knows, she has not been approved to receive surgery.

In November 2002, Plaintiff G filed a complaint about her excessive bleeding and about not having heard anything about whether she was going to have a hysterectomy. She also complained about having signed up three times for sick call and not being seen by a doctor. Later in the month, after receiving a response to her complaint, she filed two grievances, the first of which was about not being seen by a doctor despite several requests. In her second grievance, she complained about not seeing a doctor, and stated that she had been bleeding non-stop for two months and was experiencing dizziness.

Plaintiff H is currently incarcerated at Tutwiler Prison. She is 52 years old and has been a prisoner in the Alabama Department of Corrections since July 2002.

Plaintiff H has emphysema, heart problems, chronic obstructive pulmonary disease, and throat cancer in remission. Because of her respiratory condition, Plaintiff H requires oxygen supplements 24 hours per day. She lives in one of the two hospital beds in the health care unit
at Tutwiler. Plaintiff H is required to use an oxygen machine she brought from home, but it needs to be serviced regularly. She also requires 6-8 aerosol breathing treatments every day, but at Tutwiler she receives only two. In October 2002, Plaintiff H filed a complaint about not receiving enough breathing treatments and not having her oxygen machine serviced, despite the fact that it is falling apart. The medical staff responded to her complaint by asking her whether her family could take her machine to be serviced. Plaintiff H filed a grievance the second week of October about her machine not being serviced. In response, the medical staff asked whether she had Medicare coverage and told her that they were waiting to hear back from the company that had previously serviced the machine. Because of scarring from her throat surgery, Plaintiff H also needs to have her throat dilated every three months to keep her airway open. She has requested this procedure, but has not had it done during the five months she has been in prison.

Plaintiff I is currently incarcerated at Tutwiler Prison. She is 45 years old and has been a prisoner in the Alabama Department of Corrections since 1997. Plaintiff I has multiple cysts in her left breast, has an undiagnosed condition that causes her abdomen to swell, and problems with her colon. She has a family history of cancer, and fears that her abdominal condition and the multiple cysts in her breast have not been properly diagnosed or treated. Plaintiff I has filed numerous medical requests and medical complaints because on several occasions she did not receive the diagnostic tests or surgical procedures that physicians have ordered for her.

Plaintiff I has also complained about being charged the medical co-pay every time she goes back to the health care unit, even though she is requesting help with a chronic problem that is not responding to treatment. On August 30, 2002, she filed a complaint about not receiving a
sonogram that had been ordered for her by the prison's physician. During the week of her visit with the physician, she had returned to the health care unit four times suffering with pain, fever, and swelling in her pelvis and abdomen. After not receiving a response to this complaint,
she filed grievances on September 5 and September 8. In the September 8th grievance, she complained about not having the sonogram and about the many other tests and procedures that had been ordered for her but had not been approved or performed. She had previously filed requests and complaints about all of these issues without adequate resolution. For example, she asked why the hysterectomy that doctors had told her she needed (in July 2001) had not been approved. She also asked why she could not get a biopsy to help diagnose the numerous masses in her breasts. The response to her grievance stated that approval for the hysterectomy was a time-consuming process when it was not an emergency situation. Plaintiff I is not satisfied with this response and is afraid that NaphCare and the Department of Corrections are waiting until it is too late to do anything for her.

Plaintiff J has been at Tutwiler Prison since December 4, 2002, when she was transferred from the Birmingham Work Release Center. She is 40 years old and has been a prisoner in the Alabama Department of Corrections since February 2002. Plaintiff J suffers from major depression. In June 2002, she was coded seriously mentally ill? by the Department of Corrections. Prior to her incarceration in the Department of Corrections, Plaintiff J took medication to treat her psychiatric condition. However, once she was transferred to Birmingham in March 2002, she was forced to wait three months without any medication. During this time, Plaintiff J requested to see the nurse at Birmingham four times to ask about her psychiatric medication, and was finally taken to a psychiatrist at Donaldson Correctional Facility in June. The psychiatrist at Donaldson prescribed anti- depressants for Plaintiff J. However, as with many other prisoners at Birmingham, Plaintiff J had to wait several weeks between refills of her prescription medication. The disruptions in her medication caused Plaintiff Ks mental health to deteriorate. While at Birmingham, Plaintiff J asked the warden if she could go to the mental health center for counseling. The warden referred the issue to an assistant, and Plaintiff J was never permitted to go to the mental health center or have any other kind of mental health counseling. Plaintiff J asked for complaint forms and grievance forms while at Birmingham Work Release and was informed by several different staff members that there is no grievance procedure available at that facility. Prior to coming to Tutwiler on December 4, Plaintiff Js medication had lapsed for almost six weeks, and no medication was transferred with her to Tutwiler. Since her arrival at Tutwiler on December 4, Plaintiff J has received no medication.

