Case 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page ... · Case 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 30 of 35 Pageid#: 4749April Wimberley Declaration & Exhibit

Mary Bauer Declaration & ExhibitCase 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 1 of 35 Pageid#: 4720





Alex Gulotta Declaration & ExhibitCase 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 6 of 35 Pageid#: 4725


DateTotal

Time

Timed Item

Type

Timed Item

SpecificsDescription

1/25/2010 2 Case Work Strategy/Planning mtg @ WR

1/25/2010 6 Case Work Travel travel

3/29/2010 9.1 Case Work Other mtg at wiley rein; travel; f/u

7/9/2010 1.5 Case Work Strategy/Planning .5 prep; 1 call

11/17/2010 9.8 Case Work Strategy/Planning to DC

3/9/2011 3.5 Case Work Strategy/Planning prep; mtg w co‐counsel

6/23/2011 7 Case Work Strategy/Planning travel; DC mtg; back to Gainesville

11/21/2011 1.5 Case Work Phone Call plan

1/20/2012 1.5 Case Work Phone Call call and prep

3/15/2012 2 Case Work Trial/Hearing Prep. rev; prep call

5/16/2012 6 Case Work Strategy/Planning travel; prep, planning meeting

7/10/2012 1.5 Case Work Strategy and Planning re‐read opinion; call

8/27/2012 1.3 Case Work Strategy and Planning prep; review; call

10/15/2012 0.7 Case Work Trial/hearing preparations prep

12/19/2012 0.8 Case Work Strategy and Planning call

9/6/2013 3.3 Case Work Strategy and Planning prep & meeting

57.5

3/21/2012 5 Case Work Court Appearance travel; wtg; appearance; debrief; travel

10/15/2012 1.2 Case Work Trial/hearing‐includes travel MTD ‐ wtg, & appearance

4/30/2013 2.1 Case Work Strategy and Planning prep; call; follow‐up and mtd

6/17/2013 2.8 Case Work Trial/hearing‐includes travel prep, travel, court, follow‐up

11.1


Angela Ciolfi Declaration & ExhibitsCase 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 9 of 35 Pageid#: 4728














Catherine Martin Declaration & ExhibitCase 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 23 of 35 Pageid#: 4742



1 April Wimberley Declaration & ExhibitCase 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 26 of 35 Pageid#: 4745



1

Pro Bono Hours worked by Attorney April Wimberley for Scott v. Clarke (Redacted to remove names of clients who are neither class representatives

nor declarants in this action)

2011

DATE

WORK TIME

1.12.11 Meet with BH regarding her MRSA infection. Meet with Marguerite Richardson regarding her health conditions, including Hepatitis C; swelling under the ribcage; and limited bathroom access. Counsel each regarding grievance process and other potential relief.

2.6 hours

1.26.11 Draft notes for the file regarding meeting with Marguerite Richardson and BH.

1 hour

2.2.11 Meet with CS regarding neck and back injuries. Counsel regarding grievance process and other potential relief.

1.6 hour

2.9.11

Meet with JS regarding prison’s punitive use of diet loaf; strip search; and possible seizure of outgoing mail. Draft follow-up letter to CS regarding grievance process and for update regarding her condition.

2.5 hours

2.16.11 Meet with SS regarding her ovarian cancer. Meet with TW regarding mental health needs and PREA complaint. Meet with Esther Gordon regarding sarcoidosis. Counsel each regarding grievance process and other potential relief. Draft notes for the file regarding meeting with SS.

4.1 hours

2.23.11 Draft notes for the file of meetings with JS, Esther Gordon, and TW.

1.5 hours

3.16.11 Meet with SC regarding artery cut during surgery. Meet with DD regarding healthcare needs related to her diabetes. Meet with RS-A regarding medication overdoses; falls; and migraines. Counsel each regarding grievance process and other potential relief.

3.6 hours

3.17.11 Draft interview notes regarding meeting with SC. 0.5 hour 3.23.11 Meet with SL regarding assault by other prisoner and

possible involvement of prison staff. Meet with TW regarding mental health treatment and sexual assault. Meet with RS regarding her pain in feet; vaginal discharge; claims against supervisor. Counsel each regarding grievance process and other potential relief. Draft follow-up letter to RS-A. Draft notes for the file regarding meetings with RS-A and DD.

5.6 hours

3.30.11

Meet with JW regarding lupus; sores on face; ITP; migraines; and asthma. Meet with IB regarding healthcare needs and past treatment for her lung cancer. Meet with PD regarding her lupus and heart attack or stroke. Counsel regarding grievance process and other

5.1 hours

April Wimberley Declaration & ExhibitCase 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 29 of 35 Pageid#: 4748

2

potential relief. Draft notes for the file regarding meetings with SL, TW, and RS.

