Sharon Smith

12              MR. WILSON:  WE'D CALL SHARON SMITH AT THIS TIME,

 

      13     YOUR HONOR.

 

      14              THE COURT:  IS SHE GOING TO TELL ME ANYTHING

 

      15     DIFFERENT, MR. WILSON?

 

      16              MR. WILSON:  YES, SHE WILL, YOUR HONOR.

 

      17              THE COURT:  KAREN SMITH?

 

      18              MR. WILSON:  SHARON.

 

      19              THE COURT:  SHARON.  MRS. SMITH, WOULD YOU STEP UP

 

      20     HERE, PLEASE.  COME RIGHT UP TO THE FRONT.  IF YOU'D YOUR

 

      21     RIGHT HAND, PLEASE, AND FACE THE CLERK SHE'LL PLACE YOU UNDER

 

      22     OATH.

 

      23                         SHARON OSMOND SMITH,

 

      24              HAVING BEEN DULY SWORN, WAS EXAMINED AND

 

      25              TESTIFIED AS FOLLOWS:

 

       1              THE COURT:  IF YOU'LL HAVE A SEAT UP HERE, PLEASE.

 

       2     GIVE US YOUR FULL NAME AND SPELL YOUR LAST NAME FOR US.

 

       3              THE WITNESS:  THANK YOU.  MY NAME IS SHARON OSMOND

 

       4     SMITH, S-M-I-T-H.

 

       5                          DIRECT EXAMINATION

 

       6    BY MR. WILSON:

 

       7     Q.  SHARON, WHERE DO YOU CURRENTLY RESIDE?

 

       8     A.  I RESIDE IN CENTERVILLE.

 

       9     Q.  AND YOU'RE THE WIFE OF KENT SMITH?

 

      10     A.  YES.

 

      11     Q.  AND THE DAUGHTER-IN-LAW OF LYDIA SMITH?

 

      12     A.  YES.

 

      13     Q.  SHARON I WANT TO TAKE YOU TO THE TIME THAT YOUR

 

      14     MOTHER-IN-LAW WAS ADMITTED TO THE GEROPSYCH UNIT AT THE DAVIS

 

      15     HOSPITAL?

 

      16     A.  YES.

 

      17     Q.  DO YOU RECALL THAT TIME?

 

      18     A.  YES.

 

      19     Q.  DID YOU VISIT WITH HER AT THE HOSPITAL?

 

      20     A.  I DID.

 

      21     Q.  AND WERE YOU PRESENT ON THE 7TH OF JANUARY OF 1996 WHEN A

 

      22     CONVERSATION TOOK PLACE BETWEEN THE DEFENDANT AND YOUR OTHER

 

      23     FAMILY MEMBERS?

 

      24     A.  I WAS THERE.

 

      25     Q.  CAN YOU TELL US, IN THAT CONVERSATION, WAS THERE ANY

 

       1     REFERENCES BY THE DEFENDANT IN RESPECT TO ANY MEDICATIONS

 

       2     THAT WERE BEING ADMINISTERED TO YOUR MOTHER-IN-LAW?

 

       3     A.  HE DID NOT TELL WHAT MEDICATIONS WERE BEING GIVEN TO HER

 

       4     THAT NIGHT, AS FAR AS I REMEMBER.

 

       5     Q.  DO YOU RECALL -- AND COULD YOU DESCRIBE JUST BRIEFLY THE

 

       6     CONDITION OF YOUR MOTHER-IN-LAW THAT NIGHT?

 

       7     A.  SHE WAS LYING IN HER BED, SHE WAS -- APPEARED TO BE LIKE

 

       8     IN A COMATOSE STATE.  SHE DID NOT REALLY MOVE -- SHE DID NOT

 

       9     MOVE OR RESPOND TO ANYBODY TALKING TO HER.  THE ONLY THING

 

      10     SHE DID WAS LIFT HER ARM TWICE, LIKE THAT (INDICATING).

 

      11     Q.  DID THE CONVERSATION WITH THE DOCTOR TAKE PLACE IN THE

 

      12     ROOM?

 

      13     A.  IT DID.

 

      14     Q.  DO YOU RECALL HIM MAKING A STATEMENT CONCERNING YOUR

 

      15     MOTHER-IN-LAW?

 

      16              THE COURT:  WHO'S HIM, MR. WILSON?

 

      17              MR. WILSON:  EXCUSE ME.

 

      18     Q.  (BY MR. WILSON)  DO YOU RECALL THE DEFENDANT MAKING A

 