Plaintiff K is currently incarcerated at Edwina Mitchell Center. She is 43 years old and has been a prisoner in the Alabama Department of Corrections since July 2001. Plaintiff K has chronic high blood pressure and a congenital defect in a blood vessel near her heart. Just before Thanksgiving of this year, Plaintiff K ran out of Atenolol, one of her heart medications, and did not receive it for two weeks because neither security staff nor medical staff did what was necessary to ensure that she received her refill on time. This lapse in her medication occurred despite the fact that one and a half weeks before she ran out of medication, Plaintiff K
had filled out a medical request indicating that she needed a refill. She has also been waiting since July 2001 for an appointment with a dentist. On December 2, 2002, Plaintiff K attempted to file a medical complaint about severe pain in her left side and about her left knee causing her so much pain she could not sleep. She had been seen by medical staff on November 22, but had heard nothing from them. She requested a complaint form from the EMC shift office and was told by the officer there that none was available. The officer advised her to use a health services request form and write complaint form? at the top. Plaintiff K submitted a complaint according to the officers instructions on December 2. She did not receive a response to her complaint. On December 9, she requested a grievance form, and was told none was available, so she used a health services request form and wrote grievance? at the top, and submitted a grievance. She received a response to her grievance on December 11th that said wrong form? No complaint on file? and advised her to get new forms from Capt. Davenport.? Neither Plaintiff K nor any of the other prisoners at EMC can obtain forms from Captain Davenport, as he works at Tutwiler, not EMC.

Plaintiff L is currently incarcerated at Tutwiler Prison. She is 32 years old and has been a prisoner in the Alabama Department of Corrections since September 2002. Plaintiff L has rheumatoid arthritis and was diagnosed with a blood clotting disease called Immune Thrombocytopenia Purpura on April 22, 2002, prior to her incarceration. At the time of her
diagnosis, she was very weak, was bleeding from her nose, and had blood clots and ulcers in her mouth. Her platelet count was so low that she had to have a blood transfusion and bone marrow transplant. Since she arrived at prison in September, Plaintiff L has experienced swelling and pain around her knees and legs. She has had bleeding and ulcers in her mouth and bleeding from her nose; bruising on her legs; and severe headache. She has not been approved to see a specialist for her condition, despite the fact that the prison's physician does not have any expertise in treating her disease. Plaintiff L filed a complaint on October 16 about the problems she was having with swelling in her knees and legs, which made it difficult for her to walk. She stated that she had been to health care three times and had only been given Tylenol. She also complained that the doctor had ordered x-rays, but they had not been done. Plaintiff L was transferred from Tutwiler to EMC in late October 2002 with a two-week supply of her medications. The medications ran out on November 5 and she then went without them for over seven days. This caused her severe anxiety. She wrote a grievance on November 8th explaining that she needed her medication, was feeling sick, very weak, and had small hemorrhages in her skin because her platelet count was dropping. She explained that she had blood clots on her legs and in her mouth. Plaintiff L did not receive a response until six days later. The response stated that her medications (which had run out on November 5) were sent to EMC on November 13, when they arrived from the pharmacy. She filed another complaint on November 24, but as of December 12th had not received a response. Plaintiff L has requested a grievance form so that she can file a grievance about the November 24th complaint, but has been told that no grievance forms are available.

Plaintiff M is currently incarcerated at Tutwiler Prison. She is 55 years old and has been a prisoner in the Alabama Department of Corrections since January 1998. Plaintiff N has chronic hepatitis C, hypertension, ulcers, and mental illness. She has been informed by the prison's doctor that she will never receive drug therapy for hepatitis C in prison because it is too expensive. She received tests of her liver function in October, after she spit vomited blood for two days and became dehydrated. Although she has requested her lab results repeatedly from health care staff, these requests have been denied. Her platelet count drops very low, which Plaintiff M has been told indicates severe liver damage. She has also been told that she has cirrhosis of the liver. Plaintiff M experiences depression, anxiety, and insomnia related to her hepatitis C. In June 2002, she began to request mental health treatment for these symptoms, and filed a complaint on September 11 2002, after not receiving the treatment she had requested. The response to her complaint, on September 12, was a list of dates when she was supposedly seen by mental health staff. Plaintiff M recalls that those were dates when mental health staff walked down the aisle of the mental health dorm and asked everyone how they were doing. She was also told she would be notified when she had an appointment to see the psychiatrist. On October 24, when she had still not seen anyone for her mental health problems, she filed a grievance. In November, after the grievance was filed, she finally saw a psychiatrist who put her on Elavil, an antidepressant medication to be used with caution in patients with liver disease. Although she is relieved to have finally seen a psychiatrist, the Elavil she was prescribed is causing serious side effects, such as fatigue, that make it difficult for her to take the medication.