4.03.11 Draft notes for the file regarding meeting with PD. 0.5 hour 4.06.11 Draft notes for the file regarding meetings with IB and

JW. 1 hour

4.14.11 Meet with NH regarding suspected exposure to TB. Counsel regarding grievance process and other potential relief. Draft follow-up letter to TW regarding grievance process; mental health care; and PREA complaint process.

2.1 hour

4.14.11 Meet with PT regarding a tear between her rectum and vagina and her corresponding medical needs.

2.1 hour

4.27.11 Draft follow-up letters to NH and PT. Draft notes for the file regarding meeting with PT. Counsel regarding grievance process and other potential relief.

1.5 hour

5.4.11 Meet with BL regarding discontinuation of her prescription medications; seizure of over-the-counter medications; and swelling in extremities. Meet with MC regarding seizures; change or discontinuation of prescription medications; and contorted legs and feet. Counsel each regarding grievance process and other potential relief.

2.6 hour

5.6.11 Draft follow-up letter to SC. 0.5 hour 5.11.11 Draft follow-up letters to BL and MC. Draft notes for the

file regarding meetings with BL and MC. 1.5 hour

5.12.11 Draft follow-up letter to SL. 0.4 hour 5.18.11

Meet with HM regarding her seizures and maintenance of her hearing aid. Meet with MJ regarding staph infection; potential exposure to TB; and injury sustained during removal of cast. Meet with MK regarding her lung disease; PTSD; discontinuation of prescription medications; and medical clemency. Counsel each regarding grievance process and other potential relief. Draft follow-up letter to JS.

4.1 hour

5.25.11 Draft follow-up letter to MJ and MK. Draft notes for the file regarding meetings with MJ, MK, and HM.

1.7 hour

6.8.11 Read client correspondence. Draft follow-up letter to RS-A regarding migraines and questions about grievance process.

1.5 hour

6.29.11

Meet with TJ regarding removal of her wisdom teeth; refused mental health care; and assault by other prisoner. Meet with LW regarding rheumatoid arthritis and problems getting prescribed medications. Counsel each regarding grievance process and other potential relief.

2.6 hour

7.6.11

Meet with JS regarding accommodations for impaired hearing; pericardial cyst; need for a medical diet; rheumatoid arthritis; need for new glasses; osteoporosis. Counsel regarding grievance process and other potential

2.1 hour


3

relief. Visited FCCW to meet with BW regarding her epilepsy. She was not available to meet me as scheduled. Draft notes for the file regarding meeting with TJ.

7.13.11 Draft follow-up letters to TJ, LW, and JS. Draft notes to the file regarding meetings with same.

2 hours

7.20.11

Meet with DS regarding medication error by prison nurse and subsequent care at UVa Hospital. Draft follow-up letter to JS.

1.5 hour

7.27.11 Review FCCW Monthly Grievance Reports for 31-month period; tabulate rejection rates and reasons for rejections; confer with colleagues regarding same. Draft notes for the file of meeting with DS.

2.5 hour

8.23.11 Read correspondence from clients. 1 hour 8.31.11

Meet with GB regarding e.coli and MRSA infections at site of post-operative wound. Draft follow-up letter to Carrie Seward regarding health status and grievance process. Meet with RH regarding eczema and sexual abuse by prison officer; eczema. Counsel each regarding grievance process and other potential relief.

3.6 hours

9.14.11 Draft follow-up letters to GB and RH. 0.8 hour 9.21.11 Meet with KB regarding healthcare needs.

Meet with Toni Hartlove regarding prosthetic eye; epilepsy; and breast infections. Counsel each regarding grievance process and other potential relief.

2.6 hours

9.28.11 Draft follow-up letter to Toni Hartlove. Draft FOIA request to DOC regarding formulary/list of approved prescription medications.

1.3 hour

10.12.11 Meet with LK regarding her unresolved medical conditions, including swelling, pain, bleeding, blackouts, numbness; and diabetes. Meet with CB regarding slip and fall and subsequent medical treatment. Counsel each regarding grievance process and other potential relief.

2.6 hours

10.13.11 Draft notes for the file regarding meeting with LK; communicate with colleagues regarding same.

1 hour

10.14.11 Conduct research and confer with colleagues regarding legal options to obtain health care for LK.

2 hours

10.19.11 Meet with ET regarding untreated pain in legs and no access to a wheelchair or cane. Counsel regarding grievance process and other potential relief.

