RETURN DATE: 12/17/02 ) SUPERIOR COURT ELAINE … · GINGER BOCHICCHIO, GAIL N. FREDETTE and DR. MINGZER TUNG were medical workers assigned on November 17, 1999 to the GARNER CORRECTIONAL

RETURN DATE: 12/17/02 ) SUPERIOR COURT ) ELAINE WISEMAN, ADMINISTRATOR ) OF THE ESTATE OF BRYANT ) WISEMAN, ) PLAINTIFF, ) ) vs. ) ) JOHN J. ARMSTRONG; JACK TOKARZ; ) DR. WILLIAM JOUGHIN; DR. REGINALD ) JUDICIAL DISTRICT OF HOFFLER; OSCAR MALDONADO; MICHAEL ) A. PACE; KEVIN COWSER; JAMES E. ) REILLY; DONALD J. HEBERT; ROBERT ) G. STACK; JOSE ZAYAS; KEVIN J. ) DANDOLINI; ANGELO P. GIZZI; EDWIN ) MYERS; WILLIAM SMITH; VAUGHN ) WILLIS; BRIAN C. BRADWAY; FRANK ) MIRTO, in their individual and ) HARTFORD AT HARTFORD official capacities; and ) IRIS PRESCOTT; ANDRE CHOUINARD; ) WILLIAM SCOTT; STEVEN SANELLI; ) JIMMY GUERRERO; JEFFREY HOWES; ) MAURELLIS POWELL; DENNIS CAMP; ) RAYMOND BRODEUR; MOISES PADILLA; ) ANNE MARIE STOREY; ROBERTA C. ) LEDDY; CLO BARSOTTI; GINGER ) BOCHICCHIO; GAIL N. FREDETTE; DR. ) MINGZER TUNG, in their individual ) capacities; and CONNECTICUT ) DEPARTMENT OF CORRECTION; STATE OF ) CONNECTICUT; UNIVERSITY OF ) CONNECTICUT HEALTH CENTER; GARNER ) CORRECTIONAL INSTITUTION, ) ) DEFENDANTS. ) NOVEMBER 15, 2002 COMPLAINT

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1. This Complaint concerns the failure of the Connecticut

Department of Correction to care properly for persons with mental

illness. It specifically concerns the brutal death of a young

mentally ill man at the hands of the correctional officers and

medical workers charged with his supervision and care.

2. On November 17, 1999, 28-year old Bryant Wiseman died

while incarcerated at the Garner Correctional Institution.

3. Bryant was mentally ill, and at the time of his death he

had been diagnosed as suffering from paranoid schizophrenia.

4. Notwithstanding Bryant’s mental illness, however, the

Department’s doctors, nurses and other medical workers failed and

refused to provide adequate and proper medical care, supervision

and medication to him, they allowed his mental illness to go

untreated and inadequately treated, and they permitted him to

decompensate and to become paranoid and aggressive under

circumstances that they knew would lead to violent confrontations

with other inmates and correctional staff.

5. On November 17, 1999, after several days during which his

doctors intentionally withheld required anti-psychotic medication,

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Bryant’s untreated mental illness caused him to become paranoid and

disruptive, and as could and should have been expected, he was

subsequently violently subdued and restrained by more than eight

correctional officers and other Department staff.

6. Beginning at approximately 12:45 p.m., in a mental health

cell at the Garner Correctional institution, the officers and staff

piled on top of Bryant, handcuffed him behind his back, put him in

leg irons, savagely beat him, asphyxiated him, caused him to vomit,

rendered him unconscious and comatose, and ultimately killed him.

7. The guard’s violent and savage assault on Bryant Wiseman

and his brutal death at their hands unfortunately is not an

isolated incident at the Department of Correction. Seven months

before Bryant was killed, another young mentally ill man, Timothy

Perry, was killed by guards under similar circumstances while in

custody at a facility of the Department of Correction.

8. As with Bryant Wiseman, Timothy Perry’s schizophrenia

caused him to become paranoid and aggressive, and he was killed by

guards while being violently subdued and restrained in a mental

health cell.

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9. Following Timothy Perry’s death, however, none of the

guards and medical workers responsible for his death told the truth

about how he was killed or otherwise notified Department officials

of the immediate need for Department-wide training in the treatment

and supervision of mentally ill inmates and proper take-down and

restraint procedures.

10. Moreover, following Timothy Perry’s death, neither the

Commissioner of the Department of Correction nor any other

Department official conducted an adequate investigation and review

of Timothy’s death or of Department procedures to ensure that

proper training was conducted and to avoid further injury and death

to mentally ill inmates such as Bryant Wiseman.

11. As a result of the above failings, no adequate training

was conducted, no precautionary procedures were instituted, no

required monitoring and supervision of correctional staff was

contemplated, and, as could and should have been expected and

prevented by Department officials, Bryant Wiseman was killed in a

nightmarish reenactment of Timothy Perry’s death only a few months

earlier.

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12. This Complaint seeks redress from the persons and

entities responsible for the care and treatment of this State’s

mentally ill inmates and for Bryant Wiseman’s anguish, injuries and

death.

PARTIES

13. Plaintiff ELAINE WISEMAN, ADMINISTRATOR OF THE ESTATE OF

BRYANT WISEMAN, is Bryant Wiseman’s mother. The Fiduciary’s

Probate Certificate appointing ELAINE WISEMAN as the Administrator

is attached hereto.

14. Defendant JOHN J. ARMSTRONG is, and was at all relevant

times, the Commissioner of the CONNECTICUT DEPARTMENT OF

CORRECTION. As such, he was responsible for the administration of

this State’s correctional system, the care and custody of persons

incarcerated by the DEPARTMENT, and the hiring, supervision,

training, discipline and control of persons working for the

DEPARTMENT. He is sued in his individual and official capacities.

15. Defendant JACK TOKARZ is, and was at all relevant times,

the Deputy Commissioner of the CONNECTICUT DEPARTMENT OF CORRECTION

in charge of the Programs and Staff Development Division. As such,

he was responsible for the administration of this State’s

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correctional system, the care and custody of persons incarcerated

by the DEPARTMENT, and the hiring, supervision, training,

discipline and control of persons working for the DEPARTMENT. He

is sued in his individual and official capacities.

16. Defendant STATE OF CONNECTICUT is a governmental entity,

and is the proper party against which suit may be brought pursuant

to Connecticut General Statutes §§ 4-141, et seq.

