0001
 1     THE STATE of OHIO,   )
 2   COUNTY of CUYAHOGA.  )  SS:
 3                    - - - - -
 4          IN THE COURT OF COMMON PLEAS
 5                    - - - - -
 6   MARY WILLIAMS, etc.,      )
 7                plaintiff,   )
 8         vs.                 ) Case No.
 9                             ) 406184
10   PARMA COMMUNITY GENERAL   )
11   HOSPITAL, et al.,         )
12                defendants.  )
13                    - - - - -
14             Videotaped deposition of DEBBIE
15   BAZZO, R.N., a witness herein, called by the
16   plaintiff as if upon cross-examination, and
17   taken before David J. Collier, RPR, Notary
18   Public within and for the State of Ohio,
19   pursuant to agreement of counsel, and
20   pursuant to the further stipulations of
21   counsel herein contained, on Tuesday, the
22   30th day of January, 2001, at 4:29 p.m., at
23   Parma Community General Hospital, City of
24   Parma, County of Cuyahoga and the State of
25   Ohio.
0002
 1   APPEARANCES:
 2   ON BEHALF OF THE PLAINTIFF:
 3   Harlan Gordon, Esq.
     David Paris, Esq.
 4   Nurenberg, Plevin, Heller & McCarthy
     Standard Building - First Floor
 5   Cleveland, Ohio  44113
     (216) 621-2300
 6   
 7   ON BEHALF OF THE DEFENDANT PARMA COMMUNITY
     GENERAL HOSPITAL:
 8   
     John W. Jeffers, Esq.
 9   Weston, Hurd, Fallon, Paisley & Howley
     2500 Terminal Tower
10   Cleveland, Ohio  44113
     (216) 241-6022
11   
12   ON BEHALF OF THE DEFENDANTS WILLIAM HAHN,
     M.D. and THE WOMEN'S WELLNESS CENTER:
13   
     Patrick J. Murphy, Esq.
14   Bonezzi, Switzer, Murphy & Polito
     1400 Leader Building
15   Cleveland, Ohio  44114
     (216) 875-2767
16   
17   ON BEHALF OF THE DEFENDANTS TUNG-CHANG
     HSIEH, M.D. and PHYSICIAN STAFFING:
18   
     Jeffrey E. Schobert, Esq.
19   Hanna, Campbell & Powell
     3737 Embassy Parkway
20   Akron, Ohio  44334
     (330) 668-8960
21   
22   ALSO PRESENT:
23   Monica Keile
24   A. David Tackla, Videographer
25   
0003
 1                     I N D E X
 2   
 3   WITNESS:                  DEBBIE BAZZO, R.N.
 4                                           PAGE
 5   Cross-examination by Mr. Gordon            5
 6   Cross-examination by Mr. Schobert         85
 7   
 8                      - - - - -
 9   
10                INDEX OF OBJECTIONS
11   
12   BY MR. JEFFERS:     PAGE/LINE      PAGE/LINE
13                         37/12          79/5
14                         42/5           80/8
15                         76/8           82/16
16                         78/3           83/10
17                         78/22
18   
19   
20   BY MR. SCHOBERT:    PAGE/LINE      PAGE/LINE
21                         35/14          79/25
22                         78/5           80/7
23                         78/21          83/14
24                         79/4
25   
0004
 1                DEBBIE BAZZO, R.N.
 2   of lawful age, having been first duly sworn,
 3   as hereinafter certified, was examined and
 4   testified as follows:
 5                    - - - - -
 6             MR. GORDON:       Good afternoon.
 7             THE WITNESS:      Hi.
 8             MR. GORDON:       Mr. Jeffers
 9   introduced me, I'll repeat my name.  My name
10   is Harley Gordon, I'm one of the attorneys
11   representing the family of Mary Williams.
12             THE WITNESS:      Okay.
13             MR. GORDON:       Seated next to
14   me is my senior partner, David Paris.  He's
15   also representing the -- the family of Mary
16   Williams.  This afternoon, probably into
17   this evening, I'll be asking you questions
18   primarily involving your care and treatment
19   of Mary Williams on June 25th, 1999.  During
20   the course of my questioning, please make
21   sure you understand my question before you
22   answer it.  Did you -- do you understand
23   that?
24             THE WITNESS:      Yes.
25             MR. GORDON:       Okay.  And if
0005
 1   you don't understand a question, don't
 2   answer it, tell me to repeat it or define a
 3   term, okay, so you can understand it.  Do
 4   you understand that?
 5             THE WITNESS:      Yes.
 6             MR. GORDON:       And if you want
 7   to take a break for whatever reason, just
 8   stop us and we'll take a break, okay?
 9             THE WITNESS:      Okay.
10                    - - - - -
11                CROSS-EXAMINATION
12   BY MR. GORDON:
13   Q    Now, we'll start with your full name
14   and home address.  Can you tell us that?
15   A    Yes.  Debbie Bazzo.
16   Q    And your home address?
17   A    8750 Edgerton Road, E-D-G-E-R-T-O-N.
18   Q    Yeah.
19   A    North Royalton, Ohio  44133.
20   Q    Okay.  And are you married?
21   A    Yes.
22   Q    What's your -- what was your maiden
23   name?
24   A    Setlak, S-E-T-L-A-K.
25   Q    Did you live on this Edgerton Road
0006
 1   address in June of 1999?
 2   A    Yes, I did.
 3   Q    Okay.  Let's talk about your family.
 4   Your -- your husband's name is what?
 5   A    Donald, D-O-N-A-L-D.
 6   Q    Setlak?
 7   A    Bazzo.
 8   Q    Bazzo.  Okay.  Missed that one.  Okay.
 9   And --
10             MR. JEFFERS:      He's just
11   clever.
12   Q    How many -- do you have any children?
13   A    I have two children.
14   Q    Okay.  Is your husband in the medical
15   field?
16   A    No, he is not.
17   Q    Now, when did you become a licensed
18   nurse?
19   A    1979.
20   Q    And before that how -- let's see.
21   Where did you have your education to become
22   a nurse?
23   A    Four years at Bowling Green State
24   University.
25   Q    So you have a Bachelor's of Science in
0007
 1   nursing?
 2   A    Correct.
 3   Q    Have you had any further formal
 4   education in nursing?
 5   A    Yes, I have.
 6   Q    And could you tell us about that?
 7   A    I have a Master's degree I received in
 8   June of 1999, and I'm a women's health care
 9   nurse practitioner now.
10   Q    Where did you obtain your degree in
11   June of 1999?
12   A    Kent State.
13   Q    Okay.  And what is -- what do you do as
14   a woman's health care practitioner?
15   A    I work at MetroHealth, I've been there
16   one year, and I provide outpatient or
17   ambulatory care to well women, including
18   obstetric and gynecology.
19   Q    You still deal with postpartum ladies?
20   A    Not in the hospital, no.
21   Q    Okay.
22   A    I may see them at a six week checkup.
23   Q    Okay.
24   A    Six weeks after they've had their
25   child.
0008
 1   Q    Then --
 2   A    I don't provide in-hospital care.
 3   Q    Okay.  Are you a licensed nurse
 4   practitioner?
 5   A    Yes, I am.
 6   Q    And your specialty is obstetrics and
 7   gynecology?
 8   A    It's called women's health nurse
 9   practitioner.
10   Q    Okay.
11   A    And I'm -- it's called certified, I
12   hold a certificate of authority in the State
13   of Ohio.
14   Q    Yes, I'm familiar --
15   A    Okay.
16   Q    -- but I don't know if it was licensed
17   or -- excuse me if I misspoke.  Okay.  I
18   know it's difficult.  It's very, very
19   commendable that you have that.
20             Now, let's -- let's -- have you
21   had any further education after that in
22   nursing?
23   A    No.
24   Q    Okay.  Now, when did you begin working
25   at Parma Community General Hospital?
0009
 1   A    In 1987.
 2   Q    And you worked at Parma Community
 3   General Hospital from 1987 until when?
 4   A    1999, December.
 5   Q    Okay.  Now, had you worked in a
 6   hospital as a nurse before 1987?
 7   A    Yes.
 8   Q    Where and when?
 9   A    At MetroHealth, from 1979 to 1982, in
10   obstetrics.
11   Q    Okay.  Working on the labor and
12   delivery floor?
13   A    Postpartum and then -- yeah.  It was a
14   labor and delivery unit, it was called the
15   perinatal research unit, where we had high
16   risk obstetrical patients.
17   Q    Okay.  Then 19 -- after you left Metro
18   in 1982 and before you began here at Parma
19   Community General Hospital, where did you
20   work?
21   A    I worked at Parmadale Children's
22   Village in Parma, and I provided ambulatory
23   pediatric care to the children who lived
24   there.
25   Q    From 1982 to '87?
0010
 1   A    Um-hum.
 2   Q    Is that correct?
 3   A    Correct.  Actually, '86.
 4   Q    Okay.  And then between 1986 and '87
 5   were you employed in the nursing field?
 6   A    I had a baby --
 7   Q    Okay.
 8   A    -- took a year off, did some minor
 9   consulting in geriatric care, like one day a
10   week in '86 and '87.
11   Q    Okay.  What's your date of birth?
12   A    5-17-57.
13   Q    Okay.  Are you a member of any
14   professional associations in nursing or
15   nurse practitioner?
16   A    Yes, I am.
17   Q    And what association?
18   A    American Nurse Association, Ohio Nurse
19   Association, the National Association of
20   Nurse Practitioners in Women's Health, and
21   then Sigma Theta Tau.
22   Q    Have you ever heard of NACOG?
23   A    Yes.
24   Q    Are you --
25   A    Or AWON, or -- um-hum.
0011
 1   Q    Have you ever been a member of that
 2   organization?
 3   A    No, I haven't.
 4   Q    All right.  Have you ever testified
 5   before?
 6   A    No, I have not.
 7   Q    To prepare yourself for your deposition
 8   today did you look at any materials?
 9   A    The chart.
10   Q    And solely the chart?
11   A    Yes.
12   Q    All right.  By looking at the chart, we
13   know that you wrote certain nurse's notes
14   and other entries in Mary Williams' chart.
