Case 3:13-cv AC Document 16 Filed 03/14/14 Page 1 of 11

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1 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 1 of 11 James M. Daigle, P.C., OSB # Robert B. Coleman, OSB # STEWART SOKOL & GRAY, LLC 2300 SW First Avenue, Suite 200 Portland, OR Phone: Facsimile: (503) Of Attorneys for Defendants Corizon Health, Inc., Prison Health Services Correction Healthcare, Inc., Washington County, Dr. Joseph McCarthy, M.D., Leslie Fitzgerald, PA, Leslie Fischer, Tina Barnes, Rebecca Sharp, Carolyn Christ, Cindy Allen, C.J. Buchanan UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION EMMA WARD, Personal Representative for the Estate of Andre Ward, EMMA WARD, v. Plaintiffs, CORIZON HEALTH INC., PRISON HEALTH SERVICES CORRECTION HEALTHCARE INC., WASHINGTON COUNTY, by and through the Washington County Sheriff s office, a political subdivision of the State of Oregon, DR. JOSEPH MCCARTHY, M.D., LESLIE FITZGERALD, PA, LESLIE FISCHER, TINA BARNES, REBECCA SHARP, CAROLYN CHRIST, CINDY ALLEN, C.J. BUCHANAN, JOHN AND JANE DOES 1-10, No. 3:13-cv AC DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES TO FIRST AMENDED COMPLAINT Defendants. COME NOW the named defendants, and for their answers to plaintiffs First Amended Complaint, admit, deny, and allege as follows: Page 1 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

2 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 2 of Paragraph 1 is plaintiffs statement of the case, to which no answer is required. To the extent the Court deems an answer to be required, defendants deny the allegations of paragraph Defendants admit the allegations of paragraphs Defendants deny the allegations of paragraph 5 based on lack of sufficient information to form a belief in the truth of the matters asserted. 6. Defendants admit that the entity defendants, Corizon Health, Inc., and Prison Health Services (collectively, Corizon ) had a contract with Washington County to provide medical care to inmates housed in the Washington County Jail, and that Corizon is a state actor, but otherwise deny the allegations of paragraph Admit that the named individual defendants were employees or independent contractors or Corizon at the times material to plaintiffs complaint, admit that Corizon is a state actor, and deny the remaining allegations of paragraph Defendants admit that Washington County is a political subdivision of the State of Oregon, that the Sheriff s office maintains the Washington County Jail, that the County is responsible for providing medical care within the Jail, and deny the remaining allegations of paragraph 8. Page 2 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

3 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 3 of Defendants admit that the individually named defendants were employees of Corizon, except the John and Jane Does, that they provided health care to plaintiff Ward during the time periods relevant to the complaint, admit that in so doing they were acting under color of state law, and deny the remainder of the allegations of paragraph Defendants deny, on information and belief, that Andre Ward was an inmate, and allege that Andre Ward was a pretrial detainee and that his status as a pretrial detainee may have changed prior to his death in December of Defendants deny that plaintiffs are entitled to their attorney fees. 12. Defendants deny the allegations of paragraph 12 based on lack of sufficient information to form a belief in the truth of the matters asserted. 13. Defendants admit that Mr. Ward was a 37-year-old male African American pretrial detainee being held on criminal charges when admitted to the Washington County jail on or about October 30, 2011, and admit that Mr. Ward died on December 12, 2011 after spending 14 days receiving intensive care from Tuality Hospital, and deny the remaining allegations of paragraph 13. Page 3 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

4 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 4 of Defendants admit that on November 4, 2011, plaintiff complained of a swollen right testicle after sitting down on it wrong, was seen by a Corizon nurse, who sent Mr. Ward to Tuality Hospital, where he was seen that day and sent back to the jail, and deny the remainder of the allegations of paragraph Defendants admit that Mr. Ward was seen again by a Corizon nurse for the injury to his testicle on November 6, 2011, and that he was sent again by Corizon to the hospital, and deny the remainder of the allegations of paragraph Defendants admit that Mr. Ward was seen again by Tuality Hospital on November 6, 2011, that a culture of the wound on his testicle indicated the presence of an antibiotic resistant infection ( MRSA ), that Tuality Hospital informed Corizon of this fact on or about November 8, 2011, at which time Corizon put Mr. Ward on a course of Bactrim, an antibiotic used to treat MRSA infections, and deny the remaining allegations of paragraph Defendants admit that Mr. Ward returned to the jail from Tuality Hospital on or about November 6, 2011, and deny the remainder of the allegations of paragraph Paragraph 18 appears to be an attempt to recite the contents of some of plaintiff s medical records from November 11 through November 29, 2011, and violates Page 4 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

5 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 5 of 11 Fed. R. Civ. P. 8(a)(2). Defendants deny that the attempt at recitation is an accurate description of the medical records, and therefore deny the allegations of paragraph Defendants deny the allegations of paragraph With respect to paragraphs 20-28, defendants admit that MRSA is a bacterial infection that is resistant to some antibiotics, and admit that MRSA is commonly treated with Bactrim. The remainder of paragraphs violates Fed. R. Civ. P. 8(a)(2) and states plaintiffs opinions regarding MRSA, and therefore no answer is required. To the extent the Court deems an answer to be required to the allegations of paragraphs not specifically admitted, defendants deny those allegations, and further deny those allegations for lack of information sufficient to form a belief in the truth of the matters asserted. 29. Defendants incorporate their answers to paragraphs 1 to Defendants admit that Andre Ward was a pretrial detainee and that he was entitled to the protections of the law to which all pretrial detainees are entitled. The remainder of paragraph 30 is plaintiffs description of one of their claims, to which no answer is required; to the extent the Court deems an answer to be required, defendants deny the remaining allegations of paragraph Defendants deny the allegations of paragraph 31. Page 5 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

