Maureen Frikke, MD

         25           MR. WILSON:  Thank you, Your Honor.  We call Dr.

 

          1  Maureen Frikke to the stand at this time.

 

          2           THE COURT:  Dr. Frikke, step up, please.  Come right

 

          3  up here, please, and be sworn.

 

          4                       MAUREEN FRIKKE,

 

          5           being first duly sworn, was examined and

 

          6           testified as follows:

 

          7           THE COURT:  Please take the witness stand.  State

 

          8  your name and spell the last name.

 

          9           THE WITNESS:  My name is Maureen Jane Frikke.

 

         10  F-r-i-k-k-e.

 

         11           THE COURT:  Thank you.  Go ahead, Mr. Wilson.

 

         12                      DIRECT EXAMINATION

 

         13  BY MR. WILSON:

 

         14  Q.  Dr. Frikke, will you tell us where you are currently

 

         15  employed, please.

 

         16  A.  I'm employed by the Office of the Medical Examiner, which

 

         17  is part of the State Department of Health.

 

         18  Q.  And in what capacity are you so employed?

 

         19  A.  I'm the assistant medical examiner.

 

         20  Q.  Okay.  And can you tell us, if you would, please,

 

         21  relative to your -- a brief explanation as to your

 

         22  educational background?

 

         23  A.  I have a doctor of medicine degree from Washington

 

         24  University in St. Louis.  I did my pathology training, which

 

         25  was an internship and residency in anatomic and clinical

 

          1  pathology, at the University of Florida in Gainsville,

 

          2  Florida.  I did one year of fellowship training in forensic

 

          3  pathology at the Hennepin County medical examiner's office in

 

          4  Hennepin County, which is the county that includes

 

          5  Minneapolis, Minnesota.  And after my fellowship training I

 

          6  came to Utah.

 

          7  Q.  Okay.  In term of your experience you say you came to

 

          8  Utah after that training?

 

          9  A.  I did.

 

         10  Q.  And when did you come to Utah?

 

         11  A.  That was in August of 1991.

 

         12  Q.  Okay.  Have you been with the medical examiner's office

 

         13  since that time?

 

         14  A.  I have.

 

         15  Q.  And have you performed autopsies since that time?

 

         16  A.  I have.

 

         17  Q.  And can you tell us how many autopsies you've performed

 

         18  over the time that you've been employed with the medical

 

         19  examiner's office?

 

         20  A.  I do between three and four hundred patients per year.

 

         21  That's 3300, 3500, somewhere in there.

 

         22  Q.  Okay.  Have you testified in court proceedings before?

 

         23  A.  Yes, I have.

 

         24  Q.  And can you tell us how many times you've testified?

 

         25  A.  Probably about twice a month.

 

          1  Q.  All right.  Calling your attention to the matter before

 

          2  the court here, did you have occasion to perform an autopsy

 

          3  examination relative to Mary Crane?

 

          4  A.  I did.

 

          5  Q.  Can you tell us when that took place?

 

          6  A.  That examination was on June 24th, 1999.

 

          7  Q.  And where was it conducted?

 

          8  A.  At the medical examiner's office in Salt Lake City.

 

          9  Q.  And can you tell us who was present on that occasion?

 

         10  A.  The official witness was Detective Joe Morrison.

 

         11  Q.  Okay.  And do you know what department he's with?

 

         12  A.  He's with the Layton police department.

 

         13  Q.  Okay.  The body, as I understand it, was presented to you

 

         14  at that time?

 

         15  A.  It was.

 

         16  Q.  And can you tell us, was it in a casket at the time that

 

         17  you first observed the body?

 

         18  A.  Yes.

 

         19  Q.  Okay.  Now, you do autopsies with a set procedure, is

 

         20  that correct?

 

         21  A.  It's fairly regular.  It's subject to variation,

 

         22  depending upon the specific needs of the case, but it's

 

         23  fairly standard.

 

         24  Q.  And as I understand it, you make an external examination

 

         25  of the body, is that correct?

 

          1  A.  Yes.

 

          2  Q.  And did you do so on this occasion?

 

          3  A.  I did.

 

          4  Q.  And can you tell us relative to -- strike that.  I want

 

          5  to step back one step further.  Did you review any other

 

          6  records or investigative reports prior to conducting this

 

          7  autopsy?

 

          8  A.  I had a report that was prepared by the medical examiner

 

          9  investigator that presented some of the facts regarding the

 

         10  circumstances that resulted in this lady's exhumation.

 

         11  Q.  What about her medical records, do you know whether or

 

         12  not you ever reviewed those medical records, hospital

 

         13  records?

 

         14  A.  I have medical records for her.  I don't remember if I

 

         15  had them before the examination or right after it, but it was

 

         16  about the time that I did her examination that I also had her

 

         17  medical records.

 

         18  Q.  All right.  So you're not sure whether you reviewed those

 

         19  medical records previous to performing the autopsy, is that

 

         20  correct?

 

         21  A.  Yes, I don't remember that.

 

         22  Q.  Okay.  And in terms of the reports that you did make, did

 

         23  that create any alteration in the procedure or did you

 

         24  reference that report in terms of what you were going to be

 

         25  looking for in terms of this autopsy?

 

          1  A.  Well, I knew what had been documented with respect to her

 

          2  past medical history, so I could anticipate some of her

 

          3  physical findings.  But that doesn't particularly influence

 

          4  the way I do the examination.

