Robert Bitner, MD

17                      ROBERT FELT BITNER,
      18    BEING FIRST DULY SWORN, WAS EXAMINED AND TESTIFIED
      19    AS FOLLOWS:
      20                      DIRECT EXAMINATION
      21    BY MR. WILSON:
      22    Q.  DR. BITNER, COULD YOU STATE YOUR FULL NAME FOR THE
      23    RECORD, PLEASE?
      24    A.  ROBERT FELT BITNER.
      25    Q.  AND ARE YOU CURRENTLY EMPLOYED IN ANY PROFESSION?


                                                                       1142



       1    A.  I'M RETIRED.  I WAS A PHYSICIAN AT THE TANNER MEMORIAL
       2    CLINIC FOR 43 YEARS.
       3    Q.  OKAY.
       4    A.  RETIRED ABOUT FIVE YEARS AGO.
       5    Q.  RETIRED ABOUT FIVE YEARS AGO?
       6    A.  YES.
       7    Q.  SO YOU WERE WORKING AT TANNER MEMORIAL CLINIC BACK IN
       8    1995 AND EARLY '96?
       9    A.  YES.
      10    Q.  DID YOU HAVE -- WELL, WHEN DID YOU GRADUATE FROM MEDICAL
      11    SCHOOL, DOCTOR?
      12    A.  1951, UNIVERSITY OF UTAH.
      13    Q.  OKAY.  AND HOW LONG HAVE YOU BEEN IN PRACTICE SINCE THAT
      14    TIME?
      15    A.  FORTY-THREE YEARS.
      16    Q.  OKAY.  DO YOU HAVE ANY BOARD CERTIFICATIONS?
      17    A.  NO.  I -- I HAD -- I WAS CONSIDERED BOARD ELIGIBLE IN
      18    INTERNAL MEDICINE.  I INTERNED IN A ROTATING INTERNSHIP IN
      19    CONNECTICUT, AND THEN LATER WENT TO NEW YORK CITY FOR A
      20    RESIDENCY IN INTERNAL MEDICINE.  AND THEN RETURNED TO SALT
      21    LAKE.
      22    Q.  OKAY.  SO HOW LONG HAVE YOU PRACTICED IN UTAH?
      23    A.  WELL, I'VE BEEN AT THE -- I'VE BEEN AT THE CLINIC SINCE
      24    THE -- FOR THE 43 YEARS I'VE BEEN IN PRACTICE.
      25    Q.  FOR 43 YEARS?


                                                                       1143



       1    A.  YES.
       2    Q.  OKAY.  HOW LONG HAS THAT BEEN WITH TANNER MEMORIAL
       3    CLINIC?
       4    A.  THE SAME FOR ALL THAT TIME.
       5    Q.  AND HAVE YOU SPECIALIZED IN ANY PARTICULAR AREA IN YOUR
       6    PRACTICE?
       7    A.  YES.  INTERNAL MEDICINE AND CARDIOLOGY.  AT THE TIME I
       8    FIRST CAME HERE WITH THIS BACKGROUND OF TRAINING, IT WAS
       9    NECESSARY THAT WE KNOW JUST ABOUT EVERYTHING ON EVERY
      10    SPECIALTY.  IT WASN'T HIGHLY CHANNELLED LIKE IT IS NOW.
      11    Q.  OKAY.  JUST A MINUTE, DOCTOR.  LET ME GRAB AN EXHIBIT
      12    HERE.
      13             MR. MAY:  DO YOU NEED THE ELMO?
      14             MR. WILSON:  WELL, I'LL SEE.
      15    Q.  (BY MR. WILSON)  I'M HANDING YOU -- EXCUSE ME -- WHAT'S
      16    MARKED AS STATE'S EXHIBIT NUMBER 4.  THIS DOCUMENT -- OR
      17    THIS LOOSELEAF CONTAINS THE MEDICAL RECORD OF A PATIENT BY
      18    THE NAME OF LYDIA SMITH WHO WAS ADMITTED TO THE GEROPSYCH
      19    UNIT AT THE DAVIS HOSPITAL BACK IN DECEMBER OF 1995.  ARE
      20    YOU ACQUAINTED WITH THAT PATIENT -- OR DID YOU HAVE ANYTHING
      21    TO DO WITH THAT PATIENT?  I'LL PUT IT THAT WAY.
      22    A.  YES, I DID.
      23    Q.  DO YOU RECALL WHAT YOUR INVOLVEMENT WITH THE PATIENT
      24    WAS?
      25    A.  HONESTLY I DIDN'T AT THE TIME I RECEIVED THE -- THE


