1 1 The State of Ohio, ) ) SS: 2 County of Cuyahoga. ) 3 - - - - - IN THE COURT OF COMMON PLEAS 4 - - - - - 5 MARK WILLIAMS, etc., ) ) 6 Plaintiff, ) ) 7 -vs- ) Case No. 406184 ) Judge Saffold 8 PARMA COMMUNITY GENERAL ) HOSPITAL, et al., ) 9 ) Defendants. ) 10 - - - - - 11 12 Videotaped deposition of PAULETTE_PROKOP, a ________ ______ 13 witness herein, called by the plaintiff as if upon 14 cross-examination under the statute, and taken 15 before Suzanne Lamparter, Court Reporter and 16 Notary Public within and for the State of Ohio, 17 pursuant to the agreement of counsel, and pursuant 18 to the further stipulations of counsel herein 19 contained, on Wednesday, the 15th day of November, 20 2000, at 8:40 a.m., at Parma Community General 21 Hospital, 7007 Powers Boulevard, City of Parma, 22 County of Cuyahoga and the State of Ohio. 23 - - - - - 24 25 TACKLA & ASSOCIATES 2 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 Nurenberg, Plevin, Heller & McCarthy, Co., L.P.A.: 4 DAVID_M._PARIS,_ESQ. _____ __ ______ ____ HARLAN_M._GORDON,_ESQ. ______ __ _______ ____ 5 The Standard Building -- First Floor 1370 Ontario Street 6 Cleveland, Ohio 44113 (216) 621-2300 7 On behalf of Defendant Parma Community 8 General Hospital: 9 Weston, Hurd, Fallon, Paisley & Howley, L.L.P., by: 10 JOHN_W._JEFFERS,_ESQ. ____ __ ________ ____ 2500 Terminal Tower 11 50 Public Square Cleveland, Ohio 44113 12 (216) 241-6602 13 On behalf of Defendants Dr. Hahn and The Women & Wellness Center: 14 Bonezzi, Switzer, 15 Murphy & Polito, L.L.P., by: WILLIAM_D._BONEZZI,_ESQ. _______ __ ________ ____ 16 1400 Leader Building 526 Superior Avenue 17 Cleveland, Ohio 44114 (216) 875-2767 18 On behalf of Defendants Dr. Hsieh and 19 Physician Staffing: 20 Hanna, Campbell & Powell, L.L.P., by: JEFFREY_E._SCHOBERT,_ESQ. _______ __ _________ ____ 21 3737 Embassy Parkway P.O. Box 5521 22 Akron, Ohio 44334 (330) 670-7300 23 Also Present: 24 George Tackla, Videographer 25 Monica Keil TACKLA & ASSOCIATES 3 1 OBJECTIONS 2 - - - - - 3 ATTORNEY PAGE-LINE ________ _________ 4 5 Mr. Jeffers 31-07 6 Mr. Schobert 31-08 7 Mr. Bonezzi 31-19 8 Mr. Bonezzi 64-16 9 Mr. Bonezzi 65-18 10 Mr. Bonezzi 65-21 11 Mr. Bonezzi 73-08 12 Mr. Jeffers 73-19 13 Mr. Schobert 74-22 14 Mr. Gordon 101-19 15 - - - - - 16 17 18 19 20 21 22 23 24 25 TACKLA & ASSOCIATES 4 1 PROCEEDINGS 2 - - - - - 3 PAULETTE PROKOP, a 4 witness herein, being of lawful age, having been 5 first duly sworn according to law, deposes and 6 says as follows: 7 - - - - - 8 CROSS-EXAMINATION 9 BY MR. PARIS: 10 Q Ms. Prokop, my name is David Paris. I, 11 along with my partner Harley Gordon, represent the 12 Williams family in connection with Mrs. Williams 13 death in June of 1999. 14 I'm going to ask you some questions this 15 morning about your background, uh, your education, 16 your employment, and the events that occurred on 17 your shift back in June of 1999. If at any time I 18 ask you a question which is not clear to you for 19 whatever reason, uh, I would like you to stop me 20 and tell me that and give me the opportunity to 21 rephrase it and make it clear. Will you do that? 22 A Okay. Yes. 23 Q If you do answer one of my questions I'll 24 assume that you understood it and I'll rely on 25 your answer; do you understand that? TACKLA & ASSOCIATES 5 1 A Yes, I do. 2 Q And in answering any of my questions or 3 anybody else's questions, we have the hospital 4 charts here. Feel free to -- to look in the chart 5 to refresh your memory if you don't have an 6 independent memory of the things I'm asking about. 7 A I will. 8 Q Okay. Will you state your full name for the 9 record? 10 A Paulette V. Prokop. 11 MR. BONEZZI: Excuse me. Would 12 you say that again, please? 13 A Paulette V. Prokop. 14 Q What is your home address? 15 A 2821 Ralph Avenue, that's Cleveland, Ohio 16 44109. 17 Q And how old are you? 18 A 46. 19 Q And your date of birth? 20 A 5 -- May 9th of 1954. 21 Q Are you married? 22 A Yes. 23 Q And your husband's name? 24 A Dennis. 25 Q Did you grow up here in the Cleveland area? TACKLA & ASSOCIATES 6 1 A I grew up in North Royalton, Cleveland area, 2 uh-huh. 3 Q Where did you go to high school? 4 A Um, Cleveland Central Catholic. 5 Q And what year did you graduate? 6 A 1972. 7 Q After high school did you go on to have 8 further formal education? 9 A At Lutheran Medical Center in Cleveland. 10 Q Was that a nursing school program? 11 A Yes, it was a diploma program. 12 Q And was that a two year -- I'm sorry -- four 13 year -- 14 A Three year. 15 Q Three-year course? 16 When did you graduate that program? 17 A 1975. 18 Q And did you go on to have any further formal 19 education after that? 20 A Just a course here or there, nothing -- 21 Q Okay. Did you go to work after nursing 22 school? 23 A Yes, I did. 24 Q And where did you go to work? 25 A Uh, for the first two years, two to three TACKLA & ASSOCIATES 7 1 years I worked at the -- the St. John's on Detroit 2 and after I was married -- I married in 1976. 3 About three months after we were married we moved 4 to Canton and worked -- I worked at Timken Mercy 5 Hospital there for about two years. 6 Q What department did you work in at Timken? 7 A Timken was med/surg and at St. John's it was 8 also med/surg floors. 9 Q Okay. And then after Timken? 10 A I moved back and it was -- well, all with my 11 husband's job change. When we moved back I worked 12 again at St. John's for a couple of years and then 13 after that I came to Parma and I worked at Parma 14 for 17, almost 18 years. 15 Q And when you started at Parma, in what 16 department did you work? 17 A I worked, um, I think, two to three years 18 of, like, floating, med/surg-type nursing. 19 Q Then what? 20 A And then to OB and maternity. 21 Q And you've been OB maternity nurse ever 22 since? 23 A Uh-huh, correct, yes. 24 Q So probably for the last 14 years? 25 A Yeah, approximately. TACKLA & ASSOCIATES 8 1 Q All right. In your career as an OB nurse 2 here at Parma have you had any experience in 3 participating in the recognition or treatment of 4 any post-delivery infections in mothers? 5 A We have had some, not a lot that I -- that I 6 recall. 7 Q Okay. Did any of those infections in 8 post-delivery mothers include strep A, if you -- 9 A No -- 10 Q None of strep -- 11 A Not that I know of. Not that I recall. 12 Q Do you specifically recall the nature of the 13 infections? 14 A Boy, not any particulars on it, you know? I 15 know we have had some -- sometimes due to -- some 16 maybe more prophylactically they might start some 17 antibiotics when there's difficult deliveries, and 18 then when mom runs a temp, but sometimes that can 19 be deceiving, too, because moms do run low grade 20 temps post delivery many times too. 21 Q Have you been involved in and experienced in 22 the recognition of treatment of evolving sepsis or 23 sepsis in any patients besides OB patients? 24 A Yeah, when I worked med/surg, yeah, I have 25 been involved in that type. TACKLA & ASSOCIATES 9 1 Q Okay. I take it you're licensed in Ohio? 2 A Yes, uh-huh. 3 Q Any other states? 4 A No. 5 Q And I take it you're -- 6 MR. JEFFERS: Excuse me. No 7 uh-huhs. You did say yes, then you said 8 uh-huh, but let's keep it to the yes types 9 THE WITNESS: Okay. Got it. 10 MR. JEFFERS: Or nos. 11 Q I -- 12 THE WITNESS: Okay. 13 Q I take it your license has never been 14 revoked or suspended? 15 A No, it HAS not. 16 Q Are you a member of any professional 17 associations? 18 A No, not at this point. The only thing that, 19 um, over the last -- in February of this year I 20 received certification in the patient OB, just 21 like an extra certification, but as far as 22 belonging to any organizations, I don't at this 23 time. 24 Q Are you familiar with an organization called 25 NAACOG? TACKLA & ASSOCIATES 10 1 A Yes, uh-huh. 2 Q What is that? 3 A That's the -- I can't remember the exact -- 4 it's OB -- sets some of the standards for nursing, 5 for -- for OB nursing, maternity nursing, and I 6 can't recall the letters offhand. 7 Q Okay. But you're not a member of that 8 association? 9 A No, I'm not at this time. 10 Q Okay. Are you -- are any of the other OB 11 nurses here at Parma Hospital members of that 12 organization if you know? 13 A There are a few that I know of. Offhand 14 maybe, that I can think of, two or three right 15 now. 16 Q Okay. Do you participate in teaching to any 17 extent other nurses or students? 18 A I'm trying to think if I ever have had any 19 opportunity. 20 Not really. You know, sometimes we have 21 students that work with us where we're kind of 22 like a preceptor for them, work with them a little 23 bit, new nurses, but I don't -- that's not 24 specifically one of my job descriptions. 25 The only other teaching I would do would TACKLA & ASSOCIATES 11 1 be out on the floor with the patients. 2 Q Have you ever had your deposition taken 3 before? 4 A No, I have not. 5 Q Okay. Is this your first exposure to the 6 litigation experience? 7 A Yes, it is. 8 Q Okay. Are there nursing texts that you 9 refer to in your daily work environment? 10 A I'm not sure if I understand. 11 Q Any nursing texts that you refer to here in 12 the library, the Parma library? 13 A Oh, books you're talking about? 14 Q Yeah, books that you consider to be reliable 15 authorities. 16 A Yes, we do -- we do have -- 17 MR. JEFFERS: There's two 18 questions there now. One question is are 19 there texts. The second question, what your 20 reliance is on them. So obviously, you 21 know, you're not taking them as being 22 dictatorial, but you've got two questions 23 and he's got to split it up. 24 MR. PARIS: I'll be happy to 25 split it up. TACKLA & ASSOCIATES 12 1 Q Are there books here at the Parma library 2 that you refer to from time to time? 3 A Right in the library -- not specifically in 4 the library, but here in the hospital we do have 5 some OB texts on the floor that we use as a 6 reference. 7 Q And can you identify them by name, some of 8 them? 9 A I can't remember the authors. Oh, what is 10 the last name? There's one that we use fairly 11 often, but I can't remember the author's last name 12 if -- 13 MR. JEFFERS: That's okay. This 14 is a new experience for you. Don't worry 15 about it. 16 Q Okay. Do you know Dr. Hahn? 17 A Yes, I do. 18 Q You've worked with him before? 19 A Yes, uh-huh. 20 Q Over what period of time? 21 A Since he came to the hospital. I've been 22 here -- and I'm not sure what time frame that is 23 exactly. Maybe five or six years. I don't know 24 for sure. 25 Q Over the five or six years, with what TACKLA & ASSOCIATES 13 1 regularity have you interfaced with him, 2 reacted -- interacted with him? Daily? 3 A Not -- I work part time, so I don't really 4 see him that often. 5 What do I want to say? 6 I'd say just an average, maybe once a 7 week or so. 8 Q Let me go back to your employment here. 9 You work part time currently? 10 A Yes. Yes, uh-huh. 11 Q How long have you worked part time here? 12 A Since my -- since I started, yeah. 13 Q When you say part time, how many hours a 14 week is that? 15 A When I first started it was more like a PRN 16 basis where I'd work -- the minimum it would be at 17 that time was two days a month where you could 18 just -- when I was having -- younger and my 19 children were little, and then now I pretty much 20 work about three days a week. And that's -- in 21 fact at this time it actually is three days a 22 week, but I split it. I usually work two nights a 23 week and then I also do part of a prenatal 24 interview program that we have at the hospital 25 where we talk with our moms ahead of time and that TACKLA & ASSOCIATES 14 1 like splits up into that last day of the week, of 2 the three days. 3 Q So that's about 24 hours a week that you 4 work? 5 A Correct. Yeah. 6 Q And have you worked that shift arrangement 7 for the past several years? 8 A I'd say about five or six. Yeah, probably. 9 Q And your shift at night is -- you come on 10 shift at what time? 11 A 11:00 p.m. to 7:30 a.m. 12 Q All right. And is there a change-over 13 period when you come on? 14 A Yeah, from 11:00 to 11:30, then from 7:00 to 15 7:30. 16 Q Okay. And what is a change over? I mean, 17 what happens during that change over? 18 A We just -- the next shift comes on, they 19 give us an oral report with all the patients and 20 that, and just pass on any information. 21 Q Well, I understand the -- the prior nurse on 22 duty provides you with significant information 23 regarding patients? 24 A Correct. Yes. 25 Q Do you then have to review the charts of the TACKLA & ASSOCIATES 15 1 patients? 