 

          5  Q.  All right.  So then you made the external -- going back

 

          6  to the autopsy, you conducted the external examination.  Did

 

          7  I ask you the question, I can't remember if I did, was there

 

          8  any significant findings in your mind related to this autopsy

 

          9  as far as the external examination goes?

 

         10  A.  What was particularly striking about her, obviously, was

 

         11  she'd been embalmed and entombed for quite some period of

 

         12  time.  There was a lot of changes on the external surface of

 

         13  the body as a result of those procedures.

 

         14  Q.  All right.  But in terms of any findings relative to the

 

         15  external examination, was there anything significant to your

 

         16  subsequent opinion that you rendered as far as this

 

         17  examination goes?

 

         18  A.  No.  The external features of her body were basically

 

         19  pretty unremarkable.

 

         20  Q.  Okay.  And then I assume you conducted an internal

 

         21  examination of the body, is that correct?

 

         22  A.  I did.

 

         23  Q.  And you have a procedure you followed on this particular

 

         24  occasion of examining certain parts of the internal organs?

 

         25  A.  Yes.

 

          1  Q.  Can you tell us what procedure you followed?

 

          2  A.  The basic procedure for the internal examination is that

 

          3  the chest is opened and the abdomen is opened so that we can

 

          4  remove all of the internal organs and separate them out and

 

          5  dissect them and look at them organ by organ.  In the process

 

          6  of doing that, we do try to collect materials that would be

 

          7  used for doing drug analysis.  I collect tissue samples that

 

          8  I would save so that I can look at selected organs under the

 

          9  microscope.

 

         10  Q.  Following the chest area, do you also examine the brain?

 

         11  A.  I did.

 

         12  Q.  Okay.  Any other areas that you examined in connection

 

         13  with this autopsy?

 

         14  A.  Well, the chest organs were examined.  The abdominal and

 

         15  pelvic organs were examined.  The neck organs are examined

 

         16  and the brain.

 

         17  Q.  Okay.  And on this particular occasion can you describe

 

         18  for us, if you would, relative to your findings as it

 

         19  pertained to any significant findings, let's put it that way,

 

         20  or acute findings, relative to the internal organs that you

 

         21  examined?

 

         22  A.  The organs that had visible signs of disease or

 

         23  abnormality were her heart, her kidneys and her brain.

 

         24  Q.  Okay.

 

         25  A.  She had an enlarged heart.  She had signs of high blood

 

          1  pressure.  And there was some narrowing of her coronary

 

          2  arteries on gross examination.

 

          3      Her kidneys, on gross examination, had some scarring that

 

          4  can occur as a result of a couple of different disease

 

          5  processes.  She had evidence in her brain of having had a

 

          6  stroke in the past.

 

          7  Q.  Okay.  In respect to the heart organs, can you describe

 

          8  whether or not there was any acute findings relative to any

 

          9  damage to the heart?

 

         10  A.  Everything that I saw in her heart was old.

 

         11  Q.  Okay.  In respect to the kidneys, can you tell us whether

 

         12  or not there was any acute findings relative to damage to the

 

         13  kidneys?

 

         14  A.  There were no new or acute disease processes in her

 

         15  kidneys that I could identify.

 

         16  Q.  Okay.  In respect to her brain, can you tell us whether

 

         17  or not there were any acute findings as to your examination

 

         18  of the brain?

 

         19  A.  No, there were not.

 

         20  Q.  Okay.  If you could, did you prepare an autopsy report?

 

         21  A.  I did.

 

         22  Q.  Let me show you what has previously been marked as

 

         23  state's exhibit C and ask you to take a look at that, please.

 

         24  A.  (Witness complied.)

 

         25  Q.  Can you identify that particular document?

 

          1  A.  (Pause.)  I can.

 

          2  Q.  And would you do so, please.

 

          3  A.  This is a photocopy of the report of examination that I

 

          4  prepared.  Attached to it are the results of the toxicology

 

          5  testing that was done by the department of health.

 

          6  Q.  Okay.  Can you tell, Doctor, and turn to the second page

 

          7  of that particular examination, did you prepare an opinion

 

          8  relative to this autopsy?

 

          9  A.  Yes.

 

         10  Q.  Calling your attention to the first paragraph of that

 

         11  page, in the last sentence, can you characterize for us what

 

         12  your findings were relative to any disease processes?

 

         13  A.  What I stated in my opinion was that there were no

 

         14  gross -- there was no gross, which is visible, or microscopic

 

         15  evidence, which is evidence that requires the microscope to

 

         16  see, that acute injury had occurred in any of the vital

 

         17  organs.

 

         18  Q.  And in respect to the sentence just above that, in terms

 

         19  of the disease processes, what was your notation there?

 

         20  A.  Okay.  I indicated that no significant acute disease

 

         21  processes which would have been likely to cause death were

 

         22  identified.

 

         23  Q.  All right.  Now, down at the bottom paragraph you make a

 

         24  determination relative to cause of death and manner of death,

 

         25  do you not?

 

          1  A.  I do.

 

          2  Q.  And can you tell us what your opinion was relative to any

 

          3  cause of death?

 

          4  A.  My opinion was the cause of death was certified as

 

          5  undetermined.

 

          6  Q.  And in respect to the manner of death, did you make

 

          7  any -- form any opinion there?

 

          8  A.  I did.

 

          9  Q.  And what was that?

 

         10  A.  In my opinion the manner of death should be certified as

 

         11  undetermined if injured.

