Bader Cassin, MD

4       MS. ISAACSON:  DEFENSE CALLS DR. BADER CASSIN.

 

 5       THE COURT:  DOCTOR, WOULD YOU STEP UP HERE PLEASE?

 

 6  WOULD YOU RAISE YOUR RIGHT HAND PLEASE AND FACE CLERK AND

 

 7  SHE'LL PLACE YOU UNDER OATH.

 

 8       IF YOU'LL HAVE A SEAT UP HERE, DOCTOR.  IF YOU'LL GIVE

 

 9  US YOUR FULL NAME AND SPELL THE LAST NAME PLEASE.

 

10       THE WITNESS:  THANK YOU.  MY NAME IS BADER CASSIN,

 

11  C-A-S-S-I-N.

 

12  BY MS. ISAACSON:

 

13  Q.   DR. CASSIN, WHAT IS YOUR OCCUPATION?

 

14  A.   I'M A PHYSICIAN.

 

15  Q.   AND DO YOU PERFORM AUTOPSIES?

 

16  A.   I DO.

 

17  Q.   AND WHAT FURTHER QUALIFICATIONS OTHER THAN BEING A

 

18  PHYSICIAN DO YOU HAVE TO PERFORM AUTOPSIES?

 

19  A.   WELL, I'M -- I HAVE SUB -- EXCUSE ME.  I HAVE SPECIALTY

 

20  TRAINING IN PATHOLOGY.  I HAVE WORKED AS A HOSPITAL

 

21  PATHOLOGIST FOR OVER TEN YEARS.  AND THEN I DID A FELLOWSHIP

 

22  IN FORENSIC PATHOLOGY AND HAVE BEEN DOING THAT FOR THE LAST

 

23  20 YEARS.  SO I HAVE BEEN TRAINED, FIRST OF ALL, IN PATHOLOGY

 

24  AND THEN SUBSEQUENTLY TRAINED IN A SUBSPECIALTY OF FORENSIC

 

25  PATHOLOGY, WHICH ESSENTIALLY HAS ME DOING AUTOPSIES SOLELY

 

 1  FOR THE LAST 15 OF THOSE 25 YEARS.

 

 2  Q.   AND ARE YOU A MEDICAL EXAMINER?

 

 3  A.   YES.

 

 4  Q.   AND DO YOU HAVE TO HAVE A LICENSE TO BE A MEDICAL

 

 5  EXAMINER?

 

 6  A.   YOU HAVE TO HAVE A MEDICAL LICENSE TO BE A MEDICAL

 

 7  EXAMINER, BUT THERE IS NO SUCH THING AS A MEDICAL EXAMINER

 

 8  LICENSE.

 

 9  Q.   WHERE DO YOU PERFORM AUTOPSIES AND WHO DO YOU WORK FOR

 

10  CURRENTLY?

 

11  A.   I WORK IN THE STATE OF MICHIGAN.  I HEADQUARTER IN ANN

 

12  ARBOR WHERE I ALSO TEACH AT THE UNIVERSITY OF MICHIGAN.  I'M

 

13  A MEDICAL EXAMINER FOR TWO OF THE COUNTIES IN THE STATE OF

 

14  MICHIGAN AND I DO THE FORENSIC AUTOPSIES FOR THE MEDICAL

 

15  EXAMINER IN AN ADJACENT COUNTY IN ADDITION TO THAT AS WELL AS

 

16  GETTING CASES REFERRED TO ME FROM AROUND THE STATE BY VARIOUS

 

17  PROSECUTORS OR MEDICAL EXAMINERS BECAUSE WE ARE A HEALTH

 

18  CENTER JUST AS THE SALT LAKE CITY AREA IS A HEALTH CENTER.

 

19  Q.   AND SO HOW DOES AN AUTOPSY COME TO YOU TYICALLY?

 

20  A.   AS A MEDICAL EXAMINER, IT COMES TO ME BECAUSE OF A

 

21  REPORT OF DEATH, A DEATH THAT WOULD APPEAR TO MEET THE

 

22  REQUIREMENTS OF LAW.  AND YOU HAVE THE SAME LAW IN THIS

 

23  STATE.  AND IS IS ESSENTIALLY THAT A PERSON HAS DIED UNDER

 

24  THE CIRCUMSTANCES OF EITHER AN UNNATURAL DEATH, WHICH MEANS

 

25  THAT THEY HAVE DIED BECAUSE OF SOMETHING THAT IS NOT DUE TO

 

 1  DISEASE, AN INJURY IN OTHER WORDS, OR SOMETHING THAT MIGHT BE

 

 2  DUE TO SOMETHING OTHER THAN DISEASE.

 

 3  Q.   AND HOW MANY AUTOPSIES HAVE YOU PERFORMED OVER THE

 

 4  COURSE OF YOUR CAREER?

 

 5  A.   SOMEWHERE BETWEEN TEN AND TWELVE THOUSAND I'VE DONE

 

 6  MYSELF.  I'VE SUPERVISED THAT MANY MORE, BUT THAT I'M SURE IS

 

 7  THE NUMBER I'VE DONE MYSELF.

 

 8  Q.   DO YOU ALSO PERFORM AUTOPSIES IN HOSPITALS?  OR RELATED

 

 9  TO HOSPITAL DEATHS?

 

10  A.   RELATED TO HOSPITAL DEATHS, I HAVE PERFORMED MANY, AND

 

11  STILL DO.  FOR INSTANCE, I AM ONE OF THE STAFF PATHOLOGISTS

 

12  FOR THE PATHOLOGY SERVICE AT THE UNIVERSITY OF MICHIGAN AS

 

13  WELL AS FOR THE ADJACENT TERTIARY CARE CENTER, WHICH IS

 

14  ST. JOB MERCY HOSPITAL IN ANN ARBOR.  IN THAT ROLE I

 

15  SUPERVISE PATHOLOGISTS IN TRAINING IN DOING THEIR AUTOPSIES,

 

16  TRAIN THEM IN TECHNIQUES OF AUTOPSY AS WELL AS AN

 

17  INTERPRETATION OF THEIR FINDINGS, REVIEW OF THEIR FINDINGS,

 

18  THAT SORT OF THING.  BEFORE THAT OF COURSE I DID HOSPITAL

 

19  AUTOPSIES MYSELF AS A HOSPITAL PATHOLOGIST.

 

20  Q.   AND HOW ARE THESE HOSPITAL AUTOPSIES DIFFERENT FROM

 

21  OTHER TYPE OF AUTOPSIES?

 

22  A.   HOSPITAL AUTOPSIES ARE DONE AS A WAY OF SUBSTANTIATING

 

23  OFTEN DIAGNOSES THAT ARE MADE CLINICALLY.  THEY -- THERE IS A

 

24  GREAT ATTENTION TO DETAILS THAT MIGHT NOT OTHERWISE BE

 

25  ATTENDED TO FOR THE PURPOSES OF EDUCATION AT LEAST IN PLACES

 

 1  WHERE I WORK.  SO THAT MEDICAL STUDENTS THAT WE TEACH AS WELL

 

 2  AS MEDICAL AND OTHER SURGICAL RESIDENTS AND PATHOLOGY

 

 3  RESIDENTS CAN BE FURTHER TRAINED IN THE MINUTIAE OF WHAT IS

 

 4  FOUND IN THE BODY, AND CORRELATE WITH RADIOGRAPHS AND OTHER

 

 5  LABORATORY TESTS AND OTHER SUCH CLINICAL TESTS.  WHEREAS

 

 6  FORENSIC AUTOPSIES THAT ARE DONE UNDER THE AEGIS OF A MEDICAL

 

 7  EXAMINER SYSTEM ARE DONE PRIMARILY TO IDENTIFY AN INJURY OR

 

 8  TO EXCLUDE AN INJURY IF INDEED THERE IS A QUESTION ABOUT

 

 9  WHETHER OR NOT ONE EXISTS.  BUT THEY DONE THOROUGHLY TO FOCUS

 

10  IN UPON THAT ISSUE.

 

11  Q.   SO IF YOU'RE DOING A HOSPITAL AUTOPSY, LET ME MAKE SURE

 

12  I UNDERSTAND, IS THIS A SITUATION WHERE YOU'RE TRYING TO

 

13  CONFIRM WHAT THE TREATING PHYSICIAN THOUGHT THE CAUSE OF

 

14  DEATH WAS?  IS THAT -- DO I HAVE IT RIGHT?

 

15  A.   THE EFFORT IS NOT TO CONFIRM.  THE EFFORT IS TO BE

 

16  INDEPENDENT.  THE CLINICIAN WOULD LIKE US TO CONFIRM THE

 

17  CLINICAL DIAGNOSIS.  WE MIGHT, HOWEVER, FIND SOMETHING THAT

 

18  IS DIFFERENT, EITHER DIFFERENT IN DEGREE OR DIFFERENT FROM

 

19  EVEN KNOWN DIAGNOSIS.  BUT THE EFFORT CLINICALLY IS TO -- IS

 

20  TO CONFIRM OR CORRELATE THE FINDINGS AT AUTOPSY WITH THOSE

 

21  FINDINGS MADE DURING LIFE.

 

22  Q.   AND SO WOULD IT OFTEN BE THAT AN ATTENDING PHYSICIAN OR A

 

23  CLINICIAN WHO WAS TREATING THE PATIENT RIGHT BEFORE THEY DIED

 

24  WOULDN'T ALWAYS GET IT EXACTLY RIGHT ON THE CAUSE OF DEATH?

 

25  A.   OH, THAT'S VERY TRUE.  I WOULD SAY THE GREAT MAJORITY OF

 

 1  CLINICIANS GET IT RIGHT, BUT AS YOU SAY, NOT EXACTLY RIGHT.

 

 2  THERE MAY BE SOME ADDITIONAL THINGS EITHER BY DEGREE OR BY

 

 3  PERHAPS SMALL DIFFERENCE FROM THEIR CLINICAL DIAGNOSES THAT

 

 4  THEY LEARN THROUGH THE AUTOPSIES ON THEIR PATIENTS, WHICH IS

 

 5  REALLY THE PRINCIPAL REASON FOR THE HOSPITAL AUTOPSIES --

 

 6  Q.   OKAY.

 

 7  A.   -- IN PLACES WHERE I DO THOSE.

 

 8  Q.   HOW DID YOU GET INVOLVED IN THIS PARTICULAR CASE?

 

 9  A.   I GOT -- I'M NOT EVEN SURE I REMEMBER, BUT I RECEIVED A

 

10  COMMUNIICATION FROM YOUR LAW FIRM ASKING ME TO REVIEW SOME

 

11  DEATHS AND TO INDICATE WHETHER I WOULD BE INTERESTED IN

 

12  MAKING A FORMAL DETERMINATION OF CAUSE AND MANNER OF DEATH IF

 

13  I WERE GIVEN THE OPPORTUNITY TO REVIEW THE RECORDS AVAILABLE

 

14  IN THAT CASE.  I HAVE TO TELL YOU RIGHT AWAY, EVEN THOUGH

 

15  YOU'RE NOT ASKING ME THIS QUESTION --

 

16       MR. MAJOR:  YOUR HONOR, WE'RE GONNA OBJECT.  IT'S NOT

 

17  RESPONSIVE --

 

18       THE COURT:  SUSTAINED.

 

19       MR. MAJOR:  -- TO THE QUESTION.

 

20  Q.  (BY MS. ISAACSON)  WHAT IS IT THAT -- ONCE YOU RECEIVED

 

21  THAT COMMUNICATION FROM MY OFFICE, WHAT WAS YOUR NEXT STEP?

 

22  A.   MY NEXT STEP WAS TO REVIEW THE MATERIALS THAT HAD BEEN

 

23  SENT FOR PREVIEW, WHICH I DID.  AND THEN RESPONDED BY SAYING

 

24  THAT I WOULD PURSUE THIS.

 

25  Q.   AND SO YOU REVIEWED THE MEDICAL EXAMINER FILES THAT OUR

 

 1  OFFICE PROVIDED TO YOU?

 

 2  A.   I DID.

 

 3  Q.   AND THE MEDICAL RECORDS OF ALL THE PATIENTS DURING THEIR

 

 4  STAY AT THE GEROPSYCHIATRIC UNIT?

 

 5  A.   I DID.

 

 6  Q.   IN REVIEWING EACH OF THESE FIVE PATIENTS -- WELL, LET ME

 

 7  BACK UP A LITTLE BIT.  WITH REGARD TO THE ISSUE OF MORPHINE,

 

 8  IN YOUR EXPERIENCE AND IN YOUR PRACTICE, DO YOU SEE MORPHINE

 

 9  OR OTHER OPIATES IN TOXICOLOGY REPORT -- IN TOXICOLOGY

 

10  RESULTS?

 

11  A.   MANY TIMES.

 

12  Q.   AND HOW DO YOU RESPOND OR HOW DO YOU INTERPRET THE

 

13  PRESENCE OF MORPHINE OR OTHER OPIATES IN TOXICOLOGY RESULTS

 

14  IN AN AUTOPSY?

 

15  A.   WELL, IT'S ENTIRELY WITH REGARD TO THE CONTEXT.  ONE

 

16  NEEDS TO PLACE THE FINDING OF MORPHINE POST MORTEM AND THE

 

17  TESTING DONE POST MORTEM INTO THE KNOWN INCIDENTS THAT ARE

 

18  PRESENT DURING LIFE SO AS TO INTERPRET THEM PROPERLY.

 

19  Q.   WHAT KIND OF PATIENTS HAVE YOU SEEN THESE KIND OF

 

20  RESULTS IN?

 

21       MR. MAJOR:  OBJECTION, YOUR HONOR.  I'M NOT SURE WHAT

 

22  THE RELEVANCY OF THIS QUESTION IS.

 

23       THE COURT:  OVERRULED.  GO AHEAD.

 

24       THE WITNESS:  THE KINDS OF PATIENTS WOULD BE PATIENTS

 

25  WHO ARE TREATED FOR SEVERE INJURIES DURING WHICH THEY ARE

 

 1  CONSCIOUS AND EXPERIENCING PAIN.  AND MORPHINE IS GIVEN AS A

 

 2  WAY OF REDUCING PAIN.  THEY ARE IN PATIENTS WHO ARE

 

 3  SEMICOMATOSE AND DYING.  AND THESE ARE PATIENTS WHO ARE

 

 4  RECEIVING MORPHINE FOR CONTROL OF PAIN AS WELL AS FOR COMFORT

 

 5  CARE IN THEIR LAST HOURS OR DAYS OF LIFE.  THAT SORT OF

 

 6  THING.  I ALSO SEE MORPHINE IN PATIENTS -- NOT PATIENTS, IN

 

 7  BODIES WHO HAVE NO CLINICAL HISTORY.  WHO HAVE NO ABNORMALITY

 

 8  IN THEIR BODY.  WHOSE BODIES ARE FOUND IN PLACES THAT THEY

 

 9  WEREN'T EXPECTED TO DIE.  AS A MEDICAL EXAMINER, I SEE THOSE

 

10  AS WELL.

 

11  Q.  (BY MS. ISAACSON)  ALL RIGHT.  LET'S TALK ABOUT THE

 

12  SPECIFIC PATIENTS.  NOW, THE MEDICAL EXAMINER'S OFFICE HERE

 

13  IN UTAH PREPARED AN AUTOPSY REPORT IN EACH CASE THAT YOU'VE

 

14  REVIEWED, IS THAT RIGHT?

 

15  A.   YES.

 

16  Q.   I'D LIKE TO GO TO THE AUTOPSY REPORT OF ELLEN ANDERSON.

 

17  AND THIS IS, COUNSEL AND YOUR HONOR, STATE'S 2-D, PAGE 1 OF

 

18  ELLEN ANDERSON'S AUTOPSY REPORT.  WE DON'T HAVE A -- WELL,

 

19  FIRST OF ALL, CAN YOU TELL ME WHAT -- WHAT IS INCLUDED ON

 

20  THIS FIRST PAGE OF ELLEN ANDERSON'S REPORT?

 

21  A.   THIS IS A SUMMARY PAGE WHICH IS FREQUENTLY FOUND ON THE

 

22  FRONT OF AUTOPSY REPORTS AND IT IS THE FORMAT APPARENTLY FOR

 

23  THE STATE MEDICAL EXAMINER'S OFFICE IN UTAH WHEREBY IT GIVES

 

24  AN IDENTIFIER AT THE TOP.  HAS THREE PARTS REALLY, IT HAS --

 

25  ON THIS PAGE ANYWAY, ALTHOUGH THERE ARE FOUR IN THE SUMMARY,

 

 1  FOUR PARTS IN THE SUMMARY.  THE FIRST PART OF THE SUMMARY IS

 

 2  IDENTIFICATION DATA.  WHO AND WHEN AND WHERE THE PERSON WAS

 

 3  AND WHETHER THE AUTOPSY WAS DONE AND SO ON AND BY WHOM.

 

 4  UNDER THAT, IT GIVES THE CAUSE AND MANNER OF DEATH, WHICH IS

 

 5  WHAT A MEDICAL EXAMINER IS REQUIRED BY LAW TO DO.  NAME A

 

 6  CAUSE AND MANNER OF DEATH.  THAT'S THE ONLY REASON TO DO A AN

 

 7  AUTOPSY, OR SHOULD BE ACCORDING TO LAW.  AND THE THIRD PART

 

 8  OF THE SUMMARY IS TO GIVE DIAGNOSES, TO -- AN ENNUMERATION OF

 

 9  DIAGNOSES, AND IN THIS CASE, CLUSTERED IN SOME WAY THAT SHOWS

 

10  RELATIONSHIP OF ONE FINDING TO THE OTHER.

 

11  Q.   SO DO I UNDERSTAND WITH REGARD TO ELLEN ANDERSON, THIS

 

12  IS A LIST OF THINGS THAT THE MEDICAL EXAMINER FOUND WHEN HE

 

13  PERFORMED THE AUTOPSY?

 

14  A.   THAT'S THE WAY I UNDERSTAND IT.  AND I UNDERSTAND IT

 

15  THAT WAY BECAUSE FOLLOWING THIS, THERE IS A NARRATIVE THAT

 

16  DESCRIBES BY DIFFERENT ORGAN SYSTEMS AND REGIONALLY IN THE

 

17  BODY THOSE SPECIFIC FINDINGS AS THEY ARE DISCOVERED DURING

 

18  THE PROCEDURE.  AND WHEN I CORRELATE THOSE PROCEDURES WITH

 

19  THIS LIST, I SAY, YES, THAT'S CLEARLY WHAT THIS EFFORT IS.

 

20  AND THAT'S CUSTOMARY, AS I SAID.

 

21  Q.   IN ADDITION TO THE MEDICAL RECORDS YOU REVIEWED, DID YOU

 

22  ALSO OBTAIN PHOTOGRAPHS FROM THE MEDICAL EXAMINER'S OFFICE?

 

23  A.   I DID.

 

24  Q.   AND WERE PHOTOGRAPHS TAKEN OF -- WHAT WERE THE -- WHAT

 

25  DID THE PHOTOGRAPHS SHOW YOU WITH REGARD TO EACH PATIENT?

 

 1  A.   THE PHOTOGRAPHS DEPICTED THE REMOVAL OF BODIES FROM

 

 2  THEIR BURIAL PLACES, THE TRANSPORT TO THE MEDICAL EXAMINER

 

 3  OFFICE, THE APPEARANCE OF THE BODY CLOTHED AND UNCLOTHED.

 

 4  AND IN SOME CASES, INTERNAL PHOTOGRAPHS OF THE BODY DURING OR

 

 5  FOLLOWING AUTOPSY.

 

 6  Q.   AND WERE YOU ALSO ABLE TO REVIEW ALL OF MICROSCOPIC

 

 7  SLIDES THAT THE MEDICAL EXAMINER'S OFFICE HAD WITH REGARD TO

 

 8  EACH PATIENT?

 

 9  A.   YES, I DID REVIEW THOSE.  THEIR DESCRIPTION WAS LIKEWISE

 

10  INCLUDED IN THE REPORT, BUT I ASKED TO BE ABLE TO REVIEW

 

11  THOSE SLIDES BECAUSE IT IS A WAY OF COURSE OF REVIEWING

 

12  SOMEBODY ELSE'S WORK, WHICH IS WHAT I DO COMMONLY IN

 

13  REVIEWING OTHER AUTOPSIES AS WELL AS MY OWN.

 

14  Q.   WITH REGARD TO ELLEN ANDERSON AND THE DIAGNOSES THAT

 

15  WERE IDENTIFIED BY THE MEDICAL EXAMINER, COULD YOU EXPLAIN TO

 

16  US WHICH -- WHICH OF THESE DO YOU THINK ARE SIGNIFICANT AND

 

17  AND -- AND RELATE SPECIFICALLY TO CAUSE OF DEATH?

 

18  A.   WELL, THE CAUSE OF DEATH IS STATED AS UNDETERMINED, AND

 

19  THEREFORE, EVERYTHING RELATES OR NOTHING RELATES TO

 

20  UNDETERMINED SIMPLY BECAUSE THE MEDICAL EXAMINER IN THIS CASE

 

21  HAS CHOSEN NOT TO FIND A CAUSE OF DEATH.  THAT USUALLY IS A

 

22  PRIVILEGE GIVEN BY THE STATE TO MEDICAL EXAMINERS ALONE SO AS

 

23  TO ALLOW THEM TO SAY, I DON'T KNOW.  THAT IS ESSENTIALLY WHAT

 

24  THAT MEANS.  I DON'T KNOW.  IT COULD ALSO MEAN THAT I DON'T

 

25  WANT TO KNOW OR I DON'T WANT TO TELL YOU.  AFTER ALL, THAT'S

 

 1  WHAT UNDETERMINED MIGHT LIKEWISE MEAN.  FRANKLY, I DON'T KNOW

 

 2  HOW THE MEDICAL EXAMINER MEANT IT HERE, BUT IN ANY CASE,

 

 3  THERE WAS NO SPECIFIC FINDING OF A CAUSE OF DEATH.

 

 4  Q.   WHAT WERE THE SIGNIFICANT FINDINGS TO YOU IN THIS LONG

 

 5  LIST OF FINDINGS BY DR. GREY?  AND WE CAN -- WE CAN GO OVER

 

 6  THIS OR WE CAN TALK ABOUT SOME OF YOUR FINDINGS, HOWEVER

 

 7  YOU'D LIKE TO DO THAT.

 

 8  A.   WELL, YOU ASKED ME WHAT I THINK IS SIGNIFICANT, SO LET

 

 9  ME QUICKLY GO OVER THIS WITH YOU AND THEN SHOW YOU SOMETHING

 

10  THAT I WOULD HAVE CONSTRUCTED HAD I CONSTRUCTED THE FINAL

 

11  AUTOPSY REPORT.  HAVING READ THE REPORT THOROUGHLY, LOOKED AT

 

12  THE PHOTOGRAPHS, AND LOOKED AT THE MICROSCOPIC SECTIONS.

 

13  BECAUSE I DON'T BELIEVE THAT THIS LIST NECESSARILY REFLECTS

 

14  THE FINDINGS AS THEY SHOULD HAVE BEEN DEPICTED ON THE FINAL

 

15  AUTOPSY LIST.  AND I THINK THE REASON MIGHT BE, IF I MIGHT

 

16  SAY THIS, THE REASON MIGHT BE THAT THE AUTOPSIES WERE CON --

 

17       MR. MAJOR:  YOUR HONOR, WE'RE GONNA OBJECT TO THAT.  IT

 

18  SOUNDS HE'S MAKING ASSUMPTION HERE.

 

19       THE COURT:  SUSTAINED.  YOU'RE NOT TO RESPOND TO THAT

 

20  QUESTION AT LEAST AT THIS POINT, DOCTOR. .

 

21       THE WITNESS:  OKAY.  OKAY.

 

22       THE COURT:  GO AHEAD.

 

23  Q.  (BY MS. ISAACSON)  DR. CASSIN, OBVIOUSLY, THIS LIST WAS

 

24  COMPILED BY THE MEDICAL EXAMINER'S OFFICE HERE, AND WE'LL

 

25  TALK A LITTLE BIT LATER ABOUT THE LIST THAT YOU HAVE

 

 1  COMPILED.  WERE THERE FACTORS THAT YOU SAW IN THE PHOTOGRAPHS

 

 2  OR IN THE REPORTS THAT WOULD SUGGEST TO YOU A REASON WHY HIS

 

 3  FINDINGS WOULD BE DIFFERENT FROM YOUR --

 

 4       MR. MAJOR:  I OBJEC -- OBJECTION, YOUR HONOR.  STILL

 

 5  CALLS FOR SPECULATION.

 

 6       THE COURT:  OVERRULED.

 

 7       THE WITNESS:  I WOULD PROPOSE, ALTHOUGH I DON'T KNOW

 

 8  PATHOLOGISTS WHO DID THESE FIVE AUTOPSIES, BUT I WOULD

 

 9  PROPOSE THAT THEY MAY NOT HAVE HAD EITHER SUFFICIENT

 

10  EXPERIENCE IN DOING BODIES -- DOING AUTOPSIES ON BODIES LONG

 

11  DEAD AND BURIED.  THIS BODY FOR INSTANCE WAS BURIED FOR FOUR

 

12  AND A HALF YEARS.  OTHERS WERE BURIED FOR THREE AND A HALF

 

13  YEARS, BUT NONE LESS TIME THAN THAT.  UNDERSTANDING WHAT

 

14  DECOMPOSITION DOES TO BODIES AND -- AND PERHAPS IN THAT

 

15  REGARD THERE WAS A GENERAL -- BECAUSE I DID FIND THIS, THERE

 

16  WAS A GENERAL UNDERINTERPRETATION OF FINDINGS PRIMARILY BECAUSE

 

17  THERE WAS NOT AN ADEQUATE UNDERSTANDING OF WHAT HAPPENS IN

 

18  THE DECOMPOSITION PROCESS.  LET ME EXPLAIN THAT BY SIMPLY

 

19  SAYING --

 

20       MR. MAJOR:  YOUR HONOR, THAT'S NOT RESPONSIVE TO THE

 

21  QUESTION.

 

22       THE COURT:  OVERRULED.  GO AHEAD.

 

23       THE WITNESS:  LET ME SAY THAT BY EXPLAINING THAT THE

 

24  DECOMPOSITION PROCESS -- AND I DON'T MEAN TO GIVE AN LECTURE

 

25  ON THIS -- INVOLVES A DETERIORATION, A PROGRESSIVE

 

 1  DETERIORATION ALL TISSUES OF THE BODY.  WE'RE ALL SUPPOSED TO

 

 2  GO BACK TO DUST, AND IN FACT, THAT'S WHAT EVENTUALLY HAPPENS.

 

 3  BUT IT HAPPENS AT A RATE THAT IS DEPENDENT UPON ENVIRNMENTAL

 

 4  FORCES, OF TEMPERATURE, HUMIDITY, TIME, AND OF COURSE

 

 5  EMBALMING.  HOWEVER, THERE IS A DETERIORATION OF ALL TISSUES

 

 6  PROGRESSIVELY.  IS IT NOT REASONABLE, FOR INSTANCE, TO

 

