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Case 1:06-cv-00678-SLR Document 20 Filed 12/13/2006 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RICHARD F. KLINE, JR.,
PLAINTIFF,
CIVIL ACTION NO. 06-678 SLR
CORRECTIONAL MEDICAL
SERVICES, WARDEN RAPHAEL
WILLIAMS and NURSING
TRIAL BY JURY DEMANDED
DEPARTMENT,
DEFENDANTS.
RESPONSE OF DEFENDANT, CORRECTIONAL MEDICAL SERVICES, INC., (CMS)
TO PLAINTIFF'S LETTER/MOTION POSTMARKED NOVEMBER 27, 2006
Defendant, CMS, by its undersigned attorneys, hereby responds to Plaintiff's letter/motion postmarked November 27, 2006 pursuant to the Court's December 6, 2006 Order as Moving Defendant, CMS, has not been served with the Complaint; therefore, the response of Moving Defendant, CMS, is by Order of Court and shall not be considered to be a waiver of any jurisdictional defects in service upon the Defendant, CMS. Moving Defendant, CMS, specifically reserve all rights to raise jurisdictional, service, or statute of limitations Plaintiff alleges in his letter/motion postmarked November 27, 2006 that he thinks "suicide will stop the pain". (D.I. 8) He also alleges in his November 3, 2006 Complaint that he has suicidal ideations. (D.I. 2). However, in his November 27, 2006 letter, he does not Case 1:06-cv-00678-SLR Document 20 Filed 12/13/2006 Page 2 of 5 Plaintiff was admitted to Herbert R. Young Correctional Institution on September 12, 2006. In his Intake Screening Report, he indicated that he had been hospitalized in 2000 at the Delaware County Prison for psychiatric problems, including trying to slit his wrists. He also indicated that he had been diagnosed with depression at Norristown State Hospital in 2000. He further commented that his father had committed suicide and his daughter had attempted suicide. In addition, an August 11, 2004 MRI disclosed an L5-S1 left paracentral disc herniation and bulges at L1-2, L2-3, L3-4 and L4-5. Please refer to medical records attached as Exhibit "1". "The grant of injunctive relief is an 'extraordinary remedy, which should be granted only in limited circumstances.'"1 The grant or denial of a motion for injunctive relief is within the sound discretion of the district judge.2 A plaintiff moving for injunctive relief must demonstrate: i) the likelihood of success on the merits; ii) the extent to which the plaintiff is being irreparably harmed by the conduct complained of; iii) the extent to which the defendant will suffer irreparable harm if the requested relief is granted; and iv) the public interest will not be adversely affected by the granting of relief.3 An injunction should only issue if all four factors favor relief. 4 On September 18, 2006, Plaintiff was admitted to the infirmary after being suspected of suffering a seizure. Please refer to medical records attached as Exhibit "2". On September 20, 2006 a Comprehensive Mental Health Evaluation was performed. On October 26, 2006, an Initial Psychiatric Evaluation was performed. Plaintiff admitted to abusing several substances including alcohol, cocaine, heroin, PCP and mushrooms 1 Instant Air Freight Co. v. C.F. Air Freight, Inc., 882 F.2d 797, 800 (3d Cir. 1989)(quoting Frank's GMC Truck Ctr., Inc. v. Gen'l Motors Corp., 847 F.2d 100, 102 (3d Cir. 1988)). 2 Eli Lilly & Co. v. Premo Pharmaceutical Laboratories, Inc. 630 F.2d 120, 136 (3d Cir. 1978). 3 Clean Ocean Action v. York, 57 F.3d 328, 331 (3d Cir. 1995). 