 

         12  Q.  I'm a little bit curious, what does the if injured mean?

 

         13  A.  That means that on the basis of the examination and the

 

         14  information I had, I cannot make a determination, to a degree

 

         15  of medical certainty, as to whether she died from something

 

         16  natural, which would be her own natural diseases, or an

 

         17  injury mechanism, something that would have been inflicted

 

         18  upon her from outside of her own body.

 

         19  Q.  Now, you further qualify that particular determination,

 

         20  do you not, in that last paragraph?

 

         21  A.  Yes.

 

         22  Q.  You address cardiac disease and what do you say about

 

         23  that?

 

         24  A.  I say Mrs. Crane had cardiac disease which could have

 

         25  resulted in sudden and unexpected death.

 

          1  Q.  And what did you mean by that, Doctor?

 

          2  A.  She had scarring on her heart.  She'd had episodes of

 

          3  heart attacks in the past.  The tissue had healed so she had

 

          4  scar tissue in her heart.  People who have scar tissue in

 

          5  their heart can develop chronic heart failure; or they can

 

          6  develop sudden rhythm disturbances that will cause them to

 

          7  die suddenly and unexpectedly.

 

          8  Q.  Okay.  Now, would the medical history of that particular

 

          9  patient be relevant to a determination if indeed a cardiac

 

         10  disease had brought about her sudden death?

 

         11  A.  Her medical history would certainly be -- would indicate

 

         12  if she had evidence of chronic congestive heart failure,

 

         13  which is a process of slow failure of the heart.

 

         14  Q.  Okay.  And in terms of records which would indicate

 

         15  relative to how she died, when you describe a sudden death,

 

         16  sudden and unexpected death, what do you mean by that?

 

         17  A.  What I mean is that the person would, to all observers,

 

         18  appear to be in her usual ordinary state of health, and then

 

         19  suddenly die.

 

         20  Q.  Okay.  You also talk about -- form an opinion relative to

 

         21  narcotic intoxication.  Can you tell us what your opinion was

 

         22  relative to that particular process?

 

         23  A.  My opinion was that narcotic intoxication cannot be

 

         24  excluded as either the primary cause of death or as a factor

 

         25  which contributed significantly to her death.

 

          1  Q.  Why is that, Doctor?

 

          2  A.  Because of the embalming process and the long interval

 

          3  between embalming and examination, the ability to identify

 

          4  drugs is greatly diminished.

 

          5  Q.  There are indeed drug screens that were run relative to

 

          6  certain tissues that you sent to the state lab, is that

 

          7  correct?

 

          8  A.  Yes.

 

          9  Q.  Did you get those screens back?

 

         10  A.  Yes.

 

         11  Q.  And can you tell us whether you have the ability to

 

         12  interpret those screens?

 

         13  A.  I do.

 

         14  Q.  Okay.  What were the results of the screens that were

 

         15  done in respect to that particular patient?

 

         16  A.  Opiates, which are narcotic drugs, were identified in

 

         17  fluid that we collected from a kidney cyst.  She had a cyst

 

         18  on one of her kidneys and we collected that fluid.  That

 

         19  fluid is basically urine.  Opiates were present in that

 

         20  fluid.

 

         21      She had had -- we collected at autopsy a medication patch

 

         22  that was on her back.  They identified fentanyl in that

 

         23  medication patch.  The other materials that we collected were

 

         24  embalmed blood, bile and embalmed brain.  They could not

 

         25  verify the presence of morphine in those materials.

 

          1  Q.  Okay.  As to the screening test, you said that opiates

 

          2  were identified relative to the urine sample?

 

          3  A.  That's correct.

 

          4  Q.  Okay.  Was there ever an attempt to quantify those

 

          5  opiates?

 

          6  A.  Not that I'm aware of.  The sample that we had was very

 

          7  small.

 

          8  Q.  Okay.  Turning to the back page of the report, can you

 

          9  look at the quantitative analysis there?

 

         10  A.  (Witness complied.)

 

         11  Q.  Have you got that, Doctor?

 

         12  A.  I do.

 

         13  Q.  Can you tell us whether that tells us anything under

 

         14  quantitative?

 

         15  A.  What the laboratory reported was their attempts to

 

         16  identify and quantitate morphine in the embalmed blood that

 

         17  we collected out of the aorta, from the bile and from the

 

         18  brain tissue.  What they report is morphine -- for each of

 

         19  these materials, less than 0.05 milligrams per liter.

 

         20  Q.  Okay.  And is there any ability to correlate those

 

         21  findings with what you read in the medical history?

 

         22  A.  No.

 

         23  Q.  Okay.  Did you also, during the course of the autopsy,

 

         24  have occasion to examine the body as relates to any evidence

 

         25  of a vaginal fistula?

 

          1  A.  I did examine the pelvic organs to the best of my

 

          2  ability, given that the lady had been embalmed several years

 

          3  previously.

 

          4  Q.  So I understand from that that you weren't able to make

 

          5  an examination?

 

          6  A.  I examined the tissue.  I did not identify a disease

 

          7  process there.  It's very difficult to examine that part of

 

          8  the body very well because of the effects of the embalming.

 

          9  I did not identify a fistula.

 

         10  Q.  Can you tell us whether you made any examination relative

 

         11  to a sepsis?  And before you answer that, let me ask you what

 

         12  is a sepsis?