2 A Usually through the course of the night, but 3 initially we usually try and go out and do 4 assessments and just see, at least make rounds. 5 Sometimes the patients are sleeping at that time. 6 We wouldn't necessarily wake them unless it was 7 indicated, if there was something that we needed 8 to do right away, but we usually at least make 9 rounds just to see what's going on. 10 Q Do you typically review the charts before 11 you do the patient assessment? 12 A Not typically. We usually -- I'd say more 13 often we just make rounds first just to check on 14 them. 15 Q And you do the assessment during your 16 rounds? 17 A Yes. If they're awake, we usually do the 18 assessment right at that time. 19 Q Then when do you review the chart? 20 A Later on during the course of the night, but 21 again, if there was a patient that was -- again, 22 it just depends on the circumstances. If there 23 was a patient that was having more difficulty that 24 might vary a little bit just, you know, depending 25 on what's going on. TACKLA & ASSOCIATES 16 1 Q Okay. Have you worked with Dr. Hsieh 2 before? 3 A Yes, I have. 4 Q With what regularity did you interface with 5 Dr. Hsieh? 6 A Probably more common just because he's there 7 all the time because he's a house officer, so he 8 sees all of our admissions, all of that, and any 9 problems that we have on the floor. 10 Q And he's an OB-GYN? 11 A Correct. 12 Q Okay. And he works in the OB department 13 obviously? 14 A Correct. Yeah. He's specific to the 15 OB department. 16 Q And what shifts does he work? 17 A It depends. I'm not sure what their 18 scheduling is. I don't really keep that much 19 track of it, but it appears that most of the time 20 he'll work like a 24-hour shift and that's pretty 21 typical, I think. I don't know how -- or 12 to 22 24 hour it seems like. 23 Q Have you work with him on an average of once 24 per week? 25 A At least, yeah, TACKLA & ASSOCIATES 17 1 Q More so with Dr. Hsieh than Dr. Hahn? 2 A Probably, yeah. Just, like I say, he's here 3 more often. 4 Q Before your deposition today have you 5 reviewed any documents aside from what's in the 6 chart? 7 A Could you expand on that? Like -- 8 Q You have a hospital chart of Mrs. Williams 9 in front of you? 10 A Uh-huh. Uh-huh. 11 Q Are there any documents that you have 12 reviewed in addition to the hospital chart? 13 MR. JEFFERS: I showed her one or 14 two pages of that computer printout that I 15 attached to my responses to the 16 interrogatories -- 17 A Okay. That's -- 18 MR. JEFFERS: -- that we 19 introduced. 20 A That would be all. 21 Q Can you tell me as best you can what 22 bacteremia is? 23 A It's an infection, a bacteria in the -- in 24 the blood. 25 Q And do you know how bacteremia manifests TACKLA & ASSOCIATES 18 1 itself clinically? 2 A Clinically, with, like, the temp obviously 3 in some cases, sometimes that's -- I'm trying to 4 think. Lab work, it will show up in lab work, 5 sometimes with patients there might -- just a 6 feeling for them of general -- general not feeling 7 good, sometimes malaise or whatever. 8 I'm trying to think. I can't think of 9 anything right now, but those are some of the main 10 things. 11 Q You mentioned lab work. What is it about 12 the lab work that helps you make up your mind that 13 something may be leaning towards bacteremia? 14 A An elevation of a white count, and that's 15 probably the main thing. Then from there they can 16 pick up through the differential different blood 17 cells that will appear and that. 18 Q How does bacteremia in the way that you 19 define it different -- differ from sepsis? 20 A Just the -- pretty much I think in symptom 21 wise they show up, you know, pretty much the same. 22 Q All right. And in talking about the lab 23 work you mentioned the differential. Can you tell 24 me, are you familiar with the term left shift? 25 A Yes. Yes. TACKLA & ASSOCIATES 19 1 Q Can you tell me what a left shift is in the 2 context of a complete blood count lab value? 3 A Okay. I'm familiar with the term. I'm not 4 sure if I know exactly all the terms of that, but 5 just that as far as the differential, there's 6 elevations in the -- in the -- I can't -- I'm 7 trying to think of it -- the neutrophils, the 8 bands, that kind of stuff. 9 Q Go ahead and take a look at one of the lab 10 reports. 11 A Just that there can be elevations in those 12 values, the differential part. 13 Q Which values specifically? If we look at, 14 for example, the chart -- I'm looking at page -- 15 what -- 42 of the Bates stamped -- 16 MR. JEFFERS: I don't see a Bates 17 stamp on my copy. Here it is, tiny down 18 here. 19 Yes, she's looking at the equivalent of 20 42. 21 Q Help me understand what a left shift is. 22 MR. JEFFERS: You've got it right 23 in front of you. 24 THE WITNESS: Yeah. 25 A Yeah. Just that there's elevations in TACKLA & ASSOCIATES 20 1 the -- in some of the differential counts, the 2 bands and the neutrophils, the lymphs. We always 3 look at those. And initially look at the white 4 count, which kind of tips us off right away. But 5 sometimes, like I said initially, in a delivered 6 mom those can be off a little bit. Sometimes they 7 tend to have higher white counts initially and 8 that, so we kind of, you know, just keep track of 9 those and -- 10 Q What about lowered white counts? 11 A Sometimes that can also -- from my 12 understanding that can also be a sign of something 13 going on, so to speak, as far as an infection or 14 whatever so, you know, we go for the extremes of 15 that. 16 Q Okay. And are you aware of what the normal 17 ranges of the differentials are, the bands, and 18 the metamyelocytes, and the neutrophils? 19 A You know, a lot of times those, if I'm 20 concerned about it or whatever, I always have to 21 look them up to know the exact extremes of that, 22 but usually their presence indicates something, 23 you know if they're there at all -- 24 Q Something is leading you towards -- 25 A -- is going on. TACKLA & ASSOCIATES 21 1 Q -- towards bacteremia, sepsis, infection? 2 A Something. Maybe not exactly, because many 3 patients that we have after delivery do show 4 elevations in the -- them anyways and it's almost 5 like a normal reaction to, like, delivery and all 6 of that, so we have seen some elevations. 7 Q And that's been your experience? 8 A Yeah, and not that at that time they would 9 exhibit symptoms, but you always kind of keep 10 track of that and watch them. 11 Q Uh-huh. Okay. Can you tell me -- we were 12 just talking about terms and definitions. Can you 13 tell me what pre-eclampsia is? 14 A It's a condition in moms where -- there's 15 many reasons. They don't know exactly a specific 16 reason as to why it occurs, but it's -- it has to 17 do with an elevation in blood pressure, 18 proteinuria or protein showing up in the urine, 19 some swelling, weight gain, usually a sudden 20 weight gain. Usually the blood pressure is a 21 tipoff. 22 And then there's some lab values that 23 will show up -- some if it's severe enough. 24 There's some liver enzymes that will elevate, uric 25 acid, that kind of stuff, and it can be harmful to TACKLA & ASSOCIATES 22 1 mom and harmful to baby. 2 Q And what are some of the clinical 3 manifestations of pre-eclampsia? 4 A In a severe -- as it progresses some moms 5 will have headaches, epigastric pain, sometimes 6 blurred vision. 7 It kind of varies from patient to 8 patient, but they do appear kind of puffy, you 9 know, just don't -- sometimes just don't feel 10 well, you know, that kind of stuff. 11 Q And have you been involved in the care and 12 treatment of patients with pre-eclampsia? 13 A Yes, several. 14 Q Okay. Do you specifically recall as you sit 15 here today Mrs. Williams? 16 A Yes, I do. 17 Q Do you recall the events that occurred that 18 evening during your shift? 19 A Just memory, most of them. Most of the 20 things, and just probably because -- 21 MR. JEFFERS: He didn't ask you 22 yet, but now he will ask you that. And the 23 reason is because -- go ahead. 24 Q Why is it that you remember? 25 A Because she had passed away and it was just TACKLA & ASSOCIATES 23 1 something that wasn't -- for the staff, something 2 that wasn't, you know, the norm. 3 Q All right. Do you recall her husband Mark? 4 A Yes, I do a little bit from that night. 5 Q And do you recall Mark being in her room 6 most of the night? 7 A Yes, I do. 8 Q Okay. When you came on duty that night at 9 11:00 o'clock, who -- who was the nurse signing 10 off? 11 A Debbie Vasil. 12 Q Did you have any conversations with Debbie 13 about Mrs. Williams specifically? 14 A Yes, I did. 15 Q Tell me about those conversations. 16 A Okay. In the course of the report it was 17 just apparent from what -- from her shift that she 18 was not really happy, you know, with where she was 19 at at that point. She had been, you know, 20 pre-eclamptic, and we knew that, and still had 21 mag sulfate running. 22 So she just -- the thing that really -- 23 of all the -- there was the normal symptoms of 24 pre-eclampsia, but she was still very restless at 25 that point, at the time of report, and just was TACKLA & ASSOCIATES 24 1 not happy with the way, you know, she was -- she 2 was looking. 3 Her output was not terrific, you know, 4 in the normal, you know, range, hoping for a 5 little bit more, and those were probably the two 6 things that we discussed most at that time. 7 Q So Debbie was not happy with where 8 Mrs. Williams was at? 9 A Yeah. 10 Q What was it about the -- Mrs. Williams' 11 output that had Debbie concerned? 12 A It was just a very minimal. Our output 13 should be at least 30 cc's an hour and it was 14 just, like, hovering at 30 cc's, and you're hoping 15 by then it might, you know, start to pick up a 16 little bit. 17 Q And with respect to the restlessness, what 18 was -- what was Debbie telling you about the 19 restlessness? 20 A She just had been, you know, restless on and 21 off through the night and we had talked about 22 that. So it just wasn't a normal thing. She was 23 more restless than we had seen in other patients. 24 Q Did -- what time did Debbie come on? 25 A She -- I believe she had come on at TACKLA & ASSOCIATES 25 1 3:00 o'clock. 2 Q 3:00 p.m. in the afternoon? 3 A Yes. Uh-huh. 4 Q Did Debbie tell you anything about 5 Mrs. Williams having shaking and shivering during 6 the course of the day? 7 A I did not recall that. 8 Q Did you ever look at the chart during your 9 shift -- 10 A Yes. 11 Q -- to determine that Mrs. Williams did have 12 some episodes of shaking and shivering that day? 13 A Yes. 14 Q At about what time did you review 15 Mrs. Williams' chart? 16 A Probably -- I would have reviewed it right 17 after -- pretty much after report because we had 18 talked -- I believe towards the end of report 19 talked about having the house doctor come in and 20 take a look at her just because we weren't happy. 21 So I know we pulled the chart and, you know, had a 22 look through that. 23 Q Okay. So at the end of report, we're 24 talking somewhere around 11:30? 25 A Prob -- Just because there was so much I TACKLA & ASSOCIATES 26 1 would say probably -- somewhere between 11:30 and 2 12:00 just because I'm assuming from what I recall 3 that night and knowing the type of patient we -- 4 she was, report could have gone a little bit 5 longer or we had gone through things, so somewhere 6 between 11:30 and 12:00. 7 Q Having reviewed the chart between 11:30 and 8 12:00, would it have become apparent to you at 9 that time that Mrs. Williams had some episodes of 10 shaking and shivering during the day? 11 A Yeah. 12 Q Okay. And we can turn to -- I guess it was 13 Debbie who might have charted that? 14 A Yes, uh-huh. 15 Q Did you notice that here today? 16 MR. PARIS: And gentlemen, I'm 17 looking at -- on the Bates-stamped copies, 18 pages 159, 179, and 188. 19 MR. JEFFERS: Pages 159 -- 20 MR. PARIS: 159 -- 21 MR. JEFFERS: Go ahead. 22 MR. PARIS: -- 179 and 188. 23 MR. JEFFERS: Uh-huh. 24 Q Do we see -- 25 MR. JEFFERS: Here we go. You've TACKLA & ASSOCIATES 27 1 got that page? 2 THE WITNESS: We're back to the 3 nurses' notes. 4 MR. JEFFERS: Excuse me? 5 THE WITNESS: This is just the 6 beginning of it. 7 MR. JEFFERS: Here's what he has 8 AS 159. You've got that over there. 9 Q At 15:50, or 3:50 p.m., Debbie's noting 10 Mrs. Williams having an episode of shaking and 11 shivering. 12 MR. JEFFERS: Wait a minute. 13 THE WITNESS: That's right here. 14 MR. PARIS: Why don't we look at 15 mine? 16 MR. JEFFERS: Wait a minute. 17 Okay. Here. 18 I'll share. You keep yours. 19 THE WITNESS: Okay. 20 MR. BONEZZI: You're looking at 21 159, 179, 188? 