Estate of Tomas Beauford v. Mesa County, Colorado, Et. Al.

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 1of45
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO
Civil Action No. 15-cv-00851-WYD
ESTATE OF TOMAS BEAUFORD,
TIFFANY MARSH, personally and as personal representative of the estate of TOMAS
BEAUFORD, deceased;
Plaintiffs,
v.
MESA COUNTY, COLORADO; a government entity;
CORRECT CARE SOLUTIONS, LLC;
CORRECTIONAL HEALTHCARE COMPANIES, INC.;
CORRECTIONAL HEALTHCARE PHYSICIANS, P.C.;
CORRECTIONAL HEALTHCARE MANAGEMENT, INC.;
SHERRIFF STAN HIKEY;
SERGEANT JASON L. MCCLELLAND;
SERGEANT ANTHONY LEE;
SERGEANT ROXIE HODSON;
DEPUTY PETER M. DALRYMPLE;
DEPUTY RICHARD D. PERKINSON;
DEPUTY ALMA MEDRANO;
DEPUTY ANDREW BARNEY;
DEPUTY KATHRYN M. DURRANT;
DEPUTY ERIC HERRING;
DEPUTY DONNA LAGRANGE;
DEPUTY JOSHUA S. BAY;
DEPUTY BRIDGETTE CHADD;
DEPUTY NICK BOUTON;
DEPUTY AMY MONTANO;
DEPUTY JOHN PUCKET;
DEPUTY DONNA DRAPER;
NURSE RENEE WORKMAN;
NURSE VEIDA HAYENS;
NURSE AUDRA KEENAN;
NURSE JEANNE "ANNMARIE" SCHANS.
Defendants.
Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 2 of 45
CORRECTED SECOND AMENDED COMPLAINT AND JURY DEMAND
Plaintiffs, by and through their attorneys, David A. Lane and Andy McNulty of KILLMER,
LANE & NEWMAN, LLP, and Thomas D. McFarland of McFarland Law Offices, hereby bring this
Corrected Second Amended Complaint and allege as follows:
INTRODUCTION
1.
On April 16, 2014, Tomas Beauford, a pre-trial detainee housed in Mesa County
Detention Center ("MCDF") died from seizure after seizure, left unattended as nurses and
corrections officials knew he was suffering. Mr. Beauford was a beloved son and his life was
tragically taken away.
2.
Mr. Beauford's preventable death occurred because of Defendants' deliberate
indifference to his serious medical needs in violation of the Fourteenth Amendment to the United
States Constitution and their failure to acco=odate his disabilities in violation of the
Americans with Disabilities Act.
3.
Throughout his time at MCDF, Mr. Beauford demonstrated clear signs of
epilepsy. Because of Defendants' deliberate indifference to his obviously serious medical needs,
Mr. Beauford's condition rapidly deteriorated on April 15, 2014 into the morning of April 16,
2014.
4.
Though Mr. Beauford's need for i=ediate medical attention was obvious,
thereby making Defendants fully aware that he was suffering serious symptoms of his epilepsy,
at no time was he provided with medical attention or treatment. Rather than providing him with
the medical attention and treatment he so desperately needed, Mr. Beauford was actively
ignored.
5.
Alone in his cell, Mr. Beauford ultimately had a series of seizures, fell off of his
bed, and died with his head jammed underneath his desk. Mr. Beauford's demise could have
undoubtedly been prevented had Defendants provided him with prompt and appropriate medical
attention and treatment.
6.
Defendants' acts and/or omissions, which are incompatible with the dictates of the
United States Constitution and the Americans with Disabilities Act, directly caused Mr.
Beauford's death. Had Defendants fulfilled their clearly established constitutional and statutory
obligations, Mr. Beauford would unquestionably still be alive today.
JURISDICTION AND VENUE

7.
This action arises under the Constitution and laws of the United States and is
brought pursuant to 42 U.S.C. 1983.

8.
Jurisdiction is conferred on this Court pursuant to 28 U.S.C. 1331and1367.
Jurisdiction supporting Plaintiffs' claim for attorneys' fees and costs is conferred by 42 U.S.C.
1988.
9.
Supplemental pendent jurisdiction is based on 28 U.S.C. 1367 because the
violations of federal law alleged are substantial and the pendent causes of action derive from a
co=on nucleus of operative facts.
10.
Venue is proper in the District of Colorado pursuant to 28 U.S.C. 139l(b). All
of the events alleged herein occurred within the State of Colorado, and all of the parties were
residents of the State at the time of the events giving rise to this litigation.
11.
Correct Care Solutions, LLC, Correctional Healthcare Companies, Inc.,
Correctional Healthcare Physicians, P.C., and Correctional Healthcare Management, Inc., are
private corporations, and therefore no notice of the claims against them was required under the
CGIA.
PARTIES
Plaintiffs:
12.
At all times pertinent hereto, the decedent, Tomas Beauford, was a citizen of the
United States of America and a resident of the State of Colorado confined to the Mesa County
Detention Facility.
13.
At all times pertinent hereto, Tiffany Marsh, personal representative to the Estate
of Tomas Beauford, has been a citizen of the United States of America and a resident of the State
of Colorado. Ms. Marsh is Mr. Beauford's mother.
Defendants:
14.
Defendant Mesa County, Colorado ("Mesa County") is a political subdivision of
the State of Colorado and is the public entity responsible for Mesa County and the Mesa County
Detention Facility ("MCDF"}. The MCDF is operated by the Mesa County Sheriff's Department.
15.
Defendant Correct Care Solutions, LLC ("CCS") is a for-profit Tennessee
corporation doing business in the State of Colorado, with its principal street address located at
1283 Murfreesboro Road, Suite 500, Nashville, TN 37217. Its registered agent of service in
Colorado is located at 3773 Cherry Creek North Drive #575, Denver, CO 80209. On
information and belief, this company contracts with Mesa County to provide medical services to
inmates and detainees at Mesa County Detention Facility and supervises and implements such
care.
16.
Defendant Correctional Healthcare Management, Inc. is a for-profit Colorado
corporation doing business in the State of Colorado, with its principal street address located at
6200 South Syracuse Way, Suite 440, Greenwood Village, Colorado 80111. On information and
belief, this company contracts with Mesa County to provide medical services to inmates and
detainees at Mesa County Detention Facility and supervises and implements such care.
17.
Defendant Correctional Care Solutions, LLC, Defendant Correctional Healthcare
Companies, Inc., Defendant Correct Healthcare Management, Inc., and Defendant Correctional
Healthcare Physicians, P.C. are corporate medical care providers related to one another, and are
collectively referred to as "CCS Defendants."
18.
CCS Defendants are proper entities to be sued under 42 U.S.C. 1983 for their
deliberately indifferent policies, practices, habits, customs, procedures, training, and supervision
of staff, including individual Defendants, with respect to the provision of medical care and
treatment for inmates with serious emergency medical needs.
19.
At all relevant times, the CCS Defendants were acting under color of state law
and performing a central function of the state thus making them liable under 1983. All the
conduct of the CCS Defendants and its employees and agents is also chargeable to the
government, and CCS Defendants were acting jointly with the government actors.
20.
At all times relevant to the subject matter of this litigation, Defendant Stan Hikey
was a citizen of the United States and a resident of Colorado. At all relevant times, Defendant
Hikey was acting under color of state law in his capacity as the Mesa County Sheriff. Defendant
Hikey was responsible for training and supervising all other Defendants and other employees of
the Mesa County Sheriff's Department working at the jail, for setting jail policy for the county
and the overall management of the jail, and for insuring the health and welfare of all persons
detained in the Mesa County Detention Facility.
21.
Defendant Mesa County and Defendant Hikey, in his official capacity, are
collectively referred to as "Mesa County Defendants."