15   Did you prepare any personal notes --
16   A    No, I --
17   Q    -- outside of the chart?
18   A    No, I did not.
19   Q    So whatever you wrote relative to your
20   involvement in the care and treatment of
21   Mary Williams is found in her chart?
22   A    Yes.
23   Q    All right.  Now, in terms of your
24   service with Parma Community General
25   Hospital, during the period of 1987 until
0012
 1   December of 1999, what was your position?
 2   A    A staff nurse.
 3   Q    Working on what floor or floors?
 4   A    Maternity.
 5   Q    And that would include labor and
 6   delivery, postpartum and the nursery?
 7   A    Correct.
 8   Q    Okay.  Do you remember Mary Williams?
 9   A    Yes, I do.
10   Q    And why do you remember her?
11   A    I think because her mother had worked
12   here.  I did not know her mother but other
13   people had mentioned that her mother worked
14   here, so that sort of made note in my mind.
15   She had a high risk situation of
16   preeclampsia, so I took care of her
17   one-on-one that evening, and that's how I
18   remember that.
19   Q    Can you describe her for me?
20   A    White, 28 years old, average height and
21   weight.
22   Q    Hair?
23   A    Brown, I believe.  I do not remember
24   her eye color.
25   Q    Did you meet her husband?
0013
 1   A    Yes, I did.
 2   Q    And her husband was with -- was with
 3   her when you were on duty?
 4   A    For part of the time, yes.
 5   Q    What time was that?
 6   A    When I came on at 3:30, I remember him
 7   being there, and I -- I'm not sure exactly
 8   when he left.  He was not there the whole
 9   evening.  I would guess about three to four
10   hours while I was there he was there.
11   Q    And was Mary Williams' mother present
12   during your shift on June 25th, 1999?
13   A    Yes.
14   Q    The whole shift?
15   A    No.  I remember about one hour of her
16   being present.
17   Q    Now, in June of 1999, what shifts did
18   you typically work?
19   A    3:00 to 11:00 shift.
20   Q    And you -- you worked weekdays as well
21   as weekends?
22   A    Yes.
23   Q    So on June 25th, you started your shift
24   at 3:00 p.m.
25   A    Correct.
0014
 1   Q    Okay.  And at that time there was a
 2   report?
 3   A    Yes.
 4   Q    Okay.  Let's see.
 5             MR. JEFFERS:      He's going to
 6   page 159 in that book, I think.
 7             MR. GORDON:       Yes.
 8   Q    The nurse that was on the day shift,
 9   yours -- your shift is called what, the
10   evening shift?
11   A    Yes.
12   Q    The day shift nurse was Barbara Smith?
13   A    Yes.
14   Q    Okay.  And then when you had report, it
15   would have been from what time to what?
16   A    From about 3:00 to 3:30.
17   Q    And that is when all the nurses get
18   together and they go over the various
19   patients?
20   A    Yes.
21   Q    Okay.  And what did you learn at the
22   time of report about Mary Williams?
23   A    She was a vaginal delivery,
24   uncomplicated delivery in that the delivery
25   part went normal, but she did have a
0015
 1   condition of preeclampsia; that she had been
 2   stable, her recovery was finished, she was
 3   on magnesium sulfate, and I believe -- yes,
 4   she had the baby with her at that time, when
 5   I first came on.
 6   Q    And she was bonding with the baby?
 7   A    Correct.
 8   Q    She was happy she had the baby?
 9   A    Yes.
10   Q    Her husband was happy that he had the
11   baby?
12   A    Yes.
13   Q    Actually, the grandmother was too.
14   A    Yes.
15   Q    Okay.  When you say her recovery was
16   finished, could you explain that?
17   A    After a vaginal delivery, about -- for
18   the first two hours afterwards the patient
19   is considered in recovery room --
20   Q    Oh.
21   A    -- where vital signs are taken
22   frequently, every 15 minutes, and bleeding
23   and fundal status are assessed, and after
24   about two hours, if everything is stable,
25   she is released to postpartum care, we term
0016
 1   it, where vital signs are less often and
 2   assessments are less often.
 3   Q    Did you hear anything else at report
 4   that we haven't covered?
 5   A    The magnesium that she was on, did --
 6   Q    You mentioned that.
 7   A    Okay.  And that's about it.  That's it.
 8   Q    All right.  Could you tell me what
 9   preeclampsia is?
10   A    That's a condition of pregnancy where
11   blood pressure raises, there's sometimes
12   some kidney involvement, there's fluid
13   retention in the mother.
14   Q    In your career before June 25th, 1999,
15   had you ever taken care of a mother who had
16   preeclampsia?
17   A    Yes, I have.
18   Q    Both pre and postdelivery?
19   A    Yes.
20   Q    All right.  The records show that the
21   patient was in room 359 when she was brought
22   back after the delivery, around 1358.  Do
23   you remember her being in that room?
24   A    Yes.
25   Q    And how far is that room from the
0017
 1   nurse's station?
 2   A    Feet-wise, you want --
 3   Q    Yes.
 4   A    -- to know my estimate?
 5   Q    Yes.
 6   A    200 feet.
 7   Q    Okay.  And you indicated that you were
 8   the only -- strike that.
 9             You indicated that you only had
10   one patient that day.
11   A    Yes.
12   Q    And why did you only have one patient
13   that day?
14   A    It's routine when a mother has
15   preeclampsia that it's assigned one-on-one.
16   Q    Why?
17   A    Because that patient needs more
18   monitoring and close observation.
19   Q    Did anyone else assist you in caring
20   for Mary Williams during your shift?
21   A    Dr. Hsieh, the house doctor, did.
22   Dr. Shagawat was in at one point and the
23   nursing assistant.
24             MR. JEFFERS:      And what?
25             THE WITNESS:      The nursing
0018
 1   assistant.
 2             MR. JEFFERS:      Okay.
 3   Q    The nursing assistant, what's his or
 4   her name?
 5             MR. JEFFERS:      If you don't
 6   remember, you don't have to just --
 7   A    Yeah, I don't remember her name.
 8   Q    Is the nursing assistant a nurse?
 9   A    No, she is not.
10   Q    And what is she?
11             MR. JEFFERS:      She's a nursing
12   assistant.
13   A    A nursing assistant.
14   Q    No, I mean what are the duties --
15   A    She has some delegated duties.
16   Q    And what are --
17   A    And she reports to the nurse.
18   Q    What are the delegated -- well, strike
19   that.
20             What would have been the delegated
21   duties for the nursing assistant who took
22   care of Mary Williams?
23   A    She assisted with vital signs.  She
24   can -- hygiene care with the patient,
25   bathing, feeding, she changes water pitchers
0019
 1   or fills water pitchers, assists patients to
 2   the bathroom, assists with the baby, perhaps
 3   changing diapers or transporting infants
 4   back and forth to the nursery.
 5   Q    You mentioned Dr. Hsieh, Dr. Shagawat,
 6   the nursing assistant and -- who -- who
 7   participated in her care.  There's a
 8   reference that Dr. Hahn was called during
 9   the --
10   A    Yes.
11   Q    -- shift.  So Dr. Hahn also?
12   A    Yes, was called.
13   Q    Anybody else?
14   A    No.
15             MR. JEFFERS:      Excuse me.
16   Q    Then after report, am I correct, would
17   the first thing you do is go in and assess
18   the patient?
19   A    Correct.
20   Q    Okay.  In other words, you want to see
21   what's going on with the patient.
22   A    Yes.  As soon as we get finished with
23   report.
24   Q    Let's see.  I'm trying to -- your
25   assessment would have been sometime after
0020
 1   three o'clock; is that correct?
 2   A    Correct.
 3   Q    Okay.  And then -- yeah, I think it's
 4   found on -- your assessment was found on
 5   137, 138.  Could you turn to that page?  On
 6   the right-hand side, it looks --
 7   A    Um-hum.
 8   Q    It says 1615 or four -- that would be,
 9   yeah, 4:15; is that correct?
10   A    Correct.
11   Q    And this is your complete assessment?
12   A    Yes.
13   Q    All right.  Is that right?
14   A    Yes.  Along with nurse's notes.
15   Q    Yeah.  Right.  As well as the -- you
16   also have a separate section that covers
17   vital signs, right?
18   A    Right.
19   Q    Okay.  So that would cover all the --
20   all that, all that -- all dealing with your
21   assessment.
22             Turn to the bottom of page 137.
23   You have lochia rubra.  What does that mean?
24   A    That's a dark red bleeding that is
25   normal in the first three to five days after
0021
 1   having a baby.
 2   Q    Is that considered vaginal bleeding?
 3   A    Yes.
 4   Q    Okay.  Then turn to the next page, 138,
 5   and there's lochia amount small.  What does
 6   that mean?
 7   A    That's the amount of bleeding that's on
 8   a pad.
 9   Q    And how do you -- and how do you
10   characterize the lochia amount?  Do you --
11   small, is that one?
12   A    Small, moderate and large are the three
13   categories.
14   Q    Okay.  And how do you determine whether
15   the lochia is small, moderate or lar -- or
16   large?
17   A    By looking at the pad --
18   Q    Yeah.
19   A    -- and how soaked it is.
20   Q    Okay.  So you're saying vaginal
21   bleeding is common within the first three to
22   five days?
23   A    Of rubra, of the dark red.
24   Q    Okay.
25   A    Bleeding can continue for six weeks --
0022
 1   Q    Okay.
 2   A    -- after delivery.
 3   Q    And how about the amount of the --
 4   A    The time --
 5   Q    I'm sorry.  Have you finished?
 6   A    Yes.
 7   Q    And how about the amount?
 8             MR. JEFFERS:      The what?
 9   Q    How about the lochia amount, how long
10   does -- what is the typical --
11   A    Normal is considered anywhere from
12   small to moderate for the first couple of
13   days.
14   Q    Okay.  And how about after that?
15   A    It should be small.
16   Q    Okay.  When you have vaginal bleeding,
17   you also -- my mic just fell off here.
18             When you have vaginal bleeding, is
19   the vaginal bleeding confined to the pad
20   or -- or not?
21   A    No, it can be in the vagina and up in
22   the uterus.
