Scott Cunningham, DO

2       MS. BARLOW:  WE'D CALL DR. SCOTT CUNNINGHAM.

 

 3       THE COURT:  DR. CUNNINGHAM, WOULD YOU STEP FORWARD

 

 4  PLEASE?  IF YOU'LL COME RIGHT UP HERE, RAISE YOUR RIGHT HAND

 

 5  PLEASE AND FACE THE CLERK, SHE'LL PLACE YOU UNDER OATH.

 

 6                        SCOTT CUNNINGHAM,

 

 7            BEING FIRST DULY SWORN, WAS EXAMINED

 

 8            AND TESTIFIED AS FOLLOWS:

 

 9                        DIRECT EXAMINATION

 

10       THE COURT:  IF YOU'LL HAVE A SEAT THERE PLEASE.  IF

 

11  YOU'D GIVE US YOUR FULL NAME AND SPELL YOUR LAST NAME PLEASE.

 

12  A.   THOMAS SCOTT CUNNINGHAM.  C-U-N-N-I-N-G-H-A-M.

 

13       THE COURT:  YOU MAY PROCEED, MRS. BARLOW.

 

14       MS. BARLOW:  THANK YOU, JUDGE.

 

15  BY MS. BARLOW:

 

16  Q.   GOOD MORNING, DR. CUNNINGHAM.

 

17  A.   HI.

 

18  Q.   CAN YOU TELL US WHERE YOU PRACTICE?

 

19  A.   LOGAN, UTAH.

 

20  Q.   AND HOW LONG HAVE YOU BEEN IN PRACTICE?

 

21  A.   IN LOGAN?

 

22  Q.   IN GENERAL.

 

23  A.   I FINISHED MY RESIDENCY IN 1986.  BEEN IN PRACTICE SINCE

 

24  THEN.

 

25  Q.   WHAT TRAINING DID YOU RECEIVE FOR YOUR SPECIALTY OR YOUR

 

 1  ABILITY?

 

 2  A.   I WENT TO SCHOOL AT THE UNIVERSITY OF HEALTH SCIENCE IN

 

 3  KANSAS CITY, MISSOURI.  I DID A YEAR OF A ROTATING INTERNSHIP

 

 4  IN DETROIT, MICHIGAN.  AND THEN I RECEIVED MY INTERNAL

 

 5  MEDICINE TRAINING AT THE UNIVERSITY OF MISSOURI.

 

 6  Q.   ARE YOU BOARD CERTIFIED?

 

 7  A.   YES.

 

 8  Q.   ARE YOU AN M.D.?

 

 9  A.   I'M A D.O.

 

10  Q.   WHAT IS A D.O.?

 

11  A.   OSTEOPATHIC PHYSICIAN.  WE HAVE -- IT'S A FOUR-YEAR

 

12  MEDICAL SCHOOL PROGRAM.  OSTEOPATHIC PHYSICIANS HAVE THEIR

 

13  OWN MEDICAL SCHOOLS.  TRAINING IS SIMILAR IN TERMS OF THE

 

14  MEDICAL INFORMATION WE RECEIVE.  I DID A D.O. INTERNSHIP AND

 

15  SPENT A YEAR IN MICHIGAN, AS I SAID, AND THEN I DID AN M.D.

 

16  INTERNAL MEDICINE RESIDENCY AT MISSOURI.

 

17  Q.   SO DO YOU HAVE THE SAME TRAINING AS AN M.D. FOR INTERNAL

 

18  MEDICINE?

 

19  A.   YES.  WELL, OTHER THAN A DIFFERENT MEDICAL SCHOOLS BUT

 

20  MY RESIDENCY TRAINING WAS THROUGH AN M.D. PROGRAM.

 

21  Q.   ARE YOU -- WHAT IS YOUR CURRENT OCCUPATION TITLE,

 

22  SPECIALTY, THAT SORT OF THING?

 

23  A.   I PRACTICE INTERNAL MEDICINE WHICH IS NONSURGICAL

 

24  TREATMENT OF ADULT HEALTH ISSUES.  I AM IN PRIVATE PRACTICE.

 

25  I SEE BOTH HOSPITALIZED PATIENTS AND OFFICE PATIENTS FIVE

 

 1  DAYS A WEEK.

 

 2  Q.   ARE YOU FAMILIAR WITH THE HOSPICE PROGRAM?

 

 3  A.   SURE.

 

 4  Q.   AND WHAT'S YOUR FAMILIARITY?

 

 5  A.   I'VE BEEN INVOLVED WITH THE HOSPICE IN CACHE VALLEY

 

 6  SINCE APPROXIMATELY 1995.  I'M THE MEDICAL DIRECTOR, SO WE

 

 7  HAVE MEETINGS TWICE MONTHLY.  WE DISCUSS OUR PATIENTS AND I

 

 8  HELP ANSWER MEDICAL ISSUES THAT MIGHT ARISE WITH THESE

 

 9  PATIENTS.

 

10  Q.   DO YOU HANDS-ON TREAT HOSPICE PATIENTS?

 

11  A.   I DO.  GENERALLY.  MANY OF THESE PATIENTS ARE COVERED BY

 

12  THEIR PHYSICIANS IN LOGAN.  SOME OF THEM ARE MY OWN PATIENTS.

 

13  I GET INVOLVED IN ISSUES WHEN THE HOSPICE TEAM WOULD LIKE ME

 

14  TO INTERFACE WITH THE OTHER PHYSICIANS ABOUT THE PATIENTS AND

 

15  WHATEVER ISSUE THAT MIGHT BE PERTINENT.

 

16  Q.   WHAT DOES THE TERM HOSPICE MEAN?

 

17  A.   HOSPICE IS ESSENTIALLY A PHILOSOPHY OF DELIVERING

 

18  END-OF-LIFE CARE TO PATIENTS.  IT'S A MULTIDISCIPLINARY TEAM

 

19  APPROACH, INCLUDING ISSUES REGARDING BEREAVEMENT, DYING

 

20  ISSUES.  WE HAVE NURSING STAFF, WE HAVE SOCIAL WORKERS, WE

 

21  HAVE SPIRITUAL INDIVIDUALS INVOLVED IN DELIVERING CARE.

 

22  Q.   IS THERE ANY PARTICULAR TIME FRAME THAT IS HOSPICE?  I

 

23  DON'T KNOW HOW TO PHRASE IT OTHER THAN THAT.

 

24  A.   SURE.  CLINICIAN TRIES TO MAKE A DECISION AS TO WHETHER

 

25  THE PERSON INVOLVED'S LIFE DURATION IS APPROXIMATELY SIX

 

 1  MONTHS OR LESS.  THAT'S GENERALLY THE CRITERION THAT'S USED

 

 2  BROADLY.  THERE ARE OTHER SPECIFIC CRITERIA, BUT IN GENERAL

 

 3  ANY DETERMINATION THAT SOMEONE'S LIFE MAY NOT LAST MORE THAN

 

 4  SIX MONTHS IS CERTAINLY POTENTIALLY ELIGIBLE FOR HOSPICE.

 

 5  Q.   NO ONE CAN SAY FOR SURE JUST HOW LONG A PERSON'S LIFE

 

 6  WILL BE, THOUGH, IS THAT CORRECT?

 

 7  A.   RIGHT.

 

 8  Q.   IS THERE -- DOES THE WORD TERMINAL OR TERMINALITY MEAN

 

 9  ANYTHING IN THE CONTEXT OF HOSPICE?

 

10  A.   SIMPLY -- YOU'RE TALKING ABOUT NEAR DEATH.  GENERALLY

 

11  SIX MONTHS OR LESS IS THE CRITERION AGAIN WE CONSIDER.

 

12  Q.   IS THERE ANY TERMINALITY END-OF-LIFE CONNECTION TO

 

13  DEMENTIA?

 

14  A.   SURE.

 

15  Q.   AND NOW DEMENTIA IS A MENTAL CONCERN USUALLY, ISN'T IT?

 

16  A.   RIGHT.

 

17  Q.   AND HOW DOES THAT FACTOR INTO HOSPICE AND TERMINALITY?

 

18  A.   USING THE SAME CRITERION, WHEN WE DETERMINE THAT

 

19  SOMEONE'S HEALTH IS SUCH THAT THEY HAVE A GOOD PROBABILITY OF

 

20  DYING WITHIN SIX MONTHS, WHATEVER THE ILLNESS BE, COULD BE A

 

21  CANCER-RELATED ILLNESS, IT COULD BE NONCANCER ILLNESS

 

22  INCLUDING DEMENTIA.

 

23  Q.   DEMENTIA IS AN ILLNESS THAT CAN CAUSE DEATH?

 

24  A.   SURE.

 

25  Q.   DEMENTIA IS USUALLY IN THE ELDERLY, IS THAT CORRECT?

 

 1  A.   GENERALLY, RIGHT.

 

 2  Q.   DOES DEMENTIA -- USUALLY ELDERLY PEOPLE HAVE MORE THAN

 

 3  ONE ILLNESS, IS THAT CORRECT?

 

 4  A.   CORRECT.

 

 5  Q.   DOES DEMENTIA OFTEN TAKE PEOPLE OR IT IS USUALLY

 

 6  SOMETHING -- SOME OTHER ILLNESS THAT MIGHT CAUSE THEIR DEATH?

 

 7  A.   IT'S USUALLY A COMPLICATION, SO IT'S USUALLY A

 

 8  CO-EXISTING OR OCCURRING -- ACUTELY OCCURRING PROCESS THAT

 

 9  RESULTS IN DEATH.

 

10  Q.   DID YOU HAVE OCCASION TO PROVIDE MEDICAL SERVICES FOR

 

11  ENNIS ALLDREDGE?

 

12  A.   YES.

 

13  Q.   DO YOU RECALL WHEN YOU FIRST STARTED SEEING

 

14  MR. ALLDREDGE?

 

15  A.   I SAW MR. ALLDREDGE IN -- BEGINNING IN 1995.  MY FIRST

 

16  APPOINTMENT WITH HIM WAS IN APRIL.

 

17  Q.   DO YOU HAVE YOUR MEDICAL CHART --

 

18  A.   YES.

 

19  Q.   -- FROM YOUR OFFICE FOR MR. ALLDREDGE?  DO YOU KNOW

 

20  WHERE MR. ALLDREDGE WAS PRIOR TO WHEN YOU FIRST SAW HIM?

 

21  A.   HE WAS LIVING IN SOUTHERN UTAH, FROM MY RECORDS, I

 

22  BELIEVE DELTA, UTAH.

 

23  Q.   WAS HE SEEING A DOCTOR THERE?

 

24  A.   YES.

 

25  Q.   DID YOU RECEIVE ANY RECORDS FROM THOSE DOCTORS ABOUT

 

 1  THEIR CARE PRIOR TO THE TIME YOU SAW HIM?

 

 2  A.   I DID RECE -- I DID RECEIVE RECORDS.  I CAN'T STATE

 

 3  EXACTLY WHEN IT WAS, BUT I DID RECEIVE RECORDS AND THEY ENDED

 

 4  UP IN MY OFFICE NOTES.

 

 5  Q.   DID YOU -- WHEN WAS YOUR FIRST --

 

 6  A.   APRIL '95.

 

 7       MS. BARLOW:  OKAY.  YOUR HONOR, I WILL BE ASKING HIM TO

 

 8  DEAL WITH HIS CHART, HIS MEDICAL RECORDS WHICH ARE

 

 9  DEFENDANT'S EXHIBIT NUMBER 12.  AND I WILL BE REFERRING TO

 

10  NUMBERS C.U.N.N. AND THEN THE NUMBER FOR THE PAGE WITHIN THE

 

11  RECORDS SO WE HAVE COPIES OF THAT AND THEY'VE BEEN ADMITTED

 

12  AS DEFENDANT'S 12.

 

13       THE COURT:  THANK YOU.

 

14  Q.  (BY MS. BARLOW)  I WOULD LIKE YOU -- DO YOU HAVE YOUR

 

15  RECORD FOR THAT APRIL 17TH --

 

16  A.   YES.

 

17  Q.   -- 1995?  ALWAYS TAKES US A LITTLE WHILE TO GET THE

 

18  MACHINE REWORKING CORRECTLY.  IS THAT BOTHERING ANYONE?

 

19       THE COURT:  THE LIGHT'S ON THE SIDE.

 

20       MS. BARLOW:  NOW IF WE CAN GET THE COMPUTER PART TO LET

 

21  THE --

 

22       A JUROR:  IS THE LENS ON IT?

 

23       MS. BARLOW:  NO, NO, THE LENS -- WE GET ONE PART WORKING

 

24  AND THE OTHER PART DOESN'T.

 

25       MR. BUGDEN:  CHARLENE, ARE YOU GONNA USE THE APRIL 17TH

 

 1  RECORD?

 

 2       MS. BARLOW:  YES.

 

 3       MR. BUGDEN:  WELL, WE CAN JUST DO IT FROM THE COMPUTER,

 

 4  IT'S --

 

 5       MS. BARLOW:  I WILL BE USING SEVERAL OF THEM.

 

 6       MR. BUGDEN:  WE CAN HELP YOU.  IF YOU JUST TELL US, WE

 

 7  CAN -- WE CAN TAKE YOU THERE BECAUSE I'M SURE WE HAVE IT ON

 

 8  THE COMPUTER.

 

 9       MS. BARLOW:  THERE WE GO.  THE PROBLEM IS IT MAY NOT

 

10  BLOW UP THE SAME THINGS I WANNA BLOW UP, UNFORTUNATELY.

 

11  Q.  (BY MS. BARLOW)  WELL, LET'S -- WHILE THEY'R KIND OF

 

12  PLAYING WITH THE MACHINERY, LET ME ASK YOU A COUPLE OF

 

13  QUESTIONS.  DID YOU TAKE A HISTORY OF MR. ALLDREDGE ON THE

 

14  17TH OF APRIL 1995?