17. Defendant CONNECTICUT DEPARTMENT OF CORRECTION, acting

through its agents, representatives and employees, was responsible

for the care, custody and treatment of Bryant Wiseman at all

relevant times mentioned herein.

18. Defendant UNIVERSITY OF CONNECTICUT HEALTH CENTER was at

all relevant times responsible for providing medical, mental health

and psychiatric care, services and supervision to persons in the

custody of the CONNECTICUT DEPARTMENT OF CORRECTION, including

Bryant Wiseman.

19. Defendant GARNER CORRECTIONAL INSTITUTION is the

CONNECTICUT DEPARTMENT OF CORRECTION facility where Bryant Wiseman

was incarcerated prior to and at the time of his death on November

17, 1999.

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20. Defendants MICHAEL A. PACE, KEVIN COWSER, JAMES E.

REILLY, DONALD J. HEBERT, ROBERT G. STACK, JOSE ZAYAS, KEVIN J.

DANDOLINI, ANGELO P. GIZZI, EDWIN MYERS, WILLIAM SMITH, VAUGHN

WILLIS, BRIAN C. BRADWAY, and FRANK MIRTO were correctional

officers, supervisors and other staff assigned on November 17, 1999

to the GARNER CORRECTIONAL INSTITUTION. The defendants in this

paragraph are collectively referred to as the “WISEMAN CORRECTIONAL

EMPLOYEE DEFENDANTS.” They are sued in their individual and

official capacities.

21. Defendants IRIS PRESCOTT, ROBERTA C. LEDDY, CLO BARSOTTI,

GINGER BOCHICCHIO, GAIL N. FREDETTE and DR. MINGZER TUNG were

medical workers assigned on November 17, 1999 to the GARNER

CORRECTIONAL INSTITUTION. At relevant times, some or all of these

defendants were employed by the UNIVERSITY OF CONNECTICUT HEALTH

CENTER. They are sued in their individual capacities.

22. Defendants DR. WILLIAM JOUGHIN, DR. REGINALD HOFFLER and

OSCAR MALDONADO are the doctors and social worker responsible for

treating, monitoring and managing Bryant Wiseman’s mental illness

at the CONNECTICUT DEPARTMENT OF CORRECTION prior to his death. At

relevant times, some or all of these defendants were employed by

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the UNIVERSITY OF CONNECTICUT HEALTH CENTER. They are sued in

their individual and official capacities.

23. Defendants ANDRE CHOUINARD and WILLIAM SCOTT were

Lieutenants at the CONNECTICUT DEPARTMENT OF CORRECTION who, on

April 12, 1999, seven months before Bryant Wiseman was killed, were

responsible for the death of Timothy Perry, another mentally ill

man in the custody of the DEPARTMENT. Defendants STEVEN SANELLI,

JIMMY GUERRERO, JEFFREY HOWES, MAURELLIS POWELL, DENNIS CAMP,

RAYMOND BRODEUR, and MOISES PADILLA were correctional officers

responsible for the death of Timothy Perry. Defendant ANN MARIE

STOREY was a nurse employed by the UNIVERSITY OF CONNECTICUT HEALTH

CENTER who was also responsible for the death of Timothy Perry.

The Defendants in this paragraph are collectively referred to as

the “PERRY CORRECTIONAL EMPLOYEE DEFENDANTS.” They are sued in

their individual capacities.

FACTS

24. At all times mentioned herein, each individual Defendant

was acting in the course and scope of his or her employment.

25. At all times mentioned herein, each defendant was acting

under color of state law.

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26. Bryant Wiseman was incarcerated at the CONNECTICUT

DEPARTMENT OF CORRECTION for several years before he was killed on

November 17, 1999.

27. Bryant was diagnosed by his doctors at the DEPARTMENT OF

CORRECTION as suffering from paranoid schizophrenia.

28. It was well-known to all of Bryant’s doctors, nurses and

other medical workers, including his treating psychiatrists

defendants DR. WILLIAM JOUGHIN and DR. REGINALD HOFFLER, and his

assigned social worker defendant OSCAR MALDONADO, that Bryant

required adequate and proper anti-psychotic medication in order to

control his schizophrenia, to enable him to function properly and

to prevent his becoming paranoid, aggressive and disruptive.

29. Notwithstanding this knowledge, DR. WILLIAM JOUGHIN, DR.

REGINALD HOFFLER, OSCAR MALDONADO and the other doctors and medical

workers responsible for Bryant’s well-being failed and refused to

prescribe and administer adequate and proper anti-psychotic

medications.

30. The types of medications prescribed for Bryant, the

dosage levels for those medications, and the time periods during

which those medications were prescribed were all inadequate to

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properly treat Bryant’s illness and to control his paranoia and

aggression.

31. As a result, Bryant’s mental illness went substantially

untreated or inadequately treated for much of the time that he was

incarcerated, and he suffered frequent episodes of decompensation

and resulting paranoia, fear, and aggression

32. Also as a result of substandard medical care, monitoring

and supervision, Bryant frequently became non-compliant even with

those anti-psychotic medications that were prescribed for him, and,

as a result of this non-compliance, he suffered paranoia and other

psychotic symptoms, and consequently engaged in assaultive,

impulsive and aggressive behavior toward other inmates and staff.

33. Bryant’s need for anti-psychotic medications, his

potential for non-compliance, and the resulting risk of aggression,

were all well known to his doctors and other medical workers.

34. A November 14, 1996 clinical record entry by defendant

DR. JOUGHIN, for example, states that “The large issue is

[Bryant’s] inclination to be off medication, and problems around

non-compliance � decompensation, paranoia and violence towards

others.”

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35. Similarly, a November 26, 1996 clinical entry by DR.

JOUGHIN states that “the patient’s need for medication is clear –

in terms of his paranoia and related hostility when off

medications....”

36. A clinical record entry by defendant social worker

MALDONADO on November 26, 1996 similarly states ”This inmate has a

history of poor compliance with medications. In the past he has

decompensated rapidly whenever he stops taking his medications. He

has the potential to become assaultive. Therefore his medication

intake needs to be monitored regularly.”

37. During the period of his incarceration at the DEPARTMENT

OF CORRECTION, Bryant suffered repeated episodes of becoming

noncompliant with his psychotropic medications, of decompensating

and becoming paranoid and violent as a result, of engaging in

aggressive behavior, of being restrained by correctional staff, and

of having his medications subsequently monitored or even

administered against his will.