 7  BELIEVE -- BECAUSE I FIND THIS TO BE TRUE UNIFORMLY -- THAT

 

 8  IF NORMAL TISSUES DETERIORATE, SO ALSO SHOULD ABNORMAL

 

 9  TISSUES DETERIORATE.  WOULD SEEM TO MAKE SENSE.  WELL, I THINK

 

10  IT DOES AND IT CERTAINLY CORRELATES WITH MY EXPERIENCE, AND I

 

11  BELIEVE IT YOU ASK THESE PATHOLOGISTS, THEY'D PROBABLY AGREE

 

12  WITH THAT IN THEORY AS WELL.

 

13  Q.  (BY MS. ISAACSON)  AND I HEARD YOU USE THE TERM ABNORMAL

 

14  PROCESSES.  THAT'S WHAT WE'RE LOOKING FOR HERE IS WHEN YOU --

 

15  WHEN YOU PERFORM AN AUTOPSY, THAT'S WHAT YOU'RE TRYING TO

 

16  FIND, DO I HAVE THAT RIGHT?

 

17  A.   THE EFFORT HERE IS TO DETERMINE WHAT'S WRONG WITH THE

 

18  BODY OR WHAT'S WRONG WITH THE HISTORY, IF YOU WILL, WHAT IS

 

19  IN THE MEDICAL HISTORY THAT IS OF SIGNIFICANCE WITH REGARD TO

 

20  ONE'S LONGEVITY.  WHAT COULD AFFECT THEIR SURVIVAL.

 

21  Q.   WELL, WHAT ARE THE HIGHLIGHTS HERE FOR YOU OR YOUR

 

22  COMMENTS HERE ON THE FINDINGS BY OUR MEDICAL EXAMINER'S

 

23  OFFICE?

 

24  A.   WELL, I WOULD SAY, FIRST OF ALL, THAT THE -- THERE'S

 

25  POINTED OUT AND IT'S NUMBER ONE, THAT THERE IS A HISTORY OF

 

 1  ANTEMORTEM ADMINISTRATION OF MORPHINE.  I'D SAY, OKAY, FINE.

 

 2  THAT'S ONE OF THE MANY FACTS THAT'S PRESENT IN THE HOSPITAL

 

 3  RECORDS.  AND IN SPITE OF THE FACT THAT NONE IS FOUND, BUT

 

 4  PERHAPS THEY DIDN'T LOOK -- IN FACT, THEY DIDN'T LOOK IN THE

 

 5  RIGHT SPECIMENS FOR IT, BUT MAYBE THEY DON'T KNOW THAT.  BUT

 

 6  IN ANY CASE, THEY DIDN'T FIND MORPHINE IN SPITE OF THE

 

 7  PREVIOUS ADMINISTRATION.  THE OTHER POSSIBILITY IS THAT

 

 8  MORPHINE WASN'T PRESENT DURING -- AT THE TIME OF DEATH THAT

 

 9  HAD BEEN ADMINISTERED PRIOR TO THAT.  THE ARTERIOSCLEROTIC

 

10  CARDIOVASCULAR DISEASE IS A PRIMARY DIAGNOSIS.  I THINK IT'S

 

11  VERY IMPORTANT HERE --

 

12  Q.   CAN YOU TRANSLATE THAT INTO LAY --

 

13  A.   THIS IS ATHEROSCLEROSIS.  THIS IS THE PROCESS OF

 

14  HARDENING OF THE ARTERIES.  IT HAPPENS BY TWO PROCESSES.  ONE

 

15  IS THAT THE ARTERIAL WALLS THICKEN.  THEY BECOME SLUDGED LIKE

 

16  OLD PIPES AND IN FACT, SOME OF THAT SLUDGE OCASSIONALLY

 

17  HARDENS AND CALCIFIES, BECOMES RIGID, STRICTLY SPEAKING LIKE

 

18  PIPES, AS OPPOSED TO HOSES THAT ARE NICE AND FLEXIBLE.  THIS

 

19  LIMITS THE ABILITY OF BLOOD TO TRANSMIT OXYGEN ACROSS ITS

 

20  MEMBRANES.  IN FACT, IT ELIMINATES IT, AS WELL AS TO TAKE

 

21  CARBON DIOXIDE BACK INTO THE VESSELS AND TO THE RED CELLS AND

 

22  TRANSPORT THEM TO THE LUNGS FOR -- FOR RESUSCITATION, SO TO

 

23  SPEAK, WITH OXYGEN.  SO IN THIS CASE THE -- UNDER THE

 

24  CATEGORY OF ATERIOSCLEROSIS, WHICH IS LABELED NUMBER 2,

 

25  MAJOR SECTION NUMBER 2, THERE ARE FEATURES OF

 

 1  ARTERIOSCLEROSIS THAT ARE -- THAT ARE NAMES.  ONE IS

 

 2  CORONARY ARTERY ATHEROSCLEROSIS.  THOSE ARE THE VESSELS THAT

 

 3  NOURISH THE HEART MUSCLE ITSELF.  THERE IS THE AORTA, WHICH IS

 

 4  THE LARGEST ORGAN -- EXCUSE ME, VESSEL OF THE BODY WHICH

 

 5  BRINGS ARTERIAL BLOOD TO ALL THE ORGANS OF THE BODY.  AND

 

 6  THEN FINALLY, EVIDENCE OF THERE BEING SOME ADVANCED KIDNEY

 

 7  ARTERIOSCLEROSIS BECAUSE EVEN MILD TO MODERATE RENAL

 

 8  ARTERIOSCLEROSIS IS PRESENT ONLY WHEN YOU HAVE LONGSTANDING

 

 9  SIGNIFICANT ARTERIOSCLEROSIS.  MILD DOESN'T MEAN

 

10  INSIGNIFICANT IN THIS CASE.

 

11  Q.   WHAT WHAT OTHER AREAS ARE SIGNIFICANT TO THE CAUSE OF

 

12  DEATH?

 

13  A.   BRONCHOPNEUMONIA IS LISTED AS NUMBER 3.

 

14  BRONCHOPNEUMONIA OR AS IT'S DESCRIBED HERE AS ACUTE

 

15  INFLAMMATION IN THE LEFT LUNG.  I'M NOT SURE WHY THE

 

16  PATHOLOGIST SAID THE LEFT LUNG BECAUSE BRONCHOPNEUMONIA IS

 

17  PRESENT IN BOTH LUNG SLIDES THAT HE MADE AND -- AND IS THERE

 

18  IN DIFFUSE PATTERN.  AND IT'S ALSO VERY ACUTE.

 

19  Q.   WHAT IS --

 

20  A.   SO BRONCHOPNEUMONIA IS IMPORTANT HERE BECAUSE IT'S AN

 

21  ACUTE INFLAMMATION THAT QUITE FRANKLY CAUSES DEATH VERY

 

22  COMMONLY IN PEOPLE WHO ARE ELDERLY OR OTHERWISE IMPAIRED.

 

23  Q.   YOU MENTIONED THE TERM DIFFUSE PATTERN.  IS THAT THE

 

24  TERM YOU USED?  WHAT IS THE SIGNIFICANCE OF THAT?

 

25  A.   DIFFUSE MEANS THAT IT IS WIDESPREAD.  IT'S AN

 

 1  INFLAMMATION THAT IS NOT FOCUSSED IN ONE OR TWO LITTLE

 

 2  POCKETS, MICORSCOPIC POCKETS OF THE -- OF THE LUNG, BUT

 

 3  RATHER IT'S VERY PROMINENT.

 

 4  Q.   AND THIS WAS SOMETHING THAT YOU COULD ACTUALLY OBSERVE

 

 5  IN THE MICORSCOPIC SLIDE THAT WAS SENT TO YOU?  OR THE

 

 6  MULTIPLE SLIDES.

 

 7  A.   ABSOLUTELY.  IT WAS THE SAME SLIDE THIS PATHOLOGIST HAD

 

 8  BEEN LOOKING AT.

 

 9  Q.   ANY OTHER DIAGNOSES THAT RELATE TO CAUSE OF DEATH?

 

10  A.   INTERSTITIAL AND PERIBRONCHIAL FIBROSIS INDICATES THAT

 

11  THIS PERSON HAS SOME EMPHYSEMA.  AND EMPHYSEMA IS A CHRONIC

 

12  DEBILITATING DISEASE OF THE LUNG.  REMOTE PULMONARY

 

13  INFARCTION DUE TO THOMBO-EMBOLUS IS THE DESCRIPTION OF AN OLD

 

14  PHENOMENON, AND INDEED IN MRS. ANDERSON'S MEDICAL RECORDS,

 

15  SHE DID COMPLAIN OF CHEST PAIN ON A PREVIOUS OCCASION THAT

 

16  WAS VERY SPECIFIC AND THAT VERY LIKELY IS THE CAUSE OF THAT.

 

17  SHE HAD A BLOOD CLOST THAT TRAVELED TO HER LUNG, AND WHAT

 

18  HAPPENED THERE WAS THAT IT RESOLVED, IT HEALED, BUT IT -- IN

 

19  HEALING, IT DESTROYS ALL THE LUNG TISSUE AROUND IT, WHICH

 

20  MEANS THAT THAT PART OF THE LUNG IS NONFUNCTIONAL.  SO IT

 

21  REDUCED THE LUNG MASS IN GENERAL FROM NORMAL FUNCTION JUST AS

 

22  EMPHYSEMA REDUCES THE ENTIRE LUNG MASS FROM NORMAL FUNCTION.

 

23  PULMONARY EMPHYSEMA IS THE SAME THING.  IT'S JUST GIVEN A

 

24  DIFFERENT LISTING.  I DON'T KNOW WHY.  DEGENERATIVE BONE

 

25  DISEASE IS IMPORTANT IN THIS PERSON BECAUSE OBVIOUSLY SHE HAD

 

 1  ADVANCED SOFTENING OF THE BONE, DECALCIFICATION, RESULTING IN

 

 2  PRIOR FRACTURES AND OBVIOUSLY SURGICAL REPAIR OF THOSE

 

 3  FRACTURES IN A NUMBER OF PLACES.  I THINK IT WAS IN WRIST AND

 

 4  ANKLE AS WELL AS IN BOTH HIPS.  HISTORY OF DEMENTIA IS

 

 5  IMPORTANT BECAUSE DEMENTED PEOPLE -- AND YOU PROBABLY WILL

 

 6  HEAR OR HAVE HEARD ALREADY A LOT ABOUT THAT, SO I NEEDN'T

 

 7  TALK MUCH ABOUT DEMENTIA EXCEPT TO SAY THAT I RECOGNIZE, AS

 

 8  ALL PHYSICIANS DO, THAT DEMENTIA OR THE LOSS OF ONE'S MENTAL

 

 9  REASONING OR MENTAL -- NORMAL MENTAL FUNCTION CAUSES YOU TO

 

10  HAVE ABNORMAL BEHAVIOR, SOME OF WHICH IS RELATED TO THINGS

 

11  LIKE DOING WHAT'S GOOD FOR YOU.  BEING ABLE TO EAT OR

 

12  AGREEING TO EAT.  TAKING MEDICATION.  THAT SORT OF THING.  SO

 

13  DEMENTIA IS WHAT -- IS A WAY OF THE BRAIN DETERIORATING OVER

 

14  TIME -- IT CAN BE A LONG PERIOD OF TIME OR A SHORT PERIOD OF

 

15  TIME -- AFTER WHICH OR DURING WHICH PEOPLE EVEN FORGET HOW TO

 

16  EAT, AND THAT'S WHY IN SOME CASES THEY REFUSE TO EAT BECAUSE

 

17  THEY DO NOT KNOW WHAT EATING HAS ANY GOOD TO DO.  AND THAT'S

 

18  WHY MANY PEOPLE WHO ARE DEMENTED IN FACT, EVERYBODY WHO IS

 

19  DEMENTED BECOMES WASTED EVENTUALLY IN SPITE OF THE FACT THAT

 

20  PEOPLE TRY TO FEED THEM.  THEY BECOME WASTED SIMPLY BECAUSE

 

21  THEY DON'T EAT AND THEY DON'T SWALLOW.

 

22  Q.   AND THEN I GUESS THE LAST TWO RELATE TO SOME PREVIOUS

 

23  SURGERIES THAT SHE HAD HAD?

 

24  A.   YES.  REMOVAL OF HER GALL BLADDER, APPENDIX, AND HER

 

25  UTERUS.

 

 1  Q.   NOW, DESPITE THIS LONG LIST OF DIAGNOSES BY DR. GREY,

 

 2  ULTIMATELY WHEN IT COMES TO MANNER OF DEATH AND IMMEDIATE

 

 3  CAUSE OF DEATH, AS WE'VE TALKED ABOUT BEFORE, HE INDICATES

 

 4  UNDETERMINED.

 

 5  A.   YES.

 

 6  Q.   DO YOU AGREE WITH THAT OPINION?

 

 7  A.   NO.  I THINK THAT FOR WHATEVER REASON HE MADE IT

 

 8  UNDETERMINED, AND I SUGGESTED THAT HE SIMPLY MIGHT NOT HAVE

 

 9  WANTED TO DO SO.  AND I DON'T KNOW WHAT HIS REASON WAS.  I

 

10  DON'T BELIEVE THAT THE REASON IS FOR LACK OF EVIDENCE.  HE

 

11  HAS PLENTY OF EVIDENCE TO NAME A CAUSE OF DEATH HERE.

 

12  Q.   WELL, IF YOU WERE MAKING A FINDING AND ASSESSING MANNER

 

13  AND CAUSE OF DEATH IN THIS CASE, NUMBER ONE, WOULD YOU CHANGE

 

14  ANY OF THOSE DIAGNOSES AND THEN NUMBER TWO, WOULD YOU CHANGE

 

15  THE MANNER AND CAUSE OF DEATH?

 

16  A.   YES TO BOTH.  I WOULD CHANGE SLIGHTLY SOME OF THE

 

17  FINDINGS --

 

18  Q.   WELL, WHY DONT WE --

 

19  A.   -- AS IN THE LIST OF PATHOLOGIC DIAGNOSES ONLY BECAUSE I

 

20  SEE EITHER IN HIS DESCRIPTION OR IN HIS SLIDES, BOTH OF WHICH

 

21  ARE FROM HIM, SOME WAY TO ALTER AND IN MOST CASES TO ENHANCE

 

22  THE SEVERITY OF THE PARTICULAR PROCESS.  AND ON THE OTHER

 

23  HAND, I WOULD CHANGE THE CAUSE AND MANNER OF DEATH SIMPLY

 

24  BECAUSE I BELIEVE THERE'S PLENTY OF EVIDENCE TO SAY WHAT IT

 

25  WAS.

 

 1  Q.   WELL, LET'S GO -- YOU'VE PREPARED, JUST SO THE COURT

 

 2  CAN -- OR EXCUSE ME, THE JURY CAN SEE HOW YOU WOULD HAVE

 

 3  ALTERED THESE DIAGNOSES AND THESE CONCLUSIONS, A DOCUMENT

 

 4  THAT KIND OF SUMMARIZES YOUR -- WHAT YOUR FINDINGS WOULD BE.

 

 5  SHALL WE GO TO YOUR EXHIBIT?  IT'S DEFENDANT'S EXHIBITS 104.

 

 6  IS THIS THE DOCUMENT THAT YOU PREPARED AND SUBMITTED TO ME?

 

 7  A.   YES.

 

 8  Q.   AND THIS IS -- WHY DON'T YOU EXPLAIN TO THE JURY HOW

 

 9  THIS DIFFERS, HOW YOUR CONCLUSIONS DIFFER FROM THE

 

10  CONCLUSIONS OF THE PATHOLOGIST.

 

11  A.   I -- FIRST OF ALL, LET ME EXPLAIN TO THE JURY THAT I

 

12  STRUCTURE THIS LITTLE BIT DIFFERENTLY.  I'M INCLUDING BOTH

 

13  THE CAUSE OF DEATH AND MANNER OF DEATH IN MY LISTING OF

 

14  ABNORMAL FINDINGS.  I ALSO INCLUDE IN MY LISTING OF ABNORMAL

 

15  FINDINGS PRINCIPAL CLINICAL FINDINGS; THAT IS, THINGS THAT

 

16  ARE NOTICED DURING LIFE, AS WELL AS FINDINGS THAT ARE PRESENT

 

17  AFTER DEATH, EITHER BY THE MEDICAL EXAMINER IN SALT LAKE CITY

 

18  OR BY ME IN REVIEW OF THE MEDICAL EXAMINER'S INFORMATION AND

 

19  MATERIALS.

 

20  Q.   AND SO WHAT DOES -- WHAT DOES C.O.D. MEAN?

 

21  A.   C.O.D. HERE MEANS CAUSE OF DEATH, IF YOU'LL LIVE WITH

 

22  THAT ONE.  AND YOU'LL HAVE TO PUT UP WITH A LOT OF

 

23  ABBREVIATIONS HERE.  I'M SORRY FOR THAT.

 

24  Q.   AND WHAT DOES THIS MEAN HERE?

 

25  A.   SO NUMBER 1 UNDER CAUSE OF DEATH -- AND BY THE WAY, I

 

 1  GIVE -- I SET IT UP THE WAY IT IS SET UP ON A DEATH

 

 2  CERTIFICATE.  NUMBER 31 IN THE UTAH STATE DEATH CERTIFICATE

 

 3  IS THE SECTION --

 

 4       MR. MAJOR:  OBJECTION, YOUR HONOR.  I THINK THIS

 

 5  IRRELEVANT --

 

 6       THE WITNESS:  -- WHICH THE PHYSICIAN IS --

 

 7       THE COURT:  WAIT A MINUTE.  DO YOU HAVE AN OBJECTION?

 

 8       MS. BARLOW:  YES, YOUR HONOR.  I DON'T THINK HE'S AN

 

 9  EXPERT TO BE ABLE TO TALKING ABOUT UTAH LAW AND I THINK IT'S

 

10  IRRELEVANT AT THIS POINT DOING THAT.

 

11       THE COURT:  OVERRULED.  HE'S NOT TALKING ABOUT UTAH LAW,

 

12  BUT MERELY THE FORMS USED.

 

13       MS. BARLOW:  I -- HE HAD REFERRED TO A UTAH STATUTE.

 

14  THAT'S WHY I WAS --

 

15       THE COURT:  I THOUGHT HE REFERRED TO THE DEATH

 

16  CERTIFICATE.

 

17       MR. MAJOR:  AND THE STATUTE THAT WAS GOVERNING THE DEATH

 

18  CERTIFICATE.

 

19       THE COURT:  WELL, THE DEATH CERTIFICATE HE CAN REFER TO.

 

20  OVERRULED.

 

21  Q.  (BY MS. ISAACSON)  DR. CASSIN, YOU SAW THE ORIGINAL DEATH

 

22  CERTIFICATES IN THESE CASES.

 

23  A.   YES.

 

24  Q.   AND YOU KNOW WHAT THE FORM THAT WAS USED -- YOU KNOW THE

 

25  FORM THAT WAS USED IN THESE CASES?

 

 1  A.   YES.

 

 2  Q.   AND SO IF I UNDERSTAND YOUR TESTIMONY, YOU'VE TRIED TO

 

 3  SET THIS UP IN SOME WAY CONSISTENT WITH THAT FORMAT.

 

 4  A.   YES.

 

 5  Q.   OKAY.

 

 6  A.   AND IT'S STANDARD FORMAT.  IT'S USED THROUGHOUT THE

 

 7  COUNTRY.

 

 8  Q.   OKAY.  SO CAUSE OF DEATH AND NUMBER 1?

 

 9  A.   SO CAUSE OF DEATH IS ON THE UTAH STATE DEATH CERTIFICATE

 

10  AS WELL AS ALL OTHERS, DIVIDED INTO TWO SECTIONS.  FIRST OF

 

11  ALL -- AND WE CALL THOSE PART 1, FIRST OF ALL, IS THE

 

12  IMMEDIATE CAUSE OF DEATH AS WELL AS THE UNDERLYING RATIONALE FOR

 

13  CHOOSING THAT AS THE CAUSE OF DEATH.  AND THEN PART 2 ARE

 

14  THOSE CONDITIONS THAT MAY NOT BE IMMEDIATELY KILLING THE

 

15  PATIENT, BUT THEY ARE INFLUENTIAL, THEY ARE CONTRIBUTORY TO

 

16  THE CAUSE OF DEATH.  IN OTHER WORDS, THEY MAKE DYING MORE

 

17  READILY POSSIBLE AT THE TIME THAT IT ACTUAL HAPPENED.

 

18  Q.   AND SO WHAT'S YOUR -- WHAT DOES THAT A.C. -- A.S.C.V.D.?

 

19  A.   A.S.C.V.D. ARE -- ARE INITIALS FOR THE TERM

 

20  ARTERIOSCLEROTIC CARDIOVASCULAR DISEASE.  AND WHAT I'M

 

21  TALKING ABOUT THERE IS THE GENERAL PROCESS OF

 

22  ARTERIOSCLEROSIS, AND I INDICATE THAT THAT PROCESS HAS BEEN

 

23  PRESENT FOR YEARS.  AND I SAY THAT ONLY BECAUSE THERE ARE

 

24  ADVANCED DEGENERATIVE CHANGES, NOT SURPRISING IN A

 

25  91-YEAR-OLD PERSON.

 

 1  Q.   AND THEN WHAT DO THESE -- WHAT DOES C.A.D. AND C.H.F.

 

 2  MEAN?

 

 3  A.   C.A.D. MEANS THAT THERE HAD BEEN RECOGNIZED OVER A

 

 4  PERIOD OF A LONG TIME CORONARY ARTERY DISEASE.  THAT'S THE

 

 5  C.A.D.  FOR WHICH THIS LALDY HAD ACTUALLY BEEN TREATED WITH

 

 6  NITROGLYCERIN WHEN SHE HAD BECOME UNCOMFORTABLE.  SHE HAD HAD

 

 7  CHEST PAIN AND SHE WAS GIVEN NITROGLYCERIN PERIODICALLY OR

 

 8  GIVEN IT TO TAKE WHEN SHE WAS ABLE TO CONCENTRATE ON THAT SO

 

 9  THAT SHE COULD RELIEVE HER OWN CHEST PAIN.  AND IT WAS

 

10  ATTRIBUTED TO IT A NARROWING, A PROGRESSIVE NARROWING OF THE

 

11  CORONARY ARTERIES, AND THEREBY, A LESSER NOURISHMENT OF

 

12  THE -- OF THE HEART MUSCLE.  THAT'S WHAT TYPICALLY HAPPENS.

 

13  Q.   WHAT DO THESE NOTES OVER HERE MEAN?

 

14  A.   THE NOTES TO THE RIGHT OF THAT, AND SPECIFICALLY THE

 

15  NOTE TO THE RIGHT OF THE ONE WE'RE TALKING ABOUT, CORONARY

 

16  ARTERY DISEASE, IS THAT, IS THE FINDING BASED ON MICROSCOPY.

 

17  LOOKING AT THE SLIDES WHICH WERE PREPARED AT THIS LADY'S

 

18  AUTOPSY, THERE ARE A COUPLE OF SECTIONS OF CORONARY ARTERIES

 

19  WHICH SHOWED DIFFUSE CALCIFIC CORONARY ARTERIOSCLEROSIS.  AND

 

20  I CALL IT MODERATE ONLY BECAUSE THE GUNKY PART, THE SOFT

 

21  TISSUE PART OF THE ATHEROSCLEROSIS HAS ESSENTIALLY MELTED

 

22  AWAY.  WHAT'S LEFT IS THIS RIGID PIPE.  AND A LITTLE BIT OF

 

23  THE GUNK THAT'S INSIDE OF THAT.  PERHAPS FOR THAT REASON, THE

 

24  PATHOLOGIST INTERPRETED THIS AS BEING OF LESSER SIGNIFICANCE,

 

25  BUT IN FACT, AFTER FOUR AND A HALF YEARS IN THE GROUND, THIS

 

 1  IS INDICATIVE OF NOT ONLY DIFFUSE, BUT AT LEAST MODERATE,

 

 2  WHICH MEANS VERY CLINICALLY SIGNIFICANT ARTERIOSCLEROSIS.

 

 3  Q.   EXPLAIN TO ME SO THAT -- IT WAS ACTUALLY A SLICE?  WHAT

 

 4  IS IT THAT YOU'RE LOOKING AT ON THE SLIDE?

 

 5  A.   I'M LOOKING AT THE CORONARY ARTERY THAT IS CROSSCUT.  SO

 

 6  THINK OF IT AS A PIPE.  IN THIS CASE, IT'S -- THAT'S THE BEST

 

 7  COMPARISON.  A PIPE THAT HAS BEEN CUT ACROSS ON A 90-DEGREE

 

 8  ANGLE, AND SET UP IN A PARAFFIN BLOCK, A SECTION MADE OF IT

 

 9  AND SECTIONED, AND I'M LOOKING AT IT.  I'M ALSO LOOKING IN

 

10  SECTIONS OF HEARTS THAT SMALL VESSELS AS THEY COURSE THROUGH

 

11  THESE SCALE -- THE HEART MUSCLE, WHICH IS IN THE NEXT

 

12  SECTION.

 

13  Q.   AND SO YOUR ASSESSMENT BASED UPON YOUR REVIEW OF THE

 

14  SLIDES WAS THAT THE PREVIOUS PATHOLOGIST HAD UNDERREPRESENTED

 

15  THE SEVERITY OF HIS OBSERVATIONS?

 

16  A.   YES.

 

17  Q.   AND THEN HERE THE NEXT SECTION, C.O.P.D., WHAT DOES THAT

 

18  MEAN?

 

19  A.   WELL, THE NEXT SECTION REALLY IS C.H.F.  OR DO  YOU WANT

 

20  ME TO SKIP TO --

 

21  Q.   OH, THAT WAS ALL IN THAT FIRST SECTION, HUH?

 

22  A.   C.H.F. MEANS THAT DURING LIFE -- THIS IS NOT A DIAGNOSIS

 

23  YOU CAN MAKE AFTER DEATH.  DURING LIFE, THIS PERSON HAD

 

24  CONGESTIVE HEART FAILURE, AND FOR THAT REASON WAS TREATED

 

25  WITH A DIURETIC, WHICH IS A TYPICAL WAY TO DO SO.  THAT'S

 

 1  FUROSEMIDE.  IN THAT REGARD AND MICROSCOPICALLY WHAT IS FOUND

 

 2  IS THAT THERE IS FIBROSIS OR SCARRING ALL AROUND -- IN THE

 

 3  HEART MUSCLE ALL AROUND THE SMALL VESSELS THAT ARE NOURISHING

 

 4  THE HEART MUSCLE.  THERE ARE EVEN SMALL SCARS.  SO IN

 

 5  ADDITION TO THE FIBROSIS IN THE IMMEDIATE VICINITY OF THE

 

 6  SMALL VESSELS, THERE ARE SCARS THAT HAVE OCCURRED.  THESE ARE

 

 7  SMALL HEART ATTACKS THAT HAVE OCCURRED THAT HAVE WEAKENED

 

