Free Response to Order - District Court of Delaware - Delaware

in. i2. 2005 instill lVlcCull0u%ll 0 llclolt lll- lll I- l
Case 1 :04—cv—00352-Gl\/IS Document 26-2 Filed 07/14/2005 Page 1 of 4
TN THE UNITED STATES DISTRICT CQURT
FOR THE DISTRICT OF DELAWARE
JOHN M. FRANKLIN, )
)
Pleintifi] ) CA. No. O4-CV-352-GMS
J
v. )
)
FI0'I` CORRECTIONAL MEDICAL, )
AMY W, AMY B. )
)
Defendants. )

State of Delaware )
) SS:
Sussex County )
Roberta P`. Burns, M.D., being duly sworn according to law, states as follows:
1. lem e medical doctor, licensed to practice medicine in the State cfDelewe.re. From
July 1, 2002 through June 30, 2005, I WEB employed as e Medical Doctor for First Correctional
Medical ("FCM"), the fonner health care provider for the Delaware correctional system. I nm,
presently e Medical Doctor for Correctional Medical Services (CMS), the current health core
provider for the Delaware correctional system, nucl I make this efildevit on personal lcnowleclge.
2. I em familiar with the medical conditions of plaintiff John M. Franklin. I have
reviewed his medieel chart, his complaint, end hie ellegetione ofrnedicel negligence end civil rights
violntione ngninet F CM and several of its employees (thc "FCM Defendant?).
3. FCM become the health cme provider for the Delaware correctional system on July
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1, 2002. FCM ceased being the health cm provider for the Duliiwaxe ccncctlonal aysicm on Julie
30, 2005.
4. Mr. Franlcliws primary medical complaint is that he is being dcniead proper medical
treatment for his hem condition. M1. Franklin claims that this lack oflmamncnt is causing pressure
_ in his head, nmnbncss in his hands and fleet, pain in his right side, and a knot in his cl1cst¤cm his
heart.
5. Mr. Frzmlclin suffers iitom s. heart disorder called "auial f1b1*illmi0¤". Atrial
fibrillation is the most common fom: 0fmhytl1¤11i.=:l(iL·rcgulzir hiumbcat). Wlwu an individual suffers,
fiom mxlul librillatiou, their heart has abnormal calactxical impulses tht muse the uppgr chambers
of the hem to quiver (fibrillate), resulting in irreguiargmd rapid beating of the ventricles. This
causes the ham to function less efficiently and gcxicmlly reduces blood flow to the hem itself. _
Additioxwilly, incfiiciem pumping ofrhc aim cam cause the blood to pool in the au-ia and clot there.
These clots can move imo the bloodstream and possibly lodge in the brain, resulting iu a stroke. Aa
2. result, pmiamts with atrial fibrillation should take em1.i¤¤ag¤1lantm¤cHcati0m.
6, Symptoms ofmxial iibrilluiion can include ai noticeable irregular lwzmbant, wcakncssn
shcrmezss of breatlm, hc-sm palpitations, fuintingn stroke, or ham failure. Atrial iibrillsmlicm is s.
pmgcssiva condition. Over time, these symptoms mid episodes ofatrial fibrillation occur for longer
pcxicds cfiimc and mom frequently. Eventually, the irregular hcmbcat becomes pezrsistent and it
cannot resolve em its own. At this point, mmm to normal rhythm (normal sinus rhythm), requires
cmdinvcrsion, This may be accomplished via medication or clecimical wdiovcrsinn. Wlwre
continued symptoms persist, antiarrhythmic medications may be given.
7. An aumlcoagnmlamt medication frequently pmsciibc. for amiul fibrillation patients in
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Case 1 :04—cv—00352-Gl\/IS Document 26-2 Filed 07/14/2005 Page 3 of 4
Warfarin, which goes by the brand name Coumsdiu. Warthrin thlns the hlood and helps prevent
clots from forming. Warfarin does not dissolve already existing clots, but it can prevent preexisting
clots from getting larger.
8. The dosage of Warfarin is based upon the paticntis medical condition and response
to therapy. A prothrornbin time test (PT test) and international normalized ratio (INR) should be
performed regularly throughout treatment with Warfarin to monitor the patient s response to therapy.
The results of the PT test and 1NR may cause the ps.i.ient’s dosage of Wsrfarin to he adjusted
accordingly. Because the dosage of Warfarin is so personalized to e pdflilculst patient, the proper
dosage may take weeks of trial and error to achieve.
9. A PT test measures how long it takes blood to clot. It can be used to monitor medical
treatment with medication that prevents the formation of blood cl• (W arfalin). When used to
monitor medical nesmztent, PT tests should bc given regularly until the correct dosage of Warfsrln
is determined for the individual patient.
l0. INR is a method of standardizing PT test results. A nonnal PT test calls for
coagulation from 10-13 seconds or al`NR of 1.0 · 1.4. Where a patient is taking Warftuin, the PT
time is about 1.5 to 2.5 times the normal value (or INR results of 2 - 3). I
12. John M. Franklin has been and remains to be treated for his ahisl fibrillation
condition. Mx. Franklin is in the chronic care clinic for his heart and, as such, is seen regularly by
doctors without the need for a sick call slip. Mt`. Franklin is receiving Tambocor, an antiarrhythmic,
to aid his heart in reaching normal sinus rhythm. Additionally, Mr. Franlclln is receiving Coumadin
(the brand name version of Wsrfarin), an anticoagulant, to thin his blood. Mr. Franltlin’ s Coumadin
treatment is being monitored through regularly administered PT tests.
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` ase :04—cv—00352-Gl\/IS Document 26-2 Filed 07/14/2005 Page 4 of 4
13. Unfortunately, the dosege for Coumeclin treatment is not universal end the specific
dosage for each individual, is diflicultto ascertain. Medicel steffhsve been continually working with
Mr. Frztnldiu to schieve en INR between 2 — 3,
lil. Mr. Franklin has not been sent to the hospital for his subjective symptoms becttusc
there has been no objective need. Regarding the alleged numbness in his bends and feet, Mr.
Frsnl of rt stroke, his ems and legs are fine, and he wellcs normally. As to Mr. Frsnlclirfs headache
complaints, he has been unable to pin pressure downto e certain portion of his heed.
15. At this time, it is my medical opinion, based upon Mt. Frenklin’s subiective
complaints end the objective findings by various medical staff and my review of his medical chmt,
that Mr. Franklin is suffering from minor side effects ss rt result ofthe attempts to tind the proper
dosage of Coumedin to treat his etriel fibrillation. These side effects do not rise to the level of need
requiring sn MRL
16. Based on my medical knowledge in general, end personal knowledge of M1.
Frsnlclilfs condition from review of his chen and records, it is my medical opinion thet Mr, Franlclin
hes elweys received proper medical care iicm ell FCM personnel. The medical csre provided by
FCM personnel mot the stsndsrd of este for treatment of Mr. l`ix·s.rrl no deviations from the stendetd of cure with respect to sny F CM personnel.
‘`“i` i ii ``i`”` i `""" W s. o i'i`i il; O r ,4.4 V /it/l
NOTARY PUBUC [li//Lil;]/l»U pg hu/Wl-’7l’N
H Cemmls e V t,,,· - i ° `
Sworn to and subscribed before me l
this lfiiildey of July, 2.005. _ , Y
. - t ii fi .. -_ . Q,
· . i cl
Neely sein ' *‘.. t i ··

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