 

15  A.   YES.

 

16  Q.   HOW DID YOU DO THAT?

 

17  A.   HIS -- I ASKED HIM QUESTIONS.  HIS WIFE WAS ALSO

 

18  PRESENT.  I DON'T KNOW SPECIFICALLY HOW MUCH INFORMATION SHE

 

19  GAVE ME DURING THE VISIT, BUT SHE WAS AT THE VISIT.

 

20  Q.   PART OF THAT HISTORY WAS THAT HE HAD HAD A HISTORY OF

 

21  MYCOSIS FUNGOIDES.  DO YOU KNOW WHAT THAT IS?

 

22  A.   I HAVE A VAGUE -- I HAVE A GENERAL IDEA ABOUT WHAT IT

 

23  IS.

 

24  Q.   WHAT IS IT?

 

25  A.   IT'S A FORM OF LYMPHOMA, NON-HODGKINS LYMPHOMA, WHICH IS

 

 1  A CANCER.  MYCOSIS FUNGOIDES IS PRIMARILY INVOLVED THE SKIN.

 

 2  CAUSES AREAS ON THE SKIN THAT LOOK VERY LIKE -- VERY MUCH

 

 3  LIKE ECZEMA.  TENDS TO BE A SLOW, INDOLENT SLOW-GROWING

 

 4  PROCESS.  CAN SPREAD TO ORGANS BUT GENERALLY, AS IN HIS CASE,

 

 5  I'M NOT AWARE THAT IT DID.  HE RECEIVED RADIATION TREATMENTS

 

 6  FOR THAT.  AND MY UNDERSTANDING IS, IS THAT THAT WAS WELL

 

 7  CONTROLLED AND NOT AN ACTIVE PROCESS.

 

 8  Q.   SO IT WAS NOT A TERMINAL CONDITION AT THAT POINT?

 

 9  A.   NO.

 

10  Q.   WE ALWAYS THINK OF CANCER AS BEING SOMETHING --

 

11  A.   YEAH, THAT WAS NOT THAT.  THIS WAS A VERY INDOLENT

 

12  PROCESS AND SEEMED TO BE WELL CONTROLLED.

 

13  Q.   WHAT WAS HIS GENERAL HEALTH?  PHYSICAL HEALTH?

 

14  A.   HE HAD OTHER MEDICAL PROBLEMS.  HE HAD HAD A HISTORY OF

 

15  CORONARY ARTERY DISEASE.  HE HAD A BYPASS IN 1982.  HIS

 

16  CORONARY DISEASE WAS NOT ACTIVE.  IN OTHER WORDS, HE WASN'T

 

17  HAVING PROBLEMS WITH CHEST PAIN, HE WASN'T HAVING PROBLEMS

 

18  WITH WEAKNESS OF HIS HEART SUCH THAT HE WAS IN --

 

19  PERIODICALLY IN CONGESTIVE HEART FAILURE.  SO HIS CARDIAC

 

20  PROCESS WAS, QUOTE, STABLE.  HE HAD DIABETES FOR WHICH HE WAS

 

21  ON INSULIN.  HE HAD A HISTORY OF LOW THYROID, HYPOTHYROIDISM.

 

22  HE WAS ON THYROID MEDICATION FOR THAT.  THAT WAS STABLE.  HE

 

23  HAD HE HYPERTENSION WHICH WAS CONTROLLED ON MEDICATIONS.

 

24  Q.   DID HE HAVE ANY IMMEDIATELY LIFE THREATENING CONDITIONS

 

25  AT THAT POINT?

 

 1  A.   NO.

 

 2  Q.   AND ON PAGE 13 OF YOUR -- 13 FOR ME, THE SECOND PAGE OF

 

 3  YOUR EVALUATION ON THE 17TH OF APRIL, WHAT WAS YOUR FIRST

 

 4  IMPRESSION OF HIS MEDICAL CONDITION?

 

 5  A.   UNDER THE IMPRESSIONS, I LISTED STABLE.  MEDICALLY

 

 6  STABLE.  DIABETES, DEMENTIA, HIS MYCOSIS FUNGOIDES THAT WE'VE

 

 7  SPOKEN ABOUT, HIS THYROID, LOT THYROID, HYPERTENSION.

 

 8  Q.   DID YOU HAVE HAVE OCCASION TO SEE MR. ALLDREDGE AFTER

 

 9  THAT FIRST VISIT?

 

10  A.   I SAW HIM AGAIN THE FOLLOWING MONTH.

 

11  Q.   AND WHY WAS THE VISIT THAT QUICKLY AFTERWARDS?

 

12  A.   HE HAD JUST MOVED INTO THE NURSING HOME, AND GENERALLY,

 

13  I SEE PATIENTS WITHIN THE NEXT FOUR WEEKS.

 

14  Q.   DID YOU SEE ANY CHANGE IN HIS CONDITION AT THAT TIME?

 

15  A.   I NOTED THAT HIS DIABETES, HIS BLOOD SUGARS WERE RUNNING

 

16  SLIGHTLY ELEVATED, PARTICULARLY IN THE AFTERNOONS.  SO I MADE

 

17  SOME MODIFICATION IN HIS INSULIN.  OTHERWISE, I DID NOT MAKE

 

18  ANY ANY OTHER CHANGES.

 

19  Q.   HIS DIABETES THEN, WOULD YOU CALL IT UNDER CONTROL OR

 

20  WAS IT OUT OF CONTROL, WHAT --

 

21  A.   I THINK IT WAS MILD -- IT WAS MILDLY OUT OF CONTROL.  IT

 

22  WASN'T ANYTHING DRAMATIC.  HIS BLOOD SUGARS WERE IN THE

 

23  LOW -- LOW TO MID 200'S IN THE AFTERNOON, WHICH IS MILDLY

 

24  ELEVATED.  HIS MORNING BLOOD SUGARS WERE -- WERE WITHIN THE

 

25  100 RANGE, SO I THOUGHT THAT HIS BLOOD SUGARS WERE SLIGHTLY

 

 1  ELEVATED, BUT NOTHING SUBSTANTIAL.

 

 2  Q.   DID YOU HAVE OCCASION TO HAVE AN OCCUPATIONAL THERAPIST

 

 3  DO AN EVALUATION OF HIM?

 

 4  A.   AN OCCUPATIONAL THERAPIST SAW HIM IN APRIL.

 

 5  Q.   AND WHAT -- DID THEY REPORT BACK TO YOU THEIR FINDINGS?

 

 6  A.   YES.

 

 7  Q.   WHAT DID THEY FIND OR REPORT TO YOU?

 

 8  A.   I'LL TURN TO THE FORM, BUT GENERALLY THEY -- GENERALLY,

 

 9  THEY FELT THAT -- MORE SPECIFICALLY, THEY NOTED THAT HE

 

10  REQUIRED SOME ASSIST WITH AMBULATION.  HE REQUIRED VERBAL

 

11  CUES IN TERMS OF STANDING FROM HIS SEATED POSITION.  HE

 

12  REQUIRED VERBAL CUES AND ONE-ARM ASSIST IN GETTING INTO THE

 

13  BATHTUB.  THEY FELT THAT HIS STRENGTH WAS GOOD.  HIS --

 

14  PARTICULARLY UPPER EXTREMITY STRENGTH THEY SPOKE ABOUT AND

 

15  SAID THAT WAS IN GOOD CONDITION.  LET ME REFER TO THE FORM TO

 

16  SEE OTHER THINGS.

 

17       THEY COMMENTED THAT AT HOME HE AMBULATED WITH A WALKER,

 

18  AND THA TWAS CONSISTENT WITH HIS NEED FOR ONE-HAND ASSISTANCE

 

19  WITH WALKING.  THEY RECOMMENDED SOME ASSISTANCE -- OR THEY

 

20  STATED HE NEEDEDED ASSISTANCE WHEN DOING SOME COMPLEX TASKS

 

21  SUCH AS BUTTONING HIS SHIRT, PULLING UP HIS PANTS.  HE WAS

 

22  INDEPENDENT IN EATING, SO HE DID NOT NEED HELP WITH EATING.

 

23  Q.   WHAT ABOUT HIS COGNITIVE ABILITIES, DID THEY REFER TO

 

24  THAT AT ALL?

 

25  A.   I CAN JUST READ THEIR COMMENT, IF THAT WOULD BE --

 

 1  Q.   IF YOU WOULD PLEASE.

 

 2  A.   COGNITION, THE PATIENT DEMONSTRATES SEVERE COGNITIVE

 

 3  DEFICITS.  IS ORIENTED TO PERSON AND GENERALLY TO PLACE.  HE

 

 4  IS NOT ORIENTED TO TIME OR PURPOSE.  HE DEMONSTRATES A FAIRLY

 

 5  SHORT ATTENTION SPAN OF APPROXIMATELY ONE MINUTE OF BRIEF

 

 6  TASKS.  HE HAS VERY POOR IMMEDIATE AND SHORT-TERM MEMORY.

 

 7  REMOTE AND DISTANT MEMORY ARE MORE FUNCTIONAL.

 

 8  Q.   IS THAT CONSISTENT WITH YOUR FINDING THAT HE HAD

 

 9  DEMENTIA?

 

10  A.   YES.

 

11  Q.   DID YOU EVER MAKE A DETERMINATION OF WHAT HAD CAUSED THE

 

12  DEMENTIA?

 

13  A.   IN REVIEWING THESE RECORDS, I -- MY INITIAL -- MY

 

14  INITIAL STATEMENT ON THE RECORD WAS ALZHEIMER'S DEMENTIA,

 

15  WHICH IS ONE FORM OF DEMENTIA.  WHEN I WAS LOOKING THROUGH

 

16  THE RECORDS, DR. SMITH WHO WAS HIS PHYSICIAN IN DELTA, HAD

 

17  WRITTEN ON ONE OF THE SHEETS THAT, QUESTION MARK,

 

18  MULTI-INFARCT DEMENTIA.  IN OTHER WORDS, HISTORY OF MULTIPLE

 

19  STROKES CAUSING MEMORY LOSS AND DEMENTIA, BUT I DID NOT SEE

 

20  ANY FURTHER DOCUMENTATION REGARDING THAT, SO I'M NOT EXACTLY

 

21  CERTAINLY THE SPECIFIC ORIGIN OF HIS DEMENTIA.

 

22  Q.   IS THERE A DIFFERENCE BETWEEN A -- AN ALZHEIMER'S TYPE

 

23  DEMENTIA AND I GUESS WHAT'S A STROKE OR A C.V.A. KIND OF

 

24  DEMENTIA?

 

25  A.   THEY -- THEY PRESENT GENERALLY OR CAN THE SAME WITH

 

 1  SIGNIFICANT COGNITIVE LOSS.  OBVIOUSLY, THE ORIGIN OF THE

 

 2  DEMENTIA IS DIFFERENT.  MULTI-INFARCT DEMENTIA IS BECAUSE OF

 

 3  MULTIPLE STROKES.  HE DIDN'T HAVE ANY FOCAL MOTOR WEAKNESS,

 

 4  HE DIDN'T HAVE ANY FOCAL NEUROLOGICAL SIGNS THAT WOULD

 

 5  SUGGEST TO ME CLEARLY THAT HE HAD HAD PREVIOUS STROKES.

 

 6  THEY'RE BOTH PROGRESSIVE, THEY BOTH CAN CAUSE SEVERE DECLINE

 

 7  AND SEVERE DEBILITY AND POTENTIALLY, AS WE'VE TALKED ABOUT

 

 8  BEFORE, ULTIMATELY DEATH.

 

 9  Q.   DID YOU HAPPEN TO SEE MR. ALLDREDGE THEN IN AUGUST OF

 

10  1995?

 

11  A.   YES.

 

12  Q.   DO YOU RECALL WHAT DAY THAT WAS?

 

13  A.   I SAW HIM TWICE IN AUGUST.  I SAW HIM IN EARLY AUGUST,

 

14  THEN I SUBSEQUENTLY SAW HIM TOWARDS THE END OF AUGUST.  I

 

15  BELIEVE THE SUBSEQUENT VISIT LATER IN AUGUST WAS BECAUSE HE

 

16  WAS ADMITTED TO A NURSING HOME JUST PRIOR TO THAT, AND IT'S

 

17  PRETTY STANDARD FOR ME TO SEE THE PATIENT AGAIN ONCE THEY'VE

 

18  BEEN ADMITTED TO THE NURSING.  SO IN AUGUST, I SAW HIM ON

 

19  AUGUST 3RD, 1995 --

 

20       THE COURT:  MRS. BARLOW, WILL YOU TURN ORR THE LIGHT IF

 

21  YOU'RE GONNA USE THAT SO THE JURY CAN SEE.  JUST TURN OFF THE

 

22  ONE.

 

23       MS. BARLOW:  THIS ONE OR THE OTHER ONE?

 

24       THE COURT:  THE OTHER ONE.  DO YOU NEED 'EM BOTH OFF,

 

25  LADIES AND GENTLEMEN?  NEED 'EM BOTH OFF.  THERE YOU GO.

 

 1       MS. BARLOW:  I WILL BE KIND OF GOING BACK AND FORTH A

 

 2  LITTLE BIT WITH THESE, YOUR HONOR.

 

 3       THE COURT:  WE'LL LEAVE IT OFF FOR A WHILE.

 

 4  Q.  (BY MS. BARLOW)  OKAY.  THERE IS YOUR AUGUST 3RD, 1995.

 

 5  YOUR PHYSICAL EXAM, WAS THERE ANYTHING UNUSUAL OR A PROBLEM

 

 6  WITH ANYTHING YOU SAW IN YOUR PHYSICAL EXAM?

 

 7  A.   I FELT THINGS PHYSICALLY WERE ESSENTIALLY THE SAME AS

 

 8  BEFORE.

 

 9  Q.   HAD HE LOST ANY WEIGHT?

 

10  A.   HE WEIGHED 203 POUNDS.  WHEN HE CAME -- WHEN I INITIALLY

 

