Curtis Ames 683892 NLCI
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My name is Curtis Ames and I'm an inmate at New Lisbon Correctional. I write because I am pursuing attorney assistance
with a suit for Deliberate Indifference, inadequate healthcare, and personal injury while on the job here.
To say that the healthcare I've received since being incarcerated has been spotty would be... overly generous. Here are a few highlights of the "care" I've been subject to since March of '24:
• While at Dodge Correctional, I had my Gabapentin abruptly stopped.,(I took it for Restless Leg Syndrome, but it also helped with a few other conditions.) After I complained, they trialed me on Pramipexole, which is, I've learned since, usually a drug of 3rd or 4th resort due to the prevalence and severity of side effects. I had to stop taking it quickly- due to severe side effects. (I do still have documentation for all of this.) After that, when I requested to try something else, I was told to, and I quote, "Try taking nothing for a while." 'A while,' in this case, turned out to be 6 months, because NLCI had no provider when I arrived. Other drugs, with less common and severe side effects were available- I know because I was eventually given Ropinrole, which after some dosage adjustments seems to be working out fine. Due to this delay in care, I lost so much sleep that I began hearing voices, which were encouraging me to self-harm- to "Kill yourself." Several medical requests were sent, and in the end I wound up spending 3 days in what is known as Observations"- an environment that combines total lack of privacy, huge physical discomfort and lights that never shut off. I had no mattress, blanket, or pillow; my CPAP machine was not given to me. All because they couldn't be othered to write a prescription.
• Also at DCI, I requested help for a condition that causes me to clench my jaw almost constantly, which got worse after my Gabapentin was taken away. I was told to purchase a mouth guard from one of the property catalogs for "teeth grinding at night." I explained, in as many ways as I had at my disposal, that I was NOT grinding my teeth. There was a back-and-forth in which they continued to insist that my complaint was nocturnal teeth grinding, and I would explain again that I did not want nor need a mouth guard, that the issue was pain and fatigue in the muscle and joint from jaw clenching. In the end, I wound up filing a complaint via the Inmate Complaint System, to which Health Services' response came back: "This is obviously about inmate's request for a mouth guard for teeth grinding." (Yes, I still have the paperwork.) Now, aside from the fact that they were ignoring my actual complaint, there are a few issues here:
1. I use a CPAP, with a full-face mask, because I breathe through my mouth at night, rendering a mouthguard unusable.
2. Aside from face masks for disease transmission, no one is allowed to buy ANY property from catalogs while in DCI.
The law is very clear that inmates have a right to "Adequate Health Care" (as nebulous and open to interpretation as that is); it does not state that we should PURCHASE said healthcare through a for-profit property catalog.
4. The funds which they assumed could be spent on said mouthguard were nonexistent.
5. Inmate's with 'unmet dental needs' of certain types cannot get mouthguards through HSU.
So. They offered a non-solution, for a problem I didn't have and never reported, that was unavailable, and told me to • spend ghost money on it.
• On May 21st, 2025, I suffered an injury- I caught my foot while changing in my cell and, in correcting to avoid a fall, pulled a muscle in my back. As required by the rules, I reported the injury to the officer at the desk. She said to me, and I quote, "So you want them to know your ankle is bad?" (It is, as I'll explain later on.) I replied that no, I wanted to report that I'd injured my back. DAI policy is for a CO who receives a report of an injury to file an Incident Report and ask the inmate if they need to be seen by HSU. I had a feeling given this particular officer's attitude, and the fact that she didn't ask the required question, that she was going to forego her duty- so, that night, I wrote a request to HSU myself, stating that I'd reported the injury and was attempting to treat it myself. I wrote a few paper requests to HSU as well as electronic requests to the Security Team during the next few days, inquiring about the Incident Report. On discovering, finally, that one had not been filed, I requested that the security footage be preserved from the time period during which I reported the injury to the officer. (Unfortunately, there is no audio capability [so I'm told] for those cameras, which is unfortunate- it would go a long way toward keeping the officers honest.) I filed a complaint; the Inmate Complaint Examiner said there was no evidence I'd reported the injury. (The officer pulled me aside, apologized and said she "Didn't remember" me reporting the injury, adding "And that's what I'm going to tell them.") I appealed, both times reaching the same predetermined endpoint: I am an inmate, my word means nothing. "There is
no evidence inmate reported his injury." Because of this incident, care and assessment were delayed, and I spent
multiple days in so much pain I couldn't stand up straight. After contacting HSU multiple times, I was finally seen and
given an injection of the NSAID Keterolac.