      19     STATEMENT CONCERNING YOUR MOTHER-IN-LAW?

 

      20     A.  YES.

 

      21     Q.  AND WHEN IN THE CONTEXT OF THAT CONVERSATION WAS THIS

 

      22     STATEMENT MADE?

 

      23     A.  HE HADN'T BEEN IN THE ROOM TOO LONG.  HE JUST REFERRED

 

      24     TO -- DO YOU WANT ME TO -- HE JUST REFERRED TO HER AS A

 

      25     CRABBY OLD LADY, UNHAPPY LADY, DIDN'T KNOW WHY SHE'D WANT TO

 

       1     LIVE, SHOULDN'T LIVE AND WAS ALONG THAT LINE.

 

       2     Q.  I SEE.  DO YOU KNOW WHETHER -- DID YOU TALK TO HIM ABOUT

 

       3     THAT STATEMENT OR DID YOU SAY ANYTHING TO HIM ABOUT THAT

 

       4     STATEMENT?

 

       5     A.  I DID NOT SAY ANYTHING TO HIM.  I TALKED AMONG OTHER

 

       6     FAMILY MEMBERS ABOUT IT.

 

       7     Q.  ARE YOU AWARE WHETHER OTHERS IN THE ROOM HEARD THAT

 

       8     STATEMENT?

 

       9     A.  I DON'T KNOW WHETHER THEY HEARD EXACTLY THE WAY I HEARD

 

      10     IT.  IT'S JUST THAT WE TALKED ABOUT HOW WE KNEW HE DIDN'T

 

      11     HAVE A LIKENESS FOR HER.

 

      12     Q.  THE FOLLOWING DAY DID YOU HAPPEN TO BE IN YOUR

 

      13     MOTHER-IN-LAW'S ROOM?

 

      14     A.  I WAS.

 

      15     Q.  AND APPROXIMATELY WHAT TIME OF DAY WERE YOU THERE?

 

      16     A.  I WAS THERE BEFORE 8 O'CLOCK.

 

      17     Q.  CAN YOU AGAIN DESCRIBE FOR US IF YOU WOULD WHAT YOU

 

      18     OBSERVED ABOUT YOUR MOTHER-IN-LAW ON THAT OCCASION, WHERE WAS

 

      19     SHE IN THE ROOM?

 

      20     A.  SHE WAS IN HER BED.  SHE WAS MAKING NO MOVEMENTS AT ALL.

 

      21     THE NURSE TOLD US THAT WE SHOULD TALK TO HER BECAUSE SHE WAS

 

      22     DYING.  AND MY DAUGHTER AND I TALKED TO HER, TOLD HER --

 

      23     TALKED TO HER ABOUT MEMORIES AND SO FORTH AND SHE NEVER MADE

 

      24     ACKNOWLEDGMENT THAT SHE HEARD WHAT WE WERE SAYING.  SHE MADE

 

      25     NO MOVEMENTS AT ALL.  SHE JUST LAID THERE.

 

       1     Q.  DID YOU EVER SEE THE DEFENDANT DURING THAT TIME?

 

       2     A.  I DID NOT.

 

       3     Q.  DID YOU EVER SEE ANY MEDICATIONS BEING ADMINISTERED TO

 

       4     YOUR MOTHER-IN-LAW AT THAT TIME?

 

       5     A.  A NURSE GAVE HER A SHOT WHILE I WAS THERE, WHILE MY

 

       6     DAUGHTER AND I WERE THERE.

 

       7     Q.  DO YOU KNOW WHAT TYPES OF MEDICATIONS WERE ADMINISTERED

 

       8     TO HER?

 

       9     A.  THE NURSE DIDN'T SAY WHAT IT WAS.  SHE JUST SAID IT

 

      10     WAS -- SHE WAS GIVING HER A SHOT TO KEEP HER COMFORTABLE.

 

      11     Q.  ALL RIGHT.  DID YOU NOTE ANYTHING ABOUT YOUR

 

      12     MOTHER-IN-LAW DURING THE TIME FRAME YOU WERE THERE INDICATING

 

      13     ANY UNCOM -- ANY DISCOMFORT?

 

      14     A.  SHE WAS NOT THRASHING, SHE WAS NOT MOVING.  SHE WAS --

 

      15     SHE WAS JUST LYING THERE.

 

      16     Q.  OKAY.

 

      17     A.  HER BREATHING WAS A LITTLE HEAVIER BUT SHE WAS NOT

 

