Sheila Moore
22 MS. BARLOW: WE'D NEXT CALL SHEILA MOORE, AND I
23 BELIEVE SHE'S JUST OUTSIDE THE DOOR.
24 THE COURT: SHEILA MOORE.
25 MS. MOORE, WOULD YOU STEP UP HERE, PLEASE? MS. MOORE,
1 COME RIGHT UP TO THE FRONT. IF YOU'LL RAISE YOUR RIGHT HAND
2 AND FACE THE CLERK, SHE'LL PLACE YOU UNDER OATH.
3 SWORN, WAS EXAMINED AND TESTIFIED AS FOLLOWS:
4 SHEILA MOORE,
5 BEING FIRST DULY SWORN, WAS EXAMINED AND
6 TESTIFIED AS FOLLOWS:
7 THE COURT: IF YOU'LL HAVE A SEAT UP HERE, PLEASE.
8 GIVE US YOUR NAME, PLEASE, AND SPELL YOUR LAST NAME.
9 THE WITNESS: SHEILA MOORE, M-O-O-R-E.
10 THE COURT: THANK YOU.
11 YOU MAY PROCEED, MS. BARLOW.
12 MS. BARLOW: THANK YOU, YOUR HONOR.
13 DIRECT EXAMINATION
14 BY MS. BARLOW:
15 Q. GOOD AFTERNOON.
16 A. HI.
17 Q. CAN YOU TELL US WHAT YOUR OCCUPATION IS?
18 A. I'M A REGISTERED NURSE.
19 Q. AND HOW LONG HAVE YOU BEEN A NURSE?
20 A. SINCE 1979.
21 Q. WHAT EDUCATION AND TRAINING DID YOU RECEIVE TO BECOME A
22 REGISTERED NURSE?
23 A. I GRADUATED FROM BRIGHAM YOUNG UNIVERSITY IN THE
24 ASSOCIATE PROGRAM.
25 Q. THAT'S A TWO-YEAR PROGRAM?
1 A. YES, MA'AM.
2 Q. OKAY. IS THERE A -- WHEN YOU SAY A REGISTERED NURSE, WE
3 ALWAYS HEAR THE TERM R.N. IS THERE ANY CONNECTION BETWEEN
4 THE TWO OF THOSE?
5 A. IT'S THE SAME.
6 Q. OKAY. ARE THERE OTHER LEVELS OF NURSES WITH OTHER LEVELS
7 OF TRAINING?
8 A. YES.
9 Q. CAN YOU TELL US JUST BRIEFLY WHAT SOME OF THE OTHER ONES
10 ARE?
11 A. THERE'S A BACCALAUREATE NURSE, THERE'S A NURSE
12 PRACTITIONER --
13 Q. UH-HUH.
14 A. -- AND THERE'S A LICENSED PRACTICAL NURSE, AND THERE'S A
15 NURSES' AIDE.
16 Q. OKAY. A CERTIFIED NURSING ASSISTANT, WHERE DOES THAT FIT
17 IN THERE?
18 A. BELOW THE -- WELL, BELOW THE L.P.N.
19 Q. OKAY. AS AN R.N., WHAT ARE YOU ALLOWED TO DO AS FAR AS
20 THE PATIENTS' CARE IS CONCERNED?
21 A. MANAGE THEIR CARE AS FAR AS ADMINISTERING MEDICATIONS,
22 TAKING THEIR VITAL SIGNS, GIVING THEM, YOU KNOW, DIRECT CARE.
23 Q. OKAY. DID YOU HAVE OCCASION -- WELL, BACK UP JUST A
24 LITTLE BIT.
25 FROM THE TIME THAT YOU RECEIVED YOUR DEGREE AND BECAME
1 AN R.N., WHAT HAS BEEN YOUR WORK EXPERIENCE?
2 A. I STARTED ON A SURGICAL UNIT. WORKED THERE ABOUT SEVEN
3 YEARS, THEN I WENT TO THE OPERATING ROOM. WORKED THERE ABOUT