 8  PROGRESSIVELY THE HEART MUSCLE OVER A PERIOD OF YEARS.  AND

 

 9  THIS IS IN THE -- IN THE LEFT VENTRICLE, THAT'S THE L.V.

 

10  THERE'S A RESOLVING MICRO-INFARCT IN THE SEPTUM.  IN OTHER

 

11  WORDS, IN THE -- IN THE WALL BETWEEN THE RIGHT AND LEFT MAIN

 

12  PUMPING CHAMBERS, I FIND A MYOCARDIAL INFARCTION, A HEART

 

13  ATTACK.  NECROSIS, DEATH OF THE THE -- AND THIS IS

 

14  MICROSCOICALLY.  DEATH OF THE HEART MUSCLE THAT HAS BEEN

 

15  RESOLVED.  AND IT'S TRYING TO HEAL ITSELF.  SO THIS IS

 

16  SEVERAL WEEKS OLD, MAYBE A COUPLE OF WEEKS OLD AT THIS TIME.

 

17  AND I ALSO FIND AND THE PATHOLOGIST ALSO AS WELL FOUND THAT

 

18  THERE IS NEPHROSCLEROSIS.  SO THE PROCESS OF ARTERIOSCLEROSIS

 

19  HAS PROGRESSED ALSO TO THE KIDNEYS, WHICH IN FACT CONTRIBUTES

 

20  AS WELL NOT ONLY TO KIDNEY FAILURE, BUT TO CONGESTIVE HEART

 

21  FAILURE.

 

22  Q.   SO THE FIRST SECTION IF I UNDERSTAND IS THE

 

23  ARTERIOSCLEROSIS PART WHICH IS SEPARATE FROM THIS HEART ISSUE

 

24  AND -- BUT THESE WERE BOTH OBSERVED MICROSCOPICALLY, SLIDES

 

25  THAT YOU HAVE -- THAT YOU SAW THAT THE OTHER PATHOLOGIST ALSO

 

 1  SAW.

 

 2  A.   SURE.

 

 3  Q.   OKAY.  AND SO THEN THE NEXT SECTION C.O.P.D.

 

 4  A.   C.O.P.D. IS JUST A CHRONIC OBSTRUCTIVE PULMONARY DISEASE

 

 5  WHICH IS THE JARGON TERM THAT PHYSICIANS USE FOR PULMONARY

 

 6  EMPHYSEMA.  AND I PUT IT HERE BECAUSE IT IS LIKEWISE IN THE

 

 7  SECTION OF PRIMARY CAUSE OF DEATH.  IT CONTRIBUTED DIRECTLY.

 

 8  THE LUNGS ARE NOT ABLE TO OXYGENATE BLOOD THAT COMES TO THEM

 

 9  WHEN IT'S PUMPED BY A WEAK HEART.  SO YOU NOT ONLY HAVE A

 

10  WEAK PUMP, YOU ALSO HAVE LUNGS THAT DON'T WORK WELL, THEY

 

11  DON'T WORK PROPERLY, BECAUSE THEY ARE DIFFUSELY INVOLVED BY

 

12  THIS SCARRING AND REDUCTION IN AVAILABLE SPACE FOR GAS

 

13  EXCHANGE IN THE LUNGS.

 

14  Q.   SO THE PRIMARY CAUSE -- IS THE TERM PRIMARY CAUSE OF

 

15  DEATH THE RIGHT TERM FOR THIS SECTION?

 

16  A.   YES, YES.

 

17  Q.   AND THERE ARE BASICALLY THREE SUBPARTS TO THE

 

18  CARDIOVASCULAR DISEASE PART, IS THAT --

 

19  A.   YES.

 

20  Q.   -- DO I HAVE THAT RIGHT?

 

21  A.   WELL, THERE ARE TWO SUBPARTS.  WHAT I'M OFFERING IS THAT

 

22  THERE ARE REALLY TWO THAT ARE WORKING TOGETHER.  ONE IS THAT

 

23  THERE IS A WEAK HEART WITH BAD CORONARY ARTERY DISEASE AND A

 

24  HEART WEAKENED BY MULTIPLE INFARCTS IN THE PAST, AS WELL AS

 

25  CHRONIC CONGESTIVE HEART FAILURE.  THERE IS ALSO ON THE OTHER

 

 1  SIDE OF THAT, ONE OF THE REASONS THAT THE HEART PUMPS IS TO

 

 2  CIRCULATE BLOOD ALSO THROUGH THE LUNG.  AND THE FACT IS THAT

 

 3  THROUGH THE LUNGS WHERE THE RED CELLS PICK UP ADEQUATE

 

 4  OXYGEN, THERE IS LIKEWISE DISEASE WHICH REDUCES THE VOLUME

 

 5  AVAILABLE FOR EXCHANGE.  NOW, IN THAT REGARD OF PULMONARY

 

 6  EMPHYSEMA, IT IS NOT UNCOMMON, AND IN THIS CASE WAS PRESENT,

 

 7  AN ACUTE BRONCHOPHEUMONIA.  THIS WAS PRESENT AS I INDICATE IN

 

 8  BOTH LUNG SLIDES, SO IT WAS PRESENT IN BOTH LUNGS, AND THERE

 

 9  WERE FIVE SECTIONS MADE OF THE LUNGS.  AND THAT IS TO SAY,

 

10  FIVE SLICES.  AND IT WAS PRESENT IN THREE OF THE FIVE SLICES

 

11  AND ON BOTH SLIDES.  AND SO IT'S HARD FOR ME TO BELIEVE,

 

12  THOUGH IT MAY THEORETICALLY BE TRUE BECAUSE I DON'T KNOW THE

 

13  EXACT PLACE HE GOT THOSE SECTIONS, THAT SHE HAD ACUTE

 

14  BRONCHOPNEUMONIA IN ONLY ONE LUNG, BUT EVEN IF SHE DID, EVEN

 

15  THOUGH I THINK IT WAS PROBABLY BOTH LUNGS, EVEN THOUGH SHE

 

16  DID, IT WAS BAD DISEASE.  AND IT WAS ACUTE.  THAT IN ITSELF

 

17  CAN BE A CAUSE OF DEATH.  THIS BRONCHOPNEUMONIA WAS

 

18  PRESENT -- AS I UNDERSTAND, MRS. ANDERSON WAS IN THE HOSPITAL

 

19  FOR ONE DAY.  SHE COULD HAVE COME INTO THE HOSPITAL WITH THIS

 

20  BRONCHOPNEUMONIA.  IT WAS ACUTE, BUT IT WASN'T PRESENT FOR AN

 

21  HOUR OR TWO.  IT WAS PRESENT FOR A DAY, ANYWAY.  SO I

 

22  INDICATE THAT IT HAS ORIGINATED EITHER BEFORE OR AT LEAST AT

 

23  THE TIME OF ADMISSION, ONE DAY.  AND IT IS APPROXIMATELY ONE

 

24  DAY IN APPEARANCE.

 

25  Q.   AND TALKING ABOUT THE SECONDARY CAUSES OF DEATH, YOU'VE

 

 1  IDENTIFIED – I THINK WE'RE ALL AWARE THAT SHE HAD DEMENTIA AND

 

 2  OSTEOPOROSIS AND COMPRESSION FRACTURES.  THE JURY HAS HEARD

 

 3  QUITE A BIT ABOUT THAT.

 

 4  A.   OKAY.

 

 5  Q.   HOW DO THOSE FACTOR INTO THE -- THE CAUSE OF DEATH?

 

 6  A.   DEMENTIA, AS YOU KNOW A LOT ABOUT I'M SURE, HAS CAUSED

 

 7  HER BY VARIOUS PROCESSES TO BECOME WASTED.  AND THAT'S THE

 

 8  TERM I USED THERE, INANITION.  I'M SORRY FOR THE JARGON, BUT

 

 9  IN GENERAL, IT CAN BE INTERPRETED AS SHE'S BECOMING WASTED.

 

10  HER BODY HAS LOST ITS RESERVES.  HER MUSCLE MASS HAS REDUCED.

 

11  SHE'S LOST MOST OF THE FAT IN HER BODY.  SHE'S DOWN TO PRETTY

 

12  LOW WEIGHT.  SHE'S 72 AND A HALF POUNDS.  AND FIVE FEET TWO

 

13  INCHES.  THIS IS A FRAIL LADY.  VERY FRAIL.  WHICH IS WHY

 

14  REVERSALS IN FORTUNE CAN HAPPEN VERY QUICKLY IN PEOPLE WHO

 

15  ARE THIS FRAIL.  SHE HAS -- SHE HAS SO -- AN ACCELERATED

 

16  WEIGHT LOSS PROBABLY BECAUSE SHE'S NOT ABLE TO TAKE OR WILL NOT

 

17  TAKE ANY NUTRITION.  AT LEAST IS NOT EFFECTIVE.  AND SHE HAS

 

18  OF COURSE SURGICAL REPAIR, WHICH IS INEFFECTIVE REPAIR IN AT

 

19  LEAST ONE PLACE WHERE THE PIN HAS NOT EVEN BEEN ABLE TO SCAR

 

20  IN EFFICIENTLY OR BE CEMENTED IN EFFICIENTLY TO HOLD THE BONE,

 

21  AND SO THAT IS A CONTINUING PROBLEM FOR HER, I'M SURE AS

 

22  WELL.

 

23  Q.   DR. CASSIN, BEFORE I ASK YOU ABOUT YOUR OPINION ON

 

24  MANNER OF DEATH, ARE THERE ANY OTHER OF THE FINDINGS BELOW

 

25  THERE THAT WE NEED TO GO INTO?  THAT YOU THINK ARE

 

 1  SIGNIFICANT OF FACTOR INTO THE MANNER OF DEATH THAT WE

 

 2  HAVEN'T ALREADY COVERED?

 

 3  A.   IN THE MICROSECTION I MADE A NOTE THERE THAT THE THYROID

 

 4  IS GOITROUS, WHICH MEANS THAT THERE'S A LOT OF FIBROSIS.

 

 5  THERE'S NODULARITY.  IT MEANS IT DOESN'T FUNCTION PROPERLY.

 

 6  AND PEOPLE WHO HAVE POOR THYROID FUNCTION ALSO HAVE POOR

 

 7  METABOLIC CONTROL.  THESE PEOPLE DO NOT HAVE THE ENDOCRINE

 

 8  HORMONAL STIMULUS TO PROPER NUTRITION AND PROPER STABLIZATION

 

 9  OF CELL LIFE IN THE BODY.  I POINT THAT OUT ONLY BECAUSE IT

 

10  IS IN FACT A SIGNIFICANT FINDING.  ALSO THE ADVANCED ATROPHY

 

11  IN THE BRAIN IS CERTAINLY CONSISTENT WITH HER CLINICAL

 

12  DIAGNOSIS OF DEMENTIA.  AND I FIND IN THE LIVER CELLS, GOOD

 

13  EVIDENCE, GOOD OBJECTIVE EVIDENCE OF ABSOLUTELY POOR

 

14  NUTRITION.  IT SHOWS -- BASICALLY, IT'S THE LIVER OF A PERSON

 

15  WHO IS IN STARVATION.

 

16  Q.   DR. CASSIN, DO YOU HAVE AN OPINION TO A DEGREE OF

 

17  REASONABLE MEDICAL CERTAINTY THAT WHAT YOU'VE IDENTIFIED HERE

 

18  AS PRIMARY CAUSE OF DEATH WAS IN FACT THE CAUSE OF DEATH FOR

 

19  ELLEN ANDERSON?

 

20  A.   YES.

 

21  Q.   AND WHAT IS THAT OPINION?

 

22  A.   MY OPINION IS THAT ELLEN ANDERSON DIED AS A -- FROM A

 

23  COMBINATION OF ARTERIOSCLEROSIS, WITH ITS MAIN EFFECT ON THE

 

24  HEART, POOR HEART FUNCTION, AND IT WAS SUPPORTED BY, IF YOU

 

25  WILL, ENHANCED BY HER EMPHYSEMA, WHICH TERMINALLY IN THE LAST

 

 1  DAY WAS POISONED REALLY BY BRONCHOPNEUMONIA SO THAT SHE BECAME

 

 2  SEPTIC.  SHE BECAME DIFFUSELY INFECTED.  AND AS I SAID

 

 3  BEFORE, WOULD HAVE DIED ALONE BY THAT.

 

 4  Q.   AND DO YOU HAVE AN OPINION TO A DEGREE OF REASONABLE

 

 5  MEDICAL CERTAINTY AS TO THE MANNENR OF DEATH FOR ELLEN

 

 6  ANDDERSON?

 

 7  A.   YES, I DO.  THE MANNER OF DEATH IS NATURAL, AND I SAY

 

 8  THAT BECAUSE SHE IS A VICTIM OF HER DISEASE, HER CHRONIC

 

 9  DISEASES WITH THE OVERLAY OF THIS ACUTE BRONCOPNEUMONIA.

 

10  Q.   LET'S GO TO DR. WEITZEL'S ORIGINAL DEATH CERTIFICATE.

 

11  THIS IS STATE'S EXHIBIT 3-D.  NOW, WE TALKED A LITTLE BIT

 

12  ABOUT THE CERTIFICATE OF DEATH AND DR. WEITZEL ACTUALLY

 

13  IDENTIFIED THREE DIFFERENT -- OR IDENTIFIED THREE DIFFERENT

 

14  THINGS HERE.  HOW DID HE DO IN ASSESSING WHAT THE CAUSE OF

 

15  DEATH WAS FOR ALLEN ANDERSON?

 

16  A.   WHEN I FIRST LOOKED AT THIS DEATH CERTIFICATE, I

 

17  BASICALLY TRIED TO UNDERSTAND WHAT WAS IN DR. WEITZEL'S MIND

 

18  OR ANY CLINICIAN WHO WRITES A DEATH CERTIFICATE HAS TO

 

19  REFLECT BASICALLY ON WHAT THEIR DATA BASE IS.  THEY DON'T

 

20  HAVE AN AUTOPSY, THEY DON'T HAVE MAYBE OTHER INFORMATION, BUT

 

21  THEY DO HAVE CLINICAL INFORMATION, THEY HAVE OBSERVATION, AND

 

22  THEY SEE THE COURSE OF A PATIENT THROUGH A PERIOD OF TIME,

 

23  HOWEVER LONG OR SHORT THAT MIGHT BE, UNDER THEIR CARE.  AND

 

24  IN THIS CASE, HE INDICATED BY CARDIAC ARREST THAT HER HEART

 

25  STOPPED.  AND BY MYOCARDIAL INFARCTION THAT SHE PROBABLY

 

 1  HAD -- PROBABLY HAD, AND THIS IS THE ONLY -- THE STANDARD IS,

 

 2  WHAT IS MORE LIKELY THAN NOT.  SHE PROBABLY HAD A MYOCARDIAL

 

 3  INFARCTION.  WHY WOULD HE SAY THAT?  PROBABLY BECAUSE HE

 

 4  NOTED CLINICALLY THAT SHE HAD A SUDDEN LAPSE, A SEVERE

 

 5  DETERIORATION OF HER HEART FUNCTION.  I GO ALONG WITH THAT

 

 6  BASED ON WHAT I FOUND.  THERE'S EVERY REASON TO BELIEVE THAT

 

 7  SHE WOULD HAVE HAD SEVERE DETERIORATION, AND I AGREE WITH

 

 8  THAT.  EVEN THOUGH THERE MIGHT NOT HAVE BEEN A MYOCARDIAL

 

 9  INFARCTION AT THAT TIME MTHOUGH, WHO OF US KNOWS.  A SAMPLE,

 

10  A RANDOM SAMPLE OF THE HEART SHOWS ME, IN FACT, A RECENT ONE.

 

11  ANOTHER RANDOM SAMPLE MAY HAVE FOUND AN ACUTE ONE.  IT'S UP

 

12  TO CHANCE IN AN AUTOPSY.  AND THEN A SINUS ARRHYTHMIA IS

 

13  CERTAINLY TRUE BECAUSE I SUSPECT THAT FOR WHATEVER REASON,

 

14  INFECTION, ARTERIOSCLEROSIS, OR CONGESTIVE HEART FAILURE

 

15  WITH PULMONARY EMPHYSEMA, EVERYBODY DIES OF A SINUS

 

16  ARRHYTHMIA.  YOUR HEART GOES INTO AN -- AN UNWORKABLE RHYTHM

 

17  JUST AS A TERMINAL EVENT.  NOW, SHE COULD HAVE HAD A SINUS

 

18  ARRHYTHMIA BEFORE THAT.  AND I BELIEVE SHE DID CLINICALLY,

 

19  AND THE REASON FOR THAT MAY HAVE BEEN THAT SHE WAS ACUTELY

 

20  INFECTED.  OR THAT SHE WAS ATTEMPTING TO RECOVER FROM A HEART

 

21  ATTACK, WHICH IS AT LEAST WHAT I CAN SAY BECAUSE OF WAY I

 

22  FOUND IN HER HEART.

 

23  Q.   AND ATTENDING PHYSICIANS, UNLESS THEY ACTUALLY PERFORM

 

24  AN AUTOPSY, WHICH I ASSUME DOESN'T HAPPEN, CAN'T KNOW

 

25  PRECISELY WHAT THE CAUSE OF DEATH IS WHEN THEY'RE FILLING OUT

 

 1  A DEATH CERTIFICATE.

 

 2  A.   WHO OF US KNOWS ABSOLUTELY EVERYTHING.  WHO OF US

 

 3  KNOWS -- WELL, HOW CAN I SAY THAT ANY BETTER?  WHAT WE ARE

 

 4  ASKED, AND THE STANDARD ON THE DEATH CERTIFICATION PROCESS IS

 

 5  TO GIVE THE MOST LIKELY EXPLANATION FOR DEATH.  I THINK BASED

 

 6  ON A CLINICAL EXAMINATION OF THIS WOMAN AND OBSERVATION, THIS

 

 7  IS ON TRACK.

 

 8  Q.   LET'S TALK ABOUT JUDITY LARSEN.  LET'S GO TO HER AUTOPSY

 

 9  REPORT.  THIS IS STATE'S EX -- OR STATE'S EXHIBITS 3-C.  AND

 

10  AGAIN, WE'RE GOING TO THE DIAGNOSES ON THE FRONT PAGE OF THE

 

11  PATHOLOGIST'S REPORT.  ON THIS SECTION OF DIAGNOSES, CAN YOU

 

12  WALK US THROUGH -- SWITCH TO THE BLOWUP OF THAT SO WE CAN SEE

 

13  A LITTLE BIT BETTER.  FIRST OF ALL, THERE'S THE TERM DRUG

 

14  INTOXICATION.  WHAT IS MEANT BY THAT?

 

15  A.   DRUG INTOXICATION LITERALLY MEANS THAT SHE HAS -- HAS

 

16  EXPERIENCED A TOXIC EFFECT OF A -- OF A DRUG.  A DRUG MAY BE

 

17  A MEDICATION OR AN ILLICIT DRUG, BUT IT'S FROM SOME

 

18  PHARMACEUTICAL PRODUCT.

 

19  Q.   SO THE PATHOLOGIST IDENTIFIES THIS AS NUMBER ONE AND

 

20  INDICATES IN LEVELS THAT WE'VE HEARD SOMETHING ABOUT, AND

 

21  THEN GOES ON TO TALK ABOUT OTHER CONDITIONS THAT HE OBSERVED

 

22  DURING HIS AUTOPSY.  WHICH OF THESE -- WOULD IT BE HELPFUL,

 

23  WOULD YOU LIKE TO GO TO YOUR ANALYSIS OR WOULD YOU LIKE TO

 

24  EXPLAIN SOME OF THESE?

 

25  A.   WELL, WE NEED TO BE EFFICIENT TODAY, AND I THINK THAT IT

 

 1  MAY NOT BE NECESSARY TO BE AS THOROUGH AS WE HAVE BEEN

 

 2  BEFORE.  MY OWN -- LET ME JUST SIMPLY SAY MY OWN PRESENTATION

 

 3  OF FINAL PATHOLOGIST DIAGNOSES DOES NOT NEGATE ANY OF THIS

 

 4  PATHOLOGIST'S FINDINGS.  I USE THEM, IN FACT.  IT'S THE

 

 5  AUTOPSY THAT HE’D DONE -- DID AND THE FINDINGS THAT HE

 

 6  REPORTS, AS I SAID IN GENERAL.  THE ONLY DIFFERENCE I HAVE

 

 7  WITH THOSE IS MY UNDERSTANDING AND INTERPRETATION OF THESE

 

 8  FINDINGS AS IN A NUMBER OF CASES BEING MORE SEVERE THAN THEY

 

 9  WERE INTERPRETED AS, FOR WHATEVER REASON.

 

10  Q.   WHY DON'T WE GO TO YOUR -- EXCUSE ME, YOUR FINDINGS.

 

11  AND THIS IS MARKED DEFENDANT'S EXHIBIT 105.  AND AGAIN, THIS

 

12  IS A -- THE DOCUMENT THAT YOU PREPARED, AND AGAIN, YOU HAVE

 

13  MADE BASED UPON YOUR REVIEW OF THE SLIDES, THE PHOTOGRAPHS,

 

14  HIS REPORTS, HIS FILES, THE MEDICAL RECORDS, WHAT YOU BELIEVE

 

15  THE CAUSE OF DEATH IS FOR JUDITH LARSEN.  AND I GUESS WE'RE

 

16  BACK TO THE SAME -- SAME ACRONYM BEFORE.  TALK ABOUT WHAT YOU

 

17  SAW WITH REGARD TO JUDITH LARSEN ON THIS TYPE OF DISEASE.

 

18  A.   WHAT I SEE IN JUDITH LARSEN IS ADVANCED

 

19  ARTERIORSCLEROSIS.  AND IN FACT, I'VE INDICATED THAT IT IS

 

20  HER CAUSE OF DEATH.  NOW, WHY IS IT HER CAUSE OF DEATH?  IT

 

21  IS HER CAUSE OF DEATH BECAUSE, FIRST OF ALL, SHE'S HAD IT FOR

 

22  MANY YEARS AND IT IS ADVANCED.  THIS IS NOT EARLY

 

23  ATHEROSCLEROSIS.  THIS IS LATE ATHERSCLEROSIS.  NOT ONLY

 

24  BECAUSE SHE'S 93 YEARS OLD, BUT IN FACT IT IS OBJECTIVELY.

 

25  IF THIS WERE IN A 63-YEAR-OLD, IT WOULD BE ADVANCED

 

 1  ARTERIORSCLEROSIS.  SHE HAS HAD A STROKE --

 

 2  Q.   I THINK --

 

 3  A.   -- BY HISTORY.

 

 4  Q.   -- SHE ACTUALLY PASSED AWAY ON -- IN JANUARY OF '96.

 

 5  A.   OH, I'M SORRY.

 

 6  Q.   DO YOU THINK THAT -- WHAT YEAR DO YOU THINK THAT WOULD

 

 7  HAVE BEEN?

 

 8  A.   PROBABLY THE PREVIOUS YEAR.

 

 9  Q.   OKAY.  SO THAT'S YOUR -- YOUR TYPO?

 

10  A.   SORRY ABOUT THAT.  THAT'S MY MISTAKE.

 

11  Q.   SO SHE HAS A HISTORY OF STROKE.  AUGUST OF 1995.

 

12  A.   SO SHE HAS A RECENT STROKE.  SHE HAS MULTI INFARCT

 

13  DEMENTIA.  THIS IS DEMENTIA OR LOSS OF ONE'S MENTAL FACULTIES

 

14  BASED ON A CERTAIN PROCESS.  IT'S A WAY OF SAYING WHAT THE

 

15  CAUSE IS, AS OPPOSED TO THE MORE MYSTERIOUS PATTERNS, BOTH

 

16  CLINICAL AND PATHOLOGICAL, OF DEMENTIA THAT YOU MAY HAVE

 

17  HEARD ABOUT, LIKE ALZHEIMER'S AND PICK'S AND ALL THOSE - LEWY

 

18  BODY DISEASE.  THIS IS A FORM OF DEMENTIA THAT IS BASED ON

 

19  ARTERIOSCLEROSIS.  ARTERIOSCLEROSIS HAS PRODUCED INFARCTS

 

20  WHICH ARE SMALL DEATH - AREAS OF DEATH OF BRAIN TISSUE.  AND

 

21  FOR THE REASON THAT THERE IS ARTERIAL INSUFFICIENCY.  THE

 

22  ARTERIES THEMSELVES HAVE FAILED TO ADEQUATELY NOURISH THE

 

23  BRAIN TISSUE.  AND FOR THAT REASON, EVEN THOUGH THEY ARE NOT

 

24  VISIBLE GROSSLY, YOU CAN'T JUST LOOK AT THE BRAIN AND SAY

 

25  ANYTHING BUT THIS IS AN ATROPHIC BRAIN BECAUSE THEY ARE SO

 

 1  SMALL.  IN FACT, MULTI INFARCT DEMENTIA IS SEVERE

 

 2  ARTERIOSCLEROSIS WITH THE CLINICAL PICTURE OF A WORSENING

 

 3  DEMENTIA.

 

 4  Q.   AND SO ARE --

 

 5  A.   IN THAT REGARD -- EXCUSE ME.  IN THAT REGARD, C.T.

 

 6  SCANS, WHICH IS A WAY OF MAKING THAT DIAGNOSIS, CONFIRMED

 

 7  THAT.  AND SO I USE THIS TERM BECAUSE NOT ONLY WAS IT SAID

 

 8  CLINICALLY, BUT THE BASIS, THE CLINICAL BASIS FOR THAT

 

 9  DIAGNOSIS IS ESTABLISHED RADIOGRAPHICALLY BY A COMPUTERIZED

 

10  TOMOGRAPHY.

 

11  Q.   AND SO WHAT CAN YOU SEE WITH A C.T. SCAN?  YOU CAN SEE

 

12  AREAS WHERE THESE --

 

13       MR. MAJOR:  YOUR HONOR, MIGHT WE INQUIRE JUST AS A VOIR

 

14  DIRE WHETHER HE ACTUALLY REVIEWED THE M.R.I. OR WHETHER HE'S

 

15  JUST REVIEWING --

 

16       THE COURT:  YOU CAN ASK QUESTIONS IF YOU WANT.

 

17  BY MR. MAJOR:

 

18  Q.   OKAY, DOCTOR, JUST QUICK QUESTION.  WHEN YOU'RE TALKING

 

19  ABOUT THIS C.T. SCAN, AS PART OF YOUR PREPARATION FOR THIS

 

20  CASE, DID YOU ACTUALLY REVIEW THE M.R.I.?

 

21  A.   NO, SIR, I DIDN'T.

 

22  Q.   YOU JUST SIMPLY REVIEWED THE STATEMENTS OF THE --

 

23  WRITTEN FROM THE DOCTOR THAT WERE IN THE RECORDS.

 

24  A.   THAT'S CORRECT.

 

25       MR. MAJOR:  THANK YOU.

 

 1  BY MS. ISAACSON:

 

 2  Q.   DR. CASSIN, WOULD IT BE TYPICAL FOR A MEDICAL EXAMINER

 