1.6 hour

10.25.11 Draft notes for the file regarding meetings with ET, HB, and CB.

1.5 hour

11.02.11 Draft follow-up letter to ET. 0.5 hour 11.09.11 Meet with MC regarding nerve disorder and jaw pain.

Counsel regarding grievance process and other potential relief.

1.6 hour

11.16.11.

Meet with TB regarding incontinence; headaches; and episodes of passing out. Counsel regarding grievance process and other potential relief.

1.6 hour


4

11.16.11 Meet with RW regarding partially amputated foot and broken leg. Counsel regarding grievance process and other potential relief.

1.6 hour

TOTAL (2011)

81.6 HOURS

2012

1.11.12

Meet with CC regarding her untreated fibromyalgia. Meet with RW about untreated Hepatitis C. Counsel each regarding grievance process and other potential relief.

2.6 hours

1.12.12 Draft notes for the file of meetings with CC and RW. 1 hour 2.01.12 Correspond with Dr. Harvard Stevens at FCCW

regarding treatment of RW. 0.5 hour

2.8.12 Meet with AB regarding untreated tumor on her neck; coughing up blood; trouble breathing and swallowing; and aneurism. Meet with MC regarding nodules on lung and imposition of “medical hold.” Counsel each regarding grievance process and other potential relief.

1.6 hour

2.15.12 Meet with HB regarding untreated Chron’s disease. Counsel regarding grievance process and other potential relief. Correspond with Dr. Harvard Stevens regarding treatment of RW.

2 hours

2.23.12 Conduct research regarding guidelines about the “common fare” diet; special diets needed for medical reasons; criteria for determining “chronic care” conditions; and referrals to outside medical care providers. Correspond with DOC staff regarding same.

2.5 hours

3.14.12.

Meet with PD regarding untreated and unexplained abdominal swelling and difficulty with bowel movements. Counsel regarding grievance process and other potential relief. Meet with RW in follow-up regarding her untreated Hepatitis C.

2.6 hours

3.28.12

Meet with Beth Brondas regarding her health care needs. Meet with Patricia Knight regarding her health care needs. Meet with Michelle Wagoner regarding her health care needs. Meet with NSL regarding her health care needs. Counsel each regarding grievance process and other potential relief.

4.6 hours

4.11.12 Draft letter to Dr. Harvard Stevens at FCCW regarding care of RW. Conduct related research regarding DOC guidelines for the treatment of Hepatitis C.

2 hours

4.19.12 Correspond with Dr. Harvard Stevens regarding RW. 0.2 hour 4.26.12 Correspond with Dr. Harvard Stevens regarding RW. 0.2 hour 5.2.12 Meet with CS regarding her untreated Chron’s disease.

Meet with BB regarding undiagnosed cause of abdominal pain and constipation and problems related to her diabetes. Meet with JH regarding untreated chronic

4.6 hours


5

diarrhea. Counsel each regarding grievance process and other potential relief. Meet with JS for follow-up help regarding her grievances.

6.6.12

Meet with Belinda Gray regarding unexplained and untreated liver lesions, abdominal pain, and gastro-intestinal problems. Meet with LW regarding untreated swelling and pain in feet and legs. Counsel each regarding grievance process and other potential relief.

2.6 hours

7.18.12 Create report of events regarding progression of Hepatitis C in RW and efforts to obtain treatment. Draft notes for the file regarding meeting with LW.

1.5 hours

8.2.12

Meet with Taylor Gilmer regarding needs related to her diabetes.

1.6 hour

8.10.12

Meet with RH regarding her health care needs. Meet with AA regarding unwanted pregnancy, bleeding and cramping; and denial of access to abortion. Meet with AJ regarding low blood pressure; fall from bunk; and mental health care treatment. Meet with CA regarding treatment related to her anal cancer and broken hip. Counsel each regarding grievance process and other potential relief.

4.6 hours

8.13.12 Confer with Abigail Turner regarding AA. 0.3 hour 9.26.12 Meet with Esther Gordon regarding her sarcoidosis.

Meet with Michelle Wagoner regarding her health care needs. Meet with Taylor Gilmer regarding her diabetes and related medical needs. Counsel each regarding grievance process and other potential relief.

3.6 hours

10.3.12 Meet with CP regarding treatment of her strokes. Meet with TT regarding multiple infections at site of tumor removal in leg and new tumors needing removal. Counsel each regarding grievance process and other potential relief.

2.6 hours

10.17.12 Meet with DB regarding medical treatment for her lung cancer. Meet with FA regarding her medical treatment needs. Counsel each regarding grievance process and other potential relief.