      18     THRASHING ABOUT.

 

      19     Q.  WHEN YOU SAY HER BREATHING WAS A LITTLE HEAVIER, CAN YOU

 

      20     DESCRIBE THE BREATHING FOR US?

 

      21     A.  IT WAS MORE LIKE A RATTLE, LIKE SHE HAD -- IT WAS MORE

 

      22     LIKE A RATTLE.

 

      23     Q.  HOW LONG DID YOU STAY?

 

      24     A.  I WAS THERE UNTIL 12 O'CLOCK AND MY SISTER-IN-LAW CAME

 

      25     IN.

 

       1     Q.  AND YOU LEFT AT THAT TIME?

 

       2     A.  I LEFT BECAUSE I HAD A DOCTORS APPOINTMENT SO -- I

 

       3     PLANNED ON COMING BACK.

 

       4              MR. WILSON:  I HAVE NO FURTHER QUESTIONS.  THANK

 

       5     YOU.

 

       6              THE COURT:  CROSS-EXAMINE, MS. ISAACSON?

 

       7              MS. ISAACSON:  YES THANK YOU.

 

       8                          CROSS-EXAMINATION

 

       9    BY MS. ISAACSON:

 

      10     Q.  MRS. SMITH, MY NAME IS TARA ISAACSON.  I'M ONE OF THE

 

      11     ATTORNEYS THAT REPRESENTS DR. WEITZEL.

 

      12         I UNDERSTAND THAT YOU VISITED YOUR MOTHER-IN-LAW ON THE

 

      13     UNIT A NUMBER OF TIMES BETWEEN DECEMBER 20TH AND JANUARY 9TH.

 

      14     A.  YES.

 

      15     Q.  BETWEEN FIVE AND SEVEN TIMES?

 

      16     A.  RIGHT.

 

      17     Q.  AND UP UNTIL JANUARY 6TH SHE WAS EXTREMELY AGITATIVE AND

 

      18     COMBATIVE?

 

      19     A.  SHE -- SHE WANTED US TO TAKE HER OUT.  SHE WAS UNHAPPY

 

      20     BEING THERE.  SHE DID NOT LIKE WHAT THEY WERE DOING TO HER.

 

      21     Q.  HAVE YOU EVER -- WOULD YOU DESCRIBE HER AS BEING

 

      22     AGITATIVE AND COMBATIVE?

 

      23     A.  YES.  THAT WAS ONE OF THE REASONS WHY WE HAD HER THERE.

 

      24     Q.  OKAY.  AND SHE DIDN'T LIKE BEING IN A NURSING HOME, SHE

 

      25     DIDN'T LIKE BEING IN ANOTHER FACILITY?

 

       1     A.  NO, SHE DIDN'T.

 

       2     Q.  SHE WANTED TO GO HOME?

 

       3     A.  YES.

 

       4     Q.  AND THAT WASN'T AN OPTION FOR YOUR MOTHER-IN-LAW?

 

       5     A.  THAT WAS NOT AN OPTION AT THAT TIME.

 

       6     Q.  NOW, ON JANUARY 7TH, DR. WEITZEL HAD COMMUNICATED TO THE

 

       7     FAMILY THAT HE WOULD LIKE TO MEET WITH THE FAMILY?

 

       8     A.  I CALLED THE HOSPITAL AND THEN -- TO FIND -- TO TALK TO

 

       9     HIM ABOUT HER CONDITION THAT MORNING AND THE NURSE SAID TO ME

 

      10     THAT DR. WEITZEL WOULD LIKE TO MEET WITH THE FAMILY THAT

 

      11     NIGHT.

 

      12     Q.  SO HE WANTS TO HAVE THIS MEETING, AND IF I UNDERSTAND

 

      13     RIGHT, IT WAS IN YOUR MOTHER-IN-LAW'S ROOM AT THE HOSPITAL?

 

      14     A.  IT WAS.

 

      15     Q.  AND YOUR HUSBAND WAS THERE WHO JUST TESTIFIED?

 

      16     A.  YES.

 

      17     Q.  AND YOUR SISTER-IN-LAW, BONNIE, WAS THERE?

 

      18     A.  RIGHT.

 

      19     Q.  YOUR BROTHER-IN-LAW, HAROLD, WAS THERE?

 

      20     A.  YES.

 

      21     Q.  HAROLD'S WIFE WAS THERE?

 

      22     A.  YES.

 

      23     Q.  AND YOUR MOTHER-IN-LAW WAS IN THE ROOM?

 