23   Q    And also can it be on the -- seen on
24   the bedspread --
25   A    Yes.
0023
 1   Q    -- or the sheet?
 2   A    Yes.
 3   Q    Now, let's turn to your nurse's notes.
 4             MR. JEFFERS:      159.
 5   Q    They begin on 159; am I correct?
 6   A    Yes.
 7   Q    And they end on page 160; is that
 8   correct?
 9   A    Yes.
10   Q    All right.  That day did you leave at
11   eleven o'clock in the evening?
12   A    No, I did not.
13   Q    When did you leave?
14   A    I believe around midnight.
15   Q    Why did you leave at midnight?
16   A    Our shift ends at 11:30, but I believe
17   the report perhaps went a little bit over
18   that, and I do have an entry at 11:46, that
19   was my last entry, and then I left after
20   that point.  Until I change clothes and
21   punch out, it's probably midnight.
22   Q    Okay.  So typically you work from 3:00
23   to 11:30?
24   A    Yes.
25   Q    Half an hour for lunch?
0024
 1   A    Yes.
 2   Q    Okay.  Now, let's -- we're starting out
 3   at --
 4             MR. JEFFERS:      Do you want a
 5   cup?
 6             THE WITNESS:      No.
 7             MR. GORDON:       What was that?
 8             MR. JEFFERS:      I was asking her
 9   if she wanted a cup for her water.
10             MR. GORDON:       Okay.  Do you
11   want a cup for your water?
12             THE WITNESS:      No, I don't.
13   Q    Okay.  On page 159 we have an entry at
14   June -- on June 25th, 1999 at 1550, or
15   that's 3:50 p.m.; is that correct?
16   A    Yes.
17   Q    And the time after the 6-25-99, the
18   1638, that's the time you recorded the event
19   that took place at 1550; is that correct?
20   A    Right.
21   Q    Okay.  Could you read what's written
22   here at 1550?
23   A    Called to patient's room by husband.
24   Patient noted to be shaking, shivering at
25   this time.  Patient alert and oriented.
0025
 1   Answers questions appropriately.  Complained
 2   of not feeling well.  No large muscle
 3   movements noted.  Dr. Hsieh into room to
 4   assess patient.
 5   Q    Okay.  What did the husband say to you
 6   to bring you into the patient's room?
 7   A    I believe he just called to say his
 8   wife was shaking.
 9   Q    Okay.  And then when you went into the
10   room, you actually visually observed her
11   shaking and shivering?
12   A    Yes.
13   Q    Or -- and can you describe that for
14   me?  Was that the whole body or was it a
15   portion of her body, or --
16   A    I think mostly upper body, arms, chest.
17   Q    She was both shaking and shivering?
18   A    Yes.
19   Q    Okay.  Now, with a postpartum lady, is
20   this usual or unusual?
21   A    This can happen, yes.
22   Q    Okay.  Do you know what causes that?
23   A    Immediately after delivery, sometimes
24   the temperature drops, just as someone who
25   has had surgery, that's why we keep warm
0026
 1   blankets available to cover a person.  So
 2   first couple of hours afterwards it is
 3   normal to shake and shiver a little bit from
 4   temperature regulation.
 5   Q    Okay.
 6   A    My concern with her was the
 7   preeclampsia.
 8   Q    And how does the shaking and shivering
 9   relate to the preeclampsia?
10   A    Well, I wanted to assure she wasn't
11   having a seizure, which I proved by saying
12   she was alert and oriented, she never lost
13   consciousness, and I brought Dr. Hsieh in to
14   observe her also during this episode.
15   Q    Okay.  So you -- you called for
16   Dr. Hsieh because you were concerned whether
17   the shaking and shivering could be related
18   to the preeclampsia; am I correct?
19   A    Yes.
20   Q    Okay.  Did you take -- before -- before
21   we get into that, did you take her
22   temperature?
23   A    Immediately after this we did.
24   Q    Okay.
25   A    And I'm not sure where her vital signs
0027
 1   are.
 2   Q    Okay.
 3   A    What page.
 4   Q    Page 137, there should be a temperature
 5   here.
 6             MR. GORDON:       David?
 7             MR. PARIS:        Yeah.
 8             MR. GORDON:       Where's the
 9   temperature?
10             MR. JEFFERS:      You can compare
11   them with this.
12   A    Okay.  Here, June --
13   Q    Oh, here it is.
14   A    -- 26, 1615.
15   Q    You took the temperatures, 99.7?
16   A    Correct.
17   Q    Okay.  Is that normal?
18   A    Yes.
19   Q    Okay.
20   A    After delivery.
21   Q    What is the normal range postpartum,
22   within the first 24 hours?
23   A    Well, not that there's an exact, but a
24   ballpark figure might be 98.0 on up to about
25   101.5.
0028
 1   Q    101.5?
 2   A    Yes.
 3   Q    Okay.  And where did you learn that?
 4   A    It's sort of accepted, that's the
 5   standard.
 6   Q    Okay.  Because someone mentioned 100.5.
 7   I'm -- and I'm quibbling with you because it
 8   has some importance.
 9   A    Um-hum.  And I believe it to be 101.5.
10   Q    Okay.  Can you direct me to any
11   document or record which indicates that's
12   the normal range?
13   A    No, I can't.
14   Q    Okay.  Now, so let's go back to your
15   calling Dr. Hsieh.  All right.  How did you
16   call Dr. Hsieh?
17   A    From the patient's room to his call
18   room.
19   Q    And what did you tell him when you
20   reached him?
21   A    I asked him to come -- I would like him
22   to come and take a look at the patient for
23   me.
24   Q    And did he ask you why he wanted -- you
25   wanted him to see the patient?
0029
 1   A    Not that I recall.
 2   Q    Okay.
 3   A    I don't specifically remember saying
 4   what, but that I felt he should be seen --
 5   or she should be seen.
 6   Q    Okay.  Then when Dr. Hsieh got to the
 7   patient's room, did you at that point tell
 8   him why you wanted to see the patient?
 9   A    Yes.
10   Q    What did you tell Dr. Hsieh why you
11   wanted Dr. Hsieh to see the patient?
12   A    Because of the shivering that I
13   observed, and I wanted him to evaluate to
14   make sure it was not a seizure.
15   Q    Then, for instance, did you ask him to
16   see if -- whether or not the patient had
17   convulsions?
18             MR. JEFFERS:      You mean did she
19   ask that specific word?
20             MR. GORDON:       Yes.
21   A    No, I asked him to assess the
22   patient --
23   Q    With a view --
24   A    -- however he felt was appropriate and
25   fit.
0030
 1   Q    Okay.  With a -- did you express the
 2   words to assess the patient looking for
 3   possible seizures when you expressed that to
 4   Dr. Hsieh?
 5   A    I believe so, because my notes show
 6   that we checked reflexes, in the next entry.
 7   Q    That's at --
 8   A    Headache and blurred vision, and those
 9   are some of the things you check.
10   Q    You're talking about your entry at
11   15 --
12   A    15 --
13   Q    -- 55?
14   A    Correct.
15   Q    Or 3:55 p.m., found on page 160; is
16   that correct?
17   A    Right.
18   Q    Okay.  And then the patient did deny
19   headaches.
20   A    Yes.
21   Q    But the patient had blurred vision.
22   A    Patient denied headaches --
23   Q    Oh.
24   A    -- and blurred vision.
25   Q    Oh, that's what --
0031
 1   A    That's all the same.
 2   Q    Okay.  But at 1555 the patient was
 3   continuing to have shakes and shivers?
 4   A    Yes.
 5   Q    Okay.  So that shaking and shivering
 6   lasted about five minutes?
 7   A    It lasted until -- at about -- my next
 8   entry is 1605 and it had ceased at that
 9   point in time.
10   Q    So we can conclude that from 1550 or
11   3:50 to 1605 or --
12   A    Sure.
13   Q    -- 4:05 p.m., the patient was shaking
14   and shivering?
15   A    Yes.
16   Q    Was the extent of the shaking and
17   shivering, approximately 15 minutes,
18   unusual?
19   A    No.
20   Q    Now, what did you observe Dr. Hsieh do
21   in terms of his assessment of the patient?
22   A    He spoke with her, checked for
23   neurological status as far as being
24   oriented, same complaints that I had asked
25   her about of headache, blurred vision.  He
0032
 1   checked reflexes.  I believe he sort of went
 2   head to toe and did a full assessment.
 3   Q    Now, after Dr. Hsieh did an assessment,
 4   did he talk to you about the patient?
 5   A    Well, I know he called Dr. Hahn, it's
 6   in my note, he spoke with Dr. Hahn about it.
 7   Q    Okay.  But --
 8   A    And they felt she had not had a
 9   seizure.
10   Q    Okay.  The question is:  Did Dr. Hsieh
11   talk to you about the patient after he had
12   assessed her?
13   A    Stating what?
14   Q    Anything.
15   A    I'm trying to understand the question.
16   Q    Okay.
17   A    Did he talk to me?  Yes.
18   Q    And what did he --
19   A    He didn't feel she'd had a seizure.
20   Q    Okay.  Did Dr. Hsieh ask you at any
21   time while he was assessing the patient to
22   give you any information about lab values or
23   vital signs?
24   A    That he gave the vital signs to me?
25   Q    No.  No.  No.  Did Dr. Hsieh ask you to
0033
 1   give him any information regarding the
 2   patient's lab values and/or vital signs?
 3   A    No to lab values at that point in time,
 4   and yes to vital signs.
 5   Q    Okay.  And where did -- what vital
 6   signs did you tell Dr. Hsieh?
 7   A    Blood pressure and pulse and pulse
 8   oximetry.  That appears on the screen of our
 9   monitoring machine that was in the room.
10   Q    Okay.  Dr. Hsieh in his progress note,
11   which is found on page 188, and his note is
12   timed 1550 or 3:50 p.m., gives -- or
13   indicates a blood pressure of 95 over 78.
14   A    Um-hum.
15   Q    In that -- terms of that blood
16   pressure, did you give him that blood
17   pressure?
18   A    Well, I have to look at my note.
19   Q    That's on 137 or 138.
20   A    I would have given him the blood
21   pressures that appear here from the monitor.
22   Q    Okay.
23   A    At 1555 was 125 over 103.  Yes, I would
24   have read them off the monitor to him.