 

         13  A.  Sepsis is a common term for blood poisoning.  Bacteria

 

         14  gets into the blood and travels all around the body and you

 

         15  become very ill very rapidly.

 

         16  Q.  Is there any way to determine pathologically in an

 

         17  autopsy whether or not an individual has had a sepsis or

 

         18  infection of that nature in their body?

 

         19  A.  When we have the opportunity to do the examination on a

 

         20  body that is not embalmed, it's very easy to do because we

 

         21  can collect blood, cerebral spinal fluid, different fluids

 

         22  from the body, and actually submit them to the laboratory for

 

         23  bacterial cultures, just like you would do with a living

 

         24  person who you suspect might have sepsis.  And we do that

 

         25  regularly.  That's a very common practice in our office.

 

          1      Sepsis is blood infection.  Once a person is embalmed --

 

          2  first of all the goal, one of the goals of embalming, is to

 

          3  wash away all the blood and to replace it with fluids that

 

          4  preserve the tissues.  So the blood is gone, or most of it is

 

          5  gone, after the embalming process.  The embalming process

 

          6  also kills the bacteria and that's part of what keeps you all

 

          7  in one piece after you are buried.  So the embalmed person is

 

          8  a very poor candidate for looking for sepsis.

 

          9      The only information we could find that we would be

 

         10  looking for in a patient like this is evidence that infection

 

         11  had actually been set up in tissues, like the lung and the

 

         12  heart and brain and kidneys.

 

         13  Q.  Did you see any evidence of that nature?

 

         14  A.  She had a very small amount of infection, basically a

 

         15  bronchitis, in one of her lungs.  I did not see evidence of

 

         16  infection in her other organs.

 

         17  Q.  Okay.  Doctor, I'm going to show you now what has been

 

         18  marked as state's exhibit 4D and ask you to identify that

 

         19  particular exhibit if you would, please.

 

         20  A.  This exhibit is a copy of an official State of Utah death

 

         21  certificate.

 

         22  Q.  That's on the first page?

 

         23  A.  Correct.

 

         24  Q.  Is there an amended certificate attached?

 

         25  A.  There is.

 

          1  Q.  And can you identify that particular portion of the

 

          2  exhibit?

 

          3  A.  Yes.  The second page is an official State of Utah

 

          4  Department of Health amendment to a death certificate.

 

          5  Q.  And was that your amendment to the death certificate?

 

          6  A.  Dr. Grey signed it.

 

          7  Q.  Okay.  Relative to the first page, that was the original

 

          8  death certificate as I understand it?

 

          9  A.  That's my understanding also.

 

         10  Q.  Do you know what the cause of death was listed relative

 

         11  to that?

 

         12  A.  There is a cause of death listed, yes.

 

         13  Q.  Can you tell us what that is?

 

         14  A.  The cause of death that is listed on the original death

 

         15  certificate is cardiac arrest due to respiratory arrest, due

 

         16  to seizure, due to -- as the consequence of CVA.

 

         17  Q.  Okay.  Can you interpret that for us?

 

         18  A.  What this says is that the heart stopped because the

 

         19  lungs stopped because of a seizure because of a stroke.

 

         20  Q.  Okay.  Did you find any evidence of an acute stroke, in

 

         21  terms of your findings, as far as the autopsy was concerned?

 

         22  A.  No.

 

         23           MR. WILSON:  Thank you, Doctor.

 

         24           THE COURT:  Cross-examine.

 

         25           MS. ISSACSON:  If we could have a moment?

 

          1           THE COURT:  Sure.

 

          2      (Pause in the proceedings.)

 

          3                      CROSS-EXAMINATION

 

          4  BY MS. ISAACSON:

 

          5  Q.  Dr. Frikke, my name is Tara Isaacson.  I'm one of the

 

          6  attorneys representing Dr. Weitzel.

 

          7      One of the major findings in your opinion is that Mrs.

 

          8  Crane had cardiac disease which could have resulted in her

 

          9  sudden and unexpected death?

 

         10  A.  That's correct.

 

         11  Q.  You also noted in your examination that Mrs. Crane had

 

         12  evidence of a stroke from the past?

 

         13  A.  That's true.

 

         14  Q.  And there are certainly strokes that a patient can have

 

         15  that are subacute or that you cannot detect by your autopsy

 

         16  examination?

 

         17  A.  I don't necessarily agree with that statement.

 

         18  Q.  Okay.  It's not -- in this case, given the level of

 

         19  decomposition and given the condition of this patient's

 

         20  brain, it is possible that there could be a subacute event in

 

         21  this brain that you could not detect?

 

         22  A.  Her tissues were extremely well preserved.  The funeral

 

         23  director did a good job of embalming her.  Her tissues were

 

         24  not decomposed.  She had mold on her outside, but her tissues

 

         25  were extremely well preserved.

 

          1  Q.  But it is true, isn't it, that there are subacute events

 

          2  in a brain that you cannot detect that could have occurred

 

          3  shortly before her death or after death?

 

          4  A.  If you're talking about strokes, I don't think I would

 

          5  agree with that statement.

 

          6  Q.  How about a subacute event in the brain, something short

 

          7  of an actual stroke?

 

          8  A.  Certainly there can be such events.

 

          9  Q.  And this brain you noted was unusually small?

 

         10  A.  It was.

 

         11  Q.  And you're aware that in this case, because you reviewed

 

         12  the medical records, Dr. Dienhart reported a possible seizure

 

         13  on January 7th?