                                                                       1144



       1    REQUEST TO APPEAR HERE, BUT IN LOOKING BACK ON THE NOTE THAT
       2    I MADE AT THAT TIME, I -- MY MEMORY RETURNED PRETTY WELL.
       3    Q.  SO YOU DID HAVE AN OPPORTUNITY TO REVIEW YOUR NOTE AS IT
       4    RELATED TO THE PATIENT LYDIA SMITH?
       5    A.  YES.
       6    Q.  OKAY.  AND I WANT YOU TO TURN IN THAT PARTICULAR EXHIBIT
       7    TO A -- THERE'S A PAGING SYSTEM AT THE BOTTOM THAT SAYS
       8    M-E-D, AND IT'S 00703, IF YOU COULD FIND THAT, PLEASE.
       9    A.  AT THE BOTTOM?
      10             MR. WILSON:  MAY I?
      11             THE COURT:  YES.
      12             MR. WILSON:  THANK YOU.  LET'S SEE IF I CAN FIND IT
      13    THERE.
      14    Q.  (BY MR. WILSON)  DOES THAT APPEAR TO BE THE NOTE THAT
      15    YOU REFERENCED THAT YOU HAD REVIEWED PRIOR TO COMING HERE TO
      16    COURT TODAY?
      17    A.  YES, SIR.
      18    Q.  OKAY.  NOW, DID YOU HAVE PRIVILEGES AT THE HOSPITAL,
      19    DAVIS HOSPITAL?
      20    A.  YES.
      21    Q.  OKAY.  AND AT THIS TIME WERE YOU DOING ANY WORK AS A
      22    CONSULTANT AT THE HOSPITAL?
      23    A.  I WAS ON THE STAFF AS AN INTERNIST, INTERNAL MEDICINE.
      24    Q.  OKAY.
      25    A.  AND CARDIOLOGY AS A SECONDARY.  AND BEING ON THE STAFF I


                                                                       1145



       1    HAD SOME OBLIGATION TO RESPOND TO REQUESTS FOR CONSULT.
       2    Q.  OKAY.  DID YOU HAVE OCCASION IN -- IN THAT CAPACITY TO
       3    DO ANY EVALUATIONS FOR PATIENTS WHO WERE BEING ADMITTED TO
       4    THE GEROPSYCH UNIT ON THE HOSPITAL?
       5    A.  YEAH.  THE PROCEDURE AT THAT TIME, AND I'M -- MAYBE IT'S
       6    THAT WAY STILL -- WAS THAT IF THERE WAS AN ADMISSION TO THE
       7    GEROPSYCHIATRIC WARD BY A PSYCHIATRIST THAT THEY ASKED ONE
       8    OF THE AVAILABLE INTERNISTS TO SEE THE PATIENT AND EXAMINE
       9    THE PATIENT, LEAVE A HISTORY THAT'S AVAILABLE.  AND THEN
      10    THIS WAS FOR THE PURPOSE OF DETERMINING WHETHER IT WAS
      11    APPROPRIATE THAT THAT PATIENT BE MANAGED ON THIS FACILITY,
      12    FROM A MEDICAL STANDPOINT.
      13    Q.  AND DID YOU DO SUCH AN EVALUATION AS IT RELATED TO LYDIA
      14    SMITH?
      15    A.  YES, SIR, I DID.
      16    Q.  OKAY.  CAN YOU TELL THE JURY HOW YOU CONDUCTED THAT
      17    PARTICULAR EVALUATION?  FIRST OF ALL, AS TO WHAT DATE DID
      18    YOU CONDUCT THE EVALUATION?  DO YOU REMEMBER?
      19    A.  YES.  IT WAS THE 20TH OF DECEMBER IN '95.
      20    Q.  OKAY.  DID YOU SUBSEQUENTLY -- WELL, DO YOU REMEMBER
      21    WHAT TIME OF THE DAY OR DOES THAT REFLECT -- IS THAT
      22    REFLECTED IN THE NOTE?
      23    A.  IT WAS -- IT WAS DURING -- IT WAS DURING THE DAY.  AS
      24    FAR AS I KNOW, IT WAS IN THE MORNING TIME.
      25    Q.  OKAY.