4 THREE OR FOUR YEARS. WENT INTO ADOLESCENT PSYCH, STAYED
5 THERE ABOUT SEVEN YEARS. AND THEN I WENT INTO ADULT PSYCH --
6 NO, GERIATRIC PSYCH FROM THERE.
7 Q. OKAY. AND ARE YOU STILL DOING GERIATRIC PSYCH?
8 A. NO, I'M ON THE SKILLED NURSING FACILITY WHICH DOES DEAL
9 WITH GERIATRIC PATIENTS, BUT IT'S A REHAB.
10 Q. AND WHERE DO YOU DO THAT?
11 A. AT DAVIS HOSPITAL.
12 Q. OKAY. SO YOU'RE STILL IN LAYTON?
13 A. YES.
14 Q. OKAY. I'M SORRY. MY TRAIN OF THOUGHT JUST LEFT THE
15 STATION.
16 YOU SAY THE SURG UNIT -- SURGICAL UNIT AND O.R.
17 A. RIGHT.
18 Q. OPERATING. WHAT'S THE DIFFERENCE BETWEEN THOSE TWO?
19 A. THE SURGICAL UNIT WAS WHERE THEY BROUGHT THE PATIENTS
20 AFTER THEY HAD THEIR SURGERY; THE OPERATING ROOM WAS WHERE
21 THEY HAD THEIR SURGERY.
22 Q. OKAY. ON THAT UNIT DID YOU EXPERIENCE OR WERE YOU
23 FAMILIAR WITH PEOPLE WITH PAIN?
24 A. YES.
25 Q. ARE YOU FAMILIAR THEN WITH PAIN MEDICATIONS THAT ARE
1 ADMINISTERED POST-SURGICAL?
2 A. YES.
3 Q. OKAY. DID YOU WORK AT THE DAVIS NORTH GERIATRIC UNIT?
4 A. YES, I DID.
5 Q. THE GEROPSYCH UNIT, I GUESS IT'S CALLED?
6 A. YES.
7 Q. WHEN DID YOU FIRST WORK THERE?
8 A. I STARTED THERE WHEN THE UNIT OPENED AND THAT WAS
9 JULY 1994.
10 Q. OKAY. HOW DID YOU GET INVOLVED IN -- IN THIS START-UP
11 UNIT?
12 A. THEY HAD AN APPLICATION FOR THE ADMINISTRATIVE
13 SUPERVISOR, THE HEAD NURSE OF THE UNIT. I APPLIED, I GOT IT.
14 Q. SO YOU WERE OVER WHAT? THE OTHER NURSES --
15 A. RIGHT.
16 Q. ALL NURSES OR JUST A CERTAIN SHIFT OR WHAT WAS IT?
17 A. NO. ALL -- ALL THE NURSES ON THAT UNIT I WAS OVER.
18 Q. ABOUT HOW MANY NURSES WERE THERE ON A UNIT IN ANY
19 CERTAIN TIME -- ON THE UNIT AT ANY CERTAIN TIME?
20 A. THERE WOULD ALWAYS BE AT LEAST ONE R.N. PER THE 24 HOURS,
21 AND A SECOND EITHER C.N.A. OR A SECOND R.N.
22 Q. DO YOU RECALL HOW MANY SHIFTS THERE WERE ON THE UNIT?
23 A. THERE WERE THREE SHIFTS.
24 Q. THREE EIGHT-HOUR SHIFTS?
25 A. RIGHT.
1 Q. WHAT WERE YOUR DUTIES THEN AS THE HEAD NURSE FOR THE
2 UNIT?
3 A. I WOULD DO -- MANAGE THE NURSING STAFF AS FAR AS PAYROLL
4 GOES; DISCIPLINARY -- YOU KNOW, IF THE NURSES NEEDED
5 DISCIPLINARY; ATTEND MEETINGS THROUGHOUT THE HOSPITAL. ALSO
6 I WORKED THE UNIT TWO SHIFTS A WEEK WITH DIRECT PATIENT CARE.
7 Q. WHAT TYPE OF PATIENTS WERE THERE ON THE GEROPSYCH UNIT?