38. These repeated episodes of noncompliance, aggression,

restraint, and subsequent medication were well-known to Bryant’s

treating psychiatrists and to the other doctors, nurses and medical

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staff who had responsibility for treating and managing Bryant’s

mental illness, including defendants JOUGHIN, HOFFLER, MALDONADO

and PRESCOTT.

39. For example, in November 1996, after having refused his

medications for several days, Bryant became paranoid and he

assaulted another inmate. Correctional officers restrained him,

and his treating psychiatrist, DR. JOUGHIN, subsequently ordered

that Bryant be given anti-psychotic medication against his will if

he continued to refuse voluntary medication. A Supervisory Review

of the incident determined that “Wiseman had not been taking his

medications regularly, and this could have triggered his violent

outbursts.”

40. For another example, in January 1998, Bryant was found

fighting in his cell and was restrained by correctional staff. For

days prior to the incident, he had been non-compliant with his

psychotropic medication. On January 21, 1998, medical staff at the

DEPARTMENT ordered that Bryant be forcibly medicated due to his

“history of assaultive behavior when not on medication.”

41. For another example, in October 1999, just weeks before

his death, Bryant again refused to take his anti-psychotic

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medications and he became gravely disabled and acutely agitated as

a result. Bryant’s treating psychiatrist at the time, DR. REGINALD

HOFFLER, confined Bryant to his cell and noted that Bryant has a

history of “extreme agitation” and that he is a “danger to self or

others when in psychotic state.”

42. Notwithstanding Bryant’s profound and well-documented

need for anti-psychotic medication, his well-documented potential

for rapid decompensation, paranoia and aggression in the absence of

such medication, and the fact that any such aggressive behavior

would lead inevitably to Bryant being forcibly subdued and

restrained by one or more correctional officers and other custodial

staff, incredibly, on November 1, 1999, just days before Bryant’s

death, defendant DR. HOFFLER ordered that Bryant’s anti-psychotic

medication be “discontinue[d] if [patient] remains noncompliant.”

43. Following DR. HOFFLER’s astounding order, Bryant, as he

had on numerous prior occasions, became non-compliant with his

anti-psychotic medication, and he refused to take the required

dosages numerous times between November 1 and November 15.

Pursuant to DR. HOFFLER’s order, Bryant’s anti-psychotic medication

was then discontinued on November 15, 1999.

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44. There was no valid medical reason for discontinuing

Bryant’s anti-psychotic medication; DR. HOFFLER’s order was a grave

and unforgivable breach of the standard of care.

45. As a result of the discontinuance of his medication, and

as a result of the failure of his doctors, nurses and other medical

workers to properly monitor and evaluate his condition, Bryant

rapidly decompensated and became aggressive. His propensity for

rapid decompensation and immediate aggression was well-documented

in the clinical record, and it should have been anticipated and

prevented by Bryant’s doctors and nurses.

46. On November 15, 1999, one of Bryant’s medical workers

noted that he “has been refusing to take medication and has been

aggressive.” She further noted that Bryant “will be evaluated by

psychiatrist and will possibly be paneled for involuntary

medication.”

47. On November 16, 1999, DR. HOFFLER examined Bryant and

wrote in the clinical record that Bryant had been exhibiting

“bizarre behavior” for the past two days and was “possibly

decompensating.”

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48. HOFFLER ordered the nurse to “refer inmate to

psychiatrist tomorrow a.m.,” but, incredibly, HOFFLER and the other

medical workers responsible for Bryant’s care failed and refused to

schedule an immediate psychiatric consultation for Bryant, and they

failed to do anything to ensure that Bryant was promptly given

anti-psychotic medication, either voluntarily or involuntarily.

49. In the morning of November 17, 1999, Bryant continued to

show signs of psychosis and paranoia, and at approximately 9:40

a.m., Correctional Officer James Santopietro told the DEPARTMENT’s

mental health staff that Bryant was “acting bizarre.” However,

notwithstanding all of the evidence to the contrary, including the

specific written medical evaluations described above, mental health

staff responded that Bryant “was fine.”

50. As could and should have been expected, several hours

later on November 17, 1999, two days after DR. HOFFLER inexplicably

and unforgivably discontinued Bryant’s anti-psychotic medication,

Bryant followed the same pattern of rapid decompensation, paranoia

and aggression that he had followed numerous times in the past, he

got into an altercation with a fellow inmate, and he was forcibly

restrained and subdued by correctional staff.

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51. This time, however, due to a profound lack of training

in how to properly manage mentally ill inmates, and due to the

officers’ violent, unrestrained and excessive use of force against

Bryant, something went terribly wrong.

52. At approximately 12:45 p.m., in Cell 520 on the Inpatient

Medical (IPM) Unit of the GARNER CORRECTIONAL INSTITUTION, more

than eight correctional officers and other custodial staff (the

WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS): forced Bryant into a

face-down “hog tie” position with his feet up on the bed, his torso

down on the floor, and his hands shackled behind his back; placed

his legs in leg irons; brutally and repeatedly beat him on the

backs of his legs, his stomach, his shins and other parts of his

body; attacked and used extreme and excessive force against him;

utterly compromised his respiratory system and asphyxiated him;

caused him to vomit and to bleed from his mouth; rendered him

unconscious and comatose; and ultimately killed him.

53. Specifically, in the course of subduing and restraining

Bryant, the defendants perpetrated the following acts, among other

things:

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a. defendant Correctional Officer MICHAEL A. PACE forcibly

pressed Bryant’s head and shoulders against the cell

floor;

b. defendant Lt. KEVIN D. COWSER held Bryant’s upper torso

and left arm, applied handcuffs to Bryant’s wrists, and

forcibly pinned Bryant’s upper torso to the floor by

pressing his knee on Bryant’s shoulder;

c. defendant Correctional Officer JAMES E. REILLY held

Bryant’s right arm and wrist while Lt. COWSER applied

hand cuffs, and he held Bryant’s upper body to the cell

floor by pressing on Bryant’s arms and by pressing his

knee on Bryant’s back;

d. defendant correctional counselor DONALD J. HEBERT, who

was acting CTO for the IPM Unit, savagely and

repeatedly beat Bryant with hammer-type strikes to his

body while the other defendants held Bryant down;

e. defendant Lt. ROBERT G. STACK held Bryant’s right leg

and applied leg irons to both legs;

f. defendant Correctional Officer JOSE ZAYAS grabbed

Bryant’s legs by the ankles, held his left foot, and,

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after the leg irons were applied, continued to hold on

to the leg iron chain;

g. defendant Correctional Officer KEVIN J. DANDOLINI

grabbed Bryant’s right leg and ankle, and beat Bryant’s

left leg with a closed fist; and

h. defendant Correctional Officer ANGELO P. GIZZI knelt on

the back of Bryant’s legs and held Bryant’s ankles.