                                                                       1146



       1    A.  I THINK I WAS MAKING ROUNDS AND THEY CALLED ME THAT I
       2    HAD A -- A DUTY TO PERFORM AND SO I RESPONDED.
       3    Q.  SO IN -- IN MAKING YOUR EVALUATION, DO YOU GO THROUGH A
       4    CERTAIN PROCESS?
       5    A.  YES, I -- I SAW THE -- THE PATIENT, WAS INTRODUCED TO
       6    HER BY THE NURSES AND --
       7    Q.  DO YOU HAVE ANY RECORD --
       8    A.  -- WITH THE IDEA OF DOING -- OF OBTAINING A HISTORY, AN
       9    IDEA OF WHAT THE PROBLEM WAS, AND A PHYSICAL EXAMINATION AND
      10    THEN LEAVING A RECORD OF WHAT MY FINDINGS WERE.
      11    Q.  WELL, ON THIS PARTICULAR DATE DO YOU HAVE A RECOLLECTION
      12    NOW, AFTER REVIEWING THE NOTES, AS TO WHAT OCCURRED ON THIS
      13    PARTICULAR DAY?
      14    A.  YES, I DO.  IT WAS --
      15    Q.  OKAY.  CAN YOU TELL US WHEN YOU MET THIS PATIENT WHAT IF
      16    ANYTHING OCCURRED IN -- IN THE CONTEXT OF THAT MEETING?
      17    A.  SHE WAS -- THIS WAS VERY UNUSUAL IN THAT SHE WAS VERY
      18    DISTURBED AND -- AND CONFUSED AND TOTALLY UNCOOPERATIVE.
      19    AND I EXPECTED THAT I MIGHT BE ABLE TO SIT DOWN WITH HER
      20    AND -- AND GET HER CALMED DOWN AND MAYBE BE ABLE TO GET SOME
      21    EVALUATION OF HER -- OF HER MEDICAL SITUATION, OF HER
      22    PHYSICAL SITUATION.
      23    Q.  DO YOU REMEMBER WHETHER OR NOT SHE WAS ABLE TO
      24    COMMUNICATE WITH YOU IN ANY FASHION?
      25    A.  SHE LET ME KNOW RIGHT OFF THAT SHE DIDN'T WANT ME TO


