Rebuttal - Bonnie Hardey

13                        BONITA HARDEY,
      14           CALLED BY THE PLAINTIFF, HAVING BEEN DULY
      15         SWORN, WAS EXAMINED AND TESTIFIED AS FOLLOWS:
      16                      DIRECT EXAMINATION
      17    BY MS. BARLOW:
      18    Q.  GOOD MORNING.
      19    A.  GOOD MORNING.
      20    Q.  WOULD YOU STATE YOUR NAME AGAIN FOR THE RECORD.
      21    A.  BONITA HARDEY.
      22    Q.  AND YOU'VE BEEN HERE AND TESTIFIED PREVIOUSLY TO THIS;
      23    IS THAT CORRECT?
      24    A.  YES.
      25    Q.  I'LL REMIND YOU THAT YOU ARE STILL UNDER OATH.


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       1    A.  OKAY.
       2    Q.  MISS HARDEY, HAVE YOU HAD OCCASION TO REVIEW WHAT DAYS
       3    YOU WORKED AT THE DAVIS NORTH HOSPITAL BETWEEN DECEMBER 6,
       4    1995 AND JANUARY 14 OF 1996?
       5    A.  NOT A WHOLE BUNCH.
       6    Q.  WOULD YOU PULL OUT JUDITH LARSEN'S BINDER THERE.  WOULD
       7    YOU EITHER MAKE NOTES OR AT LEAST SIGN YOUR NAME ON THE
       8    NURSING NOTE FOR DAYS THAT YOU WOULD HAVE WORKED DURING THAT
       9    TIME PERIOD?
      10    A.  YES.
      11    Q.  MAYBE, IF WE CAN START WITH 524, WHICH IS THE ADMIT.  I
      12    BELIEVE THIS IS THE 6TH OF DECEMBER.  DID YOU WORK THAT DAY?
      13    A.  NO.
      14    Q.  WHAT ABOUT THE NEXT PAGE, 525?
      15    A.  OKAY.  YES, THAT'S MY SIGNATURE.
      16    Q.  WHAT SHIFT DID YOU WORK?  THAT APPEARS TO BE THE 6TH OF
      17    DECEMBER.  ITS CUT OFF AT THE TOP...
      18    A.  YES.  I WORKED A THREE UNTIL 11 SHIFT.
      19    Q.  THREE UNTIL 11:00 P.M.?
      20    A.  YES.
      21    Q.  THE 7TH DID YOU WORK?
      22    A.  NO.
      23    Q.  HOW ABOUT THE 8TH?
      24    A.  NO.
      25    Q.  THE 9TH?


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       1    A.  NO.
       2    Q.  WELL, MAYBE WE BETTER HAVE YOU JUST KIND OF LOOK THROUGH
       3    AND SEE WHAT'S THE NEXT DAY THAT YOU WORKED?
       4    A.  IT LOOKS LIKE THE 11TH.
       5    Q.  AND WHAT SHIFT DID YOU WORK THEN?
       6    A.  THREE TO 11.
       7    Q.  AND WHAT'S THE NEXT DAY THAT YOU WORKED?
       8    A.  THE 12TH.
       9    Q.  AND WHAT SHIFT?
      10    A.  THREE TO 11.
      11    Q.  AND THE NEXT DAY?
      12    A.  THE 13TH, THREE TO 11.
      13    Q.  AND THE NEXT DAY?
      14    A.  THE 16TH.
      15    Q.  WHICH SHIFT?
      16    A.  SEVEN TO THREE.  AND THEN ON THE 17TH --
      17    Q.  EXCUSE ME.  I'M SORRY.  I DIDN'T HEAR THE SHIFT ON THE
      18    16?
      19    A.  SEVEN TO THREE, A MORNING SHIFT.
      20    Q.  SEVEN TO THREE IN THE MORNING.  AND THE 17TH, YOU SAY?
      21    A.  THE 17TH, YES.
      22    Q.  WHAT SHIFT?
      23    A.  THAT WOULD BE A MORNING SHIFT.  AND THEN THE 19TH, A
      24    THREE TO 11 SHIFT.  THE 20TH, A THREE TO 11 SHIFT.  THE
      25    24TH, THREE TO 11 SHIFT.  THE 25TH, A MORNING SHIFT, THREE