6 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 6 of Defendants deny the allegations of paragraph Defendants deny the allegations of paragraphs 33 through Defendants incorporate by reference their answers to paragraphs 1 through The allegations of paragraphs are conclusions of law to which no answer is required; to the extent the Court deems an answer to be required, defendants deny the allegations of paragraphs Defendants deny the allegations of paragraphs 41 through Defendants incorporate their answers to paragraphs 1 through Admit that the individual defendants were employees or contractors of Corizon, and deny the remainder of the allegations of paragraph Paragraph 46, as drafted alleges that Plaintiff deviated from the standard of care. To the extent plaintiffs intend to allege that defendants deviated from the standard of care, defendants deny all the allegations of paragraph Defendants deny the allegations of paragraph 47. Page 6 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

7 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 7 of Defendants deny the allegations of paragraph Defendants incorporate their answers to paragraphs 1 through Defendants admit that Washington County contracted with Corizon to provide medical care and deny the remaining allegations of paragraph Defendants deny the allegations of paragraphs 51 through Defendants incorporate their answers to paragraphs 1 through Defendants admit that Washington County and Corizon had a contract with each other, and assert that the contract is the best evidence of its contents. Defendants deny the remaining allegations of paragraph Defendants admit that Corizon is in the business of providing health care services to jails and prisons in many states, admit that the contract with Washington County refers to the standards set forth by the National Commission on Correctional Health Care (NCCHC), and admit that Corizon provides information on medical care issues in jails, but assert that the contract between Washington County and Corizon is the best evidence of its contents and otherwise deny the allegations of paragraph 55. Page 7 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

8 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 8 of Defendants admit that Corizon employs Regional Medical Directors, and that Corizon maintains updated treatment protocols and policies to provide medical care that meets or exceeds the required standard of care, that it provides training to its medical staff, including with respect to HIV, HCV, and MRSA, and deny the remaining allegations of paragraph Defendants deny the allegations of paragraphs 57 through Defendants incorporate their answers to paragraphs 1 through Defendants deny the allegations of paragraphs 62 through 64. FIRST AFFIRMATIVE DEFENSE (Failure to State a Claim) 65. Plaintiffs claims, or some of them, fail to state claims upon which relief may be granted. SECOND AFFIRMATIVE DEFENSE (Timeliness of Tort Claim Notice) 66. Plaintiffs tort claim notice may not have been timely. If untimely, plaintiffs wrongful death claim may be barred by statute. Page 8 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

9 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 9 of 11 THIRD AFFIRMATIVE DEFENSE (Damages Cap in Medical Negligence Case) 67. Some or all of plaintiffs claims may be subject to the limit on non-economic damages in ORS FOURTH AFFIRMATIVE DEFENSE (Tort Claims Act Damages Cap) 68. Some or all of plaintiffs claims may be subject to the limit on damages found in ORS et seq. FIFTH AFFIRMATIVE DEFENSE (Contributory Negligence) 69. Andre Ward refused care, insisted on taking care of himself, and failed to report symptoms to defendants, and his contributory negligence caused his injuries, in whole or in part. SIXTH AFFIRMATIVE DEFENSE (Qualified Immunity) 70. Defendants did not deprive plaintiff of any clearly established federal law or constitutional right of which a reasonable person would have known. Page 9 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

10 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 10 of 11 SEVENTH AFFIRMATIVE DEFENSE (Other s Medical Negligence) 71. Mr. Ward s injuries were caused, in whole or in part, by medical negligence of others outside of defendants control. WHEREFORE, having fully answered plaintiffs First Amended Complaint, defendants pray for a judgment in their favor together with their costs and disbursements incurred herein. DATED this 14th day of March, STEWART SOKOL & GRAY, LLC By: /s/ Robert B. Coleman James M. Daigle, P.C., OSB # Robert B. Coleman, OSB # STEWART SOKOL & GRAY, LLC 2300 SW First Avenue, Suite 200 Portland, OR Phone: Facsimile: (503) Of Attorneys for Defendants Corizon Health, Inc., Prison Health Services Correction Healthcare, Inc., Washington County, Dr. Joseph McCarthy, M.D., Leslie Fitzgerald, PA, Leslie Fischer, Tina Barnes, Rebecca Sharp, Carolyn Christ, Cindy Allen, C.J. Buchanan M:\wdocs\ssgmain\1238\ \PLEAD\ WPD Page 10 - DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES

11 Case 3:13-cv AC Document 16 Filed 03/14/14 Page 11 of 11 CERTIFICATE OF SERVICE I hereby certify that I served the foregoing DEFENDANTS ANSWERS AND AFFIRMATIVE DEFENSES on: Michelle R. Burrows, OSB # Attorney at Law SW Park Street Sherwood, OR Phone: (503) Fax: (503) Of Attorneys for Plaintiff by E-filing a full, true and correct copy thereof to the attorney, as shown above, at the electronic mail address reflected on the court s CM/ECF system, on the date set forth below. DATED this 14th day of March, STEWART SOKOL & GRAY, LLC By: /s/ Robert B. Coleman Robert B. Coleman, OSB # STEWART SOKOL & GRAY, LLC 2300 SW First Avenue, Suite 200 Portland, OR Phone: Facsimile: (503) Of Attorneys for Defendants Corizon Health, Inc., Prison Health Services Correction Healthcare, Inc., Washington County, Dr. Joseph McCarthy, M.D., Leslie Fitzgerald, PA, Leslie Fischer, Tina Barnes, Rebecca Sharp, Carolyn Christ, Cindy Allen, C.J. Buchanan CERTIFICATE OF SERVICE

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