11  SAW HIM, I BELIEVE HE WEIGHED TWO OH -- WELL, LET ME LOOK.

 

12  WEIGHT WAS THE SAME.  HE WEIGHED 203 IN APRIL.  HE WEIGHED

 

13  203 IN MAY.  IN AUGUST, ON AUGUST 3RD, HE WEIGHED 203.  JUST

 

14  FOR INFORMATION’S SAKE FOR EVERYBODY, WHEN HE -- WHEN --

 

15  THE LAST WEIGHT I HAVE ON HIM WAS ON OCTOBER 12 AND HE

 

16  WEIGHED 199, SO THERE'S A LITTLE BIT OF A DISCREPANCY IN

 

17  WEIGHTS THERE.

 

18  Q.   SO HE'D LOST ABOUT FOUR POUNDS OVER THE COURSE OF APRIL

 

19  TO OCTOBER?

 

20  A.   RIGHT.

 

21  Q.   IS THAT UNUSUAL?  WELL --

 

22  A.   NO.

 

23  Q.   -- DID IT CAUSE YOU ANY CONCERN?

 

24  A.   NO.  NO.

 

25  Q.   HE'S A PRETTY GOOD-SIZED MAN, IT SOUNDS LIKE?

 

 1  A.   RIGHT.

 

 2  Q.   INDICATED THAT THERE WAS NOTHING REALLY THAT YOU WANTED

 

 3  TO CHANGE ABOUT HIS MEDICAL REGIMEN AT THE TIME?

 

 4  A.   I ORDERED AN ECHOCARDIOGRAM, I BELIEVE GIVEN HIS CARDIAC

 

 5  DISEASE.  AN ECHOCARDIOGRAM IS AN IMAGE OF THE HEART.  IT'S

 

 6  AN ULTRASOUND.  YOU CAN SEE THE HEART VALVES, YOU CAN SEE THE

 

 7  STRENGTH OF THE VENTRICULAR CONTRACTIONS.  HIS

 

 8  ECHOCARDIOGRAM -- VOILA -- WAS -- HIS PUMP FUNCTION WAS 55

 

 9  PERCENT.  THAT WAS DESCRIBED BY DR. HAWS, ONE OF THE LOCAL

 

10  CARDIOLOGISTS, AS MILDLY DECREASED.  THAT'S VERY CLOSE TO

 

11  NORMAL.  I DON'T THINK THAT'S -- THAT'S A FAIRLY GOOD

 

12  EJECTION FRACTION.  HE --

 

13       THE COURT:  MS. BARLOW, IF YOU'RE GONNA REFER TO THESE

 

14  EXHIBITS, WE NEED TO MAKE A RECORD --

 

15       MS. BARLOW:  I APOLOGIZE, YOUR HONOR.

 

16       THE COURT:  -- ON THE NUMBER AND WHAT WE'RE TALKING

 

17  ABOUT.  I ASSUME THEY'RE ALL FROM THE SAME GENERAL EXHIBIT

 

18  BUT DIFFERENT PAGES?

 

19       MS. BARLOW:  THEY ARE.  D-12, AND AND THIS IS PAGE 26.

 

20  I APOLOGIZE.  I'LL TRY TO REMEMBER TO DO THAT.

 

21       THE COURT:  THANK YOU.

 

22  Q.  (BY MS. BARLOW)  WAS THERE ANYTHING ABOUT THIS

 

23  ECHOCARDIOGRAM THAT GAVE YOU CONCERNS AS HIS PHYSICIAN?

 

24  A.   NO.

 

25  Q.   DID HE HAVE THE HEART OF A 20-YEAR-OLD?

 

 1  A.   HARDLY.

 

 2  Q.   SO THERE WERE PROBLEMS.

 

 3  A.   WELL, SURE, HE HAD -- YEAH, HE HAD, AS I SAID BEFORE,

 

 4  HE'D HAD HIS BYPASS IN 1982.  SO HE HAD CORONARY ARTERY

 

 5  DISEASE.

 

 6  Q.   AND WHAT IS CORONARY ARTERY DISEASE?

 

 7  A.   THAT IS ABNORMALITIES INVOLVING THE CORONARY ARTERIES,

 

 8  WITH FAT DEPOSITION, NARROWING OF THE ARTERIES.

 

 9  Q.   IS THAT UNUSUAL IN A MAN OF HIS AGE?

 

10  A.   IT'S A FREQUENT FINDING IN AN 82-YEAR-OLD.

 

11  Q.   YOU INDICATED YOU SAW HIM AGAIN ON THE -- AT THE END OF

 

12  AUGUST.  WAS THERE ANY CHANGE IN HIS CONDITION AT THAT TIME?

 

13  A.   I THOUGHT, BASED UPON MY REVIEW OF THE NOTES, I THOUGHT

 

14  THAT HIS MENTAL STATUS HAD BEGUN TO DETERIORATE FURTHER.

 

15  I COMMENTED ABOUT HE WAS -- HE WAS MORE DISORIENTED.  I ASKED

 

16  HIM TO DO SOME SIMPLE MATHEMATICAL CALCULATIONS THAT HE

 

17  WASN'T ABLE TO DO.  BY THAT I MEAN ADDING SOME SIMPLE

 

18  NUMBERS.  HIS SPEECH WAS NOT AS CLEAR TO ME.  HE WAS -- HE

 

19  SEEMED TO BE MORE CONFUSED IN HIS CONVERSATION WITH ME.  SO I

 

20  THOUGHT THERE WERE CLEARLY MENTAL STATUS CHANGES AT THAT

 

21  POINT COMPARED TO OUR EARLIER VISITS.

 

22  Q.   WHAT ABOUT HIS PHYSICAL CONDITION, HAD IT DETERIORATED?

 

23  A.   I MADE NO COMMENTS ABOUT ANY PHYSICAL PROBLEMS THAT HE

 

24  WAS HAVING.  IN TERMS OF STRENGTH AND HIS OTHER MEDICAL

 

25  PROBLEMS THAT WE'VE DISCUSSED, THOSE WERE ESSENTIALLY THE

 

 1  SAME.  THROUGHOUT THE TIME THAT I WAS TAKING CARE OF HIM, WE

 

 2  WERE CONTINUOUSLY MONITORING HIS BLOOD SUGARS AND OFTENTIMES

 

 3  HIS NUMBERS WOULD BE ELEVATED IN THE AFTERNOONS, AND WE WERE

 

 4  UPPING HIS INSULIN PROGRAM TO TRY TO GET A LITTLE MORE

 

 5  PRECISE CONTROL.  SO THROUGHOUT HIS TIME WITH ME, WE WERE

 

 6  DOING THAT.

 

 7       MS. BARLOW:  YOUR HONOR, THIS IS PAGE 27.

 

 8       THE COURT:  THANK YOU.

 

 9       MS. BARLOW:  I NEGLECTED TO SAY THAT.  I APOLOGIZE.

 

10  Q.  (BY MS. BARLOW)  IN THE MIDDLE UNDER PAST MEDICAL

 

11  HISTORY, IT SAYS, HE VOICES NO COMPLAINTS.  DO YOU RECALL HIM

 

12  COMPLAINING ABOUT PAIN DURING THAT VISIT?

 

13  A.   ALL I CAN SAY IS I DIDN'T MAKE ANY COMMENTS IN MY RECORD

 

14  ABOUT HIM DISCUSSING PAIN, PAINFUL PROCESSES.  I WOULD USUALLY

 

15  DO THAT IF HE DID.

 

16  Q.   FACT, IN EACH OF THESE VISITS THAT YOU HAD WITH HIM, DID

 

17  YOU EVER HAVE HIM COMPLAIN OF ANY PARTICULAR PAIN?  DO YOU

 

18  EVER RECALL HIM COMPLAINING?

 

19  A.   I DON'T -- I DON'T RECALL ANY COMPLAINTS OF PAIN.  WHEN

 

20  I SAW HIM IN OCTOBER, HE CAME TO SEE ME BECAUSE HE WAS HAVING

 

21  A PROBLEM OVER THE PRECEDING DAY OF NAUSEA AND VOMITING.  I

 

22  DON'T HAVE ANY NOTATION IN MY RECORDS ABOUT HIM COMPLAINING

 

23  ABOUT ABDOMINAL PAIN IN ASSOCIATION WITH THAT OR ANY OTHER

 

24  TYPES OF PAIN.  SO THE ANSWER I -- TO YOUR QUESTION IS NO.

 

25  Q.   SO OCTOBER 12TH YOU SAW HIM?

 

 1  A.   CORRECT.

 

 2  Q.   AND WHAT DID YOU THINK -- WHAT DIAGNOSIS DID YOU GIVE

 

 3  FOR THE COMPLAINTS HE HAD AT THAT TIME?

 

 4  A.   WELL, I -- I LISTED A NONSPECIFIC DIAGNOSIS OF

 

 5  GASTROENTERITIS.  I WASN'T ENTIRELY SURE WHY HE WAS HAVING

 

 6  THIS ABRUPT ONSET OF NAUSEA AND VOMITING.  HIS PHYSICAL

 

 7  EXAMINATION DIDN'T GIVE ME ANY IDEA.  HIS ABDOMINAL EXAM WAS

 

 8  FINE.  HIS OTHER PHYSICAL EXAMINATION, HIS LUNGS, HIS HEART

 

 9  WERE STABLE AND WERE NOT SUGGESTIVE OF ANY PARTICULAR THAT HE

 

10  HAD CAUSING THIS ABRUPT ONSET OF THE NAUSEA AND VOMITING.  I

 

11  DID SOME LABORATORY TESTS INCLUDING A CHEMISTRY ANALYSIS.

 

12  LIVER FUNCTIONS, KIDNEY FUNCTIONS, ELECTROLYTES, COMPLETE

 

13  BLOOD COUNT, WHICH LOOKS FOR ANEMIA, WHITE BLOOD CELL COUNT,

 

14  WHICH ELEVATED MIGHT SUGGEST A INFLAMMATORY OR INFECTIOUS

 

15  PROCESS.  AND THOSE WERE -- THOSE WERE NONINDICATIVE OF ANY

 

16  SIGNIFICANT PROBLEM.  SO I BASICALLY DECIDED TO NOT INTERVENE

 

17  ANY FURTHERMORE AND JUST WATCH HIM.

 

18       MS. BARLOW:  THIS IS PAGE 28, YOUR HONOR, OF THE D-12.

 

19  Q.  (BY MS. BARLOW)  WHEN YOU AREN'T REALLY SURE WHAT A

 

20  PERSON'S PROBLEM IS, IS IT COMMON THEN TO ORDER OTHER TESTS

 

21  AND THAT SORT OF THING?

 

22  A.   WELL, IT DEPENDS ON THE SITUATION.  IF YOU'RE -- IF IT'S

 

23  AN ABRUPT ONSET OF A PROBLEM, WHICH IS NOT ALL THAT UNUSUAL

 

24  OF A PROBLEM, I THINK WE'VE ALL HAD NAUSEA AND VOMITING IN

 

25  OUR LIFETIME.  IF THE EXAMINATION IS UNREMARKABLE, IF THE

 

 1  LABORATORY STUDIES DON'T SUGGEST ANY SERIOUS PROCESS -- AND

 

 2  THAT'S WHAT YOU'RE TRYING TO DETERMINE, IS THERE A SERIOUS

 

 3  PROBLEM GOING ON HERE.  IF YOU DON'T FIND ANY OF THOSE,

 

 4  OFTENTIMES IT'S REASONABLE TO JUST KINDA STEP BACK AND WATCH

 

 5  AND SEE HOW THINGS PROCEED.  IF THEY BECOME SICKER OR IF THE

 

 6  PROCESS CONTINUES, THEN CERTAINLY YOU DO OTHER TESTS.

 

 7  OFTENTIMES THE PROCESS JUST RESOLVES AND NO FURTHER

 

 8  INTERVENTION IS NEEDED.

 

 9  Q.   DID THIS PROCESS RESOLVE?

 

10  A.   YES.

 

11  Q.   WHAT WAS THE NEXT TIME THAT YOU SAW MR. ALLDREDGE?

 

12  A.   I SAW HIM ON NOVEMBER 16TH.

 

13  Q.   WAS THERE ANY CHANGE IN HIS CONDITION AT THAT TIME?  NOT

 

14  FROM GASTROENTERITIS, BUT FROM HIS GENERAL OVERALL CONDITION

 

15  FROM THE TIME YOU'D SEEN HIM IN APRIL?

 

16  A.   I FELT THAT HE WAS CONTINUING TO DEMONSTRATE SUBSTANTIAL

 

17  DEMENTIA SIGNS, SYMPTOMS.  HIS SPEECH WAS DIFFICULT TO MAKE

 

18  ANY SENSE OUT OF.  I WRITE, HE HAD EXPRESSIVE APHASIA, WHICH

 

19  MEANS HE WAS UNABLE TO COMMUNICATE WITH ME VERBALLY IN ANY

 

20  MEANINGFUL WAY.  I WROTE THAT HE HAD -- HE SEEMED TO

 

21  UNDERSTAND WHAT I SAID TO HIM, SO USUALLY I'LL ASK SOMEBODY

 

22  TO CLOSE THEIR EYES, RAISE THEIR HAND, OR SOMETHING LIKE THAT

 

23  JUST TO SEE IF I CAN -- IF WHAT I'M SAYING TO HIM REGISTERS.

 

24  AND BY ME SAYING HE SEEMS TO UNDERSTAND THE SPOKEN WORD TO

 

25  HIM, IT IMPLIES THAT DURING THAT EXAMINATION, HE SEEMED TO

 

 1  UNDERSTAND WHAT I WAS SAYING.  HE JUST COULDN'T TALK TO ME IN

 

 2  ANY INTELLIGENT MANNER.

 

 3  Q.   DO YOU RECALL WHETHER HE EXHIBITED ANY FRUSTRATION FROM

 

 4  HIS INABILITY TO EXPRESS HIMSELF?

 