Plaintiff N is currently incarcerated at Edwina Mitchell Center. She is 52 years old and has been a prisoner in the Alabama Department of Corrections since 1996. She has been at EMC since April 30, 2002. Plaintiff O has chronic diarrhea and had an intestinal bypass many years
ago. She also has hypoglycemia, hypertension, and several food allergies. Plaintiff N suffers from mental illness and arthritis. Plaintiff N often waits several weeks to have her medications refilled after they run out, despite putting in for a refill two or three weeks before her medication lapses. In early November, she notified health care by a written request that she needed refills of Elavil, her mental health medication, and Naprosen, a medication for arthritis pain. Despite her request, she ran out of her medication on about December 2, and as of December 12, had still not received them. She submitted a complaint on the day she ran out of medication, and on December 11, submitted a grievance. The same problem has occurred at least four times since she has been at EMC, and each time she has filed a complaint and grievance during the lapse in medication. The officers at EMC refuse to provide complaint forms or grievance forms upon request, so Plaintiff N makes her own.

Plaintiff O is currently incarcerated at Birmingham Work Release Center. She is 41 years old and has been a prisoner in the Alabama Department of Corrections since April 2002. Plaintiff O has been diagnosed with major affective disorder (major depression or bipolar disorder) and has been coded by defendants as seriously mentally ill? during this incarceration. Plaintiff O was seen by a doctor one week after she arrived at Tutwiler in April 2002 and placed on a very low dose of Prozac. Two weeks later, she was transferred to Birmingham Work Release with a 7-day supply of medication. When this ran out, she waited two weeks to receive her refill. Once at Birmingham, she had one to two week lapses nearly every time her prescription ran out. Because she was sporadically on and off of her psychiatric medication, the medication was not effective and gave her intolerable side effects. She was taken to Donaldson Correctional Facility in October to see a psychiatrist, but the transport officer took her medical records instead of her mental health record, so the psychiatrist would not provide treatment. Plaintiff O has chosen to stop taking her medication because defendants will not provide it to her consistently. She is trying to keep her work release job, and cannot afford to risk the side effects of receiving her medication improperly, despite the fact that she needs mental health treatment. Plaintiff O has not been provided any mental health counseling during her eight months in prison. Plaintiff O is one of 102 prisoners who received a behavior citation on October 4, 2002, the same day that a paralegal working with undersigned counsel was at the facility interviewing prisoners. She was awakened by Warden Carter and an officer who handed her a citation for having a radio on her bed. She had never before seen Ms. Carter at the prison, and was shocked to find her standing in front of her shaking with anger over something that was such a minor infraction (if an infraction at all). Warden Carter's unpredictable anger and erratic behavior exacerbate the symptoms of prisoners with anxiety and major depression, and cause unnecessary stress on prisoners who are trying to maintain a clean record.

Plaintiff P is currently incarcerated at Birmingham Work Release Center. She is 48 years old and has been a prisoner in the Alabama Department of Corrections since October 2001. Plaintiff P has Type II, non-insulin dependent diabetes. She was transferred from EMC to Birmingham on October 10, 2002. At EMC and Tutwiler, she was taking Diabeta and Glucotrol for her diabetes and Zantac for her stomach. After she arrived at Birmingham on October 10, 2002, it took 10 days to receive her medication. She went to pill call repeatedly and was told by the officers distributing medication that there was nothing for her. She finally saw the nurse who found the medication in her medical jacket that had been sent over from Tutwiler. Plaintiff P also has asthma. During the first week of December, she asked the nurse at Birmingham about treatment for her asthma and the nurse said there was nothing in her medical jacket
about asthma. She is not receiving any treatment or evaluation for her asthma at Birmingham.