                                                                       1147



       1    TOUCH HER.
       2    Q.  OKAY.
       3    A.  AND --
       4    Q.  WAS THAT COMMUNICATED VERBALLY OR WAS THAT COMMUNICATED
       5    IN ANOTHER FASHION?
       6    A.  WELL, SHE KICKED THE NURSE AND PINCHED THE NURSE WHILE I
       7    WAS THERE, AND THE NURSES THAT WERE TRYING TO SORT OF HELP
       8    ME ACCOMPLISH WHAT I WAS SUPPOSED TO DO.  AND WE WERE TRYING
       9    TO GET HER CALMED DOWN SO THAT I COULD OBTAIN SOMETHING
      10    SPECIFIC TO FULFILL MY PART OF THE -- OF THE ASSIGNMENT.
      11    Q.  OKAY.
      12    A.  SHE -- SHE TALKED, BUT GARBLED.  I COULDN'T ALWAYS
      13    UNDERSTAND WHAT SHE WAS -- SHE WASN'T -- SHE WASN'T TALKING
      14    IN AN ORDERLY WAY.  SHE WAS -- I FELT THAT SHE WAS DEMENTED.
      15    Q.  OKAY.
      16    A.  AND SHE WAS NOT FUNCTIONING MENTALLY AT ALL LIKE I WOULD
      17    LIKED TO HAVE HAD HER FOR MY PURPOSES.
      18    Q.  TURN TO PAGE TWO OF YOUR NOTE, IF YOU WOULD, PLEASE.
      19    YOU HAVE A NOTE THERE RELATED TO PHYSICAL EXAMINATION.  WERE
      20    YOU, IN FACT, ABLE TO CONDUCT A PHYSICAL EXAMINATION ON THIS
      21    PATIENT?
      22    A.  NOT REALLY.  ORDINARILY WITH A PHYSICAL EXAMINATION YOU
      23    EXAMINE THEM CLOSELY:  HEART, LUNGS, EYES, EARS, NOSE AND
      24    THROAT, FUNCTION OF THE BODY GENERALLY, AND I -- I REALLY
      25    COULDN'T ACCOMPLISH THAT AT ALL OTHER THAN TO OBSERVE HOW


                                                                       1148



       1    SHE WAS MOVING AROUND AND -- AND ABLE TO --
       2    Q.  OKAY.  WOULD YOU READ YOUR -- YOUR NOTE UNDER PHYSICAL
       3    EXAMINATION AS TO YOUR GENERAL IMPRESSION AS TO HER PHYSICAL
       4    EXAM?
       5    A.  PHYSICALLY -- PHYSICALLY SHE APPEARS TO BE FRAIL, BUT IS
       6    STRONG ENOUGH TO GET UP AND WALK AROUND, ESPECIALLY WITH
       7    HELP.  SHE SHOWS EVIDENCE OF WEIGHT LOSS.  SHE IS VERY THIN,
       8    BUT IN GENERAL SHE IS QUITE FUNCTIONAL.  BLOOD PRESSURE
       9    RECORDED BY THE NURSE IS 130/60 WITH A PULSE OF 80 THAT IS
      10    REGULAR.
      11    Q.  SO HER BLOOD PRESSURE WAS -- WAS WITHIN THE NORMAL
      12    RANGE?
      13    A.  YES.
      14    Q.  OKAY.  OTHER THAN WHAT YOU HAD READ ABOUT HER PAST
      15    HISTORY AND PAST MEDICATIONS AND WHAT YOU'D RECEIVED AS TO
      16    THE BLOOD PRESSURE REPORT, WERE THERE ANY OTHER TESTS THAT
      17    YOU REVIEWED IN ORDER TO FORM ANY DIAGNOSTIC OPINION AS TO
      18    THIS PATIENT?
      19    A.  I -- I REVIEWED THE -- THE -- THE SERIES OF VITAL SIGNS
      20    THAT WERE TAKEN:  TEMPERATURE, RESPIRATION, BLOOD PRESSURE,
      21    PULSE, AND SO ON, AND THAT -- I OBSERVED THAT THERE WERE
      22    LABORATORY WORK THAT HAD BEEN REQUESTED.  AND I DON'T
      23    REMEMBER WHEN I SAW THE LABORATORY WORK, BUT I FOUND THAT IT
      24    WAS REASONABLY WITHIN NORMAL LIMITS.
      25    Q.  DID YOU REVIEW THE MEDICATIONS THAT SHE HAD BEEN ON?


