"FORMAL COMPLAINT"
A.D.A VIOLATIONS

To: Disability Rights Section, NYA, Civil Rights
Division U.S. Dept. of Justice, ADA Coordinator
Cynthia Phelps, Fla. Dept. of Corrections
Senior Medical Director Olugbengo Ogunsanwo,
T. Macey HSA Corizon

From: Ronald Wayne Clark Jr. #812947
Union Correctional Institution P-6118
7819 N.W. 228th Street
Raiford, Florida 32026-4460

Date: August 19, 2014

Subject: ADA Health and Safety Violations
by Corizon Inc. and their health care employees

In January 2014 I began having problems with my back and right knee. It began to effect my exercising, I had to give up basketball, which is one of my new favorite enjoyments. By June I had to give up volleyball, and all forms of exercise. For I had went from walking and moving in some form of pain, to stumbling around and falling.

On June 9, 2014 Doctor LaFontant here at Union Correctional Institution (UCI) ordered a wheelchair pass and an MRI on my right knee and back (see attached radiology reports dated 11/15/2013, 2/14/2014 and 2/28/2014 showing osteoarthritis in the right knee and degenerative disc disease). Corizon executives denied the MRI's, failing to do further testing, much needed testing.

On August 13, 2014 Wednesday, Nurse Goroom came to my cell front and stated, "Corizon has D.C. (discontinued) your wheelchair." They said, "more testing is needed." But the reason more testing hasn't been done is because Corizon Inc. refused to approve the testing.

On July 30, 2014 Wednesday, I had seen Doctor LaFontant who ordered MRI's again, stating that I am unable to walk. So a qualified doctor, who has examined me, is being over ruled by some company executive. Doctor LaFontant not only put in an order for the MRI's but ordered that I be sent to the orthopedic specialist, still pending decision.

Since June 2014 I've been dealing with high blood pressure due to the excruciating pain in my back. My blood pressure on August 12, 2014 Tuesday was 174/108, then 168/104 and 169/106. It was sent to urgent care and was seen by Doctor Melendez-Torres who ordered that I be given two injections to help alleviate the back pain. The injections worked for 24 hours. She also prescribed "methylprednisolone" which has done nothing.

I am unable to walk, can only stand while holding on to bars, or sturdy structures. I've fallen numerous times in the cell, attempting to move about the cell. So on July 18, 2014 I sent a memo to ADA Coordinator requesting an ADA cell with wheelchair. Also contacted T. Macey and had my mother assist in contacting them, to no avail. I sent Ms. Cynthia Phelps a 2nd letter on August 12, 2014 again, requesting an ADA certified cell, which to this day has went unanswered.

I'm sitting in a cell, completely immobile, can't get down to the shower, law library, pastoral visits, regular visits. Can't go outside for fresh air and sunshine and if there was a fire or some type of emergency evacuation, I'd be in serious trouble.

Corizon is violating my constitutional rights, for the courts have stated in Cummings 628 F,2d at 1068 (8th cir. 1980) (inmate with back injury who was denied wheelchair stated Eighth Amendment claim).

Being that this disability is effecting me, by being unable to walk, standing, bending and lifting, I qualify as being disabled under 42 USC & 12102 (4) (b)-(d) for this degenerative disc disease will effect me the rest of my life.

I need someone to step in and override Corizon Inc. Protecting my life, health and safety, as well as my constitutional rights. Please help me with this. See attached Appendix. Radiology Reports.

Respectfully
Submitted
Ronald W. Clark Jr.