 3  TO ACTUALLY REVIEW SUCH A C.T. SCAN ITSELF?

 

 4  A.   WELL, IT MAY BE, BUT I -- I DOUBT THAT MOST PATHOLOGISTS

 

 5  WOULD EITHER BOTHER TO DO THAT OR DO IT ONLY FOR LACK OF

 

 6  TRAINING SPECIFICALLY IN THAT.  DEPENDS ON THEIR OWN

 

 7  READINESS TO DO SO.  IT'S A SPECIALTY IN ITSELF.  THE C.T.

 

 8  SCANS ARE ALL REPORTED, THOUGH, BY SPECIALISTS IN THAT AREA.

 

 9  AND YOU REVIEWED THE REPORT OF THE C.T. SCAN IN THIS CASE.

 

10  A.   YES.

 

11  Q.   INCLUDED IN THE MEDICAL RECORDS.  WITH REGARD -- KEEP

 

12  GOING ON THE -- SO THESE ARE SUBPARTS OF THE PRIMARY CAUSE OF

 

13  DEATH, AND YOUR EXPLANATION OF THE DETAILS OF THAT, WHAT IS

 

14  ISCHEMIC -- ISCHEMIC HEART DISEASE?

 

15  A.   ISCHEMIC HEART DISEASE IS A TERM GIVEN TO CLINICALLY --

 

16  A CLINICAL TERM GIVEN TO A HEART, A HEART FUNCTION THAT

 

17  APPEARS TO BE LESSENING OVER TIME IN EFFICIENCY.  IT MAY

 

18  INVOLVE HEART FAILURE, IT MAY INVOLVE ARRHYTHYMIA, THAT IS

 

19  NOT LETHAL ARRHYTHMIA, BUT NEVERTHELESS ARRHYTHMIA, ABNORMAL

 

20  HEART RHYTHM THAT IS BASED ALSO ON A CLINICAL FINDING OF

 

21  ARTERIOSCLEROSIS.  ISCHEMIC HEART DISEASE MEANS THAT THERE IS

 

22  GRADUAL DYING OF HEART MUSCLE.  OR IN -- BASED ON INEFFECTIVE

 

23  PERFUSION THROUGH THOSE SMALL BLOOD VESSELS BECAUSE OF

 

24  ARTERIOSCLEROSIS.  ONE OF THE FINDINGS LIKEWISE THAT

 

25  SUBSTANTIATES THIS IS ANGINA, OR CHEST PAIN.  THAT THIS WAS

 

 1  REPORTED IN THIS LADY AND FOR WHICH SHE WAS TREATED WITH A

 

 2  NITROGLYCERINE LIKE COMPOUND, ISORDIL, WHICH HAS A LONGER

 

 3  LASTING EFFECT THAN NITROGLYCERINE.  ALSO, SHE HAS ON

 

 4  MICROSCOPY A VERY DENSE CALCIFIC CORONARY ARTERIOSCLEROSIS.

 

 5  THESE ARE COLLARS OF CALCIFICATION.  THERE IS NO HOLE THROUGH

 

 6  WHICH GASSES CAN GO.  THIS IS SEVERE CORONARY

 

 7  ARTERIOSCLEROSIS.  AND I INTERPRETED THIS FROM THE SLIDES

 

 8  THAT THE PATHOLOGIST PROVIDED MADE -- MADE AT AUTOPSY.  ALSO

 

 9  THERE IS, AS YOU CAN SEE HERE, CLINICAL -- CLINICAL EVIDENCE

 

10  OF A SEIZURE IN DECEMBER FOR WHICH THIS LADY WAS GIVEN

 

11  DILANTIN I BELIEVE INTRAVENOUSLY.

 

12  Q.   SO DO I UNDERSTAND THAT THE BIG PICTURE HERE IS THAT HER

 

13  ARTERIES ARE DISEASED?

 

14  A.   YES.

 

15  Q.   AND IT AFFECTS BOTH THE BRAIN AND THE HEART --

 

16  A.   YES.

 

17  Q.   -- IN THIS PATIENT?

 

18  A.   YES, IT DOES.  SIGNIFICANTLY SO.

 

19  Q.   AND THERE'S --

 

20  A.   WITH DYSFUNCTION.  DYSFUNCTION OF THE BRAIN UP TO AND

 

21  INCLUDING SEIZURE.  I MEAN THIS IS MASSIVE DYSFUNCTION.

 

22  Q.   AND HOW DOES THIS CAUSE DEATH?

 

23  A.   THIS CAUSES DEATH BY CAUSING FATAL ARRHYTHMIA.  A SUDDEN

 

24  ABNORMAL RHYTHM THAT SIMPLY IS SO INEFFICIENT THAT IT DENIES

 

25  THE BRAIN SUDDENLY ANY KIND OF BASELINE KIND OF CIRCULATION.

 

 1  Q.   AND IS THERE ANY WAY TO TELL IN AN AUTOPSY, IS THERE A

 

 2  WAY TO SEE THAT AN ARRHYTHMIA OCCURRED?

 

 3  A.   NO.  IT'S A DYNAMIC PROCESS.  IT'S A PHYSIOLOGIC

 

 4  PROCESS.  AND AT AUTOPSY, IN SPITE OF WHAT YOU MAY THINK FROM

 

 5  LOOKING AT T.V., AUTOPSIES ONLY LOOK AT NONMOVING TISSUE, AND

 

 6  SO IT'S A STRUCTURAL THING THAT AN AUTOPSY IDENTIFIES.

 

 7  ARRHYTHMIA AS WELL AS A NUMBER OF OTHER CLINICAL PHENOMENA

 

 8  SIMPLY CAN'T BE APPRECIATED AT AUTOPSY.  THAT'S WHY I LOOK AT

 

 9  THE MEDICAL RECORDS FIRST.

 

10  Q.   AND THEN WE GO TO THIS SECONDARY OR CONTRIBUTING CAUSES.

 

11  YOU ALSO NOTE DEHYDRATION AND ANEMIA.

 

12  A.   A CONTRIBUTING CONDITION I BELIEVE IN THIS CASE WAS

 

13  DEHYDRATION AND I BELIEVE THIS SINCERELY BECAUSE DEHYDRATION

 

14  AND ANEMIA WERE TWO THINGS THAT WERE DOCUMENTED WELL.  THERE

 

15  WAS PERSISTENT NAUSEA AND VOMITING WHICH FIRST OF ALL

 

16  DESTROYS THE ELECTRICAL BALANCE IN THE BODY, AS WELL

 

17  ELIMINATING -- ELIMINATING NECESSARY FLUIDS BECAUSE THE ONLY

 

18  WAY SHE WAS ABLE TO TAKE FLUIDS WAS ORALLY.  AND THIS WAS

 

19  PERSISTENT.  ALSO, SHE HAD BLOODY EMESIS WHICH MEANS SHE

 

20  BEGAN TO THROW UP SOME BLOOD AND SHE HAD SOME BLOOD IN HER

 

21  STOOL, HEMATOCHEZIA, AND THE REASON FOR THAT WAS INADEQUATE

 

22  SUPPORT OF THE DELICATE LINING OF THE STOMACH.  AND AS WELL

 

23  AS THE ENTIRE GASTROINTESTINAL TRACT.  THERE WAS A NOTE --

 

24  AND I'LL REFER BACK TO WHAT WAS SAID ON THE -- ON THE AUTOPSY

 

25  REPORT BY THE PATHOLOGIST HERE, THAT SAID, WELL, THERE WAS NO

 

 1  BLOOD FOUND IN THE GASTROINTESTINAL TRACT.  WELL, THAT'S

 

 2  FINE.  THAT'S FINE.  IT'S A GOOD OBSERVATION, BUT IT DOESN'T

 

 3  MEAN THAT IT DIDN'T HAPPEN BEFORE.  AND IN FACT, CLINICALLY,

 

 4  IT DID HAPPEN ON DECEMBER 30TH AND 31ST TO THE POINT WHERE

 

 5  HER HEMATOCRIT WENT DOWN BY ONE-QUARTER.  SO THAT'S A SEVERE

 

 6  DEPRESSION OF HEMATOCRIT.  SHE BECAME ACUTELY ANEMIC.  AND

 

 7  THAT IN ITSELF COULD HAVE BEEN A CAUSE DEATH AND VERY LIKELY

 

 8  PRECIPITATED THE PROCESS OF ARRHYTHMIA BECAUSE IT REDUCED THE

 

 9  NUMBER OF RED CELLS TO CARRY GAS FROM THE LUNGS TO THE BRAIN

 

10  AND THE OTHER ORGANS.  SO NOT ONLY WERE THE ORGANS

 

11  DYSFUNCTIONAL IN -- OF THE ORGANS OF THE PUMP SYSTEM, IN THE

 

12  HEART PART ONE, BUT ALSO THE NUMBER OF RED CELLS AVAILABLE TO

 

13  THIS BODY WERE REDUCED BY 25 PERCENT OVER THE COURSE OF --

 

14  OVERNIGHT, I THINK IT WAS.  ONE DAY.  AND SHE BECAME

 

15  HYPOTENSIVE WHICH MEANS THAT HER BLOOD PRESSURE DROPPED

 

16  PRECIPITOUSLY AS WELL.  I INCLUDE HERE -- IF YOU WANT ME TO

 

17  GO ON.

 

18  Q.   SURE.

 

19  A.   I INCLUDE HERE HYPOTHYROIDISM.  THIS LADY HAD HER

 

20  THYROID REMOVED.  SHE HAD BEEN REPLACED WITH SYNTHROID, WHICH

 

21  IS L-THYROXINE.  IT'S THE THYROID HORMONE, THE PRIMARY

 

22  THYROID HORMONE, THAT THAT GLAND PRODUCES FOR US TO MAINTAIN

 

23  THE METABOLISM OF THE BODY, TO REGULATE OUR BODY SYSTEM.

 

24  THIS LADY ULTIMATELY HAD BEEN REMOVED FROM ALL OF HER

 

25  MEDICATIONS, INCLUDING THYROID HORMONE.  HYPOTHYROIDISM

 

 1  THEREFORE BECOME A DIRECT -- A DIRECT INFLUENCE ON

 

 2  MALFUNCTION, ORGAN MALFUNCTION, DIFFUSELY.  AND I NOTE THERE

 

 3  THAT PART OF THAT PROCESS WAS VERY READILY EVIDENT IN THE

 

 4  RECORDS FROM NEW YEAR'S EVE UNTIL JANUARY 3RD WHERE THE DYING

 

 5  PATTERN THAT WE SEE IN SO MANY PEOPLE WHO ARE DYING SLOWLY OF

 

 6  ALTERED RESPIRATORY PATTERNS, THAT'S THE INCONSISTENCY,

 

 7  FLUCTUATING BLOOD PRESSURE, RESTLESSNESS AND AGITATION FROM

 

 8  INADEQUATE PERFUSION OF THE BRAIN, ALL -- ALL ARE PRESENT

 

 9  DURING THAT PERIOD OF TIME.  AND PROBABLY MADE WORSE BY THE

 

10  FACT THAT HER TERMINAL CARE WAS FOR SOME REASON, PROBABLY A

 

11  MISUNDERSTANDING, NOT PROPERLY TREATED MEDICALLY.  BECAUSE AS

 

12  I RECALL, SHE WAS DENIED SOME OF HER REGULAR DOSING OF

 

13  MORPHINE, IF NOT OTHER THINGS, WHICH OF COURSE WOULD HAVE

 

14  STABILIZED HER DYING COURSE AND KEPT HER MORE COMFORTABLE.

 

15  Q.   NOW, THIS -- IN ALL THE TOXICOLOGY RESULTS, THERE'S ONLY

 

16  ONE POSITIVE FINDING FOR MORPHINE, AND THAT'S WITH REGARD TO

 

17  JUDITH LARSEN.  HOW DID THAT TOXICOLOGY RESULT FACTOR INTO

 

18  YOUR ANALYSIS WITH REGARD TO CAUSE OF DEATH?

 

19  A.   WELL, I EXPECTED TO FIND MORPHINE IN THIS CASE AND

 

20  FRANKLY, I WOULD HAVE EXPECTED TO FIND IT HAD IT BEEN

 

21  PROPERLY TESTED FOR IN EVERY CASE HERE.  BECAUSE THERE IS

 

22  EVIDENCE IN EVERY ONE OF THESE CASES THAT THESE PEOPLE, WITH

 

23  THE EXCEPTION OF ONE, HAD RECEIVED -- THAT'S MRS. ANDERSON --

 

24  HAD RECEIVED MORPHINE RELATIVELY CLOSE TO THE TIME OF DEATH.

 

25  AT LEAST THAT -- THE LAST DOSE.  SO IT WOULD HAVE BEEN A

 

 1  FINDING I THINK THAT WOULD HAVE BEEN EXPECTED OR SHOULD HAVE

 

 2  BEEN EXPECTED.  TO FIND IT HERE DOESN'T SURPRISE ME AT ALL.

 

 3  Q.   AND HOW IS IT THAT YOU DIFFER -- WHY IS IT THAT YOU

 

 4  DIFFER FROM THE OTHER PATHOLOGIST ON THE CAUSE OF DEATH AND

 

 5  THE MANNER OF DEATH?

 

 6  A.   LET ME CIRCLE BACK AND -- AND SAY SOMETHING MAYBE IN A

 

 7  LITTLE DIFFERENT WAY.  I THINK THERE'S A MISUNDERSTANDING

 

 8  HERE, PERHAPS ABOUT THE DYING PROCESS.  PERHAPS THERE WASN'T

 

 9  AN EXAMINATION OF THE MEDICAL RECORDS IN SUCH A WAY THAT THE

 

10  DYING PROCESS WAS SEEN --

 

11       MR. MAJOR:  YOUR HONOR, I'M GONNA OBJECT AT THIS TIME.

 

12  I'M NOT SURE THIS IS -- THIS IS BEYOND THE SCOPE OF HIS

 

13  EXPERTISE AS A PATHOLOGIST.  I THINK WE'RE NOW GETTING INTO

 

14  AREAS THAT HE CANNOT TESTIFY TO ON HIS EXPERTISE.

 

15       THE COURT:  OVERRULE THE OBJECTION.  GO AHEAD.

 

16       THE WITNESS:  BUT FOR SOME REASON, THERE WAS A FOCUSSING

 

17  UPON MORPHINE PRESENCE TO THE EXTENT THAT HE ACTUALLY SAID

 

18  DEATH HAD HAPPENED BECAUSE THERE WAS A TOXIC EFFECT OF

 

19  MORPHINE.  I THINK THIS EXHIBITS, FRANKLY, A MISUNDERSTANDING

 

20  OF THE ENTIRE PROCESS.  DEATH WITH MORPHINE IN THE BODY

 

21  DOESN'T MEAN DEATH BY MORPHINE IN THE BODY, JUST LIKE DEATH

 

22  WITH -- WITH ELAVIL IN THE BODY, AS IN MRS. ANDERSON, DIDN'T

 

23  MEAN DEATH BY ELEVIL.  DEATH WITH ASPIRIN IN THE BODY DOESN'T

 

24  MEAN DEATH BY ASPIRIN, OKAY?  TOXICOLOGY REVEALS A LOT OF

 

25  THINGS IF YOU LOOK FOR THEM.  OKAY?  AND IF THEY'RE THERE.

 

 1  THE IMPORTANT THING IS THE INTERPRETATION OF THESE.  IN THIS

 

 2  CASE THE MORPHINE GIVEN AS A PART OF THE ASSISTANCE OF THIS

 

 3  LADY DURING HER DYING PROCESS, WHICH IS VERY NICELY DEPICTED

 

 4  FRANKLY, IN THE MEDICAL RECORD.

 

 5  Q.  (BY MS. ISAACSON)  AND HAVE YOU SEEN SIMILAR FINDINGS IN

 

 6  OTHER PATIENTS WHO'VE RECEIVED MORPHINE AT THE END OF LIFE

 

 7  FOR COMFORT CARE?

 

 8       MR. MAJOR:  OBJECTION, YOUR HONOR.  THINK IT'S

 

 9  IRRELEVANT.

 

10       THE COURT:  SUSTAINED.

 

11       THE WITNESS:  FRANKLY, I SEE THIS A LOT.  I WORK --

 

12       THE COURT:  WAIT, WAIT --

 

13       THE WITNESS:  OH, I'M SORRY.

 

14       THE COURT:  SUSTAINED.

 

15       THE WITNESS:  SUSTAINED --

 

16       THE COURT:  THAT MEANS YOU DON'T ANSWER IT.  GO AHEAD.

 

17       THE WITNESS:  EXCUSE ME.

 

18  Q.  (BY MS. ISAACSON)  DO YOU HAVE AN OPINION TO A REASONABLE

 

19  DEGREE OF MEDICAL CERTAINTY AS TO THE CAUSE OF DEATH OF

 

20  JUDITH LARSEN?

 

21  A.   YES.

 

22  Q.   AND WHAT IS THAT OPINION?

 

23  A.   MY OPINION, AS I'VE INDICATED HERE, IS THAT SHE DIED OF

 

24  ADVANCED ARTERIORSCLEROSIS.  AND THAT THIS WAS PRECIPITATED

 

25  PRIMARILY BY THE CONDITION THAT MADE THIS COME TO FULL

 

 1  FLOWER, SO TO SPEAK, WAS THE UNDERLYING ANEMIA, THE REDUCTION

 

 2  OF AVAILABLE BLOOD SUPPLY, RED CELLS, AND DEHYDRATION, THE

 

 3  LOSS OF FLUID FROM HER BODY.  THIS I BELIEVE WAS ASSOCIATED

 

 4  LIKEWISE WITH HYPOTHYROIDISM BECAUSE SHE WAS NO LONGER

 

 5  GETTING HER THYROID REPLACEMENT MEDICATION.  AND SHE HAD NO

 

 6  THYROID GLAND TO PROVIDE IT TO HERSELF.

 

 7  Q.   AND DO YOU HAVE AN OPINION TO A DEGREE OF REASONABLE

 

 8  MEDICAL CERTAINTY AS TO THE MANNER OF DEATH --

 

 9  A.   YES.

 

10  Q.   -- FOR JUDITH LARSEN?

 

11  A.   YES.

 

12  Q.   AND WHAT IS THAT OPINION?

 

13  A.   SHE DIED FROM DISEASE.  SHE DIED FROM HER DISEASES.  SHE

 

14  DIED IN A WAY THAT LOOKS PREDICTABLE TO ME CLINICALLY.  I

 

15  FIND NOTHING TO CONTROVERT THAT, SO I CALL IT A NATURAL

 

16  DEATH.

 

17       MS. ISAACSON:  IF I COULD JUST HAVE ONE MOMENT, YOUR

 

18  HONOR?

 

19       THE COURT:  YOU MAY.

 

20  Q.  (BY MS. ISAACSON)  IN THE INTEREST TIME, WE'VE HEARD WHAT

 

21  YOUR FINDINGS AND YOUR CONCLUSIONS ARE ABOUT JUDITH AND SO

 

22  LET'S JUST MOVE ON TO THE -- TO THE NEXT PATIENT, MARY CRANE.

 

23  AND THIS IS STATE'S EXHIBITS 4-C.  LET'S GO OVER -- WELL,

 

24  LET'S JUST BRIEFLY IDENTIFY FOR THE JURY WHAT -- WHAT'S

 

25  INCLUDED ON THE ORIGINAL REPORT AND THEN WE'LL GO TO YOUR

 

 1  FINDINGS.  I THINK THAT'S -- THAT MIGHT BE HELPFUL.  WITH

 

 2  REGARD TO MARY CRANE, FIRST OF ALL, LET'S TALK ABOUT THE

 

 3  MANNER OF DEATH AND IMMEDIATE CAUSE OF DEATH.  WE SEE NOW A

 

 4  NEW TERM, UNDETERMINED INJURY.  WHAT DOES THAT TERM MEAN?

 

 5  A.   WELL, I'M NOT SURE I'VE EVER HEARD THAT BEFORE.  BUT AS

 

 6  I UNDERSTAND IT, IT'S AN EXPLANATION FOR WHY THIS PATHOLOGIST

 

 7  REFUSES TO DETERMINE IT.  IT'S -- THE RESERVATION IS THAT THE

 

 8  PATHOLOGIST IS NOT SURE IF THERE'S BEEN AN INJURY OF SOME

 

 9  SORT.  THERE MIGHT BE A NUMBER OF REASONS, AS I INDICATED,

 

10  FOR NOT WANTING TO DETERMINE THE CAUSE OF DEATH.  BUT IT

 

11  SEEMS TO ME THAT THAT'S WHAT THAT WOULD MEAN.

 

12  Q.   ULTIMATELY, SHE INDICATED SHE COULD NOT DETERMINE THE

 

13  CAUSE OF DEATH IN THAT CASE. 

 

14  A.   BECAUSE SHE'S UNABLE TO DETERMINE WHETHER THERE'S AN

 

15  INJURY.

 

16  Q.   OKAY.

 

17  A.   THAT'S THE WAY I UNDERSTAND THAT.

 

18  Q.   AND THE FINDINGS BY THE PATHOLOGIST IN THIS CASE, DO YOU

 

19  DISAGREE GENERALLY WITH THE FINDINGS HERE?

 

20  A.   NO.  NO.  IN FACT, I RELY UPON THEM.  SHE DID THE

 

21  AUTOPSY.  SHE MADE THE OBSERVATIONS.  THERE'S NO WAY FOR US

 

22  TO REDO THE AUTOPSY IN EXACTLY THE SAME WAY, ESPECIALLY NOW.

 

23  SO I RELY UPON THEM.  I TAKE THEM AT FACE VALUE.

 

24  Q.   LET'S GO TO YOUR OUTLINE OF FINDINGS, AND THIS IS

 

25  DEFENDANT'S EXHIBIT 106.  SAME THING WE'VE SEEN BEFORE.  WITH

 

 1  REGARD TO HER CAUSE OF DEATH, WHAT DID YOU -- WHAT DID YOU

 

 2  FIND WAS HER PRIMARY CAUSE OF DEATH?

 

 3  A.   THIS LADY HAS TWO MAJOR PROBLEMS.  BOTH OF THEM HAVE TO

 

 4  DO WITH THE CARDIOVASCULAR SYSTEM, THE PUMPING SYSTEM AND THE

 

 5  BLOOD SUPPLY SYSTEM.  ONE IS HYPERTENSION OR HIGH BLOOD

 

 6  PRESSURE, WHICH PRODUCES A PROGRESSIVE DELETERIOUS EFFECT

 

 7  UPON THE PUMP AS WELL AS UPON THE KIDNEYS AND THE TISSUES THAT

 

 8  ARE SUPPLIED.  CARDIOMEGALY, AS I'VE INDICATED THERE IN

 

 9  THE -- EXCUSE ME, LET ME FINISH THE QUESTION BEFORE.  THE

 

10  OTHER DISEASE THAT IS VERY IMPORTANT IN THIS CASE IS

 

11  ARTERIOSCLEROSIS AS WELL.  IT'S A DISEASE THAT IS ADVANCED

 

12  FOR THIS PARTICULAR LADY, EVEN THOUGH SHE'S CERTAINLY OLD

 

13  ENOUGH TO HAVE IT.  SHE HAPPENS NOT TO BE AS OLD AS THE

 

14  OTHERS, BUT SHE HAS EVERY BIT AS SEVERE CORONARY ARTERY

 

15  DISEASE AS THE OTHERS DO.  SO I BELIEVE THAT THOSE TWO

 

16  CATEGORIES ARE THE CAUSE FOR HER DYING.

 

17  Q.   AND WHEN I SEE THIS MYOCARDIAL SCARRING, IS THAT IN THE

 

18  HEART?

 

19  A.   RIGHT.  THERE'S EVIDENCE IN HER HEART THAT SHE HAS,

 

20  FIRST OF ALL, OBSTRUCTED CORONARY ARTERIES.  THEY ARE

 

21  SEVERELY OBSTRUCTED, AS THIS PATHOLOGIST HAS INDICATED.  THE

 

22  LEFT ANTERIOR DESCENDING CORONARY ARTERY IS OBSTRUCTED 80

 

23  PERCENT.  AND THAT'S AT THE TIME OF AUTOPSY, WHICH IS THREE

 

24  AND A HALF YEARS AFTER SHE'S -- SHE'S BEEN BURIED.  IT WAS

 

25  PROBABLY CLOSED MORE THAN THAT AT THE TIME SHE ACTUALLY DIED.

 

 1  BUT THREE AND A HALF YEARS LATER, SHE'S STILL AT 80 PERCENT

 

 2  OBSTRUCTION OF THE AVAILABLE NORMAL SPACE OF THE CORONARY

 

 3  ARTERY, AS WELL AS IN THE RIGHT CORONARY ARTERY BEING ABOUT

 

 4  HALF OBSTRUCTED.  THAT'S VERY ADVANCED DISEASE.  THAT'S PART

 

 5  OF THE REASON THAT SHE ALSO HAS MYOCARDIAL SCARRING.  THE

 

 6  HEART ITSELF HAS HAD HEART ATTACKS AND THE SCARS ARE EVIDENCE

 

 7  OF THOSE HEART ATTACKS THAT HAVE RESULTED FROM POOR CORONARY

 

 8  CIRCULATION OVER A LONG PERIOD OF TIME.

 

 9  Q.   SO TO KIND OF TRANSLATE INTO PLAIN LANGUAGE THIS

 

10  SECTION, ULTIMATELY, DO THE ARTERIES NOT GIVE BLOOD TO THE

 

11  HEART?  HOW DOES SOMEONE ACTUALLY -- HOW DOES THIS CAUSE THE

 

12  DEATH?

 

13  A.   THAT SECTION TALKS ABOUT POOR CIRCULATION BASICALLY.

 

14  POOR CIRCULATION BECAUSE OF ARTERIOSCLEROSIS IN THREE MAJOR

 

15  IMPORTANT ORGANS, THE HEART, THE LUNGS, AND THE KIDNEYS.

 

16  THAT'S WHAT THE NEPHROSCLEROSIS IS.  THAT'S THE KIDNEYS.  AND

 

17  THE PULMONARY ATHEROSCLEROSIS IS THE -- IN THE SECTIONS, THE

 

18  MICROSCOPIC SECTIONS OF THE LUNG, ONE CAN SEE THROUGHOUT THEM

 

19  ADVANCED ARTERIOSCLEROSIS.

 

20  Q.   AND I GUESS I DON'T QUITE UNDERSTAND HOW THE

 

21  HYPERTENSION WORKS.  CAN YOU EXPLAIN THAT IN AS PLAIN

 

22  LANGUAGE AS YOU CAN?

 

23  A.   HYPRETENSION WORKS BY -- BASICALLY, IT STRESSES THE

 

24  HEART, WHICH IS THE PUMP, TO PUSH BLOOD AT THE BODY'S

 

25  NECESSARY RATE, WHATEVER THE DEMAND OF THE BODY IS AT ANY

 

 1  GIVEN MOMENT, TO PUSH ADEQUATE BLOOD TO END ORGANS WHICH

 

 2  REQUIRE THAT OXYGENATION AND NUTRITION, AGAINST PERIPHERAL

 