                                                                       1149



       1    A.  YES, SIR.
       2    Q.  DO YOU KNOW WHETHER OR NOT SHE'D STARTED RECEIVING ANY
       3    MEDICATIONS AT THE HOSPITAL ITSELF?
       4    A.  I UNDERSTOOD THAT SHE HAD.  I'M NOT SURE THE TIMING ON
       5    THAT.
       6    Q.  ALL RIGHT.
       7    A.  WOULD HAVE TO BE --
       8    Q.  CAN YOU TELL US WHETHER OR NOT IN -- IN YOUR OPINION --
       9    YOU FORMED ANY OPINION AS TO WHETHER OR NOT THIS PATIENT WAS
      10    SUFFERING FROM ANY KIND OF PAIN?
      11    A.  SHE DIDN'T INDICATE TO ME THAT -- BY HER MOVEMENTS OR
      12    ACTIVITY THAT SHE WAS IN ANY PAIN AT ALL.   Nor that she wasn't.
      13    Q.  OKAY.  LOOKING DOWN FURTHER ON YOUR DIAGNOSTIC SECTION
      14    OF THE EXAM YOU INDICATE ARTERIOSCLERO -- BETTER HAVE -- I
      15    BETTER HAVE YOU READ THE NOTE.
      16    A.  ARTERIOSCLEROTIC CARDIOVASCULAR DISEASE, ESPECIALLY
      17    CEREBRAL ARTERIOSCLEROSIS.
      18    Q.  OKAY.  AND WHAT WAS THAT DIAGNOSIS FORMED ON?  I MEAN,
      19    WHAT -- WHAT DID YOU USE TO MAKE THAT PARTICULAR DIAGNOSIS?
      20    A.  I THINK PRIMARILY HER HISTORY, AND ALSO SHE WAS
      21    RECEIVING TREATMENT FOR HYPERTENSION -- FOR HIGH BLOOD
      22    PRESSURE, AND ALSO OTHER MEDICATION THAT WAS DIRECTED
      23    TOWARDS MANAGEMENT OF THE -- THE HEART FUNCTION.
      24    Q.  IN YOUR RECOMMENDATIONS YOU INDICATE GENERAL CARE AS
      25    OUTLINED AS FAR AS NUTRITION AND MEDICATIONS AND JUST


                                                                       1150



       1    GENERAL SUPPORTIVE CARE.
       2    A.  YES, SIR.
       3    Q.  OKAY.  DID YOU SEE THAT THIS PATIENT WAS SUFFERING FROM
       4    ANY KIND OF AN ACUTE ILLNESS AT THAT POINT?
       5    A.  OTHER THAN HER DEMENTIA, NO.
       6    Q.  OKAY.  DID YOU HAVE ANYTHING FURTHER TO DO WITH THE
       7    PATIENT, DOCTOR, AFTER THAT PARTICULAR DAY?
       8    A.  NO, SIR.
       9    Q.  OKAY.
      10             MR. WILSON:  I HAVE NO FURTHER QUESTIONS.
      11             THE COURT:  OKAY.  MR. STIRBA?
      12                       CROSS-EXAMINATION
      13    BY MR. STIRBA:
      14    Q.  DOCTOR, GOOD MORNING.  YOU DO HAVE -- UNDER DIAGNOSIS
      15    YOU DO HAVE ARTERIOSCLEROTIC CARDIOVASCULAR DISEASE; IS THAT
      16    RIGHT?
      17    A.  YES, SIR.
      18    Q.  DO YOU CONSIDER THAT A SERIOUS MEDICAL CONDITION?
      19    A.  YES, SIR.
      20    Q.  AND CERTAINLY THAT'S A MEDICAL CONDITION THAT COULD END
      21    UP IN DEATH; IS THAT TRUE?
      22    A.  THE COMPLICATIONS OF THAT MAY CAUSE DEATH, YES.
      23    Q.  AND WOULD THE SAME BE WITH CEREBRAL ARTERIOSCLEROSIS?
      24    WOULD THAT ALSO BE A SERIOUS MEDICAL CONDITION?
      25    A.  YES, SIR.