22 MR. JEFFERS: Last entry on 159. 23 MR. BONEZZI: I saw 159, but 24 what's 169 and 188 have to do with it? 25 MR. PARIS: It's actually 179 TACKLA & ASSOCIATES 28 1 and 188. 2 MR. BONEZZI: I'm sorry. 179, 3 188. Thank you. 4 MR. JEFFERS: Here we go. 5 He's referring to the 15:50 note of 6 June 23rd. 7 MR. PARIS: Correct. 8 MR. SCHOBERT: 179 is the orders. 9 MR. BONEZZI: 179 are the orders. 10 MR. PARIS: Well, then I may 11 stand corrected. 12 MR. SCHOBERT: Yeah, I think 159 is 13 what you're referring to. 14 MR. BONEZZI: 159 has it. That's 15 the nursing note. 16 MR. PARIS: Yeah, thanks. 17 Q Is that what Debbie noted? 18 A Yeah. 19 Q And that's something that you reviewed? 20 A Uh-huh. 21 Q Okay. 22 MR. JEFFERS: Yes? 23 A Yes. Sorry. 24 Q And if you look at Bates stamped 188, was 25 there -- was that also noted by Dr. Hsieh? TACKLA & ASSOCIATES 29 1 A Yes, that would be his. Yes, that is. 2 Q That the patient had an episode of shaking 3 and shivering? 4 A Uh-huh. Yes. 5 Q All right. 6 MR. JEFFERS: Where am I looking? 7 I've got it. I'm looking at the time. 8 That's the 15:50? 9 MR. PARIS: Yes, sir. 10 Q Had there been episodes, if you recall, and 11 we can turn to the pages if you want, but did you 12 notice episodes of blurred vision during the day? 13 A During the day -- 14 Q During the day. 15 A Okay. 16 Q Under Debbie's shift when you reviewed the 17 chart. 18 MR. JEFFERS: We didn't go back 19 all the way through her notes. 20 THE WITNESS: Yeah, we didn't go 21 back. 22 MR. JEFFERS: This would 23 be a new review for her. 24 Q Well, I don't want you to do it right now. 25 The chart is going to speak for itself. TACKLA & ASSOCIATES 30 1 But when you reviewed the chart between 2 11:30 p.m. and midnight -- 3 A Uh-huh. 4 Q -- I'm trying to get a feel for what your 5 sense of this patient was and whether or not you 6 were aware of some episodes of shaking, some 7 variations in her blood pressure during the day, 8 in the evening. 9 A Uh-huh, yes. Yes, uh-huh. 10 Q You were aware of that? 11 A Yes. Yes. 12 Q Were you -- did you also become aware that 13 she had developed a temperature that was charted 14 at 7:25 p.m. of 101.6? 15 A I was aware she'd had it earlier, earlier in 16 her shift. 17 Q Okay. You were aware that orders had been 18 given for Tylenol 3? 19 A Yes, I did. 20 Q And ice to the back of her neck for elevated 21 temperature? 22 A Yes, I believe I -- I saw that later. 23 Q Does that sometimes have an effect of 24 suppressing a temperature, the Tylenol 3 and the 25 ice? TACKLA & ASSOCIATES 31 1 A The Tylenol and the ice would also -- would 2 be something that would be used to bring down the 3 temperature. 4 Q Do you know why Tylenol 3 and ilûfce was used 5 to bring her temperature down? 6 MR. JEFFERS: Objection. 7 MR. SCHOBERT: Objection. 8 MR. JEFFERS: In other words he's 9 asking you do you know what was in the mind 10 of the person ordering it, et cetera, and 11 I'm sure you don't know what was in the mind 12 of the person ordering it. 13 Q What's -- what's normal heart rate? 14 A For an adult, whatever? 15 Q Yes. 16 A Between 60 and 80, with some variations, but 17 usually between 60 and 80. 18 MR. BONEZZI: Objection to the 19 form of the question. 20 Are you speaking of an adult or are you 21 speaking of an adult who has just delivered? 22 MR. PARIS: I'm going -- I'm 23 going there. 24 MR. BONEZZI: Thank you. 25 A Uh-huh. TACKLA & ASSOCIATES 32 1 Q And what is the range of normal in an adult 2 who has just delivered? 3 A That -- it tends -- does tend to be a little 4 bit faster. 5 Q In what range? 6 A I'd say probably -- we've had patients 7 immediately post partum, my experience is up to 8 like 120 and still -- and watching, but not overly 9 concerned. 10 Q And when you say immediate post partum, how 11 many hours are you talking about? 12 A That particularly would be recovery room to 13 probably two to four hours after, but it's 14 still -- it does still remain elevated, though, 15 through the next several hours I'd say up -- 16 Q But by 12 hours post delivery, what is the 17 range that usually comes back down to, the normal 18 range? 19 A I -- my honest answer is I have seen still 20 variations at that point that I don't get too 21 concerned about. I don't -- it's still, you know, 22 not unusual to be up around 100. 23 Q What about respirations? 24 A Those usually tend to be about 18 to 20, 25 sometimes a little bit higher, but around that. TACKLA & ASSOCIATES 33 1 Q In a normal -- in a normal adult? 2 A In a normal adult. 3 Q What about immediate post delivery? 4 A Again, sometimes tend to be a little bit 5 higher. 6 Q And then does it tend to come back down 7 after -- within 12 hours of delivery? 8 A Pretty much. Uh-huh, pretty much. 9 Q Okay. After you reviewed the chart and you 10 became aware of the episodes of the shaking and 11 shivering and the elevations in temperature you 12 talked to Debbie about some concern of 13 Mrs. Williams' restlessness and output? 14 A Uh-huh. 15 Q And I think you mentioned that you wanted 16 the house officer to look at Debbie? 17 A Uh-huh. 18 Q I'm sorry. To look at Mrs. Williams? 19 A Uh-huh, correct. 20 Q Did you perform your assessment on 21 Mrs. Williams before you asked the house officer 22 to look at her? 23 A I don't recall if I actually did a hands-on 24 assessment at that point because we tried to get 25 him -- it was more kind of just an eyeball, you TACKLA & ASSOCIATES 34 1 know, not where I was listening to the lung sounds 2 or anything from what I recall. 3 Q Let's -- if you look at the lab work, when 4 you came on -- 5 MR. JEFFERS: Page what again? 6 MR. PARIS: 42. 7 Q When you came on shift had the labs already 8 been drawn, the blood work already been drawn, if 9 you know? 10 A According to the nurses' notes they were -- 11 they were there drawing them. I believe it was at 12 23:45 or 46. 13 Q Okay. Yeah, I see that actually on page 160 14 of the Bates stamped chart. 15 MR. JEFFERS: Page what? 16 MR. PARIS: 160. I think I saw 17 a reference to the lab being present and the 18 blood work drawn -- 19 MR. JEFFERS: Just a minute. 20 MR. PARIS: -- at 23:46. 21 MR. JEFFERS: What page did you 22 say it was on? 23 MR. PARIS: Page 160, I think. 24 MR. SCHOBERT: It's also on page 25 132. 132 has continuous nursing notes and I TACKLA & ASSOCIATES 35 1 see that reference. 2 MR. PARIS: All right. 3 Thanks. 4 MR. SCHOBERT: 23:46. 5 MR. JEFFERS: You see that? 6 THE WITNESS: Yeah, and I picked 7 it up here, too. 8 Yeah, lab here at 23:46. 9 MR. JEFFERS: What time? 10 THE WITNESS: 23:46. 11 MR. JEFFERS: 23:46? 12 THE WITNESS: Yeah. 13 Q That would be after you came on shift and 14 after your report with Debbie? 15 A Correct. 16 Q Were you aware that a complete blood count 17 was the order of -- 18 A Correct, yes. 19 Q And how long does it usually take to get the 20 complete blood count results back? 21 A Somewhere around a half hour somewhere. I 22 mean, I think they -- I believe they can rush it 23 if they have to, but the normal is about a half 24 hour or so. 25 Q And the complete blood count at this TACKLA & ASSOCIATES 36 1 facility includes the differential? 2 A I believe that it -- they do the complete 3 blood count and then if it's indicated they'll do 4 a differential and kind of add that on 5 automatically. I believe that's the lab routine. 6 Q All right. Have you accessed the lab 7 results on the computers at this hospital? 8 A Yes. 9 Q Not only on that night, but on occasions 10 prior to this night? 11 A Yes, uh-huh. 12 Q When you access the lab results at this 13 hospital, how do you go about doing that? 14 A Just through the computer. Just pull up the 15 lab screen and -- I'm not sure if I know 16 specifically what you're asking. 17 Q I would like you to take me through it 18 manually. How do you do it? You want to know 19 what Mrs. Williams' lab values are on the 11:30, 20 11:46 blood draw. 21 A Yeah. You just -- I'm not sure. Sometimes 22 when you get to the screens you see it as you go 23 along. But you would just pull up her name on the 24 screen. You enter just her name and then there's 25 a specific screen you go through for patient -- I TACKLA & ASSOCIATES 37 1 believe it's patient records. Then they've 2 changed some of that a little bit in the last 3 year, but it's patient records. Then it will give 4 you the lab results. Actually, it will give you 5 all of them. You can kind of pick from whatever's 6 available. 7 Q You can get the white blood count, the 8 hemoglobin, the hematocrit; they're all there? 9 A Correct. Yes. 10 Q Do they appear on the screen in the same 11 fashion that they appear on Bates stamped 42? 12 A Yeah. I mean, you're saying just like a 13 column kind of report? Yes. 14 Q So you can see everything on the screen in 15 front of you? 16 A Correct. Yes. 17 Q And the same holds true for the 18 differential? 19 A Yes, that would be there also. 20 Q That would be the bands, the metamyelocytes, 21 the neutrophils, so forth? 22 A Yes. 23 Q When there is an automated differential 24 count on the bands, metamyelocytes, neutrophils, 25 so forth, how is that displayed on the screen; do TACKLA & ASSOCIATES 38 1 you recall? 2 A No, I don't recall. 3 Q If there is a manual count -- 4 A Uh-huh. 5 Q -- not an automated count -- 6 A Uh-huh. 7 Q -- of the bands, neutrophils, and 8 metamyelocytes, and so forth, how is that 9 indicated; are you -- do you recall? 10 A I'm sorry, I don't recall, no. 11 Q Are there occasions when you have looked on 12 the labs on the computer screen where you've seen 13 a reference that the manual count of the bands, 14 neutrophils -- 15 A I -- 16 Q -- are pending? 17 A Yeah, I have seen that. 18 Q Okay. And what does that tell you when you 19 look at the screen and you see the white blood 20 count values, the hemoglobin, platelets, 21 hematocrits, but there's a reference to the 22 differential is pending, the manual differential 23 is pending, what does that tell you? 24 A It just tells us that they're doing them and 25 it might take them like a few more minutes or TACKLA & ASSOCIATES 39 1 whatever to get that. 2 Q And if you want to see the results of the 3 manual differential, what do you have to do? 4 A They'll just show up. They'll put the 5 results in and they'll show up later. 6 Q Do you have to go back to the computer -- 7 A Yeah. Yeah. 8 Q -- punch it back in and obtain those 9 results? 10 A Right. Yes. 11 Q And typically what is the delay time for 12 that? 13 A Oh, I -- from what I recall, I don't 14 think -- I believe it's maybe ten minutes or 15 15 minutes, something like that. 16 Q All right. If -- looking at, I think, Bates 17 stamped page 141, 142, can you tell me -- 18 MR. JEFFERS: Wait. Wait a 19 minute. 20 Q Is that part of your assessment? 21 A I'm sorry. Yes, uh-huh. 22 Q Okay. Would that be your initial 23 assessment? 24 A Yes, uh-huh. 25 Q And when you initially assessed TACKLA & ASSOCIATES 40 1 Mrs. Williams, was Mark, her husband, in the room? 2 A I don't know for sure, but I believe he was. 3 He was there most of the night. 4 Q All right. At your assessment, how was her 5 color? 6 A Okay. Just kind of pale. 7 Q What was her temperature? 8 A It might be on the regular vital signs. 9 MR. JEFFERS: You have to look 10 someplace else. 11 THE WITNESS: Yeah. That's what 12 I'm trying to figure out where the other 13 vital signs are. 14 MR. SCHOBERT: David, so we're 15 clear, are we looking under 00:30? 16 MR. PARIS: Yeah, and I'm going 17 to get the time on that also. 18 - - - - - 19 (Inaudible.) 20 - - - - - 21 Q If you look at page 142, I think the 22 temperature is on the right-hand column there. 23 MR. JEFFERS: This is stuck where 24 the clip is. 25 THE WITNESS: Okay. TACKLA & ASSOCIATES 41 1 A I have 100.4. 2 Q And what time was your assessment of this 3 patient? 4 A Okay. The assessment -- the initial 5 assessment? 6 Q Yes. 7 MR. JEFFERS: Okay. I'll keep 8 this out for you. 9 THE WITNESS: Thank you. 10 A Okay. 11 MR. JEFFERS: His question is what 12 is your initial assessment. 13 Q What time? 14 A The time of the initial assessment? From 15 here, the time, okay, would -- at 12:30. 16 Q Okay. 17 MR. JEFFERS: A.M.? 18 THE WITNESS: A.M. 19 Q Right. That would be June 26, 1999? 20 A Yeah. 21 Q As part of your initial assessment, besides 22 taking her temperature did you take her blood 23 pressure? 24 A Yes, uh-huh. 25 Q And the first time you took her blood TACKLA & ASSOCIATES 42 1 pressure, what was it? 2 A 119 over 64. 3 Q Was that normal? 4 A Yes, uh-huh. 5 Q What was her heart rate? 6 A 128. 7 Q Is that elevated? 