posted by admin on Mar 10

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1 Q. Okay. You mentioned earlier that since, I

2 think, ‘88 physicians have the option to use an

3 electronic fetal monitor or to auscultate every 15

4 minutes even in high-risk patients; is that correct?

5 A. Yes, that’s correct.

6 Q. Assume hypothetically a physician chooses

7 Option A, to use electronic fetal monitoring. Does a

8 nurse — is a nurse allowed under the applicable

9 standard of care to look at that monitor once every 15

10 minutes as if she was auscultating?

11 A. If a patient is in labor, that is — that

12 is true — as if she was auscultating. That’s how the

13 standard is written.

14 Q. Okay. When this parent, Ms. K., was

15 admitted to V.University Medical Center, were

16 you at all involved in her treatment?

17 A. No, I was not. It was one of my partners.

18 Q. Thomas Wheeler?

19 A. Correct.

20 Q. Did you discuss this case with Dr. Wheeler

21 when Ms. K. was an inpatient?

22 A. No, I did not.

23 Q. Did you know of her when she was an

24 inpatient?

25 A. No, I did not.


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1 Q. When did you first learn that your partner

2 treated Ms. K.?

3 A. When the medical records were sent to me, I

4 saw that Dr. D. had called Dr. Wheeler for transfer

5 so the mother could be with the baby. That was the

6 first time.

7 Q. Okay. And, of course, you’ve never

8 discussed this case with Dr. Wheeler; correct?

9 A. Correct.

10 Q. If hypothetically I had sent you a case

11 where I was suing Dr. D. — say even in another

12 case –

13 A. Uh-huh.

14 Q. – would you be willing to review the

15 records and give me an objective opinion about the

16 case?

17 A. No.

18 Q. Why not?

19 A. Well, you live in Israel. I mean, it’s so

20 far away — no.

21 I have made it a policy, Mr. Gershon, that

22 I do not take plaintiff cases for physicians who refer

23 to Vanderbilt. Because of my unique position here as

24 Director of Maternal-Fetal Medicine representing

25 Vanderbilt, I find it difficult to testify against


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1 physicians who call me up on the phone and tell me

2 exactly what’s going on and then send their patients to

3 me for management or consultation.

4 I think it’s — it would impede transfer of

5 these patients to us. It would set up a situation that

6 was very controversial or contentious. And I don’t

7 think it’s good politics, and I don’t think it helps

8 patients.

9 My job is to educate these doctors. If

10 they want to admit that they may have done something

11 wrong or they ask if they could have done something

12 differently and they speak openly and honestly with me,

13 I don’t want them ever to think that I will turn around

14 and use that against them.

15 So as a policy ever since I started

16 reviewing cases for lawyers since 1981, I have not

17 taken cases that fall into my catchment area, which is

18 the state of A., northern Alabama, and southern

19 K.. And …and Dr. D. are in that

20 catchment area.

21 Q. You would agree that a physician, when they

22 serve as a medical expert, needs to be completely

23 objective?

24 A. Oh, absolutely.

25 Q. Do you believe that you can be completely


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1 objective and unbiased when you review a case on behalf

2 of a physician that you have a professional

3 relationship with such as Dr. D.?

4 A. Sure. And I have done that and talked to

5 many attorneys and said that I would be unable to help

6 even though these were colleagues of mine or even in

7 some instances — well, colleagues — colleagues that I

8 work with side by side.

9 I have told attorneys that I cannot help

10 them if they have a significant problem. I feel like I

11 can be very objective.

12 Q. Would you agree with me, sir, that when you

13 have a relationship established with a health care

14 provider that, if nothing else, you’re gonna give the

15 health care provider the benefit of a doubt?

16 A. Well, I think I have written in a paper –

17 and maybe this is where you get the words — that when

18 there’s dispute that the patient says one thing

19 happened, the doctor says the other, or the nurse says

20 the other, if it — if it is consistent with what I

21 would expect the health care provider to do under

22 similar circumstances, I’ll give the health care

23 provider the doubt — the benefit of the doubt.