2.6 hours

10.31.12

Meet with JJ regarding treatment of possible food poisoning and e. coli infection. Counsel regarding grievance process and other potential relief. Meet with Taylor Gilmer regarding unmet needs related to her diabetes.

2.2 hours

11.14.12 Meet with NM regarding her health care needs. Meet with AM regarding her health care needs. Counsel each regarding grievance process and other potential relief. Draft letter to JW regarding sores on face and status of other health conditions and next steps.

3.1 hours

11.15.12 Draft notes of meetings with NM, JW, and AM for the files. Consult with colleagues regarding same.

2 hours

12.12.12

Meet with BJ regarding withholding of prescription medications; inappropriate charges for sick calls; need

2.6 hours


6

for endoscopy. Meet with AA regarding untreated asthma; migraines; high blood pressure; and inappropriate charging for chronic-care appointments. Counsel each regarding grievance process and other potential relief.

TOTAL (2012)

52.6 HOURS

2013

1.11.13 Confer with consulting diabetes expert Dr. Jennifer Kirby regarding treatment of Taylor Gilmer’s Type 1 diabetes; draft notes for the file regarding same.

1.5 hour

1.14.13 Correspond and confer with Abigail Turner and consulting expert Dr. Jennifer Kirby regarding treatment of Taylor Gilmer’s Type 1 diabetes.

0.8 hour

1.16.13 Meet with Holly Landry regarding her multiple sclerosis. Meet with KZ regarding irregular mammogram and seizures. Counsel each regarding grievance process and other potential relief.

2.6 hours

1.23.13 Revise outline of FCCW grievance process for prisoners. Draft notes for the file regarding meeting with Holly Landry.

1.5 hour

1.30.13 Meet with Tonya Lane regarding untreated carpal tunnel; incontinence; Hepatitis C; and depression. Counsel regarding grievance process and other potential relief. Meet with Beth Brondas in follow-up regarding her health care needs.

2.6 hours

3.20.13.

Meet with RG regarding kidney failure; unexplained pain; history of heart problems; and need for follow-up care. Meet with SG regarding concerns about hysterectomy and removal of ovary. Meet with LW in follow-up regarding her medical conditions and treatment. Counsel each regarding grievance process and other potential relief.

3.6 hours

3.22.13 Draft notes to the file regarding meetings with LW, SG, and RG.

1.5 hour

5.03.13 Meet with Michelle Wagoner regarding her health care needs.

2 hours

5.5.13

Meet with TMG regarding untreated eye infection; bipolar disorder; and migraines. Counsel regarding grievance process and other potential relief. Draft notes to the file regarding same. Draft notes for the file regarding meeting with Michelle Wagoner.

2.5 hours

6.5.13

Meet with Ines Ford regarding untreated leg pain, spasms, and depression. Counsel regarding grievance process and other potential relief. Draft notes for the file regarding meeting with Ines Ford.

2.6 hours

6.19.13 Meet with GGO regarding medical conditions needing 4.6 hours


7

attention, including hypertension; diabetes; chest pains with history of heart problems; and thyroid dysfunction. Meet with TD regarding unexplained seizures. Meet with DM regarding severe urinary tract problems and hearing impairment. Counsel each regarding grievance process and other potential relief. Draft notes regarding meeting with DM and confer with colleagues regarding same.

7.10.13

Meet with JJ regarding undertreated irritable bowel syndrome and chronic diarrhea; diabetes; restless leg syndrome; and insufficient supply of incontinence pads and medications. Counsel regarding grievance process and other potential relief.

2 hours

7.31.13

Meet with Ines Ford in follow-up regarding her medications and other health care concerns. Counsel regarding grievance process. Submit request for medical records of Margaret Baldi.

2.1 hour

8.07.13 Conduct follow-up research regarding medical records of Margaret Baldi.

0.8 hour

9.25.13

Meet with IJ regarding inadequate treatment of broken ankle. Meet with TMG in follow-up regarding her medical care needs. Meet with RW regarding untreated Hepatitis C and severe ascites. Counsel each regarding grievance process and other potential relief.

3.6 hours

10.23.13 Meet with Lucretia Stewart-Moore regarding withholding of tamoxifen as prescribed for post-breast-cancer treatment; and pain in breasts. Meet with Bobinette Fearce regarding status of medical conditions and care.

2.6 hours

TOTAL (2013)

36.9

2014

1.15.14 Draft responses to interrogatories regarding Rebecca Scott.

0.8 hour

TOTAL (2011-2014) 171.1 HOURS


Documents

Case 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page ... · Case 3:12-cv-00036-NKM Document 228-6 Filed 10/20/15 Page 30 of 35 Pageid#: 4749April Wimberley Declaration & Exhibit