 5  A.   I DON'T RECALL.  I CAN'T ANSWER THAT.

 

 6  Q.   THEN YOU NEXT SAW HIM ON JANUARY 4TH, 1996?

 

 7  A.   CORRECT.

 

 8  Q.   WAS THAT ROUTINE OR WAS IT A REQUEST FROM THE NURSING

 

 9  HOME?

 

10  A.   THAT WAS MY REQUEST TO THE NURSING HOME.  HE WAS --

 

11  BEGINNING IN EARLY DECEMBER, HIS BEHAVIOR HAD BECOME QUITE

 

12  AGITATED, COMBATIVE, OCCASIONALLY PHYSICALLY VIOLENT.  AND

 

13  THROUGHOUT -- THROUGHOUT DECEMBER, WE WERE ATTEMPTING TO

 

14  CONTROL HIS AGITATED, COMBATIVE, PHYSICALLY ABUSIVE BEHAVIOR

 

15  WITH MEDICATIONS.  THINGS WEREN'T GETTING UNDER CONTROL.  IT

 

16  WAS CONTINUED TO MANIFEST THAT TYPE OF BEHAVIOR, SO I HAD HIM

 

17  COME INTO MY OFFICE ON JANUARY 4TH TO EXAMINE HIM AND TRY TO

 

18  DETERMINE IF THERE IS ANY OTHER UNDERLYING MEDICAL PROBLEM

 

19  THAT MIGHT BE PROVOKING THIS BEHAVIOR.

 

20  Q.   DID YOU FIND ANY SUCH UNDERLYING MEDICAL PROBLEM?

 

21  A.   I DIDN'T FIND ANY -- ANY SPECIFIC PROBLEM THAT I COULD

 

22  PUT MY FINGER ON TO EXPLAIN HIS INCREASING AGITATION OVER

 

23  DECEMBER.  THERE WAS -- THERE WAS SOME CONCERN THAT THERE

 

24  MIGHT HAVE BEEN SOME MEDICATIONS THAT HE HAD BEEN ON THAT

 

25  COULD BE CAUSING A CONFUSIONAL STATE.  ONE OF THEM WAS

 

 1  TAGAMET, HE HAD BEEN ON FOR REFLUX.  SO I STOPPED THAT.

 

 2  Q.   IS THAT COMMON FOR TAGAMET TO CAUSE AGITATION?

 

 3  A.   IT CAN, IT CAN.

 

 4  Q.   THAT'S NOT --

 

 5  A.   I WOULDN'T SAY IT'S COMMON, BUT IT DOES OCCUR.

 

 6  Q.   OKAY.

 

 7  A.   SO WE STOPPED THE TAGAMET, AND HIS BEHAVIOR DIDN'T

 

 8  REALLY CHANGE.  HE CONTINUED TO PHYSICALLY BEHAVE THIS WAY.

 

 9  SO I DIDN'T BELIEVE THAT TAGAMET NECESS -- -- WAS ULTIMATELY

 

10  RESPONSIBLE FOR THAT GIVEN THE FACT THAT HIS BEHAVIOR DIDN'T

 

11  NECESSARILY CHANGE UPON DISCONTINUING IT.

 

12  Q.   DID YOU MAKE ANY OTHER MODIFICATIONS IN HIS MEDICAL

 

13  REGIMEN?

 

14  A.   I CHANGED -- I CHANGED HIS MEDICATIONS.  I PUT HIM ON --

 

15  EARLIER IN DECEMBER WE HAD PUT HIM ON AN ANTIPSYCHOTIC

 

16  MEDICATION CALLED MELLARIL, WHICH IS USED TO TRY TO SUBDUE

 

17  THESE BEHAVIORS.

 

18  Q.   HAD THAT BEEN SUCCESSFUL?

 

19  A.   NO.

 

20  Q.   WHAT DID YOU DO THEN?

 

21  A.   I SWITCHED ON JANUARY -- I'M SORRY, I'M CONFUSING YOU

 

22  GUYS.  I CHANGED HIM FROM THE MELLARIL TO THE -- TO THIS

 

23  OTHER AGENT SEVERAL DAYS AFTER THAT BECAUSE I RECEIVED A

 

24  PHONE CALL FROM THE NURSING HOME AGAIN TELLING ME THAT HE WAS

 

25  BECOMING QUITE AGITATED AND ABUSIVE.  SO I SWITCHED HIM FROM

 

 1  MELLARIL AT THAT POINT TO A DIFFERENT AGENT, RISPERIDAL.

 

 2  Q.   AND WHAT DAY WAS THAT?

 

 3  A.   THAT WAS JANUARY 8TH.

 

 4       MS. BARLOW:  YOUR HONOR, I'M PUTTING UP PAGE NUMBER 36.

 

 5       THE COURT:  THANK YOU.

 

 6  Q.  (BY MS. BARLOW)  DO YOU RECALL THIS TELEPHONE

 

 7  CONVERSATION THAT'S REFERRED TO ON PAGE 30 -- OR ON PAGE 36?

 

 8  A.   YES.

 

 9  Q.   HOW DID THAT COME ABOUT?  DO YOU RECALL WHETHER THEY

 

10  CALLED YOU OR YOU CALLED THEM?

 

11  A.   I HAVE A NOTE IN MY RECORD FROM JANUARY 8TH THAT SAYS,

 

12  THE PATIENT HIT AIDE IN THE ABDOMEN, THREW A BINGO GAME ALL

 

13  OVER HIM, AND -- WELL, I'M REALLY CONFUSING PEOPLE HERE.  HE

 

14  HAD BEEN ON RISPERIDAL APPARENTLY AFTER OUR JANUARY 4 VISIT,

 

15  AND THEN WHEN THEY CALLED ME ON JANUARY 8TH WITH THESE

 

16  ADDITIONAL BEHAVIORS, I UPPED THE DOES OF THE RISPERIDAL FROM

 

17  A HALF A MILLIGRAM TWICE A DAY TO ONE MILLIGRAM TWICE A DAY,

 

18  AND I ASKED THEM TO GIVE HIM SOME ATIVAN AT THAT POINT IN

 

19  TIME TRYING TO CONTROL HIS BEHAVIOR.

 

20  Q.   WHAT IS ATIVAN?

 

21  A.   IT'S A -- IT'S A SEDATIVE.

 

22  Q.   WHAT ABOUT RISPERIDAL?

 

23  A.   ANITPSYCHOTIC.

 

24  Q.   AND THEN YOU ALSO INDICATE SOME BUSPAR, 10 MILLIGRAMS,

 

25  IS THAT T.I.D., THREE TIMES A DAY?

 

 1  A.   RIGHT.

 

 2  Q.   AND WHAT'S --

 

 3  A.   THAT'S AN ANTIANXITEY TYPE OF MEDICATION, AGAIN, TRYING

 

 4  TO CONTROL HIS AGITATED BEHAVIOR.

 

 5  Q.   DO YOU KNOW WHETHER THIS WAS SUCCESSFUL ON THE 8TH?  DID

 

 6  YOU RECEIVE ANY FURTHER PHONE CALLS FROM THE NURSING HOME?

 

 7  A.   I DON'T HAVE ANY RECORDS OF ANY FURTHER INFORMATION FROM

 

 8  THE NURSING HOME AFTER THE 8TH.  I SUGGESTED ON THE 8TH GIVEN

 

 9  MY DIFFICULTY CONTROLLING HIS BEHAVIOR AND THE FACT THAT HE

 

10  HAD ACTUALLY INJURED SOMEONE -- ANOTHER RESIDENT IN THE

 

11  PROCESS, THAT WE MAKE ARRANGEMENTS FOR HIM TO BE TRANSFERRED

 

12  DOWN TO DAVIS.

 

13  Q.   HE WAS A STRONG MAN, WASN'T HE?  BIG MAN?

 

14  A.   WELL, HE WEIGHED A HUNDRED AND WHAT, 90 --

 

15  Q.   199.

 

16  A.   199.

 

17  Q.   DID YOU EVER SEE HIM AGAIN AFTER THIS PHONE CONVERSATION

 

18  ON THE 8TH OF JANUARY?

 

19  A.   WELL, I DIDN'T SEE HIM -- MY LAST VISUALIZATION OF

 

20  MR. ALLDREDGE WAS ON JANUARY 4TH.

 

21  Q.   DID YOU EVER HEAR ANYTHING FURTHER ABOUT HIM BEING

 

22  TRANSFERRED?

 

23  A.   ON THE 9TH, WE RECEIVED A -- ON THE 9TH -- 9TH, I HAVE A

 

24  NOTE IN MY CHART FROM MY NURSE WHO SAID THAT SHE SPOKE WITH

 

25  THE -- WITH A SOCIAL WORKER -- I DON'T KNOW WHETHER THE

 

 1  SOCIAL WORKER WAS AT DAVIS HOSPITAL OR WHETHER THE SOCIAL

 

 2  WORKER WAS AT THE NURSING HOME -- DISCUSSING THE PLANS FOR

 

 3  ADMITTED MR. ALLDREDGE TO DAVIS ON THE FOLLOWING DAY, WHICH

 

 4  WOULD HAVE BEEN THE 10TH.  AND THAT'S THE LAST NOTATION I

 

 5  HAVE OF -- WITH THE CIRCUMSTANCES.

 

 6  Q.   WHAT HAD BEEN REPORTED TO YOU AS HIS -- FIGURE OUT HOW

 

 7  TO PHRASE THIS -- AS HIS ACTING OUT AT THE NURSING HOME THAT

 

 8  LAST MONTH IN SAY DECEMBER AND JANUARY?

 

 9  A.   WELL, HIS -- I WOULD RECEIVE PHONE CALLS FROM NURSING

 

10  HOME TALKING ABOUT HOW HE WAS MORE AGITATED.  HE WAS THROWING

 

11  THINGS.  HE THREW -- HE WAS THROWING WALKERS.  I DON'T HAVE

 

12  ANY SPECIFIC INFORMATION EXACTLY MECHANICALLY HOW THAT

 

13  OCCURRED.  I DON'T KNOW WHAT POSITION HE WAS IN WHEN HE WAS

 

14  DOING THAT.  HE HAD IN SOME MANNER -- TO BE PRECISE AS BEST I

 

15  CAN HERE, ON DECEMBER 28TH, I HAVE A NOTE FROM THE NURSING

 

16  HOME THAT SAID, PATIENT VERY AGITATED.  THROWING WHEELCHAIR

 

17  YESTERDAY.  CAUSED A PATIENT TO FALL.  PATIENT BROKE HIP.

 

18  PATIENT IS UNABLE TO ATTEND ACTIVITIES, TOO COMBATIVE.  AND

 

19  THAT WAS THE -- THAT WAS THE VISIT THAT I MODIFIED HIS

 

20  MELLARIL AT THAT POINT, AND THEN ASKED THAT HE COME IN AND BE

 

21  SEEN.

 

22  Q.   HAD YOU WRITTEN ANY ORDERS FOR P.R.N. MEDICATIONS TO

 

23  CALM HIM DOWN, IF YOU RECALL?  P.R.N. MEANING AS NEEDED, THE

 

24  NURSES COULD DECIDE WHEN IT WAS REQUIRED?

 

25  A.   ON DECEMBER 18TH I WROTE, WHEN -- WHEN PATIENT VERY

 

 1  COMBATIVE, MAY GIVE 5 MILLIGRAM HALDOL.  I THINK TO BE

 

 2  PRECISE, YOU'D HAVE TO LOOK AT THE NURSING RECORDS AND SEE

 

 3  WHAT THEY HAD ORDERED ON THEIR RECORDS AS TO WHETHER HE HAD

 

 4  AN AS NEEDED MEDICATION ORDERED.  THE IMPLICATION FROM THAT

 

 5  NOTE IN MY CHART WAS THAT HE DID HAVE AN AS NEEDED ORDER, BUT

 

 6  I CAN'T CONFIRM THAT OTHERWISE.

 

 7  Q.   AND WHAT IS HALDOL?

 

 8  A.   IT'S ANOTHER ANTIPSYCHOTIC MEDICATION THAT WE USE FOR

 

 9  TREATMENT OF AGITATION OFTENTIMES IN DEMENTED PATIENTS.

 

10  Q.   DOES IT SEDATE A PATIENT?

 

11  A.   IT CAN.

 

12  Q.   IT CAN.  GIVEN HIS COMBATIVENESS, DID THEY -- DID ANYONE

 

13  CONTACT YOU ABOUT SEDATING HIM IN ORDER TO TRANSFER HIM TO

 

14  DAVIS NORTH, THAT YOU KNOW OF?

 

15  A.   NOT THAT I KNOW OF.  I HAVE NO RECORD OF THAT.

 

16  Q.   YOU DIDN'T ORDER ANYTHING TO SEDATE HIM FOR TRANSFER?

 

17  A.   I DON'T RECALL HAVING DONE THAT.  IT'S OBVIOUSLY BEEN A

 

18  LONG TIME AGO.  I DON'T RECALL IT.  I HAVE NO NOTATION OF

 

19  THAT, SO I WOULD SAY LIKELY NOT.

 

20  Q.   IF THE NURSING HOME HAD WANTED SOME KIND OF SEDATIVE IN

 

21  ORDER TO TRANSFER HIM, COULD THEY HAVE CALLED A DIFFERENT

 

22  DOCTOR --

 

23  A.   POSSIBLE.

 

24  Q.   -- ORDERED THAT?

 

25  A.   WELL, SOMEONE COVERING FOR ME, IF IT WOULD HAVE BEEN

 

 1  AFTER HOURS OR IF IT WOULD HAVE BEEN MY AFTERNOON OFF, THEY

 

 2  MIGHT HAVE CONTACTED SOMEONE ELSE.  THAT WOULD BE THE

 

 3  CIRCUMSTANCE THEY WOULD HAVE DONE THAT.  THEY MAY HAVE HAD A

 

 4  P.R.N. ORDER, AS NEEDED ORDER, FOR MEDICATION TO BE GIVEN AND

 