22.
At all times relevant to the subject matter of this litigation, Defendant Jason L.
McClelland was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant McClelland was acting under color of state law in his capacity as a Sergeant
employed by the Mesa County Sheriff's Office.
23.
At all times relevant to the subject matter of this litigation, Defendant Anthony
Lee was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Lee was acting under color of state law in his capacity as a Sergeant employed by the
Mesa County Sheriff's Office.
24.
At all times relevant to the subject matter of this litigation, Defendant Roxie
Hodson was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Hodson was acting under color of state law in his/her capacity as a Sergeant
employed by the Mesa County Sheriff's Office.
25.
At all times relevant to the subject matter of this litigation, Defendant Peter M.
Dalrymple was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Dalrymple was acting under color of state law in his capacity as a Deputy employed
by the Mesa County Sheriff's Office.
26.
At all times relevant to the subject matter of this litigation, Defendant Richard D.
Perkinson was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Perkinson was acting under color of state law in his capacity as a Deputy employed
27.
At all times relevant to the subject matter of this litigation, Defendant Alma
Medrano was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Medrano was acting under color of state law in his/her capacity as a Deputy employed
28.
At all times relevant to the subject matter of this litigation, Defendant Andrew
Barney was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Barney was acting under color of state law in his/her capacity as a Deputy employed
29.
At all times relevant to the subject matter of this litigation, Defendant Kathryn M.
Durrant was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Durrant was acting under color of state law in her capacity as a Deputy employed by
the Mesa County Sheriff's Office.
30.
At all times relevant to the subject matter of this litigation, Defendant Eric
Herring was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Herring was acting under color of state law in his/her capacity as a Deputy employed
31.
At all times relevant to the subject matter of this litigation, Defendant Donna
LaGrange was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant LaGrange was acting under color of state law in his/her capacity as a Deputy
employed by the Mesa County Sheriffs Office.
32.
At all times relevant to the subject matter of this litigation, Defendant Joshua S.
Bay was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Bay was acting under color of state law in his capacity as a Deputy employed by the
Mesa County Sheriff's Office.
33.
At all times relevant to the subject matter of this litigation, Defendant Bridgette
Chadd was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Chadd was acting under color of state law in her capacity as a Deputy employed by
the Mesa County Sheriff's Office.
34.
At all times relevant to the subject matter of this litigation, Defendant Nick
Bouton was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Bouton was acting under color of state law in his/her capacity as a Deputy employed
35.
At all times relevant to the subject matter of this litigation, Defendant Amy
Montano was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Montano was acting under color of state law in his/her capacity as a Deputy employed
36.
At all times relevant to the subject matter of this litigation, Defendant John Pucket
was a citizen of the United States and a resident of Colorado. At all relevant times, Defendant
Pucket was acting under color of state law in his/her capacity as a Deputy employed by the Mesa
County Sheriff's Office.
37.
At all times relevant to the subject matter of this litigation, Defendant Donna
Draper was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Draper was acting under color of state law in his/her capacity as a Deputy employed
38.
At all times relevant to the subject matter of this litigation, Defendant Renee
Workman was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Workman was acting under color of state law in her capacity as a Nurse employed by
CCS Defendants.
39.
At all times relevant to the subject matter of this litigation, Defendant Velda
Havens was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Velda was acting under color of state law in her capacity as a Nurse employed by
CCS Defendants.
40.
At all times relevant to the subject matter of this litigation, Defendant Audra
Keenan was a citizen of the United States and a resident of Colorado. At all relevant times,
Defendant Audra was acting under color of state law in her capacity as a Nurse employed by
CCS Defendants.
41.
At all times relevant to the subject matter of this litigation, Defendant Jeanne
"AnnMarie" Schans was a citizen of the United States and a resident of Colorado. At all relevant
times, Defendant Schans was acting under color of state law in her capacity as a Nurse employed
by CCS Defendants.
FACTUAL ALLEGATIONS
Tomas Beauford was a loved member ofa close-knit tilmilv and he had a deeo. meanineful
relationship with his mother Tiffany Marsh.
42.
Tomas Beauford was born on July 18, 1989.
43.
Mr. Beauford's mother, Tiffany Marsh, was extremely close with her son.
44.
Although Mr. Beauford lived in the Grand Junction and Wheat Ridge Regional
Centers, Ms. Marsh visited him regularly.

45.
At the time of Mr. Beauford's death, Ms. Marsh was pursuing guardianship of
10
Mr. Beauford.
46.
In her eulogy for Mr. Beauford, Ms. Marsh described her son and the special bond
that she had with him:

Only one word truly describes the person you are: Beautiful. My Beautiful
Tomas[,] Beautiful is who you are. Beautiful is how you make others feel when
you are present; Beautiful is your essence, your heart and soul. I will miss your
beautiful smile and warmth when you are present. You light up my life. You are
the light of my life. I will miss you so much. I cannot believe that you are gone.
You are so young. I love you so much. Everywhere you go you bring joy to all
who are near. You make others feel special. You love to dance and play around.
You love Taco bell burritos and starburst candy, sprite and [r]oot beer mix. You
were always yourself. You are the most real person I know. Your love for the
Lord was magical and magnetic and it is because of this I know you are with the
Lord. I cry not because I am sad, but because I am going to miss you more than
words can say.
Mr. Beauford suffered from multiple disabilities and serious medical conditions that required
specialized care and attention.
47.
Mr. Beauford, at age 24, had an IQ of 52 and operated at the mental capacity of a
child who is five or six years old.
48.
Mr. Beauford was declared by a state of Colorado court to have a legal
intellectual and developmental disability pursuant to C.R.S. 25.5-10-202.

49.
Because of his legal intellectual and developmental disability, Mr. Beauford was
declared legally mentally incompetent. See C.R.S. 27-10.5-110.

50.
Mr. Beauford was housed in the Grand Junction Regional Center because of his
severe intellectual disability and other mental illnesses.

51.
Mr. Beauford also spent time in Wheat Ridge Regional Center. Because of his
intellectual disability, and also because of his severe epilepsy, Wheat Ridge Regional Center had
a court order allowing them to force Mr. Beauford to take his various prescribed medications if
necessary.
11
52.
Mr. Beauford sustained a traumatic brain injury. This injury is associated with his
epilepsy, severe intellectual disability, mental illnesses, and inability to control his emotions.
53.
Mr. Beauford had an implanted Vagal Nerve Stimulator ("VNS").
54.
The Vagus Nerve is part of the autonomic nervous system, which controls
functions of the body that are not under voluntary control, such as heart rate. The Vagus Nerve
passes through the neck as it travels between the chest and abdomen and the lower part of the
brain.
55.
The VNS is programmed to cycle on and off, giving stimulation at regular
intervals during the day to the Vagus Nerve. Additionally, the implanted VNS is controlled
manually by a special magnet. When the special magnet is held near the implanted device, it
triggers the device to deliver another burst of stimulation, outside of the programmed intervals.
For individuals who experience auras (or warnings) prior to their seizures, activating the
stimulator with the magnet when the aura occurs usually stops the seizure or dramatically
reduces the magnitude or duration of the seizure.
56.
Mr. Beauford had a bracelet ("VNS medical bracelet") that he always wore which
contained the special magnet linked to his VNS. Mr. Beauford experienced auras prior to his
seizures. When Mr. Beauford would experience an aura, he would hold the VNS medical
bracelet containing the special magnet near his chest, where his VNS was implanted. The
subsequent shock delivered by the VNS to Mr. Beauford's Vagus Nerve typically stopped the
seizure from occurring or dramatically reduced the magnitude and/or duration of the seizure.
57.
Mr. Beauford took multiple medications for his multiple disabilities. These
medications including Lithium Carbonate, Olanzapine, Oxcarbazepine, Potassium Chloride,

Propranolol, Benztropine, Clonazepam, and Divalproex.
12
58.
Without his medication, Mr. Beauford was prone to serious seizures and
worsened symptoms of his intellectual disability and mental illnesses.
MCDF officials were on notice ofMr. Beauford's disabilities and serious medical conditions.
59.
During Mr. Beauford's previous incarceration at MCDF, MCDF recognized that it
could not properly acco=odate Mr. Beauford because of his unique medical issues and
intellectual disability. MCDF transferred Mr. Beauford back to the Grand Junction Regional
Center during this previous incarceration, so that Mr. Beauford could receive the appropriate
level of care and acco=odation.
60.
On November 30, 2013, Mr. Beauford was booked into MCDF. On the "Mesa
County Detention Pre-Custody I Medical Intake" form, Mr. Beauford indicated that he suffered
from seizures and that he was currently taking "Depicoate[,]" also known as divalproex sodium
or Depakote. Depakote is a co=only prescribed and known anti-seizure medication. Depakote
is often prescribed to complement treatment using a VNS. While regular electric intervals of the
VNS and a prescription ofDepakote provide preventative measures for seizures, utilizing the
VNS medical bracelet to trigger an extra shock of the Vagus Nerve helps to prevent serious
seizures as they happen or to stop the seizure after it has already begun.
61.
On November 21, 2013 the Grand Junction Regional Center sent a document
captioned "Pertinent Information Mesa County Sheriff's Department" regarding Mr. Beauford.
Included in this memo is the note "WRRC Psychiatric clinic has court order for Tomas to take
his meds." The memo further noted "Incompetent: mother pursuing guardianship." In a section
captioned "BERAVIORS THAT THE PERSON MAY DISPLAY IF PLACED IN
JAIL: Refusal of medications" was noted. Listed under "CURRENT MEDICATIONS: Refer to
medication received and any medication records accompanying the individual." For "HEALTH
CONCERNS/MEDICAL CONDITION(S): Per Dr. Shenk and Dyrud physical 11/7/13" among
13
many concerns/conditions was listed "intellectual disability[,]" "Epilepsy[,]" "Bipolar