54. Defendants Captain EDWIN MYERS, Correctional Officer

WILLIAM SMITH, Correctional Officer VAUGHN WILLIS, Correctional

Treatment Officer BRIAN C. BRADWAY and Correctional Training

Officer FRANK MIRTO also participated in, witnessed, and failed and

refused to stop the assault on Bryant.

55. After savagely beating Bryant, and after placing him in

hand cuffs and leg irons, the defendants continued for several

minutes to hold him in the face-down hog tie position, with his

feet up on the bed and his face pressed against the floor and with

the weight of several correctional officers on him, while they

waited for cutting shears to cut Bryant’s clothes from his body so

that they could perform a strip search.

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56. At this point, Bryant began to vomit, and the defendants

realized that he was unconscious and comatose and had stopped

breathing.

57. Following the officer’s attack, after Bryant had been

rendered unconscious and comatose, and after he had vomited and

stopped breathing, the officers finally called medical staff for

assistance.

58. Defendants Correctional Hospital Nurse Supervisor ROBERTA

C. LEDDY, Correctional Hospital Nurse IRIS R. PRESCOTT, Nurse CLO

BARSOTTI, Correctional Hospital Nurse GINGER BOCHICCHIO, Nurse GAIL

N. FREDETTE, and Dr. MINGZER TUNG responded to the call; however,

these defendants rendered profoundly substandard medical care to

Bryant.

59. These defendants failed to obtain and to use adequate and

properly functioning medical equipment, they failed to properly

check Bryant’s vital signs, and they failed to provide proper,

standard and required CPR and other emergency medical treatment and

care.

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60. At this time, Bryant had a weak radial pulse and was

unresponsive to stimuli, vomitus had clogged his airway, his pupils

were dilated, and he had no pulse and no respiration.

61. At approximately 1:16 p.m., Bryant was transported by

ambulance to the emergency department at Danbury Hospital, where he

was pronounced dead at 2:01 p.m.

62. Defendant WILLIAM SMITH recorded on videotape some of the

events, acts and omissions alleged in the preceding paragraphs.

That portion of the videotape that has been produced to plaintiff’s

counsel by the CONNECTICUT DEPARTMENT OF CORRECTION is Exhibit A to

this Complaint, and the events, acts, omissions and admissions

recorded on that tape are incorporated into this Complaint as if

fully alleged herein.

63. Following Bryant’s death, officials of the DEPARTMENT OF

CORRECTION, including defendants ARMSTRONG and TOKARZ, determined

that all of the defendants’ conduct was perfectly proper and fully

consistent with the DEPARTMENT’s policies and procedures concerning

the restraint of mentally ill and aggressive inmates.

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64. Not one of the defendants was ever punished or

disciplined for his or her responsibility for Bryant’s injuries and

death.

65. Seven months before Bryant’s death, on April 12, 1999,

Timothy Perry, another young mentally ill man, was similarly

brutally killed while in the custody of the CONNECTICUT DEPARTMENT

OF CORRECTION.

66. Like Bryant Wiseman, Mr. Perry had a history of mental

illness and psychiatric disorders, including schizophrenia.

67. Like Bryant Wiseman and many other seriously mentally ill

persons, Mr. Perry’s illness caused him to engage in impulsive and

aggressive behavior.

68. On April 12, 1999 at the Hartford Correctional Center,

Timothy succumbed to his mental illness, and became severely

agitated and anxious.

69. At approximately 7:45 p.m., while defendants Nurse STOREY

and Correctional Officer POWELL stood by and watched, defendant

Correctional Officer HOWES pushed Timothy backwards, and defendant

Correctional Officers SANELLI, GUERRERO and CAMP descended upon

Timothy and restrained him with the use of force.

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70. At approximately 8:00 p.m., defendant POWELL initiated a

“code orange,” seeking assistance from other correctional officers.

Defendant Correctional Officer BRODEUR responded to the “code

orange,” and he handcuffed Timothy behind his back.

71. Defendants Correctional Officer PADILLA and Lieutenant

CHOUINARD also responded to the “code orange” and, along with and

assisted by other PERRY CORRECTIONAL EMPLOYEE DEFENDANTS, began

restraining, subduing and using excessive force against Timothy,

even after Timothy was face down on the floor and was handcuffed

behind his back.

72. The CORRECTIONAL OFFICER DEFENDANTS carried Timothy face

down to South Block Cell 10, put him face down on the mattress,

shackled him with leg irons, continued to use excessive force

against him, and, like Bryant Wiseman, asphyxiated him.

73. The take-down and restraint procedures utilized, and the

use of force perpetrated, by the PERRY CORRECTIONAL EMPLOYEE

DEFENDANTS were essentially identical to the take-down and

restraint procedures and the use of force utilized and perpetrated

by the WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS seven months later.

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74. At or about the time that the PERRY CORRECTIONAL EMPLOYEE

DEFENDANTS carried Timothy to Cell 10 and/or held Timothy in Cell

10, defendant Nurse STOREY spoke to a DEPARTMENT OF CORRECTION

staff psychiatrist who ordered that Timothy be tied down by his

hands and feet.

75. The defendants carried Timothy face down and handcuffed

from Cell 10 to Cell 24, a 4-point restraint cell.

76. The Defendants’ use of excessive force against Timothy

rendered Timothy unconscious, comatose, dying or dead at or near

the time that he was in Cell 10 and at and after the time that the

Defendants moved him to Cell 24.

77. In Cell 24, the Defendants put Timothy face down on the

bed, and removed his handcuffs, leg irons and clothes.

78. Defendant Lieutenant CHOUINARD was the scene supervisor

for the “code orange” and was responsible for supervising the other

PERRY CORRECTIONAL EMPLOYEE DEFENDANTS throughout the entire

incident.