 5  THEY COULDN'T HAVE DONE IT IN THAT MANNER.

 

 6       MS. BARLOW:  THANK YOU.  THOSE ARE ARE THE QUESTIONS I

 

 7  HAVE, YOUR HONOR.

 

 8       THE COURT:  CROSS-EXMINE, MR. BUGDEN.

 

 9                        CROSS-EXAMINATION

 

10  BY MR. BUGDEN:

 

11  Q.   GOOD MORNING, DR. CUNNINGHAM.

 

12  A.   HI.

 

13  Q.   I'M WALTER BUGDEN.  I'M ONE OF THE LAWYERS REPRESENTING

 

14  DR. WEITZEL.  I'D LIKE TO BEGIN WITH SORT OF SOME BIG PICTURE

 

15  QUESTIONS AND THEN WE WILL WALK THROUGH THE CHARTS AGAIN.  I

 

16  APOLOGIZE.

 

17  A.   THAT'S FINE.

 

18  Q.   DR. CUNNINGHAM, THIS PATIENT, MR. ALLDREDGE, HAD

 

19  END-STATE DEMENTIA, IS THAT RIGHT?

 

20  A.   HE HAD -- HE HAD SERIOUS -- HE HAD SEVERE DEMENTIA.

 

21  END-STAGE?  THAT'S KIND OF A VAGUE TERM, BUT I'D SAY HIS

 

22  DEMENTIA WAS SEVERE.

 

23  Q.   OVER THE PERIOD OF TIME THAT YOU'VE DESCRIBED FOR US

 

24  THAT YOU TREATED ENNIS ALLDREDGE, YOU SAW A PROGRESSIVE

 

25  DECLINE IN HIS MENTAL FUNCTIONING, ISN'T THAT RIGHT?

 

 1  A.   CORRECT.

 

 2  Q.   WE'RE GONNA TALK ABOUT THAT IN JUST A MOMENT, BUT IT

 

 3  WENT FROM A LOT OF DISORIENTATION IN THE VERY BEGINNING OF

 

 4  YOUR INTERACTION WITH THIS PATIENT TO, BY THE END, BY THE

 

 5  NOVEMBER VISIT THAT YOU HAD WITH HIM, HE WAS EXTREMELY

 

 6  DISORIENTED, COULDN'T RESPOND TO QUESTIONS, AM I RIGHT?

 

 7  A.   I THINK THAT WHEN I INITIALLY SAW HIM, I WAS AT LEAST

 

 8  THROUGH MY RECORDS AND INTERPRETING MY RECORDS, I WAS ABLE TO

 

 9  CONVERSE WITH HIM.

 

10  Q.   IN THE BEGINNING.

 

11  A.   IN THE BEGINNING.

 

12  Q.   BY THE END YOU WERE --

 

13  A.   BY THE END, HE HAD SUBSTANTIALLY DECLINED.  HE WAS TO

 

14  THE POINT WHERE HE COULD NOT TALK.  I COULD NOT HOLD A

 

15  COMMUNICATION WITH HIM.  HIS SPEECH WAS TOTALLY INCOHERENT.

 

16  SO THERE WAS A DR -- THERE WAS A SUBSTANTIAL CHANGE IN HIS

 

17  MENTAL STATUS BETWEEN APRIL OF '95 AND JANUARY OF 1996.

 

18  Q.   AND IN THE LAST FEW MONTHS, IN NOVEMBER AND DECEMBER

 

19  LEADING UP TO JANUARY 4TH, IN ADDITION TO THE DISORIENTATION

 

20  OR HIS INABILITY TO COMMUNICATE WITH YOU, ANOTHER CHANGE IN

 

21  THIS MAN'S BEHAVIOR WAS THAT HE BECAME EXTREMELY COMBATIVE,

 

22  AM I RIGHT?

 

23  A.   IN MY RECORDS I -- WHEN I WAS REVIEWING MY RECORDS, I

 

24  NOTED THAT HIS COMBATIVENESS, HIS AGITATION, COMBATIVENESS

 

25  SEEMED TO START IN DECEMBER.

 

 1  Q.   WELL, LET'S TAKE IT RIGHT THERE.

 

 2  A.   UH-HUH.

 

 3  Q.   IN DECEMBER, BY DECEMBER, THOUGH, WE HAVE AN INCREASING

 

 4  PATTERN OF HIM INJURING PEOPLE?

 

 5  A.   CORRECT.

 

 6  Q.   STRIKING OUT AT THE CARE PROVIDERS.

 

 7  A.   RIGHT.

 

 8  Q.   AND COUNSEL JUST ASKED YOU ABOUT THIS GENTLEMAN'S

 

 9  STRENGTH.  I MEAN, THIS WAS AN 82-YEAR-OLD MAN WHO WEIGHED

 

10  ABOUT 200 POUNDS.  AND IN SPITE OF BEING 82 YEARS OLD, IN

 

11  LATE DECEMBER HE WAS ABLE TO PICK UP A WHEELCHAIR AND THROW

 

12  THAT AT ANOTHER RESIDENT BREAKING THAT RESIDENT'S HIP, IS

 

13  THAT RIGHT?

 

14  A.   WHAT -- ALL I CAN STATE IS THAT SOMEHOW A WHEELCHAIR

 

15  ENDED UP INTO A PATIENT, AND WHETHER HE PICKED IT UP OR

 

16  PUSHED IT OUT, I DON'T KNOW THAT MECHANISM HE USED, BUT HE

 

17  HAD -- HE WAS STRONG ENOUGH TO ALLOW THAT TO OCCUR.  I GUESS

 

18  THAT'S AS BEST I CAN SAY.

 

19  Q.   DOCTOR, WE HAVE -- THESE ARE GONNA BE PROBABLY THE SAME

 

20  RECORDS THAT WE'VE BEEN TALKING ABOUT, BUT THEY'RE ORGANIZED

 

21  IN A DIFFERENT WAY.

 

22  A.   OKAY.

 

23  Q.   AND LET ME JUST SHOW YOU.  EXCUSE ME, I SOMETIMES MORE

 

24  OFTEN THAN NOT WILL USE THIS NUMBER TO IDENTIFY IT FOR THE

 

25  JUDGE.  BUT IT MAY BE EASIER TO BRING YOU TO THE PAGE I WANNA

 

 1  TALK ABOUT --

 

 2  A.   OKAY.

 

 3  Q.   -- BY TALKING ABOUT THAT NUMBER IN THE --

 

 4  A.   THAT'S FINE.

 

 5  Q.   -- RIGHT-HAND SIDE CORNER.  YOU FIRST SAW MR. ALLDREDGE

 

 6  IN APRIL, AM I RIGHT, APRIL 17TH?

 

 7  A.   CORRECT.

 

 8  Q.   AND AT THAT TIME HE WAS BROUGHT TO YOUR OFFICE BY VONDA,

 

 9  HIS WIFE, IS THAT RIGHT?

 

10  A.   CORRECT.

 

11  Q.   SHE WAS A 78-YEAR-OLD WOMAN, DOES IT SAY THAT?

 

12  A.   AS I UNDERSTAND, RIGHT.

 

13  Q.   AND DURING THAT FIRST VISIT, MRS. ALLDREDGE WAS UPSET,

 

14  IS THAT RIGHT?

 

15  A.   CORRECT.

 

16  Q.   SHE WAS TEARFUL IN YOUR OFFICE, IS THAT RIGHT?

 

17  A.   CORRECT.

 

18  Q.   AND THE STRESS OF TAKING CARE OF MR. ALLDREDGE REALLY

 

19  HAD BECOME TOO MUCH FOR HER, IT WAS QUITE OVERWHELMING.

 

20  A.   RIGHT.

 

21  Q.   AND YOU THEN DID A MEDICAL EXAMINATION AND YOU'VE TOLD

 

22  US ABOUT SOME OF THE FINDINGS THAT YOU MADE.  ONE OF THE

 

23  FINDINGS -- THIS WAS PROBABLY JUST THE HISTORY THAT WAS

 

24  GIVEN -- WAS THAT HE HAD THE MYCOSIS FUNGOIDES, IS THAT

 

25  RIGHT?

 

 1  A.   RIGHT.

 

 2  Q.   HE ALSO HAD DIABETES?

 

 3  A.   CORRECT.

 

 4  Q.   AND THAT HAD TO BE TREATED WITH -- OR HE HAD TO RECEIVE

 

 5  SHOTS?

 

 6  A.   WITH INSULIN, RIGHT.

 

 7  Q.   WITH INSULIN.  THE PRINCIPAL DIAGNOSIS -- AND I THINK,

 

 8  YOUR HONOR AND COUNSEL, THIS IS STATE'S EXHIBIT 6-A, AND IT'S

 

 9  THE NURSING HOME RECORD 1 -- OR 13-B-2.  AND IT LOOKS TO ME,

 

10  DOCTOR, LIKE THAT'S SLIDE 2 FOR YOU.  OR ACTUALLY IT'S --

 

11  LET'S SEE HERE, SLIDE 4 OR PICTURE 4 FOR YOU.  AM I CORRECT

 

12  THAT YOU DID MAKE THE DIAGNOSIS OF DEMENTIA ON THAT DATE?

 

13  A.   I FELT THAT THE WAY HE PRESENTED, IT WAS CONSISTENT WITH

 

14  DEMENTIA.  I HAD BEEN TOLD EITHER BY HIS WIFE OR HIMSELF THAT

 

15  HE HAD A PREVIOUS HISTORY OF DEMENTIA, SO I DIDN'T

 

16  NECESSARILY MAKE THE DIAGNOSIS.  IT HAD ALREADY BEEN

 

17  CONCLUDED.  BUT I FELT HIS PRESENTATION WAS DEFINITELY

 

18  CONSISTENT WITH THAT.

 

19  Q.   AND HE ALSO HAD CORONARY ARTERY DISEASE, IS THAT RIGHT?

 

20  A.   RIGHT.

 

21  Q.   AND YOU TALKED ABOUT, HE WASN'T IN ACUSE DISTRESS IN

 

22  YOUR OFFICE, FOR EXAMPLE, WITH THE CORONARY ARTERY DISEASE,

 

23  THIS WAS AN 82-YEAR-OLD MAN.  THIS IS SOMEONE WHO COULD

 

24  SUFFER A HEART ATTACK REALLY AT ANY APPOINTMENT AT THAT AGE

 

25  WOULD --

 

 1  A.   CORRECT.

 

 2  Q.   -- WOULD THAT -- IS THAT RIGHT?

 

 3  A.   SURE, CORRECT.

 

 4  Q.   THEN IF I CAN ASK YOU SOME QUESTIONS ABOUT DEMENTIA,

 

 5  WITH THIS VERY PATIENT USE -- DEMENTIA IS A PROGRESSIVE

 

 6  DISEASE, ISN'T IT?

 

 7  A.   YES.

 

 8  Q.   AND WITH THIS VERY PATIENT, YOU COULD SEE THE

 

 9  PROGRESSIVE NATURE OF HIS LOSS OF MENTAL FUNCTIONING.

 

10  A.   CORRECT.

 

11  Q.   IN THE INITIAL EXAMINATION, IT WAS REPORTED TO YOU THAT

 

12  THERE HAD BEEN I GUESS A RECENT MENTAL STATUS CHANGE, IS THAT

 

13  WHAT HIS WIFE TOLD YOU?  MAYBE FOR YOU, DOCTOR, PAGE 5.

 

14  A.   WELL, I'D HAVE TO -- I'D HAVE -- I THINK I KNOW WHAT

 

15  YOU'RE REFERRING TO --

 

16  Q.   WELL, LET ME JUST --

 

17  A.   I HAD TOLD HIM HE HAD REC -- HE HAD PROBLEMS WITH RECENT

 

18  MEMORY LOSS, MEANING, IT'S HARD FOR ME TO INTERPRET EXACTLY

 

19  WHETHER THAT MEANS HE -- SHE HAD NOTED PROGRESSIVE LOSS OF

 

20  MEMORY MORE SO THAN SHE HAD NOTED BEFORE OR WHETHER THIS WAS

 

21  JUST A STATEMENT OF SAYING THAT HE LOST HIS MEMORY.

 

22  Q.   OKAY.

 

23  A.   SO I DON'T KNOW.

 

24  Q.   DURING THE EXAMINATION ON THAT DATE, YOU DID TRY TO ASK

 

25  A FEW QUESTIONS THAT WERE DESIGNED TO SEE WHAT SORT OF FUND

 

 1  OF GENERAL INFORMATION --

 

 2  A.   RIGHT.

 

 3  Q.   AND FOR EXAMPLE, HE WAS UNABLE TO TELL YOU WHO THE

 

 4  PRESENT PRESIDENT OF THE UNITED STATES WAS, IS THAT RIGHT?

 

 5  A.   CORRECT.

 

 6  Q.   AND THEN YOU ALSO ASKED HIM IF HE COME IDENTIFY WHAT THE

 

 7  SIMILARITY MIGHT BE BETWEEN A BOWLING BALL AND AN ORANGE.

 

 8  AND HIS RESPONSE WAS THAT YOU CAN GET JUICE OUT OF A BOWLING

 

 9  BALL?

 

10  A.   RIGHT.

 

11  Q.   SO OBVIOUSLY, THERE WAS A DISCONNECT THERE?

 

12  A.   CORRECT.

 

13  Q.   THEN AS I UNDERSTAND IT, YOU DID SEE HIM ALMOST EVERY

 

14  DAY -- OR I'M SORRY, EVERY MONTH FROM ONCE HE WAS -- IS THAT

 

15  RIGHT?

 

16  A.   I SAW HIM APRIL.  I SAW HIM A MONTH LATER IN MAY.  I SAW

 

17  HIM IN EARLY AUGUST.  HE WAS ADMITTED TO A NURSING HOME AT

 

18  THE END OF AUGUST, SO I SAW HIM JUST AFTER HE HAD BEEN

 