4 See S & R Corp. v. Jiffy Lube Internat'l, Inc., 968 F.2d 371, 374 (3d Cir. 1992). Case 1:06-cv-00678-SLR Document 20 Filed 12/13/2006 Page 3 of 5 in the past. As a result of the psychiatric evaluation, he was prescribed Haldol5. Plaintiff had psychiatric consults on November 9, 2006 and December 8, 2006 at which time he was placed in Psychiatric Close Observation (PCO). Plaintiff was discharged from (PCO) on December 10, 2006. Please refer to Psychiatric records attached as Exhibit "3". Plaintiff has been prescribed phenobarbital from September 21, 2006 through January 7, 2007. He was prescribed Haldol from October 26, 2006 through January 26, 2007. However, when he began experiencing some side effects, Haldol was discharged on November 16, 2006. For pain relief, Plaintiff was prescribed the following medication: Motrin from September 22, 2006 through January 12, 2007; Tylenol from September 17, 2006 through October 17, 2006; Lortab from October 18, 2006 through November 18, 2006; Ultram from September 20, 2006 through October 13, 2006 and November 3, 2006 through November 13, 2006; and Soma from October 13, 2006 through January 13, 2007. Plaintiff was also prescribed two (2) tablets of Vicodin on October 15, 2006. On December 13, 2006, Plaintiff's medications were re-evaluated and doses and prescriptions were adjusted. Please refer to medical records Plaintiff has been seen by medical staff multiple times per week from September 18, 2006 through the present. In addition, on October 13, 2006, Plaintiff was treated at St. Francis Hospital where he was prescribed Skelaxin and provided 1 tablet of Oxycontin for pain relief for his lower back. On November 29, 2006, Plaintiff's walker was discharged and he was On November 4, 2006, Plaintiff was discharged from the infirmary to housing. On November 4, 2006, Plaintiff fell when he tried to go to the bathroom without using his walker. 5 Haldol is used to reduce mental disorders. Case 1:06-cv-00678-SLR Document 20 Filed 12/13/2006 Page 4 of 5 Plaintiff did not have any complaints of pain following the fall. He has since been re-admitted to As can be seen from the medical records, Plaintiff has received more than adequate care. He has not demonstrated a likelihood of success on the merits or that he would be irreparably harmed by the conduct complained of. Plaintiff's claim in his November 27, 2006 letter/motion are without merit and frivolous. While Plaintiff alleges he has suicidal thoughts, he has been receiving regular treatment for his pain and mental conditions. Plaintiff has been incarcerated at HRYCI for less than three (3) months and has been treated by mental health professionals, nurses, and doctors multiple times per week, including being placed on Psychiatric WHEREFORE, defendant, Correctional Medical Services, Inc., requests that this Honorable Court deny Plaintiff's Motion for Immediate Injunctive Relief. MARSHALL, DENNEHEY, WARNER,
COLEMAN AND GOGGIN
BY: ___/s/ Eric Scott Thompson, Esquire
KEVIN J. CONNORS, ESQUIRE (#2135)
ERIC SCOTT THOMPSON, ESQUIRE (#4633)
1220 N. Market Street, 5th Floor
Wilmington, DE 19801
Attorneys for Defendant,
Correctional Medical Services, Inc.
DATED: December 13, 2006 \15_A\LIAB\ESTHOMPSON\LLPG\396162\ESTHOMPSON\13252\15000 Case 1:06-cv-00678-SLR Document 20 Filed 12/13/2006 Page 5 of 5 CERTIFICATE OF SERVICE
I, Eric Scott Thompson, hereby certify that two (2) copies of the RESPONSE OF
DEFENDANT, CORRECTIONAL MEDICAL SERVICES, INC., (CMS) TO
PLAINTIFF'S LETTER/MOTION POSTMARKED NOVEMBER 27, 2006 have been
served by electronic and first class mail upon the following: Herbert R. Young Correctional Institution MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN

DATED: December 13, 2006 \15_A\LIAB\ESTHOMPSON\LLPG\396162\ESTHOMPSON\13252\15000 Case 1:06-cv-00678-SLR Document 20-3 Filed 12/13/2006 Page 1 of 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RICHARD F. KLINE, JR.,
PLAINTIFF,
CIVIL ACTION NO. 06-678 SLR
CORRECTIONAL MEDICAL
SERVICES, WARDEN RAPHAEL
WILLIAMS and NURSING
TRIAL BY JURY DEMANDED
DEPARTMENT,
DEFENDANTS.
AND NOW, this ______day of _________________, 2006, upon consideration of Plaintiff's
Motion for Immediate Injunctive Relief and the Response of Defendant, Correctional Medical Services, Inc. thereto, it is hereby ORDERED that Plaintiff's Motion for Immediate Injunctive Relief is DENIED. ___________________________________ THE HONORABLE SUE L. ROBINSON

\15_A\LIAB\ESTHOMPSON\LLPG\396180\ESTHOMPSON\13252\15000

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