79. Defendant Lieutenant WILLIAM SCOTT assisted in

restraining Timothy and in the use of excessive force against him.

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Defendant SCOTT also observed the other Defendants’ excessive force

against Timothy, and he did nothing to stop it.

80. In Cell 24, despite the fact that Timothy did not move or

resist in any way, and despite the fact that he was obviously

unconscious, comatose, dying or dead, the PERRY CORRECTIONAL

EMPLOYEE DEFENDANTS continued to restrain him, and to use excessive

force against him.

81. The PERRY CORRECTIONAL EMPLOYEE DEFENDANTS then turned

Timothy onto his back, they cut and tore off the rest of his

clothing, and they tied him down by his wrists and ankles.

82. At approximately 8:30 p.m., the PERRY CORRECTIONAL

EMPLOYEE DEFENDANTS left Timothy strapped down and alone in the 4-

point restraint cell.

83. Defendant POWELL recorded on videotape some of the

events, acts and omissions alleged in the preceding paragraphs.

That portion of the videotape that was previously produced by the

CONNECTICUT DEPARTMENT OF CORRECTION is Exhibit B to this

Complaint, and the events, acts, omissions and admissions recorded

on that tape are incorporated into this Complaint as if fully

alleged herein.

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84. At approximately 10:30 p.m. on April 12, about two hours

after the PERRY CORRECTIONAL EMPLOYEE DEFENDANTS left Timothy

strapped down and alone in the 4-point restraint cell, another

member of the HARTFORD CORRECTIONAL CENTER medical staff, Nurse

Yvonne Smith, noticed through the cell window that Timothy’s feet

were discolored and that he was in the exact same position that he

had been in two hours earlier.

85. Nurse Smith had Timothy’s cell door opened, and she

discovered that Timothy had no pulse, that he was cold, stiff and

not breathing, and that he had been dead for some time.

86. Timothy’s body was transported by ambulance to Hartford

Hospital, where he was officially pronounced dead.

87. Following the death of Timothy Perry, not one of the

PERRY CORRECTIONAL EMPLOYEE DEFENDANTS was appropriately punished

or disciplined. Four months later, defendant STOREY was actually

offered a promotion.

88. Following Timothy Perry’s death, his estate sued

defendant Commissioner ARMSTRONG, THE DEPARTMENT OF CORRECTION, THE

PERRY CORRECTIONAL EMPLOYEE DEFENDANTS and others responsible for

26

his death. The defendants agreed to settle that lawsuit by paying

to Mr. Perry’s estate $2.9 million.

89. Notwithstanding the settlement of the case, and

notwithstanding all of the evidence showing that the PERRY

CORRECTIONAL EMPLOYEE DEFENDANTS were responsible for killing

Timothy Perry, nearly all of those defendants continue to be

employed by the DEPARTMENT OF CORRECTION and continue to hold

positions of substantial authority in the DEPARTMENT.

90. Following Timothy Perry’s death, throughout the course of

(a) an internal investigation conducted by the DEPARTMENT OF

CORRECTION, (b) an investigation conducted by the Connecticut State

Police, and (c) the subsequent lawsuit brought by Mr. Perry’s

estate, not one of the PERRY CORRECTIONAL EMPLOYEE DEFENDANTS told

the truth about how Mr. Perry was killed; rather, they hid the

truth and deliberately lied in order to avoid blame and punishment

for his death.

91. Following Timothy Perry’s death, not one of the PERRY

CORRECTIONAL EMPLOYEE DEFENDANTS told the truth or notified

DEPARTMENT officials about their profound lack of skill,

experience, training and supervision in the handling of mentally

27

ill and aggressive inmates and in the use of force against, and the

restraint of, such inmates.

92. Following Timothy Perry’s death, not one of the PERRY

CORRECTIONAL EMPLOYEE DEFENDANTS told the truth or notified

DEPARTMENT officials about the urgent need for Department-wide

training for all custodial staff in the proper handling of mentally

ill and aggressive inmates and in the use of force against such

inmates.

93. At no point following Mr. Perry’s death did defendant

Commissioner ARMSTRONG, defendant Deputy Commissioner TOKARZ, or

any other DEPARTMENT official institute meaningful, adequate and

effective Department-wide training for custodial staff in the

proper handling of mentally ill and aggressive inmates and in the

use of force against such inmates, even though, following Mr.

Perry’s death, it was known to them, and should have been known to

them, that such training was urgently required.

94. The above failures of the PERRY CORRECTIONAL EMPLOYEE

DEFENDANTS, and of defendants ARMSTRONG and TOKARZ, directly and

proximately caused the death of Bryant Wiseman.

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95. The individually named defendants in this Complaint each

acted with reckless or callous indifference to Bryant Wiseman’s

dignity as a human being and to his constitutional and statutory

rights.

96. As a direct and proximate result of the acts and

omissions of the defendants, Bryant Wiseman suffered extreme

distress, anguish, pain and death.

FIRST COUNT

(Deliberate Indifference -- Failure to Provide Constitutionally Adequate Medical Care -- against defendants DR. WILLIAM JOUGHIN, DR. REGINALD HOFFLER, OSCAR MALDONADO, IRIS PRESCOTT, ROBERTA C. LEDDY, CLO BARSOTTI, GINGER BOCHICCHIO, GAIL N. FREDETTE, DR.

MINGZER TUNG, and the WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS in their individual capacities, pursuant to 42 U.S.C § 1983)

1. Plaintiff realleges and incorporates by reference each and

every allegation in Paragraphs 1 through 96.

2. By failing to provide Bryant Wiseman with

constitutionally adequate medical care, and by failing to summon

such care, the defendants knowingly disregarded an excessive risk

to Bryant’s health and safety and knowingly subjected him to pain,

physical and mental injury, and death, thereby violating Bryant’s

29

rights under the Fourth, Eighth and Fourteenth Amendments to the

United States Constitution.

SECOND COUNT

(Deliberate Indifference -- Failure to Provide Constitutionally Adequate Medical Care -- Supervisory Liability, against defendants ARMSTRONG and TOKARZ in their individual capacities, pursuant to 42

U.S.C. § 1983)

1. Plaintiff realleges and incorporates by reference each

and every allegation in Paragraphs 1 through 96.