19  ADMITTED IN THE NURSING HOME IN AUGUST.  I SAW HIM IN OCTOBER

 

20  FOR THE NAUSEA AND VOMITING EPISODE THAT WE'VE TALKED ABOUT.

 

21  I SAW HIM IN I BELIEVE NOVEMBER.  DECEMBER HE HAD ALL OF

 

22  THESE EPISODES OF AGITATION, COMBATIVENESS, THAT WE WERE

 

23  TRYING TO SUBDUE WITH MEDICATION --

 

24  Q.   DOCTOR, WE'RE GONNA WALK THROUGH SOME OF THOSE

 

25  EXAMINATIONS.  YOU DID SEE HIM IN OCTOBER, AM I RIGHT?

 

 1  OCTOBER 12TH?

 

 2  A.   RIGHT.

 

 3  Q.   AND IF I COULD ASK YOU TO TURN TO PAGE 6?

 

 4  A.   OKAY.

 

 5  Q.   NOW, HE WAS LIVING IN THE SUNSHINE TERRACE NURSING HOME

 

 6  BY THEN IS THAT RIGHT?

 

 7  A.   CORRECT.

 

 8  Q.   BY THAT TIME HIS SPEECH WAS -- WELL, HE WASN'T ABLE TO

 

 9  SPEAK AS LUCIDLY, IS THAT WHAT YOU'VE WRITTEN?

 

10  A.   RIGHT.

 

11  Q.   IS THERE A BLOW-UP OF THAT?  AND BY THIS TIME WAS HE

 

12  BEGINNING TO HAVE APHASIA, SIR?

 

13  A.   HE WAS DEFINITELY HAVING SIGNIFICANT DIFFICULTIES WITH

 

14  COMMUNICATION.  IT WAS DIFFICULT TO UNDERSTAND EXACTLY WHAT

 

15  HE WAS SAYING.

 

16  Q.   OKAY.  THEN YOU SAW HIM AGAIN AFTER -- IN NOVEMBER, IS

 

17  THAT RIGHT?  NOVEMBER 16TH?

 

18  A.   CORRECT.

 

19  Q.   I THINK THAT THAT'S YOUR SLIDE OR YOUR NUMBER 8.  AND

 

20  THIS IS N.H. 20, JUDGE.  AGAIN, HE WAS HAVING -- IS THERE A

 

21  BLOW-UP OF THAT PAGE PLEASE?  EXPRESSIVE APHASIA.  THAT MEANS

 

22  HE COULDN'T -- COULDN'T SPEAK CLEARLY OR HE COULDN'T SPEAK

 

23  REALLY AT ALL?

 

24  A.   HE WOULD -- HE COULD NOT -- IT WOULD NOT BE THAT HE

 

25  COULD NOT VERBALLY UTTER SOMETHING; IT WAS NONSENSICAL.

 

 1  Q.   OKAY.  NOW, ON THAT DATE, DO YOU RECALL, DOCTOR, THAT

 

 2  YOU AND MRS. ALLDREDGE FILLED OUT A MEDICAL TREATMENT PLAN?

 

 3  A.   (WITNESS SHAKES HEAD.)

 

 4  Q.   DID YOU DO THAT, DOCTOR?

 

 5  A.   I DON'T KNOW.

 

 6  Q.   COULD WE LOOK -- WOULD YOU LOOK AT NUMBER 10, AND,

 

 7  JUDGE, THIS IS N.H. 278.  IS THERE A BLOW-UP OF THIS PAGE AS

 

 8  WELL?  OH, LET'S GO BACK TO THE BIGGER PICTURE THEN.  DO YOU

 

 9  HAVE A COPY AS WELL THAT YOU COULD LOOK AT OR USING YOUR

 

10  REPORT, DOCTOR?

 

11  A.   I DON'T HAVE THAT BUT, I'M QUITE FAMILIAR WITH THOSE.

 

12       THE COURT:  MOVE YOUR CHAIR OVER, DOCTOR, IF YOU NEED TO

 

13  SO YOU CAN --

 

14  A.

 

15       THE WITNESS:  LET ME SEE IF I HAVE ONE -- CHART.

 

16  Q.  (BY MR. BUGDEN)  THAT'S NOT IN THE DOCUMENT YOU HAVE?

 

17  A.   I DON'T THINK SO.  I DON'T REMEMBER SEEING IT, BUT LET

 

18  ME --

 

19  Q.   THE ONES I GAVE YOU?  PAGE 10?

 

20  A.   OKAY.  I HAVE THAT.  GO AHEAD.

 

21  Q.   BEARS YOUR NAME AT THE TOP.

 

22  A.   UH-HUH.

 

23  Q.   CAN YOU RECOGNIZE ANY OF THIS WRITING?  FOR EXAMPLE, IS

 

24  THIS YOUR SIGNATURE DOWN WHERE IT SAYS TEN ELEVEN?

 

25  A.   THAT IS MY SIGNATURE.

 

 1  Q.   AND AT THAT TIME WHEN YOU FILLED THIS OUT ON OCTOBER

 

 2  11TH, YOU SAID THAT MR. ALLDREDGE WAS SUFFERING FROM

 

 3  ALZHEIMER'S, AND YOU'VE CHECKED OFF THE BOX THAT HE WAS IN A

 

 4  CONDITION WHICH RENDERED HIM INCAPABLE OF MAKING MEDICAL

 

 5  DECISIONS, IS THAT RIGHT?

 

 6  A.   CORRECT.

 

 7  Q.   AND THEN MRS. ALLDREDGE, THE WIFE, SIGNED ON BEHALF OF

 

 8  MR. ALLDREDGE, IS THAT RIGHT?

 

 9  A.   THAT'S CORRECT.

 

10  Q.   AND YOU'VE EXPLAINED TO US THAT BY THIS TIME, YOU'D

 

11  BEGUN TO SEE THE MENTAL DECLINE AND THE EXPRESSIVE APHASIA.

 

12  DO YOU BELIEVE THAT BECAUSE OF THE MENTAL DECLINE WITH

 

13  PATIENT, THAT THAT MAY BE WHY YOU AND MRS. ALLDREDGE FILLED

 

14  OUT A MEDICAL TREATMENT PLAN ON THAT OCCASION?

 

15  A.   I WOULD SAY THAT THAT THAT'S TRUE, THAT HIS DEMENTIA HAD

 

16  PROGRESSED.  HIS WIFE OBVIOUSLY WAS LIVING WITH IT EVERY DAY

 

17  UP UNTIL HE WAS ADMITTED THE NURSING HOME.  RECOGNIZED THAT

 

18  HIS CONDITION WAS DETERIORATING.  AND RECOGNIZED THAT HE WAS

 

19  INCAPABLE OF PROVIDING AN ANSWER TO THE ISSUE OF

 

20  RESUSCITATIVE MEASURES.  SHE MADE THE DECISION BASED UPON

 

21  THAT INFORMATION.

 

22  Q.   AND BECAUSE OF THE DECLINE AND DETERIORATING CONDITION,

 

23  DO YOU THINK YOU WOULD HAVE TALKED WITH MRS. ALLDREDGE ABOUT

 

24  WHAT HE WOULD LIKE TO DO IN THE EVENT THAT SOME MEDICAL ACUTE

 

25  PROBLEM OCCURS AND YOU WOULD HAVE TALKED ABOUT THE NO C.P.R.,

 

 1  NO RESPIRATORS?

 

 2  A.   SOMETIMES WE DISCUSS THIS DIRECTLY.  SOMETIMES THE

 

 3  CAREGIVERS, THE WIFE, THE RESPONSIBLE PERSON TAKES IT UPON

 

 4  THEMSELVES TO FILL THIS INFORMATION OUT BASED UPON THE

 

 5  PATIENT'S MEDICAL CONDITION.  I DON'T KNOW WHICH ONE OF THOSE

 

 6  CIRCUMSTANCES OCCURRED HERE.

 

 7  Q.   OKAY.  NOW, YOU'VE TALKED ABOUT HIS DETERIORATING

 

 8  CONDITION.  AT 82 YEARS OLD, DR. CUNNINGHAM, A PERSON WITH

 

 9  LONG -- I MEAN HE DID HAVE LONGSTANDING DIABETES, HE HAD THE

 

10  BYPASS SURGERY, HE WAS SUFFERING FROM DEMENTIA WHERE YOU

 

11  COULD SEE A PROGRESSIVE CHANGE, HE HAD CORONARY ARTERY

 

12  DISEASE, HYPOTHYROIDISM.  WOULD YOU SAY THAT ALL OF THOSE

 

13  CONDITIONS TOGETHER WOULD MAKE MR. ALLDREDGE SOMEONE WHO

 

14  WOULD BE SUSCEPTIBLE TO OR A CANDIDATE FOR A STROKE?

 

15  A.   PEOPLE WITH CORONARY ARTERY DISEASE AND HYPERTENSION

 

16  HAVE AN INCREASED INCIDENCE OF STROKE, SO I THINK HIS RISKS

 

17  FOR HAVING THAT HAPPEN WERE -- WOULD BE GREATER THAN SOMEONE

 

18  WITHOUT THOSE, CORRECT.

 

19  Q.   AND --

 

20  A.   AND DIABETES.

 

21  Q.   -- DOCTOR, WITH -- WITH THIS POPULA -- OR THIS AGE GROUP

 

22  OF PATIENT, ELDERLY PEOPLE, WHEN THEY BECOME ACUTELY ILL --

 

23  WELL, FIRST LET ME ASK YOU, IT DOESN'T REALLY TAKE MUCH OF AN

 

24  INFECTION OR MUCH OF A PROBLEM FOR PEOPLE AT THIS AGE GROUP

 

25  TO BECOME VERY ILL.  WOULD YOU AGREE WITH THAT?

 

 1  A.   YES.

 

 2  Q.   THEN YOU ALSO SAW THE PATIENT ON JANUARY 4TH, IS THAT

 

 3  RIGHT?

 

 4  A.   CORRECT.

 

 5  Q.   AND BY THIS TIME, MR. ALLDREDGE HAD BEGUN TO DEMONSTRATE

 

 6  THESE COMBATIVE BEHAVIORS THAT WE'VE TALKED ABOUT, THE

 

 7  VIOLENT BEHAVIOR, IS THAT RIGHT?

 

 8  A.   CORRECT.

 

 9  Q.   BY THAT TIME, HE'D INJURED ANOTHER PATIENT AT THE

 

10  NURSING HOME, IS THAT RIGHT?

 

11  A.   RIGHT.

 

12  Q.   AND IT'D BEEN REPORTED TO YOU THAT HE'D STRUCK OUT OR

 

13  HIT HIS CARE PROVIDERS, IS THAT RIGHT?  COULD I ASK YOU TO

 

14  TURN TO PAGE 12 THAT I'VE GIVEN YOU THERE, AND IT'S N.H. 21?

 

15  A.   I HAVE THAT.

 

16  Q.   COULD YOU JUST READ THE HISTORY SECTION, AND THEN I MAY

 

17  INTERRUPT YOU OCCASIONALLY AS YOU'RE READING IT TO THE JURY?

 

18  A.   OKAY.  82-YEAR-OLD MALE WHO HAD BEEN HAVING DIFFICULTY

 

19  CONTROLLING HIS DEMENTIA AND AGITATION OVER THE PRECEDING

 

20  MONTH.  WE HAVE BEEN ACCELERATING HIS MELLARIL UP TO A DOSE

 

21  CURRENTLY OF 15 MILLIGRAMS THREE TIMES DAILY WITH THE

 

22  ADDITION OF --

 

23       THE COURT:  SLOW DOWN PLEASE, IF YOU YOU WOULD.

 

24       THE WITNESS:  -- WITH THE ADDITION OF BUSPAR

 

25  APPROXIMATELY TWO WEEKS AGO OF 10 MILLIGRAMS THREE TIMES

 

 1  DAILY.  HE CONTINUES TO BE COMBATIVE AND DIFFICULT TO MANAGE.

 

 2  A NOTE FROM THE NURSING STAFF WAS RECEIVED.  IT STATED THAT

 

 3  HE IS STILL HAVING OUTBURSTS OF CONFUSION, AND SOME APPARENT

 

 4  OCCASIONAL DEPRESSED CRYING EPISODES.

 

 5  Q.  (BY MR. BUGDEN)  NOW, YOU CHANGED HIS MEDICATION.  HE HAD

 

 6  BEEN ON MELLARIL, IS THAT RIGHT?

 

 7  A.   HE HAD BEEN ON MELLARIL.

 

 8  Q.   LET ME STOP YOU THERE.  AND IS THAT AN ANTIPSYCHOTIC,

 

 9  DOCTOR?

 

10  A.   YES.

 

11  Q.   AND DID YOU DISCONTINUE THE MELLARIL AND START HIM ON

 

12  RISPERDAL?

 

13  A.   YES, AT -- AT THAT VISIT.

 

14  Q.   AND HE ALSO WAS ON THE BUSPAR?

 

15  A.   CORRECT.

 

16  Q.   WHAT IS BUSPAR PLEASE?

 

17  A.   THAT'S AN ANTI-ANXIETY.

 

18  Q.   SO AND THE RISPERDAL IS ALSO AN ANTI-ANXIETY, IS IT?

 

19  A.   IT'S AN ANTI-PSYCHOTIC SIMILAR TO MELLARIL.

 

20  Q.   SO AT THAT POINT YOU HAD HIM ON THE BUSPAR AND THE

 

21  RISPERDAL, ALL TRYING TO CONTROL THIS AGITATION?

 

22  A.   CORRECT.

 

23  Q.   AND YOU WERE AWARE THAT BOTH OF THOSE, THE BUSPAR AND

 

24  RISPERDAL, THEY DO HAVE A POSSIBLE SEDATING EFFECT, IS THAT

 

25  RIGHT?

 

 1  A.   SURE.

 

 2  Q.   AND IN FACT, THAT WAS THE GOAL, WAS TO TRY TO GET THE

 