8 A That's a little bit elevated, yeah. 9 Q And her respirations? 10 A 18. 11 Q Within normal range? 12 A Uh-huh. 13 Q Yes? 14 A Yes. I'm sorry. 15 Q Did you then recheck her blood pressure? 16 A Okay. At that time I don't believe so, not 17 until -- 18 Q The reason I ask is I'm looking at 19 Bates stamped 142. 20 A Oh, okay. 21 Q Do you recall -- does this record indicate 22 that there was a recheck of her blood pressure? 23 A Yeah. 24 Q And what was it when you rechecked it? 25 A Um, 88 over 53. TACKLA & ASSOCIATES 43 1 MR. JEFFERS: Where are you 2 looking right now? 3 THE WITNESS: Right here. 4 MR. JEFFERS: Okay. 5 MS. KEIL: What time was that? 6 MR. JEFFERS: Where is it? 7 Q Can you tell me what 100 over 44 reflects? 8 A Um, it's still within the normal range, you 9 know? Lower, but still within that range. 10 Q Let me back up. 11 You initially at 12:30 took her blood 12 pressure and it was 119 over 64? 13 A Uh-huh. 14 Q Then you rechecked her blood pressure. The 15 second time it was 100 over 44? 16 A Uh-huh. 17 MR. BONEZZI: At what time? 18 Q Yes? Excuse me. Yes? 19 A Yes, uh-huh. 20 Q And would that have been immediately 21 following the first blood pressure? 22 A Um, I'm trying -- I want to see specifically 23 how that was done. Sometimes we recheck and then 24 I know she had the pulse ox in the room and that 25 will automatically take a blood pressure. TACKLA & ASSOCIATES 44 1 Sometimes the reading's on there. If we get one 2 that's not exactly right, we recheck them, so that 3 might have been part of that. 4 Q All right. But then you rechecked her blood 5 pressure a third time; is that correct? 6 A Uh-huh, yes, I believe it was. 7 Q And the third time it was 88 over 53? 8 A Yes. 9 Q That's low? 10 A Yeah, and on here she's -- I believe she's 11 laying on her side. Sometimes that -- sometimes 12 we do get a little bit lower reading on the side. 13 Q Okay. Was it after your assessment of the 14 patient that you asked Dr. Hsieh to see her? 15 A I think -- I think so. I called him at 16 12:30 to see her and, um, I believe that's when it 17 was done. 18 Q Okay. Let's take a look at page 160. 19 MR. JEFFERS: You want to give 20 that back to Dave? 21 We need to just rip the clip off. 22 Q And I'm looking at the 12:30 entry, 23 12:30 a.m. 24 A Okay. 25 Q Do you have that? TACKLA & ASSOCIATES 45 1 A Yes, uh-huh. 2 Q You would have called Dr. Hsieh to the room 3 to evaluate the patient due to anxiety, output, 4 vital signs, et cetera? 5 A Correct. 6 Q Tell me about the anxiety. Or why did you 7 write down anxiety? 8 A Just because that was unusual and we don't 9 get too much of that type of reaction after 10 delivery. 11 Q All right. Is this different than the 12 restlessness that Debbie characterized? 13 A Probably one in the same. 14 Q Okay. 15 A I think it was just a difference in wording. 16 Q Difference -- 17 A A difference in wording. We both felt she 18 was restless, anxious, that kind of thing. 19 Q Okay. How did she manifest that? 20 A Just that in bed she kind of was, you know, 21 back and forth and whatever, and just kind of a 22 nervousness kind of thing, that kind of 23 restlessness or whatever. 24 Q Was there anything about what she was saying 25 that led you to the conclusion that she was having TACKLA & ASSOCIATES 46 1 anxiety? 2 A Not that I remember. 3 Q Okay. I think you told me about your 4 concern of the -- her output -- 5 A Yes. 6 Q -- that being you wanted to see her output 7 to be at least 30 cc's per hour and it was just 8 hovering at 30 cc's? 9 A About, yeah. 10 Q The vital signs that concerned you were 11 what; her temperature -- 12 A Temperature and just -- 13 Q -- blood pressure? 14 A The blood pressure was varying a little bit 15 and that -- that kind of went throughout the 16 night, you know, with the blood pressure. 17 Q What about her respirations or heart rate; 18 were those a concern? 19 A The respirations seemed okay, um, and the 20 heart rate, like I said, a little bit high, but 21 still wasn't a real, real concern at that point. 22 Q Okay. You next -- and then you say 23 et cetera. What have we left out? 24 A Just that -- just like the general feeling 25 that you didn't, you know -- that there wasn't TACKLA & ASSOCIATES 47 1 something right, I believe. That you just didn't 2 feel comfortable with how she was at that point. 3 Q At 12:30, at the time that you performed 4 your assessment, had you looked at her lab values 5 in the computer? 6 A We had pulled them up, you know, to -- 7 because we knew the house doctor was coming, so we 8 had pulled them up and stuff so -- 9 Q You reviewed them? 10 A We had them available. I don't specifically 11 remember, you know, reviewing them at that time, 12 just that we had pulled them up. And mostly at 13 that point we weren't really concerned that she 14 wasn't acting particularly right, so I did more 15 like with on patient care and I know we were in 16 process of pulling them up so we would have them 17 available. 18 Q Who's we? 19 A I'm not really sure who was on that night, 20 if we had a secretary, but usually like the other 21 nurses could say, "Could you pull that up for me," 22 or whatever, the labs and stuff. 23 Q Do I understand that it was you -- you were 24 the person primarily interacting with 25 Mrs. Williams? TACKLA & ASSOCIATES 48 1 A Yes, uh-huh. 2 Q Okay. Was there an LPN working with you in 3 the care and treatment of Mrs. Williams? 4 A Gail Castro (sic) was on that night and she 5 had helped me a couple of times just with some 6 care, like direct care in the room, but that was 7 probably about all. 8 Q Anybody else? 9 A Just the other nurses. I know another 10 nurse, Nancy Stevens, was on and just throughout 11 the night just, you know, kind of talking like we 12 always do with patients: do you think there's 13 something else, is there something we're not 14 seeing, that kind of stuff. But that was probably 15 about it. 16 Q Had any of these other nurses come into 17 Mrs. Williams' room to look at her, talk to her, 18 examine her, or review her chart? 19 A Um, through the night I know we had all 20 gone, looked at the chart and that. Gail had 21 been, like I said, with me a couple of times just 22 kind of helping me with her care and stuff. 23 Q Okay. Also on Bates stamped page 160, in 24 your note at 12:30 a.m. you say something about a 25 "Vaginal exam" -- TACKLA & ASSOCIATES 49 1 A Uh-huh. 2 Q -- "rectal exam" -- 3 A Yes. 4 Q -- "and palpated and Foley checked per 5 doctor." Can you tell me what that means? 6 A Okay. The vaginal exam was done because 7 many times restlessness and anxiety can indicate 8 the possibility of a hematoma after delivery and 9 there was some indication from report and that 10 that she had had a little bit more difficult 11 delivery. She had vacuum extraction and things 12 like that. So that was a fair concern and our 13 feeling. So the only way that would be picked up 14 would be sometimes like right at the outside, but 15 usually a vag exam is the -- would be the way to 16 find that. And also due to the concern of the 17 output, sometimes there's a possibility of, like, 18 the catheter which was in place, tubing could be 19 kinked or things like that. 20 So Dr. Hsieh had checked, palpated, made 21 sure the bladder was, you know, was palpable, 22 which means it was filling and not emptying and 23 also if there was any problem with the placement 24 of it or anything. 25 Q Okay. And so what you charted here, TACKLA & ASSOCIATES 50 1 "Vaginal exam, rectal exam, palpated and Foley 2 checked per doctor," you meant to describe what 3 Dr. Hsieh did after he came to the room? 4 A Yes. Yes, uh-huh. 5 Q Okay. After your assessment of 6 Mrs. Williams at 12:30 you contacted Dr. Hsieh? 7 A Yes. 8 Q How did you get a hold of him? 9 A Just called him. He's right on the floor 10 in the -- they have a sleeping room. 11 Q Had he been asleep? 12 A I don't know that. I don't know. 13 Q Was he in the sleeping room, though? 14 A Yes, uh-huh, but that's where they stay all 15 the time. 16 Q Did he respond as soon as you got a hold of 17 him? 18 A Yes, I -- a timely fashion. I mean, nothing 19 that I was worried about. 20 Q You called him and spoke to him on the 21 phone? 22 A Correct. Yes. 23 Q Do you recall what you said to him? 24 A Um, I don't recall specifically. Just 25 relating our concerns, you know, about the TACKLA & ASSOCIATES 51 1 patient, you know, is all I can say. I don't 2 recall the exact conversation. 3 Q You called him from the nurses' station? 4 A Yes, uh-huh. 5 Q And then he met you at the nurses' station 6 or did he meet you in the patient's room? 7 A I believe he met us at the nurses' station 8 from what I recall and, you know, just gave him 9 our concerns and there. 10 Q Did you have the chart with you at the 11 nurses' station or was the chart in the room? 12 A No, it was at the nurses' station. 13 Q Did he review the chart before he went and 14 examined the patient? 15 A He did review the chart. I'm not sure if it 16 was before or after, but I know he did go through 17 the chart. 18 Q In your presence? 19 A Yes. I was there. I mean, not like over his 20 shoulder. I was there at the nurses' station. I 21 know he did. 22 Q About how much time did he spend reviewing 23 the chart? And this is in the context of that 24 12:30 exam. 25 A Yeah. I would say at least several minutes. TACKLA & ASSOCIATES 52 1 I don't know for sure. I know -- I know he was -- 2 he was going through it, you know, going through 3 all the -- 4 Q Did you accompany him into the room for the 5 examination? 6 A Yes. 7 Q Can you describe his examination? 8 A I know that he did -- as I charted, he did 9 do the rectal exam and he checked the placement of 10 the catheter, he talked to her a little bit I 11 know, just to kind of see how she was, asking her 12 a little bit about how she felt and stuff and -- 13 Q And what did she say? 14 A You know, just that she didn't feel good, 15 you know, that's all. I don't remember too many 16 specifics, but I think more he just wanted to see 17 what she was like, you know, kind of that thing, 18 and I know he listened to her lungs. I think 19 that's about it. 20 Q Did Dr. Hsieh ask you about the laboratory 21 values? 22 A He didn't specifically, no. 23 Q Did you tell Dr. Hsieh what the laboratory 24 values were? 25 A That -- I just know we pulled -- you know, TACKLA & ASSOCIATES 53 1 we pulled them up on the computer so, you know, 2 they were there. 3 Q Who's we? 4 A Like I said, just the nurses that were on 5 that night. 6 Q Okay. At the time that Dr. Hsieh examined 7 Mrs. Williams -- 8 A Uh-huh. 9 Q -- either immediately before or immediately 10 after, was Mrs. Williams' lab values on the 11 computer screen? 12 A Yes, they -- they should have been. 13 Q Well, did he look at the lab values on the 14 screen? 15 A I'm not sure if he looked on the screen. We 16 can run them right off and that's usually what we 17 do. We don't usually have them on the screen. We 18 print them. 19 Q You print a copy of the lab values? You can 20 do that at the nurses' station? 21 A Yes, uh-huh. 22 Q Do you know whether or not that was done 23 that night? 24 A I believe it was as far as I know. 25 Q Okay. And when it is printed off at the TACKLA & ASSOCIATES 54 1 nurses' station does it appear in the same format 2 as we see on page 42 of the chart? 3 A It's a little bit different just, I guess, 4 because of the printing or whatever, but it does 5 occur in the same, you know, column type. 6 Q When -- and approximately what time do you 7 think that these were printed off? 8 A I don't know for sure. I can't say a 9 precise time, but it was, you know -- it was -- my 10 point was to hopefully get like the whole picture 11 of the patient and the labs together. 12 Q Okay. My question is did Dr. Hsieh have 13 available to him the complete lab results of this 14 patient, the labs that were drawn at 11:46? 15 A I -- he should -- 16 MR. JEFFERS: Depending upon what 17 clock we're all looking at, you know. So 18 when you say 11:46, I'm not sure that's 19 11:46 what time versus 11:30 lab time versus 20 whatever time, so -- 21 Q We know that labs were run at or around 22 between 11:30 and midnight? 23 A Uh-huh. 24 Q And those are the labs I'm talking about. 25 A Uh-huh. TACKLA & ASSOCIATES 55 1 Q So when I ask you whether Dr. Hsieh had 2 available to him immediately before or after his 3 examination of Mrs. Williams those lab results -- 4 A Should have been on the chart, yeah. 5 Q Okay. That would include the white blood 6 count and the differential? 