2. The defendants were personally involved in and

responsible for the deliberate indifference to Bryant Wiseman’s

serious medical needs in that:

a. They created a policy and custom, and they allowed the

continuance of a policy and custom, under which

inmates would be deprived of adequate medical care;

and

b. They were deliberately indifferent in supervising and

training subordinates who committed the wrongful acts

described herein.

3. The acts and omissions of the defendants proximately

caused Bryant Wiseman’s suffering, injuries and death.

30

4. By failing to provide Bryant Wiseman with

constitutionally adequate medical care, the defendants knowingly

disregarded an excessive risk to Bryant’s health and safety and

knowingly subjected him to pain, physical and mental injury, and

death, thereby violating Bryant’s rights under the Fourth, Eighth

and Fourteenth Amendments to the United States Constitutions.

THIRD COUNT

(Deliberate Indifference to Safety -- Failure to Protect --against the WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS in their individual

capacities, pursuant to 42. U.S.C. § 1983)



2. Each of the WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS knew

that the other WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS, and each

of them, were using excessive force against Bryant and/or were

failing to summon or provide obvious and urgently needed medical

attention for him.

3. Each defendant could have taken action to stop the use of

excessive force, to summon or provide medical care, and to prevent

injury and death to Bryant, but refused and failed to do so.

31

4. Each defendant failed to protect Bryant from the use of

excessive force and the deliberate failure to provide medical care

in violation of the Fourth, Eighth and Fourteenth Amendments to the

United States Constitution.

FOURTH COUNT

(Deliberate Indifference to Safety -- Failure to Protect -- against the PERRY CORRECTIONAL EMPLOYEE DEFENDANTS in their

individual capacities, pursuant to 42. U.S.C. § 1983)



2. At no point after Timothy Perry’s death on April 12,

1999, and up until Bryant Wiseman’s death seven months later, did

any of the PERRY CORRECTIONAL EMPLOYEE DEFENDANTS tell the full

truth about how Timothy Perry was killed.

3. In fact, in multiple sworn statements made by the PERRY

CORRECTIONAL EMPLOYEE DEFENDANTS following Mr. Perry’s death, the

defendants lied to investigators about their acts, omissions and

responsibility, about their failure to properly restrain Mr. Perry,

about their failure to summon urgently needed medical care for him

and about other relevant facts.

32

4. By their intentional failure and refusal to honestly

report the facts concerning their responsibility for Mr. Perry’s

death, the PERRY CORRECTIONAL EMPLOYEE DEFENDANTS hid information

from DEPARTMENT OF CORRECTIONS officials and profoundly hindered

and interfered with those officials’ ability to prevent similar

injuries and deaths in the future, including the death of Bryant

Wiseman.

5. For example, the PERRY CORRECTIONAL EMPLOYEE DEFENDANTS

intentionally failed and refused to put DEPARTMENT officials on

notice of serious deficiencies in the DEPARTMENTS’ training of

correctional officers to deal with mentally ill inmates and to

safely restrain inmates.

6. Each of the PERRY CORRECTIONAL EMPLOYEE DEFENDANTS knew:

(a) that other correctional officers and medical workers in the

DEPARTMENT OF CORRECTION had been improperly and inadequately

trained to safely and properly restrain inmates, especially

mentally ill inmates; (b) that other mentally ill inmates, such as

Bryant Wiseman, were in the custody of the DEPARTMENT; (c) that

correctional employees are frequently called upon to deal with and

restrain mentally ill inmates in situations that require safe and

33

proper techniques and that pose a risk of harm to the inmates; and

(d) that the lack of training would inevitably lead to the injury

and death of other inmates and mentally ill inmates such as Bryant

Wiseman.

7. The defendants’ failure and refusal to tell the truth

about their responsibility for Mr. Perry’s death, and to otherwise

put DEPARTMENT officials on notice of the urgent need to provide

proper and adequate training to correctional employees concerning

how to safely restrain inmates and how to otherwise safely and

properly deal with mentally ill inmates, proximately caused Bryant

Wiseman’s injuries and death and violated his Fourth, Eighth and

Fourteenth Amendments rights under the United States Constitution.

FIFTH COUNT

(Deliberate Indifference to Safety -- Failure to Protect -- Supervisory Liability, against defendants ARMSTRONG and TOKARZ in

their individual capacities, pursuant to 42 U.S.C. §1983)



2. Following Timothy Perry’s death, and at other times

before Bryant Wiseman was killed, defendants ARMSTRONG and TOKARZ

34

were on actual and constructive notice that inmates, especially

mentally ill inmates such as Bryant Wiseman, were at a profound

risk of harm and death at the hands of correctional employees who

were inadequately and improperly trained to manage, supervise and

restrain such inmates.

3. Defendants ARMSTRONG and TOKARZ were personally involved

in and responsible for the failure to protect Bryant Wiseman in

that:



correctional officers and other persons employed at

the DEPARTMENT OF CORRECTION are allowed, permitted

and/or encouraged to look the other way and to remain

silent when excessive force is used against inmates in

the correctional system;

b. They created a policy and custom, and they allowed the


correctional officers and other persons employed at

the DEPARTMENT OF CORRECTION are allowed, permitted

and/or encouraged to look the other way and to remain

35

silent when it becomes clear that employees have been

inadequately or improperly trained to deal with

mentally ill and other inmates and when the lack of

training increases the risk of harm to inmates in the

correctional system; and

c. They were deliberately indifferent in supervising and

training subordinates who committed the wrongful acts

described herein.



5. The defendants failed to protect Bryant in violation of

the Fourth, Eighth and Fourteenth Amendments to the United States

Constitution.

SIXTH COUNT

(Deliberate Indifference to Safety -- Failure to Train -- Supervisory Liability, against defendants ARMSTRONG and TOKARZ in

their individual capacities, pursuant to 42 U.S.C. § 1983)



36

2. Following the death of Timothy Perry, and at other times

before Bryant Wiseman’s death, defendants ARMSTRONG and TOKARZ had

actual and constructive knowledge of the facts that (a) DEPARTMENT

employees were improperly and inadequately trained to deal with

mentally ill inmates, (b) DEPARTMENT employees were improperly and

inadequately trained to safely and properly restrain mentally ill

and other inmates, and (c) that the failure to train had resulted

in death and injury to one or more inmates in the correctional

system, including Timothy Perry.