 3  AGITATION UNDER CONTROL AND TO MELLOW HIM OUT, IS THAT RIGHT?

 

 4  A.   RIGHT, CORRECT.

 

 5  Q.   AND COULD WE TURN TO -- I THINK IT'S PAGE 14, DOCTOR.

 

 6  A.   I'M THERE.

 

 7  Q.   IN FACT, THERE MAY BE A BLOW-UP OF THAT.

 

 8       THE COURT:  WHAT'S THE NUMBER FOR THE COURT'S BENEFIT?

 

 9       MR. BUGDEN:  IT'S N.H. 22, JUDGE.

 

10  Q.  (BY MR. BUGDEN)  THE NOTE SAYS THAT YOU'RE GONNA

 

11  DISCONTINUE THE MELLARIL, AND THEN IT SAYS, WILL TRY THE

 

12  RESPECTFUL -- THAT'S ACTUALLY THE RISPERDAL --

 

13  A.   RIGHT.

 

14  Q.   -- RIGHT?  THEN THE NOTE ALSO SAYS, OBVIOUSLY IF THIS

 

15  MEDICINE CAUSES OVERSEDATION, WE'LL DISCONTINUE IT.  IS THAT

 

16  RIGHT?

 

17  A.   RIGHT.

 

18  Q.   SO THE IDEA WAS, YOU HAD TO RESPOND TO THE SYMPTOMS AT

 

19  THAT POINT, YOU'RE TRYING TO RESPOND TO THE REPORTS AND THEN

 

20  YOU -- IF MEDICATION IS TOO STRONG FOR THE PATIENT, THEN YOU

 

21  LOWER THE DOSAGE.

 

22  A.   RIGHT.  AND I START AT AN EXTREMELY LOW DOSE, WITH THE

 

23  PLANS OF WORKING UP ON THE DOSAGE AS NECESSARY.

 

24  Q.   OKAY.  THEN ON JANUARY 8TH, THAT'S WHEN THE -- BY THAT

 

25  TIME, LET'S SEE HERE, FROM JANUARY 4TH TO JANUARY 8TH, HE'D

 

 1  BEEN ON THE RISPERDAL AND THE BUSPAR AND THEY HADN'T WORKED,

 

 2  RIGHT?  THEY HADN'T GOTTEN THE CONTROL OR GOTTEN CONTROL OF

 

 3  HIS AGITATION.

 

 4  A.   CORRECT.

 

 5  Q.   AND THAT'S WHEN YOU GOT THE PHONE CALL FROM THE NURSING

 

 6  HOME?

 

 7  A.   RIGHT.  HE'D APPARENTLY HIT AN AIDE IN THE ABDOMEN AND

 

 8  HE THREW A BINGO GAME --

 

 9  Q.   SO EVEN WITH THE RISPERDAL AND THE BUSPAR, HE WAS EVEN

 

10  MORE COMBATIVE.  OR THE LEAST HE STRUCK OUT.

 

11  A.   WELL, HE WAS STILL COMBATIVE.  I DON'T KNOW TO WHAT

 

12  DEGREE HE WAS COMPARATIVELY, BUT HE WAS STILL COMBATIVE.

 

13  Q.   OKAY.  AND THEN ON THAT DATE, YOU INCREASED THE

 

14  RISPERDAL TO ONE MILLIGRAM, AM I RIGHT?

 

15  A.   CORRECT.

 

16  Q.   AND ALSO TO TRY TO DEAL WITH THE IMMEDIATE NATURE OF THE

 

17  PROBLEM, YOU ORDERED THAT HE BE -- THAT HE BE STARTED ON 3

 

18  MILLIGRAMS OF ATIVAN, IS THAT RIGHT?

 

19  A.   CORRECT.  THAT WAS BASED UPON THE WAY I'VE WRITTEN THIS,

 

20  IT WAS A ONE-TIME ORDER.  3 MILLIGRAM I.M.

 

21  Q.   INTRAMUSCULAR, IS THAT --

 

22  A.   CORRECT.

 

23  Q.   -- WHAT I.M. MEANS?

 

24  A.   CORRECT.

 

25  Q.   AND THEN YOU RECOMMENDED THAT HE BE TRANSFERRED TO THE

 

 1  DAVIS HOSPITAL BECAUSE OF THE AGITATION?

 

 2  A.   RIGHT.

 

 3  Q.   BECAUSE IN SPITE OF THE INCREASING MEDICATIONS THAT

 

 4  YOU'D TRIED OR THE DIFFERENT COMBINATIONS OF MEDICATIONS THAT

 

 5  YOU'D TRIED, YOU JUST WEREN'T ABLE TO CONTROL THE

 

 6  COMBATIVENESS?

 

 7  A.   I WASN'T ABLE TO CONTROL HIM.  HE WAS CONTINUING TO

 

 8  INJURE OTHER INDIVIDUALS AT THE NURSING HOME.

 

 9  Q.   AND THAT, FOR EXAMPLE, THE PATIENT THAT APPARENTLY HAD A

 

10  BROKEN HIP AS A RESULT OF THE WHEELCHAIR COLLISION, THAT

 

11  POSES A SIGNIFICANT HEALTH PROBLEM FOR THE OTHER PATIENTS,

 

12  DOESN'T IT?

 

13  A.   SURE.

 

14  Q.   AND THE NURSING HOME JUST COULDN'T HANDLE THIS MAN AT

 

15  THAT POINT.

 

16  A.   I COULDN'T HANDLE THIS MAN.

 

17       MR. BUGDEN:  OKAY.  THANK YOU VERY MUCH.

 

18       THE WITNESS:  SURE.

 

19       THE COURT:  REDIRECT, MS. BARLOW.

 

20       MS. BARLOW:  THANK YOU, YOUR HONOR.

 

21                        REDIRECT EXAMINATION

 

22  BY MS. BARLOW:

 

23  Q.   DR. CUNNINGHAM, I WANT TO JUST FOLLOW UP ON A FEW

 

24  MATTERS HERE.  MR. BUGDEN ASKED YOU ABOUT END-STAGE DEMENTIA.

 

25  AND YOU SAID THAT'S A VAGUE TERM.  HAVE THERE BEEN ANY

 

 1  STUDIES DONE ABOUT DEMENTIA AND LIFE EXPECTANCY?

 

 2  A.   I'M NOT QUALIFIED TO ANSWER THAT.  I DON'T KNOW OF ANY

 

 3  SPECIFIC STUDIES.  A NEUROLOGIST MIGHT HAVE A BETTER WORKING

 

 4  KNOWLEDGE OF THE --

 

 5  Q.   OKAY.

 

 6  A.   -- LITERATURE.  I DON'T.

 

 7  Q.   BUT IT IS PROGRESSIVE?

 

 8  A.   RIGHT.

 

 9  Q.   CAN YOU EVER LOOK AT A PATIENT'S POSITION OR STAGE AND

 

10  SAY, THEY'RE NO LONGER ABLE TO DO THIS, YOU SAY THAT'S MORE

 

11  SEVERE.  CAN YOU EVER SAY HOW MANY MORE YEARS THEY HAVE TO

 

12  LIVE FROM WHAT THEY CAN DO OR CANNOT DO?

 

13  A.   THERE IS -- THE CRITERION I'M -- I'M KNOWLEDGEABLE OF IS

 

14  USED WITH HOSPICE.  MEDICARE HAS SPECIFIC CRITERION THEY USE

 

15  IN TERMS OF TRYING TO OBJECTIVELY DETERMINE WHEN SOMEBODY'S

 

16  AN APPROPRIATE HOSPITAL CANDIDATE -- A HOSPICE, EXCUSE ME,

 

17  HOSPICE CANDIDATE.

 

18  Q.   MEANING SIX MONTHS LEFT TO LIVE.

 

19  A.   CORRECT.  THESE ARE NOT MEANT TO BE STRICT CRITERION, SO

 

20  IF SOMEONE DOESN'T ABSOLUTELY MEET THESE CRITERION, YOU CAN

 

21  STILL ADMIT THEM TO HOSPICE.  YOU HAVE TO DOCUMENT CONTINUED

 

22  PHYSICAL OR MENTAL DETERIORATION TO CONTINUE TO QUALIFY FOR

 

23  THEM FOR HOSPICE IN THE FUTURE.  BUT THERE ARE SPECIFIC

 

24  CRITERION THAT ARE USED TO HELP OBJECTIVELY DETERMINE WHETHER

 

25  SOMEONE MEETS THIS SIX-MONTH CRITERION.  THIS HAS TO DO WITH

 

 1  FUNCTIONAL CAPACITY, IT HAS TO DO WITH SPEECH, IT HAS TO DO

 

 2  WITH AMBULATION, IT HAS TO DO WITH BOWEL AND BLADDER

 

 3  CONTINENCE.  HE -- MR. ALLDREDGE -- WHEN I REVIEWED THESE

 

 4  CRITERION RECENTLY, HE MET THE FUNCTIONAL CRITERION.  THEY

 

 5  HAD A SECOND CRITERION THAT ADDRESSED THINGS SUCH AS ACUTE

 

 6  ILL -- ACUTE MEDICAL PROBLEMS, AND THEY INCLUDED

 

 7  PYELONEPHRITIS, WHICH IS RENAL INFECTION, FEVER, PNEUMONIA,

 

 8  ASPIRATION.  THERE WERE SOME CRITERION, AND BASED ON THESE

 

 9  CRITERION, YOU'RE SUPPOSED TO SATISFY BOTH.  I -- IN

 

10  REVIEWING THOSE CRITERION, HE DIDN'T FIT THE SECOND

 

11  CRITERION, SO HE MET SOME BUT NOT ALL.  BUT AGAIN, THOSE ARE

 

12  NOT MEANT TO BE SPECIFICALLY EXCLUSIVE IN THAT IT WOULD STILL

 

13  BE UP TO THE INDIVIDUAL CAREGIVER TO DETERMINE IF THEY

 

14  THOUGHT HE WAS AN APPROPRIATE CANDIDATE.  IT'S A LONG ANSWER

 

15  TO A QUESTION.

 

16  Q.   BUT I APPRECIATE IT.  I THINK THAT HELPS US.  YOU

 

17  ORDERED BUSPAR AND MELLARIL AND, WELL, AND THEN RISPERDAL.

 

18  YOU INDICATE THEY HAVE SEDATING EFFECTS.  YOU ORDERED THEM

 

19  THREE TIMES A DAY AT CERTAIN DOSAGE.  IS THAT LESS SEDATING

 

20  TO DO IT THREE TIMES A DAY AS OPPOSED TO JUST ONE SHOT AT A

 

21  CERTAIN TIME?

 

22  A.   YOU'RE TRYING TO BE -- CONTROL A SPECIFIC SITUATION,

 

23  SUCH AS HIS BEHAVIOR, AND INTERMITTENTLY GIVING DOSAGES

 

24  DOESN'T ALLOW A CONTROL, IT ALLOWS BREAKTHROUGH TO OCCUR.  SO

 

25  YOU DOSE THOSE MEDICATIONS, AND THAT'S A TYPICAL DOSING

 

 1  PROGRAM, TO TRY TO MAINTAIN A SPECIFIC SITUATION, SUCH AS

 

 2  TRYING TO MAINTAIN A CONTROL OF HIS AGITATION AND BEHAVIOR,

 

 3  COMBATIVENESS.

 

 4  Q.   YOU HAD WRITTEN ON JANUARY 4TH, WE WILL DISCONTINUE

 

 5  MELLARIL AND TRY -- WELL, IT SAYS RESPECTFUL, BUT I THINK IT

 

 6  WAS PROBABLY RISPERDAL.

 

 7  A.   CORRECT.

 

 8  Q.   YOU DICTATED THIS, SOMEONE ELSE TYPED IT.  OBVIOUSLY, IF

 

 9  THIS MEDICINE CAUSES OVERSEDATION, WE WILL HAVE TO

 

10  DISCONTINUE IT.  IS THAT SOMETHING YOU LOOK FOR IN

 

11  ANTIPSYCHOTICS AND ANTI-ANXIETY MEDICATIONS?

 

12  A.   I MEAN IT'S CERTAINLY -- WHEN YOU READ ABOUT THESE

 

13  MEDICATIONS, THEY ALWAYS TALK ABOUT THE POTENTIAL FOR

 

14  SEDATION.  THAT'S PART OF THE EFFECT YOU'RE TRYING ACHIEVE IS

 

15  SEDATION IN SOMEONE WHO'S BEHAVING IN A COMBATIVE OR

 

16  AGGRESSIVE MANNER, SO THE EFFECTS OF SEDATION ARE A POSITIVE

 

17  EFFECT, BUT YOU HAVE TO BE CAREFUL BECAUSE YOU OBVIOUSLY

 

18  DON'T WANNA OVERSEDATE SOMEONE.  AND THEREFORE, YOU START AT

 

19  A RELATIVELY LOW DOSE AND GRADUALLY WORK THE DOSE UP TO TRY

 

20  TO AVOID OVERSEDATING SOMEONE.

 

21  Q.   WHAT HAPPENS IF YOU OVERSEDATE SOMEONE?

 

22  A.   WELL, THERE ARE -- THERE ARE POTENTIALS FOR RESPIRATORY

 

23  INFECTIONS.  PEOPLE CAN'T CONTROL THEIR SECRETIONS AS WELL

 

24  WHEN WHEN THEY'RE OVERSEDATED, SO THERE'S A POTENTIAL FOR

 

25  PNEUMONIA.  THEIR FUNTIONAL CAPACITY IS SUBSTANTIALLY

 

 1  LIMITED, SO THEY'RE USUALLY IN BED.  THAT'S NOT A GOOD

 

 2  SITUATION IF YOU CAN AVOID IT.

 

 3  Q.   BETTER TO BE UP AND WALKING AS MUCH AS POSSIBLE?

 

 4  A.   IT IS UNLESS YOU'RE COMBATIVE AND THROWING THINGS AROUND

 

 5  AND --

 