disorder[,]" "paranoid schizophrenia[,]" and "attention hyperactivity disorder[.]"
62.
Importantly, on the Pertinent Information document sent to the Mesa County
Sheriff's Department from the Grand Junction Regional Center, it was noted that Mr. Beauford
had an implanted "VNS (vagal nerve stimulator)."
63.
Upon information and belief, officials at MCDF, knew that Mr. Beauford was to
have his VNS medical bracelet on at all times for medical purposes.
64.
Upon information and belief, MCDF is not equipped to acco=odate individuals
with an intellectual disability. If an inmate has an IQ lower than 55, as Tomas Beauford did, then
MCDF is supposed to transfer the inmate to the proper regional center, hospital, or mental health
treatment facility.
65.
The social worker at MCDF during Mr. Beauford's incarceration told multiple
officials at MCDF that Mr. Beauford needed his VNS medical bracelet on at all times. Despite
this warning, MCDF officials confiscated Mr. Beauford's VNS medical bracelet during his
incarceration from December 1, 2013 to December 3, 2013 and from March 1, 2014 to his death
on April 16, 2014.
Mr. Beauford was incarcerated at MCDF from December 1. 2013 to December 3. 2013.
66.
On December 1, 2013, Mr. Beauford was booked into MCDF. At that time he was
wearing his VNS medical bracelet. MCDF records show that Mr. Beauford's bracelet was logged
in as part ofMCDF's Inmate Property Report. MCDF confiscated Mr. Beauford's bracelet from
him and held it until his release from the detention center on December 3, 2013.
67.
Mr. Beauford's VNS medical bracelet was confiscated on December 1, 2013,
pursuant to the custom, policy or practice of MCDF, as promulgated by Sheriff Stan Hikey.
14
68.
On December 1, 2013, a questionnaire, officially known as a Decision Tree
within MCDF, was created by Deputy Montano, who falsely reported that Mr. Beauford did not
have any special medical needs or special mental health needs. This document was utilized in
treating and accommodating Mr. Beauford during his incarceration at MCDF from December 1,
2013 to December 3, 2013. Deputy Montano's Decision Tree was in direct contravention of the
document that the Grand Junction Regional Center had sent to MCDF and the intake
questionnaire that Mr. Beauford had filled out on December 1, 2013.
During his incarceration at MCDF from December 1, 2013 to December 3, 2013, Mr.
Beauford suffered multiple seizures, placingMCDF offlcials on notice that he suffered from
epilepsv.
69.
While at MCDF in connection with the November 30, 2013 incident, Mr.
Beauford had multiple reported seizures.

70.
On December 1, 2013, at 9:37 p.m., Mr. Beauford had a seizure in holding cell
one. An unnamed nurse and another unnamed deputy responded. Deputy Bouton reported that
Mr. Beauford was not having a full body seizure, so no one entered the cell to assist Mr.
Beauford. The nurse and officer cited "safety concerns" as their reason for not entering the cell.
After the initial seizure, Mr. Beauford moved towards the door. At this time, Deputy Bouton
asked Mr. Beauford ifhe was feeling ill. Mr. Beauford did not respond and started to experience
another seizure, his arms shaking violently. Deputy Bouton, the unnamed nurse, and the
unnamed deputy, never entered Mr. Beauford's cell or moved him into medical. They could not
convince Mr. Beauford to take his medication. Instead of taking any of these actions, they simply
left. This incident is memorialized in Mr. Beauford's Inmate Activity Log at MCDF.
71.
The inmate activity log for December 1, 2013, shows that Mr. Beauford refused
his seizure medication on multiple occasions.
15
72.
Throughout his incarceration at MCDF from November 30, 2013 to December 3,
2014, Mr. Beauford regularly refused his medication.

73.
Mr. Beauford's refusal of his medication is a manifestation of his intellectual
disability, bipolar disorder, paranoid schizophrenia, and/or attention hyperactivity disorder.
74.
Ultimately, Mr. Beauford was released on bond and transferred back to the Grand
Junction Regional Center on December 3, 2013. Mr. Beauford was released on bond and
transferred back to Grand Junction Regional Center, and not held until his court date, because
MCDF was not equipped to properly accommodate his disabilities.
Mr. Beauford was incarcerated at MCDF from March 1, 2014 until his death on April 16,
2014.
75.
Mr. Beauford was sent to MCDF after an incident at Grand Junction Regional
Center on February 25, 2014.
76.
Officer B. Bloydstun wrote in a case report, which was given to officials at
MCDF, that he responded to the Regional Center in Mesa County on February 25, 2014 to a
report of a disturbance caused by Mr. Beauford. The officer was informed by staff that Mr.
Beauford operated at the mental age of a "five or six year old." Mr. Beauford was charged with
misdemeanor assault.
77.
Mr. Beauford was booked into MCDF on March 1, 2014.
78.
Deputy Richard D. Perkinson was the Booking Deputy upon Mr. Beauford's
arrival at MCDF on March 1, 2014.

79.
During the booking process, Mr. Beauford suffered at least one seizure and, upon
information and belief, Mr. Beauford suffered from ongoing seizures throughout the booking
process.
80.
During the booking process, Mr. Beauford also exhibited signs of his severe
16
intellectual disability through a failure to comprehend simple direction.

81.
Deputy Perkinson personally witnessed Mr. Beauford's multiple seizures during
the booking process. As a result, Mr. Beauford stayed in booking for an extended period of time.
82.
Upon arrival at MCDF, on March 1, 2014, Mr. Beauford filled out a form entitled
"Mesa County Detention Facility Pre-Custody I Medical Intake[.]"

83.
On the Mesa County Detention Facility Pre-Custody I Medical Intake form, Mr.
Beauford indicated that he was ill or injured or had medical conditions that MCDF needed to be
aware of, had been hospitalized or been seen by medical personnel recently, had mental health
conditions that may require attention while in custody, and suffered from seizures.
84.
The Mesa County Detention Facility Pre-Custody I Medical Intake form noted
that if an inmate indicated that any of these conditions applied to him or her, that the medical
staff and shift sergeant had to be advised and that they had to ask further questions to determine
if the arrestee should be incarcerated or if further medical attention was necessary prior to being
booked and processed into MCDF.
85.
A staff member and a medical staff member both signed Mesa County Detention
Facility Pre-Custody I Medical Intake form, acknowledging that they had reviewed it with Mr.
Beauford.
Officials at MCDF demonstrated deliberate indifference bv misclassitving Beauford and

confiscating his VNS medical bracelet.
86.
On March 1, 2014, Deputy Barney filled out MCDF's initial intake questionnaire,
referred to internally as the "Decision Tree." Despite Mr. Beauford's indications on the Mesa
County Detention Facility Pre-Custody I Medical Intake form, MCDF's prior history with Mr.
Beauford, and the document previously sent to MCDF by the Grand Junction Regional Center
outlining Beauford's history of seizures, VNS, intellectual disability, Bipolar disorder, paranoid
17
schizophrenia, and attention hyperactivity disorder, Deputy Barney indicated on the Decision
Tree that Mr. Beauford did not have medical special needs or mental health special needs. Mr.
Beauford had exhibited multiple and obvious outward signs of mental illness, the symptoms of
his traumatic brain injury, and severe intellectual disability.
87.
Even absent knowledge of the clear indications made by Mr. Beauford on the
Mesa County Detention Facility Pre-Custody I Medical Intake form, MCDF's prior history with
Mr. Beauford and the document previously sent to MCDF by the Grand Junction Regional
Center outlining Beauford's history of seizures, VNS, and intellectual disability, Deputy Barney
would have had to willfully, recklessly, or purposefully misevaluate Mr. Beauford ifhe were to
say that Mr. Beauford had no medical special needs or mental health special needs. Deputy
Barney knew or should have known of these serious medical needs.
88.
After Mr. Beauford was booked into MCDF on March 1, 2014, Mr. Beauford's
mother, Tiffany Marsh, gave officials at MCDF specific instructions as to how to convince Mr.
Beauford to take his medication. Because of Mr. Beauford's intellectual disability, he often
refused to take his medication. Mr. Beauford's mother, however, knew the method that could be
used to successfully convince Mr. Beauford to take his medication and relayed this method to
officials at MCDF.
89.
Despite Ms. Marsh's specific instructions on how to convince Mr. Beauford to
take his medication, officials at MCDF did not follow the protocol outlined by Ms. Marsh. As a
result, Mr. Beauford consistently refused his medication. After Mr. Beauford's refusal, MCDF
officials would make no attempts to convince Mr. Beauford to take his prescribed medications.
90.
Without his prescribed medications, Mr. Beauford's risk of a life threatening
seizure was dramatically increased.
18
91.
Mr. Beauford's VNS medical bracelet was confiscated on March 1, 2014. Mr.
Beauford's property intake form indicates that his jailers had taken two bracelets from him.
92.
Mr. Beauford's VNS medical bracelet was confiscated on March 1, 2014,
pursuant to the custom, policy or practice of MCDF, as promulgated by Sheriff Stan Hikey.
93.
Mr. Beauford did not have his VNS medical bracelet from March 1, 2014 until his
death on April 16, 2014.
Mr. Beauford's severe intellectual disabilitv. bipolar disorder, and attention deficit
hvoeractivitv disorder were apparent during his March J, 2014, incarceration at MCDF and
MCDF officials knew that thev were not equipped to accommodate Mr. Beauford's disabilities.
94.
On March 4, 2014, at approximately 1:20 p.m., Sergeant Anthony Lee noted in
Mr. Beauford's inmate activity log that Mr. Beauford "is very low functioning[.]" Sergeant Lee
also noted that Deputies Durrant, Herring, and LaGrange were aware of Mr. Beauford's severe
intellectual disability and mental illnesses. Despite their awareness of Mr. Beauford's severe
intellectual disability and mental illnesses, the Deputies made no efforts to accommodate Mr.
Beauford's disability or transfer him to another facility.
95.
Mr. Beauford's intellectual disability and mental illnesses also manifested
themselves in an inability to control his bodily functions or to take care of his personal hygiene.
MCDF officials provided Mr. Beauford with adult diapers during his stay at MCDF and nurses at
MCDF changed Mr. Beauford's adult diapers multiple times during his incarceration.
96.
One instance of Mr. Beauford's adult diapers being changed by nurses at MCDF
is documented in Mr. Beauford's inmate log on March 6, 2014, at 8:27 p.m.