3. Following the death of Timothy Perry, and at other times

before the Bryant Wiseman’s death, defendants ARMSTRONG and TOKARZ

knew to a moral certainty that DEPARTMENT employees would confront

and continue to confront situations that called for the restraint

of mentally ill and other inmates and that posed a risk of harm to

the inmates if the employees failed to properly and safely conduct

the restraint.

4. Following the death of Timothy Perry, and notwithstanding

this knowledge, defendants ARMSTRONG and TOKARZ made no meaningful

changes to the DEPARTMENT’s training protocols concerning how to

properly deal with mentally ill inmates or how to effectuate a

37

proper and safe inmate restraint, and they ordered no meaningful

additional or different training for the DEPARTMENT’s correctional

officers, including the WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS,

concerning these matters.

5. The defendants failed to require meaningful additional or

different training in these matters even though, following Timothy

Perry’s death and at other times before Bryant Wiseman was killed,

the need for such training was so obvious that the inadequacy was

very likely to result in injury and death to other mentally ill

inmates, including Bryant Wiseman.


responsible for the failure to train in that:

a. They created a policy and custom, and they allowed

the continuance of a policy and custom, under which

correctional officers and other persons employed at the

DEPARTMENT OF CORRECTION are inadequately and improperly

trained to deal with mentally ill and other inmates and

to safely restrain inmates; and

38

b. They were deliberately indifferent in supervising

and training subordinates who committed the wrongful acts

described herein.



8. The defendants’ failure to protect Bryant Wiseman and

their failure to properly and adequately train correctional

employees, or to ensure such training, violated Bryant’s rights

under the Fourth, Eighth and Fourteenth Amendments to the United

States Constitution.

SEVENTH COUNT

(Excessive Force, against the WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS in their individual capacities, pursuant to 42 U.S.C. §

1983)



2. The force used by the defendants against Bryant Wiseman

on November 17, 1999 was unreasonable and excessive in violation of

Bryant’s rights under the Fourth, Eighth and Fourteenth Amendments

to the United States Constitution.

39

EIGHTH COUNT

(Excessive Force, Supervisory Liability, against defendants ARMSTRONG and TOKARZ in their individual capacities, pursuant to

42. U.S.C. § 1983)




responsible for the excessive force used against Bryant Wiseman in

that:



correctional officers and other employees of the

DEPARTMENT OF CORRECTION are allowed, permitted and/or

encouraged to use excessive force against inmates; and

b. They were deliberately indifferent in supervising and

training subordinates who participated in the use of

excessive force against Bryant Wiseman.



4. By their acts and failures to act, the defendants

subjected Bryant Wiseman to pain, physical and mental injury, and

40

death in violation of his rights under the Fourth, Eighth and

Fourteenth Amendments to the United States Constitution.

NINTH COUNT

(Violation of Conn. Gen. Stat. § 17a-542 -- failure to provide humane and dignified treatment -- against THE CONNECTICUT

DEPARTMENT OF CORRECTION, THE UNIVERSITY OF CONNECTICUT HEALTH CENTER, THE GARNER CORRECTIONAL INSTITUTION, defendants ARMSTRONG and TOKARZ, defendants JOUGHIN, HOFFLER, and

MALDONADO, and the WISEMAN CORRECTIONAL EMPLOYEE DEFENDANTS, in their individual and official capacities)



2. At all times mentioned herein, Bryant Wiseman was a

“Patient” within the meaning of Conn. Gen. Stat. § 17a-540(b).

3. The facilities of the CONNECTICUT DEPARTMENT OF

CORRECTION, including the GARNER CORRECTIONAL INSTITUTION, and the

UNIVERSITY OF CONNECTICUT HEALTH CENTER, are “Facilities” within

the meaning of Conn. Gen. Stat. § 17a-540(a).

4. During the period that Bryant Wiseman was incarcerated at

the DEPARTMENT OF CORRECTION, the defendants failed to provide

humane and dignified treatment to him, in violation of Conn. Gen.

Stat. § 17a-542.

41

5. As a direct and proximate consequence of the Defendants’

acts and omissions, Bryant Wiseman’s mental illness was improperly

and inadequately treated, he was deprived of the ability to live a

productive life, he suffered extreme fear, agitation, pain and

anguish, and he was killed.

6. This Count is brought pursuant to Conn. Gen. Stat. § 17a-

550.

TENTH COUNT

(Violation of Conn. Gen. Stat. § 17a-542 -- failure to provide a specialized treatment plan -- against THE CONNECTICUT DEPARTMENT OF CORRECTION, THE UNIVERSITY OF CONNECTICUT HEALTH CENTER, THE GARNER

CORRECTIONAL INSTITUTION, defendants ARMSTRONG and TOKARZ, and defendants JOUGHIN, HOFFLER, and MALDONADO, in their individual and

official capacities)









42


the DEPARTMENT OF CORRECTION, the defendants failed to treat and

monitor him in accordance with a specialized treatment plan suited

to his disorders and to his psychiatric circumstances, including

treatment for his schizophrenia and his related impulsive and

aggressive behavior, in violation of Conn. Gen. Stat. § 17a-542.

5. As a direct and proximate consequence of the defendants’

acts and omissions, Bryant Wiseman’s mental illness was improperly

and inadequately treated, he was deprived of the ability to live a

productive life, he suffered extreme fear, agitation, pain and

anguish, and he was killed.


550.

ELEVENTH COUNT

(Violation of Conn. Gen. Stat. § 17a-545 -- failure to conduct psychiatric examinations –- THE CONNECTICUT DEPARTMENT OF

CORRECTION, THE UNIVERSITY OF CONNECTICUT HEALTH CENTER, THE GARNER CORRECTIONAL INSTITUTION, defendants ARMSTRONG and TOKARZ, and

defendants JOUGHIN, HOFFLER, and MALDONADO, in their individual and official capacities)



43








the DEPARTMENT OF CORRECTION, the Defendants failed to conduct, or

to ensure Bryant’s receipt of, proper psychiatric examinations, in

violation of Conn. Gen. Stat. § 17a-545.

5. As a direct and proximate consequence of the Defendants’

acts and omissions, Bryant Wiseman’s mental illness was

inadequately and improperly treated, he was deprived of the ability

to live a productive life, he suffered extreme fear, agitation,

pain and anguish, and he was killed.


550.

44

TWELFTH COUNT

(Negligence/Medical Malpractice against the STATE OF CONNECTICUT)



2. During the time that Bryant Wiseman was incarcerated at

the CONNECTICUT DEPARTMENT OF CORRECTION, and until his death on

November 17, 1999, the STATE OF CONNECTICUT and its employees,

servants and agents, undertook his care, treatment, monitoring and

supervision.