 3  BLOOD VESSELS, SMALL BLOOD VESSELS IN THE PERIPHERY AND IN

 

 4  THE END ORGANS THAT ARE STENOSED, THAT ARE CRIMPED DOWN.  AND

 

 5  NOBODY SEEMS TO KNOW EXACTLY WHY THIS HAPPENS, BUT IT'S A

 

 6  PROCESS THAT CAN OBVIOUSLY BE CAUSED BY ARTERIORSCLEROSIS AS

 

 7  WE INDICATED, BUT IT IS ALSO A SEPARATE PROCESS BECAUSE EVEN

 

 8  WITHOUT ARTERIOSCLEROSIS, THOSE SMALL VESSELS CONTRACT, THEY

 

 9  SQUEEZE DOWN, IF THEY ARE NOT ABSOLUTELY RIGID IN THE SMALL

 

10  VESSELS.  AND THEY CAUSE THE BLOOD PRESSURE TO RISE.  IT'S

 

11  LIKE OBSTRUCTING A HOSE WHEN YOU TRY TO PUSH -- PUSH WATER

 

12  THROUGH IT, YOU RAISE THE PRESSURE OF THE WATER IN THE LINE.

 

13  AND YOU HAVE TO PUSH HARDER TO GET IT BY AN OBSTRUCTION.

 

14  THAT'S WHAT HYPERTENSION DOES.  NOW, THE BAD EFFECT OF ALL OF

 

15  THAT IS THAT THE PUMP WILL WEAR OUT.  AND THAT'S WHY THE

 

16  HEART ENLARGES.  THIS WAS OVER 400 GRAMS.  NORMAL FOR THIS

 

17  LADY WOULD HAVE BEEN 250 TO 300 GRAMS.  THIS IS OVER 400

 

18  GRAMS IN WEIGHT, AND SHE HAS A 1.8 TO 2 CENTIMETER THICKNESS

 

19  IN HER LEFT VENTRICULAR WALL.  THIS INDICATES THAT HER LEFT

 

20  VENTRICULAR WALL, LIKE A -- LIKE A WEIGHTLIFTER'S MUSCLE,

 

21  BICEPS, HAS BECOME THICK BECAUSE OF ITS CONTINUING HARD WORK.

 

22  NOW, UNLIKE THE WEIGHTLIFTER WHO TAKES PRIDE IN THE BIG

 

23  BICEPS, A THICKENED HEART MUSCLE REQUIRES MORE NUTRITION.

 

24  AND IF ONE HAS ARTERIOSCLEROSIS AS THIS LADY DOES, NUTRITION

 

25  SIMPLY ISN'T GONNA BE ADEQUATE.  AND THERE'S A BREAKING

 

 1  POINT.  AND THAT'S FRANKLY CALLED FATAL ARRHYTHMIA AND DEATH.

 

 2  Q.   WITH REGARD TO THE SECONDARY CAUSES, I SEE A LONG LIST

 

 3  OF THINGS THAT YOU'VE INDICATED.  HOW DO THESE PLAY INTO THE

 

 4  CAUSE OF DEATH?

 

 5  A.   I CALL THESE CONTRIBUTING CONDITIONS BECAUSE THEY'RE

 

 6  LABAELLED AS NUMBER 2, AND VERY QUICKLY, LET ME JUST SAY,

 

 7  PEOPLE WITH DIABETES, LONGSTANDING DIABETES HAVE ACCELERATED

 

 8  ARTERIOSCLEROSIS.  IT'S JUST ONE OF THE PROBLEMS ASSOCIATED

 

 9  WITH THAT DISEASE.  THE OTHER PROBLEM IS THAT WITH UNSTABLE

 

10  BLOOD SUGARS, WHICH THIS LADY EXPERIENCED IN THE FIRST DAYS

 

11  OF JANUARY, THE UNSTABLE BLOOD SUGARS PROVIDE UNSTABLE

 

12  NUTRITIONAL BALANCE AND AVAILABILITY TO ALL THE TISSUES IN

 

13  THE BODY.  SO THEY DON'T SUPPORT THE AMOUNT OF GLUCOSE, WHICH

 

14  IS AN ESSENTIAL NUTRIENT, IS NOT AVAILABLE ON A REGULAR

 

15  BASIS.  LUNG ASPIRATION MEANS THAT SHE HAS ASPIRATED SOME OF

 

16  HER GASTRIC CONTENT.  THIS IS SOMETHING THAT IS NOT UNCOMMON,

 

17  IN HEALTHY PEOPLE CAN BE SURVIVED, BUT IN UNHEALTHY PEOPLE,

 

18  IT CAN ACTUALLY DESTROY LUNG TISSUE.  FIRST OF ALL, IT CAN

 

19  BE -- IT CAN BECOME INFECTED AS THE THIRD ITEM IS ACUTE

 

20  PURULENT BRONCHITIS.  AND I TOOK THAT RIGHT OFF OF THE

 

21  AUTOPSY REPORT.  THAT WAS IDENTIFIED BY THE PATHOLOGIST.  AND

 

22  I FIND EVIDENCE FOR THAT IN THE CLINICAL RECORDS WHICH SAY

 

23  THAT SHE ASPIRATED ON TWO DIFFERENT OCCASIONS, THE 3RD AND

 

24  THE 7TH OF JANUARY.  SHE HAD FEVER.  SHE EVEN HAD A SEIZURE

 

25  BECAUSE OF THAT.  PROBABLY A FEVER -- A FEVER-ASSOCIATED

 

 1  SEIZURE.  SHE HAD HYPOALBUMINEMIA, MEANING THAT BASICALLY SHE

 

 2  HAD NO NUTRITION, EXTERNAL NUTRITION.  SHE HAD A WASTING

 

 3  DISEASE.  SHE HAD DEHYDRATION, WHICH IS AN EXCELLENT BED FOR

 

 4  THE DEVELOPMENT OF GENERALIZED INFECTION, AND IT'S POSSIBLE

 

 5  THAT SHE COULD HAVE HAD GENERALIZED INFECTION.  YOU FRANKLY

 

 6  CAN'T DIAGNOSE THAT AT AUTOPSY.  BUT I THINK IT'S A VERY

 

 7  LEGITIMATE CLINICAL OR POSSIBLE CLINICAL DIAGNOSIS HERE.  SHE

 

 8  WAS TREATED FOR A RECTO/VAGINAL FISTULA WHICH MAY HAVE BEEN A

 

 9  CAUSE OF THAT, IF NOT THE ACUTE PURULENT BRONCHITIS.  SHE HAD

 

10  RENAL INSUFFICIENCY, KIDNEY INSUFFICIENCY, WHICH I INDICATED

 

11  ABOVE WAS DUE TO THE ARTERIOSCLEROSIS.  SHE HAD SEVERE

 

12  DEMENTIA AND WASTING BECAUSE OF THAT.  AND PSYCHOTIC

 

13  DEPRESSION WHICH CAUSED HER TO -- IF YOU RECALL, SHE WAS A

 

14  LADY WHO WAS SO CONFUSED THAT SHE -- SHE USED TO DRINK

 

15  PHENOMENAL AMOUNTS OF WATER.  THIS ACTUALLY CAN BE

 

16  DELETERIOUS.  POLYDIPSIA IS AN ABNORMAL -- THAT'S WHY IT'S

 

17  CALLED PSYCHOGENIC.  IT'S AN ABNORMAL CONSUMPTION OF WATER

 

18  THAT PUTS YOUR ELECTROLYTES AND YOUR FLUID BALANCE OUT OF

 

19  WHACK.  WELL, THE BEST WAY TO TREAT THAT IS RESTRICTION.

 

20  THIS LADY WOULD DRINK WATER OUT OF TOILETS WHEN RESTRICTED IF

 

21  NOT PROPERLY SUPERVISED OR CONTINUALLY SUPERVISED SIMPLY

 

22  BECAUSE SHE WAS DRIVEN TO CONSTANTLY DRINK WATER EVEN THOUGH

 

23  THE BODY DIDN'T REQUIRE ALL OF THAT.  AND AFTER SHE HAD BEEN

 

24  RESTRICTED AND -- FROM IT ABSOLUTELY, THEN SHE BECAME

 

25  DEHYDRATED.  SHE WENT TO THE OTHER WAY.  SO SHE HAD A SEVERE

 

 1  FLUID AND ELECTTROLYTE PROBLEM GOING THROUGH THE LAST DAYS OF

 

 2  LIFE.  AND THEN SHE HAD CHRONIC LOW BACK PAIN WHICH WAS

 

 3  PRESENT EVEN AFTER SHE HAD DISK SURGERY FOR WHICH SHE WAS

 

 4  TREATED, AS YOU PROBABLY HAVE DISCUSSED ELSEWHERE, WITH

 

 5  OPIATE MEDICATIONS OVER A LONG PERIOD OF TIME.

 

 6  Q.   ULTIMATELY, DR. CASSIN, WITH REGARD TO MARY CRANE, DO

 

 7  YOU HAVE AN OPINION TO A DEGREE OF REASONABLE MEDICAL

 

 8  CERTAINTY AS TO THE CAUSE OF DEATH OF MARY CRANE?

 

 9  A.   YES.

 

10  Q.   AND WHAT IS THAT OPINION?

 

11  A.   I THINK THAT MARY CRANE DIED BY THE TWO PROCESSES I PUT

 

12  AT THE TOP OF THIS LIST.  SHE DIED BECAUSE SHE HYPERTENSION,

 

13  WHICH LEFT ITS ANATOMICAL LANDMARK CLEARLY AND BOLDLY IN THE

 

14  AUTOPSY.  ALL WE HAD TO DO WAS READ THE PATHOLOGIST'S REPORT.

 

15  AND ARTERIOSCLEROSIS, WHICH WAS THE OTHER SIDE OF THAT COIN,

 

16  MAKING HER BLOOD VESSELS CRIMPED DOWN AND OBSTRUCTED SO THAT

 

17  EVEN WITH HIGH BLOOD PRESSURE, SHE WAS GETTING VERY POOR

 

18  NUTRITION TO HER HEART, HER BRAIN, HER LUNG, AND HER KIDNEY.

 

19  Q.   AND DO YOU HAVE AN OPINION TO A DEGREE OF REASONABLE

 

20  MEDICAL CERTAINTY AS TO THE MANNER OF DEATH OF MARY CRANE?

 

21  A.   YES.  THE MANNER OF DEATH, BECAUSE SHE DIED OF HER

 

22  DISEASES, AGAIN, IS A NATURAL DEATH.

 

23       MS. ISAACSON:  YOUR HONOR, I HAVE TWO MORE AUTOPSIES TO

 

24  GO THROUGH.  SHOULD WE TAKE A BREAK NOW?

 

25       THE COURT:  I THINK WE NEED TO TAKE OUR LUNCH BREAK AT

 

 1  THIS TIME.  DOCTOR, YOU MAY STEP DOWN.

 

 2       THE WITNESS:  THANK YOU.

 

 3       THE COURT:  LADIES AND GENTLEMEN, WE'LL BE BACK AT 1:15.

 

 4  AGAIN REMIND YOU OF MY PRIOR CAUTION.  WE'LL SEE YOU BACK

 

 5  THEN.  1:15.  BE IN RECESS UNTIL THEN.

 

 6            (MORNING SESSION ENDED.)

 

                      THE COURT:  PARTIES AND COUNSEL ARE PRESENT.  JURY

 

             IS IN THE JURY BOX.  DOCTOR, WILL YOU COME BACK UP TO THE

 

             STAND, PLEASE.  THE COURT REMINDS YOU, DOCTOR, THAT YOU'RE

 

             STILL UNDER OATH.

 

                      THE WITNESS:  THANK YOU.

 

                      THE COURT:  YOU MAY CONTINUE WITH YOUR EXAMINATION,

 

             MS. ISAACSON.

 

                      MS. ISAACSON:  THANK YOU, YOUR HONOR.

 

                             DIRECT EXAMINATION (CONT'D)

 

            BY MS. ISAACSON:

 

             Q.  DR. CASSIN, LET'S TALK ABOUT LYDIA SMITH.  LET'S GO TO

 

             STATE'S 5-C, PAGE 1 OF LYDIA SMITH'S AUTOPSY REPORT.  AGAIN,

 

             A LIST BY THE PATHOLOGIST OF HIS FINAL PATHOLOGIC DIAGNOSES.

 

             FIRST, CAN YOU EXPLAIN WHY THAT LIST IS SHORTER THAN THE

 

             PREVIOUS LIST?

 

             A.  WELL, ACTUALLY, I'M NOT SURE I CAN.  BUT THE DIFFERENCE

 

             IN THIS PARTICULAR CASE, AT LEAST THE MOST REMARKABLE

 

             DIFFERENCE I THINK FROM THE STANDPOINT OF POSTMORTEM

 

             EXAMINATION, IS THAT THIS BODY WAS LEAST WELL-PRESERVED, AND

 

             IN FACT, WAS POORLY PRESERVED.  THIS BODY HAD BEEN IN THE

 

             GROUND FOR FOUR AND A HALF YEARS PRIOR TO AUTOPSY, AND I

 

             SUSPECT THAT'S WHY WE HAVE KIND OF A TRUNCATED LIST.  BUT I

 

             CAN'T SAY FOR SURE BECAUSE THERE'S AN ABSENCE OF FINDINGS

 

             STILL IN THIS FINAL LISTING OF ABNORMAL FINDINGS.

 

             Q.  WELL, LET'S GO TO THE LIST THAT YOU COMPILED THAT'S BEEN

 

             MARKED DEFENDANT'S EXHIBIT 107.  WITH LYDIA SMITH, WHAT HAVE

 

             YOU IDENTIFIED AS HER PRIMARY CAUSE OF DEATH?

 

             A.  WELL, REMEMBERING THAT C.O.D. MEANS CAUSE OF DEATH AND

 

             I'M INCLUDING UNDER THAT AN OUTLINE THAT IS

 

             CHARACTERISTICALLY USED ON THE DEATH CERTIFICATION FORMAT.

 

                 WHAT YOU SEE HERE IS THAT I HAVE AGAIN IDENTIFIED -- AND

 

             THIS IS THROUGH THE EXAMINATION OF THE PATHOLOGIST OF THE

 

             BODY FOUR AND A HALF YEARS, NONETHELESS -- OR NOTWITHSTANDING

 

             SOME ADVANCED DECOMPOSITIONAL CHANGES.  BUT THERE WAS STILL

 

             ATHEROSCLEROSIS AND IT WAS SIGNIFICANT, IT WAS SEVERE.  AND I

 

             INDICATE THAT THIS IS THE PRIMARY CAUSE OF DEATH HERE BECAUSE

 

             OF THOSE FINDINGS, THAT IN SPITE OF THE FACT THAT MUCH OF

 

             THIS BODY HAD MELTED AWAY SO TO SPEAK, THERE STILL WAS

 

             IDENTIFICATION OF CALCIFIC RIGHT CORONARY RIGHT

 

             ATHEROSCLEROSIS.  THERE WAS STILL IDENTIFICATION OF A RIGID

 

             AORTA BECAUSE OF THE CALCIFICATION AND THERE WAS STILL AN

 

             IDENTIFICATION OF CYSTIC KIDNEYS, WHICH RESULT, OF COURSE,

 

             AGAIN, ATHEROSCLEROSIS.

 

                 ALONG WITH THAT IS HISTORY OF UNSTABLE ANGINA.  MEANING

 

             THAT THIS PERSON FROM TIME TO TIME EXPERIENCED CHEST PAIN AND

 

             WAS TREATED FOR THAT.  THERE WAS ATRIAL FIBRILLATION WHICH IS

 

             NOT UN COMMON IN PATIENTS WITH THAT DISEASE IN THEIR HEART

 

             FROM ATHEROSCLEROSIS.

 

             Q.  WHAT DOES THAT TERM MEAN, THAT ATRIAL FIBRILLATION?

 

             A.  ATRIAL FIBRILLATION IS ARRHYTHMIA WHICH IS NOT FATAL.  IT

 

             MEANS THAT A PORTION OF THE HEART IS BEATING WITHOUT CONTROL

 

             BUT IT ISN'T THE MAIN PUMPING CHAMBER.  IT IS THE LESSER TWO

 

             PUMPING CHAMBERS.

 

             Q.  AND SO THIS SECTION HERE, THIS IS THE HISTORY THAT YOU

 

             SAW IN THE MEDICAL RECORDS?

 

             A.  THESE ARE HISTORICAL POINTS THAT COME UP IN REVIEW OF

 

             MEDICAL RECORDS.

 

             Q.  RIGHT.

 

             A.  INCLUDING THE IDENTIFICATION -- OR THE CITATION OF A

 

             PREVIOUS MYOCARDIAL INFARCT OR HEART ATTACK.  IN SUPPORT OF

 

             THAT AS WELL IS THE EFFECT ON THE BRAIN, AND THAT IS THAT

 

             THERE WERE -- THERE WAS A HISTORY OF STROKES AND THE MOST

 

             DRAMATIC BEING, OR AT LEAST ACCORDING TO THE RECORDS I

 

             REVIEWED THE MOST DRAMATIC BEING, A RECENT ONE.  BUT PRIOR TO

 

             ADMISSION, THAT'S WHAT P.T.A. MEANS, THERE WAS A RIGHT

 

             PARIETAL STROKE, MEANING THAT THE RIGHT SIDE OF THE BRAIN,

 

             THE DOMINANT HEMISPHERE OR PART OF THE HEMISPHERE HAD BEEN

 

             REDUCED SIGNIFICANTLY BY DESTRUCTION BY A STROKE.  SO

 

             VASCULAR OBSTRUCTION DUE TO ATHEROSCLEROSIS.

 

             Q.  AND DO I UNDERSTAND -- WE'VE BEEN TALKING A LOT ABOUT

 

             THIS ATHEROSCLEROSIS AND ALL THESE PATIENTS IT'S INDICATED IN

 

             THE RECORDS THEY HAVE DEMENTIA, IS THIS ACTUALLY PART OF THE

 

             CAUSE OF THE DEMENTIA?

 

             A.  WELL, THIS PERSON AS YOU CAN SEE DOWN IN NUMBER TWO HAD

 

             PSYCHOTIC DEPRESSION AND I SAY IT'S AFTER C.V.A., IT'S AFTER

 

             THE STROKE.  THE MAJOR PSYCHIATRIC PROBLEM THAT IS IDENTIFIED

 

             IN THE TERMINAL RECORDS IS PSYCHOTIC DEPRESSION WITH

 

             AGITATION, AND THIS IS DATED APPARENTLY BACK TO THE TIME

 

             SEVERAL WEEKS BEFORE OF STROKE.  AND SO IT'S ACCEPTABLE FROM

 

             THE STANDPOINT OF ONCE ONE LOSES A LOT OF ONE'S BRAIN MASS,

 

             ONE ALSO LOSES THE BENEFITS OF HAVING BRAIN CONTROL OF

 

             FUNCTION AND OF OTHER THINGS LIKE ATTITUDE, BEHAVIOR PATTERNS

 

             AND THAT SORT OF THING.  SO, YES, IT IS A PART OF

 

             ATHEROSCLEROSIS.

 

             Q.  OKAY.  THEN YOU'VE INDICATED IN THE SECOND SECTION

 

             VALVULAR HEART DISEASE.  HOW IS THAT A CONTRIBUTING FACTOR?

 

             A.  THE BEST PRESERVED ITEM IN THE CASKET HERE OTHER THAN THE

 

             CASKET ITSELF WAS THE HEART VALVE THAT HAD BEEN REPLACED IN

 

             THIS LADY.  AND WHAT THIS VALVE DID APPARENTLY -- IT WAS

 

             DESCRIBED AS BEING FUNCTIONAL, MEANING THAT IT APPEARED TO

 

             WORK OKAY.  IT DIDN'T APPEAR TO BE DAMAGED, FOR INSTANCE, OR

 

             ANYTHING LIKE THAT.  NEVERTHELESS, THIS LADY HAD HAD A SEVERE

 

             ENOUGH VALVULAR DAMAGE WHICH WAS STILL PRESENT BY WAY OF

 

             CALCIFICATION, SO THE EFFECTS OF ATHEROSCLEROSIS AROUND THE

 

             ANNULUS OR RING AROUND ITS BASE, EVEN THOUGH THOSE THINGS

 

             WERE STILL PRESENT, THE HEART VALVE HAD BEEN REPLACED.

 

                 AND SO PEOPLE WITH VALVULAR HEART DISEASE, EVEN THOUGH

 

             THEY MAY HAVE A REPLACEMENT OF THE VALVE, ARE STILL LIVING SO

 

             TO SPEAK ON BORROWED TIME.  THE VALVE MAY APPEAR TO BE

 

             FUNCTIONING WELL BUT IT ISN'T THE SAME AS A REAL HEART VALVE.

 

             IT'S SIMPLY A MECHANICAL VALVE THAT MAY OCCASIONALLY MISFIRE,

 

             MISFUNCTION AND NOT REVEAL BY EXAMINATION EXCEPT UNDER

 

             FLUOROSCOPY, AN IN-LIFE OR DURING-LIFE STUDY, THAT IT

 

             ACTUALLY IS NOT FUNCTIONING ADEQUATELY.

 

                 IN ANY CASE, AFTER DEATH, IT WAS APPARENTLY STILL

 

             FUNCTIONING.  ON THE OTHER HAND, THE DISEASE THAT CAUSED THE

 

             VALVE TO BE ABNORMAL WAS STILL PRESENT, AND THAT'S THE

 

             CALCIFIC ANNULUS OR SURROUNDING TISSUE IN THE VALVE.

 

             Q.  WE'VE TALKED A LITTLE BIT ABOUT THE PSYCHOTIC DEPRESSION.

 

             YOU'VE ALSO INDICATED HERE IN CONJUNCTION WITH THAT A REFUSAL

 

             OF FLUIDS AND FOOD.  HOW DOES THAT TIE INTO PSYCHOTIC

 

             DEPRESSION AND INTO THE CAUSE OF DEATH?

 

             A.  THE PSYCHOTIC DEPRESSION IS TIED IN HISTORICALLY TO THE

 

             STROKE.  THE PSYCHOTIC DEPRESSION WAS ONE OF THE MAIN

 

             MANIFESTATIONS OF THIS SEVERE RAPID ONSET OF DEMENTIA IN THIS

 

             PERSON.  SO IT IS A PART OF THE MANIFESTATION OF DEMENTIA

 

             WHICH INCLUDES THE REFUSAL OF WHAT WOULD ORDINARILY BEEN

 

             CONSIDERED NORMAL OR BENEFICIAL, SELF-PRESERVING BEHAVIOR

 

             WHICH IS FOUND IN DEMENTIA ROUTINELY.  IT'S A REFUSAL NOT

 

             ONLY OF FLUID AND NOURISHMENT SUSTENANCE, BUT FRANKLY IN THIS

 

             CASE, IT WAS ALSO A REFUSAL OF ORAL MEDICATION.

 

             Q.  NOW, WITH REGARD TO THE WEIGHT LOSS, OF COURSE, WE'VE

 

             TALKED ABOUT THE REFUSAL OF FLUIDS AND FOOD.  NOW, THIS ALL

 

             TOOK PLACE DO I HAVE IT RIGHT IN THE RECORDS PRIOR TO HER

 

             ADMISSION?

 

             A.  YES.  THE 30-POUND WEIGHT LOSS YOU'RE REFERRING TO?  YES,

 

             SHE WAS STILL ANOREXIC MEANING THAT SHE DID NOT EXHIBIT ANY

 

             APPETITE FOR FOOD.  BUT SHE HAD OVER A RELATIVELY RECENT

 

             PERIOD OF TIME LOST 30 POUNDS WHICH IS A DRAMATIC SHIFT IN

 

             WELL-BEING DOWNWARD AND HAPPENS IN ELDERLY PEOPLE

 

             CHARACTERISTICALLY ASSOCIATED WITH DEMENTIA.

 

             Q.  THEN HOW DOES A URINARY TRACT INFECTION PLAY INTO THE

 

             CAUSE OF DEATH?

 

             A.  URINARY TRACT INFECTIONS FOR ALL THEIR APPARENT MINOR

 

             CLASSIFICATION CERTAINLY BY A PATHOLOGIST BECAUSE THEY'RE

 

             ASSOCIATED WITH A RELATIVELY SMALL PART OF THE BODY, BUT EVEN

 

             BY SOME CLINICIANS WHO IN TREATING OTHERWISE NORMAL PATIENTS

 

             CAN TREAT IT EFFECTIVELY.  URINARY TRACT INFECTIONS HAVE A

 

             WAY OF DEPLETING EVEN NORMAL PEOPLE OF NORMAL ENERGY.  I

 

             GUESS THE PROOF WOULD BE IN HAVING ONE YOURSELF AND

 

             EXPERIENCING IT, BUT MANY PHYSICIANS CAN TELL YOU URINARY

 

             TRACT INFECTIONS CAN DEPLETE PEOPLE OF ENERGY JUST LIKE

 

             CONSTIPATION CAN DEPLETE YOU OF ENERGY FOR A PERIOD OF A TIME

 

             OR HAVING A SEVERE UPPER RESPIRATORY TRACT INFECTION.  IN ANY

 

             CASE, IT'S ONE OF THOSE NEGATIVE INFLUENCES ON NORMAL

 

             METABOLISM.

 

             Q.  AND WHAT IS THIS TERM IN THIS NEXT SECTION?

 

             A.  SPONDYLARTHRITIS MEANS THAT THERE IS SPINAL DISEASE.  IT

 

             MEANS THAT THERE IS ARTHRITIS OF THE SPINE.  AND THE TERM

 

             THAT I TAKE FROM THE AUTOPSY REPORT IS MILD SCOLIOSIS,

 

             MEANING THAT THERE IS AN S-SHAPED CURVE IN THE SPINE.  NOW BY

 

             MILD WE'RE TALKING ABOUT SOMETHING LESS THAN SEVERE, OKAY.

 

             SO THERE ISN'T SUCH A BEND IN THE SPINE A THE PERSON IS

 

             ABSOLUTELY BENT OVER SIDEWAYS.  BUT THERE IS AN S-SHAPED

 

             CURVE, WHICH MEANS THAT THE NORMAL STRAIGHT CONFIGURATION OF

 

             THE SPINE IS COMPROMISED BY A TILTING IN TWO DIFFERENT WAYS

 

             OF THE SPINE WHICH CAUSES COMPRESSION IRREGULARITY AND

 

             FRACTURES IN ELDERLY PEOPLE WITH OSTEOPOROSIS AND ALL ELDERLY

 

             PEOPLE HAVE OSTEOPOROSIS.

 

             Q.  HOW DOES THAT FINDING FACTOR INTO CAUSE OF DEATH?

 

             A.  IT'S -- IT'S AN AGGRAVATION MINIMALLY.  IT'S A SIGN OF

 

             GENERALIZED WEAKNESS ALSO AND SO I PUT IT LOWER ON THE LIST.

 

             BUT I CONSIDER IT AS ANOTHER MANIFESTATION LIKE DEPRESSION

 

             AND SO ON AS A MANIFESTATION OF FRAILNESS AND LESS VIGOROUS,

 

             PERHAPS EVEN PAINFUL EXISTENCE.