 6  Q.   RIGHT.  YOU SAY -- WELL, YOU SAID, HOPEFULLY HE WILL

 

 7  TOLERATE THIS LOW DOSE.  IS THAT IN TERMS OF THE SEDATION?

 

 8  A.   CORRECT.

 

 9  Q.   YOU WANT HIM DOWN, BUT NOT TOO FAR DOWN.

 

10  A.   RIGHT.

 

11  Q.   OKAY.  AND TITRATE ACCORDING FOR -- ACCORDINGLY FOR

 

12  AGITATION.  WHAT DOES TITRATION MEAN?

 

13  A.   INCREASED BASED UPON THE RESPONSE.  IF HE CONTINUES TO

 

14  BE QUITE AGITATED, YOU UP THE DOSE.  AND I HAD BEEN DOING

 

15  THAT WITH MELLARIL.

 

16  Q.   THEN IF THE -- IF A CERTAIN MEDICATION'S NOT WORKING,

 

17  YOU MIGHT TRY SOMETHING ELSE AS YOU DID HERE?

 

18  A.   RIGHT.

 

19       MS. BARLOW:  THAT'S ALL I HAVE, YOUR HONOR.

 

20       THE COURT:  RECROSS?

 

21                        RECROSS-EXAMINATION

 

22  BY MR. BUGDEN:

 

23  Q.   DOCTOR, WHEN YOU ENTER ORDERS FOR DIFFERENT DOSAGES OF

 

24  MEDICATIONS, AGAIN, YOU'RE TRYING GENERALLY SPEAKING TO

 

25  RESPOND TO THE PATIENT'S SYMPTOMS AND TO TREAT THOSE

 

 1  SYMPTOMS.

 

 2  A.   CORRECT.

 

 3  Q.   AND WITH ENNIS ALLDREDGE, WHEN WE -- WHEN YOU WERE

 

 4  CONFRONTED WITH SITUATIONS WHERE HE WAS EXTREMELY COMBATIVE

 

 5  OR HIGHLY AGITATED, THEN YOU HAD TO AT LEAST HAVE A RESPONSE

 

 6  TO THAT AGITATION WITH MEDICATION, OR AT LEAST THAT'S WHAT

 

 7  YOU WERE TRYING TO DO.

 

 8  A.   RIGHT.

 

 9  Q.   AND WITH THE BUSPAR, WHERE YOU -- WHERE YOU ORDERED 10

 

10  MILLIGRAMS THREE TIMES A DAY --

 

11  A.   UH-HUH.

 

12  Q.   -- THAT ACTUALLY IS ABOVE THE -- WHAT'S CONSIDERED THE

 

13  SUGGESTED GERIATRIC STARTING DOSAGE, ISN'T IT?

 

14  A.   THE STARTING DOSE, I THINK WRITTEN IS PROBABLY WHAT, 15

 

15  MILLIGRAMS, SO THAT IS A LARGER DOSE.

 

16  Q.   AND THE REASON YOU DID THAT WAS BECAUSE YOU'RE TRYING TO

 

17  DEAL WITH THIS URGENT SITUATION, THIS PRESENTING PROBLEM OF

 

18  THE PATIENT BEING AGITATED, RIGHT?

 

19  A.   CORRECT.  HE HAD NOT RESPONDED TO REASONABLE DOSAGES OF

 

20  AN ANTIPSYCHOTIC, AND MOST LIKELY MY THINKING WAS, IS LET'S

 

21  START WITH A LARGER DOSE RATHER THAN A SMALLER DOSE OF THE

 

22  BUSPAR, GIVEN THE FAILURE OF THE OTHER MEDICATION TO -- TO

 

23  BRING ABOUT ANY EFFECT.  SO I SUSPECT THAT WAS MY RATIONALE

 

24  FOR STARTING AT A LARGER DOSE RATHER THAN A SMALLER DOSE IN

 

25  THAT CIRCUMSTANCE.

 

 1  Q.   SO AGAIN, THAT ALSO WOULD SORT OF FIT IN THE GENERAL

 

 2  IDEA OF TITRATING TO EFFECT.  YOU'VE BEEN USING OTHER

 

 3  ANTIPSYCHOTICS.  THEY WERE NOT EFFECTIVE, SO YOU -- AND THIS

 

 4  WAS A BIG MAN AND WHO PRESENTED WITH ALL THIS AGITATION, SO

 

 5  YOU USED A LARGER DOSE, TRYING TO AGAIN TREAT THIS AGITATION.

 

 6  A.   RIGHT.  IT WAS A LARGER DOSE.  IT WAS STILL WITHIN

 

 7  ACCEPTABLE RANGES.  IT WASN'T IN -- IT WASN'T A DOSE OUT OF

 

 8  THE RECOMMENDATION IN ITEMS OF TOTAL DOSAGE.  BUT AS YOU --

 

 9  YOU'RE CORRECT, I USED -- I STARTED WITH A HIGHER DOSE RATHER

 

10  THAN A LOWER DOSE.

 

11       THE COURT:  MR. BUGDEN, THE JURY MIGHT LIKE TO KNOW WHAT

 

12  TITRATE TO EFFECT MEANS.

 

13  Q.  (BY MR. BUGDEN)  WOULD YOU TELL US WHAT THAT PHRASE

 

14  MEANS?

 

15  A.   TITRATE TO EFFECT WOULD MEAN THAT IF YOU'RE -- WHATEVER

 

16  PROCESS YOU'RE TRYING TO TREAT -- FOR EXAMPLE, IN THIS CASE,

 

17  HE'S THROWING WHEELCHAIRS AND COMBATIVE AND AGITATED, THEN

 

18  YOU INCREASE THE MEDICATION IN TERMS OF TRYING TO SUBDUE --

 

19  YOUR GOAL IS TO CALM THIS GENTLEMAN DOWN, SO TITRATE TO

 

20  EFFECT IS, IS YOU UP THE DOSAGE GRADUALLY UNTIL YOU'VE

 

21  ACHIEVED THE ELEMENT OF BEHAVIOR THAT YOU'RE SEEKING.  SO IN

 

22  HIS CASE, SO HE'S NOT COMBATIVE AND AGITATED.

 

23       MR. BUGDEN:  MAY I APPROACH THE WITNESS, YOUR HONOR?

 

24       THE COURT:  YOU MAY.

 

25  Q.  (BY MR. BUGDEN)  LOOKS LIKE THE GERATRIC DOSAGE HANDBOOK,

 

 1  THESE ARE SUGGESTIONS.  DO YOU AGREE WITH THAT, DOCTOR?

 

 2  A.   SURE.

 

 3  Q.   AND YOU AS THE CLINICIAN, YOU AS THE TREATING PHYSICIAN,

 

 4  YOU KNOW WHAT THE PATIENT'S CIRCUMSTANCE IS, YOU KNOW WHAT'S

 

 5  BEEN TRIED BEFORE, AND THEN YOU MAKE YOUR BEST MEDICAL

 

 6  JUDGMENT ABOUT WHERE TO START A START -- FOR EXAMPLE, WHERE

 

 7  TO BEGIN WITH A STARTING DOSAGE, IS THAT CORRECT?

 

 8  A.   CORRECT.

 

 9  Q.   WITH BUSPAR, DOES THIS COMPORT WITH YOUR MEMORY --

 

10       MS. BARLOW:  YOUR HONOR, I THINK I'M GOING TO OBJECT AT

 

11  THIS POINT.  THIS MAN IS NOT AN EXPERT.  HE'S A TREATING

 

12  PHYSICIAN.  I DON'T KNOW THAT WE NEED TO GET INTO GERIATRIC

 

13  DOSAGE HANDBOOK.

 

14       THE COURT:  I WILL SUSTAIN THE OBJECTION UNLESS IT CAN

 

15  BE ESTABLISHED THAT YOU'RE WILLING TO ACCEPT THIS TREATISE AS

 

16  ONE THAT IS GENERALLY USED WITHIN THE FIELD AND ONE THAT THIS

 

17  DOCTOR USES IN CONJUNCTION WITH HIS PRACTICE.  IF YOU

 

18  ESTABLISH THAT, THEN THE COURT'S GONNA ALLOW IT IN.

 

19       MS. BARLOW:  THAT'S FINE, IF THIS IS THE 1995 OR --

 

20       THE COURT:  IS IT?

 

21       MS. BARLOW:  -- THE ONE THAT WAS IN EFFECT IN 1995.

 

22  Q.  (BY MR. BUGDEN)  THIS IS 1998.  BUT LET ME ASK YOU,

 

23  DOCTOR, ARE YOU FAMILIAR WITH THE GERIATRIC DOSAGE HANDBOOK?

 

24  A.   I DON'T HAVE THAT BOOK.  THERE ARE MULTIPLE BOOKS

 

25  REGARDING DOSING.  I DON'T -- I DON'T HAVE THAT, SPECIFICALLY

 

 1  THAT BOOK.  I WOULDN'T NECESSARILY DISAGREE WITH WHAT THE

 

 2  INFORMATION IS IN THERE.

 

 3  Q.   SO IF THIS SUGGESTED THAT THE INITIAL STARTING DOSAGE,

 

 4  GERIATRIC STARTING DOSAGE WAS 5 MILLIGRAMS TWICE A DAY,

 

 5  THAT'S JUST A SUGGESTION, AND IN YOUR CASE, YOU RECOMMENDED

 

 6  THAT THE BUSPAR BE STARTED AT 10 MILLIGRAMS THREE TIMES A

 

 7  DAY.

 

 8  A.   CORRECT.

 

 9  Q.   AND AGAIN, YOU WERE JUST TREATING THE SYMPTOM.

 

10  A.   RIGHT.

 

11  Q.   AND WITH THE ATIVAN --

 

12  A.   I THINK THERE'S A MAXIMUM -- THINK THERE'S A MAXIMUM

 

13  RECOMMENDED DOSAGE WITH THESE MEDICATIONS, AND YOU DON'T TRY

 

14  TO EXCEED THAT.  BUT I THINK IT'S AN INDIVIDUAL'S JUDGMENT AS

 

15  TO WHAT STARTING DOSE TO USE.  I HAD STARTED ON LOW DOSAGES

 

16  OF OTHER MEDICATIONS AND I GOT NOWHERE, SO I FELT IN THIS

 

17  CASE, MY THINKING PROBABLY WAS THAT LET'S GO WITH THE LARGER

 

18  DOSE RATHER THAN THE SMALLER DOSE INITIALLY WITH -- WITH

 

19  BUSPAR.

 

20  Q.   AND WITH THE ATIVAN, YOU RECOMMENDED 3 MILLIGRAMS.  AND

 

21  AGAIN, WOULD YOU AGREE THAT THAT'S AGGRESSIVE --

 

22  A.   THAT'S A HIGH DOSE.

 

23  Q.   -- THAT'S A HIGH DOSE.

 

24  A.   THAT'S A HIGH DOSE.

 

25  Q.   BUT AGAIN, IT WAS A HIGH DOSAGE WHERE YOU HAD MADE A

 

 1  CLINICAL MEDICAL JUDGMENT THAT WE NEED TO USE A HIGH DOSAGE

 

 2  TO TRY TO CONTROL MR. ALLDREDGE'S AGITATION.

 

 3  A.   CORRECT.

 

 4  Q.   YOU CERTAINLY WEREN'T TRYING TO OVERDOSE THE PATIENT.

 

 5       MS. BARLOW:  OBJECTION, YOUR HONOR.  I DON'T THINK

 

 6  THAT --

 

 7       THE COURT:  SUSTAINED.

 

 8       MS. BARLOW:  -- THAT'S AN APPROPRIATE QUESTION.

 

 9  Q.  (BY MR. BUGDEN)  YOU WERE USING YOUR BEST JUDGMENT ABOUT

 

10  HOW TO TREAT THIS MAN'S AGITATION, ISN'T THAT RIGHT?

 

11  A.   CORRECT.

 

12       MR. BUGDEN:  THANK YOU.

 

13       THE COURT:  REDIRECT?

 

14                        REDIRECT EXAMINATION

 

15  BY MS. BARLOW:

 

16  Q.   JUST ONE QUESTION.  YOU ORDERED THE INCREASE IN

 

17  RISPERDAL ON THE 8TH OF JANUARY, IS THAT CORRECT.   1

 

18  A.   RIGHT.

 

19  Q.   WERE YOU ABLE TO LEARN WHAT THE EFFECT WAS BEFORE

 

20  MR. ALLDREDGE LEFT THE NURSING HOME AND LEFT YOUR CARE?   2

 

21  A.   I DON'T KNOW WHAT -- I HAVE NO INFORMATION ABOUT WHAT HE

 

22  WAS LIKE THE DAY HE LEFT TO GO TO DAVIS.

 

23  Q.   SO WHEN YOU'RE TITRATING TO EFFECT, YOU WERE NEVER ABLE

 

24  TO SEE THE EFFECT OF THE AMOUNT OF DRUGS THAT -- THE AMOUNT

 

25  OF RISPERDAL AND BUSPAR THAT YOU HAD ORDERED FOR HIM ON THE

 

 1  8TH OF JANUARY, IS THAT CORRECT?   3

 

 2  A.   CORRECT.

 

 3       MS. BARLOW:  OKAY.  THANK YOU.  NO FURTHER QUESTIONS,

 

 4  YOUR HONOR.

 

 5       MR. BUGDEN:  NOTHING FURTHER.

 

 6       THE COURT:  RECROSS?  YOU MAY STEP DOWN, DOCTOR.

 

 7       THE WITNESS:  THANK YOU.

 

 8       THE COURT:  MAY THIS WITNESS BE EXCUSED, MS. BARLOW?

 

 9       MS. BARLOW:  YES, YOUR HONOR.

 

10       THE COURT:  MR. BUGDEN?

 

11       MR. BUGDEN:  YES, SIR.

 

12       THE COURT:  DR. CUNNINGHAM, YOU MAY BE EXCUSED, AND

 

13  THANK YOU FOR TESTIFYING.

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