97.
On March 8, 2014, at 7:39 a.m., Sergeant Lee memorialized in Mr. Beauford's
Inmate Activity Log that Mr. Beauford was placed on a medical hold because he had soiled all of
his clothes and the adult diaper he was wearing. Nurses Velda and Audra recommended the
19
medical hold and moved him from Cedar Pod to the booking area.
98.
On March 8, 2014, at 5:36 p.m., Deputy Perkinson memorialized in Mr.
Beauford's Inmate Activity Log that the nurses on call changed Mr. Beauford's adult diapers and
treated him for bed sores.
99.
On March 12, 2014, at 10:10 a.m., Deputy Wilson memorialized in Mr.
Beauford's Inmate Activity Log that MCDF staff changed his diaper, t-shirt, and pants.
100.
On March 12, 2014, at 2:23 p.m., Deputy Wilson memorialized in Mr. Beauford's
Inmate Activity Log that Mr. Beauford was taken off his medical hold and returned to Cedar
Pod.
101.
On March 18, 2014, at 6:37 a.m., Deputy LaGrange memorialized in Mr.
Beauford's Inmate Activity Log that he had been observed wearing his mattress cover over his
head and walking into the walls of his cell. Mr. Beauford was not placed on a medical hold or
otherwise monitored more closely after this incident.
Mr. Beauford had multiple seizures during his incarceration from March 1. 2014 to April 16.
2014 at MCDF.
102.
On March 1, 2014, at approximately 4:41 p.m., Mr. Beauford had a seizure.
Deputy Medrano responded to the call for assistance and observed Mr. Beauford on the floor
seizing and foaming at the mouth. Deputy Medrano advised Sergeant Hodson of Mr. Beauford's
seizure, who responded and witnessed Mr. Beauford seizing. Deputy Medrano and Sergeant
Hodson moved Mr. Beauford to holding cell #1 and radio-ed for a nurse to assist them. Nurse
Velda came to assist, along with Nurse Schans, and administered oxygen to Mr. Beauford. After
a few minutes, Mr. Beauford's seizure subsided. Even after this seizure, Deputy Medrano,
Sergeant Hodson, Nurse Velda, and Nurse Schans failed to give Mr. Beauford his VNA medical
bracelet or ensure that he had taken his medication by following Ms. Marsh's instructions for
20
administering Mr. Beauford's medication.

103.
On March 1, 2014, at approximately 6:00 p.m., Mr. Beauford had another seizure.
Nurse Velda, Deputy Pucket and Deputy Draper responded to care for Mr. Beauford's seizure.
Even after this seizure, Deputy Pucket, Deputy Draper, and Nurse Velda failed to give Mr.
Beauford his VNS medical bracelet or ensure that he had taken his medication.
MCDF officials exhibited deliberate indifference to Mr. Beauford's serious medical needs.
particularlv his eoileosv, which caused Mr. Beauford's death on April 16. 2014.
104.
Mr. Beauford was housed in Cedar pod on April 15, 2014 and April 16, 2014.
105.
Deputy Dalrymple was assigned to supervise Cedar Pod during the night shift on
April 15, 2014, which encompassed the morning of April 16, 2014.
106.
Deputy Dalrymple did not speak to Mr. Beauford during the entirety of his shift
on April 15 and April 16.

107.
Deputy Dalrymple performed a head count of all inmates in Cedar pod at 6:00
p.m. and a security check at 6:20 p.m. and 6:50 p.m. During these checks, Deputy Dalrymple
reported that no inmates, including Mr. Beauford, were experiencing any issues.
108.
From 6:50 p.m. until 8:30 p.m., Deputy Perkinson performed security checks in
Cedar pod approximately every half hour by himself.

109.
Deputy Perkinson completed a security check at approximately 7:50 p.m. During
that security check, Deputy Perkinson was forced to enter Mr. Beauford's cell when Mr.
Beauford did not place his dinner tray outside of his cell. When Deputy Perkinson entered Mr.
Beauford's cell, Mr. Beauford was under his blanket, shaking and grunting. Despite Deputy
Perkinson's knowledge of Mr. Beauford's seizure disorder, he did not check to see if Mr.
Beauford was having a seizure. Instead, he simply assumed that Mr. Beauford was masturbating
21
and left the cell without as much as asking Mr. Beauford if he was having medical issues.
110.
Deputy Perkinson returned to Mr. Beauford's cell at approximately 8:30 p.m. to
assist Nurse Workman with passing out medications. When Deputy Perkinson and Nurse
Workman arrived at Mr. Beauford's cell, Deputy Perkinson observed through the cell window
that Mr. Beauford was under his blanket and shaking.
111.
Deputy Perkinson and Nurse Workman had Mr. Beauford's cell door opened, so
as to administer his medications. When they entered the cell, they found that Mr. Beauford was
suffering a seizure. Nurse Workman then rolled Mr. Beauford on his side and Deputy Perkinson
and Nurse Workman waited with Mr. Beauford until he stopped seizing. Mr. Beauford's seizure
lasted for approximately five minutes.
112.
After the seizure, Nurse Workman checked a sore on Mr. Beauford's back. Nurse
Workman did not take any steps to more closely monitor Mr. Beauford's condition. Although the
initial reason for entering Mr. Beauford's cell was the administration of medication, Deputy
Perkinson stated in an interview after Mr. Beauford's death that a no point during this visit did
Nurse Workman discuss medication with Mr. Beauford and Mr. Beauford was given no
medication during this round, when he was supposed to receive medication.
113.
After finishing their medication rounding, Deputy Perkinson and Nurse Workman
returned to Mr. Beauford's cell to check on him. Mr. Beauford refused to let Nurse Workman
check his vital signs. Again, Nurse Workman did not administer Mr. Beauford his medication or
order closer observation of Mr. Beauford.
114.
During the 8:30 p.m. medication round, Deputy Dalrymple was in the pod officer
station watching Deputy Perkinson and Nurse Workman perform the medication round. Deputy
Dalrymple observed Deputy Perkinson and Nurse Workman in Mr. Beauford's cell for a longer
22
time than was normal for the medication round.

115.
After the conclusion of the 8:30 p.m. medication round, Deputy Dalrymple asked
Deputy Perkinson why Nurse Workman and he were in Mr. Beauford's cell for an extended
period of time. Deputy Perkinson then told Deputy Dalrymple that Nurse Workman and he had
found Mr. Beauford having a seizure and that they waited in Mr. Beauford's cell until the seizure
had ended.
116.
Deputy Dalrymple performed another security check at approximately 9:00 p.m.
During the security checks, inmates are locked in their cells and deputies walk from cell to cell,
looking into each to observe the inmate.
117.
During the 9:00 p.m. security check, Deputy Dalrymple looked into Mr.
Beauford's cell. Deputy Dalrymple observed Mr. Beauford having a seizure on his bed. Deputy
Dalrymple did not open Mr. Beauford's cell or use the intercom to check on Mr. Beauford.
Instead, knowing that Mr. Beauford was at that very moment in the midst of a seizure, he
deliberately and indifferently continued on to the next cell.
118.
After finishing the 9:00 p.m. security check, Deputy Dalrymple told Deputy
Perkinson about Mr. Beauford's seizure. Deputy Perkinson told Deputy Dalrymple that Mr.
Beauford would be fme. In fact, Deputy Perkinson told Deputy Dalrymple that Nurse Workman
told him that Mr. Beauford would be fine and not to worry about the seizures he was having.
Neither Deputy Perkinson nor Deputy Dalrymple returned to Mr. Beauford's cell to check on
him after Deputy Dalrymple observed Mr. Beauford seizing during his 9:00 p.m. security check.
119.
Deputy Perkinson performed the 9:35 p.m. and 10:10 p.m. security checks.
Deputy Perkinson did not enter Mr. Beauford's cell to check his medical needs, or ifhe was
suffering seizures, during either of these checks. The next time Deputy Perkinson would see Mr.
23
Beauford, he would be dead.