                                                                       1151



       1    Q.  AND COULD THAT ALSO END UP IN DEATH OR THE COMPLICATIONS
       2    THEREFROM?
       3    A.  YES.
       4    Q.  NOW, YOU HAVE -- YOU HAVE YOUR REPORT IN FRONT OF YOU,
       5    DO YOU NOT?
       6    A.  YES, UH-HUH.
       7    Q.  I MEAN, THIS IS NOT A MEMORY TEST HERE.
       8    A.  THANK YOU.
       9    Q.  YOU'RE WELCOME.  IF YOU LOOK AT THE TOP IT SAYS ADMIT,
      10    AND IT HAS 12/20/95.  DO YOU SEE THAT?
      11    A.  YES.
      12    Q.  DO YOU RECALL IS THAT THE DATE WHEN YOU CONDUCTED YOUR
      13    EXAMINATION?
      14    A.  YES, BUT I -- I UNDERSTOOD THAT SHE WAS ADMITTED THE DAY
      15    BEFORE.
      16    Q.  OKAY.  BUT THE DATE AT LEAST WHEN YOU DID YOUR
      17    EXAMINATION YOU RECALL BEING 12/20/95?
      18    A.  YES, SIR.
      19    Q.  AND THEN IF YOU GO TO THE -- PAGE 2, DOWN AT THE
      20    LEFT-HAND CORNER OF THE DOCUMENT YOU'LL SEE THERE IS SOME
      21    INITIALS APPARENTLY FOR SOMEBODY WHO WAS INVOLVED IN
      22    TRANSCRIBING YOUR DICTATED NOTE.  AND THERE'S A "D" AND THAT
      23    STANDS FOR DICTATION, RIGHT?
      24    A.  YES, THAT'S RIGHT.
      25    Q.  AND THEN THERE'S A DATE, 12/21/95, AND THEN IT APPEARS


                                                                       1152



       1    TO BE 1310 HOURS.  DO YOU SEE THAT?
       2    A.  UH-HUH.  YES.
       3    Q.  NOW, WOULD THAT HAVE BEEN THE -- THE ACTUAL DATE WHEN
       4    YOU DICTATED THIS NOTE?
       5    A.  IT PROBABLY WAS, ALTHOUGH --
       6    Q.  SO THAT --
       7    A.  ALTHOUGH THE PRACTICE AT THAT TIME AFTER SEEING THE
       8    PATIENT WAS TO DICTATE IT THEN.  AND I CAN'T TELL YOU FOR
       9    SURE.
      10    Q.  SURE.  BUT AT LEAST AS FAR AS -- AS WHAT YOU HAVE IN
      11    FRONT OF YOU, IT -- AT LEAST IT APPEARS THAT IT WAS DICTATED
      12    ON 12/21/95 AND TRANSCRIBED ON 12/21/95.
      13    A.  THAT'S WHAT IT LOOKS LIKE, YES, SIR.
      14    Q.  AND IT'S TRUE, IS IT NOT, DOCTOR, THAT THERE'S --
      15    THERE'S -- THAT'S NOT AN UNUSUAL PRACTICE IN THE MEDICAL
      16    PROFESSION WERE YOU MIGHT HAVE TO DICTATE SOMETHING THE NEXT
      17    DAY?
      18    A.  IT DOES HAPPEN, YES, SIR.
      19    Q.  AND, IN FACT, WASN'T -- WASN'T THERE -- DO YOU RECALL
      20    WHETHER THERE WAS A REQUIREMENT OR AN EXPECTATION THAT FOLKS
      21    LIKE YOU, INTERNAL MEDICINE DOCTORS --
      22    A.  UH-HUH.
      23    Q.  -- WOULD SEE THE PATIENTS ADMITTED TO THE UNIT WITHIN 24
      24    HOURS AFTER ADMISSION?
      25    A.  I DON'T RECALL ANYTHING TO THAT EFFECT, BUT I THINK IT