Plaintiff Q is currently incarcerated at Birmingham Work Release Center. She is 39 years old and has been a prisoner in the Alabama Department of Corrections since 1997. Plaintiff Q has Type I, insulin-dependent diabetes. She self-administers insulin twice a day. The officers at Birmingham interfere with her ability to take her insulin as prescribed for her condition. For example, in October 2002, a sergeant called prisoners to get on the van to leave for work earlier than usual, and the prisoners had not yet been called for pill call. The sergeant would not allow Plaintiff Q to take her insulin before the van left. Birmingham Work Release frequently runs out of insulin syringes, and has even run out of Plaintiff Q's insulin, forcing her to use a different type of insulin from what she is prescribed. Other prisoners are allowed to use her insulin, so she runs out of insulin before the prescription runs out. The Center usually waits until she runs out of insulin to order more, which is a very risky practice. There is no diabetic diet available to prisoners at Birmingham, and it is very difficult for diabetics to eat properly for their medical condition. While at Tutwiler, Plaintiff Q had eyeglasses ordered because her diabetes had caused her vision to blur. She has been waiting for a year to receive these glasses, and at this point may need surgery. While at Birmingham in February 2002, Plaintiff Q became sick at work and was sent back to Birmingham Work Release, where she was put in the lock-up cell without her insulin for 2-3 days before being sent back to Tutwiler. Plaintiff Q was one of 102 prisoners who received a behavior citation on October 4, 2002, the same day that a paralegal working with undersigned counsel was at the facility interviewing prisoners. She was given a citation for having a cup of water on her bed. Plaintiff Q has to keep a cup of water on her bed because her diabetes is not in control. Consequently she is very thirsty. The constantly changing rules and erratic behavior of Warden Carter are extremely stressful for her.

Plaintiff R is currently incarcerated at Tutwiler Prison. She is 39 years old and has been a prisoner in the Alabama Department of Corrections since 1992. Plaintiff R has periodontal disease that has caused her severe pain since 1998. She began filing complaints about not being treated for her periodontal disease in 2000. Plaintiff R is housed in segregation for 6
months out of every year. While housed in segregation most recently she was scheduled to see the dentist on several occasions, but security staff would not escort her to her appointments. While in segregation Plaintiff S filed a grievance stating, I am in continual pain and have abscesses due to my periodontal disease. I am not being seen by the dentist and I need to have my teeth pulled.? When she did not receive a timely response to this grievance, Plaintiff S asked security officers to escort her to healthcare due to her extreme pain. When the officers refused to take her, she was driven to pulling out one of her own teeth to relieve the pain. Two or three months after Plaintiff R pulled out her own tooth, the dentist extracted her eight abscessed top teeth. Plaintiff R's gums are raw and sore because she still has not received her dentures, although impressions were made in September of 2002.

Plaintiff S is currently incarcerated at Tutwiler Prison. She is 40 years old and has been a prisoner in the Alabama Department of Corrections since February 1999. Plaintiff S has hepatitis C, cirrhosis of the liver, and several hernias in her pelvic area. In April 2001, she began feeling sick, had difficulty with her bowels, and swelling of her abdomen, feet, and legs.
Medical staff told her it was from her sweat, standing on concrete, and eating too much salt. In July 2001, she developed a growth on her pelvic bone that continued to get larger. In January 2002, she saw the doctor at Tutwiler and told him that she was still swelling and not feeling
well. By the time she saw the doctor in January, she had several growths on her pelvis. The doctor diagnosed the growths as hernias and sent her out for a cat scan on January 14. She filed a complaint about the lack of treatment for her hernia and the swelling in her legs and abdomen. The prison doctor informed her on January 18 that she had cirrhosis of the liver and that her small intestine was not functioning. He finally gave her something to help reduce the swelling. He also informed her that she would not get surgery for her hernias. In about August 2002, Plaintiff S filed a complaint stating that if they had treated her hepatitis and hernias
earlier maybe they could have done something to help her. She also asked if she could see an outside doctor to get a second opinion about whether she needed surgery to remove the hernias. The director of nursing responded to her complaint by explaining that because of her condition, she could not have surgery or she would bleed to death. The director of nursing also told her that she did not need to see a liver specialist about her hepatitis and cirrhosis because Dr. Henderson, NaphCare's medical director, tells the prison doctor how to treat patients for hepatitis. Plaintiff S filed a grievance and is not satisfied with her treatment. Despite the fact that she has chronic hepatitis which causes her to feel ill and fatigued, Plaintiff S is forced to sleep next to the large toilet and shower facility in Dorm 9, where it is very loud and there is constant moisture from prisoners taking showers beginning at 1:00 a.m. The large industrial
fans that blow into the toilet facility stand next to her bed. Due to the constant noise, she cannot get enough sleep and has felt sick and congested for the past three months.

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