7 A Yes. 8 Q That would be the bands, the neutrophils, 9 metamyelocytes, and so forth? 10 A Yes, as far as I know. 11 Q Okay. Are you aware that -- did you have a 12 chance to review Dr. Hsieh's entry at 12:25 a.m.? 13 A No, I didn't. 14 Q If you look at page, I believe, 189 in the 15 Bates stamped -- 16 MR. JEFFERS: Let's stick this 17 here so we can get back to that. 18 MR. GORDON: You might want to 19 red flag that page. 20 MR. JEFFERS: Oh, Yeah. Thank 21 you. I need help. 22 Wait a second. 23 Q Ms. Prokop, have you ever seen this entry 24 before? 25 A No, I don't believe so. TACKLA & ASSOCIATES 56 1 MR. BONEZZI: What page was that 2 again? 3 MR. PARIS: 189. 4 MR. BONEZZI: Thank you. 5 Q What is the custom and practice as it 6 relates to a progress note? Do the physicians -- 7 when do the physicians normally make those 8 entries? 9 MR. JEFFERS: If you know. 10 She doesn't make them obviously. 11 Q Yeah, if you know. 12 A I don't know for sure. They always -- I 13 know they always do a progress note after they see 14 a patient. 15 Q Okay. Based on your experience over the 16 past 14 years in OB nursing here at this hospital, 17 do the doctors typically sign off after they see 18 the patient on their progress note -- on their 19 progress notes? 20 A Yes. 21 Q And then -- 22 MR. GORDON: Wait. Did she 23 answer? I didn't hear. 24 THE WITNESS: Yes. 25 Q Then if they make another entry, for TACKLA & ASSOCIATES 57 1 example, do they sign off again every time there's 2 a separate entry? 3 A Yes. Yes, as far as what I've seen. 4 Q And at this hospital as it relates to 5 progress notes, do these -- do you normally see 6 progress notes that are only a half a page long 7 and then they start up again on the following page 8 or are they usually separated -- are they usually 9 written right under each other in chronological 10 order? 11 MR. JEFFERS: Or is it none of the 12 above? 13 Q Or none of the above? 14 A Okay. It varies. 15 MR. JEFFERS: Do you follow? 16 A Yeah, it varies. I don't see that there's 17 any particular pattern, you know, of the way 18 they're written, you know? 19 I don't know. I've seen, you know, 20 house doctors and the primary physician, you know, 21 write separate ones and -- but usually they just 22 follow in order, but I don't see as to how they 23 enter them. 24 Q Okay. 25 MR. JEFFERS: Hold on one second TACKLA & ASSOCIATES 58 1 here. 2 THE WITNESS: Oh, okay. 3 MR. JEFFERS: Okay? 4 THE WITNESS: Okay. 5 MR. JEFFERS: Okay. Go ahead. 6 Q Okay. Did you discuss with Dr. Hsieh his 7 findings? 8 A Um, I don't recall specifically. You know, 9 we knew that he couldn't detect a hematoma. I 10 knew that. Um, and output he was aware of and 11 everything, so at that point, um, I think we just 12 together decided to call Dr. Hahn, which I would 13 have done anyways just to give him a progress 14 report. 15 Q Okay. So did Dr. Hsieh ask you to call 16 Dr. Hahn? 17 A Um, that's -- I don't recall that 18 specifically. That's probably like the normal 19 routine. 20 Q Okay. 21 A But they don't normally call too much on 22 their own. 23 Q Going back to page 189, Mr. Jeffers will 24 show you. I just want to see if I can put into 25 context what Dr. Hsieh has written on the very TACKLA & ASSOCIATES 59 1 last line. 2 "Dr. Hahn was reported by nurse," I 3 think, "as orders." 4 A Okay. 5 Q Am I to understand that you had a telephone 6 conversation with Dr. Hahn? 7 A Yes, uh-huh. 8 Q Okay. And is it your understanding that 9 Dr. Hsieh did not have a conversation with 10 Dr. Hahn or you don't -- 11 A From what I recall, I don't believe he did. 12 I don't -- 13 Q Okay. I looked at the nurses' notes, your 14 notes, on page 160 of the chart -- 15 MR. JEFFERS: I've got it. 16 - - - - - 17 (Inaudible.) 18 - - - - - 19 Q -- and you record -- 20 MR. SCHOBERT: What page? 21 MR. GORDON: 160. 22 Q -- record a telephone conversation between 23 yourself and Dr. Hahn -- 24 A Correct. 25 Q -- at 12:45 a.m.? TACKLA & ASSOCIATES 60 1 A Yes. 2 Q And that follows Dr. Hsieh's examination of 3 Mrs. Williams? 4 A Correct. Yes. 5 Q And why is it that you wanted to call 6 Dr. Hahn? 7 A Because of her unusual status and, um, just 8 to report to him, um, just the findings, to 9 report, you know, that we weren't -- just we 10 weren't happy with where she was at, um, having 11 Dr. Hahn -- or Dr. Hsieh check her and his 12 findings so we could report that back to him and 13 see what he wanted us to do from there. 14 Q All right. Now you specifically wrote down 15 that Dr. Hahn was called? 16 A Uh-huh. 17 Q And you informed him of the lab results? 18 A Yes, uh-huh. 19 Q And do I understand -- 20 MR. JEFFERS: Did you say yes? 21 THE WITNESS: Yes. 22 Q -- you informed Dr. Hahn of all the lab 23 results? 24 A Yes, as far as I recall. 25 Q Okay. That would be all the lab results TACKLA & ASSOCIATES 61 1 that we see on page 42 of this chart? 2 A Yes. 3 Q That includes the bands -- 4 A Uh-huh, as far as -- 5 Q -- correct? 6 A Yes. If they were there, my normal routine 7 is just to read through the whole -- the whole 8 thing. 9 Q Okay. Did you recognize that lab as showing 10 somewhat of a left shift? 11 MR. JEFFERS: Go back and look at 12 it. 13 A Yeah, I knew, um, that they were unusual, 14 um, but again, I always feel better having them go 15 through it because some of that stuff -- like I 16 said, some things can be a little off just with 17 delivery, so I just always want them to be aware 18 of that. 19 Q I understand. But you had recognized that 20 her white blood count previously had been up to 21 16 and was now down to 4.6? 22 A Yeah, as far as I -- yeah. 23 Q You knew that. And you knew now that at 24 11:30, or 12:30, or 12:45, certainly when you were 25 talking to Dr. Hahn, that she had metamyelocytes TACKLA & ASSOCIATES 62 1 numbers -- six -- there were six metamyelocytes 2 noted? 3 A Yeah, I reported, you know -- I reported 4 what I had. I can't recall specifics of what was 5 there, just that I knew that it was unusual or a 6 little tending towards that. 7 Q Okay. Do you recall Dr. Hahn asking you any 8 specific questions about any abnormalities in the 9 lab values? 10 A Not that I recall. 11 Q Okay. Typically when you have these phone 12 conversations -- 13 A Uh-huh. 14 Q -- and I take it it's not unusual for you to 15 have phone conversations like this with -- 16 A Yes. 17 Q -- with attending OBs, is it you that 18 describes all the lab values or do you just 19 describe the abnormal values? 20 A My -- my typical thing is just to read them 21 off, just read them right off. 22 Q List them. Okay. And therefore that 23 probably answers my next question. 24 But then typically the doctor on the 25 other end of the phone doesn't say, "Are there any TACKLA & ASSOCIATES 63 1 abnormalities on the labs"? 2 A Right. I feel like I should just report 3 them as is and, you know -- 4 Q Let them make the decision. 5 A -- go from there. But if he did ask 6 specifics, I could, you know, give him that and 7 any other -- 8 Q Okay. Did you know where Dr. Hahn was that 9 evening? 10 A I don't know. 11 Q Do you know if he was in the hospital for 12 example? 13 A He wasn't -- he was not in the hospital, um, 14 as far as I recall. I don't believe he was in the 15 hospital. 16 Q Do you know if he was at another hospital? 17 A I don't -- I really don't recall at all. I 18 couldn't say. 19 Q Okay. Fair. How did you get a hold of him; 20 just by paging him? 21 A Well, that depends. As I recall, I don't 22 remember like -- there was no -- never -- there 23 was no difficulty getting a hold of him. He was 24 prompt. It wasn't like there was a delay like he 25 was someplace and we had to trace him or anything. TACKLA & ASSOCIATES 64 1 I don't remember that as ever being a problem. 2 Q Okay. Do you recall anything else about the 3 conversation? 4 A Let me see where it is. 5 I'm trying to think. I don't believe 6 that there was anything else, just that we were 7 concerned at that time. 8 MR. JEFFERS: I just didn't hear 9 you. Thank you. 10 A I just -- just the concern about the 11 restlessness, you know, that, you know, just the 12 normal reporting, you know, what we had -- what we 13 were concerned about. 14 Q What did Dr. Hahn say? 15 MR. BONEZZI: Objection. 16 Go ahead and answer. 17 A From what I remember he was -- you know, he 18 was also concerned about that. He said, you know, 19 to try the Ativan, see if that would help to kind 20 of calm her down a little bit. 21 Q Anything else? 22 A Just I would have asked him -- I have an 23 order for the Motrin, so I had talked about the 24 uterine cramping from my notes, but specifically 25 from the conversation I don't remember if there TACKLA & ASSOCIATES 65 1 was anything else. 2 Q Did Dr. Hahn say anything to you about any 3 of the lab values that you provided him? 4 A No, I don't believe so. Not from what I 5 recall. 6 Q Okay. You don't recall him saying anything 7 about a left shift? 8 A Not -- no, I don't. 9 Q You don't recall him saying anything about 10 the fall of her white blood count from 16 to 4? 11 A I -- I don't recall him making any comment 12 or anything about that. 13 Q Okay. Was there anything that he said that 14 indicated to you that he was considering 15 infection, sepsis, bacteremia, or anything along 16 those lines -- 17 MR. BONEZZI: Objection. 18 Q -- based on the lab values that you gave 19 him? 20 MR. BONEZZI: Objection. 21 A Not that I recall. 22 Q Okay. What happened next? 23 A I know -- just that I know he was concerned 24 because it was different, you know, from what we 25 were used to with the anxiety and that, but I TACKLA & ASSOCIATES 66 1 don't recall any specifics of, you know, him 2 making any other comments or that. Okay. 3 And then, um, your question again? 4 Q What happened after Dr. Hahn gave you the 5 order to give her Ativan and Motrin? 6 A Okay. 7 MR. JEFFERS: You mean -- this 8 could be a narrative through the rest of the 9 night? 10 MR. PARIS: No, no, no, I don't 11 want to do that. 12 Q Did you go ahead and do that? 13 A Yes, I did give her the Ativan. 14 Q All right. Then did you continue to follow 15 this patient the rest of the night? 16 A Correct. Yes. 17 Q Did you talk to Dr. Hahn again during the 18 course of that evening at 3:45 a.m.? 19 MR. JEFFERS: Let's see. This is 20 the problem is this holder they've got on 21 there. 22 Here's 3:45. 23 A Yes. Uh-huh. Yes, I did. 24 Q What did you talk to him about at that time? 25 A Um, just from my notes, just to update on TACKLA & ASSOCIATES 67 1 her status. Um, still the Ativan seemed to help a 2 little bit, um, but also her -- it was still the 3 output that was unusual, unusually low or kind of 4 maintaining. 5 Q You had checked her blood pressure at 2:15; 6 is that right? 7 A Yeah. Uh-huh. 8 MR. PARIS: Looking at page 143, 9 John, for her blood pressure checks. 10 A I have 100 over 44. 11 MR. JEFFERS: I couldn't hear you. 12 THE WITNESS: 100 over 44. 13 Q If you look at page 143, there's three blood 14 pressures taken at that time; is that correct? 15 MR. JEFFERS: What time are you 16 looking at? 17 MR. PARIS: 2:15. 18 A 2:15, 100 over 44. 19 Q Is there a recheck of her blood pressure, 20 88 over 53? 21 A Yes. 22 Q Is that low? 23 A That's low, and as I mentioned before, 24 sometimes -- I know that pulse ox was still in 25 there and so I rechecked it, you know, rechecked TACKLA & ASSOCIATES 68 1 it again. 2 Q Okay. 3 A And it is listed that it was -- pulse ox was 4 used. 5 Q Okay. Then it was rechecked at 120 over 60 6 for the third time? 7 A Yes. 8 Q At 2:30, do you recall the patient 9 complaining that her abdomen was feeling hard? 10 MR. JEFFERS: What time is this? 11 MR. PARIS: 2:30 a.m. 12 A Okay. Yes. 13 Q And she's having some kind of a deja vu 14 feeling? 15 A Yeah. Um, I believe she was the one who 16 said it felt like deja vu, that she had met me 17 before, you know, and that was all that she had 18 said. 19 Q Did you palpate her abdomen? 20 A Yes, uh-huh. 21 Q It felt hard to you? 22 A A little bit. You know, sometimes with the 23 cramping and that it was a little bit hard, and 24 I'm not sure -- 25 MR. JEFFERS: Double check your TACKLA & ASSOCIATES 69 1 notes. 2 Okay, Dave, what's the question? 3 Q The question is -- 4 MR. PARIS: Could you read the 5 question back, please? 6 - - - - - 7 (Whereupon, the question was read back 8 at this time.) 9 - - - - - 10 Q You charted at 2:30 that her abdomen felt 11 hard? 12 A Uh-huh. 13 MR. JEFFERS: Yes? 14 Q Yes? 15 A Yes. 16 Q Okay. And was it also somewhat distended at 17 that time? 18 A I don't have it as charted, but I don't know 19 for sure. I don't recall. 