3. While under the care of the STATE’s employees, servants

and agents, Bryant Wiseman suffered severe, serious, painful and

permanent injuries and death.

4. The injuries and death suffered by Bryant Wiseman were

caused by the failure of the STATE OF CONNECTICUT, and its

employees, servants and agents, to exercise reasonable care under

all of the circumstances then and there present, in that they:

a. failed to adequately and properly care for, treat,

monitor and supervise Bryant Wiseman;

45

b. failed to prescribe proper types and adequate

amounts of psychotropic and other medications to Bryant Wiseman;

c. failed to anticipate, plan for, and prevent Bryant’s

mental decompensation;

d. failed to properly check vital signs and failed to

provide proper, standard and required CPR and other emergency

medical care on November 17, 1999;

e. failed to ensure that the emergency medical

equipment available for use at the GARNER CORRECTIONAL INSTITUTION

on November 17, 1999 was adequate and in proper working order;

f. failed to provide physicians, nurses, counselors and

other medical and mental health workers with the required skill,

training and experience to care for Bryant Wiseman;

g. failed to provide adequate and proper monitoring,

supervision and training of the physicians, nurses, counselors and

other medical and mental health workers who had responsibility for

Bryant Wiseman at the DEPARTMENT OF CORRECTION; and

h. failed to have available physicians, nurses,

counselors and other medical and mental health workers who are

competent and knowledgeable in the care and treatment of mentally

46

ill persons and in the care and treatment of persons suffering

emergency medical complications such as those suffered by Bryant

Wiseman on November 17, 1999.

5. As a result of the carelessness and negligence of the

defendant, STATE OF CONNECTICUT, and its employees, servants and

agents, Bryant Wiseman suffered the following severe, serious,

painful and permanent injuries:

a. His mental illness, including schizophrenia, went

untreated and improperly treated, and was allowed to become more

severe and debilitating;

b. He was repeatedly subjected to extreme emotional and

psychological distress;

c. He was repeatedly allowed to mentally decompensate

and to suffer all of the complications associated with his

decompensation, including uncontrollable paranoia, fear, stress,

and anxiety;

d. He was repeatedly allowed to become assaultive, and

to engage in behavior that could and did lead to his physical

injury at the hands of other inmates and DEPARTMENT OF CORRECTION

staff; and

47

e. He died.

6. As a result of all of these injuries and his death,

Bryant Wiseman has been permanently deprived of his ability to

carry on and enjoy life’s activities and his earning power has been

permanently erased.

7. On August 29, 2002, the Connecticut Claims Commissioner

granted plaintiff ELAINE WISEMAN and the ESTATE OF BRYANT WISEMAN

permission to sue the State of Connecticut for medical malpractice.

A copy of the Commissioner’s August 29, 2002 Finding and Order, and

a copy of the claimants’ Certificate of Good Faith, submitted

pursuant to Conn. Gen. Stat. § 52-190a, are attached hereto.

48

PRAYER FOR RELIEF

WHEREFORE, Plaintiff ELAINE WISEMAN, ADMINISTRATOR OF THE

ESTATE OF BRYANT WISEMAN, prays for relief as follows:

1. For compensatory damages according to proof;

2. For punitive damages;

3. For costs and reasonable attorneys fees; and

4. For such further relief as the Court deems just and

proper.

Dated: November 15, 2002

THE PLAINTIFF

By___________________________ Antonio Ponvert III, Esq. Koskoff, Koskoff & Bieder, P.C. 350 Fairfield Avenue, 5th Floor Bridgeport, CT 06604 Tele: (203) 336-4421

Juris No. 32250

49

RETURN DATE: 12/17/02 ) SUPERIOR COURT ) ELAINE WISEMAN, ADMINISTRATOR ) OF THE ESTATE OF BRYANT ) WISEMAN, ) PLAINTIFF, ) ) vs. ) ) JOHN J. ARMSTRONG; JACK TOKARZ; ) DR. WILLIAM JOUGHIN; DR. REGINALD ) JUDICIAL DISTRICT OF HOFFLER; OSCAR MALDONADO; MICHAEL ) A. PACE; KEVIN COWSER; JAMES E. ) REILLY; DONALD J. HEBERT; ROBERT ) G. STACK; JOSE ZAYAS; KEVIN J. ) DANDOLINI; ANGELO P. GIZZI; EDWIN ) MYERS; WILLIAM SMITH; VAUGHN ) WILLIS; BRIAN C. BRADWAY; FRANK ) MIRTO, in their individual and ) HARTFORD AT HARTFORD official capacities; and ) IRIS PRESCOTT; ANDRE CHOUINARD; ) WILLIAM SCOTT; STEVEN SANELLI; ) JIMMY GUERRERO; JEFFREY HOWES; ) MAURELLIS POWELL; DENNIS CAMP; ) RAYMOND BRODEUR; MOISES PADILLA; ) ANNE MARIE STOREY; ROBERTA C. ) LEDDY; CLO BARSOTTI; GINGER ) BOCHICCHIO; GAIL N. FREDETTE; DR. ) MINGZER TUNG, in their individual ) capacities; and CONNECTICUT ) DEPARTMENT OF CORRECTION; STATE OF ) CONNECTICUT; UNIVERSITY OF ) CONNECTICUT HEALTH CENTER; GARNER ) CORRECTIONAL INSTITUTION, ) ) DEFENDANTS. ) NOVEMBER 15, 2002

50

AD DAMNUM

This matter is within the jurisdiction of the Court. The

Plaintiff demands money damages in excess of FIFTEEN THOUSAND and

00/100 DOLLARS ($15,000.00) excluding attorneys fees, interest and

costs.

THE PLAINTIFF

By___________________________ Antonio Ponvert III, Esq. Koskoff, Koskoff & Bieder, P.C. 350 Fairfield Avenue, 5th Floor Bridgeport, CT 06604 Tele: (203) 336-4421

Juris No. 32250

Documents

RETURN DATE: 12/17/02 ) SUPERIOR COURT ELAINE … · GINGER BOCHICCHIO, GAIL N. FREDETTE and DR. MINGZER TUNG were medical workers assigned on November 17, 1999 to the GARNER CORRECTIONAL