 

             Q.  AND THEN FINALLY RENAL FAILURE, WHAT DOES THAT MEAN?

 

             A.  THIS PERSON'S URINE OUTPUT DROPPED TO ZERO JUST BEFORE

 

             DEATH INDICATING THAT THERE WAS LACK OF HYDRATION, LACK OF

 

             ADEQUATE HYDRATION SIMPLY BECAUSE THERE WAS WITHDRAW OF

 

             TREATMENT AND THE PERSON'S KIDNEY'S HAD FAILED.  THIS IS A

 

             PART OF THE DYING PROCESS.  KIDNEYS WILL FAIL ACUTELY IN

 

             VIRTUALLY ALL DEATH.

 

             Q.  WE'VE TALKED ABOUT THE ISSUE OF DEHYDRATION AND LACK OF

 

             NUTRITION IN A COUPLE OF THE CASES.  YOU'VE ALSO TALKED ABOUT

 

             PATIENTS REFUSING NUTRITION.  WAS THERE ANYTHING IN THE

 

             MEDICAL RECORDS THAT SUGGESTED TO YOU A REASON WHY THIS

 

             WASN'T PROVIDED ARTIFICIALLY?

 

             A.  WELL, IT WASN'T PROVIDED ARTIFICIALLY SUCH AS BY

 

             INTUBATION, INTRAVENOUS HYDRATION, MEDICATION, THAT SORT OF

 

             THING, IT WASN'T PROVIDED BECAUSE IT WAS PROHIBITED IN MOST

 

             CASES.

 

                      MR. MAJOR:  OBJECTION, YOUR HONOR.  BEYOND THE SCOPE

 

             OF HIS EXPERTISE.

 

                      THE COURT:  OVERRULED.

 

                      MS. ISAACSON:  YOU CAN ANSWER THAT.

 

                      THE WITNESS:  THE RECORDS INDICATE THAT THERE WAS

 

             FAMILY CONFERENCING AND THERE WERE IN SOME CASES WRITTEN

 

             DOCUMENTS THAT SAID THAT AS A PART OF TERMINAL CARE THERE

 

             SHOULD BE NO SUPPORT OF LIFE BEYOND MINIMAL MAINTENANCE OR

 

             CARING FOR DISCOMFORTS.  AND SO I UNDERSTOOD THIS THAT IT WAS

 

             VERY LOGICAL, THAT EVEN THOUGH A PERSON WOULD GO INTO RENAL

 

             FAILURE, WITHOUT ADEQUATE HYDRATION, THE ADEQUATE HYDRATION

 

             WASN'T SUPPLIED SIMPLY BECAUSE IT WAS NOT PERMITTED BY THE

 

             PERSON'S OWN WISHES, SUPPORTED BY THEIR THE FAMILIES AND

 

             CAREGIVERS.

 

             Q.  (BY MS. ISAACSON)  DO YOU HAVE AN OPINION TO A DEGREE OF

 

             MEDICAL CERTAINTY AS TO THE CAUSE OF DEATH OF LYDIA SMITH?

 

             A.  YES.

 

             Q.  WHAT IS THAT OPINION?

 

             A.  LYDIA SMITH DIED WITH EVIDENCE OF CHRONIC ADVANCED

 

             DISEASE.  AGAIN, IN THIS CASE IT WAS ATHEROSCLEROSIS.  IT WAS

 

             MANIFESTED IN THE HEART BY HISTORY BECAUSE THE HEART WAS MUSH

 

             IN THE CASKET.  IT WAS PRESENT IN THE BRAIN WHICH LIKEWISE

 

             WAS MUSH IN THE CASKET BUT HISTORICALLY WAS WELL-DOCUMENTED

 

             THAT SHE HAD A SEVERE STROKE AND WAS COMPROMISED BY THAT AS

 

             PSYCHIATRICALLY AS WELL AS PHYSICALLY.  AND I INCLUDE

 

             VALVULAR HEART DISEASE AND DEMENTIA AND ALL THE

 

             MANIFESTATIONS OF DEMENTIA AS CONTRIBUTING TO THAT SEVERE

 

             CHRONIC DISEASE.

 

             Q.  DO YOU HAVE AN OPINION TO A DEGREE OF REASONABLE MEDICAL

 

             CERTAINTY AS TO THE MANNER OF DEATH OF LYDIA SMITH?

 

             A.  YES.

 

             Q.  AND WHAT IS THAT OPINION?

 

             A.  MY OPINION THAT THIS, AGAIN, IS A NATURAL DEATH.  THERE

 

             IS PLENTY TO SUPPORT HERE THAT THIS DEATH HAPPENED AS A

 

             CONSEQUENCE OF DISEASE AND THAT ALONE.

 

             Q.  LET'S TALK ABOUT ENNIS ALLDREDGE.  WE'LL GO TO STATE'S

 

             6-C PAGE 1.  I THINK THIS MAY ACTUALLY THE BE THE WRONG PAGE.

 

             THIS MAY NOT BE THE FINAL PAGE.

 

                      MS. ISAACSON:  WHY DON'T WE -- CAN YOU TELL,

 

             COUNSEL, IS THAT THERE'S SOME HAND WRITING ON THAT.

 

             THERE'S NOT THAT ON THE FINAL, IS THERE?

 

             Q.  (BY MS. ISAACSON)  LET'S GO ON TO -- I DON'T ACTUALLY

 

             HAVE HIS FINAL FINDINGS THERE SO WHY DON'T WE TALK ABOUT

 

             YOURS THAT I ASSUME WE'VE TALKED ABOUT BEFORE.

 

                 YOU REVIEWED THE PATHOLOGICAL DIAGNOSES IN EVERY CASE

 

             FROM THE OTHER PATHOLOGIST?

 

             A.  I DID AND I USED THEM HERE.  I INCLUDE THEM IN HERE.

 

             Q.  SO WE'LL GO TO THIS PAGE THEN AND THIS IS GOING TO BE

 

             DEFENDANT'S EXHIBIT 108, ENNIS ALLDREDGE.  LET'S START WITH

 

             AGAIN CAUSE OF DEATH, THE PRIMARY CAUSE -- AM I USING THE

 

             RIGHT TERM PRIMARY CAUSE?

 

             A.  SURE, THAT'S FINE.  SURE.  CAUSE OF DEATH, AGAIN ALL IN

 

             NUMBER ONE.  AND YOU CAN SEE THAT THERE ARE THREE PRIMARILY

 

             LISTED.  ONE IS ATHEROSCLEROSIS WHICH HAD BEEN PRESENT FOR

 

             YEARS AND WAS SEVERE, QUITE FRANKLY, ADVANCED ATHEROSCLEROSIS

 

             AND WE'LL TALK ABOUT THAT IN A MINUTE.  BUT ALONG WITH THAT,

 

             AND WE SAW THIS BEFORE, WAS HIGH BLOOD PRESSURE.  HIGH BLOOD

 

             PRESSURE ADDING ITS OWN INSULTS TO THE BODY BY WAY OF

 

             INCREASING HEART SIZE AND REDUCING KIDNEY FUNCTION.  AND

 

             THEN, OF COURSE, AGAIN, THERE WAS ACUTE BRONCHOPNEUMONIA.  I

 

             ADD THAT SIMPLY BECAUSE AS A TERMINAL FINDING, IT IS NOT

 

             UNCOMMON IN THE DEATHS OF PEOPLE WHO ARE CHRONICALLY ILL TO

 

             FALL VICTIM TO PNEUMONIA.

 

                 SO WE CAN GO BACK TO THE FIRST ONE, IF YOU WISH, AND LOOK

 

             AT THE ITEMS THAT ARE DEMONSTRATIVE OF ATHEROSCLEROSIS BEING

 

             THE PRIMARY CAUSE OF DEATH.  AND THEY ARE FIRST OF ALL THE

 

             HISTORY THAT HE HAD BYPASS GRAFTING.  HE HAD THREE VESSEL

 

             BYPASS GREATER THAN 10 YEARS BEFORE.  MOST CARDIOLOGISTS WILL

 

             TELL YOU 10 YEARS AND YOU'RE OUT.  IN OTHER WORDS, 10 YEARS

 

             FOR CORONARY ARTERY BYPASS IS A PRETTY GOOD LIFE EXPECTANCY.

 

             HE HAD HAD THAT GREATER THAN 10 YEARS BEFORE.

 

                 NOW WHAT DID WE FIND THERE OR WHAT DID THE PATHOLOGIST

 

             WHO DID THIS AUTOPSY FIND THERE THREE AND A HALF YEARS AFTER

 

             THIS BODY WAS IN THE GROUND?  SEVERE CORONARY ARTERY DISEASE.

 

             EVEN AT THAT POINT THERE WAS 90 PERCENT OCCLUSION OF THE

 

             RIGHT CORONARY ARTERY AND THE LEFT ANTERIOR DESCENDING ARTERY

 

             AND 30 PERCENT OCCLUSION OF THE CIRCUMFLEX.  THOSE ARE THE

 

             THREE MAJOR BRANCHES OF THE CORONARY CIRCUIT.  AND YOU SEE

 

             THAT THERE IS MAJOR OBSTRUCTION, WHICH PERHAPS AT THE TIME OF

 

             DEATH WAS EVEN VERY LIKELY GREATER THAN 90 PERCENT, BUT THREE

 

             AND A HALF YEARS AFTER BEING IN THE GROUND THREE AND A HALF

 

             YEARS, WE'RE STILL LEFT WITH 90 PERCENT OCCLUSION.

 

             Q.  I THINK WE COVERED THIS A LITTLE BIT BUT I GUESS THE IDEA

 

             THAT YOU'RE EXPRESSING IS THAT WHAT YOU WOULD SEE THREE AND A

 

             HALF YEARS LATER WOULD LIKELY BE DIMINISHED BY THE

 

             DECOMPOSITION, DO I HAVE THAT RIGHT?

 

             A.  YES.

 

             Q.  SO YOU WOULD EXPECT THAT AT THE TIME OF DEATH THIS

 

             CONDITION ACTUALLY WOULD HAVE BEEN -- YOU COULD SEE A MORE

 

             SERIOUS CONDITION?

 

             A.  IT WOULD HAVE BEEN MORE SEVERE, YES.

 

             Q.  WHAT IS THIS SECTION TALKING ABOUT?

 

             A.  THE POSTERIOR AND ANTEROSEPTAL LEFT VENTRICULAR SCARS, WE

 

             ARE TALKING HERE ABOUT SCARS, BIG AREAS OF FIBROSIS,

 

             DESTROYED HEART TISSUE THAT HAVE RESULTED DURING LIFE FROM

 

             HEART ATTACKS ON AT LEAST TWO DIFFERENT OCCASIONS.  SO THIS

 

             MAN HAD AT LEAST TWO SEVERE HEART ATTACKS, MOST LIKELY

 

             RESULTING, OF COURSE, FROM THE SEVERE CORONARY ARTERY

 

             DISEASE.

 

                 AND AS WE INDICATE BEFORE, HE HAS ALSO AS A RESULT OF

 

             ATHEROSCLEROSIS, HE HAS DIMINISHED KIDNEY FUNCTION AND THE

 

             ANATOMIC EVIDENCE FOR THAT IS IS THAT HE HAS ATHEROSCLEROSIS

 

             IN THE KIDNEY, WHICH IS AN ADVANCED CHANGE.

 

                 ANOTHER BIT OF EVIDENCE THERE IS HE HAD -- IT IS

 

             THOUGHT -- A PROBABLE STROKE IN THE HOSPITAL.  THIS WAS

 

             SHORTLY BEFORE HE DIED AND SHORTLY BEFORE THE DICTATES OF HIS

 

             LIVING WILL WERE PUT INTO FULL EFFECT.  AND AT THAT TIME IT

 

             WAS CONSIDERED AN OCCIPITAL STROKE.  I SUSPECT IT WAS

 

             PROBABLY GREATER THAN AN -- IN OTHER WORDS, IT WASN'T SIMPLY

 

             CONFINED --

 

                      MR. MAJOR:  OBJECTION, YOUR HONOR, HE'S SPECULATING.

 

                      THE COURT:  SUSTAINED.

 

                      THE WITNESS:  OKAY.

 

             Q.  (BY MS. ISAACSON)  WELL --

 

             A.  THERE WAS -- THE REASON I SAY THIS IS, THOUGH, IS THAT

 

             THERE ARE RESPIRATORY ABNORMALITIES THAT CAME ON AT THAT TIME

 

             THAT ARE NOT ASSOCIATED WITH OCCIPITAL STROKES.  IT PROBABLY

 

             WAS A LARGER THAN OCCIPITAL STROKE AT THE BACK AND BOTTOM OF

 

             THE BRAIN TO CAUSE AN INFLUENCE ON THE BRAIN STEM.

 

             Q.  HOW ABOUT THE HYPERTENSION, HOW DOES THAT FACTOR IN?

 

             A.  HIGH BLOOD PRESSURE WE HAVE SPOKEN OF BEFORE.  LET ME

 

             QUICKLY REVIEW THAT TO SAY AGAIN THAT HIGH BLOOD PRESSURE

 

             CAUSES AN ABNORMALITY OF THE PUMP.  IT CAUSES IT TO EXPAND

 

             AND GET BIGGER WHICH ONLY INCREASES ITS OWN LIABILITY FOR

 

             SUPPORT BY THE VASCULAR SYSTEM, ESPECIALLY WHERE THE VASCULAR

 

             SYSTEM IS SO POORLY ABLE TO GET NUTRITION.  IT'S GOT A 1.9

 

             CENTIMETER THICKNESS IN THE LEFT VENTRICLE, THE MAIN PUMPING

 

             CHAMBERS, AND THIS IS WHAT THE PATHOLOGIST TELL US WHO DID

 

             THE AUTOPSY, WHICH IS TWICE THE THICKNESS IT SHOULD BE.  AND

 

             OF COURSE, THERE IS ARTERIOLAR NEPHROSCLEROSIS, EVEN THE

 

             SMALL VESSELS OF THE KIDNEYS WHICH ARE CHARACTERISTICALLY NOT

 

             AFFECTED BY HIGH BLOOD PRESSURE ARE AFFECTED AS WELL.  SO

 

             THERE'S KIDNEY DISEASE ASSOCIATED WITH BOTH ATHEROSCLEROSIS

 

             AND WITH HYPERTENSION.

 

             Q.  SO THIS THAT YOU JUST REFERRED TO THIS 1.9 IS ACTUALLY

 

             SOMETHING YOU GOT FROM THE PATHOLOGIST?

 

             A.  OH, YES.  IN FACT, EVERYTHING HERE I GOT FROM THE

 

             PATHOLOGIST THAT I'VE TALKED ABOUT.

 

             Q.  OKAY.  AND YOU'VE MENTIONED --

 

             A.  EXCUSE ME.  ANOTHER THING I DIDN'T TELL YOU -- I SAID

 

             CARDIOMEGALY.  THIS IS A 570 GRAM HEART.  THE NORMAL HEART

 

             WEIGHT FOR THIS MAN WOULD HAVE BEEN ABOUT 350 GRAMS.  THIS IS

 

             A MASSIVELY ENLARGED PUMP.  AND ENLARGEMENT ONLY MEANS

 

             WEAKNESS, IT DOESN'T MEAN A GREAT BICEP.

 

             Q.  AND THEN THE BRONCHOPNEUMONIA, HOW DOES THAT FACTOR IN?

 

             A.  ACUTE BRONCHOPNEUMONIA IS A TERMINAL CHANGE.  IT'S A

 

             CHANGE THAT IS INFECTION, IT COMES AT THE END OF LIFE.  IT

 

             WAS PRESENT IN HALF THE SECTIONS THAT WERE PRESENT THERE AND

 

             IT'S PRESENT ALSO IN BOTH LUNGS SLIDES.  SO THERE'S -- WE

 

             CAN'T DISMISS IT AS INSIGNIFICANT, IT'S IN BOTH LUNGS.

 

             Q.  YOU'VE MENTIONED THESE SLIDES.  DO I UNDERSTAND CORRECTLY

 

             THAT FOUR SLIDES WERE TAKEN OF SECTIONS OF THIS BODY'S LUNGS?

 

             A.  FOUR SECTIONS WERE MADE AND THEY WERE SET UP IN TWO

 

             SLIDES.  AND THE USUAL STANDARD IS TO PREPARE THE SECTIONS

 

             FROM ONE LUNG IN ONE SLIDE AND THE OTHER LUNG IN THE OTHER

 

             SLIDE.

 

             Q.  NOW, WHAT ABOUT THE SECONDARY ITEMS THAT YOU'VE

 

             IDENTIFIED HERE, HOW DOES THE DIABETES FACTOR IN?

 

             A.  THIS MAN OF ALL OUR FIVE PATIENTS HAD THE MOST SEVERE

 

             DIABETES.  HE HAD THE LONGEST STANDING DIABETES, IT GOES FOR

 

             20 YEARS, IT'S INSULIN DEPENDENT.  IT'S THE WORST KIND SO TO

 

             SPEAK, AND IN FACT, IT IS AS I SAID BEFORE ALWAYS GOING TO

 

             CAUSE AN INCREASE IN ATHEROSCLEROSIS THERE IN ALL PATIENTS.

 

             IT IS JUST PART OF THE UNFORTUNATE RESULT OF THAT DISEASE IN

 

             PEOPLE WHO HAVE IT FOR A LONG PERIOD OF TIME.

 

                 IT WAS ALSO POORLY CONTROLLED.  AS YOU CAN SEE THERE, THE

 

             HEMOGLOBIN A1C WHICH IS A WAY OF TESTING ITS CHRONIC CONTROL,

 

             A TEST THAT'S AVAILABLE FOR THE LAST 15 YEARS OR SO WAS

 

             INCREASED INDICATING THAT THIS CONTROL OF DIABETES OR BLOOD

 

             SUGAR WAS NOT VERY GOOD.  THIS IS NOT TO POINT THE FINGER AT

 

             ANYBODY.  THE POINT IS THAT IT WAS PROBABLY NOT ABLE TO BE

 

             CONTROLLED VERY WELL WHEN HE WAS NOT UNDER AN ACUTE CARE

 

             REGIMEN.

 

             Q.  SO WHEN YOU'RE REFERRING TO THE POOR RECENT CONTROL, WAS

 

             THAT PRIOR TO HIS ADMISSION?

 

             A.  OH, YEAH.  YEAH.  EXACTLY.  YES.

 

             Q.  YOU ALSO DETECTED EMPHYSEMA?

 

             A.  YES.  HE DID HAVE EMPHYSEMA.  IT WAS A DISEASE THAT HE AS

 

             WELL AS A NUMBER OF OTHERS HAD.  IT'S NOT UNCOMMON IN OLDER

 

             AGE -- AND I PUT IT IN THERE NOT AS A PRIMARY CAUSE BUT

 

             SIMPLY AS A REASON WHY HIS BLOOD MAY NOT HAVE BEEN OXYGENATED

 

             AS EFFICIENTLY HAD HE NOT HAD IT.  SO IT MAKES

 

             ATHEROSCLEROSIS, AS BAD AS IT IS, EVEN WORSE.

 

             Q.  WE'VE TALKED ABOUT DEMENTIA REALLY WITH ALL OF THE

 

             PATIENTS AND I -- IS THERE ANYTHING DIFFERENT ABOUT HOW IT

 

             WOULD HAVE AFFECTED MR. ALLDREDGE WITH REGARD TO CAUSE OF

 

             DEATH?

 

             A.  WELL, HE -- HE HAD AS I INDICATE HERE AND I GET THIS OUT

 

             OF THE MEDICAL RECORDS THAT HE HAD A VERY RAPID ONSET.  IT

 

             WAS MULTI-INFARCT, SO IT WAS DUE TO ATHEROSCLEROSIS BY THE

 

             STUDIES AND CLINICAL OBSERVATIONS MADE.  IT DID NOT HAVE A

 

             MYSTERIOUS ORIGIN.  IT WAS REALLY A PART OF HIS CHRONIC

 

             DISEASE WHICH OBVIOUSLY WAS ALREADY SEVERE.  IT CAME ON,

 

             HOWEVER, FAIRLY RAPIDLY SO VERY LIKELY BECAUSE OF STROKES,

 

             REPEATED SMALL STROKES THAT WERE PRESENT.  AND IT WAS -- AND

 

             IT WAS PREVALENT IN THE YEAR PREVIOUS TO HIS LIFE SO THAT IT

 

             AFFECTED HIS ENTIRE WELL-BEING THE WAY DEMENTIA, AS WE'VE

 

             SAID ALREADY, AFFECTS PEOPLE BY ALTERING THEIR ATTITUDE,

 

             THEIR COOPERATIVENESS, THEIR SENSE OF SELF-PRESERVATION,

 

             THEIR INTEREST IN THEIR OWN CARE AND THEIR OWN WELL-BEING AS

 

             WELL.  AND I INDICATE HERE THAT IT PRECIPITATED THIS ERRATIC

 

             BEHAVIOR, RAPID ONSET AND DIMINISHING OF HIS WELL-BEING

 

             PRECIPITATED THE FOLLOWING OF HIS LIVING WILL, WHICH I FOUND

 

             TO BE AN ELOQUENT DOCUMENT AND VERY SPECIFIC --

 

                      MR. MAJOR:  OBJECTION, YOUR HONOR.

 

                      THE COURT:  SUSTAINED.  STRICKEN.  THAT'S A

 

             DIFFERENT AREA, DOCTOR.

 

                      THE WITNESS:  SORRY.

 

             Q.  (BY MS. ISAACSON)  DR. CASSIN, LET'S TALK ABOUT THE

 

             MYCOSIS FUNGOIDES, AM I SAYING THAT RIGHT?  WHAT IS THAT?

 

             A.  MYCOSIS FUNGOIDES IS A SKIN CONDITION THIS IS SIMILAR TO

 

             A LYMPHOMA OR A CANCER OF THE LYMPHOID SYSTEM, THE LYMPH

 

             NODES.  IT IS A SKIN DISEASE, HOWEVER, AND IT IS CHRONIC.

 

             AND IN THIS CASE HAS BEEN TREATED AS IT OFTEN IS WITH TOTAL

 

             BODY IRRADIATION.  I DON'T KNOW WHAT IT'S CONTINUING EFFECT

 

             ON HIM WAS BECAUSE THERE WAS NO SPECIFIC MENTION OF IT.  I

 

             CAN ONLY SAY FROM MY EXPERIENCE THAT PEOPLE WHO HAVE RECEIVED

 

             IRRADIATION AND ESPECIALLY OVER THAT EXTENSIVE AREA OF THEIR

 

             BODY ALSO RECEIVE A DIMINISHING OF THEIR IMMUNE SYSTEM MAKING

 

             THEM MORE SUSCEPTIBLE TO COMMON DISEASES, PARTICULARLY

 

             INFECTION.

 

             Q.  AND WE'VE TALKED I BELIEVE IN ANOTHER CASE ABOUT

 

             HYPOTHYROIDISM, WOULD THAT FACTOR ANY DIFFERENTLY IN THIS

 

             CASE?

 

             A.  IT WOULDN'T BE ANY DIFFERENT.  I PUT IT HERE BECAUSE I

 

             LEARNED FROM THE PATHOLOGIST REPORT THAT HE HAD A REMARKABLY

 

             SHRUNKEN AS HE SAID, A REMARKABLY SHRUNKEN THYROID.  SO HE

 

             NOTED THAT THE THYROID WAS ALMOST GONE AND THAT WAS PROBABLY

 

             BY -- RATHER THAN BY SURGERY IN THE PREVIOUS CASE, ONE OF THE

 

             PREVIOUS CASES, IT WAS DIMINISHED TO THE POINT OF BEING

 

             RELATIVELY NONFUNCTIONAL.  AND IT MUST HAVE BEEN THAT WAY

 

             BECAUSE HE WAS TREATED WITH THYROID HORMONE AS A SUPPLEMENT

 

             DURING LIFE.  THAT, OF COURSE, AS WE SAID WAS A CONDITION

 

             THAT WOULD DIMINISH HIS METABOLIC CONTROL.

 

             Q.  AND THEN THE FINAL ISSUE, THE NEUROGENIC BLADDER, WHAT

 

             DOES THAT MEAN?

 

             A.  HE HAD A POORLY FUNCTIONING BLADDER.  IT PROBABLY WAS

 

             RELATED AS WELL TO HIS REPEATED STROKES, HIS NEURO CONTROL BY

 

             HIS NERVOUS SYSTEM WHICH ULTIMATELY IS ASSOCIATED WITH HIS

 

             ADVANCED ATHEROSCLEROSIS, THIS ASSOCIATED WITH A URINARY

 

             TRACT INFECTION WHICH WAS DOCUMENTED ON THE 12TH OF JANUARY.

 

             Q.  DO YOU HAVE AN OPINION, DOCTOR, TO A DEGREE OF REASONABLE

 

             MEDICAL CERTAINTY AS TO THE CAUSE OF DEATH OF ENNIS

 

             ALLDREDGE?

 

             A.  YES.

 

             Q.  AND WHAT IS THAT OPINION?

 

             A.  IN THIS CASE, I BELIEVE THAT ENNIS ALLDREDGE DIED OF HIS

 

             DISEASE, PARTICULARLY HIS SEVERE ATHEROSCLEROSIS.  IT WAS

 

             ASSOCIATED WITH AS AN EQUALLY DELETERIOUS CONDITION.  HIS

 

             HIGH BLOOD PRESSURE AND THE RESULTS OF THAT ARE THE FINDINGS

 

             IN THE HEART AS WE SAW AS WELL AS THE KIDNEY.  AND THAT

 

             TERMINALLY HE HAD A SERIOUS DISEASE, AN ACUTE INFECTION,

 

             BRONCHOPNEUMONIA.

 

             Q.  DO YOU HAVE A OPINION TO A DEGREE OF REASONABLE MEDICAL

 

             CERTAINTY AS TO THE MANNER OF DEATH OF THIS PATIENT?

 

             A.  YES.  I BELIEVE THAT BECAUSE HE DIED OF HIS DISEASE HIS

 

             DEATH SHOULD BE CHARACTERIZED AS NATURAL.

 

             Q.  WITH REGARD TO -- GOING BACK TO ELLEN ANDERSON, YOU'VE

 

             TESTIFIED AS TO HER CAUSE OF DEATH BEING ATHEROSCLEROTIC

 

             CARDIOVASCULAR DISEASE.  DID THE ADMINISTRATION OF MORPHINE

 

             TO ELLEN ANDERSON CAUSE THAT CONDITION OR CAUSE THAT DISEASE?

 

             A.  CAUSE WHICH DISEASE AGAIN DID YOU SAY?

 

             Q.  THE ATHEROSCLEROTIC CARDIOVASCULAR DISEASE.

 

             A.  NO.  ABSOLUTELY NOT.

 

             Q.  DID THE ADMINISTRATION OF MORPHINE MAKE THAT CONDITION

 

             WORSE?