20 MR. SCHOBERT: Was that at 3:15? 21 Q Well, actually at 2:30 I asked was it 22 distended at that time and your answer is you 23 didn't chart that? 24 A I didn't check that, no. 25 Q But at 3:15 you did chart that her abdomen TACKLA & ASSOCIATES 70 1 was more distended? 2 A Uh-huh. 3 Q Yes? 4 A Yes. 5 MR. JEFFERS: Now it says, 6 "Abdomen appears slightly more distended." 7 A -- more distended. 8 Q Okay. 9 A Uh-huh. 10 Q Does that suggest to me that previous to the 11 3:15 there was some distention of the abdomen as 12 well? 13 A Distention, yes, correct. 14 Q Did you report all of this to Dr. Hahn when 15 you spoke to him at 3:45 a.m.? 16 A Yes, I -- I would have because that was a 17 concern with the distention and we were checking 18 bowel sounds and that. 19 Q And still the diminished output, you 20 reported that to Dr. Hahn? 21 A Yes, uh-huh. 22 Q And what did he say? 23 MR. JEFFERS: I couldn't hear you. 24 THE WITNESS: Yes. 25 Q What did Dr. Hahn say? TACKLA & ASSOCIATES 71 1 A 3:45, as our discussion -- as I recall our 2 discussion, he, knowing that she was 3 pre-eclamptic, you don't want to really force 4 fluids because their fluid is there, but it's 5 outside of the cells, but the cells are actually 6 kind of like thirsty, for lack of a better term, 7 but we don't normally do that because it can throw 8 them into pulmonary edema. So when I called him 9 he did give an order to infuse quickly and let me 10 just check the order. 11 I believe it was -- 12 MR. JEFFERS: What the order is -- 13 Go ahead. 14 Q On page 179, is that what you're looking 15 for, the order? 16 A Yeah, 180. Yeah. 17 Q I'm sorry. 180. 18 A Where he had -- I wanted to make sure of the 19 amount. A liter of lactated Ringers over the next 20 hour. 21 He felt that due to the delivery, that 22 she was probably dry, so to speak, and that she 23 could probably tolerate it, but he did -- and I 24 remember this in the phone call -- say, you know, 25 to keep checking lung sounds to make sure that TACKLA & ASSOCIATES 72 1 there wasn't any possibility of a pulmonary edema. 2 MR. PARIS: Let's take a 3 few-minute break, okay? 4 Let's go off the record. 5 THE VIDEOGRAPHER: Off the record. 6 - - - - - 7 (Whereupon, a brief recess was had at 8 this time.) 9 - - - - - 10 THE VIDEOGRAPHER: Back on the record. 11 BY MR. PARIS: 12 Q I'm going to go back and cover some of the 13 areas that -- some details that I may have left 14 out -- 15 A Okay. 16 Q -- as per my partner's request. 17 MR. JEFFERS: That's why these are 18 always longer, because Harley gives a list 19 of 80,000 things. 20 Q And to the extent that I may be repeating 21 myself, I apologize. 22 A Okay. 23 Q Do you recall the titles of any of the OB 24 books that you referred to? 25 A No, I don't. No. TACKLA & ASSOCIATES 73 1 MR. JEFFERS: She already 2 responded to that. 3 Q Did you give a statement to anyone, a 4 written statement or a recorded statement, 5 following this event in the context of this 6 litigation? 7 MR. BONEZZI: Objection to the 8 form. 9 MR. JEFFERS: Other than your 10 attorneys. 11 A Other than the attorneys, no. 12 Q Okay. Have you reviewed that statement 13 before this deposition? 14 A I don't understand the question. Which 15 statement? 16 MR. JEFFERS: The answer is no, 17 she hasn't reviewed any statements. 18 And objection anyway. 19 Q Do you know whether or not Debbie, the nurse 20 who was on -- on the shift before you, had any 21 conversations with Dr. Hsieh or Dr. Hahn about her 22 concerns of the vital signs, and the output, and 23 the restlessness? 24 MR. JEFFERS: Other than what 25 might be indicated in the chart? TACKLA & ASSOCIATES 74 1 MR. PARIS: Yes. 2 MR. JEFFERS: You don't have to go 3 look at the chart for that question. The 4 question is do you have any knowledge of it. 5 A All I know is that she had talked with them 6 during the night, during her shift. 7 Q Debbie did talk to who? 8 A Yeah, Dr. Hsieh and Dr. Hahn just according 9 to the notes and that and, you know, what we had 10 talked about in report. 11 Q Based upon your conversations with Debbie as 12 it relates to her discussions with Dr. Hsieh and 13 Dr. Hahn -- 14 A Uh-huh. 15 Q -- does that chart accurately reflect, as 16 far as you know, those conversations or did she 17 tell you something other than or in addition to 18 what's in the chart? 19 MR. JEFFERS: I don't know that 20 she's -- 21 MR. SCHOBERT: Objection. 22 MR. JEFFERS: -- reviewed every 23 comment on that chart, so I don't know that 24 she can respond to that. 25 If you think you can, go ahead. TACKLA & ASSOCIATES 75 1 Q To the extent you have reviewed the chart? 2 A As far as I know, there were no other 3 conversations. 4 Q Okay. Did you and Debbie exchange your 5 thoughts as to what was causing Mrs. Williams' -- 6 these symptoms that you and Debbie were concerned 7 about? 8 A At that point our discussions were that we 9 really didn't know, you know, and that was -- was 10 a concern, that we just thought it was unusual and 11 mostly referring to the anxiety. The output is 12 always kind of questionable with the 13 pre-eclampsia, but that was a concern, along with 14 the anxiety, seemed a little bit different from 15 what we -- we had experienced. 16 Q Was Debbie already gone by the time the labs 17 of 11:30 or midnight were known to you? 18 A I don't recall. 19 Q Did you discuss those labs with Debbie? 20 A No, I don't -- no. 21 Q Okay. Do you recall approximately how many 22 patients you were caring for that evening? 23 A With a pre-eclamptic -- this type of 24 patient? 25 Q OB patients. TACKLA & ASSOCIATES 76 1 A Oh, no, OB patients are -- regular OB 2 patients are different, but if we have a patient 3 on mag sulfate it's a one-on-one nurse -- nurse to 4 patient. 5 Q Were you caring for other patients that 6 evening besides Mrs. Williams? 7 A No. That's what I'm saying. Because she 8 was on mag sulfate, she was my only patient. 9 Q Okay. And what is it about a patient on 10 magnesium sulfate that requires the one-on-one? 11 A Just the frequent monitoring the vital 12 signs, hourly outputs, all of that. 13 Q How often were you monitoring her? 14 A Um, throughout the night at least every hour 15 it would be with outputs and vital signs. There 16 was a period when we were infusing the IV that I 17 stayed -- stayed in the room and that was more 18 frequent, but at least every hour from what I 19 recall. 20 Q Were you taking her temperature every hour 21 as well? 22 A Um, not unless that would be ordered 23 specifically, but I believe it was, from what I 24 recall, about every two hours through the night. 25 Normal is usually every four hours or every shift. TACKLA & ASSOCIATES 77 1 Well, the regular OB patient would be every shift 2 then, you know? 3 Q At the 12:30 when you did your assessment of 4 the patient her pulse ox was 97 percent? 5 A Uh-huh, yes. 6 Q Was that normal? 7 A Yes. 8 MR. JEFFERS: What time was that? 9 MR. PARIS: 12:30 a.m. 10 MR. JEFFERS: What was the 11 percent? 12 THE WITNESS: 97 percent. 13 Q Do you recall having any conversations with 14 Dr. Hsieh about Mrs. Williams prior to 12:30 a.m.? 15 A Not that I recall. 16 Q Where was the computer located? The 17 computer that you accessed the lab information on, 18 where was that located in relationship to 19 Mrs. Williams' room? 20 A Mrs. Williams was in the first room right by 21 the desk and the computer is -- is right at the 22 desk. 23 Q So you're talking about a matter of feet, 24 steps? 25 A Feet, correct. TACKLA & ASSOCIATES 78 1 Q Can you tell me why a rectal exam was 2 performed by Dr. Hsieh at 12:30? 3 A That would have been the vaginal and rectal 4 exam, I believe he did both, and looking for a 5 hematoma. 6 Q If Dr. Hsieh had asked you about her labs, 7 and I'm talking about around the midnight labs, 8 11:30 or midnight -- 9 A Yes. 10 Q -- labs, would it have been your custom and 11 practice to tell him all of the lab results as you 12 did with Dr. Hahn or would it have been your 13 custom and practice to hand him the lab sheet that 14 you printed off? 15 A Just because he was right there I would have 16 handed them right to him or in the chart. 17 Q Okay. As opposed to standing there and 18 reciting? 19 A And going -- correct. 20 Q Okay. Going back to custom and practice 21 again, if a house officer asks you specific labs, 22 can you check for me what the hematocrit is and 23 the hemoglobin -- 24 A Yes, uh-huh. 25 Q -- and the magnesium sulfate, is it your TACKLA & ASSOCIATES 79 1 custom and practice only to give him those lab 2 results as requested? 3 A Correct. If he asked specifically, that 4 probably would be all I would give him. 5 Q In the context of this case, I want to just 6 give you a hypothetical and see if you can answer 7 it for me. If you can't, that's fine, but this 8 relates to your custom and practice. 9 If at 12:30 you had all the labs in 10 front of you -- 11 A Yes. 12 Q -- and Dr. Hsieh said, "Would you tell me 13 what the hematocrit, hemoglobin, and magnesium 14 sulfate values are" -- 15 A Yes. 16 Q -- would you have only given him that 17 information or would you have also informed him of 18 any abnormalities of the other values? 19 A As far as I know, I would have informed him 20 of any other abnormalities. Um. Yeah. That's 21 all I can say. 22 Q Okay. Or any other shifts or changes -- 23 A Or -- yeah. 24 Q -- dramatic changes? 25 A Yeah, if he had asked. Yeah. Yes, I would TACKLA & ASSOCIATES 80 1 have. 2 Q So, for example, if you had this lab sheet 3 in front of you and Dr. Hsieh had asked you for 4 the hematocrit, hemoglobin, and magnesium sulfate 5 values, would you also have given him information 6 about the 52 bands that appeared? 7 A I would have given him that. I don't know 8 if I should add, but it was right there, so I -- 9 you know -- 10 Q I know. 11 A You know -- 12 Q But assuming he didn't look at the computer 13 screen and assuming he didn't look at the sheet 14 that was probably printed out, would you also -- 15 A Okay. 16 Q -- have given him that information about the 17 52 bands? 18 A Yes. 19 Q Would you also have given him the 20 information that the white blood count had dropped 21 from 16 down to 4.2? 22 A Yes. 23 Q Was Dr. Hsieh available -- I'm sorry. Was 24 Dr. Hsieh present when you had your telephone 25 conversation with Dr. Hahn? TACKLA & ASSOCIATES 81 1 A I don't recall. I don't recall 2 specifically. 3 Q Did you have that telephone conversation 4 with Dr. Hahn in the patient's room or out by the 5 nurses' station? 6 A Out by the nurses' station. 7 Q Okay. Did you at any time tell Dr. Hahn 8 that Mrs. Williams' lab results -- and we're 9 talking about the lab results of 11:30 p.m. or 10 midnight -- 11 A Uh-huh. 12 Q -- were normal? 13 A Were normal? 14 Q Yeah. 15 A I don't recall. I don't believe so. 16 Q Okay. 17 A Like I say, I don't really label normal or 18 not normal. My practice is just to report them as 19 they're written. 20 Q So that is not terminology that you would 21 use? 22 A Not -- yeah, not normally. I mean, if there 23 was something that I called him just for that, but 24 this was more just an overall status of what the 25 patient was and I wouldn't have just -- TACKLA & ASSOCIATES 82 1 Q Let's hold on until the noise level's down. 2 Can you say that again? 3 A This was more like an overall picture of the 4 patient, so I just would have recited them down, 5 you know, as my normal practice. 6 Q Okay. If on the lab results of midnight, 7 June 26th, if the differential was pending -- 8 A Uh-huh. 9 Q -- would you have told this to Dr. Hahn as 10 well? 11 MR. BONEZZI: If what was pending? 12 MR. PARIS: The differential. 13 A If it was listed there, yes. 14 Q As pending? 15 A Uh-huh. 16 Q Okay. Is it -- is it typical that you have 17 telephone contact with an attending OB in the 18 middle of the night? 19 A Normal with a normal patient? 20 Q Yes. 21 A Not really, no. 22 Q Under what circumstances do you typically 23 have conversations with the attending OB? 24 A Just unusual happenings with the patient, 25 you know, with labor obviously, unusual behaviors, TACKLA & ASSOCIATES 83 1 just something that was out of the ordinary. 2 Q Not -- not all patients who are on magnesium 3 sulfate display unusual behavior, correct? 4 A Oh, yeah. Yeah. 5 Q So just by virtue of the fact that this 6 patient was on magnesium sulfate wasn't reason for 7 you to have conversations with the attending OB 8 during the course of the night or early morning 9 hours? 10 A Correct. 