                                                                       1153



       1    WAS EXPECTED THAT WE WOULD -- WE WOULD DO IT AS -- AT THE
       2    TIME THAT WE WERE CALLED.
       3    Q.  NOW, ONCE AGAIN YOUR -- YOUR REPORT -- JUST A FEW
       4    THINGS, IF YOU COULD GO BACK TO PAGE 1, PLEASE.
       5    A.  OKAY.
       6    Q.  AND UNDER PAST HISTORY YOU STATE IN THAT SECOND
       7    PARAGRAPH:  SHE IS TOTALLY UNCOOPERATIVE OTHER THAN TO VOICE
       8    SOME RESENTMENT IN A KIND OF GARBLED FASHION THAT I DO NOT
       9    UNDERSTAND.
      10         DID I READ THAT CORRECTLY?
      11    A.  YES.
      12    Q.  AND THEN THE NEXT SENTENCE YOU SAY:  HER FAMILY IS
      13    INTERESTED IN HER CARE, BUT APPARENTLY NOT TO THE POINT OF
      14    BEING ABLE TO HELP OR KNOW WHAT TO DO.
      15         DID I READ THAT CORRECTLY?
      16    A.  YES.
      17    Q.  AND THEN IF YOU'LL GO TO THE NEXT PAGE, YOU -- YOU -- ON
      18    PAGE 2 UP AT THE TOP YOU INDICATE THAT SHE'S LOST 30 POUNDS
      19    IN THE LAST YEAR; IS THAT RIGHT?
      20    A.  YES.
      21    Q.  AND YOU ALSO INDICATE THAT THERE IS SOME QUESTION ABOUT
      22    HER APPETITE.  TRUE?
      23    A.  YES.
      24    Q.  AND THEN DOWN AT THE BOTTOM UNDER RECOMMENDATIONS YOU
      25    STATE:  GENERAL CARE AS OUTLINED AS FAR AS NUTRITION AND


                                                                       1154



       1    MEDICATIONS, AND JUST GENERAL SUPPORTIVE CARE.
       2    A.  YES.
       3    Q.  DID I READ THAT CORRECTLY?
       4    A.  YES, THAT'S RIGHT.
       5    Q.  COULD YOU TELL ME AND TELL US, PLEASE, WHAT YOU MEANT BY
       6    GENERAL SUPPORTIVE CARE?
       7    A.  WELL, IN -- IN HER CASE IT WOULD BE CLOSE NURSING CARE;
       8    HELP WITH HER NUTRITION, AS FAR AS FEEDING IS CONCERNED;
       9    MANAGEMENT OF HER INTAKE AND OUTPUT, BOTH AS FAR AS FOOD, IF
      10    SHE'S ABLE, OR -- OR MOISTURE -- I.V. -- OR LIQUID INTAKE
      11    AND OUTPUT.
      12         AND THEN THE MEDICATIONS AS ORDERED, I WOULD EXPECT
      13    THEM TO FOLLOW UP ON -- ON THAT AS IT WAS WRITTEN.  I DID
      14    NOT WRITE THOSE ORDERS.
      15    Q.  I UNDERSTAND.
      16    A.  AND THEN THE OTHER THING, OF COURSE, IS TO BE SURE
      17    THAT -- THAT THE NURSES WATCH HER AND -- AND HELP HER IF
      18    SHE'S UP OR IF SHE'S WALKING AROUND SO THAT SHE WOULDN'T
      19    HURT HERSELF BECAUSE SHE WAS -- HAD NO JUDGMENT AND NO -- NO
      20    NORMAL ABILITY TO -- FOR HER SELF-CARE.  SO SHE WOULD HAVE
      21    TO BE MANAGED ALMOST ENTIRELY BY THE NURSING STAFF.
      22    Q.  ALL RIGHT.
      23             MR. STIRBA:  THANK YOU, DOCTOR.
      24             THE COURT:  ANYTHING FURTHER OF THIS WITNESS?
      25             MR. WILSON:  NO FURTHER QUESTIONS.


                                                                       1155



       1             THE COURT:  OKAY.  MAY HE BE EXCUSED?
       2             MR. WILSON:  HE MAY.

<<Back to Home Page