Scribd

Kel

Aterman

Runsten

L L P

SCOTT

J.

ALDWORTH

SUSANT.

ALTERMAN

**,

—

JOHN

P.

ASHWORTH

DOUGLAS

S.

CHIAPUZIO CPA

GARY

P.

COMPA

WILLIAM

DICKAS

ROBERT

E.

KABACY

*

LEE

DAVISKELLROBERT

B.

LOWRY++MELISSA

MAY*

WAYNE

D.

PALMER

EMILY

C.

RAKE

PAULA

RANEY*

THOMAS

R.

RASK,

ROBIN

M.

RUNSTEIN

TED

E.RUNSTEINERICSOGGE

DENNIS

STEINMAN

ZACHARY

WALKER

ATTORNEYS

AT

LAWSUITE

600

520S.W.

YAMHILLSTREET

PORTLAND,OREGON97204-1329

TELEPHONE

(503)222-3531

FACSIMILE(503)227-2980

WWW.KELRUN.COM

E-MAIL;dstemman@kelrun.comRAYMOND

M.

KELL(1911-1991)

CLIFFORD

B.

ALTERMAN

(1925-1995)

ALSOADMITTED

IN

•CALIFORNIA

WASHINGTON

'GEORGIA

••COLORADO

• WASHINGTON

DCLL.M.

IN

JTAXATION

++OFCOUNSEL

December

5,

2014

Via

Certified

Mail

No.

7013

2630

00007870

Return

Receipt

Requested

Mchael

Jordan

Chief

Operating

Officer

and

DAS

Director

OregonDepartment

of

Administrative

Services

1225

Ferry

Street,SE

U150

Salem,

Oregon

97301

Via

Certified

Mail

No.

7013

2630

0000

2808

7887

Return

Receipt

Requested

Suzanne

Huffman,

Interim

Director

Oregon

Health

Authority

500

Summer

St.

NE,

E20Salem,

OR

97301-1097

Re:

Our

Client:

Location

of

Incident:

Dates

of

Incident:Our

File

No.:

Lisa

Feehely,

Personal

Representative

for

theEstate

of

Christopher

Patrick

Crawford

Salem

Oregon

October

2013-January

3,

201421675\002ORS

30.275

NOTICE

OF

A

CLAIM

Dear

M.

Jordan

and

Ms.

Huffman:

PursuanttoORS30.275,please

take

notice

as

follows;

Theundersignedattorney,

Dennis

Steinman

of

Kell,

Aterman

Runstein,

L L P

represents

Lisa

Feehely,the

Personal

Representative

for

theEstate

of

Christopher

Patrick

Crawford

( Claimant ).

Correspondence

concerningthis

lettershould

be

directed

tothe

attention

of

DennisSteinman

at

the

address

set

forth

above.

Claimant

intends

to

assert

claims

for

damages

against

the

State

of

Oregon

relating

tothetreatment

of

ChristopherPatrick

Crawford

while

patient

at

Oregon

State

Hospital

( OSH )

during

the

periodleading

up

to

and

including

his

death

onJanuary

3,

2014.

Claimant s

Michael

Jordan

ORDepart

of

Admin

Servs

Kell,

Alterman

Runstein

L.L.P.

Suzanne

Huffinan

ORHealth

Authority

December

5

2014

Page

2

claims

for

damages

include but

are

not

limited

to claims

for

wrongful

death,

violations

of

state

whistleblowerretaliation

laws

and

violations

of

the

United

States

Constitution.

2.

The

time

place

and

circumstances

giving

rise

to

Claimant s

claims

so

far

as

presentlyknown

are

as

follows;

OnSeptember

9

1992

ChristopherPatrickCrawford

was

admitted

to

OSH

afterbeing

found

guilty

except

for

insanity

oncertain

criminal

chargesand

placed

under

the

jurisdiction

of

the

PsychiatricSecurity

Review

Board

for

a

periodnotto

exceed

40

years.

Mr.

Crawford

suffered

frombipolar

disorder

but

was

a

veryhighfunctioning

patient

for

nearly

all

of

his

time

at

OSH.

Beginning

in

late

2013

however

Mr.

Crawford s

physical

condition

deteriorated

culminating

in

his

deathon

January

3

2014.

Mr.Crawford s

decline

waspreceded

by

an

event

that

occurred

in

or

around

August

2013.

At

that

time

Mr.

Crawford

learnedthat

an

OSH

nurse

Jennifer

Barren

wasengaged

in

a

sexual

relationship

with

an

OSHpatient.

Mr.

Crawford

reported

the

relationshipto

two

supervisors

at

OSH

who

toldMr.

Crawford

that

theywere

aware

of

the

relationship

and

that

Mr.

Crawford

should

keepthe

information

confidential.

Mr.

CrawfordbelievedthatMs.Barren sbehavior

was

extremely

inappropriate

and

that

OSH

was

asking

him

to

collude

in

keeping

her

conduct

confidential.

Mr.

Crawforddid

not

believe

that

this

was

right

and

made

the

decision

tocontactthe

media

and

police

about

the

inappropriate

relationship.

Mr.Crawford

contactedreporters

from

The

Oregonian

and

the

Statesman-Journal

both

of

whom

investigated

the

information

provided

by

Mr.

Crawford

and

subsequently

wrotearticles

about

Ms.

Barren s

inappropriate

relationship.

Mr.

Crawford

also

reported

Ms.Barren sconduct

tothe

Oregon

State

Police.

After

Mr.Crawford s

reports

to

the

media

and

law

enforcement

OSH s

treatment

of

him

changed.

OSH

had

recently

been

thesubject

of

an

investigation

by

the

U.S.

Department

of

Justice

and

manyOSHemployeeswereupset

that

Mr.

Crawford s

reportscould

draw

additional

scrutiny

to

the

hospital.

In

October

2013 OSHtransferred

Mr.

Crawford

away

from

the

unit

at

which

he

had

been

living,

BridgeTwo.BridgeTwo

wastheleast

restrictive

ward

at

OSH

and

allowed

patientsthe

greatest

level

of

freedom.

On

Bridge

Two

Mr.

Crawford s

limited

medication

was

well-managed;

he

was

able

toparticipate

in

a

number

of

OSH s

programs

and

activities

andhe

enjoyed

a

relatively

independent

lifestyle.

Without

justification,

Mr.

Crawford

was

moved

from

Bridge

Two

to

UnitBird

Two.

UnitBird

Two

was

one

of

the

most

restricted

wards

at

OSHwherepatients

had

constant

supervision

and

were

often

heavily

medicated.

Life

on

Unit

BirdTwo

was

much

worse

forMr.

Crawford.

His

movementswere

much

morerestricted

and

hewas

subjectedtoone on one

monitoring

in

which

an

OSH

staff

member

followed

hismovements

at

all

times.He

was

no

longer

ableto

participatein

the

programs

and

activities

thathad

previously

been

a

largepart

of

histreatment.

Most

significantly,Mr.

Crawford s

medication

waschanged

dramatically.

Whereas

the

medicationthat

Mr.Crawford

receivedon

BridgeTwo

was

well-balanced

and

allowed

him

to

lead

a

functional