 

             A.  NO.

 

             Q.  DID MORPHINE CAUSE CONGESTIVE HEART FAILURE?

 

             A.  NO.  IT NEVER HAS THAT EFFECT.

 

             Q.  DID MORPHINE MAKE IT WORSE?

 

             A.  I DON'T SEE HOW IT COULD HAVE.

 

             Q.  WITH REGARD TO JUDITH LARSEN, AGAIN I THINK YOU'VE

 

             MENTIONED ON BOTH JUDITH LARSEN, LYDIA SMITH AND ENNIS

 

             ALLDREDGE THAT YOU DETECTED EVIDENCE OF ADVANCED

 

             STAGES OF ATHEROSCLEROTIC CARDIOVASCULAR DISEASE, AGAIN DOES

 

             MORPHINE CAUSE THAT DISEASE?

 

             A.  NO.

 

             Q.  DOES MORPHINE MAKE THAT DISEASE WORSE?

 

             A.  NO.

 

             Q.  ALL OF THE PATIENTS EXCEPT ELLEN ANDERSON WERE GIVEN

 

             PSYCHOTROPIC MEDICATIONS, WEREN'T THEY?

 

             A.  YES.

 

             Q.  DO YOU BELIEVE TO A REASONABLE DEGREE OF MEDICAL

 

             CERTAINTY THAT IN THESE CASES WHERE PSYCHOTROPIC MEDICATIONS

 

             WERE ADMINISTERED THAT THESE MEDICATIONS MADE OR CAUSED ANY

 

             OF THESE CHRONIC DISEASE PROCESSES THAT YOU'VE IDENTIFIED?

 

             A.  NO.  THEY DON'T CAUSE ANY OF THOSE DISEASE PROCESSES.  I

 

             AM CERTAIN OF THAT.

 

             Q.  YOU INDICATED WHEN WE TALKED ABOUT JUDITH LARSEN THAT YOU

 

             WERE NOT AT ALL SURPRISED TO LEARN THAT SHE HAD MORPHINE IN

 

             HER SYSTEM.  WHY DO YOU SAY THAT?

 

             A.  BECAUSE SHE WAS GIVEN MORPHINE, ACCORDING TO THE MEDICAL

 

             RECORDS, WITHIN HOURS OF HER DEATH.

 

             Q.  AND DOES THE PRESENCE OF MORPHINE IN THE SYSTEM OF A BODY

 

             THAT YOU EXAMINE MEAN THAT MORPHINE CAUSED THAT DEATH?

 

             A.  NO.  ABSOLUTELY NOT.  AS I SAID BEFORE, THE PRESENCE OF

 

             MORPHINE IN A BODY OR ANYTHING, ANY MEDICATION FOR THAT

 

             MATTER, DOESN'T MEAN THAT THE PERSON HAS DIED FROM IT.  IT

 

             HAS TO BE PLACED INTO CONTEXT, CLINICAL CONTEXT.

 

             Q.  AS A MEDICAL EXAMINER, ARE YOU FAMILIAR WITH SITUATIONS

 

             WHERE SOMEONE MIGHT DIE IN AN UN -- STRIKE THAT.

 

                 AS A MEDICAL EXAMINER, ARE YOU AWARE OF SITUATIONS WHERE

 

             INDIVIDUALS DIE SUDDENLY FROM CHRONIC DISEASES?

 

             A.  IT HAPPENS ROUTINELY.  SOMEBODY MAY CALL IN THE MORNING

 

             AND SAY MOTHER OR DAD DIDN'T WAKE UP, THEY'RE DEAD IN BED.

 

             THEY ARE SURPRISED PERHAPS EVEN BECAUSE THE NIGHT BEFORE THEY

 

             WATCHED TELEVISION WITH THEM OR HAD DINNER WITH THEM OR

 

             ENJOYED A JOKE OR A MOVIE OR WHATEVER IT WAS OR RODE AROUND

 

             IN A CAR WITH THEM.  YES, THEY DO DIE SUDDENLY BECAUSE IT'S A

 

             FREQUENT MANIFESTATION IN ELDERLY PEOPLE OF THE SEVERITY OF

 

             THEIR DISEASE.  FORTUNATELY THEY DON'T DIE BY A LONG

 

             PROTRACTED COURSE IN CASES BUT THEY ALSO DIE FREQUENTLY

 

             SUDDENLY.

 

                      MS. ISAACSON:  THAT'S ALL I HAVE.

 

                      THE COURT:  CROSS-EXAMINE, MR. MAJOR.

 

                      MR. MAJOR:  THANK YOU, YOUR HONOR.

 

                                  CROSS-EXAMINATION

 

            BY MR. MAJOR:

 

             Q.  GOOD AFTERNOON, DOCTOR.

 

             A.  AFTERNOON.

 

             Q.  I'M STEVE MAJOR.  I'M WITH THE PROSECUTION.  I HAVE A FEW

 

             QUESTIONS TO ASK YOU.

 

                 NOW, AS I UNDERSTAND, YOU HAVE BEEN HIRED BY THE DEFENSE

 

             TO APPEAR TODAY AND TESTIFY; IS THAT CORRECT?

 

             A.  YES.  THAT'S A WAY OF SAYING IT.

 

             Q.  WHEN WERE YOU FIRST CONTACTED BY THE DEFENSE?

 

             A.  I CAN'T REMEMBER EXACTLY BUT IT WAS APPROXIMATELY IN THE

 

             SUMMER, EARLY SUMMER TO MID SUMMER.

 

             Q.  AND YOU WERE ASKED TO PREPARE YOUR FINDINGS THAT YOU

 

             BROUGHT IN TODAY?

 

             A.  EVENTUALLY SO, YES.

 

             Q.  AND YOU CHARGED THE DEFENSE A FEE AS AN EXPERT FEE; IS

 

             THAT CORRECT?

 

             A.  I DO.  I HAVE A REGULAR FEE THAT I CHARGE FOR --

 

             Q.  AND HOW MUCH IS THAT?

 

             A.  I CHARGE $350 AN HOUR.

 

             Q.  DOES THAT INCLUDE TESTIFYING AND EVERYTHING LIKE THAT?

 

             A.  IT INCLUDES EVERYTHING.

 

             Q.  IN ADDITION, THERE'S I ASSUME YOU GET YOUR EXPENSES FOR

 

             TRAVEL AND THAT TYPE OF THING?

 

             A.  YES.

 

             Q.  IS THAT TRUE?

 

             A.  WHATEVER I PAY FOR THAT I DO, SURE.

 

             Q.  NOW, IN MAKING THESE EXAMINATIONS THAT YOU MADE,

 

             OBVIOUSLY YOU DID NOT ACTUALLY HANDLE THE BODY; IS THAT

 

             CORRECT?

 

             A.  THAT'S TRUE.

 

             Q.  AND YOU WERE JUST PREPARING YOUR OPINION, RELIED ON THE

 

             SLIDES AND PHOTOS THAT WERE PROVIDED YOU BY THE DEFENDANT --

 

             OR THE DEFENSE I SHOULD SAY?

 

             A.  AN AUTOPSY REPORTS, YES.

 

             Q.  AND DURING THIS PERIOD OF TIME THAT YOU WERE PREPARING

 

             THIS, DID YOU HAVE CONVERSATIONS NOT WITH THE DEFENSE ITSELF

 

             BUT WITH THE DEFENDANT HIMSELF?  DID YOU HAVE A CONVERSATIONS

 

             WITH DR. WEITZEL?

 

             A.  NO, SIR.

 

             Q.  AND YOU ALSO INDICATED THAT AS PART OF YOUR FORMULATION

 

             OF YOUR OPINION THAT YOU RELIED ON MEDICAL RECORDS THAT WERE

 

             PROVIDED YOU; IS THAT RIGHT?

 

             A.  YES, SIR.

 

             Q.  LET ME SHOW YOU WHAT'S BEEN MARKED FOR IDENTIFICATION,

 

             FOR EXAMPLE, I'LL GRAB ELLEN ANDERSON, THIS IS EXHIBIT 2-C.

 

             HAVE YOU LOOK AT THAT.  IS THAT BASICALLY THE TYPE DOCUMENT

 

             THAT YOU HAD EXAMINED OR SIMILAR TO THE DOCUMENT YOU

 

             EXAMINED?

 

             A.  YES, SIR.  THAT LOOKS LIKE IT.

 

             Q.  OKAY.  WERE YOU GIVEN ANY OTHER DOCUMENT?  NOW, THOSE ARE

 

             THE DOCUMENTS FROM -- THE MEDICAL DOCUMENTS FROM THE

 

             HOSPITAL.  DID YOU EXAMINE ANY OTHER DOCUMENTS?

 

             A.  NO.  I GOT HOSPITAL RECORDS.  THAT'S WHAT I MEANT BY

 

             DOCUMENTS, HOSPITAL RECORDS.

 

             Q.  YOU DIDN'T GET ANYTHING FROM THE NURSING HOMES?

 

             A.  I DON'T RECALL THAT I DID.  I THINK ALL I HAVE IS THIS

 

             MATERIAL.

 

             Q.  JUST WHAT WAS PROVIDED TO YOU --

 

             A.  NOW, THERE'S REFERENCE IN THESE RECORDS TO NURSING HOME

 

             DIAGNOSES AND CARE.

 

             Q.  YEAH.

 

             A.  SO THAT'S HOW I BELIEVE I LEARNED ABOUT THOSE THINGS.

 

             Q.  OKAY.  AND BUT YOU DON'T RECALL RECEIVING ANY OTHER

 

             DOCUMENTS OTHER THAN FROM ANY OF THE NURSING HOMES?

 

             A.  NO, SIR, I DON'T RIGHT NOW.  I DON'T THINK SO.  I THINK

 

             ALL I HAVE ARE THE HOSPITAL RECORDS.

 

             Q.  OKAY.  WELL, DOCTOR, NOW I WANT TO ASK YOU SOMETHING, YOU

 

             HAVE FAMILIARITY YOU'VE SAID WITH MORPHINE; IS THAT CORRECT?

 

             A.  I DO.

 

             Q.  AND MORPHINE IS WHAT YOU WOULD CONSIDER TO BE A POWERFUL

 

             DRUG?

 

             A.  YES.

 

             Q.  A POWER PAINKILLER?

 

             A.  YES.

 

             Q.  AND MORPHINE CAN HAVE SOME SIGNIFICANT SIDE EFFECTS;

 

             ISN'T THAT CORRECT?

 

             A.  YES.

 

             Q.  ONE OF THOSE SIDE EFFECTS THAT MORPHINE HAS IS THAT IT

 

             CAN LOWER RESPIRATIONS?

 

             A.  IT CAN.

 

             Q.  IT CAN LOWER BLOOD PRESSURE?

 

             A.  YES.

 

             Q.  AND WHEN A PERSON ACTUALLY DIES FROM AN OVERDOSE OF

 

             MORPHINE -- I'M ASSUMING YOU'VE HAD PEOPLE DIE OF OVERDOSES

 

             OF MORPHINE?

 

             A.  OH, YES.

 

             Q.  AND I'M ASSUMING THAT THE WAY PEOPLE DIE OR WHAT ACTUALLY

 

             CAUSES THE DEATH ON AN OVERDOSE IS THAT THE BODY SHUTS DOWN;

 

             IS THAT CORRECT?

 

             A.  IT DOES.

 

             Q.  IT DOESN'T GET ENOUGH OXYGEN, IT DOESN'T GET ENOUGH BLOOD

 

             GOING INTO ITS ORGANS AND IT BASICALLY SHUTS DOWN?

 

             A.  YES.

 

             Q.  PRETTY MUCH?

 

             A.  YES.

 

             Q.  AND SO YOU WOULD AGREE THAT MORPHINE IN AND OF ITSELF

 

             DOES CAUSE SOME PROBLEMS WITH OXYGENATION OF THE BODY; IS

 

             THAT CORRECT?

 

             A.  IT CAN, YES.

 

             Q.  IT CAN.  AND ESPECIALLY HIGH DOSES OF MORPHINE; IS THAT

 

             CORRECT?

 

             A.  YES.

 

             Q.  NOW, LACK OF OXYGEN THAT GOES INTO THE BODY CAN CAUSE

 

             PROBLEMS, SPECIFICALLY WITH THE BRAIN, THE KIDNEYS, THE

 

             LUNGS, THOSE TYPE OF THINGS; IS THAT CORRECT?

 

             A.  OH, YES.

 

             Q.  AND THEY CAN ALSO CAUSE THE BODY TO START TO SHUT DOWN;

 

             IS THAT CORRECT?

 

             A.  IT COULD, YES.

 

             Q.  AND ONE OF THE THINGS THAT IT CAN DO IS IT CAN PROHIBIT

 

             THE ORGANS FROM DOING THEIR NORMAL FUNCTIONS AS EXCRETING

 

             WATER FROM THE BODY OR THOSE TYPE OF THINGS?

 

             A.  WELL, I THINK THAT'S WHAT I MEAN -- WHAT YOU MEAN BY

 

             SHUTTING DOWN.

 

             Q.  SHUTTING DOWN, YEAH.  THE THING IT CAN ALSO DO IS IT CAN

 

             AFFECT THE PERSON'S ABILITY TO COUGH OR CLEAR THEIR THROAT,

 

             CORRECT?

 

             A.  THAT MIGHT HAPPEN.

 

             Q.  SO A PERSON WHO HAS SOME SEDATION WITH MORPHINE, THERE IS

 

             A RISK THAT CAN THEY COULD ASPIRATE WATER OR WHATEVER INTO

 

             THEIR LUNGS; IS THAT CORRECT?

 

             A.  IT'S POSSIBLE.

 

             Q.  AND IF THE ORGANS ARE SHUTTING DOWN AND THEY'RE HAVING

 

             PROBLEMS WITH REMOVING THE WATER FROM THE BODY, THEIR LUNGS

 

             COULD FILL UP WITH LIQUID?

 

             A.  IT'S POSSIBLE, YES.

 

             Q.  AND THAT COULD HAVE A SAME SIDE EFFECT AS HAVING

 

             BASICALLY PNEUMONIA; IS THAT CORRECT?

 

             A.  SAY --

 

             Q.  HAVING A PNEUMONIA, THAT CAN CAUSE A PNEUMONIA?

 

             A.  IT'S SIMILAR.

 

             Q.  YOU DO -- ALSO IN THIS CASE THERE WAS EVIDENCE THAT THESE

 

             PATIENTS HAD RECEIVED SOME PSYCHOTROPIC DRUGS.  ARE YOU

 

             FAMILIAR WITH THOSE DRUGS?

 

             A.  WELL, I'M GENERALLY FAMILIAR WITH THEM, SOME MORE THAN

 

             OTHERS.

 

             Q.  ARE YOU FAMILIAR WITH RISPERDAL AND THOSE TYPE OF --

 

             ATIVAN?

 

             A.  I AM IN ONLY A GENERAL WAY.  I DON'T OBVIOUSLY USE THEM

 

             IN ANY PATIENTS THAT I CARE FOR, BUT I'M AWARE OF THEIR USE.

 

             Q.  AWARE OF THEIR USE.  WERE YOU ALSO AWARE THAT THOSE TYPE

 

             OF DRUGS ARE I GUESS A BREATHING SUPPRESSANT WHERE THEY

 

             SUPPRESS THE BREATHING?

 

             A.  I'M NOT AWARE OF THAT, NO.

 

             Q.  IF WE HAD TESTIMONY TO THE FACT THAT THEY WERE A

 

             BREATHING SUPPRESSANT, THAT WOULD NOT BE CONTRARY TO ANYTHING

 

             THAT YOU UNDERSTAND OR LEARNED?

 

             A.  I JUST DON'T KNOW THAT.

 

             Q.  OKAY.  NOW, I WANT TO TURN JUST BRIEFLY TO ELLEN ANDERSON

 

             AND ASK YOU A COUPLE OF QUESTIONS CONCERNING HER.  I'M NOT

 

             GOING TO GO THROUGH IN ANY DETAIL SPECIFICALLY WHAT HER --

 

             EACH ONE OF THE CATEGORIES YOU LISTED AS CAUSE OF DEATH.

 

                 BUT BASICALLY ON THE LISTING THAT YOU HAD LISTED THAT YOU

 

             BELIEVE OR THAT YOU FOUND THAT CAUSED ELLEN ANDERSON'S DEATH

 

             IS SOMETHING THAT AFFECTS HER ABILITY TO ABSORB OXYGEN IN THE

 

             BODY; IS THAT CORRECT?

 

             A.  IN ONE WAY OR ANOTHER THAT IS OFTEN THE CASE, YES.

 

             Q.  AND ALL OF THESE SYMPTOMS THAT YOU RECORDED HERE EXISTED

 

             PRIOR TO HER COMING TO THE HOSPITAL?

 

             A.  YES.

 

             Q.  AND THEY'D EXISTED FOR A NUMBER OF YEARS PRIOR TO HER

 

             COMING TO THE HOSPITAL?

 

             A.  WELL, I DID MENTION IN ELLEN ANDERSON AS I RECALL ACUTE

 

             PNEUMONIA.  SHE HAD AN PNEUMONIA THAT WAS VERY FRESH.  THAT

 

             MAY WELL HAVE HAPPENED PRIOR TO HER COMING TO THE HOSPITAL.

 

             SHE WAS ONLY THERE A SHORT TIME, A DAY OR SO.

 

             Q.  YEAH.

 

             A.  THAT MAY HAVE BEEN PRESENT AT THE TIME OF ADMISSION, SO I

 

             WOULDN'T SAY YEARS.

 

             Q.  IT COULD HAVE BEEN THERE BEFORE.  NOW, WERE YOU AWARE

 

             THAT THE TIME OF HER ADMISSIONS THAT THE NURSES AND NURSES

 

             STAFF DID NOT FIND ANY SIGNS OF PNEUMONIA?

 

             A.  IT WAS NOT LISTED AS A FINDING, THAT'S CORRECT.

 

             Q.  CAN WE ASSUME THEN IF IT WAS NOT FOUND AT THE TIME OF HER

 

             ADMISSION IT MAY HAVE DEVELOPED LATER?

 

             A.  NO.  PNEUMONIA LIKE A LOT DISEASES STARTS INSIDIOUSLY AND

 

             DOESN'T NECESSARILY MANIFEST ITSELF.

 

             Q.  NOW, DOCTOR, ONE OF THE QUESTIONS I WAS GOING TO ASK TO

 

             YOU IS THESE -- AS I SAID, THESE SYMPTOMS EXISTED WITH ELLEN

 

             ANDERSON FOR A PERIOD OF TIME PRIOR TO HER COMING TO THE

 

             HOSPITAL, INCLUDING HIP SURGERY; IS THAT CORRECT?

 

             A.  YES.

 

             Q.  AND SHE HAD BASICALLY SURVIVED THAT PERIOD OF TIME, FROM

 

             THE TIME SHE HAD THESE THINGS, UNTIL SHE HIT HOSPITAL; IS

 

             THAT CORRECT?

 

             A.  CERTAINLY.

 

             Q.  AND THE FACT OF THE MATTER IS YOUR -- MR. CASSIN, THE

 

             ONLY DIFFERENCE BETWEEN THE TREATMENT SHE RECEIVED PRIOR TO

 

             COMING TO THE HOSPITAL AND THE TREATMENT SHE RECEIVED AT THE

 

             HOSPITAL WAS THAT SHE WAS ADMINISTERED MORPHINE; ISN'T THAT

 

             CORRECT?

 

             A.  I CAN'T SAY FOR SURE WITHOUT REVIEW OF THE RECORDS AGAIN.

 

             SHE -- SHE WAS TREATED WHEN SHE CAME TO THE HOSPITAL, YES,

 

             BUT --

 

             Q.  AND IF THE RECORDS INDICATED THAT THE ONLY MEDICATION

 

             SHE'D RECEIVED AT THE HOSPITAL WAS MORPHINE, WOULD YOU AGREE

 

             WITH THAT?

 

             A.  WELL, SURE.

 

             Q.  AND THAT WAS THE ONLY INTERVENING FACTOR THAT HAPPENED

 

             BETWEEN TIME THAT SHE HAD ALL OF THESE DISEASES AND THE TIME

 

             SHE HIT THE HOSPITAL; IS THAT CORRECT?

 

             A.  IF THAT'S WHAT THE RECORDS SHOWS, THEN I WOULD AGREE WITH

 

             YOU.

 

             Q.  AND MORPHINE IN AND OF ITSELF, AS WE'VE TALKED ABOUT, CAN

 

             SUPPRESS THE OXYGEN ABSORPTION INTO A PATIENT; IS THAT

 

             CORRECT?

 

             A.  IT CAN.

 

             Q.  AND A PATIENT WHO IS ALREADY SIGNIFICANTLY SUFFERING FROM

 

             CONDITIONS THAT PREVENT OXYGEN ABSORPTION, MORPHINE IS GOING

 

             TO ENHANCE THAT, ISN'T IT?

 

             A.  IT MAY.

 

             Q.  AND, IN FACT, GIVING AS YOU RECALL SHE RECEIVED 12

 

             MILLIGRAMS OF MORPHINE DURING THIS SHORT PERIOD OF TIME OF

 

             HER STAY, THAT VERY WELL COULD SIGNIFICANTLY ENHANCED HER

 

             ABILITY OR LACK OF ABILITY TO ABSORB OXYGEN; ISN'T THAT

 

             CORRECT?

 

             A.  I CAN'T SAY THAT FOR SURE.  I'M NOT REALLY SURE WHAT HER

 

             OWN REACTION TO THAT WAS --

 

             Q.  SURE.  BUT IT'S A POSSIBILITY --

 

             A.  -- NECESSARILY --

 

                      THE COURT:  WAIT A MINUTE, MR. MAJOR.  LET HIM

 

             FINISH.

 

                      MR. MAJOR:  I'M SORRY, YOUR HONOR.

 

             Q.  (BY MR. MAJOR)  THAT IS A POSSIBLY, IS IT NOT?

 

             A.  THERE ARE A LOT OF POSSIBILITIES.

 

             Q.  RIGHT.  AND IT'S SOMETHING THAT YOU CAN'T ELIMINATE TO

 

             ANY TYPE OF SCIENTIFIC CERTAINTY?

 

             A.  CORRECT.

 

             Q.  AND THEREFORE IF MORPHINE COULD HAVE IN FACT CAUSED THIS

 

             DEATH, THAT'S ANOTHER FACTOR IN DETERMINING WHAT THE CAUSE OF

 

             DEATH WAS, WASN'T IT?

 

             A.  I DON'T THINK MORPHINE CAUSED THIS DEATH.  I THINK THIS

 

             MORPHINE TO MAKE THIS --

 

             Q.  WELL --

 

                      THE COURT:  LET HIM FINISH, MR. MAJOR.

 

                      MR. MAJOR:  IT'S NOT RESPONSIVE TO MY QUESTION.

 

                      THE COURT:  LET HIM FINISH MR. MAJOR.

 

                      THE PLAINTIFF:  I WILL.

 

                      THE WITNESS:  I THINK MORPHINE WAS GIVEN TO ASSIST

 

             THIS PERSON DURING A DYING PROCESS AND TO MAKE HER MORE

 

             COMFORTABLE.  WHAT ALL OF ITS EFFECTS WERE THERE, BUT I DON'T

 

             BELIEVE NECESSARILY THAT IT SUPPRESSED HER RESPIRATION.

 

             Q.  (BY MR. MAJOR)  YOU DON'T BELIEVE IT DID, BUT IT COULD

 

             HAVE?

 

             A.  I SAID IT'S POSSIBLE, YES.

 

             Q.  AND DOESN'T THAT MAKE THE CAUSE OF DEATH UNDETERMINED,

 

             BECAUSE YOU DON'T KNOW WHETHER IT DID OR DIDN'T?

 

             A.  WELL, INDEED.  I THINK THEORETICALLY ANY DEATH CAN BE

 

             CALLED UNDETERMINABLE IF ONE WANTS TO FALL BACK ONTO THE

 

             DICTATES OR STANDARDS OF ABSOLUTE CERTAINTY, BUT WE'RE NOT

 

             ASKED TO BE ABSOLUTELY CERTAIN IN AUTHORING DEATH

 

             CERTIFICATES.

 

             Q.  SO IN YOUR POSITION THEN, THE UNDETERMINEDNESS OF WHAT THE

 

             MEDICAL EXAMINER FOUND IN ELLEN ANDERSON ISN'T NECESSARILY

 

             WRONG?

 

             A.  NO.  IT IS -- IT IS HIS OPINION.

 

             Q.  OKAY.

 

             A.  AS I INDICATED, I DON'T KNOW WHY HE SAID IT WAS

 

             UNDETERMINED.

 

             Q.  NOW, I WOULD LIKE TO TURN JUST BRIEFLY TO MS. LARSEN.

 

             AGAIN, WITH MS. LARSEN ALL OF THE CONDITIONS THAT YOU LISTED

 

             THAT YOU FEEL THAT SHE DIED FROM ARE CONDITIONS THAT AFFECT

 

             HER BREATHING?

 

             A.  ULTIMATELY OR ONE WAY OR ANOTHER, YES.

 

             Q.  AND THESE CONDITIONS BASICALLY AFFECT HER ABILITY TO

 

             ABSORB OXYGEN; IS THAT CORRECT?

 

             A.  WELL, PARTICULARLY THE ATHEROSCLEROSIS, YES.

 

             Q.  THAT WOULD.  OKAY.  AND THE QUESTION I HAD:  YOU ALSO

 

             INDICATED WITH MS. LARSEN THAT THERE WAS SOME PERSISTENT

 

             NAUSEA AND VOMITING THAT OCCURRED; IS THAT CORRECT?

 

             A.  YES.

 

             Q.  AND THIS ALSO CAUSED HER PROBLEMS CONTRIBUTED TO HER

 

             DEATH?

 

             A.  IT DID.  I BELIEVE IT PROBABLY MADE HER ELECTROLYTES

 

             ABNORMAL AND HER WATER BALANCE INSUFFICIENT SO I SUSPECT SHE

 

             WAS SOMEWHAT DEHYDRATED BECAUSE OF THAT.  IT ALSO COULD HAVE

 

             PRECIPITATED HER GASTROINTESTINAL BLEEDING.

 

             Q.  BLEEDING.  AND SHE HAD THIS CONDITION OF BLEEDING FOR

 

             APPROXIMATELY 14 HOURS; IS THAT CORRECT?

 

             A.  I DON'T REMEMBER EXACTLY BUT IT WAS THERE FOR A WHILE.

 

             Q.  AND DURING THAT PERIOD OF TIME, THE DEFENDANT DID

 

             ABSOLUTELY NOTHING TO ATTEMPT TO ALLEVIATE THAT VOMITING?

 

             A.  I DON'T KNOW THAT.  I WOULD HAVE TO REFER --

 

             Q.  YOU DO NOT SEE ANYTHING IN THE RECORD THAT INDICATED THAT

 

             HE DID?

 

             A.  I DON'T REMEMBER THAT DETAIL.

 

             Q.  AS A MATTER OF FACT, IN THESE CONDITIONS THAT WE HAD WITH

 

             ELLEN ANDERSON, DID YOU SEE ANYTHING IN THE RECORDS WHICH

 

             WOULD INDICATE THAT THE DEFENDANT DIAGNOSED THOSE CONDITIONS?