120.
On April 15, 2014, Deputy Bridgette Chadd and Deputy Joshua S. Bay performed
rounds at the Cedar Pod, covering for Deputy Dalrymple during his lunch break.
121.
Deputies Chadd and Bay performed their first security check at approximately
10:50 p.m. During the 10:50 p.m. check, they saw Mr. Beauford lying on his stomach under his
blanket on his bunk and did not enter his cell to check on him. Deputies Chadd and Bay did not
knock on Mr. Beauford's cell. Deputies Chadd and Bay did not call Mr. Beauford over the
intercom.
122.
Deputies Chadd and Bay performed a second security check at 11 :20 p.m. During
the 11 :20 p.m. check, they saw Mr. Beauford lying on his stomach under his blanket on his bunk
and did not enter his cell to check on him. Deputies Chadd and Bay did not knock on Mr.
Beauford's cell. Deputies Chadd and Bay did not call Mr. Beauford over the intercom.
123.
Deputy Dalrymple returned from his lunch break at 11 :30 p.m. and resumed his
supervision of the Cedar Pod. Deputies Bay and Chadd went on their lunch break at this time.
124.
Deputy Dalrymple completed the 11 :55 p.m. security check. When Deputy
Dalrymple arrived at Mr. Beauford's cell and looked in, he saw Mr. Beauford on the ground on
his stomach with his head inside the bottom shelf of his desk. Deputy Dalrymple did not enter
Mr. Beauford's cell to check on him, knock on Mr. Beauford's door, or utilize the intercom
system to ensure that Mr. Beauford was not injured or seizing. Deputy Dalrymple elected not to
enter Mr. Beauford's cell to check on him, knock on Mr. Beauford's door, or to utilize the
intercom to check on him, even though he knew that Mr. Beauford had suffered multiple seizures
earlier in the night. He finished his security check and returned to the officer station.
125.
Twenty minutes after completing the 11 :55 p.m. security check, Deputy
24
Dalrymple decided to return to Mr. Beauford's cell and check on him.

126.
At approximately 12: 15 a.m., Deputy Dalrymple arrived at Mr. Beauford's cell
and looked inside. Deputy Dalrymple did not see any movement from Mr. Beauford and
proceeded to knock on his door to attempt to get a response from Mr. Beauford. Mr. Beauford
did not respond to Deputy Dalrymple's knocks. At this point, looking into Mr. Beauford's cell,
Deputy Dalrymple could not tell if Mr. Beauford was breathing.
127.
Instead of entering Mr. Beauford's cell, Deputy Dalrymple returned to the officer
station and called to Mr. Beauford's cell on the intercom. Mr. Beauford did not respond to
Deputy Dalrymple's calls over the intercom.
128.
Deputy Dalrymple then radio-ed for assistance, asking for a nurse and one
security officer to respond and that there was a "Code 4" in progress.
129.
"Code 4" at MCDF indicates to other officers and nursing staff that the situation
to which they are being called is not urgent and is nothing out of the ordinary.
130.
After calling the "Code 4," Deputy Dalrymple arrived at Mr. Beauford's cell and
waited for Nurse Workman and Sgt. McClelland to arrive before entering Mr. Beauford's cell.
131.
hnmediatelyupon entering Mr. Beauford's cell, Nurse Workman indicated to
Deputy Dalrymple and Sergeant McClellan that Mr. Beauford was not breathing. Deputy
Dalrymple called a "Medical Code l" over the radio, indicating a serious medical situation, and
began CPR while Nurse Workman retrieved an AED.
132.
At 12:30 a.m. Deputies Bay and Chadd both heard a call to Cedar Pod and, when
they arrived, they found Mr. Beauford on the ground with Deputy Dalrymple giving CPR.
133.
Nurse Workman returned to Mr. Beauford's cell and attached an AED to Mr.
Beauford. The AED could not detect a heartbeat and did not administer a shock to Mr. Beauford.
25
134.
Mr. Beauford was dead by the time Deputy Dalrymple, Nurse Workman, and Sgt.
McClelland entered Mr. Beauford's cell.

135.
EMS personnel would arrive a short time later and Mr. Beauford would be
officially declared dead less than 30 minutes after Deputy Dalrymple began performing CPR on
Mr. Beauford, at approximately 1:00 a.m. on April 16, 2014.
136.
The Mesa County Coroner determined, after an autopsy of Mr. Beauford, that Mr.
Beauford died of a natural death caused by seizure.

137.
After an investigation conducted by the office of Sheriff Stan Hikey, all deputies
and nurses were cleared of any wrongdoing related to the death of Mr. Beauford.
138.
In an interview conducted during the investigation into Mr. Beauford's death
performed by the Mesa County Sheriff's office, Deputy Perkinson stated that he did not
specifically recall ever seeing Mr. Beauford sleeping in odd locations, including the floor, in the
past.
139.
The individual MCDF and CSCC Defendants were aware of Mr. Beauford's
history of seizures. The individual MCDF and CSCC Defendants were aware of Mr. Beauford's
diagnosed severe intellectual disability, epilepsy, and mental illnesses, including bipolar
disorder, paranoid schizophrenia, and attention hyperactivity disorder.
MCDF has numerous unconstitutional policies, practices, and customs regarding medical
care of inmates.
140.
Upon information and belief, the CCS Defendants and Mesa County Defendants
maintained unconstitutional policies, practices, and customs regarding medical care for inmates.
141.
Defendant CCS and Defendant Mesa County had a contractual agreement by
which Defendant CCS would provide medical services at the MCDF.

142.
Upon information and belief, the contract entered into between Defendant CCS
26
and Defendant Mesa County made Defendant CCS responsible for providing medical, dental,
psychiatric, technical, and pharmaceutical, and support personnel necessary for the rendering of
health care services to inmates at the MCDF.
143.
Upon information and belief, CCS Defendants and Mesa County Defendants
failed to adequately train and supervise their jail and medical staff, amounting to deliberate
indifference to the serious medical needs of inmates presenting with epilepsy.
144.
Upon information and belief, jail personnel were not trained to care for inmates
who suffered from epilepsy, intellectual disability, attention deficient hyperactivity disorder,
bipolar disorder, and/or schizophrenia. Jail personnel were not trained as to when they were
required to notify medical personnel that an inmate needs medical attention.
145.
Upon information and belief, medical staff was not trained to treat epilepsy as a
serious medical condition. Medical staff was not trained to identify persons who were at a high
risk of epilepsy. Medical staff was trained not to provide preventative medicine to persons who
were at a high risk of epilepsy.
146.
Upon information and belief, instead of treating epilepsy appropriately, medical
staff was trained to adopt a wait and see approach, without meaningful or appropriate evaluation.
Medical staff was not trained on the importance of monitoring inmates (including taking vitals)
who were suffering from seizures.
147.
Upon information and belief, it was the custom, policy, or practice to confiscate
medical devices, including VNS medical bracelets, upon intake at MCDF. It was MCDF's policy
to confiscate medical devices, including VNS medical bracelets, upon intake at MCDF,
regardless of the medical needs of the inmate.
148.
If treated appropriately, epilepsy, while serious, is very rarely fatal.
27
149.
But for CCS and Mesa County Defendants' highly deficient training (or lack
thereof) and deliberate indifference to Mr. Beauford's known, serious medical needs, Mr.
Beauford's death could have been prevented.
150.
But for CCS and Mesa County Defendants' policy, custom, or practice that
medical staff did not need to check on inmates despite a request for medical attention, Mr.
Beauford's death could have been prevented.
151.
CCS and Mesa County Defendants' policies, customs, and practices were so far
outside of the standard of care for medical professionals as to be objectively and obviously
reckless to a layperson and deliberately indifferent to the known serious medical needs of
inmates presenting with epilepsy.
152.
Upon information and belief, it is the policy, custom, or practice at MCDF to
leave inmates who suffer from seizures in their cell and not move them to medical housing. This
policy, custom, or practice is carried out even when an inmate has had multiple seizures or has a
known history of serious seizure disorder.
153.
Upon information and belief, it is the custom, policy, or practice at MCDF to
retain inmates with severe intellectual disability, epilepsy, bipolar disorder, paranoid
schizophrenia, or attention hyperactivity disorder, and not transfer them to another facility, even
though MCDF does not have the facilities and services to properly acco=odate such inmates.
CCS Defendants have a long history offailing to provide adequate medical care in detention
facilities.
154.
At the time of the events alleged herein, Defendant CCS was a national company
with a disgraceful history of failing to provide constitutionally adequate medical care to inmates.
155.
There is an abundance of examples in Colorado, and nationwide, establishing that
the CCS Defendants and the counties that employ them are deliberately indifferent in their
28
policies, customs, and practices with respect to the medical needs, and constitutional rights, of
inmates.
156.
In McGill v. Correctional Healthcare Companies, Inc. et al., Case No. 1: 13-cv-
01080-RBJ-BNB (D. Colo.), Kenneth McGill sued Defendant CCS for deliberately indifferent
failure to provide appropriate medical care in response to a stroke he suffered at the Jefferson
County Detention Facility. Similar to Mr. Beauford's case, Defendant CCS employees, acting
with deliberate indifference, failed to take Mr. McGill to a hospital in a timely fashion where he
could have received necessary emergency medical care. This case went to trial and resulted in a
plaintiff's verdict for approximately $11 million, including the imposition of over $8 million in
punitive damages.
157.
In Revilla v. Stanley Glanz, Sheri.ff of Tulsa County, et al., Case No. 4:13-cv-
00315-JED-TLW (N.D. Okla.), several plaintiffs sued Defendant CCS in connection with three
deaths and one near fatality that occurred at the Tulsa County Jail. One plaintiff died due to
bowel perforation and sepsis after medical staff refused to transport him to the hospital despite
escalating and serious symptoms. Another detainee died from a heart attack after complaints of
chest pain were ignored for days without emergency transport. A third detainee, who had a
known history of cardiovascular problems, died after complaints of pain, nausea, and vomiting
were ignored and emergency transportation was denied. It was alleged that "[t]here is a
longstanding policy, practice or custom at the Jail of CCS/CHM/CHMO and TCSO [the jail] of
refusing to send inmates with emergent needs to the hospital ...."The United States District
Court for the Northern District of Oklahoma denied the defendants motion to dismiss and this
case is in active litigation.
158.
In Lara-Williams/Burke v. Glanz, et al, 11-CV-720-JED-PJC (N.D. Okla.), an
29
inmate named Earl Williams died after he was known to have gone days without food or water.
Mr. Williams' serious and known medical needs were ignored by CHC medical staffbecause
there was an inappropriate 'faking or malingering' diagnosis that prevented him from receiving
timely hospital care. Expressly concluding that he was faking paralysis, the nurses recklessly
ignored Mr. Williams deteriorating and dehydrated status. CHC staff moved him into a medical
'observation room' to videotape him to prove that his paralysis was fake - which it turned out
not to have been. Before he died, staff threw food at Mr. Williams and put water just outside his
reach. It was alleged in that case that the CHC-related defendants ''maintained a policy,
practice, and/or custom of severely limited the use of off-site medical, mental health and
diagnostic service providers, even in emergent situations, in disregard to the known, obvious and
excessive risks to the health and safety of inmates."
159.
In Layton v. Board of County Commissioners of Oklahoma County, et al., Case
No. 5:09-cv-01208-C (W.D. Okla.), Charles Holdstock died after the medical staff of a CCSrelated company ignored lab results that Mr. Holdstock's kidneys were not functioning properly
(and were failing to eliminate the toxic build-up of his heart medication). Mr. Holdstock was
found unresponsive on his cell floor and later died in a hospital emergency room.
160.
In Turley v. Correctional Healthcare Management, Inc., et al., Case No. 1:10-cv-
02772-REB-BNB (D. Colo.), Robert Turley experienced severe pain in his throat when a piece
of a sandwich became lodged in his esophagus. He began coughing up blood and alerted the
guards and medical personnel. The nurse who evaluated him simply gave him Tylenol and
advised him that he would have to wait to see the physician. Mr. Turley became hypoxic and
unconscious, and had to be taken by ambulance to the hospital where he underwent emergency
surgery for an esophageal perforation. Although Mr. Turley survived, he had significant medical
30
issues that resulted from Correctional Care's mistreatment.