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       1    TO 11.
       2    Q.  YOU SAY MORNING SHIFT?
       3    A.  I MEAN A SEVEN TO THREE.
       4    Q.  SEVEN TO THREE.
       5    A.  THE 26TH, THE THREE TO 11 SHIFT.  THE 27TH, A MORNING
       6    SHIFT, SEVEN TO THREE.  THE 30TH, A MORNING SHIFT.  THE
       7    31ST, A MORNING SHIFT.  THE 1ST, A MORNING SHIFT.  THE 2ND,
       8    A THREE TO 11 SHIFT.  THE 3RD, A THREE TO 11 SHIFT.
       9    Q.  I BELIEVE THAT'S THE LAST OF THE RECORDS FOR MISS
      10    LARSEN.  DURING THAT TIME PERIOD DO YOU RECALL DR. WEITZEL
      11    COMING TO VISIT JUDITH LARSEN?
      12    A.  I RECALL ONE PARTICULAR NIGHT, THE NIGHT THAT WE --
      13             MR. STIRBA:  I'M GOING TO OBJECT.  IT'S BEYOND THE
      14    SCOPE OF WHAT HER QUESTION WAS.
      15    Q.  (BY MS. BARLOW)  DO YOU REMEMBER DURING THESE TIME
      16    PERIODS THAT YOU WERE ON SHIFT?
      17    A.  YES, I DO.
      18    Q.  WHAT TIME OF DAY WOULD DR. WEITZEL COME IN TO SEE THE
      19    PATIENTS?
      20    A.  THIS ONE TIME WAS 11:00 O'CLOCK AT NIGHT.
      21             MS. BARLOW:  YOUR HONOR, SHE RECALLS A SPECIFIC
      22    DAY.
      23             MR. STIRBA:  IF THAT'S ALL SHE REMEMBERS, THAT'S
      24    ALL SHE CAN TESTIFY TO.
      25    Q.  (BY MS. BARLOW)  DO YOU RECALL ANY OTHER DATES AND WHAT


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       1    TIME HE WOULD COME IN --
       2             THE COURT:  ARE YOU TALKING ABOUT DECEMBER 6
       3    THROUGH JANUARY 3RD?
       4             MS. BARLOW:  I AM.
       5    Q.  (BY MS. BARLOW)  -- DURING THIS TIME PERIOD TO SEE
       6    JUDITH LARSEN?
       7    A.  DURING THIS SPECIFIC TIME I JUST RECALL ONE DATE THAT I
       8    CAN SAY YES FOR SURE AND THAT WAS AT 11:00 O'CLOCK.
       9    Q.  11:00 O'CLOCK?
      10    A.  AT NIGHT.
      11    Q.  DO YOU RECALL ANY OTHER SPECIFIC TIMES WITH ANY OF THE
      12    OTHER PATIENTS WHEN DR. WEITZEL CAME?
      13             MR. STIRBA:  I'M GOING TO OBJECT.  FOUNDATION, YOUR
      14    HONOR.
      15             MS. BARLOW:  WELL, IT'S BROAD, AND THEN IF SHE
      16    DOESN'T RECALL ANY OR IF SHE RECALLS SOME, I'LL ASK HER.
      17             THE COURT:  ALL RIGHT.  GO AHEAD.
      18             THE WITNESS:  I WORKED THREE UNTIL 11 AND HE WOULD
      19    COME IN ON THAT SHIFT WITH OTHER PATIENTS, YES.
      20    Q.  (BY MS. BARLOW)  DURING THE TIME PERIOD WE'RE TALKING
      21    ABOUT HERE, DECEMBER 6 TO JANUARY 4?
      22    A.  DURING DECEMBER, YES, HE WOULD COME.
      23    Q.  THREE TO 11, WHAT TIME DURING THAT SHIFT WOULD HE COME?
      24             MR. STIRBA:  YOUR HONOR, I'M GOING TO OBJECT.
      25             THE COURT:  LET'S HAVE SOME FOUNDATION.


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       1    Q.  (BY MS. BARLOW)  DO YOU RECALL ANY SPECIFIC DAYS?
       2    WE'VE GOT THESE TIMES THAT YOU WORKED THREE TO 11?
       3    A.  RIGHT.
       4    Q.  OKAY.  DO YOU RECALL ANY OTHER SPECIFIC DAYS OF HIM
       5    COMING IN DURING THAT THREE TO 11 SHIFT?
       6    A.  A SPECIFIC DATE WITH JUDITH LARSEN, I DO, A SPECIFIC
       7    DATE.
       8    Q.  DO YOU RECALL ANY OTHER SPECIFIC DATES WITH ANY OF THE
       9    OTHER PATIENTS?
      10    A.  NO.
      11    Q.  THIS THREE TO 11 SHIFT, DO YOU RECALL APPROXIMATELY WHAT
      12    TIME DR. WEITZEL WOULD COME IN DURING THIS TIME PERIOD ON
      13    THAT SHIFT?
      14             MR. STIRBA:  I'M GOING TO OBJECT.  IRRELEVANT.
      15             THE COURT:  SUSTAINED.
      16             MS. BARLOW:  YOUR HONOR, WITH THAT I HAVE NO
      17    FURTHER QUESTIONS.
      18             THE COURT:  ANY CROSS-EXAMINATION?
      19             MR. STIRBA:  NO QUESTIONS, YOUR HONOR.
      20             THE COURT:  MAY THIS WITNESS BE EXCUSED?
      21             MS. BARLOW:  SHE MAY BE EXCUSED, YOUR HONOR.

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