 

         14  A.  I think I recall that.  His handwriting is almost

 

         15  impossible to read, though.

 

         16           MR. BUGDEN:  That's been well documented.

 

         17           THE WITNESS:  If he thought he saw a seizure.  I'm

 

         18  not sure that I could read his handwriting.  It's really bad.

 

         19  Q.  (BY MS. ISSACSON)  Would you agree that within the

 

         20  medical records that were notes from both nurses and from Dr.

 

         21  Dienhart that indicated a potential seizure, symptoms of a

 

         22  seizure?

 

         23  A.  That may be.  I couldn't verify it from his writing,

 

         24  though.

 

         25           THE COURT:  Assume that that has been the testimony.

 

          1  Q.  (BY MS. ISSACSON)  You would agree that a seizure is a

 

          2  clinical determination?

 

          3  A.  It is.

 

          4  Q.  And it's not something that you're going to have a

 

          5  finding on during an autopsy?

 

          6  A.  No, not the seizure itself.

 

          7  Q.  And we've already heard on direct examination that you

 

          8  were unable, given what you had to work with, to rule out

 

          9  sepsis in this patient?

 

         10  A.  That's correct.

 

         11  Q.  And of course there are certain conditions that you

 

         12  simply can't detect after decomposition?

 

         13  A.  That's true.

 

         14  Q.  And in this case, for example, we all know, we've heard

 

         15  the testimony, that there was a rectal/vaginal fistula, but

 

         16  you weren't able to see that when you performed the

 

         17  examination even though you were looking for it?

 

         18  A.  That's correct.

 

         19  Q.  And do I understand correctly that there were actually

 

         20  two Duragesic patches found on the upper back of Mrs. Crane?

 

         21  A.  That's correct.

 

         22  Q.  So in this case you can't rule out heart problems or

 

         23  cardiac disease as a cause of death?

 

         24  A.  True.

 

         25  Q.  You can't rule out sepsis?

 

          1  A.  True.

 

          2  Q.  And you're unable to make a determination about the

 

          3  seizure?

 

          4  A.  That's true.

 

          5  Q.  Part of your report, in addition to these physical

 

          6  findings, what you're actually able to see, you make mention

 

          7  in your opinion section that Mary Crane had only been treated

 

          8  for her pain previously with nonprescription medication.  You

 

          9  actually write, Mary Crane had a past history of rupture of

 

         10  an intervertebral disk in 1984 and pain relief was

 

         11  accomplished with nonprescription medications in the

 

         12  convalescent center in which she'd resided.  That was part of

 

         13  your opinion in this case, is that right?

 

         14  A.  That is medical history that I am citing as part of my

 

         15  rationale for why the death certificate was amended to what

 

         16  it was.

 

         17  Q.  And would you be surprised to hear that in fact Mrs.

 

         18  Crane had been treated with prescription medications in the

 

         19  nursing home where she resided?

 

         20  A.  It wasn't in the records that I had.

 

         21  Q.  Let me show you what is marked as defendant's exhibit 97.

 

         22  Please take a look at that.  Have you ever seen that record

 

         23  before in conjunction with your autopsy of Mary Crane?

 

         24  A.  No.

 

         25  Q.  What does it -- does it appear to be a controlled drug

 

          1  record of Mary Crane?

 

          2  A.  What it is is a lot of columns with no signatures on it.

 

          3  And then signatures, some of which are legible and some which

 

          4  aren't.

 

          5  Q.  Let's start with the top page.  You would agree that in

 

          6  the bottom right corner there is reference to the patient

 

          7  Mary Crane next to the exhibit marker?

 

          8           THE COURT:  That's a yes or no answer.

 

          9           THE WITNESS:  Yes.

 

         10  Q.  (BY MS. ISSACSON)  And isn't it true that it says below

 

         11  that ordered as Darvocet, and then there's a DSPDT of 4/8/91,

 

         12  a dispense date of 4/8 of '91?  Is that writing on the front

 

         13  of that medication log?

 

         14  A.  Okay.  The bottom line, yeah.

 

         15  Q.  And you would agree that Darvocet prescribed to Mary

 

         16  Crane in 1991 would count as a prescription pain medication

 

         17  certainly?

 

         18  A.  It is.

 

         19  Q.  And it's actually an opiate based pain medication?

 

         20  A.  It is.

 

         21  Q.  And is a relative of morphine?

 

         22  A.  It is a congener of it, yes.

 

         23  Q.  And I won't have you go through page by page, but at

 

         24  least this first page starts in 1991.  And then if you look

 

         25  at the end page, or as you flip through, we go up to Mary

 

          1  Crane and we go up to September of 1995.  There are all of

 

          2  these logs, and we won't go through them day by day, but of

 

          3  this patient receiving pain medications for years prior to

 

          4  her admission to the geropsych unit.  Would you agree it

 

          5  appears, at least from your review of that exhibit, that Mary

 

          6  Crane in fact had been prescribed pain medications for pain

 

          7  prior to her admission?

 

          8  A.  If this is a part of her record.  This was not -- the

 

          9  records that I have from the care center where she was had

 

         10  medications lists with them.  This drug was not included on

 

         11  that medication list.  And in fact this record stops in 1994.

 

         12  Q.  With regard to the records that you actually reviewed,

 

         13  did you review the medical records from Davis Hospital in

 

         14  conjunction with the nursing home records or just the medical

 

         15  records from the hospital?