11 Q Okay. 12 MR. PARIS: Pull the 12:45 -- 13 Q Did you discuss with Dr. Hahn that 14 Dr. Hsieh's examination of her at 12:30 a.m. was a 15 normal exam? 16 A Yeah, the results of it, that he did not 17 find any hematoma. No. Yeah, just the results of 18 that exam. 19 Q On the computer when you're pulling up the 20 lab values and you're printing off the lab 21 values -- 22 A Yes. 23 Q -- are you printing off only the lab values 24 from a certain time or do you also have the 25 previous time lab values? TACKLA & ASSOCIATES 84 1 For example when you print it off, do we 2 see all the lab values that exist like we see on 3 page 42? 4 A So far? 5 Q Yeah. 6 A You -- you actually would have the -- I 7 believe from what I -- you would have the option 8 of pulling up any ones that you wanted, but if you 9 were -- you would just be pulling up for the most 10 part, when we know it's a specific set of -- you 11 know, like a 12:00 o'clock lab, we would just key 12 in that time and most often we would just pull up 13 that one. 14 Q All right. Do you have a specific 15 recollection of what you printed out on that 16 night -- 17 A No, I don't. 18 Q -- for Dr. Hsieh? 19 A No, I don't. 20 Q Okay. Do you have any recollection of any 21 discussions with Dr. Hsieh, with Debbie, with 22 Dr. Hahn, about infection with this patient at any 23 time during your shift? 24 A No, I don't believe so. 25 Q That is not a term that anybody used in TACKLA & ASSOCIATES 85 1 connection with this patient? 2 A Not that I recall. 3 Q And did infection enter your thinking 4 processes during this shift? 5 A We more, um -- just with discussion with 6 Debbie and the nurses through the night we were 7 thinking more like complications of the 8 pre-eclampsia. 9 Q Did you ever ask Dr. Hahn to come in and see 10 the patient? 11 A Not -- we -- I did not ask him specifically 12 to come in. I talked -- just talked to him I 13 think the three times during the night, um, but I 14 never asked him specifically to come in. 15 Q Did you ever have any discussions with 16 Mrs. Williams' family after her death? 17 A No, I did not. 18 Q Did you attend the funeral? 19 A Yeah, it was our whole -- many from the 20 floor who were taking care of her went to the 21 funeral. 22 Q Did you know Mrs. Williams' mother? 23 A I know who she is. I do know who she is, 24 but I don't know her as to -- like a friend or 25 anything like that. I just know that she had TACKLA & ASSOCIATES 86 1 worked here and -- but I did not know her 2 otherwise. 3 MR. PARIS: Give me one more 4 minute. 5 MR. GORDON: Can we take a short 6 break? 7 MR. PARIS: Off the record 8 THE VIDEOGRAPHER: Off the record. 9 - - - - - 10 (Whereupon, a brief recess was had at 11 this time.) 12 - - - - - 13 THE VIDEOGRAPHER: On the record. 14 BY MR. PARIS: 15 Q After 12:45 did you have any further 16 conversations with Dr. Hahn about the lab values? 17 A Um, the only -- from what I recall, the 18 only -- and with the nurses' notes, at 7:30 in the 19 morning I had called him with the results of the 20 later labs as far as I can recall. 21 Q And those would be the labs that are 22 documented at 5:36 -- yeah, 5:30 a.m.? 23 A Yeah. Yes. 24 Q Okay. Did you have any further 25 conversations with Dr. Hsieh about this patient TACKLA & ASSOCIATES 87 1 during the course of the night? 2 MR. SCHOBERT: You mean subsequent 3 to 12:30? 4 MR. PARIS: Absolutely. 5 A Um, not that I recall. Nothing specific. 6 Q Did you have any conversations with 7 Mark Williams during the course of the night? 8 A We did have a couple. Um, we just talked 9 about -- you know, he was talking about his 10 concern for her and I was in and out of the room 11 throughout the night from the time that we did the 12 infusion. 13 I -- he was saying something about being 14 tired and I said something about maybe, "If you 15 want to lay down because I'll be right here in the 16 room," so I remember that conversation. 17 Um, I don't remember time wise, but 18 he -- she was complaining of the cramping. That 19 was something that was an issue. Not that we were 20 overly concerned, but it was an issue, abdominal 21 cramping, and he had mentioned that -- and we had 22 given her Motrin one time, but he had mentioned 23 with her regular period that she is very 24 uncomfortable and that she takes that just for her 25 regular period, so he felt that maybe she could TACKLA & ASSOCIATES 88 1 use something else for pain was his feeling. And 2 sometimes that does kind of follow through. It 3 seems like people who do have heavier or more 4 uncomfortable periods sometimes do have a little 5 bit more cramping just from my experience. So it 6 was something that I felt was legitimate and I had 7 discussed that with Dr. Hahn when I talked to him 8 and, though, only the last conversation I had to 9 him was more towards the end of the shift. She 10 had had the Ativan and she, um, still not, you 11 know, fully happy with where she was at, but she 12 seemed to be resting a little bit better and just 13 talked to him. 14 Again, we were talking about her, you 15 know, being up most of the night and saying maybe 16 now if she can get rest, she might feel a little 17 bit better, and something along that line. 18 Q Are all of the notes that you've generated 19 with regard to this patient contained in the 20 chart? 21 A Um, I don't know if I understand. 22 Q Is there anything -- are there any notes 23 that you have created related to this patient 24 which are not in the chart? 25 A Like afterwards or -- TACKLA & ASSOCIATES 89 1 Q Any notes -- 2 A Any notes? 3 Q -- with regards to the care and treatment 4 other than something that you've prepared for your 5 lawyer. I'm not interested in that. 6 A Okay. No, as far as I -- I never did any. 7 The only one would be those. Yeah, the notes that 8 are here, the regular -- 9 MR. JEFFERS: Anything other than 10 what's in this chart. 11 THE WITNESS: Oh, okay. 12 A Yeah, that's it. I'm sorry, I didn't know 13 if I -- 14 Q Everything that you've recorded about this 15 patient is in the chart -- 16 A In this chart. 17 Q -- unless it's been prepared for your 18 lawyer? 19 A Yeah. 20 MR. PARIS: Thank you very much. 21 MR. BONEZZI: I do not have any 22 questions on behalf of Dr. Hahn. 23 THE WITNESS: Okay. 24 MR. SCHOBERT: I just -- on behalf 25 of Dr. Hsieh I have a few questions. I want TACKLA & ASSOCIATES 90 1 to just see -- time out. I need -- 2 THE VIDEOGRAPHER: Off the record. 3 - - - - - 4 (Whereupon, discussion was held off the 5 record at this time.) 6 - - - - - 7 THE VIDEOGRAPHER: On the record. 8 - - - - - 9 CROSS-EXAMINATION 10 BY MR. SCHOBERT: 11 Q I represent Dr. Hsieh and I just want to see 12 if I can clarify a few points. 13 In this chart, page 24 -- 14 MR. JEFFERS: 21? 15 MR. SCHOBERT: It's 24. It's the 16 face page and the graphics. 17 MR. JEFFERS: Oh, here we go. 18 Q Do you see that in front of you? 19 A Yes. Uh-huh. 20 Q How was that information generated 21 throughout page 24? 22 A I'm not sure if I understand the question. 23 Q Well, in other words I assume that -- you've 24 testified that there's a pulse ox connected to the 25 patient -- TACKLA & ASSOCIATES 91 1 A Yes, uh-huh. 2 Q -- that takes certain vitals information on 3 a continuous basis? 4 A Um, you can set it. It can be a continuous 5 and timed every so often and it will, if it is 6 specifically the pulse, it will say the PUL, pulse 7 ox on that, and towards the top where it says 8 apical, that would indicate that it was taken by a 9 nurse. 10 Q By a nurse? 11 A Okay. 12 Q Okay. So when we look at the entries down 13 at the bottom here starting at 00:30, you see that 14 down there? 15 A Correct. 16 Q So that temperature of 100.4 was an oral 17 temperature that you had taken and then recorded 18 it and that comes out on this graphic chart? 19 A Yes, uh-huh. 20 Q And then the blood pressure was 119 over 64? 21 A Correct, yes. 22 Q All right. Then going down, I see an entry 23 at zero -- on June 26th at 02:15? 24 A Yes. 25 Q And it has a blood pressure of 100 over 44? TACKLA & ASSOCIATES 92 1 A Yes. 2 Q Now you were asked some questions very early 3 on about some notations that you made about 4 rechecking blood pressures -- 5 A Uh-huh. 6 Q -- and so forth, and one of the numbers that 7 you were asked about was 100 over 44. Do you 8 remember that? 9 A Yes. 10 Q Would I be correct in understanding that the 11 100 over 44 that you probably made mention to in 12 your other notes would have been taken at -- at 13 this time, at 2:15? 14 A Yes, uh-huh. 15 Q And then we go down again and the next entry 16 is at 3:15; do you see that? June 26th at 03:15? 17 A Yes, uh-huh. 18 Q Now at that point the oral temperature 19 you've recorded as 98.4? 20 A Yes. 21 Q That again would have been taken by you or 22 the LPN and then entered into the chart and then 23 it ultimately comes out on this graph? 24 A Right. What happens in the Meditech that we 25 use for this, it's a screen that pops up and you TACKLA & ASSOCIATES 93 1 can say temp 98.4, indicated that it was taken 2 oral, then when you go to the other vital signs 3 you can indicate if it was taken left side, right 4 side. You can indicate even the sides you took it 5 on, you can indicate if it was taken by the pulse 6 ox or just regular blood pressure. But this is 7 put in by hand if that's what you're saying. 8 Q Okay. Then going across that line, it 9 appears the pulse is 105? 10 A Yes. 11 Q So it appears the pulse is now -- it has 12 dropped down over the last couple of hours -- 13 A Uh-huh. 14 Q -- back towards a more normal level? 15 MR. JEFFERS: You have to say yes. 16 A Yes. Yes. 17 Q And then the blood pressure you have there 18 is 80 over 52? 19 A Yes. 20 Q Yes? 21 A Yes. 22 Q And again, I believe you were asked some 23 questions early on about a blood pressure of 24 80 over 52 on one of those pages. I guess it was 25 on page 142 of your nursing notes. TACKLA & ASSOCIATES 94 1 Well, actually it's 88 over 53 is the 2 number I have. 3 A Uh-huh. 4 MR. JEFFERS: Wait. Wait. 5 You got it? 6 THE WITNESS: Yeah. 7 Q Do you see that? 8 A Yes. 9 Q You were asked about that earlier? 10 A Yes. 11 Q Do you know specifically when you -- you 12 know, the blood pressure of 88 over 53 was taken? 13 A Just that it doesn't actually document it. 14 It just takes it. So it would be sometime around 15 that 00:53, because we -- if we're not right 16 like -- 17 MR. JEFFERS: 00 what? 18 THE WITNESS: I'm sorry, 00:30. 19 A If we're not right near a computer sometimes 20 we'll write them down just with the times. 21 Q Well, in that same entry on 142 you had 22 recorded the 100 over 44 -- 23 A Correct, yes. 24 Q -- that the graphic chart also on page 24 25 records as being -- at least that blood pressure TACKLA & ASSOCIATES 95 1 as being her blood pressure at 2:15 a.m.? 2 MR. JEFFERS: Remember she 3 described about going from one to, you know 4 -- from taking herself from going to the 5 pulse ox and then sometimes going back. 6 Q What I'm trying to establish is whether or 7 not it's reasonable to assume that the 100 over 44 8 recorded in the graphic on page 24 -- 9 A Uh-huh. 10 Q -- references the 100 over 44 that's on 11 page 142. 12 A Oh, I see what you're saying. 13 MR. JEFFERS: Where is that? 14 You're looking at -- 15 THE WITNESS: This is it. 16 MR. JEFFERS: What time is that? 17 THE WITNESS: 2:15. 18 MR. JEFFERS: 2:15. Go back, find 19 2:15. 20 THE WITNESS: Yeah. 21 MR. JEFFERS: You may need to 22 move. 23 THE WITNESS: Okay. 24 A It wasn't -- oh, there was also another one 25 at 2:15 at 100 over 44, so it would have been the TACKLA & ASSOCIATES 96 1 same blood pressure at both times. 2 Q Okay. 3 MR. JEFFERS: Plus then you'll 4 notice there are two others at that time: 5 one pulse ox and one going back to her 6 regular check. 7 Q Well, on this graphic portion or this 8 page 142 you have documentation of blood pressures 9 that were taken around 2:15 -- 10 A I'm sorry. At -- 11 MR. JEFFERS: Page 142? 12 MR. SCHOBERT: Yeah, page 142 or -- 13 Q Do you have blood pressures -- or 143. Do 14 you note blood pressures that were taken at 15 2:15 -- 16 A Okay. 17 Q -- or thereabouts? 18 MR. JEFFERS: Yeah. 19 Q Yeah, you do. 100 over 44. 20 MR. JEFFERS: There are three 21 blood pressures, yes. 22 A Yeah. 23 Q But if I -- what confuses me is that you 24 noted -- if you look at page 143, you see it says 25 02:15. You see that entry, date, 6/26? TACKLA & ASSOCIATES 97 1 A Yes. 2 Q First blood pressure there says 100 over 44, 3 right? 4 A Correct, yes. 5 Q If you go back to page 142, that first blood 6 pressure that you record there says 100 over 44. 7 MR. JEFFERS: At what time? 8 MR. SCHOBERT: Well, we go 9 down to that section there where she's been 10 been referring to earlier. 