• More currently, I have just today (8/1/25 as of this writing session) received a complaint back regarding deliberate
indifference with regard to pain relief. I pointed out in my appeal that the information they used to justify denial of the
complaint was inaccurate- as of the time of the complaint, the HSU Manager had refused to make any changes to my
pain management regimen; it was only after it had been filed that I had new medication prescribed; the amount of
Acetaminophen I'm 'given is inadequate to take the recommended dosage daily (I am given 100 pills/month and told
to take 2, twice a day. This would require approximately 120 pills/month, assuming a short month.) and they justify
this by citing blood test results that indicate some loss of kidney function; as yet my request to have a re-test has
come to nothing. In addition, the final ICE Secretary's decision claims I have an order for Naproxen, which is untrue- I
HAD Naproxen, but it was changed for Meloxicam and Diclofenac ointment. Additionally, the prescription directions
from HSU do not match those sent with the medication by the manufacturer.
I have several sources of chronic pain: A surgical site on my left heel, ribs/cartilage that have been damaged
four times in the same place resulting in a rib that slips out of joint regularly, right foot pain due to arthritic changes
_and_an alteredzait.frorn,the left Achilles issue which causes me.to take all_myweight on-the-rightleg-more-often.than--- -----
not, insertional tendinitis on the right heel, a torn left bicep that wasn't surgically repaired (I missed my time window
due to a miscommunication with my health care team), arthritis in my left knee, a scrotal varicocele, the
aforementioned jaw clenching, and of course all the other issues that come along with being an overweight, middle-
aged man. When I brought this up, HSU took the opportunity to victim-blame, saying I need to lose weight. While this
is true, it's difficult to exercise when one has a repetitive strain injury in one's ankle and Fan only safely use one arm.
Further, I take multiple medications, deemed necessary by Health Services, that have side effects of... you guessed it!
Weight gain.
• And finally we come to the reason(s) for the lawsuit. I've been trying to get reasonable accommodations for a
longstanding ankle issue since September of '24 and have been consistently denied despite the issues being quite
noticeable, objectively factual, ON MY MEDICAL RECORDS and extremely painful with overuse. (One of the nurses
here by the name of Denise Valerius told me she'd gotten my medical records sent in after I reported heart
- palpitations due to a Right Bundle Branch Block- I have recently found out that was not true.) Further, I've sought a
Moderate activity level which would restrict me from being asked/told to lift heavy objects, engage in extended
physical exertion, or wOrk under time pressure. After being denied these accommodations, I was hired as a "Pots and
Pans" dishwasher in the main kitchen, which involved all three (I'd applied for the job before I'd realized how much my
physical condition had deteriorated; turning down a job can result in loss of base rate pay which I need for things like
deodorant and dental floss) and I was able to work about three and a half days before re-injuring my torn bicep.
. This was the second time I'd injured the bicep on the job, and HSU has records from both. I've shown them the
bicep, explained the injury, and asked for accommodations. Their response was that I need to self-select a job that
suits my "perceived limitations" (their exact words) in order to safely earn what passes fora living. One glaring issue
with this: under DOC/NLCI policy, I can be required to perform any job effort deemed necessary by staff- and in the
absence of medical staff acknowledging and documenting my medical issues, I can be disciplined for refusal- again, by
removal of pay, conduct reports (which under the DAI "POinttlystern" pblicy will eventually-add-up-to-a-level-where-I'll— —
be re-classified as Maximum custody level) and other consequences like job removal, cell confinement (which,
conveniently, affects my ability to come to the library, research case law and relevant policy, and do things like.., write
letters to lawyers) and anything else they can come up with.
I'd like to be able to say that the officers all have the required professionalism and humanity to forego these
opportunities for punishment, but that would be, at a minimum, hopelessly naive. I've already received three conduct
reports based on the ankle issue: One last year for refusing to injure myself pushing food carts, one for being 2
minutes late limping to the library, and a third for being late for med pass multiple times. But I digress.
