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Kell, Alterman & Runstein, L.L.

P
SCOTT J. ALDWORTH
SUSAN T. ALTERMAN **,
JOHN P. ASHWORTH "
DOUGLAS S. CHIAPUZIO.CPA '
GARY P. COMPA t
WILLIAM DICKAS
ROBERT E. KABACY "*
LEE DAVIS KELL
ROBERT B. LOWRY ++
MELISSA MAY*""
WAYNE D. PALMER

ATTORNEYS AT LAW
SUITE 600

520 S.W. YAMHILL STREET


PORTLAND, OREGON 97204-1329
TELEPHONE (503) 222-3531

CLIFFORD B. ALTERMAN
(1925-1995)
ALSO ADMITTED IN

CALIFORNIA
FACSIMILE (503) 227-2980

WWW.KELRUN.COM

EMILY C. RAKE
E-MAIL; dstemman@kelrun.com

PAULA. RANEY*"
THOMAS R. RASK, 111 "
ROBIN M. RUNSTEIN

RAYMOND M. KELL
(1911-1991)

"WASHINGTON

"'GEORGIA
"COLORADO
""WASHINGTON, DC
LL.M. IN

JTAXATION

TED E. RUNSTEIN
ERIC SOGGE

++OF COUNSEL

DENNIS STEINMAN
ZACHARY WALKER"

December 5, 2014

Via Certified Mail No. 7013 2630 0000 7870

Via Certified Mail No. 7013 2630 0000 2808 7887

Return Receipt Requested

Return Receipt Requested

Michael Jordan

Suzanne Huffman, Interim Director

Chief Operating Officer and DAS Director


Oregon Department of Administrative Services

Oregon Health Authority

1225 Ferry Street, SE U150

500 Summer St. NE, E20


Salem, OR 97301-1097

Salem, Oregon 97301

Re:

Our Client:

Lisa Feehely, Personal Representative for the Estate of


Christopher Patrick Crawford

Location of Incident:

Salem, Oregon

Dates of Incident:

October 2013-January 3, 2014

Our File No.:

21675\002

ORS 30.275 NOTICE OF A CLAIM

Dear Mr. Jordan and Ms. Huffman:


Pursuant to ORS 30.275, please take notice as follows;
The undersigned attorney, Dennis Steinman of Kell, Alterman & Runstein, L.L.P. ,
represents Lisa Feehely, the Personal Representative for the Estate of Christopher Patrick
Crawford ("Claimant").
Correspondence concerning this letter should be directed to the
attention of Dennis Steinman at the address set forth above.

1.

Claimant intends to assert claims for damages against the State of Oregon relating
to the treatment of Christopher Patrick Crawford while a patient at Oregon State Hospital
("OSH") during the period leading up to and including his death on January 3, 2014. Claimant's

Michael Jordan, OR Depart, of Admin. Servs.

Kell, Alterman & Runstein, L.L.P.

Suzanne Huffinan, OR Health Authority


December 5, 2014
Page 2

claims for damages include, but are not limited to, claims for wrongful death, violations of state
whistleblower retaliation laws, and violations of the United States Constitution.
2.
The time, place and circumstances giving rise to Claimant's claims, so far as
presently known, are as follows;
On September 9, 1992, Christopher Patrick Crawford was admitted to OSH after being
found guilty, except for insanity, on certain criminal charges and placed under the jurisdiction of
the Psychiatric Security Review Board for a period not to exceed 40 years. Mr. Crawford

suffered from bipolar disorder, but was a very high functioning patient for nearly all of his time
at OSH. Beginning in late 2013, however, Mr. Crawford's physical condition deteriorated,
culminating in his death on January 3, 2014.
Mr. Crawford's decline was preceded by an event that occurred in or around August
2013. At that time, Mr. Crawford learned that an OSH nurse, Jennifer Barren, was engaged in a
sexual relationship with an OSH patient.
Mr. Crawford reported the relationship to two
supervisors at OSH, who told Mr. Crawford that they were aware of the relationship and that
Mr. Crawford should keep the information confidential.
Mr. Crawford believed that Ms. Barren's behavior was extremely inappropriate and that
OSH was asking him to collude in keeping her conduct confidential. Mr. Crawford did not
believe that this was right and made the decision to contact the media and police about the
inappropriate relationship. Mr. Crawford contacted reporters from The Oregonian and the
Statesman-Journal, both of whom investigated the information provided by Mr. Crawford and

subsequently wrote articles about Ms. Barren's inappropriate relationship.


reported Ms. Barren's conduct to the Oregon State Police.

Mr. Crawford also

After Mr. Crawford's reports to the media and law enforcement, OSH's treatment of him
changed. OSH had recently been the subject of an investigation by the U.S. Department of
Justice and many OSH employees were upset that Mr. Crawford's reports could draw additional

scrutiny to the hospital. In October 2013, OSH transferred Mr. Crawford away from the unit at
which he had been living, Bridge Two. Bridge Two was the least restrictive ward at OSH and
allowed patients the greatest level of freedom.
On Bridge Two, Mr. Crawford's limited
medication was well-managed; he was able to participate in a number of OSH's programs and
activities, and he enjoyed a relatively independent lifestyle. Without justification, Mr. Crawford
was moved from Bridge Two to Unit Bird Two. Unit Bird Two was one of the most restricted
wards at OSH where patients had constant supervision and were often heavily medicated.
Life on Unit Bird Two was much worse for Mr. Crawford. His movements were much
more restricted, and he was subjected to one-on-one monitoring, in which an OSH staff member
followed his movements at all times. He was no longer able to participate in the programs and
activities that had previously been a large part of his treatment.
Most significantly,
Mr. Crawford's

medication was changed dramatically.


Whereas, the medication that
Mr. Crawford received on Bridge Two was well-balanced and allowed him to lead a functional,

Michael Jordan, OR Depart, of Admin. Servs.

Kell, Alterman & Runstein, L.L.P,

Suzanne Huffman, OR Health Authority


December 5, 2014
Page 3

social lifestyle, the medication that he received on Unit Bird Two put him in a state of nearconstant sedation.
Not long after his transfer to Unit Bird Two and change in medication, Mr. Crawford
began expressing to his friends at the hospital that he feared for his life because of the changes
that OSH had made to his treatment. On January 3, 2014, Mr. Crawford's fears were realized
and he was found dead in his room.

The toxicology report revealed a mixture of at least eight


different drugs in Mr. Crawford's system.
OSH and its agents owed a duty to Mr. Crawford to keep him safe from harm. Instead,
OSH retaliated against Mr. Crawford because he had reported unlawful conduct of an OSH
employee to the media.
In doing so, OSH subjected Mr. Crawford to an unnecessary and
destructive medication regimen that significantly impaired his quality of life and led to his
untimely death on January 3, 2014.
OSH's employees were deliberately indifferent to

Mr. Crawford's rights and their actions were a substantial factor in his death.
If you need further information, please contact me. Thank you.
y"

Very truly yburs,

Dennis Steinman
DS:sja
cc: LisaFeehely