11 MR. JEFFERS: Well, tell us the 12 time. 13 MR. SCHOBERT: Well, it says 00:30. 14 MR. JEFFERS: All right. 15 A They could have likely been the same blood 16 pressure. 17 Q Then go -- go back to page 143. You see 18 where it says, "Recheck" -- 19 A Yes, uh-huh. 20 Q -- "88 over 53"? 21 A Yes. 22 Q Go back to page 142. 23 A Uh-huh. 24 Q Doesn't it say, "Recheck, 88 over 53"? 25 A Yes. Yes. TACKLA & ASSOCIATES 98 1 MR. JEFFERS: At what time? 2 MR. SCHOBERT: It's Just at that 3 00:30. 4 MR. JEFFERS: Wait. Wait a 5 minute. 6 MR. SCHOBERT: See what I'm getting 7 at? 8 MR. JEFFERS: Okay. Go ahead. 9 No, you tell us what you want. 10 Q Well, my point is is -- is -- is it your 11 belief that at 12:30 and at 2:15 a.m. you got the 12 exact same two blood pressures and on recheck you 13 got the exact same blood pressure? 14 A Then at 2:15 -- I don't recall for sure. I 15 don't recall. The only -- 16 MR. JEFFERS: Go ahead. You can 17 explain. 18 A To give an explanation, sometimes when we 19 record them, if we forget to change the time on 20 there it might have shown up like a different 21 time. Because I do also have another one at 22 00:30, um, that was the 119 over 64, so I possibly 23 could have not changed the time. Or you see what 24 I mean? 25 Q No, I understand exactly what you mean. And TACKLA & ASSOCIATES 99 1 I understand from looking at this it would appear 2 to me that if you take your graphics that are in 3 that page 24 and you correlate them to what 4 transpires on page 142, 143, it would be more 5 likely that the blood pressure of 100 over 44 and 6 the recheck of 88 over 53 occurred at 2:15 a.m. -- 7 A That's what I -- I would -- 8 Q -- rather than as was implied in the initial 9 questions to you at around 12:30 a.m. 10 A Okay. 11 Q Is that -- based on your understanding and 12 knowledge of the way the computer system works and 13 what you're required to do, would that be a 14 more -- would that be your interpretation of this 15 discrepancy? 16 A That would be my interpretation. Just when 17 I went to put it in the time was -- I forgot to 18 change the time on the computer. 19 Q All right. Going back to your page 160 -- 20 MR. GORDON: What page are you 21 on? 22 MR. SCHOBERT: 160. I believe 23 those are her nursing notes. 24 Q When I look at the entry at 00:30 on that 25 page for June 26th, your entry -- do you see that? TACKLA & ASSOCIATES 100 1 A Yes, uh-huh. 2 Q Is it fair to assume that Dr. Hsieh was 3 apparently at the room at or about 12:30? 4 A Yes. 5 Q And he specifically performed, as you've 6 testified, a vaginal exam and rectal exam and the 7 chief concern was whether or not this patient 8 might be bleeding -- 9 A Into a hematoma. 10 Q -- into a hematoma which might be a cause 11 for some of the problems? 12 A Restlessness and that kind of -- that kind 13 of behavior. 14 Q And that was -- specifically you needed a 15 physician in the room at that time in order to 16 perform a rectal and vaginal exam in order to get 17 clinical findings to learn more about whether 18 there might be some type of bleed? Is that -- 19 A Correct. 20 Q -- what happened? 21 A Yes. 22 Q Now the next entry at 00:45, that last part 23 of that entry, Dr. Hsieh's exam, et cetera, you 24 put in; see that? 25 A Okay. TACKLA & ASSOCIATES 101 1 Q Now as I understand it, you would have 2 attempted to tell Dr. Hahn what it was that 3 Dr. Hsieh learned from this vaginal and rectal 4 exam that a physician needed to be performed; is 5 that correct? 6 A Correct. And also, as I mentioned before, 7 that he did check, you know, palpated her abdomen 8 and checked the Foley. So that's what I was 9 trying to say at that point. 10 Q And if Dr. Hsieh's progress note at -- that 11 was placed on the chart subsequent to that visit 12 indicated that he was specifically concerned about 13 hemoglobin and hematocrit, that would be 14 consistent with at least in part what he was there 15 to do, to determine if there was a bleed and 16 whether this patient was abnormally bleeding, 17 correct? 18 MR. GORDON: Objection. 19 Q According to what you recall from that 20 evening? 21 A That would correlate, yeah. 22 Q Okay. You were asked a lot of questions 23 about what you specifically recall from that visit 24 that Dr. Hsieh had with the patient in your 25 presence at or about 12:30; do you remember that? TACKLA & ASSOCIATES 102 1 A Yes. 2 Q And then you were asked a series of 3 questions about custom and habit as to what you 4 may or may not do under given circumstances; do 5 you remember that? 6 A Yes. 7 Q Just so I'm clear, you independently recall 8 what from that visit with Dr. Hsieh? 9 In your mind's eye as you sit here 10 today, what do you recall while you and Dr. Hsieh 11 were in the room with the patient, first of all? 12 A Okay. In the room with the patient I 13 remember him talking to her, just kind of a 14 general feel, I think, just for the feel of, you 15 know, what she was like, what she was -- you know, 16 her affect and her -- if she was uncomfortable and 17 that, that kind of stuff. Also her -- he did 18 listen to her lungs, I remember that, palpated her 19 abdomen, checked for placement of the catheter 20 because we were again worried about the output, 21 and did do the vaginal and rectal exam. 22 Q All right. And those are the things as you 23 sit here today you can recall having either 24 independent recall or having the chance to review 25 your notes and then that aiding you in any TACKLA & ASSOCIATES 103 1 independent recall that you have; is that correct? 2 A Correct. 3 MR. SCHOBERT: I have no further 4 questions. Thanks. 5 - - - - - 6 RECROSS-EXAMINATION 7 BY MR. PARIS: 8 Q I just have a couple of quick questions and 9 I really did not understand the import of what you 10 were saying about the blood pressures that were 11 recorded at 12:30 a.m. -- 12 MR. SCHOBERT: Wait a second, 13 David. I have your mike. 14 MR. PARIS: Thank you. 15 Q Help me understand the import of your 16 answers to Mr. Schobert about the blood pressures 17 that were taken at 12:30 a.m. and the blood 18 pressures taken at 2:30 a.m. 19 Am I to understand that blood pressures 20 were taken at 12:30 a.m. by you in your initial 21 assessment? 22 A Yes. Let me just find that. 23 MR. JEFFERS: Just a second. 24 She'll get it. 25 Q I'm sorry. TACKLA & ASSOCIATES 104 1 A Hold on a second. 2 Q I'm talking about blood pressures at 12:30 3 and 2:15 a.m. 4 A At 2:15, okay. 5 Q And initially you took blood pressures as 6 part of your initial assessment at 12:30 a.m.? 7 A Yes, uh-huh. 8 Q And can you tell me what the blood pressures 9 were at 12:30 a.m.? 10 A At -- according to both of these, the 11 graphic -- 12 Q We're looking at the graphic on page 24 and 13 your notes on page 142? 14 A 142, yes. 15 Q All right. Please tell me. 16 A 119 over 64, temp of 100.4, and pulse of 17 128, and then what I noted below -- that was noted 18 here in the note 00:30, okay, and then the second 19 set of blood pressures is also noted at 00:30 with 20 a different set of blood pressures that -- which 21 you were asking about. Um, but -- let's see. In 22 the graphic it is noted at 2:15 that same -- that 23 100 over 44 with a recheck, and in the graphic it 24 is 100 over 44 at 2:15 with the same pulse of 117. 25 What I'm assuming, if I can do that, TACKLA & ASSOCIATES 105 1 assuming what happened, is sometimes if we have a 2 series of blood pressures we'll write them down 3 and then go back to put them in. When I went -- 4 you can tell at 12:30, at 00:30, I put it in at 5 2:39 and noted it for 12:30. I believe what might 6 have happened is that when I went to note the 2:15 7 blood pressure, because you have to manually put 8 in the time you took it at, I probably left the 9 computer at 00:30 and did not change the time to 10 accommodate that, that particular. 11 Q So as you sit here today you believe that 12 the 12:30 a.m. blood pressure was what? 13 A 119 over 64. 14 Q Was there any rechecks at that time? 15 A At that time, um, no, not that I know of. 16 MR. JEFFERS: This is what time? 17 MR. PARIS: 12:30 a.m. 18 THE WITNESS: 12:30 a.m. 19 Q And do you normally recheck it twice? 20 A Not -- not unless it seems likes it's 21 something unusual. 22 Q Do you ever recheck it three times? 23 A Sometimes if it's indicated. 24 Q So can we assume then that at -- that you 25 did not perform any rechecks of her blood pressure TACKLA & ASSOCIATES 106 1 at 12:30 a.m.? 2 A Correct, from what -- from what I can 3 assume. 4 Q And then are we also to assume at 2:15 a.m. 5 the initial blood pressure was 100 over 44? 6 A From what I can -- how do I say that -- from 7 what I can tell from the notes, I'm assuming 8 that's what happened, that I just did not change 9 the time. 10 Q Okay. 11 A Only because it's indicated in the graphic 12 that it was that particular one at 2:15. 13 Q And it was rechecked at 2:15 at 88 over 53? 14 A Yes. 15 Q And then a third time at 120 over 60? 16 A Yes. 17 Q As it relates to the -- your nurses' notes, 18 for example we'll just take page 143 of the 19 Bates stamped, you have two times at the 20 2:15 vital signs? 21 A Yes. 22 Q You have 6/26, 2:15 PVP? 23 A Uh-huh. 24 Q Then 6/26, 03:04. What does the 03:04 refer 25 to? TACKLA & ASSOCIATES 107 1 A That's the time I believe that it was -- 2 that I actually put it in, sat down at the 3 computer and put it in and dated it back. 4 Q Okay. And that is consistent throughout 5 your nurses' notes? 6 A I believe so. As far as I know. 7 Q Okay. Are there any other errors that 8 you're aware of in the chart other than that which 9 was pointed out by Mr. Schobert? 10 A Not that I'm aware of. 11 MR. PARIS: Thank you very much. 12 MR. BONEZZI: I have one question. 13 - - - - - 14 CROSS-EXAMINATION 15 BY MR. BONEZZI: 16 Q On page 24 of the graphics -- 17 MR. SCHOBERT: You have to get it 18 from David. John's not giving his up. 19 A Yes. 20 Q Page 24 of the graphics you will note in the 21 right-hand column BP, and then the source. What 22 does LYI stand for? 23 A That would be lying. 24 MR. SCHOBERT: Pardon? 25 THE WITNESS: Lying down. TACKLA & ASSOCIATES 108 1 MR. BONEZZI: Thank you. 2 MR. PARIS: Okay. 3 MR. JEFFERS: That's it. 4 No waiver. 5 THE VIDEOGRAPHER: One-day filing 6 requirement? 7 MR. JEFFERS: 30 days, please, in 8 getting the signature. 9 MR. PARIS: Sure. 10 MR. GORDON: Do you want her to 11 review the videotape too? 12 MR. JEFFERS: No, just the 13 transcript. 14 MR. PARIS: Thank you, John. 15 MR. JEFFERS: Just needs to see 16 the transcript. I've already made 17 arrangements. It will be sent directly 18 here, but I would like the 30 days instead 19 of the seven just because what we are 20 getting into. 21 MR. PARIS: You can have 22 whatever you want. 23 MR. JEFFERS: Thank you. 24 MR. PARIS: I'm going to get 25 these quickly. TACKLA & ASSOCIATES 109 1 - - - - - 2 (Whereupon, discussion was held off the 3 record at this time.) 4 - - - - - 5 (Whereupon, deposition was concluded at 6 10:50 a.m.and signature was not waived at 7 this time.) 8 - - - - - 9 10 11 ___________________________ 12 Paulette Prokop 13 - - - - - 14 15 16 17 18 19 20 21 22 23 24 25 TACKLA & ASSOCIATES 110 1 CERTIFICATE 2 3 The State of Ohio, ) 4 ) SS: 5 County of Cuyahoga. ) 6 7 I, Suzanne Lamparter, a Notary Public within 8 and for the State of Ohio, duly commissioned and 9 qualified, do hereby certify that the within-named 10 witness, PAULETTE PROKOP, was by me first duly 11 sworn to testify the truth, the whole truth, and 12 nothing but the truth in the cause aforesaid; that 13 the testimony then given by the above-referenced 14 witness was by me reduced to stenotype in the 15 presence of said witness, afterward transcribed, 16 and that the foregoing is a true and correct 17 transcription of the testimony so given by the 18 above-referenced witness. 19 I do further certify that this deposition 20 was taken at the time and place in the foregoing 21 caption specified and was completed without 22 adjournment. 23 I do further certify that I am not a 24 relative, counsel, or attorney of either party, or 25 otherwise interested in the event of this action. TACKLA & ASSOCIATES 111 1 IN WITNESS WHEREOF, I have hereunto set my 2 hand and affixed my seal of office at Cleveland, 3 Ohio, on this 17th day of November, A.D., 2000. 4 5 6 _________________________________________ 7 Suzanne Lamparter, Notary Public in and 8 for the State of Ohio. 9 My commission expires November 30, 2002. 10 - - - - - 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TACKLA & ASSOCIATES