161.
Jn Estate ofBruce R. Howard, et al. v. County ofEl Paso, Colorado et al., Case
No. 1: 10-cv-02740-CMA-MEH (D. Colo.), Bruce Howard died of a cardiac arrhythmia after
CCS staff denied him his heart medication after his arrest. During his brief incarceration, Mr.
Howard made repeated pleas to CCS medical staff for his heart medication that were ignored.
He received no treatment despite his visible shakiness and assertions that he was hallucinating.
162.
Jn Moritz v. Correctional Healthcare Companies, Inc., et al., Case No. 4: 14-cv-
00656-GFK-PJC (N.D. Okla.), Michael Moritz died in the Tulsa County Jail. CCS employees
denied his repeated requests to administer his medications. Mr. Moritz's situation became
critical, and he was finally transported by ambulance to the emergency room where he remained
on life support until his death.
163.
Jn Guerrero v. Wichita County, Texas et al., Case No. 7:14-cv-0058-0 (N.D.
Tex.), CCS employees ignored Nicole Guerrero's obvious signs oflabor and left her unattended
in a solitary cell. CCS staff then failed to transport her to the hospital for safe delivery. The
baby was purplish and in need of medical attention upon delivery, yet CCS staff did not take
steps to resuscitate the newborn or administer CPR. The baby was pronounced dead shortly after
birth.
164.
A common thread in these, and many other, cases is that CCS and related
companies ignored obvious signs and symptoms to deny inmates access to necessary, emergent
medical care. Such deficiencies are the custom, practice, and standard operating procedure of
Defendant CCS and its related entities.
165.
Various governmental institutions have repeatedly made extensive reports of
constitutional deficiencies in the care provided by CCS-related entities.
31
166.
In 2007, the National Commission on Correctional Health Care (''NCCCS")
auditors reported serious and systemic deficiencies in the care provided to prisoners by CCSrelated companies in the Tulsa jail, including failure to triage sick calls and failure to address
health needs in a timely manner.
167.
In 2008, the Department of Justice found that the jail medical program,
administered by a CCS-related entity, was constitutionally deficient in a number ofregards.

Specifically, the DOJ found problems in "providing appropriate access to medical care during
emergencies" citing a case where a woman went into premature labor and delivered a baby while
handcuffed to a chair rail. This happened after her complaints, including that her water had
broken, were ignored. The DOJ found that there were "critical lapses in getting emergency
medical care to detainees." The DOJ also noted that they had conducted a previous tour in 2003
and that, despite many years to remedy the violations found, ''we generally did not observe
improved conditions at the time of the second tour."
168.
In 2009, an Oklahoma Department of Health investigation indicated that such
deficiencies by CCS-related companies continued unabated despite the abundant notice of the
same from NCCCS and DOJ.
169.
In 2010, during a NCCCS audit, high-level employees ofCCS attempted to
fraudulently change medical records to give the appearance of compliance. NCCCS found
deficient care, deficient investigation into deaths, and a lack of timely diagnostic and specialty
services. Even after this audit, CCS did not take the corrective measures necessary to alleviate
the obvious and substantial risks to inmate health. High-level CCS employees repeatedly
brought to CCS' s attention the many serious deficiencies, including chronic failures to triage
medical requests, falsification of records, and refusals to treat inmates with life-threatening
32
conditions, but the corporation refused to make any changes to the way CCS-related companies
operated.
170.
In November 2011, the Tulsa County Jail's own retained auditor found
deficiencies in CCS's care.

171.
In 2011, U.S. Immigration and Customs Enforcement and the U.S. Department of
Homeland Security's Office of Civil Rights and Civil Liberties ("CRCL") also conducted a
review of the medical care provided by CCS and related companies, reporting: "CRCL found a
prevailing attitude among clinic staff of indifference ....", ''Nurses are undertrained. Not
documenting or evaluating patients properly."
172.
Mesa County Defendants, in contracting with CCS-related companies to provide
medical care at the MCDF, knew or should have known of these serious issues in patient care,
licensure, and accreditation of CCS-related prison programs, the findings of multiple
governmental agencies, and refusals by CCS to correct deliberately indifferent policies.
Therefore, Mesa County Defendants are liable for the selection and retention of CCS to provide
medical services.
173.
Mesa County Defendants have a non-delegable duty to provide constitutionally
sufficient medical care to inmates and detainees.

174.
CCS Defendants and Mesa County Defendants had all of the above-described
knowledge and notice prior to Mr. Beauford's deliberately indifferent treatment and injuries,
which were the result oflongstanding, systemic deficiencies in the medical care provided to
inmates by CCS, as well as the widespread company policy of refusing to send inmates with
emergency medical needs to the hospital or other off-site providers.
175.
CCS Defendants and Mesa County Defendants ratified the constitutional violation
33
by the individual Defendants by failing to administer any discipline or to take appropriate

corrective or remedial action.
FIRST CLAIM FOR RELIEF

42 u.s.c. 1983
Fourteenth Amendment; Failure to Provide Medical Care and Treatment
(Against All Individual Defendants)
176.
Plaintiffs hereby incorporate all other paragraphs of this First Amended
Complaint as if fully set forth therein.

177.
At all times relevant to the allegations in this First Amended Complaint,
Defendants were acting under color of state law.

178.
Mr. Beauford was a citizen of the United States and all of the individual
Defendants are persons under 42 U.S.C. 1983.

179.
Mr. Beauford had a clearly established right under the Fourteenth Amendment to
the U.S. Constitution to be free from deliberate indifference to his known serious medical needs.
180.
Each individual Defendant knew or should have known of this clearly established
right at the time of Mr. Beauford's death.

181.
At all times relevant to the allegations in this First Amended Complaint, each
individual Defendant knew of and disregarded the excessive risks associated with Mr.
Beauford's serious and life-threatening medical condition.
182.
Nevertheless, with deliberate indifference to Mr. Beauford's constitutional right
to adequate medical care, as provided by the Due Process Clause of the Fourteenth Amendment
to the United States Constitution, Defendants knowingly failed to examine, treat, and/or care for
Mr. Beauford's worsening condition. They did so despite their knowledge of Mr. Beauford's
serious medical needs, thereby placing him at risk of serious physical harm, including death.
Therefore, Defendants knew or were aware that Mr. Beauford faced a substantial risk of harm
34
and disregarded this excessive risk by failing to take measures to reduce it.
183.
When Mr. Beauford, and others acting on his behalf, alerted each individual
Defendant to his need for medical assistance, Defendants acted with deliberate indifference to
Mr. Beauford's readily apparent need for medical attention and his constitutional rights by
refusing to obtain and provide any medical treatment for him.
184.
All of the deliberately indifferent acts of each individual Defendant were
conducted within the scope of their official duties and employment.

