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IN THE UNITED STATES DISTRICT COURT FOR THE NORTIIBRN DISTRICT OF GEORGIA ATLANTA DIVISION MELVIN ROBINSON, 1 Plaintiff 1 vs. | CIVIL ACTION FILE | No. 1:09-cv-01509 CORRECTIONAL MEDICAL \ ASSOCIATES, INC.; \ CECELIA 0. BABALOLA, M.D.,7 \ VALERIE BOLTON, LPN; \ CARTA SPRIIS, LPN: MYRON FREFMAN? | OLIVIA NGBEOKWERE, RN, \ Defendants \ DEPOSITION OF CARLA C. SPELLS Monday, March 29, 2010 11:02 a.m. 1180 West Peachtree Street Atlanta, Georgia Heather S. Cruz, RPR, CCR-2727 Page 2 APPEARANCES OF COUNSEL On behalf of the Plaintiff: DANIEL E, DEWOSKIN, ESQ DeWoskin Law Firm 14 Lenox Pointe, N.E. Atlanta, Georgia 30324 404-869-3565 On behalf of the Defendants; Correctional Medical Associates, Inc; Cecelia 0. Rahalola, MD? Valarie Raltan, TPN? Carla Spalle, TPN? and Olivia Mgbeokwere, RN: SHAUN M. DAUGHERTY, ESQ. Hall Booth Smith @ Slover P.c 900 Atlantic Center Plaza 1180 West Peachtree Street, N.W. Atlanta, Georgia 30309 404-954-5000 On behalf of the Defendant; Myron Freeman: STRVEN R. ROSENRERG, FSO Office of the County Attorney 141 Pryor Street, S.W. Suite 4038 Atlanta, Georgia 30303 404-612-0246 1-888-947-2963, JPA Reporting, LLC 404-853-1811 Page 3 TABLE OF CONTENTS Examination Page By Mr. DeWoskin 5 Exhibit Description Page 1 Comprehensive Medical Associates 14 Orientation Schedule 2 Fulton County Jail Medical Intake 16 Receiving Screening Form 3 Fulton County Jail Physician's Orders 20 Fulton County Jail Physician's Orders 22 5 Fulton County Jail Medical/Mental 25 Health Referral Request é Urgent Care Clinic Encounter 26 7 CMA Diabetic Management Record 33 8 Medication Administration Record 40 ° ALCidavil uf Cala Spells a2 10 Comprehensive Medical Associates 49 Treatment of Diabetes Mellitus For Inmates at Fulton County gail 1 Manual of Policies Procedures for 59 Health Services Fulton County Jail 12 Plaintiff's Statement of Undisputed 64 Facts in Support of Plaintiff's Motion for Summary Judgment (Original Exhibits 1 - 12 attached to original deposition transcript.) 1-888-947-2963 JPA Reporting, LLC 404-853-1811 10 ul 12 1B 14 15 16 17 18 19 20 21 a 23 4 25 Page 24 Q. From your understanding of CMA policies and protocols, were nurses to follow physician's orders accurately? A. Correct. Q. Were they allowed to make changes without another doctor writing an order to supercede it? A. Was nurses allowed to make changes? Yes. A. Unless another doctor I guess like you said supercedes something to make changes to the order, that is the only way a nurse can. Q. Otherwise it would not be acceptable -- A. No. for a nurse to change those orders? Were you provided with or aware of any instructions as to how Mr. Robinson's insulin was to be given in relationship to his diet, the schedule of meals? A. No. I can't recall. Q. Do you know what I'm asking? A. No. I'm confused. ©. Ts il important Uhal when a diabelic gels his medication, is there any -- scratch that. Is there any interaction between a diabetic and when he gets his insulin and when he eats? 1-888-947-2963, JPA Reporting, LLC 404-853-1811

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