8 A. MEDICARE PATIENTS USUALLY FROM 65 AND OLDER. EVERY ONCE
9 IN A WHILE WE'D TAKE THEM MAYBE AS YOUNG AS 55 AND OLDER.
10 PSYCHIATRIC PROBLEMS WOULD HAVE TO BE THEIR PRIMARY
11 DIAGNOSIS, AND IT WOULD HAVE TO BE AN ACUTE PROBLEM THAT
12 COULD BE FIXED OR COULD BE HANDLED WITHIN A SHORT PERIOD OF
13 TIME.
14 Q. ACUTE IS ONE OF THOSE MEDICAL TERMS. CAN YOU EXPLAIN TO
15 THE JURY WHAT THAT MEANS?
16 A. SHORT TERM. IT'S LIKE SOMETHING THAT HAPPENS THAT NEEDS
17 ATTENTION IMMEDIATELY, RIGHT THEN, AND IT CAN BE RESOLVED
18 WITHIN A FEW DAYS.
19 Q. WHAT ABOUT CHRONIC? IS THAT A PHRASE THAT -- OR A WORD
20 THAT MEANS ANYTHING?
21 A. CHRONIC -- CHRONIC USUALLY MEANS THAT IT'S AN ILLNESS
22 THAT HAS BEEN WITH THE PATIENT FOR QUITE A WHILE.
23 Q. WHAT KIND OF TREATMENTS WERE YOU SET UP TO DO FOR THESE
24 GERIATRIC PATIENTS?
25 A. MED MANAGEMENT. WE HAD DIFFERENT TYPES OF GROUPS.
1 SOCIAL SERVICES WOULD PROVIDE GROUPS FOR THEM. WE HAD
2 RECREATIONAL THERAPY THAT CAME IN AND DID GROUPS, AND WE HAD
3 OCCUPATIONAL THERAPY THAT WOULD COME IN AND DO GROUPS WITH
4 THEM. MED MANAGEMENT.
5 Q. OKAY. WHEN YOU SAY MED, DO YOU MEAN MEDICATION
6 MANAGEMENT?
7 A. RIGHT.
8 Q. OKAY. IF -- IF A PERSON STARTED ACTING OUT ON THE UNIT,
9 WHAT WOULD BE YOUR FIRST RESPONSE AS A NURSE?
10 A. I WOULD TAKE THAT PATIENT AWAY FROM THE STIMULI THAT HE
11 WAS IN -- THE AREA THAT HE OR SHE WAS IN TO MAYBE DE-ESCALATE
12 THEM --
13 Q. UH-HUH.
14 A. -- BRING THEM DOWN.
15 Q. YOU'D DO ONE-ON-ONE SORT OF THING?
16 A. DO ONE-ON-ONES, GET THEM AWAY FROM -- IF SOMETHING IS
17 BOTHERING THEM THAT'S IN THE GROUP -- IF THEY'RE IN A GROUP
18 AND SOMETHING IS BOTHERING THEM IN THAT GROUP, I'LL TAKE THEM
19 OUT OF GROUP.
20 Q. UH-HUH.
21 A. TAKE THEM AWAY FROM WHAT'S BOTHERING THEM.
22 Q. OKAY. ARE YOU FAMILIAR WITH THE TERM REDIRECTION IN --
23 A. UH-HUH.
24 Q. -- TERMS OF GERIATRIC PSYCHIATRIC PATIENTS?
25 A. UH-HUH.
1 MS. ISAACSON: YOUR HONOR, I'M GOING OBJECT TO THIS
2 LINE OF QUESTIONING. I DON'T SEE HOW IT'S RELEVANT. SHE
3 APPARENTLY WAS NOT ON THE UNIT DURING THE TIMEFRAME THAT
4 WE'RE TALKING ABOUT IN THIS CASE, DID NOT TREAT ANY OF THESE
5 PATIENTS. I DON'T KNOW WHAT -- SHE'S NOT AN EXPERT.