185.
The acts or omissions of each individual Defendant were the legal and proximate
cause of Mr. Beauford's death.

186.
The acts and omissions of each individual Defendant caused Mr. Beauford
damages in that he suffered extreme physical and mental pain while he was in Defendants'
custody.
187.
The intentional actions or inactions of each individual Defendant as described
herein intentionally deprived Mr. Beauford of due process and of rights, privileges, liberties, and
immunities secured by the Constitution of the United States of America, and caused him other
damages.
SECOND CLAIM FOR RELIEF 1

42 u.s.c. 1983
Fourteenth Amendment; Entity Liability
(Against Defendant Hikey in his official capacity, Mesa County Defendants, and
'Plaintiffs intend to argue that the 10th Circuit case Smedley v. Corr. Corp. ofAm., 175 F. App'x 943, 946 (10th Cir.
2005) was wrongly decided and that respondeat superior should apply to private entities, such as CCS, in 1983
actions. See Shields v. Ill. Dep't of Corr., 746 F.3d 782, 795 (7th Cir. 2014) ("For all of these reasons, a new
approach may be needed for whether corporations should be insulated from respondeat superior liability uoder
1983. Since prisons and prison medical services are increasingly being contracted out to private parties, reducing
private employers' incentives to prevent their employees from violating inmates' constitutional rights raises serious
conceros. Nothing in the Supreme Court's jurisprudence or the relevant circuit court decisions provides a sufficiently
compelling reason to disregard the important policy considerations uoderpinning the doctrine ofrespondeat superior.
Aod in a world of increasingly privatized state services, the doctrine could help to protect people from tortious
deprivations of their constitutional right."). In any event, all Defendants in this matter are legally culpable whichever
standard of institutional liability is applied.
35
CCS Defendants)
188.
Complaint as if fully set forth herein.

189.
Defendant Hikey is a person within the meaning of 42 U.S.C. 1983.
190.
Mesa County Defendants and CCS Defendants are persons within the meaning of
42 u.s.c. 1983.
191.
At all times relevant to the allegations in this First Amended Complaint,
Defendant Hikey and Mesa County Defendants were acting under color of state law and had a
non-delegable duty to provide constitutionality adequate medical care for inmates.
192.
At all times relevant hereto CCS Defendants were willful participants in a joint
activity and acting under color of state law, as the legal and functional equivalent of a
municipality providing medical care to inmates.
193.
The intentional acts or omissions of Defendant Hikey, Mesa County Defendants,
and CCS Defendants were conducted within the scope of their official duties and employment.
194.
CCS Defendants' and Mesa County Defendants' deliberately indifferent and
unconstitutional policies, customs, and/or practices regarding epilepsy and provision of

constitutionally adequate medical care as described were the moving and proximate cause of Mr.
Beauford' s injuries and death.
195.
CCS Defendants, Mesa County Defendants and Defendant Hikey deliberately
indifferently failed to properly train and supervise their employees to provide necessary medical
care to detainees at the JCDF.
196.
The failures in training, supervision and policy regarding providing necessary
medical assessment and care was so obvious that the failure to provide the same was deliberately
36
indifferent to the rights of the relevant public.

197.
CCS Defendants', Mesa County Defendants' and Defendant Hikey's deliberately
indifferent customs, and failures to train/supervise, are all actionable policy decisions tbat were
moving forces and proximate causes of the violation of Mr. Beauford's constitutional rights.
198.
The policies, customs, and practices of CCS Defendants, Mesa County
Defendants and Defendant Hikey as described herein were also moving forces in and proximate
causes of the deprivation of Mr. Beauford's right to due process and of the rights, privileges,
liberties, and immunities secured by the Constitution of the United States of America, and caused
Plaintiffs other damages.
199.
The County is also directly liable for its own policies and actions that are moving
forces in this constitutional injury under the contract between Mesa County and private
Defendants, as the County was the entity that participated in negotiating and sponsoring this
contract despite the knowledge of this company's pervasive pattern of civil rights violations.
THIRD CLAIM FOR RELIEF
42 u.s.c. 1983
Fourteenth Amendment; Deprivation of Life without Due Process
(Against All Defendants)
200.
Complaint as if fully set forth therein.

201.
All Defendants to this claim, at all times relevant hereto, were acting under the
color of state law.

202.
At the time of Mr. Beauford's death, Mr. Beauford had a clearly established
constitutional right under the Fourteenth Amendment to the United States Constitution to not be
deprived of his life without due process oflaw.
203.
The acts and omissions of the individual Defendants were the moving force
37
behind and proximate cause of Mr. Beauford's death without due process oflaw.
204.
The acts and omissions of CCS Defendants and Mesa County Defendants
deprived Mr. Beauford of the rights, privileges, liberties and immunities secured by the United
States Constitution and caused him other damages.
205.
The acts and omissions in which Defendants were engaged were pursuant to the
customs, policies, and practices of CCS Defendants and Mesa County Defendants, which
encourage, condone, tolerate, and ratify deliberate indifference to the serious medical needs of
inmates by those acting under the color of state law, and the right to not be deprived oflife
without due process. Those customs, policies and practices were moving forces and proximate
causes of Mr. Beauford's death and all related damages.
FOURTH CLAIM FOR RELIEF

42 U.S.C. 12132, et seq.- Violation of Americans with Disabilities Act of 1990, as
Amended
Unlawful Discrimination and Failure to Reasonably Accommodate
(Against All Defendants)
206.
207.
At all relevant times, Mr. Beauford was a person with a disability, had a record of
a disability, or was regarded as having a disability by Defendants and other Mesa County and
CCS personnel.
208.
Mesa County is a public entity as that term is used in Title II of the ADA.
209.
Mr. Beauford was qualified to participate in the services, programs, activities, and
benefits provided to detainees at Mesa County's detention facility within the meaning of Title II
oftheADA.
210.
Defendants discriminated against Mr. Beauford based on his disabilities and

38
failed to reasonably accommodate his disabilities despite knowing that he suffered from a
number of disabilities, including an intellectual disability, epilepsy, bipolar disorder, paranoid
schizophrenia, and attention hyperactivity disorder, and related impairments and conditions. This
violated clearly established law under Title II of the ADA and its implementing regulations.
211.
Defendants had no legitimate basis for violating Mr. Beauford's rights conferred
by the ADA.
212.
The actions of Defendants were objectively unreasonable in light of the
circumstances confronting them.

213.
Defendants and other Mesa County and CCS personnel engaged in these actions
intentionally, willfully, and wantonly.

214.
Mesa County Defendants failed (and continue to fail) to properly train, supervise
and/or discipline their employees regarding the proper treatment of, and accommodations for,
individuals with disabilities and, in particular, mental disabilities.
215.
CCS Defendants failed (and continue to fail) to properly train, supervise and/or
discipline their employees regarding the proper treatment of, and accommodations for,
individuals with disabilities and, in particular, mental disabilities.
216.
This inadequate training, supervision, and/or discipline results from a conscious
or deliberate choice to follow a course of action from among various alternatives available to
Mesa County Defendants and CCS Defendants.
217.
In light of the duties and responsibilities of Mesa County Defendants personnel
and CCS Defendants personnel, the need for specialized training, supervision and discipline
regarding such decisions is so obvious, and the inadequacy of appropriate training and/or
supervision is so likely to result in a violation of constitutional rights, such as those described
39
herein, that Mesa County Defendants and CCS Defendants are liable for its failure to properly
train, supervise, and/or discipline its subordinate employees and agents.
218.
Such failure to properly train and supervise was the moving force behind and
proximate cause of the violations of Plaintiffs' federally-protected rights described herein, and
constitutes an unconstitutional policy, procedure, custom and/or practice.
219.
Mr. Beauford has been damaged by Defendants' and other Mesa County and CCS
personnel's unlawful conduct under the ADA.

220.
The acts or omissions of Defendants and other Mesa County and CCS personnel,
including the unlawful policy, procedure, custom and/or practice described herein, were the legal
and proximate cause of Mr. Beauford's damages.
FIFTH CLAIM FOR RELIEF
Medical Negligence Causing Wrongful Death
(By Living Plaintiffs Against CCS Defendants and against Defendants Workman, Velda,
Audra, and Schans)
221.

222.
CCS Defendants are private corporations that contract with Mesa County to
provide medical care and health services to inmates at the MCDF or agents of such private
corporations where conduct as described herein was engaged in within the scope of their agency.
223.
Defendants Renee Workman, Velda, Audra, and Schans are private individuals,
and not public officials or employees.

224.
CCS Defendants and Defendants Renee Workman, Velda, Audra, and Schans are
not entitled to any immunity under the CGIA or otherwise.

225.
At all times relevant to this action, Mr. Beauford was under the medical
responsibility, care, and treatment of CCS Defendants.