25   Q    Okay.  Looking at your notes of the
0034
 1   vital signs, am I correct, a blood pressure
 2   reading of 95 over 78 does not appear?
 3   A    That's correct.
 4   Q    Then another source for the 95 over 78
 5   would be the monitor which was in Mary
 6   Williams' room?
 7   A    Um-hum.
 8   Q    Is that correct?
 9   A    Yes.
10   Q    Okay.  By the way, the monitors, it's
11   called a datascope?
12   A    Right.
13   Q    I learned that from another nurse
14   earlier.
15             And that datascope gives you the
16   blood pressure, the heart rate and the pulse
17   oximeter reading; is that correct?
18   A    Yes.
19   Q    And who sets the monitor to read
20   certain -- it reads at certain periods of
21   time, right?
22   A    The nurse does.
23   Q    Okay.  Where did you set Mary Williams'
24   monitor?
25   A    At that point it looks like I was doing
0035
 1   every five minutes --
 2   Q    Okay.
 3   A    -- because of that episode of shaking
 4   she had.
 5   Q    Then did you change that, the setting?
 6   A    Yes.
 7   Q    To what?
 8   A    I did them every five minutes until
 9   4:15, and it appears every two hours I set
10   it to then.
11   Q    All right.  Am I correct though that
12   even though you set it for every two hours,
13   if you want to get a reading you can come in
14   and get a reading?
15   A    Yes.
16   Q    Yeah.  Is there -- is there -- so I can
17   understand it, when you set it for every
18   five minutes, so every five minutes blood
19   pressure, heart rate and pulse ox come up?
20   A    Correct.
21   Q    There's not a continuous reading?
22   A    No.
23   Q    And you said --
24   A    It's a sampling at every fifth minute.
25   Q    Okay.  Now, did you overhear
0036
 1   Dr. Hsieh's conversation with Dr. Hahn
 2   regarding the patient?
 3   A    I don't -- no, I did not.  He went
 4   outside and phoned Dr. Hahn.
 5   Q    Okay.  Why is it Dr. Hsieh talked to
 6   Dr. Hahn rather than you, the nurse, talking
 7   to Dr. Hahn?
 8   A    Because he made the assessment and the
 9   decision on it, that's his role, so he would
10   call the physician in that case.
11   Q    From -- you -- had you worked with
12   Dr. Hsieh before --
13   A    Yes, I have.
14   Q    -- June 25th, '99?
15   A    Yes.
16   Q    You had.
17             When Dr. Hsieh in the -- in the
18   past was called in by you to assess a
19   patient, did he typically talk to the
20   attending?
21   A    I think it depended on the situation.
22   Q    And what would -- what were the --
23   under what circumstances would he talk to
24   the attending and under what circumstance
25   would you talk to the attending?
0037
 1   A    If he felt he needed to talk to the
 2   attending, he would; if it was something he
 3   wanted me to report, he would tell me to
 4   phone the physician.
 5   Q    Okay.  Had you worked with other house
 6   officers or house physicians other than
 7   Dr. Hsieh?
 8   A    Yes.
 9   Q    When other house officers were called
10   in by you to assess a patient, did they
11   typically talk to the attending?
12             MR. JEFFERS:      Object.  Go
13   ahead.
14             MR. SCHOBERT:     Objection.
15   Q    You can go ahead and answer unless
16   he -- Mr. Jeffers tells you not to answer.
17             MR. JEFFERS:      Yeah, I said go
18   ahead.
19   A    Again, it depends on the situation.
20   They might phone the physician or tell the
21   nurse to phone with the information.
22   Q    Okay.  Then did Dr. Hsieh tell you what
23   he had discussed with Dr. Hahn after the
24   shaking and the shivering episode?
25   A    Only that she had not had a seizure,
0038
 1   and what that was was just some shivering
 2   from probably normal thermoregulation after
 3   delivery.
 4   Q    Okay.  And you were -- were you aware
 5   of any orders that were ordered by Dr. Hahn?
 6   A    At that time, no.
 7   Q    Okay.  On page 179 there is an order
 8   written at 1550 p.m., it says repeat serum
 9   magnesium at I think it's 1700 p.m.
10   A    Um-hum.
11   Q    And CBC.  Do you see that?
12   A    Um-hum.
13   Q    You do see it?
14   A    Yes, I do.
15   Q    And were you aware of that order?
16   A    Well, I'm -- I'm sure I was.  I carried
17   it out.  The blood work was done at five
18   o'clock.
19   Q    Okay.  And turning to page 42 --
20             MR. JEFFERS:      42.  In the
21   back, it's under labs.
22   Q    The labs that were ordered at 1700,
23   including the complete blood count, at least
24   the complete blood count is found on page 42
25   under the reference 1700?
0039
 1   A    Yes.
 2   Q    Okay.  Did Dr. Hsieh see the patient
 3   again during your shift?  That's your
 4   nurse's notes --
 5   A    I have to refer to my notes again.
 6   Q    That would be found on, let's see, page
 7   160.
 8   A    Here we go.  All right.
 9   Q    The -- the notes would indicate whether
10   Dr. Hsieh did or did not see Mary Williams
11   again on your shift; is that right?
12   A    My notes and the progress notes.
13   Q    The doctor's progress notes?
14   A    Correct.
15   Q    Okay.
16   A    He did not.
17   Q    Okay.
18   A    As far as I can tell from this.
19   Q    Okay.
20   A    In my note, yes.
21   Q    Outside of the records, do you have any
22   recollection of Dr. Hsieh seeing this
23   patient at any other time on your shift?
24   A    No.
25   Q    Okay.  Now --
0040
 1             MR. JEFFERS:      Could you fill
 2   that up a little?  Thanks.
 3   Q    Could you turn to page 140?
 4             MR. JEFFERS:      140.
 5   Q    Yeah.  I want to refer you to a vital
 6   sign taken at 1925 or 7:25 p.m., all right?
 7   You have a temperature of 101.6 degrees
 8   Fahrenheit --
 9   A    Yes.
10   Q    -- is that correct?  That's abnormal?
11   A    Slightly high.
12   Q    Okay.  And -- and with that
13   temperature, on page 160, you gave the
14   patient some ice packs; is that correct?
15   A    Yes.
16   Q    In particular, at 2000 hours or
17   eight o'clock, patient given ice packs to
18   back of neck for comfort related to --
19             MR. JEFFERS:      What time is
20   that, Harley?
21             MR. GORDON:       At eight o'clock
22   or 2000 hours.
23             MR. JEFFERS:      All right.
24   Q    Which reads, patient given ice packs to
25   back of neck for comfort related to elevated
0041
 1   temperature; is that correct?
 2   A    Yes.
 3   Q    And you could without a doctor's order
 4   give a patient ice packs for an elevated
 5   temperature?
 6   A    Yes.  That's an independent nursing
 7   intervention.
 8   Q    Okay.  Just like you make nursing
 9   diagnoses --
10   A    Yes.
11   Q    -- is that correct?
12             And the ice packs were on this
13   patient the rest of your shift?
14   A    No.
15   Q    How do you know that?
16   A    Because I recall I wouldn't have left
17   them on all night, or if I had, I would
18   continue to document that.
19   Q    Is there any documentation here that
20   the ice packs were removed?
21   A    No, there's not.
22   Q    Okay.  How long do you -- do you
23   contend the ice packs were on the back of
24   her neck?
25             MR. JEFFERS:      How long does
0042
 1   she contend?
 2             MR. GORDON:       Yeah.
 3             MR. JEFFERS:      I just don't
 4   like the way you said it.  You can answer
 5   that.  She can say how long it was or she
 6   thinks it was.
 7             MR. GORDON:       You can just
 8   object to my poor choice of words --
 9             MR. JEFFERS:      All right.
10             MR. GORDON:       -- but go ahead.
11   A    What I think would be 30 to 45 minutes,
12   because it would melt by then.
13   Q    Okay.  And this ice pack, can you
14   describe it for us?
15   A    It's a clear plastic bag, probably
16   eight inches long, that then I wrap in a
17   pillowcase.
18   Q    Okay.  Then after you remove the ice
19   pack, do you typically check the temperature
20   to see what effect the ice pack has in terms
21   of the temperature?
22   A    No.
23   Q    Why don't you do that?
24   A    Within a half hour like that?  I'm not
25   sure if you would see too much difference.
0043
 1   It was a comfort measure for the patient.
 2   Q    Am I correct you never took a
 3   temperature again?
 4   A    Correct.
 5   Q    So you never really evaluated the
 6   effect of you giving the patient ice packs;
 7   is that correct?
 8   A    Correct.
 9   Q    Now, could you turn under Medications
10   to page 58?  I'm going to refer you to
11   Tylenol Number 1.  Do you see that?  Do you
12   have that?
13   A    That's -- actually it's Number 3.
14   Q    Okay.  So what does the one mean?
15   A    I think that's the other part of the --
16   when you do number, that's the second line.
17   Q    Okay.
18   A    Should have crossed through there.
19   Q    Okay.  So it's Tylenol Number 3 --
20   A    Number 3.
21   Q    -- that the patient is receiving.  Am I
22   correct you gave Tylenol Number 3 to the
23   patient at 1700 or five o'clock p.m.?
24   A    Yes.
25   Q    Okay.  And does Tylenol, to your
0044
 1   knowledge, suppress a temperature?
 2   A    Yes, it does.
 3   Q    And why did you give Tylenol?
 4   A    Tylenol Number 3 has codeine in it and
 5   that's what's routinely ordered for a
 6   patient for discomfort and episiotomy
 7   pain --
 8   Q    Okay.
 9   A    -- and cramping after having a baby.
10   Q    Can we agree that since you gave
11   Tylenol at five o'clock p.m. and the
12   temperature at 7:25 p.m. is 101.6, because
13   of the Tylenol the temperature could have
14   even been higher than 101.6?
15   A    Yes.
16   Q    Now, going to page 160 -- this might be
17   helpful.  Why don't you put this on page
18   160.  Okay.  All right?  Because we're going
19   to keep actually going back to that page.
20             At 2024 or 8:24 p.m. on June 25th,
21   1999, your nurse's notes indicate, am I
22   correct, phone check with Dr. Hahn, informed
23   of patient status, orders received?