      24     A.  THAT'S RIGHT.

 

      25     Q.  AND DR. WEITZEL COMES INTO THE ROOM AND HE SAYS THAT YOUR

 

       1     MOTHER-IN-LAW IS DYING?  IT'S ONE OF THE THINGS THAT HE

 

       2     COMMUNICATED?

 

       3     A.  YES.

 

       4     Q.  HE INDICATED THAT HE WOULD MAKE HER COMFORTABLE?

 

       5     A.  HE -- YES.  HE WOULD -- NEAR THE END HE SAID WE WOULD DO

 

       6     THINGS TO MAKE HER COMFORTABLE.

 

       7     Q.  AND YOUR HUSBAND HAS TESTIFIED TODAY THAT HE INDICATED

 

       8     THAT AN OPTION WAS TO SEND HER TO THE ICU OR INTO FURTHER

 

       9     TESTING, DO YOU RECALL HIM TELLING YOU THAT?

 

      10     A.  THE THING THAT I RECALL WAS THAT HE ASKED ABOUT LIFE

 

      11     SAVING MEASURES.

 

      12     Q.  OKAY.  AND THERE'S AT LEAST A 10-MINUTE CONVERSATION

 

      13     BETWEEN ALL OF THESE FAMILY MEMBERS AND DR. WEITZEL?

 

      14     A.  YES.

 

      15     Q.  AND DURING THE COURSE OF THAT CONVERSATION, HE SAID LOUD

 

      16     ENOUGH FOR YOU TO HEAR AND FOR THE PEOPLE IN THE ROOM TO HEAR

 

      17     THAT SHE WAS A VERY UNHAPPY OLD LADY AND SHE DIDN'T DESERVE

 

      18     TO LIVE?

 

      19     A.  HE CAME -- HE SAID THAT AROUND AT THE FIRST PART OF IT,

 

      20     YES.

 

      21     Q.  SO RIGHT WHEN HE WALKED IN WAS FIRST SPEAKING WITH THE

 

      22     FAMILY HE MADE THIS --

 

      23     A.  I'M NOT SAYING IT WAS RIGHT AT THE FIRST PART WHEN HE

 

      24     WALKED IN, BUT IT WAS AT THE FIRST PART OF THE CONVERSATION.

 

      25     Q.  WITHIN A FEW MINUTES, WITH FIVE FAMILY MEMBERS THERE,

 

       1     WITH YOUR MOTHER-IN-LAW THERE HE MAKES A STATEMENT THAT YOUR

 

       2     MOTHER-IN-LAW'S AN UNHAPPY OLD LADY AND I DOESN'T DESERVE TO

 

       3     LIVE?

 

       4     A.  YES.

 

       5     Q.  NOW, ON THE NEXT DAY ON MONDAY, YOU WERE IN YOUR

 

       6     MOTHER-IN-LAW'S ROOM AND A NURSE CAME INTO GIVE HER A SHOT?

 

       7     A.  YES.

 

       8     Q.  AND SHE TOLD YOU THAT SHE WAS DYING, THAT YOUR

 

       9     MOTHER-IN-LAW WAS DYING?

 

      10     A.  YES.

 

      11     Q.  THAT YOU SHOULD BE TALKING TO HER?

 

      12     A.  THAT'S RIGHT.

 

      13     Q.  AND THAT SHE WAS MAKING HER COMFORTABLE?

 

      14     A.  YES.

 

      15     Q.  AND YOU DID NOT WANT YOUR MOTHER-IN-LAW TO SUFFER, DID

 

      16     YOU?

 

      17     A.  NOBODY WANTS THEM TO SUFFER BUT SHE WASN'T SUFFERING AT

 

      18     THAT MOMENT.

 

      19              MS. ISAACSON:  NOTHING FURTHER.

 

      20              THE COURT:  REDIRECT.

 

      21              MR. WILSON:  NO, YOUR HONOR.  I HAVE NO QUESTIONS.

 

      22              THE COURT:  YOU MAY STEP DOWN, MRS. SMITH.  AND

 

      23     THANK YOU FOR TESTIFYING.  MAY THIS WITNESS BE EXCUSED,

 

      24     MR. WILSON?

 

      25              MR. WILSON:  SHE MAY, YOUR HONOR.

 

       1              MS. ISAACSON:  YES, YOUR HONOR.

 

       2              THE COURT:  YOU MAY BE EXCUSED.  AND THANK YOU

 

       3     MRS. SMITH.

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