• In January of 2025, I slipped on the ice while reporting for PM medication. In arresting my fall, my left ankle went
back- apparently too far and too fast for my own good. The surgical site, where my Achilles Tendon was reattached
with surgical screws after a bone spur was removed (The issue was Haglund's Deformity, a repetitive strain injury; It
became too much to bear after an accident pushing food carts in Jackson Correctional- someone pushed a heavy food
cart into me, which impacted my Achilles, causing a tear in the tendon which cascaded into needing surgery after I left
the prison system. Haglund's Deformity Excision with Gastroc Recession is the official term- they cut off the bone spur,
essentially stapled the tendon back on and loosened the calf muscle so it could recover without being pulled loose)
was injured. Like the original injury, the pain wasn't immediate- it took time for me to realize I'd even BEEN injured.
When I saw Health Services, the nurse took the opportunity to correct my terminology, but did essentially nothing.
I've been limping since this incident, and multiple attempts to get changes made to my pain meds and/or
accommodations made have met with what amounts to stonewalling. HSU denies there was even an injury. (This is an
ongoing theme.) Staff have referred to my medical concerns as a "Time management issue." They've watched me limp
around for half a year and only asked if I needed medical assistance when it directly impacts their job. I've attempted
to point out that the increased pain- as well as a lump on the tendon that didn't exist before- constitute new
symptoms and thus warrant re-evaluation, which finally got them to agree to another Special Needs Committee
session- with, of course, another copay; $7.50 may not seem like a lot but when your pay is 19 cents per hour and 70%
of that is taken for fines, court costs, and previous medical copays, it becomes a significant barrier. I need to be able to
attend things like library, classes, medication times etc without worrying about discipline for medical issues. I need to
be able to earn a living safely without re-injury. These aren't negotiable.
It's been a journey to get to this point. Along the way I've met flat refusals to adjust my pain meds- which resulted in yet
another complaint of Deliberate Indifference- as well as an order from Nurse Valerius to "Start leaving earlier for your
appointments and obligations" which worked, right up until it didn't- and I was once again subjected to the disciplinary process,
receiving a Conduct Warning (a copy of which I will enclose with this letter). Even if there are new accommodations made, or
old ones reinstated (I did have a lower-bunk restriction while in Dodge Correctional- the Special Needs Committee saw fit to
remove that restriction in response to my request for lower-tier and Moderate activity level restrictions) the fact is that I've had
appropriate care delayed for over half a year, my requests for adequate medical care have been met with indifference time and
time again, and the DOC's stance is that, since I'm still in a lower bunk and on the low tier, no harm has been done.
Furthermore; I've been instructed multiple times to purchase adequate pain relief via canteen, which is, in itself, a violation of
DAI policy.
I could be moved to an upper bunk or the upper tier at any point- and if I refuse in order to protect myself from harm,
guess what? Ticket again, probably a Major for refusing to follow orders. I'd lose my job, my position in guitar class, wind up
with no pay for at least 90 days and be that much closer to being sent to a Maximum facility.
Further, NLCI's Business Office is now claiming that, because I receive a grand total of $3.95/2 weeks in pay, I have
adequate funds to access the court system, and denied me a legal loan. They're attempting to run out the clock.
As you may be able to imagine, this treatment would be nearly intolerable for the average person. Given that I am mentally ill
with a complex diagnosis involving PTSD, for which neglect is a trigger... I will be seeking damages for mental distress as well.
The defendants I'd like to name in this suit- or these suits, depending- are: New Lisbon Correctional Institution, the State of
Wisconsin, and the members of the Special Needs Committee, a list of whose names I have in my records. I would also be
interested in a second suit against the officer who failed to make an Incident Report as required- or, possibly, folding that suit
into this one, depending on what a legal expert in this field recomMends.
The damages I'd like to seek would be something I should discuss with an attorney, but I would want compensation for my pain
and suffering, the injury, the deliberate indifference, punitive damages if possible, and of course for mental anguish.
I have a few things on my side: I've been diligent, kept documentation, have exhausted administrative remedies on
multiple issues, and have some intelligence and drive to succeed. What I don't have, however, is access to the necessary
resources, as well as the detailed legal knowledge necessary to bring these issues to fruition.
That, hopefully, is where you come in. I need a lawyer who is experienced in this field, unafraid to take on the DOC, and
who- hopefully- can protect me from retaliation.
My deadline for filing on the injury is 120 days from May 23- September 20th. I'm planning on proceeding In Forma
Pauperis to at least that point, so hopefully I don't mess up on the filing.
Please contact me at your earliest convenience- my mailing address is 2000 Progress Drive, New Lisbon WI 53950
-Curtis N. Ames, #683892