24   A    Yes.
25   Q    Okay.  Now, let's direct our attention
0045
 1   to that event.  What is meant by phone
 2   check?
 3   A    He -- I had paged him and he had called
 4   me back.
 5   Q    Okay.  Why had you paged Dr. Hahn?
 6   A    Because of the temperature elevation.
 7   Q    And why did you page Dr. Hahn with the
 8   temperature elevation?
 9   A    Because I thought it was a little bit
10   above the normal, slightly elevated.
11   Q    When did you page Dr. Hahn, if the
12   temperature were taken at 7:25 p.m.?
13   A    I believe the nursing assistant
14   probably reported it to me around
15   eight o'clock.  She routine -- routinely
16   starts at one end of the hallway and takes
17   the vital signs and moving down and then
18   comes and reports abnormals to the nurses.
19   Q    So you --
20   A    So I'm guessing that was around 8:00 or
21   five after 8:00 when she reported that
22   temperature elevation to me, I put the ice
23   on, and I probably paged him within five to
24   ten minutes of that, and he then again
25   usually within 10 to 15 minutes returns the
0046
 1   call.
 2   Q    Okay.  Just to stop here for a minute,
 3   at -- for the temperature at -- of 101.6 at
 4   1925 or 7:25 p.m., there's the initials PKH,
 5   and --
 6   A    That's the nursing assistant.
 7   Q    Okay.  Do you remember now who that --
 8   A    Pam Honeycut.
 9   Q    Okay.  All right.  Now, when Dr. Hahn
10   called you back, could you tell me in as
11   great detail as possible what you discussed
12   with Dr. Hahn at that time?
13   A    When I phone a physician, I usually
14   report anything out of the ordinary.  I
15   don't report normal findings.  So I informed
16   him of the temperature at that time.
17   Q    All right.
18   A    Also I informed him she was complaining
19   of some rectal and vaginal pressure, which I
20   had assessed, there was nothing abnormal, as
21   my note shows.
22   Q    Anything else you -- that you told
23   Dr. Hahn at that time, which would have been
24   2024 or 8:24 p.m.?
25   A    That I had given her Tylenol at
0047
 1   five o'clock.
 2   Q    Why did you tell Dr. Hahn that you had
 3   given the patient Tylenol at five o'clock?
 4   A    Because it can lower a temperature
 5   sometimes.
 6   Q    Okay.  Did you tell Dr. Hahn that you
 7   had given the patient ice packs?
 8             MR. JEFFERS:      I couldn't hear
 9   that.  Ice packs?
10             MR. GORDON:       Had -- I'll
11   start over.
12   Q    Had sorry.  Did you tell Dr. Hahn that
13   you had given the patient ice packs?
14   A    I don't recall if I did or did not tell
15   him that.
16   Q    How about according to your custom and
17   practice, would you have done that?
18   A    I would say no because it's, as I said,
19   an independent nursing intervention that I
20   do for patient comfort.
21   Q    Okay.  So you told Dr. Hahn of the
22   temperature of 101.6 degrees Fahrenheit; is
23   that correct?
24   A    Yes.
25   Q    You indicated that you normally don't
0048
 1   tell the doctor normal values.  Since the
 2   rectal/vaginal pressure was normal, why did
 3   you tell that to Dr. Hahn?
 4   A    Because the patient had complained
 5   about it and then I had assessed that there
 6   was no hematoma or bleeding forming there.
 7   Q    To account for the rectal or vaginal
 8   pressure --
 9   A    Yes.
10   Q    -- is that what you're saying?
11   A    Yes, and no hemorrhoids.
12   Q    Okay.  Did you tell Dr. Hahn anything
13   else?
14   A    Probably we went through her other
15   vital signs, her blood pressure, pulse, the
16   pulse oximetry.
17   Q    Okay.  And -- and could you turn to
18   page 42?  This is where we had the lab
19   values.  Okay.
20   A    Oh.  42.
21   Q    Did you get them?  Here, I'll give you
22   another sticker, all right?
23             Did you -- well, let me start
24   over.  Looking at the white -- strike that.
25             Looking at the complete blood
0049
 1   count --
 2   A    Um-hum.
 3   Q    -- on page 42 at 1700 hours --
 4   A    Yes.
 5   Q    -- you have a white blood count of
 6   16.1.  That's abnormal; is that correct?
 7   A    In pregnant women they can run higher
 8   and still be considered normal.
 9   Q    Okay.
10   A    Slightly elevated can be considered
11   normal.
12   Q    All right.  Well, even with a
13   postpartum patient --
14   A    Yes.
15   Q    -- is the 16.1 abnormal?
16   A    I would not consider it excessively
17   abnormal, no, and it was not much different
18   from the 11:00 a.m. one.
19   Q    Okay.  So you said excessively
20   abnormal.  Would you consider the 16.1,
21   first of all, as elevated for a postpartum
22   lady?
23   A    I would say no.
24   Q    Okay.  See the bands are 13?
25   A    Um-hum.
0050
 1   Q    What's the normal range?
 2             MR. JEFFERS:      For a
 3   postpartum?
 4             MR. GORDON:       No, let's start
 5   off --
 6             MR. JEFFERS:      Oh, for anyone?
 7   Q    What is the normal range, period?
 8   A    I don't recall.
 9   Q    Okay.  What's the normal range for a
10   postpartum patient?
11   A    I don't recall.
12   Q    Okay.  Did Dr. Hahn ask you to give him
13   any of the lab values, including the
14   complete blood count, at 8:25 -- 8:24 p.m.?
15   A    That I don't recall.
16   Q    Okay.
17   A    I know Dr. Shagawat had looked at those
18   results and she has an entry, I believe.
19   Q    All right.
20   A    At 5:30.  Let me --
21   Q    According to your custom and practice,
22   would you have given the lab values
23   indicated at 1700 on page 42?
24             MR. JEFFERS:      To whom?
25   Q    To Dr. Hahn.
0051
 1   A    No, because I had assumed Dr. Shagawat
 2   had reviewed them.  They were in her note at
 3   5:30.
 4   Q    Okay.
 5   A    She's his partner.
 6   Q    Look -- so looking at the lab values on
 7   page 42 at 1700, you can't -- are there any
 8   of those lab values abnormal?
 9   A    It's not really mine to say whether
10   they're abnormal or not.  It's my job to
11   report them to the physician so they're
12   aware of them, and Dr. Shagawat had seen
13   them at 5:30.
14   Q    Well, when you do have -- say a phone
15   check -- let's -- let's say you do -- you
16   get a call from a doctor, okay?
17   A    Um-hum.
18   Q    And he asks you to give him the lab
19   values.
20   A    Yes.
21   Q    What do you do?
22   A    I read them -- read them to him, down
23   the list.
24   Q    Okay.  Do you have doctors who say just
25   give me the abnormal values?
0052
 1   A    No, usually they want to know
 2   everything they ran.
 3   Q    Okay.  Okay.  On page 140, we have
 4   lab -- I'm sorry.  We have vital --
 5             MR. JEFFERS:      Hold it.  Hold
 6   it.  She's not there yet.
 7   A    140.
 8   Q    140.  Yeah.  2015 or 8:15 in the
 9   evening.
10   A    Um-hum.
11   Q    Under vital signs we have a pulse of
12   102, okay?  What is the normal range for a
13   postpartum lady?
14   A    Anywhere from about 100 -- 90 or 80 to
15   could go as high as 115, 120.
16   Q    Okay.
17   A    Right after delivery.
18   Q    And how about respiration rate, what's
19   the normal respiration rate?
20   A    18 to about 22.
21   Q    With a respiration rate of 22, is that
22   considered normal or abnormal?
23   A    Normal.
24   Q    Okay.  Did you --
25             MR. JEFFERS:      I was busy
0053
 1   sneezing when you were asking that.  What
 2   time was that?  Was that 2015?
 3             MR. GORDON:       2015.
 4             MR. JEFFERS:      Thank you.
 5             MR. GORDON:       Okay.
 6   Q    Did Dr. Hahn at this conversation you
 7   had with him at 2024, 8:24 p.m., ask you
 8   basically what you feel is going on with the
 9   patient?
10   A    No, I don't think he asked for my
11   personal opinion.
12   Q    Okay.  Did he ask you what the
13   patient's condition was?
14   A    "Condition" meaning what?
15   Q    Stable or unstable?
16   A    What I wrote --
17   Q    Stable or unstable?
18   A    Stable, with a slight temperature
19   elevation.
20   Q    Okay.  Would you -- strike that.
21             Did Dr. Hahn ask you whether the
22   vital signs were stable or unstable?
23   A    I believe we reviewed the other ones,
24   yes, and I said they were stable.
25   Q    Okay.  Do you remember anything else
0054
 1   about the conversation with Dr. Hahn?  And
 2   we're going to exclude what orders he gave.
 3   A    Oh, okay.  No, nothing else.
 4   Q    Did Dr. Hahn tell you, for instance,
 5   what he thinks -- what he thought was going
 6   on?
 7   A    No.
 8   Q    Did Dr. Hahn tell you to recheck the
 9   temperature within a certain time frame?
10   A    No.  Usually within four hours.  A
11   normal vaginal delivery, we -- it's ordered
12   only once every eight hours, but in her case
13   with an elevation you might get it in four
14   hours, which is half that time.
15   Q    But did -- the question is a little
16   different.  Did Dr. Hahn ask you to check
17   the temperature at a particular time?
18   A    No, he did not.
19   Q    Okay.  We know that you can get
20   readings of the blood pressure and the heart
21   rate, let's say every five minutes.  Is
22   there some way to get temperature readings
23   periodically, more frequently than four
24   hours, other than by doing it manually?
25   A    Not that we have a -- not that I'm
0055
 1   aware of --
 2   Q    All right.
 3   A    -- on any monitoring system we have.
 4   Q    What does it take to get it, a
 5   temperature, in June of 1999?
 6   A    A thermometer under the tongue.
 7   Q    And how long do you wait?
 8   A    The machines we have beep when they're
 9   finished.  It's probably three to four
10   minutes.