40
226.
Defendants Renee Workman, Velda, Audra, and Schans and other care providers
had a duty to provide reasonable medical care and treatment to detainees at the MCDF, including
Mr. Beauford.
227.
Defendants CCS had the duty to exercise reasonable care in the training and
supervision of their employees.

228.
These duties of care are informed by state law. For example, under C.R.S. 16-
3-401, ''prisoners arrests or in custody shall be treated humanely and provided with adequate
food, shelter, and, if required, medical treatment." The provision of adequate medical treatment
and humane care is a statutory and other legal obligation.
229.
Through their actions and omissions, Defendants Renee Workman, Velda, Audra,
and Schans and other care providers breached their duty of care when they knowingly failed to
assess, monitor, treat and care for Mr. Beauford, despite that fact that he was in obvious need of
immediate medical attention.
230.
Defendants Renee Workman, Velda, Audra, and Schans had nurse-patient
relationships with Mr. Beauford at all relevant times and were acting within the scope of their
employment throughout the duration of these relationships.
231.
With respect to their care and treatment of Mr. Beauford, Defendants Renee
Workman, Velda, Audra, and Schans owed him a duty to exercise the degree of care, skill,
caution, diligence, and foresight exercised by and expected of medical personnel in similar
situations. Defendants Renee Workman, Velda, Audra, and Schans breached that standard of
care and were negligent in failing to properly assess, monitor, treat, and care for Mr. Beauford.
232.
As a direct and proximate result of Defendants' Renee Workman, Velda, Audra,
and Schans having breached their duty to provide reasonable medical care and treatment to Mr.
41
Beauford, he suffered significant physical and mental pain and suffering, and other damages, and
ultimately died as a result.
233.
The CCS Defendants are vicariously liable for the negligent acts and omissions by
their agents and/or employees, including, but not limited to, those named individually herein, and
those directly liable for their own negligent failures in training, policies, and practices.
234.
CCS Defendants are also directly liable as they breached their duty to exercise
reasonable care in the training and supervision of their employees and agent in a manner that
provided the detainees under their care with reasonable medical care and treatment.
235.
CCS Defendants knew or should have known of the lack of supervision,
experience, and training among their employees and agents was likely to harm MCDF detainees
in need of medical care, including Mr. Beauford.
236.
In failing to exercise reasonable care in the training and supervision of their
employees and agents, as it relates to their providing reasonable medical care and treatment, CCS
Defendants were negligent and proximately caused Mr. Beauford's death.
237.
The negligent acts and omissions by these Defendants were a substantial and
significant contributing proximate cause of the death of Mr. Beauford.

238.
As a result of the complained of negligence, Plaintiffs hereto have suffered
damages, losses and injuries in an amount to be determined by the jury at trial. These damages
include, inter alia, pain and suffering, upset, grief, loss of society and companionship, anger,
depression, and all other purely non-economic damages as allowed under the Colorado Wrongful
Death Act.
239.
Ms. Marsh suffered and continues to suffer economic and non-economic damages
due to Defendants' negligent conduct toward her son, including, but not limited to, funeral
42
expenses and financial losses due to the death of Mr. Beauford, and non-economic damages for
grief, loss of her son's companionship, impairment in the quality of her life, inconvenience, pain
and suffering, and extreme emotional distress. Plaintiffs hereto are therefore entitled to general
and compensatory damages for such pain and suffering and emotional distress and to special
damages.
240.
Defendants' conduct was attended by circumstances of malice, or willful and
wanton conduct, which Defendants must have realized was dangerous, or that was done
recklessly, without regards to the consequences to Mr. Beauford and the Plaintiffs.
241.
Defendants consciously disregarded a substantial and unjustifiable risk that they
knew or should have known would cause the death of another.

SIXTH CLAIM FOR RELIEF
Survival
(Against all Defendants)
242.
Plaintiff hereby incorporates all other paragraphs ofthis First Amended
243.
Plaintiffs are the heirs of the Estate of Tomas Beauford.
244.
As a result of the deliberate indifference and/or negligence of Defendants as
described above, Plaintiffs have suffered injuries and damages, including, but not limited, to
funeral expenses, emotional distress and pain and suffering, and loss of enjoyment oflife.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully request that this Court enter judgment in their
favor and against Defendants, and grant:
(a)
Appropriate relief at law and equity;
(b)
Declaratory relief and other appropriate equitable relief;
43
( c)
Economic losses on all claims allowed by law;
( d)
Compensatory and consequential damages, including damages for emotional

distress, humiliation, loss of enjoyment of life, and other pain and suffering on all
claims allowed by law in an amount to be determined at trial;
(e)
Punitive damages on all claims allowed by law and in an amount to be determined

at trial;
( f)
Attorneys' fees and the costs associated with this action, including expert witness
fees, on all claims allowed by law;
(g)
Pre- and post-judgment interest at the highest lawful rate;
(h)
Any further relief that this Court deems just and proper, and any other relief as
allowed by law.
PLAINTIFFS HEREBY DEMAND A JURY TRIAL ON ALL ISSUES SO TRIABLE.

Dated this 12th day of August, 2016.
KILLMER, LANE & NEWMAN, LLP
s/ Andy McNulty
David A. Lane
Andy McNulty
KILLMER, LANE & NEWMAN, LLP
1543 Champa Street, Suite 400
Denver, Colorado 80202
(303) 571-1000
(303) 571-1001
dlane@kln-law.com
amcnulty@kln-law.com
Thomas D. McFarland
McFarland Law Offices
910 13th Street, Suite 200
Golden, CO 80401
303-277-0202, Ext 1
TmcflOO@aol.com
44
ATTORNEYS FOR PLAINTIFFS
45

Estate of Tomas Beauford v. Mesa County, Colorado, Et. Al.

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Estate of Tomas Beauford v. Mesa County, Colorado, Et. Al.

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Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 1of45

IN THE UNITED STATES DISTRICT COURT

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 2 of 45

CORRECTED SECOND AMENDED COMPLAINT AND JURY DEMAND

Mr. Beauford's preventable death occurred because of Defendants' deliberate

Throughout his time at MCDF, Mr. Beauford demonstrated clear signs of

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 3 of 45

JURISDICTION AND VENUE

brought pursuant to 42 U.S.C. 1983.

Jurisdiction is conferred on this Court pursuant to 28 U.S.C. 1331and1367.

Supplemental pendent jurisdiction is based on 28 U.S.C. 1367 because the

Venue is proper in the District of Colorado pursuant to 28 U.S.C. 139l(b). All

Correct Care Solutions, LLC, Correctional Healthcare Companies, Inc.,

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 4 of 45

Defendant Mesa County, Colorado ("Mesa County") is a political subdivision of

Defendant Correct Care Solutions, LLC ("CCS") is a for-profit Tennessee

Defendant Correctional Healthcare Management, Inc. is a for-profit Colorado

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 5 of 45

Defendant Correctional Care Solutions, LLC, Defendant Correctional Healthcare

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 6 of 45

collectively referred to as "Mesa County Defendants."

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 7 of 45

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 8 of 45

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 9 of 45

Tomas Beauford was born on July 18, 1989.

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 10 of 45

Centers, Ms. Marsh visited him regularly.

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 11of45

that she had with him:

child who is five or six years old.

Mr. Beauford was declared by a state of Colorado court to have a legal

intellectual and developmental disability pursuant to C.R.S. 25.5-10-202.

declared legally mentally incompetent. See C.R.S. 27-10.5-110.

severe intellectual disability and other mental illnesses.

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 12 of 45

Mr. Beauford had an implanted Vagal Nerve Stimulator ("VNS").

The VNS is programmed to cycle on and off, giving stimulation at regular

medications including Lithium Carbonate, Olanzapine, Oxcarbazepine, Potassium Chloride,

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 13 of 45

worsened symptoms of his intellectual disability and mental illnesses.

During Mr. Beauford's previous incarceration at MCDF, MCDF recognized that it

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 14 of 45

many concerns/conditions was listed "intellectual disability[,]" "Epilepsy[,]" "Bipolar

Importantly, on the Pertinent Information document sent to the Mesa County

Upon information and belief, MCDF is not equipped to acco=odate individuals

Mr. Beauford's VNS medical bracelet was confiscated on December 1, 2013,

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 15 of 45

On December 1, 2013, a questionnaire, officially known as a Decision Tree

Beauford had multiple reported seizures.

his seizure medication on multiple occasions.

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 16 of 45

Throughout his incarceration at MCDF from November 30, 2013 to December 3,

2014, Mr. Beauford regularly refused his medication.

Mr. Beauford's refusal of his medication is a manifestation of his intellectual

disability, bipolar disorder, paranoid schizophrenia, and/or attention hyperactivity disorder.

Center on February 25, 2014.

Officer B. Bloydstun wrote in a case report, which was given to officials at

Mr. Beauford was booked into MCDF on March 1, 2014.

arrival at MCDF on March 1, 2014.

Case 1:16-cv-00851-WYD-GPG Document 44 Filed 08/17/16 USDC Colorado Page 17 of 45

intellectual disability through a failure to comprehend simple direction.

Deputy Perkinson personally witnessed Mr. Beauford's multiple seizures during

"Mesa County Detention Facility Pre-Custody I Medical Intake[.]"