 

         16  A.  I had records from the care center and records from Davis

 

         17  Hospital.

 

         18  Q.  And no where in your review of those records did you note

 

         19  or see an on going prescription for opiate type pain

 

         20  medications?

 

         21  A.  Not at the care center.

 

         22  Q.  Of course, you would have received the records and

 

         23  information from the state?  You would have received those

 

         24  from the investigating agency?  That's where you would have

 

         25  received the records from?

 

          1  A.  They were provided to me and I assumed that they came

 

          2  from the Layton police department.

 

          3  Q.  You certainly didn't get any records from Dr. Weitzel?

 

          4  A.  No.

 

          5  Q.  And you didn't actually speak to any treating physicians

 

          6  or anything like that?

 

          7  A.  No.

 

          8  Q.  And you relied on the state to provide you with a

 

          9  complete picture of this patient's medical history?

 

         10  A.  I reviewed the material that was provided to me.

 

         11  Q.  At least the material that was provided to you did not

 

         12  include any information about previous opiate pain

 

         13  medication?

 

         14  A.  The medical record I got from the care center had

 

         15  medication lists and administration times and nursing

 

         16  signatures.  There were not opiate pain medications there.

 

         17  Q.  And you found this fact, this lack of prior pain

 

         18  medication, the fact that this patient had never had that

 

         19  before, significant enough to include as a separate paragraph

 

         20  in your opinion of your report of autopsy?

 

         21  A.  Previous experience with a narcotic pain medication is

 

         22  important.

 

         23  Q.  That was an important thing for you to know before you

 

         24  went into this autopsy?

 

         25  A.  It has everything to do with assessing one's tolerance to

 

          1  a narcotic pain medication.

 

          2  Q.  Now, you've indicated that you actually did review

 

          3  nursing home records, is that right?

 

          4  A.  I did.

 

          5  Q.  Were you aware that in fact Ms. Crane had been treated

 

          6  previously with morphine for a headache in March of 1994?

 

          7  A.  You know, medication history five years before you die is

 

          8  totally irrelevant with respect to narcotics.

 

          9  Q.  Well, Ms. Crane actually --

 

         10  A.  Or two years before.

 

         11  Q.  Well, you indicated in your opinion that you did not

 

         12  think that Ms. Crane, in essence, had any conditions that

 

         13  would have caused her pain, is that right?

 

         14  A.  I saw no evidence of it.  And in the nursing home records

 

         15  they were not dwelling on the fact that she had pain either.

 

         16  Q.  Despite the fact that apparently she was receiving opiate

 

         17  pain medication for years?

 

         18  A.  Well, based on my experience with people, there are a lot

 

         19  of people in this state who get opiate pain medications, to

 

         20  the point of death, who don't have pain.

 

         21  Q.  So you were unaware that this patient had been treated

 

         22  with eight milligrams of morphine for a headache in March of

 

         23  1994?

 

         24  A.  No.  If she got morphine two years before she died, it's

 

         25  an irrelevant fact.

 

          1  Q.  You certainly would have indicated that prior opiate

 

          2  experience for a patient is important to consider when

 

          3  administering opiate medications?

 

          4  A.  You need to know if your patient is tolerant to that

 

          5  drug.  If they had been getting regular treatments with that

 

          6  drug, it changes their tolerance to the drug.  If you use a

 

          7  lot of opiates, you get less effect for the same amount.

 

          8  Q.  Okay.  So let's say that we don't even consider the

 

          9  morphine that was given.  Let's talk about just opiates just

 

         10  before her admission to the unit.  We talked about the years

 

         11  of records that we have here.  Let's talk about just prior,

 

         12  two months prior.  You've indicated that you did review the

 

         13  nursing home records?

 

         14  A.  I reviewed the records that were given to me, yes.

 

         15  Q.  Okay.  Let's go to state's exhibit 4A.  This is nursing

 

         16  home record page 851.  This is a narcotic record included in

 

         17  the nursing home records from Sandy Regional.  You can step

 

         18  down if you would like to see it better.  This is a

 

         19  prescription for Mary Crane for hydrocodone, which is an

 

         20  opiate based prescription pain medication.  There's a date

 

         21  here of 10/12/95, just two months before her admission to the

 

         22  unit.

 

         23      Do you see here that starting on 10/21, almost on a daily

 

         24  basis, this patient is receiving hydrocodone, or Lortab, for

 

         25  pain?

 

          1  A.  I see that, yes.

 

          2  Q.  And you would have reviewed this at some point, if the

 

          3  state provided it to you, when you made your findings and

 

          4  your conclusions in this case?

 

          5  A.  If they had provided it to me, yes, but I don't have

 

          6  that.  It's not included in the medication records that I

 

          7  have.

 

          8  Q.  Would you disagree, Doctor, that there were certainly

 

          9  symptoms of pain in Mary Crane while she was on the unit?

 

         10  A.  The nursing notes that I read, it was very unclear that

 

         11  she had pain.  The one comment that I remember specifically

 

         12  was the nurse gave her acetaminophen, which is Tylenol, and

 

         13  talked to her for a bit and she seemed to be much better

 

         14  then.

 

         15  Q.  Let's go to the records.  You said you reviewed them and

 

         16  looked at the medical records for the geropsych unit.  Were

 

         17  you aware that when she was assessed -- when she was admitted

 

         18  on December 28th, 1995, they asked Ms. Crane to rate her pain

 

         19  on a one to five scale and she rated it a five?