6 THE COURT: WHERE ARE WE GOING, MS. BARLOW?
7 MS. BARLOW: I WAS JUST LAYING A FOUNDATION FOR --
8 FOR THE WAY NURSING CARE HAPPENED ON THIS UNIT. IT DIDN'T
9 CHANGE ANY AFTER SHE LEFT.
10 THE COURT: WELL, SHE HASN'T SAID THAT SO WE DON'T
11 KNOW THAT.
12 MS. BARLOW: OKAY.
13 THE COURT: SUSTAIN THE OBJECTION.
14 MS. BARLOW: OKAY.
15 Q. (BY MS. BARLOW) DID YOU COME TO LEAVE THAT UNIT?
16 A. YES, I DID.
17 Q. WHEN DID THAT HAPPEN?
18 A. I LEFT THE END OF NOVEMBER, 1ST OF DECEMBER OF '95.
19 Q. YOU WEREN'T THERE WHEN ANY OF THESE FIVE PATIENTS WERE --
20 A. NO.
21 Q. -- WERE THERE? YEAH, WELL, I GUESS WERE THERE.
22 A. NO.
23 Q. ARE YOU FAMILIAR WITH THE TERM P.R.N.?
24 A. YES.
25 Q. WHAT IS THAT?
1 A. IT'S A TERM USED WHEN YOU CAN DO SOMETHING AS NEEDED.
2 Q. UH-HUH.
3 A. LIKE GIVE A MEDICATION AS NEEDED.
4 Q. CAN YOU GIVE IT IF IT'S NOT BEEN ORDERED?
5 A. NO.
6 Q. OKAY. WHERE DOES THE ORDER HAVE TO COME FROM?
7 A. THE PHYSICIAN.
8 Q. HOW WOULD A P.R.N. ORDER USUALLY COME ABOUT?
9 MS. ISAACSON: YOUR HONOR, I'LL RENEW MY OBJECTION
10 ABOUT THIS LINE OF QUESTIONING. I JUST DON'T SEE THE
11 RELEVANCE --
12 THE COURT: SUSTAINED. NOW IF THIS IS -- IF YOU CAN
13 BRING THIS ON IN OTHER WITNESSES THAT ARE MORE RELEVANT TO
14 WHAT YOU'RE TALKING ABOUT, MS. BARLOW, I WANT TO USE THOSE.
15 MS. BARLOW: I'LL DO THAT, YOUR HONOR.
16 THE COURT: I DON'T WANT TO WASTE OUR TIME IN
17 SOMETHING THAT WE CAN BRING IN WITH ANOTHER WITNESS THAT IS
18 MORE CRITICAL TO THE THINGS YOU WANT TO DO.
19 MS. BARLOW: I WILL DO THAT, YOUR HONOR.
20 Q. (BY MS. BARLOW) DURING THE TIME THAT YOU WERE THERE, WAS
21 MORPHINE EVER ORDERED ON THE UNIT?
22 MS. ISAACSON: OBJECTION, YOUR HONOR. RELEVANCE
23 AGAIN.
24 THE COURT: SUSTAINED.
25 MS. BARLOW: OKAY. MAY I HAVE JUST A MOMENT,
1 YOUR HONOR?
2 THE COURT: SURE.
3 MS. BARLOW: YOUR HONOR, THOSE ARE ALL THE QUESTIONS
4 I HAVE FOR THIS WITNESS.
5 THE COURT: CROSS-EXAMINE, MS. ISAACSON?
6 MS. ISAACSON: I DON'T HAVE ANY QUESTIONS FOR THIS
7 WITNESS.
8 THE COURT: YOU MAY STEP DOWN.
9 THE WITNESS: THANK YOU.
10 THE COURT: MAY THIS WITNESS BE EXCUSED, MS. BARLOW?
11 MS. BARLOW: YES, YOUR HONOR.
12 THE COURT: MS. ISAACSON?
13 MS. ISAACSON: YES.
14 THE COURT: YOU MAY BE EXCUSED, MS. MOORE, AND THANK
15 YOU FOR COMING.