24 But as far as any other circumstance, I

25 don’t give anybody the benefit of the doubt and assume


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1 that just because I have a collegial relationship that

2 I’m gonna say something that is dishonest or

3 misrepresents the case just for the defense. I don’t

4 feel that’s my job, and it’s something that I work very

5 hard at not doing.

6 Q. Do you believe the nurses at V.are

7 trained to call you or not to call you as you believe

8 the standard of care existed in this particular case

9 for the nurses when to call Dr. D. or when not to?

10 A. I think the nurses here at Vanderbilt

11 represent a little bit of a different group of nurses

12 inasmuch as they’ve got chief residents and an

13 attending in the hospital constantly, and sometimes

14 they’ll run it by another physician before they call

15 me. So in that sense it’s a little different.

16 But assuming that it’s — that there are no

17 differences in who’s at the hospital, I think when the

18 nurses called Dr. D. they were calling at the

19 appropriate time. While I would have no problem if

20 they wanted to call earlier, that would have been fine

21 too. But I think as far as standard of care at

22 V.or at …that they acted

23 appropriately.

24 Q. Does your hospital have policies and

25 procedures on when nurses should call the doctor, when


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1 they shouldn’t call the doctor, that would be

2 consistent with your testimony today?

3 A. You know, I haven’t looked at our policies

4 and protocols in a long time. It might. I have

5 forgotten exactly the wording. So I have to plead that

6 I haven’t read it in such a long time that I don’t know

7 exactly how it’s worded. Certainly –

8 Q. Were you involved in the formulation of the

9 policies of when nurses should and shouldn’t call

10 doctors at your hospital?

11 A. Inasmuch as the nurses that run labor and

12 delivery will write them down. We have nurse

13 practitioners and others that spend a considerable

14 amount of time doing this. And then they give them to

15 me, and then I read them and approve them. I didn’t

16 actually write them. I may have changed a few

17 sentences or added or deleted a few things and then

18 eventually signed off on them.

19 I just, as we sit here, can’t cite line and

20 verse to answer that question.

21 Q. Okay. How difficult would it be for you to

22 obtain the policies and procedures for nurses, when

23 they should call doctors, that existed in your

24 institution that you approved, say, in 1996 when this

25 case was going on?


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1 A. Yeah, I probably could get that.

2 Q. Well, I’d ask you to please forward that to

3 Mr. R., as quickly as you could, and he’ll

4 hopefully send me a copy. Would that be okay?

5 A. Yes, it would.

6 MR. R.: That’s fine.

7 BY MR. GERSHON:

8 Q. Sir, is there anything else about standard

9 of care for the nurses that you intend to render

10 opinions about that I haven’t covered?

11 A. I don’t believe so.

12 Q. Are there any other areas that you’re going

13 to be defending the hospital in that we haven’t touched

14 upon?

15 A. I don’t believe so.

16 Q. Okay. I thank you very much for your time.

17 I don’t have any other questions.

18 THE WITNESS: Thank you.

19 MR. R.: Thanks.

20 (Proceedings adjourned at

21 1:15 p.m.)

22

23

24

25


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1 REPORTER’S CERTIFICATE

2 STATE OF A. )

3 COUNTY OF DAVIDSON )

4 I, Patricia W. Smith, Registered

5 Professional Reporter, with offices in N.,

6 A., hereby certify that I reported the foregoing

7 proceedings at the time and place set forth in the

8 caption thereof; that the proceedings were

9 stenographically reported by me; and that the foregoing

10 proceedings constitute a true and correct transcript of

11 said proceedings to the best of my ability.

12 I FURTHER CERTIFY that I am not

13 related to any of the parties named herein, nor their

14 counsel, and have no interest, financial or otherwise,

15 in the outcome or events of this action.

16 IN WITNESS WHEREOF, I have hereunto

17 affixed my official signature and seal of office this

18 12th day of March, 1999.

19

20

21

PATRICIA W. SMITH,

22 REGISTERED PROFESSIONAL REPORTER

AND NOTARY PUBLIC FOR THE STATE

23 OF A. AT LARGE

24 My Commission Expires:

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