11   Q    And that was true in June of 1999?
12   A    Yes.
13   Q    Now --
14             MR. JEFFERS:      179.
15             MR. GORDON:       What's that?
16             MR. JEFFERS:      Page 179, it
17   should be.
18             MR. GORDON:       Are you trying
19   to help me here?
20             MR. JEFFERS:      I'm just trying
21   to expedite it.
22   Q    Okay.  Now, on page 179, as Mr. Jeffers
23   indicates, there are some orders written at
24   2020 or 8:20 p.m.; am I correct?
25   A    Yes.
0056
 1   Q    And these are the orders that you wrote
 2   after talking with Dr. Hahn; is that
 3   correct?
 4   A    Correct.
 5   Q    Can you read those orders for us?
 6   A    They say obtain urine sample from
 7   catheter for C and S.
 8   Q    What is C and S?
 9   A    Culture and sensitivity.
10   Q    Okay.
11   A    Labs, magnesium sulfate level, SGOT,
12   SGPT and CBC, Q six hours.
13   Q    And CBC is a complete blood count?
14   A    Correct.
15   Q    Okay.  And underneath that you put down
16   telephone order, Dr. Hahn, and then you
17   wrote your name?
18   A    Yes.
19   Q    What's written after your name?
20   A    That's the secretary who then takes the
21   order off and enters it in the computer.
22   Q    Okay.  Okay.  Dr. Hahn has indicated
23   that he -- strike that.
24             In what we have just read, the
25   order on page 179, does that include a
0057
 1   urinalysis?
 2   A    No, it does not.
 3   Q    Okay.  What's a urinalysis?
 4   A    That is an analysis of the urine for a
 5   number of things, specific gravity, pH.
 6   Q    And bacteria?
 7   A    Yes.  Leukocytes and nitrites.
 8   Q    Okay.  And what's -- what's the purpose
 9   of taking a urine sample for culture and
10   sensitivity, as you understand it?
11   A    To rule out an in -- bladder infection.
12   Q    Okay.  And urinalysis is also done to
13   rule in or rule out a bladder infection; is
14   that correct?
15   A    At times, yes.
16   Q    Okay.  You wrote the order found on
17   page 179 at 2020 as Dr. Hahn told you to
18   write it?
19   A    Yes.
20   Q    Dr. Hahn has indicated that he told you
21   to order a urinalysis.  Did Dr. Hahn tell
22   you to order a urinalysis?
23   A    No.  If he did, I would have wrote it.
24   Q    How do you know that?
25   A    Because I usually write every order a
0058
 1   physician gives me.
 2   Q    And how do you do that?
 3   A    I write it on a scrap sheet of paper or
 4   as they're giving it to me, I write it right
 5   on the order sheet, as I'm on the phone with
 6   them.
 7   Q    Are you saying then that Dr. Hahn did
 8   not ask you to get a urinalysis?
 9   A    Yes.
10             MR. JEFFERS:      Yes, he did
11   not?
12   A    He did not.
13   Q    Okay.  And you, as a nurse, one of your
14   duties is to write down the orders as given
15   to you by a physician?
16   A    Correct.
17   Q    And if you don't do that, you breached
18   your duty; is that correct?
19   A    Yes.
20   Q    Did Dr. Hahn in his conversation with
21   you indicate that he was thinking that the
22   patient might be infected?
23   A    I think the orders reflect that.  I
24   don't think in the conversation he
25   specifically said that, but when you order a
0059
 1   culture and sensitivity, you're looking for
 2   a reason maybe for the temperature elevation
 3   in a urinary infection and then by repeating
 4   the CBC.
 5   Q    Okay.  Did Dr. Hahn express to you his
 6   thinking as to what was going on with the
 7   patient at 8:24 p.m. when you talked to him?
 8   A    No.
 9   Q    Did Dr. Hahn ask you to closely observe
10   the patient?
11   A    Those words specifically, no.
12   Q    Or something to that effect?
13   A    I was already watching her closely.
14   She was my only patient.
15   Q    Okay.  Is there anything else that you
16   remember about your conversation with
17   Dr. Hahn that we haven't covered at this
18   point, at 8 -- 8:24 p.m.?
19   A    I believe that we did discuss that some
20   temperature elevation is normal in the first
21   24 hours postpartum, but this was not a
22   highly abnormal finding, that it could be
23   just attributed to normal dehydration of
24   just being delivered.
25   Q    And also it could be an infection?
0060
 1   A    Well, that's why we have those couple
 2   of orders.
 3   Q    Okay.  Now, could you turn to the
 4   medication sheet on page 58?  Back to
 5   Tylenol Number 3.  We know that at 1700 you
 6   gave Tylenol to patient -- or 5:00 p.m. is
 7   that the -- is that your --
 8   A    That's --
 9   Q    -- indication that you gave Tylenol
10   again?
11   A    At 2100.
12   Q    That would be at --
13   A    9:00 p.m.
14   Q    -- nine o'clock.  Okay.  And you gave
15   Tylenol at that time for what reason?
16             MR. JEFFERS:      Is this at --
17   what -- what page are we on?
18             MR. PARIS:        9:00 p.m.
19             MR. GORDON:       9:00 p.m., over
20   here.
21             MR. JEFFERS:      Okay.  Got it?
22   A    And that was due to the 8:15 complaint
23   of the patient of the perineal pressure and
24   discomfort from her episiotomy, and that is
25   what we give for episiotomy pain.
0061
 1   Q    Okay.
 2   A    And that's when she could have it
 3   again, was
 4   nine o'clock.  It was ordered every four
 5   hours as needed.
 6   Q    Okay.  Then according to the nurse's
 7   notes at -- on page 160, at 2130, or 9:30
 8   p.m., patient transferred to room 351 via
 9   bed.  That's what happened at that time?
10   A    Yes.
11   Q    Why was the patient transferred from
12   room 359 to 351 at that time?
13   A    Usually the patients on magnesium
14   sulfate, we like to keep them closer to the
15   desk, and I am thinking that at
16   three o'clock, when she was first moved out
17   of recovery, that room was not available,
18   that's why they hadn't put her there
19   originally.
20   Q    Yeah.
21   A    They had her in 59.  You know, I don't
22   know the flow of the unit.  I think maybe
23   there had been a discharge, we cleaned the
24   room, we were able to bring her a little
25   closer, because they need a little more
0062
 1   frequent observation, you don't have to run
 2   all the way down the hall.
 3   Q    All right.  Now, you have an entry also
 4   on page 160 at 2346, 11:46, lab here, blood
 5   work drawn.  Do you see that?
 6   A    Yes.
 7   Q    Okay.  That lab work, does that relate
 8   to the order of 2020 in which it was -- it
 9   says C -- complete blood count was supposed
10   to be drawn every six hours?
11   A    Correct.
12   Q    Okay.
13   A    It was done at five o'clock, so we were
14   repeating at 11:00.
15   Q    Okay.
16   A    That was six hours later.
17   Q    And who would begin the process of
18   getting the complete blood count?  Is it the
19   process -- does that begin with after the
20   order is written and the secretary takes it
21   off --
22   A    Yes.
23   Q    -- and she puts it in a computer --
24   A    Yes.
25   Q    -- for a time when the lab is supposed
0063
 1   to draw the blood?
 2   A    Yes.
 3   Q    And you were there when the blood was
 4   drawn for the --
 5   A    Yes.
 6   Q    -- complete blood count?
 7             Were you there when the results
 8   came back?
 9   A    No.
10   Q    You had already left --
11   A    Yes.
12   Q    -- at twelve o'clock.
13   A    Yes.
14   Q    Okay.  Now, on page 42 at 2330 --
15   you're on page 42?
16   A    Yeah.
17   Q    Yeah.  This relates to the labs that
18   were -- that you indicated that blood -- the
19   blood was drawn at 2346; is that correct?
20   A    Yes.
21   Q    Okay.
22   A    Close to that time.
23   Q    Okay.
24   A    Looks like it says 2330.
25   Q    Okay.  With respect to the bands here
0064
 1   of 52, that's abnormal?
 2   A    Well, it's a big difference from what I
 3   had at five o'clock, and, yes, I would say
 4   that's abnormal.
 5   Q    Okay.  And the neutrophils of 33 are
 6   abnormal?
 7   A    Not that -- I don't recall actual
 8   numbers for abnormals, but that's a big
 9   difference from what had been --
10   Q    Okay.
11   A    -- found prior.
12   Q    And also there's a big drop from 16.1
13   white blood count at 1700 to 4.6 at 2330; is
14   that correct?
15   A    Correct.
16   Q    And do you know as a nurse that if
17   there is such a drop in a white blood count,
18   that may be a sign of an infection?
19   A    Yes.
20   Q    And the neutrophils are 33.
21             MR. JEFFERS:      We talked about
22   that.
23   Q    I'm sorry.  I wanted to talk to you
24   about the P next to the 33 of neutrophils.
25   What does P mean, do you know?
0065
 1   A    No, I don't.
 2   Q    Did you ever hear of metamyelocytes?
 3   A    No.
 4   Q    So you don't know what are normal
 5   values or abnormal?
 6   A    Met --
 7   Q    Metamyelocytes.
 8   A    (Shaking head.)
 9   Q    You never heard of that?
10   A    Never heard of that --
11   Q    Okay.
12   A    -- terminology.
13   Q    Okay.  So looking at the 2330 lab
14   values on page 42, where it says meta, you
15   don't -- do you know what that means?
16   A    Oh.  Say the question again?
17   Q    Do you know what meta means that's
18   shown on this --
19   A    No, I don't.
20   Q    -- lab sheet, 42?
21   A    Other than you mentioned the
22   metamyelocytes.
23   Q    Okay.  And --
24   A    That's --
25   Q    -- also the 2330, where it has
0066
 1   platelets, 114, that's abnormal?
 2   A    Actually, am I aware of a --
 3   preeclamptic patients, you don't get
 4   concerned until they're below 100.
 5   Q    Okay.
 6             MR. JEFFERS:      What did you say
 7   the platelets showed?
 8             MR. GORDON:       114.
 9             MR. JEFFERS:      Okay.
10             MR. GORDON:       With an L.
11             MR. JEFFERS:      Right.
12   Q    Okay.  In terms of lab values, for
13   instance, if a physician is in the hospital
14   and they ask you to give him the lab values,
15   let's say as of June, 1999, one way you can
16   give them the lab values is by having a
17   printout from the computer?