 

         20  A.  I'm aware that there is one comment in there about pain.

 

         21  Q.  In fact, there are two comments about pain by Mary Crane.

 

         22  Do you recall the second comment?

 

         23  A.  The one that I recall was her statement that says what do

 

         24  you want to have changed, or something like this.  The

 

         25  handwriting is from the person who is doing the assessment.

 

          1  It says pain.

 

          2  Q.  So although you could not in your autopsy see something,

 

          3  some magical thing on the body that would indicate, in your

 

          4  opinion, pain, you do not dispute that at least this patient

 

          5  on admission reported being in pain?

 

          6  A.  My interpretation is this woman was --

 

          7  Q.  I'm asking you if you base -- if you disagree that she

 

          8  reported that she was in pain?

 

          9  A.  I think she probably did say that.

 

         10  Q.  Okay.  Let's go to the nurse's notes and what they

 

         11  observed.  Again, you would have reviewed the nurse's notes

 

         12  and those would have been relevant to your opinion?

 

         13  A.  Correct.

 

         14  Q.  I'll skip over -- we talked about this.  Well, let's go

 

         15  back.  This is part of the rate your pain scale.  I will

 

         16  point out, and you reviewed this record before you made your

 

         17  opinion, but this is a woman with a history of back pain, a

 

         18  hip fracture on the right side, and frequent falls.  So,

 

         19  again, these are all things that certainly could cause pain

 

         20  in this patient?

 

         21  A.  They could.

 

         22  Q.  Let's go to January 3rd, and this is state's exhibit

 

         23  four, med 319.  January 3rd, patient crying out in group,

 

         24  groaning, yelling, grimacing.  Would you agree that those

 

         25  sound like a patient who could be in pain?

 

          1  A.  They could be.

 

          2  Q.  And we'll go to state's four, med 321.  Patient who,

 

          3  although she's already on the Duragesic patch at this time,

 

          4  continues to moan and is given Tylenol that has little

 

          5  effect.

 

          6  A.  That's what it says.

 

          7  Q.  And a patient who says I hurt?

 

          8  A.  That's what it says.

 

          9  Q.  You would have reviewed these as part of your examination

 

         10  and report to the state?

 

         11  A.  I did review these.

 

         12  Q.  We'll go now to 326.  You would agree that after this

 

         13  patient was administered morphine she appeared to get some

 

         14  relief.  The quote is "patient appears more comfortable after

 

         15  receiving morphine."

 

         16  A.  Morphine is a very powerful sedative drug.  It can

 

         17  relieve pain and can also put you to sleep despite your pain,

 

         18  or no pain.

 

         19  Q.  You would agree that one way to tell if someone is in

 

         20  pain is to give them a pain medication and see if they

 

         21  respond?

 

         22  A.  Well, you don't know if it's a therapeutic effect or

 

         23  placebo effect.

 

         24  Q.  The question I have to you is, if a patient -- if you

 

         25  have a patient that is moaning, grimacing, that sort of

 

          1  thing?

 

          2  A.  That's right.  And we have a patient who has Alzheimer's

 

          3  and who is rated as being demented.

 

          4  Q.  And this kind of patient has a difficult time expressing

 

          5  how they hurt or where they hurt or if they hurt?

 

          6  A.  That I don't know for a fact.

 

          7  Q.  But we actually see moaning and grimacing and those are

 

          8  sort of universally accepted symptoms of pain?

 

          9  A.  They are symptoms of a lot of things.

 

         10  Q.  So is it ultimately your opinion that this woman had no

 

         11  pain?

 

         12  A.  I don't know that this proves that she has pain.

 

         13           THE COURT:  That's not the question.

 

         14           THE WITNESS:  She could have pain and it could be a

 

         15  symptom of pain.

 

         16  Q.  (BY MS. ISAACSON)  And you would agree that you were

 

         17  completely oblivious to the fact that at least her previous

 

         18  physicians had treated her with pain medications?

 

         19  A.  I saw Tylenol and that sort of treatment in her nursing

 

         20  home chart.  It was not -- the narcotic pain medications were

 

         21  not included in the records from the nursing home that I had

 

         22  prior to her being admitted to Davis.

 

         23  Q.  The bottom line is that this woman could have died of a

 

         24  number of natural causes?

 

         25  A.  She could have, yes.

 

          1  Q.  And the bottom line is you were unaware of her pain

 

          2  condition and her past pain medication treatment?

 

          3  A.  No.  I am aware that when she came into Davis Hospital

 

          4  pain was added to her diagnosis list.

 

          5  Q.  Ma'am, we've looked at the records.  Do you deny that she

 

          6  was on pain medications, opiate based pain medications, for

 

          7  years prior to being admitted to the unit?

 

          8  A.  No, I'm not denying these records.  These are here.  And

 

          9  this set of records stops in 1994.

 

         10  Q.  Well, we looked together up on the screen at the last two

 

         11  months, and we could go through page by page, but you would

 

         12  agree that there is a record from her nursing home where this

 

         13  is a woman who had been treated with opiates?

 

         14  A.  I agree with that.

 

         15  Q.  And you said before that it's important for you to know,

 

         16  if this woman ultimately gets morphine, as to whether or not

 

         17  she had opiates before, because her -- if she has a tolerance

 

         18  it makes a difference?

 

         19           MR. WILSON:  I'll object.  I think we've been over

 

         20  this territory time and time again.