 

             A.  AGAIN, I WOULD HAVE TO REFER TO THE RECORD TO BE SURE.

 

             Q.  SO YOU DON'T RECALL IF HE DID OR DIDN'T?

 

             A.  I DON'T.

 

             Q.  OKAY.  THAT WAS SOMETHING THAT YOU WOULD ASSUME THAT A

 

             PHYSICIAN WOULD BE ABLE TO DIAGNOSIS AND DETERMINE WHAT THESE

 

             CONDITIONS THEY HAD?

 

             A.  MIGHT, YES.  AT LEAST UNDERSTAND BY WHAT'S HAPPENING TO A

 

             PERSON WHO HAS THOSE CONDITIONS.

 

             Q.  NOW, DOCTOR, I WANT TO SHOW YOU WHAT'S BEEN MARKED FOR

 

             IDENTIFICATION AS PLAINTIFF'S EXHIBIT 23.  DOCTOR, I'M GOING

 

             TO REPRESENT THIS TO YOU THAT THIS HAS BEEN ACCEPTED AS AN

 

             EXHIBIT I BELIEVE AND THIS REFLECTS TALKED TO --

 

                      THE COURT:  TURN THE LIGHTS OFF, MR. MAJOR.

 

                      MR. MAJOR:  THANK YOU, JUDGE.

 

             Q.  (BY MR. MAJOR)  AND THIS REFLECTS IN THE LAST TWO OR

 

             THREE DAYS OF MRS. LARSEN'S LIFE THE AMOUNTS OF MORPHINE THAT

 

             WERE ADMINISTERED TO HER.  AND WOULD YOU AGREE BASED ON YOUR

 

             REVIEW OF RECORDS ON THE 1ST OF JULY (SIC) SHE RECEIVED ONE,

 

             TWO, THREE, FOUR, FIVE APPROXIMATELY SIX SHOTS OF MORPHINE?

 

                      THE COURT:  IS THAT JULY 1ST?

 

                      MR. MAJOR:  THIS WOULD BE JANUARY 1ST, 1996.

 

                      THE WITNESS:  SORRY.

 

             Q.  (BY MR. MAJOR)  THAT WAS BASED ON YOUR RECOLLECTION

 

             THAT'S PRETTY MUCH --

 

             A.  I WOULD ACCEPT THAT, YEAH.

 

             Q.  AND CONTINUING OVER ON THE NEXT PAGE ALSO ON THE 1ST OF

 

             JULY SHE HAD RECEIVED AN ADDITIONAL --

 

                      THE COURT:  JANUARY?

 

                      MR. MAJOR:  SORRY, YOUR HONOR.  I APOLOGIZE.

 

             Q.  (BY MR. MAJOR)  ON JANUARY OF -- JANUARY 1ST, SHE

 

             RECEIVED AN ADDITIONAL FOUR SHOTS; IS THAT CORRECT?

 

             A.  I'LL ACCEPT THAT IF IT'S IN EVIDENCE.

 

             Q.  SO DURING THIS PERIOD OF TIME SHE RECEIVED APPROXIMATELY

 

             10 SHOTS AND RECEIVED APPROXIMATELY 50 MILLIGRAMS OF

 

             MORPHINE, YOU WOULD ACCEPT THAT?

 

             A.  MAKES SENSE.

 

             Q.  NOW, TURNING TO JANUARY 2ND, 1996, YOU CAN ALSO INDICATE

 

             HERE THAT SHE RECEIVED A SERIES OF SHOTS AND I'D REPRESENT TO

 

             YOU THAT THESE SHOTS WERE ORDERED APPROXIMATELY EVERY THREE

 

             HOURS.  DOES THAT SEEM TO BE CORRECT?

 

             A.  OKAY.

 

             Q.  AGAIN SHE RECEIVES ONE, TWO, THREE, FOUR, FIVE, SIX,

 

             SEVEN, EIGHT, NINE SHOTS OF MORPHINE APPROXIMATELY 45

 

             MILLIGRAMS OF MORPHINE DURING THAT PERIOD OF TIME, CORRECT?

 

             A.  YES.

 

             Q.  YOU ALSO RECALL DURING THIS PERIOD OF TIME READING IN THE

 

             MEDICAL RECORDS ABOUT A NURSE WHO WITH HELD A CERTAIN AMOUNT

 

             OF MORPHINE?

 

             A.  I DID READ SOMETHING ABOUT THAT.

 

             Q.  ON THE 3RD OF JULY BONNIE HARDY TESTIFIED AND I THINK

 

             IT'S REFLECTED IN THE MEDICAL RECORDS THAT DURING THE EVENING

 

             HOURS SHE OBSERVED MS. LARSEN AND SHE HAD VERY LOW

 

             RESPIRATIONS, MOTTLING OF THE SKIN, FINGERTIPS WERE BLUE, AT

 

             THAT TIME, DO YOU RECALL THAT?

 

             A.  I DO VAGUELY, YES.

 

             Q.  AND YOU RECALL THAT, IN FACT -- WELL, BASED ON THAT,

 

             WOULD IT INDICATE TO YOU THAT THIS PATIENT WAS PRETTY CLOSE

 

             TO DEATH?

 

             A.  YES.

 

             Q.  AND WOULD --

 

             A.  THIS WAS PART OF THE DYING PROCESS.

 

             Q.  DYING PROCESS.

 

             A.  YES.

 

             Q.  IT ALSO INDICATES AT THAT TIME THAT MS. HARDEY WITHHELD

 

             APPROXIMATELY THREE SHOTS DURING THE EVENING, IS THAT

 

             CORRECT, DO YOU RECALL THAT?

 

             A.  I DON'T REMEMBER THE EXACT NUMBER BUT YES THERE WAS

 

             WITHHOLDING OF MORPHINE.

 

             Q.  AND THEN HER NOTE IS THAT AFTER WITHHOLDING THE SHOT THE

 

             PATIENT REMARKABLY IMPROVED?

 

             A.  I DON'T RECALL THAT.  I THINK THERE MIGHT HAVE BEEN A

 

             LITTLE CHANGE IN STATUS, BUT I'M NOT SURE IT WAS AN

 

             IMPROVEMENT.

 

             Q.  BUT IF THAT'S WHAT SHE HAD INDICATED, THEN YOU WOULD

 

             AGREE WITH WHATEVER IS IN THE MEDICAL RECORDS?

 

             A.  WELL, I WOULD ACCEPT IT AS MEDICAL RECORDS.

 

             Q.  SO IF A PATIENT IS RECEIVING A PARTICULAR DRUG, IN THIS

 

             CASE MORPHINE, STARTS TO HAVE -- BECOME CLOSE TO DEATH AND

 

             THAT IS WITHDRAWN AND SHE IMPROVES, WOULDN'T THAT INDICATE

 

             THAT THE MORPHINE IS HAVING AN EFFECT ON THAT PATIENT?

 

             A.  THE MORPHINE WAS HAVING AN EFFECT ON THE PATIENT, YES,

 

             BUT I THINK WITHDRAWAL OF MORPHINE ENHANCED HER DYING SYMPTOMS.

 

             Q.  OKAY.  SO MORPHINE WOULD HAVE HAD AN EFFECT ON HER DYING

 

             AT THAT POINT IN TIME, EITHER WITHHOLDING OR GIVING IT?

 

             A.  IT HAS AN EFFECT ON HER, YES, ON THE PRESENTATION OF HER

 

             PHYSIOLOGIC FUNCTIONS AND ON HER SYMPTOMS.

 

             Q.  THEN GOING ON --

 

             A.  THAT'S WHY IT'S GIVEN.

 

             Q.  I APOLOGIZE.

 

                 AFTER THIS PARTICULAR AMOUNT OF MORPHINE IS WITHHELD WE

 

             START AGAIN.  AS YOU INDICATE, 7:30 AND THEN 9:30 SHE IS

 

             SHE'S GIVEN A TWO FIVE MILLIGRAM SHOT OR 10 MILLIGRAMS,

 

             CORRECT?

 

             A.  YES.

 

             Q.  THEN A HALF HOUR LATER SHE IS A GIVEN 25-MILLIGRAM SHOT

 

             OF MORPHINE?

 

             A.  YES.

 

             Q.  AND THEN AGAIN WITHIN AN HOUR AND A HALF OF THAT SHE WAS

 

             GIVEN 30 MILLIGRAMS?

 

             A.  YES.

 

             Q.  AND THEN AN HOUR LATER IT'S 5 MILLIGRAMS AND

 

             APPROXIMATELY I GUESS TWO HOURS AFTER THAT IT WAS 30

 

             MILLIGRAMS.  AND THEN WE HAVE A 5-MILLIGRAM SHOT AND 18:30 WE

 

             HAVE A 25-MILLIGRAM SHOT.  BASED ON THE RECORDS, THAT'S

 

             PRETTY MUCH WHAT YOU GLEANED FROM THE RECORDS AS FAR AS THE

 

             SHOTS BEING GIVEN?

 

             A.  YES.  THAT LOOKS SIMILAR TO WHAT I REVIEWED.

 

             Q.  SO DOCTOR I GUESS IT'S WITH --

 

                      THE COURT:  ARE YOU THROUGH WITH THAT, MR. MAJOR?

 

                      MR. MAJOR:  NOT QUITE, YOUR HONOR.

 

                      THE COURT:  TURN ON THE LIGHTS WHEN YOU USE IT NEXT

 

             TIME SO THEY CAN SEE IT A LITTLE BETTER.

 

                      MR. MAJOR:  OH, THE LIGHTS.  I'M SORRY, YOUR HONOR.

 

             I TURNED THEM OFF HOPING WE COULD SEE IT WITHOUT BOTHERING

 

             THE JURORS.  WE'LL DO THAT.

 

                      THE COURT:  THEY NEED TO SEE IT CORRECTLY.

 

                      MR. MAJOR:  OKAY.

 

             Q.  (BY MR. MAJOR)  BUT DOCTOR SO YOUR TESTIMONY WOULD BE

 

             TODAY THAT DURING THAT LAST DAY OF HER LIFE JUDITH LARSEN

 

             RECEIVED NINE SHOTS FOR A TOTAL 130 MILLIGRAMS OF MORPHINE IN

 

             APPROXIMATELY 1-2 HOUR PERIOD AND THAT DID NOT AFFECT HER

 

             DYING IN ANY WAY?

 

             A.  OH, I THINK IT DID.  I THINK IT MADE HER CONDITION MUCH

 

             MORE STABLE THAN IT MIGHT OTHERWISE HAVE BEEN.

 

             Q.  BUT IT DIDN'T HASTEN HER DEATH IN ANY WAY?

 

             A.  I'M NOT SURE IT DID.

 

             Q.  AGAIN, MOVING ON TO MARY CRANE, IN DEALING WITH MARY

 

             CRANE, AGAIN, YOU LISTED A NUMBER OF SYMPTOMS THAT YOU FOUND

 

             HAD CAUSED HER DEATH; IS THAT CORRECT?

 

             A.  YES.

 

             Q.  ALL OF THESE SYMPTOMS AGAIN ARE JUST PRIOR TO HER COMING

 

             TO THIS HOSPITAL?

 

             A.  MANY DID, YES.

 

             Q.  AND UPON ARRIVAL AT THE HOSPITAL UNIT, SHE RECEIVED AN

 

             AMOUNT OF NOT ONLY MORPHINE BUT ALSO AN AMOUNT FROM A

 

             DURAGESIC PATCH; IS THAT CORRECT?

 

             A.  OF FENTANYL THE DURAGESIC PATCH, YES.

 

             Q.  AND LET ME SHOW YOU AGAIN FROM THIS EXHIBIT I WILL

 

             INDICATE ON THE 28TH SHE RECEIVED HER 50 MILLIGRAMS FROM A

 

             DURAGESIC PATCH CORRECT?

 

             A.  YES.

 

             Q.  AND THAT CONTINUES FOR A PERIOD OF TIME.  ON THE 3RD OF

 

             JANUARY, AGAIN, SHE RECEIVED 3 MILLIGRAMS OF MORPHINE.  SHE

 

             RECEIVED ON THE 3RD OF JANUARY -- OR 3RD OF JANUARY AT 14:45

 

             WHICH IS 2:45 ANOTHER 5 MILLIGRAMS OF MORPHINE.  THE NEXT DAY

 

             SHE RECEIVES 5 MILLIGRAMS AND THEY UP THE DURAGESIC PATCH TO

 

             75 MICROGRAMS.  SHE THEN RECEIVES ANOTHER ADDITIONAL 5

 

             MILLIGRAMS OF MORPHINE AT 9:20 AND AT 10:30.

 

                 AND, AGAIN, IT'S YOUR TESTIMONY THAT EVEN THOUGH SHE HAS

 

             THIS AMOUNT OF DURAGESIC PATCH, THE FENTANYL ON HER SYSTEM,

 

             AND THAT AMOUNT OF MORPHINE IN HER SYSTEM, THE MORPHINE HAD

 

             NO AFFECT ON HER DEATH?

 

             A.  NO.  I THINK IT PROBABLY MADE HER DEATH MORE PEACEFUL

 

             THAN IT MIGHT OTHERWISE HAVE BEEN.

 

             Q.  BUT IT DIDN'T HASTEN HER DEATH IN ANY WAY?

 

             A.  I'M NOT SURE IT DID.

 

             Q.  EVEN THOUGH THIS WAS A LADY WHO WAS SUFFERING FROM ACUTE

 

             PROBLEMS IN BREATHING AND ABSORBING OXYGEN?

 

             A.  ABSOLUTELY.  I'M NOT SURE THAT IT MADE IT ANY WORSE.

 

             Q.  SO YOU WOULDN'T INDICATE THAT THE MORPHINE WOULD HAVE

 

             REDUCED THE AMOUNT OF OXYGEN INTAKE AND CAUSE ANY ADDITIONAL

 

             PROBLEMS?

 

             A.  NOT NECESSARILY.

 

             Q.  OKAY.  NOW GOING TO -- JUST QUICKLY GOING ON TO LYDIA

 

             SMITH.  AGAIN, THESE CONDITIONS EXISTED PRIOR TO HER COMING

 

             ON TO THE UNIT; IS THAT CORRECT?

 

             A.  YES, SIR.

 

             Q.  AND, AGAIN, ONE OF THE THINGS THAT YOU FOUND WITH HER WAS

 

             THAT SHE HAD RENAL FAILURE; IS THAT CORRECT?

 

             A.  YES.

 

             Q.  AND RENAL FAILURE ALSO AFFECTS THE BODY'S ABILITY TO GET

 

             MORPHINE OUT OF THE SYSTEM, DOESN'T IT?

 

             A.  YES.  IT IS ONE OF THE WAYS THAT IT DOES THAT.

 

             Q.  SO, IN FACT, WHAT IT COULD CAUSE HER TO DO IS TO RETAIN

 

             THE LEVEL OF MORPHINE AND RAISE THE LEVEL OF MORPHINE WITHIN

 

             HER SYSTEM?

 

             A.  YES.

 

             Q.  AND SHE ALSO RECEIVED A NUMBER OF PSYCHOTROPIC DRUGS?

 

             A.  SHE DID.

 

             Q.  AND YOU WOULD NOT -- YOU DON'T FEEL THAT THESE

 

             PSYCHOTROPIC DRUGS, EVEN THOUGH THEY MAY SUPPRESS THE

 

             RESPIRATION AND BLOOD PRESSURE WOULD HAVE ANY AFFECT ON HER

 

             DEATH?

 

             A.  I'M NOT SO SURE THAT THEY DID, NO.

 

             Q.  ALL THESE CONDITIONS THAT SHE HAD PRIOR TO HER COMING TO

 

             THE UNIT THAT WOULD HAVE CAUSED HER DEATH?

 

             A.  YES, SIR, I BELIEVE THAT.

 

             Q.  AND, AGAIN, JUST TURNING REAL QUICKLY ON ENNIS ALLDREDGE

 

             BASICALLY THE SAME SITUATION.  HE HAD A NUMBER OF CONDITIONS

 

             THAT YOU FELT WERE LIFE-THREATENING THAT EXISTED PRIOR TO

 

             COMING TO THE UNIT?

 

             A.  YES, SIR.

 

             Q.  ONE THING I WANTED TO ADDRESS REAL QUICKLY THOUGH WITH

 

             YOU, YOU ALSO INDICATED THAT HE HAD A STROKE WHILE AT THE

 

             HOSPITAL; IS THAT CORRECT?

 

             A.  I DID.

 

             Q.  DID YOU FIND ANYTHING IN THE ACTUAL AUTOPSY SLIDES OR

 

             ANYTHING THAT WOULD INDICATE THERE WAS A STROKE?

 

             A.  WELL, NO, I COULDN'T BECAUSE THE BRAIN HAD SO

 

             DETERIORATED THAT THE PATHOLOGIST WHO DID THE AUTOPSY COULD

 

             NOT IDENTIFY ANYTHING LIKE THAT AND MADE NO SECTIONS OF THE

 

             BRAIN SO AS TO BE ABLE EVEN MICROSCOPICALLY TO BE ABLE TO

 

             LOOK AT IT.

 

             Q.  SO YOU WERE JUST BASING YOUR INFORMATION ON THE STROKE ON

 

             WHAT YOU HAD BEEN TOLD AND WHAT YOU HAD READ IN THE RECORDS?

 

             A.  WHAT WAS IN THE RECORDS, THAT'S WHERE I GOT THAT

 

             INFORMATION.

 

             Q.  AND THAT WAS FROM THE RADIOLOGIST REPORT?

 

             A.  YES.  ACTUALLY, THAT'S WHERE IT ORIGINATED.

 

             Q.  THE RADIOLOGIST REPORT THAT INDICATES THE REPORT WAS

 

             SOMEWHAT -- THERE WAS A PROBLEM WITH THAT REPORT, THAT THEY

 

             COULDN'T GET A GOOD, CLEAR PICTURE OF IT?

 

             A.  I DO REMEMBER SOMETHING LIKE THAT, YES.

 

             Q.  DO YOU RECALL IN REVIEWING THE RECORDS, WAS THERE

 

             ANYTHING IN THOSE RECORDS INDICATING THAT THE DEFENDANT IN

 

             THIS MATTER DID ANYTHING TO DIAGNOSIS THAT STROKE?

 

             A.  I THINK IT WAS A CLINICAL IMPRESSION THAT WAS RECORDED

 

             THERE, BUT I DON'T RECALL ANYTHING OTHER THAN THE RADIOLOGY.

 

             Q.  AND WHAT DO YOU NORMALLY EXPECT A DOCTOR WHO'S RECEIVED A

 

             RADIOLOGY REPORT ABOUT A STROKE TO DO SOME TYPE OF DIAGNOSIS

 

             TO CONFIRM THAT?

 

             A.  WELL, I SUSPECT HE DID --

 

             Q.  WELL --

 

             A.  -- DO A DIAGNOSIS BY TRYING TO GET A RADIOLOGICAL STUDY

 

             TO CONFIRM IT.

 

             Q.  BUT AFTER THE STUDY COMES BACK AND IT'S A COMPROMISED

 

             STUDY, WOULDN'T YOU EXPECT THAT A DOCTOR WOULD THEN DO SOME

 

             FURTHER TESTING, PHYSICAL TESTING, THOSE TYPE OF THINGS TO

 

             VERIFY THAT THE STROKE WAS PRESENT?

 

             A.  IT'S POSSIBLE, BUT I THINK IT'S PART OF THE CONTEXT.  IN

 

             THIS CASE IT WAS DIFFICULT TO DO THE RADIOLOGIC EXAM BECAUSE

 

             OF THE AGITATION OF THE PATIENT.

 

             Q.  EXACTLY.

 

             A.  AND THE INABILITY TO KEEP HIM ADEQUATELY CONTROLLED AND

 

             SO IT WAS DIFFICULT TO DO THAT.  BUT I SAW -- I'D OFFER THIS,

 

             THOUGH I DON'T KNOW FOR SURE, THAT IT MAY BE THAT IT WAS

 

             THOUGHT THAT NOTHING BETTER COULD HAVE BEEN DONE TO

 

             SUBSTANTIATE THE EXTENT OF BRAIN DAMAGE.

 

             Q.  BUT YOU COULD DO -- I'M NOT GOING TO BELABOR THE POINT,

 

             BUT YOU COULD DO A PHYSICAL EXAM, STRENGTH EXAM, THOSE TYPE

 

             OF THINGS?

 

             A.  THOSE THINGS ARE POSSIBLE TO DO, YES/I DON'T KNOW WHAT

 

             THE EFFECT OF THAT WOULD HAVE BEEN.

 

             Q.  THE BOTTOM LINE I GUESS IN GOING BACK OVER EACH AND EVERY

 

             ONE OF THESE PATIENTS YOU INDICATE WERE SEVERELY

 

             HANDICAPPED -- PHYSICALLY HANDICAPPED OR I GUESS MEDICALLY

 

             HANDICAPPED WHEN THEY CAME ON THE UNIT; IS THAT CORRECT?

 

             A.  I BELIEVE SO, YES.

 

             Q.  THEY WERE BASICALLY CLOSE TO BEING TERMINAL WOULD YOU

 

             SAY?

 

             A.  I SAW THEM ALL AS BEING CLOSE TO OR IN TERMINAL PHASE

 

             WHEN THEY CAME, YES.

 

             Q.  AS A MATTER OF FACT, THE DEFENDANT DID NOTHING TO

 

             DIAGNOSE THESE CONDITIONS WHEN THEY CAME ONTO THE UNIT, DID

 

             HE?

 

             A.  I THINK DIAGNOSES IN MANY CASES CAME WITH THE PATIENTS.

 

             I GOT MUCH OF MY INFORMATION, AS YOU RECALL, FROM THE RECORDS

 

             FROM WHICH I SPOKE AND THOSE THINGS WERE SUBSTANTIATED BY

 

             AUTOPSY.

 

             Q.  BUT THESE ARE PEOPLE WHO ARE GOING ON TO A GEROPSYCH UNIT

 

             WHERE THEY'RE GOING TO RECEIVE TREATMENT, WHERE THEY'RE GOING

 

             TO RECEIVE DIFFERENT TYPES OF GROUP THERAPY, AND YOU -- DON'T

 

             YOU BELIEVE IN YOUR MIND EVEN GIVEN THE SIGNIFICANT CONDITION

 

             THAT THEY WERE IN THAT THEY SHOULD HAVE BEEN ON THAT UNIT?

 

             A.  WHERE THEY ARE ADMITTED IN A PARTICULAR HOSPITAL DEPENDS

 

             ON THE HOSPITAL CUSTOMS AND THE WAY PATIENTS ARE MANAGED IN A

 

             PARTICULAR AREA.  I DON'T KNOW ABOUT THAT IN THIS CASE --

 

             Q.  OKAY.

 

             A.  -- SO I CAN'T COMMENT ON WHETHER OR NOT THAT WAS THE

 

             RIGHT PLACE FOR THEM TO BE MANAGED.

 

             Q.  OKAY.  ONE FINAL QUESTION:  THE BOTTOM LINE IN THIS

 

             MATTER IS YOU'VE GOT FIVE PATIENTS THAT COME ONTO THIS UNIT,

 

             ALL OF THEM AS YOU HAD INDICATED WITH SOME SEVERE PROBLEMS,

 

             THEY WERE ON THE UNIT FOR APPROXIMATELY 16 DAYS AND THEY ALL

 

             DIE.  AND THERE'S ONE COMMON FACTOR BETWEEN ALL FIVE OF THESE

 

             PATIENTS AND THAT IS THE FACT THAT THEY RECEIVED MORPHINE; IS

 

             THAT CORRECT --

 

             A.  WELL, THERE'S MORE COMMON FACTORS THAN THAT.  THEY ALL

 

             THE HAVE ADVANCED DISEASE AS WELL.

 

             Q.  AND THEY RECEIVED PSYCHOTROPIC DRUGS AND THEY RECEIVED

 

             LARGE AMOUNTS OF MORPHINE?

 

             A.  SURE.  THERE ARE A NUMBER OF OVERLAPPING FEATURES.

 

                      MR. MAJOR:  THANK YOU.  WE HAVE NO FURTHER

 

             QUESTIONS, YOUR HONOR.

 

                      THE COURT:  DO YOU WANT TO TURN THE PROJECTOR OFF,

 

             MR. MAJOR.

 

                      MR. MAJOR:  I WILL DO THAT, YOUR HONOR.  I WILL EVEN

 

             TURN ON THE LIGHTS.

 

                                 RECROSS-EXAMINATION

 

            BY MS. ISAACSON:

 

             Q.  DR. CASSIN, IN REVIEWING THE RECORDS YOU SAW THAT ALL OF

 

             THESE PATIENTS HAD ADVANCED DIRECTIVES AS TO THEIR TREATMENT

 

             AND CARE AT THE END OF THEIR LIVES; IS THAT RIGHT?

 

             A.  I KNOW THAT THEY WERE REFERRED TO OR IN -- I REMEMBER

 

             EVEN READING ONE AT LEAST ONE IN THE RECORD.

 

             Q.  AND WITH REGARD TO JUDITH LARSEN, YOU SAW THE MORPHINE

 

             THAT WAS ADMINISTERED TO HER, IT'S TRUE THAT AT A CERTAIN

 

             POINT DURING HER HOSPITALIZATION A DECISION HAD SIMPLY BEEN

 

             MADE BASED UPON HER ADVANCED DIRECTIVES AND THE WISHES OF HER

 

             FAMILY TO KEEP HER COMFORTABLE?

 

             A.  YES.

 

             Q.  AND THAT'S ALSO TRUE WITH MARY CRANE, LYDIA SMITH, ENNIS

 

             ALLDREDGE THAT A DECISION HAD BEEN MADE TO KEEP THESE

 

             PATIENTS COMFORTABLE THROUGH THE DYING PROCESS?

 

             A.  THAT'S PART OF THE ADVANCED DIRECTIVES AND THAT'S TRUE IN

 

             THESE CASES, YES.

 

             Q.  AND ONE OF THE THINGS THAT MORPHINE CAN DO AND CAN

 

             PROVIDE IS COMFORT AT THE END OF LIFE, IS THAT TRUE?

 

             A.  IT'S COMMONLY USED FOR THAT PURPOSE, YES.

 

                      MS. ISAACSON:  THAT'S ALL I HAVE.

 

                      THE COURT:  RECROSS.

 

                      MR. MAJOR:  NONE, YOUR HONOR.

 

                      THE COURT:  YOU MAY STEP DOWN, DOCTOR.  THANK YOU

 

             FOR TESTIFYING.

 

                      THE WITNESS:  THANK YOU, SIR.

 

                      THE COURT:  MAY THIS WITNESS BE EXCUSED, MR. MAJOR?

 

                      MR. MAJOR:  YES, SIR.

 

                      THE COURT:  MS. ISAACSON?

 

                      MS. ISAACSON:  YES.

 

                      THE COURT:  THANK YOU.  AND YOU MAY BE EXCUSED.

 

             THANK YOU FOR TESTIFYING.

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