Elden M. Rosenthal, OSB No. 72217


John T. Devlin, OSB No. 042690


 

 

Rosentlial Greene Devlin, PC.
121 SW Salmon St., Suite 1090
Portland, OR 97204

Telephone: (503) 228-3015
Fasciinile: (503) 228?3269

Of Attorneys for Plaintiff

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
EUGENE DIVISION

DEREK JOHNSON, personal representative
of KELLY CONRAD GREEN II, deceased;
KELLY CONRAD GREEN and SANDY
PULVER

Plaintiffs,
v.

CORIZON HEALTH, INC., a Tennessee
Corporation; LANE COUNTY, an Oregon
county; DR. CARL KELDIE, an individual;
DR. JUSTIN MONTOYA, an individual;
VICKI THOMAS, an individual; KIRSTIN
WHITE, an individual;; SHARON
EPPERSON (nee FAGAN), an individual, and
JACOB PLEICH, an individual,

Defendants.

 

 

Civil Action No. 

DECLARATION OF CHARLES
PUGH, M.D., IN SUPPORT OF
PLAINTIFF 8? MEMORANDUM
IN OPPOSITION TO MOTION
FOR SUMMARY JUDGMENT
CORIZON

1, Charles Pugh, M.D., declare under penalty of perjury as follows:

1. I am a licensed physician, and served as the Corizon Site Medical Director in 2013
and 2014 at the Chatham County Jail in Savannah, Georgia.

Page 1 - DECLARATION OF CHARLES PUGH, M.D., IN SUPPORT OF 
MEMORANDUM IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT BY

DEFENDANTS CORIZON TAL.

 

2. As the Corizon Site Medical Director I was required by Corizon to submit all
physician consults and emergency room transfer requests to the Regional Medical
Director. During my tenure as Site Medical Director, 1 was constantly under
pressure from my superiors in Corizon to minimize emergency room treatments
and outside physician consults for jail inmates in order to save money.

3. Once or twice a week there were telephone conferences I was expected to attend
with the Corizon Regional Medical Director regarding who was in the hospital and
what was going on with patients in the hospital. There was a constant demand to
monitor all hospitalizations, to avoid hospitalizations, to request prompt hospital
discharges, and to minimize hospital stays.

4. In my experience working for Corizon, the company?s constant efforts to reduce
costs interfered with my ability, and with the staff?s ability, to provide appropriate
levels of care to inmates of the Chatham County Jail.

I hereby declare under penalty of perjury that the foregoing is true and correct.

EXECUTED ON this  day of 



Charles Pg, -

2015.

 

 

  
     

 

Page 2 DECLARATION OF CHARLES PUGH, M.D., IN SUPPORT OF 
MEMORANDUM IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT BY
DEFENDANTS CORIZON ET AL.