IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION MELVIN ROBINSON, Plaintiff, vs. CIVIL ACTION FILE CORRECTIONAL MEDICAL ASSOCIATES, INC.; CECELIA O. BABALOLA, M.U.7 VALERLE BOLTON, LPN; CARLA SPELLS, LPN; MYRON FREEMAN; OLIVIA MGBEOKWERE, RN, NO. 1:09-CVv-01509 Defendants. DEPOSITION OF VALERIE VERNA BOLTON Saturday, March 27, 2010 11:20 a.m, 1180 West Peachtree Street Atlanta, Georgia Abigail M. Pace, RPR, B-1484 1-888-947-2963 JPA Reporting, LLC 404-853-1811APPEARANCES OF COUNSEL On behalf of the Plaintiff: DANIEL E, DEWOSKIN, Esq. DeWoskin Law Firm 14 Lenox Pointe, NE atlanta, Georgia 30324 404-869-3565 On behalf of the Defendants Correctional Medical Assuciales, Inc.; Cecelia 0. Babalula, M.D.; Valerie Bolton, LPN; Carla Spells, LPN; and Olivia Mgbeokwere, RN: KEVIN A, LEIPOW, Esq. Hall Booth Smith & Slover, P.C. 900, Atlantic Center Plaza 1180 West Peachtree Street, NW Atlanta, Georgia 30309-3479 404-954-5000 On behalf of the Defendant Myron Freeman: NIKISHA L. MCDONALD, Esq. Office of Fulton County Attorney 141 Pryor Street, SW Suite 4038 Atlanta, Georgia 30303 404-612-0246 1-888-947-2963 JPA Reporting, LLC 404-853-1811EXHIBIT INDEX Plaintiff's Exhibit Description Page 1 Comprehensive Medical Associates orientation schedule 15 2 Fulton County Jail physician's orders 27 3 Fulton County Jail medical intake receiving screening form 30 4 CMA diabetic management record 40 5 Medication administration record 57 6 Fulton County Jail Chronic Care Clinic enrollment form 59 7 Urgent Care Clinic encounter dated 4/24/07 61 8 Urgent Care Clinic encounter dated 4/20/07 65 9 Affidavit of Valorie Uchegbu 68 10 Comprehensive Medical Associates Treatment of Diabetes Mellitus For Inmates at Fulton County Jail 80 41 Manual of Policies Procedures For Health Services Fulton County Jail 102 12 Amended compleint 107 13 Fulton County Jail physician's orders 176 (Original Exhibits 1 through 13 have been attached to the original transcript.) 1-888-947-2963 JPA Reporting, LLC 404-853-181110 an 12 13 14 15 16 WW 18. ag 20 a 22 23 24 25 42 order? A. From this order? Q. Yes. A. From this order. You asking me is this different than this? Yes. Q. So he received less insulin than he was supposed to get under the initial order? A. Under this written order, yes. Q. Are you aware of another written order that was in place at that time? A. Yes. Q. What other order? A. There was a policy that we had to follow on 3 South, which doctor -- the director wanted us to follow. Q. So the director wanted you to follow an order -- a policy that was different than the initial insulin order listed on tkis form? i Yes. Q. I'll go back to that. But you do concede that this -- you do agree that eight units is less than the insulin that would be indicated trom the sliding scale? A. Yes, Ido. Yes. Q. According to the initial insulin order in 1-888-947-2963 JPA Reporting, LLC 404-853-1811