JEFFREY L. METZNER, M.D., P.C.

3300 EAST FIRST AVENUE SUITE 590 DENVER, COLORADO 80206 _____ TELEPHONE (303) 355-6842 FACSIMILE (303) 322-2155 TAX ID #84-0848664

January 26, 2014 Nicole Mooney, Esq. MS&M Law Office P.O. Box 3089 Denver CO 80201 Re: Mr. Samuel Mandez Dear Ms. Mooney: This correspondence should serve as a supplemental report to my May 29, 2013 evaluation regarding Mr. Samuel Mandez. My recommendations in the May 29, 2013 report included the following:
Mr. Mandez is likely in need of psychiatric hospitalization, which should be relatively long term in nature, in order to attempt to more adequately treat his psychotic condition with medications and implement a psychosocial rehabilitation approach. However, I think that a clinical trial in the current Residential Treatment Program at Centennial Correctional Facility is a reasonable alternative although I have various questions about this program because it is so new and apparently evolving. I will attempt to learn more about this program and will supplement this report, if necessary, at a later time. The goals of treatment should initially focus on clinical improvement as characterized by decreased or absence of auditory hallucinations, decreased or hopefully absence of delusional thinking and decreased or absence of psychotic thinking. A more aggressive psychopharmacological approach is recommended with strong consideration regarding the use of Clozaril if Mr. Mandez has had adequate therapeutic trials of at least two different classes of antipsychotic medications. Continued encouragement to participate in a psychosocial rehabilitation approach, as I assume is available within RTP, is recommended.

I have reviewed documentation relevant to his treatment since my initial assessment which is consistent with the following information:
From April 27, 2013 to August 26, 2013, Mr. Mandez received less than 3 hours per week of therapeutic out of cell time (this includes individual therapy, group therapy, and recreational therapy). During this entire period, Mr. Mandez only received 30 minutes of individual therapy. The documentation shows he never refused any offered therapy but

Psychiatric Evaluation Re: Mr. Samuel Mandez Page 2 of 2

that 14 sessions (recreational therapy or group therapy) were cancelled due to facility needs. During this same period, Mr. Mandez was given shower time 16 times, yard time 22 times, dayroom time 17 times, 1 movie, and 1 work time (day hall, movie & work only while he was on Level 4). Assuming 30 minutes for shower time and an hour for the yard, dayroom, movie and work block, it appears during this period of time Mr. Mandez was getting roughly 3 hours out of cell therapeutic time and 3 hours of out of cell non-therapeutic time (and that is only if you count shower time as out of cell time).

It is my firm opinion that such out of cell time is grossly inadequate for Mr. Mandezs clinical needs. The 30 minutes of individual therapy during the same period of time is particularly egregious. I think that the trial treatment in an RTP setting has failed and I now recommend treatment in an inpatient setting such as is available for some inmates at CMHIP. This setting should provide two to four hours per weekday of out of room structured therapeutic activities in addition to unstructured dayroom time. Mr. Mandez his behaviors described in the chronlog are certainly associated with both his serious mental illness and personality disorder, which are exacerbated by his current conditions of confinement (i.e., being housed in a locked down setting). Remaining in such a setting will likely result in a lack of clinical improvement and, in fact, continued deterioration. Call me if I can answer any further questions.* Sincerely,

Jeffrey L. Metzner, M.D. Clinical Professor of Psychiatry University of Colorado School of Medicine
*This report was dictated via the use of voice software, which may explain the presence of any typographical errors.