18   A    Yes.
19   Q    Is that correct?
20   A    Yes.
21   Q    And does the printout give you not
22   only -- let's say if you ran the printout
23   sometime after 2330 and the results have
24   been reported, does the printout give you
25   not only the results at 2330 but earlier
0067
 1   results?
 2   A    No, I think the printout just gives you
 3   those results.
 4   Q    Okay.  You've had situations in which
 5   the physician asks you for the lab values
 6   and you get a printout and you give it to
 7   him?
 8   A    Right.
 9   Q    And you've had situations in which,
10   again, the physician asks you for the lab
11   values and you just -- you report to him
12   both the normal and abnormal?
13   A    Yes.
14   Q    Or you had the physicians themselves
15   access the computer to get the lab values,
16   without asking you?
17   A    Yes.
18             MR. JEFFERS:      I want to add
19   something, because I don't want this record
20   to sound funny, and what the reason is is
21   that if somebody wanted to go back and look
22   to see what the other lab values were, they
23   could, so I -- you -- the way you asked the
24   question and the way it comes out, there's
25   an implication possibly that they're not
0068
 1   accessible, but they are accessible.
 2             MR. GORDON:       What do you
 3   mean?  That's my next series of questions,
 4   but thank you for --
 5             MR. JEFFERS:      Okay.  Well,
 6   then I've answered them.
 7   Q    So as Mr. Jeffers indicates, if you
 8   want to get not only, after 2330, the
 9   results of the 2330 but the previous lab
10   values for a complete blood count, there's a
11   means by which you can access that on the
12   computer?
13   A    Yes.
14   Q    And what do you do in that regard, do
15   you remember?
16   A    How to look it up on the --
17   Q    Yeah.
18   A    -- computer?
19   Q    If you don't then we can go on, but it
20   doesn't take too much of an operation to do
21   that?
22   A    No, it doesn't.
23   Q    Okay.  And when you -- the printout
24   regarding the lab values, does it also have,
25   like we have on page 42, reference to like
0069
 1   H, L, P?
 2   A    Yes.  I've seen H and L's.
 3   Q    Okay.  And does the written printout
 4   from the computer for lab values also have
 5   the normal ranges, if you can remember?  If
 6   you can't, we --
 7   A    I think -- I think they do.
 8   Q    All right.  Then, since you were
 9   leaving -- supposed to leave at 11:30,
10   Ms. Prokop began her tour of duty at
11   eleven o'clock?
12   A    Correct.
13   Q    And then again, you had a report at
14   11:00 until 11:30.
15   A    Yes.
16   Q    Okay.  And during the report, what did
17   you say regarding Mary Williams?
18   A    We went through the usual information
19   about her delivery, the medications she were
20   on, was on, the magnesium sulfate, what her
21   vital signs were.  I know we discussed the
22   temperature, that I had medicated her twice
23   with the Tylenol on my time, because that's
24   routinely a part of report, when we give out
25   pain medication, and the upcoming lab work
0070
 1   or the labs that were just done or were due
 2   to be done.  I maybe had started report at
 3   say ten after 11:00 and they had come up
 4   right toward the end of that to obtain those
 5   laboratories.
 6   Q    Have you completed your answer?
 7   A    I -- I did want to say I think I
 8   reported to her about Mary's complaint again
 9   at 10:15 about the pressure in her bottom
10   and her vagina, which we -- I had checked
11   over again and felt she was just feeling
12   normal things that postpartum women feel
13   when they have an episiotomy.
14   Q    You're talking about 2015?
15   A    2215, she complained --
16   Q    Of vaginal pressure.
17   A    Um-hum.
18   Q    Is that right?
19   A    Yes.
20   Q    And also that -- complained of
21   rectal/vaginal pressure --
22   A    Yeah.
23   Q    -- earlier, 2015.
24   A    Right.  The perineum is a tender area
25   after delivery, so that's a common
0071
 1   complaint.
 2   Q    Okay.
 3   A    And that I had medicated her for pain
 4   for that.
 5   Q    Did you during the report indicate that
 6   earlier on your shift there had been shaking
 7   and shivering?
 8   A    Yes.
 9   Q    Did you express any concern that you
10   had regarding the patient during the report?
11   A    Nothing other than what I already
12   mentioned.
13   Q    Then, just to clarify one thing, the
14   labs that were -- were to -- strike that.
15             The labs, that would be the
16   complete blood count, at report you had
17   indicated that the labs were to be drawn
18   around eleven o'clock and they hadn't been
19   done yet?
20   A    Right.
21   Q    Okay.  So at least the Nurse Prokop
22   would know that the labs have to be drawn
23   and the results looked at?
24   A    Soon, yes.
25   Q    Was the last time you saw Mary Williams
0072
 1   at 2346 or 11:46 on June 25th, 1999?
 2   A    Yes.
 3   Q    What was her condition at that time?
 4   A    As I noted, she was resting and was
 5   dozing at intervals.  They had woken her up,
 6   I assume, to do the lab work, and I have
 7   patient dozing at intervals.
 8   Q    Where is that, what time?
 9   A    2346, after the lab work.
10   Q    Okay.  The next entry is at 20 --
11   strike that.
12             The next entry on page 16 -- 160
13   after 2346 is 0030 or 12:30 a.m. on
14   June 26th, 1999.  In that regard, were you
15   there at that time?
16   A    No, I was not.
17   Q    Okay.  Was Mary Williams at all anxious
18   or restless during your shift?
19   A    I wouldn't say anxious.  She seemed
20   overly concerned about her bottom perhaps.
21   Q    Okay.  Was she restless?
22   A    What's your definition of restless?
23   Unable to --
24   Q    Well, how do you interpret --
25   A    Restless?  Unable to relax, sleep,
0073
 1   maybe moving around in bed, not able to get
 2   comfortable.
 3   Q    Okay.  Was Mary Williams restless at
 4   all during your shift?
 5   A    I guess I would say yes then, because
 6   of this bottom discomfort, that was
 7   bothering her.
 8   Q    Okay.
 9             MR. JEFFERS:      Now we're going
10   to get into negligence questions.
11             MR. GORDON:       No, we -- we
12   aren't going to go into that at this point,
13   but we're going to go into some other areas.
14             MR. JEFFERS:      Can you give me
15   an idea of how long we're still going,
16   roughly?
17             MR. GORDON:       Until I finish.
18             MR. JEFFERS:      Pardon me?
19             MR. GORDON:       Until I finish,
20   which should be around --
21             MR. JEFFERS:      I know.  Just
22   roughly.
23             MR. GORDON:       We'll be out of
24   here within the next 15 minutes on this.
25             MR. JEFFERS:      Oh, okay.  Thank
0074
 1   you.
 2             MR. GORDON:       Unless you want
 3   me to shorten it in some way.
 4             MR. JEFFERS:      Sure, shorten
 5   it.
 6             MR. PARIS:        We'll make it 14
 7   minutes.  Very good.
 8             MR. SCHOBERT:     See if you can
 9   do it within 20.
10   BY MR. GORDON:
11   Q    Have you ever -- before June 25th,
12   1999, ever asked a house physician to assess
13   a patient for vaginal bleeding?
14   A    Yes.
15   Q    Okay.  And when you do that, do you
16   document in your nurse's notes that the
17   patient had vaginal bleeding?
18   A    Yes.
19   Q    Other than in the area where you
20   evaluate the lochia --
21   A    Yes.
22   Q    Okay.
23   A    Exactly.
24   Q    You actually put it in your narrative
25   nurse's notes?
0075
 1   A    It's in my assessment at the beginning
 2   of the shift and it's again entered that
 3   her -- at 2242 that her uterus was firm and
 4   there was no clots.
 5   Q    Okay.  But if you had a situation in
 6   which you were worried about vaginal
 7   bleeding in a patient, you would -- and you
 8   called the house physician to see the
 9   patient for that reason, would you document
10   in your narrative notes, such as on page
11   160, that called house officer for vaginal
12   bleeding?
13   A    Yes.
14   Q    Why would you do that?
15   A    Because that's an abnormal in a
16   postdelivery patient, if she's having large
17   lochia or passing clots.
18   Q    Okay.  Have you had any -- strike that.
19             At some point did you learn that
20   Mary Williams had died?
21   A    Yes.
22   Q    When did you learn that?
23   A    I believe Monday perhaps.  The next
24   time I came into work, which was the
25   beginning of the next week, I believe.
0076
 1   Q    Okay.
 2   A    Within a few days.
 3   Q    Okay.  At -- at that point, when you
 4   learned Mary Williams had passed away, did
 5   you have any discussions with any physicians
 6   and/or nurses regarding Mary Williams?
 7             MR. JEFFERS:      Can I have a
 8   continuing objection to whatever the next
 9   questions are on this same subject?
10             MR. GORDON:       Yeah, sure.
11             MR. JEFFERS:      Thanks.  Go
12   ahead.
13   A    I think we all mentioned we were
14   saddened and in shock because of this.  We
15   didn't know what had happened.
16   Q    Okay.  Did you ever have any
17   conversation with Dr. Hahn about Mary
18   Williams after she passed away?
19   A    Yes, I did.
20   Q    And when did that take place?
21   A    I believe it was two to three months
22   afterwards.
23   Q    Okay.
24   A    And I had asked him if he had heard of
25   any cause of this or the autopsy, and he
0077
 1   said he had received the autopsy.
 2   Q    And what did he tell you?
 3   A    He couldn't really discuss it, he said.
 4   Q    Okay.  Is that the extent of the
 5   conversation with him?
 6   A    He -- no.  He said one more thing, that
 7   normally he likes to go over an autopsy
 8   report with the family but he was advised
 9   not to do that in this case.
10   Q    Okay.  Did he tell you who advised him
11   not to go over the autopsy with the family?
12   A    Not --
13   Q    Okay.
14   A    -- specifically.
15   Q    Did Dr. Hahn ever mention to you that
16   the nursing staff did not advise him that
17   there were abnormal lab values?