 

         21           THE COURT:  Overruled.  We need a straight answer.

 

         22  Q.  (BY MS. ISSACSON)  You said in your report that the

 

         23  occurrence of a new condition requiring a narcotic analgesia

 

         24  was not documented?

 

         25  A.  That's true.

 

          1  Q.  A big part of your opinion is, number one, that she's not

 

          2  in pain; and, number two, she had never had anything other

 

          3  than Tylenol.  That's a big part of your opinion, would you

 

          4  agree?

 

          5  A.  No, I wouldn't say that.

 

          6  Q.  Well, let's go through the report, then.  You have two

 

          7  whole sections -- most of the report talks about pain relief

 

          8  was accomplished with nonprescription medication in the

 

          9  convalescent center at which she'd reside?

 

         10  A.  That's what is documented in the records that I have.

 

         11  Q.  And you were wrong?

 

         12  A.  Well, then you would have to say that the records I have,

 

         13  which are her day to day medical records where the nurses are

 

         14  noting what they give her, are wrong.

 

         15  Q.  The state didn't give you the record of her prior opiate

 

         16  use, did not provide that information to you?

 

         17  A.  Okay.  So she's getting two Lortabs a day according to

 

         18  the records that you gave me.

 

         19  Q.  The state did not inform you that this woman had been on

 

         20  opiates for years prior to her admission?

 

         21  A.  That's true.

 

         22  Q.  And you were wrong in your report when you said she'd

 

         23  only been treated with nonprescription pain medication?  You

 

         24  were wrong?

 

         25  A.  That's right.  That's true, then.

 

          1  Q.  And although you say there's no new condition requiring

 

          2  narcotic analgesics, that's based upon your assumption that

 

          3  she'd never been treated with narcotics before?

 

          4  A.  No.  We're talking about the medical history once she got

 

          5  into Davis Hospital, a new condition.

 

          6  Q.  But you have indicated and it is part -- you agree that

 

          7  if someone is on opiates before, then it's a different

 

          8  analysis if she's given opiates when she's there on the unit?

 

          9  A.  It has to do with her tolerance and her ability to

 

         10  withstand the sedating and respiratory depressing effects of

 

         11  those drugs.

 

         12  Q.  And although you could not see a new condition in the

 

         13  autopsy, you would agree that in the chart notes and in the

 

         14  report from the patient there are symptoms of pain?  There

 

         15  are reports of pain and observations of behaviors consistent

 

         16  with pain?

 

         17  A.  There are.

 

         18  Q.  And that pain was treated?

 

         19  A.  Those same observations of moaning and groaning were

 

         20  present in Sandy.  I don't know that that's new.

 

         21  Q.  And those symptoms, the moaning, the groaning, were

 

         22  alleviated when morphine was administered to this patient?

 

         23  A.  That's true.

 

         24           MS. ISSACSON:  I have nothing further.

 

         25           THE COURT:  Redirect.

 

          1           MR. WILSON:  Just a couple of questions.

 

          2                     REDIRECT EXAMINATION

 

          3  BY MR. WILSON:

 

          4  Q.  You skated that there were two Duragesic patches which

 

          5  were located on the back of this body, is that correct?

 

          6  A.  Yes.

 

          7  Q.  Can you tell us the dosage on those patches?

 

          8  A.  Umm, one of them was labeled 50 micrograms per hour and

 

          9  the other one was labeled 25 micrograms per hour.

 

         10  Q.  Can you characterize for us, Doctor, in your experience

 

         11  the strength of those dosages?

 

         12           MS. ISSACSON:  Objection.  Beyond the scope of

 

         13  cross.

 

         14           THE COURT:  Overruled.

 

         15           THE WITNESS:  25 micrograms per hour is the starting

 

         16  dose.  The doses at which the drugs increase are at 25 -- I

 

         17  think at 25 microgram increments.  I think a hundred is the

 

         18  largest that is made.

 

         19  Q.  (BY MR. WILSON)  Okay.  Now, assume, if you would, that

 

         20  the evidence shows that there was an average of one Lortab or

 

         21  Hy-Phen that was administered to Mary Crane over the last two

 

         22  months that she was in the nursing home prior to entering the

 

         23  geropsych unit.  Can you tell us, Doctor, would that -- and

 

         24  these were five milligram tablets.  Can you tell us would

 

         25  that change your opinion in any way as relates to your

 

          1  autopsy findings?

 

          2  A.  No.

 

          3  Q.  And why is that, Doctor?

 

          4  A.  First of all, that's a fairly low dose of hydrocodone.

 

          5  And being given on a regular basis like that it doesn't -- if

 

          6  she's been given it years on end, there's no evidence that

 

          7  she's accelerating her use of it.  She's not getting

 

          8  tolerant.  She's not metabolizing the drug and getting less

 

          9  effect, if they're able to accomplish what they want with

 

         10  just the same dose for years on end.  And when she was

 

         11  admitted to Davis she was getting Fentanyl, which is a much

 

         12  more potent drug.  She was being given morphine by injection.

 

         13  This is a very accelerated rate of administration of

 

         14  narcotics.

 

         15           MR. WILSON:  Thank you.  Nothing further.

 

         16           MS. ISSACSON:  Nothing further, Your Honor.

 

         17           THE COURT:  You may step down, Doctor.  Thank you

 

         18  for testifying.  May this witness be excused?

 

         19           MR. WILSON:  We would so request, Your Honor.

 

         20           MS. ISSACSON:  No objection.

 

         21           THE COURT:  You are excused.  Thank you.

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