18   A    No, he never said that to me.
19   Q    Did you ever have a conversation with
20   Dr. Hsieh regarding Mary Williams after she
21   passed away?
22   A    I don't think so.  I don't recall any
23   conversation with him.
24   Q    Do you have any difficulties -- or,
25   strike that.
0078
 1             Did you have any difficulties
 2   communicating with Dr. Hsieh?
 3             MR. JEFFERS:      Object.  Go
 4   ahead.
 5             MR. SCHOBERT:     Object.
 6   A    No.
 7   Q    Did you have any difficulties
 8   understanding Dr. Hsieh?
 9   A    No.  I've worked with him for a while.
10   I learned how to communicate with him.
11   Q    And how did you do that?
12   A    Listened closely.  If I didn't
13   understand something he said, I'd have him
14   write it down or spell it, so I know I had
15   it correctly.
16   Q    Okay.  Did you ever have an occasion in
17   which you discussed something with him and
18   you knew that he really didn't understand
19   it?
20             MR. JEFFERS:      That she knew?
21             MR. SCHOBERT:     Objection.
22             MR. JEFFERS:      She knew that he
23   didn't really understand it?  Object.
24   Q    Let me rephrase the question then.
25             Have you had any situations in
0079
 1   which you knew after you had a discussion
 2   with Dr. Hsieh that Dr. Hsieh didn't
 3   understand what you were talking about?
 4             MR. SCHOBERT:     Objection.
 5             MR. JEFFERS:      Objection.  How
 6   could she know whether he understood or
 7   didn't understand?
 8             MR. GORDON:       Body language.
 9   There's a bazillion ways, John, okay?  Let
10   her answer the question.
11             MR. JEFFERS:      It's just that I
12   think it's a crazy question, but --
13             MR. SCHOBERT:     I object.
14             MR. JEFFERS:      -- it's okay.
15   Go ahead.  I keep my objection noted.
16   A    Okay.  Say it again now.
17             MR. GORDON:       It's hard to
18   say.  Could you repeat that?
19   A    After all this -- yeah.
20             MR. GORDON:       Could you please
21   repeat that?
22                     - - - - -
23                 (Question read.)
24                     - - - - -
25             MR. SCHOBERT:     Objection.
0080
 1   A    No, because if I felt that way, I would
 2   keep pressing him, I think, to make sure him
 3   and I were on the same --
 4             MR. JEFFERS:      Page?
 5   A    -- page.
 6   Q    And that -- and that has happened?
 7             MR. SCHOBERT:     Objection.
 8             MR. JEFFERS:      Object.  Go on.
 9   Go on.
10   A    Well, that happens with any physician
11   sometimes.
12   Q    Okay.  Have you had any conversation
13   with any of the family members after Mary
14   Williams passed on?
15   A    No, I have not.
16   Q    There was a Kardex used by the nurses
17   relative to Mary Williams?
18   A    Yes.
19   Q    When is the last time you saw the
20   Kardex?
21   A    In report at probably 11:00 to 11:30 on
22   Jan -- June 25th.
23   Q    All right.  And does the Kardex become
24   part of the chart?
25   A    No.
0081
 1   Q    What happens to the Kardex?
 2   A    It's tossed.
 3   Q    When?
 4   A    I believe on discharge.
 5   Q    Okay.
 6   A    But -- yeah.  I never did it, so I
 7   don't know.
 8   Q    All right.  Are you aware of any policy
 9   at Parma Community General Hospital, whether
10   written or unwritten, that if you have any
11   difficulty with a physician in terms of
12   feeling that the physician is not handling
13   the patient properly, that you can go to a
14   nursing supervisor or someone else?
15   A    Yes.
16   Q    And what's that called?
17   A    It's a chain of command --
18   Q    Okay.
19   A    -- I believe, for --
20   Q    Okay.  Was there a protocol, a written
21   protocol, in that regard that was in
22   existence in June of 1999, that you're aware
23   of?
24   A    I'm not aware of -- I -- I don't know
25   one way or the other.
0082
 1   Q    Okay.  What was the protocol?  Who --
 2   who would the nurse contact if she felt that
 3   the patient was not being delivered
 4   appropriate care by a physician?
 5   A    With a house physician, you would then
 6   go to the attending physician.
 7   Q    Okay.
 8   A    And then if you had a problem with the
 9   attending physician, you might go to the
10   chief of the department.  You could always
11   contact a nursing supervisor or director for
12   assistance on that issue.
13   Q    Had you ever used the chain of command
14   while you were here at Parma Community
15   General Hospital?
16             MR. JEFFERS:      Object.  Go
17   ahead.
18   A    Actually, yes.
19   Q    Okay.  We're going to take a short
20   break and then we'll see if we're done.
21             MR. TACKLA:       Off the record.
22                     - - - - -
23                   (Recess had.)
24                     - - - - -
25   BY MR. GORDON:
0083
 1   Q    Yeah.  At the time of the recess we
 2   were talking about chain of command.
 3   A    Yes.
 4   Q    And you indicated that you had used
 5   it --
 6   A    (Nodding head.)
 7   Q    -- and I just wanted to find out, when
 8   you did use chain of command in that
 9   instance, was it successful?
10             MR. JEFFERS:      Objection.  I
11   want to have a continuing objection and then
12   you may go ahead and answer.  All right,
13   Harley?
14             MR. SCHOBERT:     Note an
15   objection.
16             MR. GORDON:       Yeah, sure.
17             MR. JEFFERS:      Thank you.  Go
18   ahead.
19   A    Let me think, because it wasn't this --
20   it was many years before that and I --
21   Q    Many years before what?
22             MR. JEFFERS:      Are you talking
23   about at Parma?
24   A    This -- yeah, it was at Parma --
25   Q    Yeah.
0084
 1   A    -- but I need to think of the
 2   specifics.
 3             Yes, it worked.  My nursing --
 4   nursing supervisor supported me in
 5   questioning a doctor's order.
 6   Q    Okay.  And was that in terms of a
 7   labor/delivery or postpartum care?
 8   A    I think it was postpartum care.
 9   Q    Okay.  In other words, your nursing
10   supervisor was able to convince the doctor
11   to, so to speak, change his opinion or
12   change his decision?
13   A    Yes.
14   Q    Okay.
15   A    Change a medicine order.
16   Q    Okay.
17   A    It was related to a medication order.
18   Q    Okay.  In terms of -- we we're talking
19   about the ice packs.  Did you tell the
20   patient or -- and/or her husband not to use
21   any ice packs after -- after you placed the
22   ice packs on the patient?
23   A    I never told her that, no.
24   Q    Now, in terms of calling a physician,
25   is it typical that -- that you call a
0085
 1   physician when something unusual is going
 2   on?
 3   A    Yes.
 4             MR. GORDON:       That's all I
 5   have.  Thank you.
 6             MR. MURPHY:       I don't think I
 7   have anything.  Let me just see here if I --
 8             MR. GORDON:       Jeff, do you
 9   have anything?
10             MR. SCHOBERT:     Yeah, just the
11   one record -- I think it's been answered.
12                    - - - - -
13                CROSS-EXAMINATION
14   BY MR. SCHOBERT:
15   Q    On any one of those nursing entries
16   that you make, is the second time that
17   appears on like those nursing notes, is that
18   the time that the entry is made, versus the
19   first time being when the action was taken?
20   A    Right.  The first time is when it
21   occurred.  I believe this is how the
22   computer system works.
23   Q    To the best of your knowledge, I
24   understand.
25   A    To the best of my knowledge.  And the
0086
 1   time it's recorded, yeah, is the second.
 2   Q    All right.  So that's the time somebody
 3   physically goes out to that computer
 4   station --
 5   A    The machine and --
 6   Q    -- and types in things that have
 7   occurred that they've kept track of usually
 8   on a piece of paper or something like that?
 9   A    Right.
10             MR. SCHOBERT:     Thank you.
11             MR. JEFFERS:      Is that it?
12   That concludes it?
13             MR. GORDON:       Mr. Murphy is
14   still looking through his notes.
15             MR. JEFFERS:      Oh.
16             MR. MURPHY:       I'm looking for
17   question marks.
18             MR. JEFFERS:      While he's
19   looking, may we have 30 days and go through
20   the same thing as we did on the prior one,
21   please?
22             MR. GORDON:       Yes, that's
23   okay.
24             MR. PARIS:        And you'll waive
25   the viewing of the videotape and the one day
0087
 1   filing requirement?
 2             MR. JEFFERS:      Yes.  I won't
 3   kid around with you.
 4             MR. GORDON:       Quid pro quo.
 5             No questions.  Thank you very
 6   much.
 7             MR. TACKLA:       Off the record.
 8                     - - - - -
 9        (Deposition concluded at 6:16 p.m.;
10               signature not waived)
11                     - - - - -
12   
13   
14   DEBBIE BAZZO, R.N.
15   
16   
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20   
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25   
0088
 1               C E R T I F I C A T E
 2   
 3   The State of Ohio,   )
 4   County of Cuyahoga.  )  SS:
 5   
 6         I, David J. Collier, Registered
 7   Professional Reporter, Notary Public within
 8   and for the State of Ohio, duly commissioned
 9   and qualified, do hereby certify that the
10   within named witness, DEBBIE BAZZO, R.N.,
11   was by me first duly sworn to testify the
12   truth, the whole truth and nothing but the
13   truth in the cause aforesaid; that the
14   testimony then given by the above-referenced
15   witness was by me reduced to stenotypy in
16   the presence of said witness; afterwards
17   transcribed, and that the foregoing is a
18   true and correct transcription of the
19   testimony so given by the above-referenced
20   witness.
21   
22         I do further certify that this
23   deposition was taken at the time and place
24   as in the foregoing caption specified, and
25   was completed without adjournment.
0089
 1         I do further certify that I am not a
 2   relative, counsel or attorney for either
 3   party, or otherwise interested in the
 4   outcome of this action.
 5   
 6             IN WITNESS WHEREOF, I have
 7   hereunto set my hand and affixed my seal of
 8   office at Cleveland, Ohio, this 2nd day of
 9   February, 2001.
10   
11   _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
12   David J. Collier, RPR,
13   Notary Public/State of Ohio.
14   Commission expiration:  April 26, 2001.
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