Direct-Examination of Dr. Henry

(Medical Doctor in Wrongful Death)

QUALIFICATIONS

OFFER AS AN EXPERT

GENERAL BURN INJURIES

  • DIFFERENCE BETWEEN A 1,2 AND 3RD DEGREE BURN?
  • WHAT ARE THE DIFFERENT WAYS BURNS ARE TREATED ?
  • ARE CHEMICAL BURNS DIFFERENT THEN OTHER TYPES OF BURNS?

REVIEW OF RECORDS

  • DID YOU REVIEW ANY RECORDS BEFORE TESTIFYING HERE TODAY?
  • WHAT RECORDS HAVE YOU REVIEWED?
  • DID YOU RELY ON THOSE RECORDS IN FORMING YOUR OPINION?

MEDICAL RECORDS

  • WHAT IS A HISTORY?
  • WHY IS IT IMPORTANT?

DAY ONE 7/28/00 FRIDAY

  • WHAT WAS THE HISTORY TAKEN FROM PATSY MARTIN IN THIS CASE?
  • WHAT WHERE HER COMPLAINTS ?
  • WHAT WAS HER ADMITTING DIAGNOSIS?
  • WHAT WAS YOUR UNDERSTANDING OF THE CHEMISTRY OF THE LIQUID SHE WAS EXPOSED TO ?
  • TWO DIAGRAMS REGARDING HER BURNS WHAT DO THOSE TELL YOU?
  • WHAT WAS HER LEVEL ON CONSCIOUSNESS?
  • IS THERE ANY NOTE THAT SHE EVER LOST CONSCIOUSNESS?
  • WHAT IS A GLASGOW COMA SCALE?
  • WHAT WERE HER SCORES?
  • WHAT WAS HER PAIN SCALE?
  • I KNOW AT FIRST NO ONE AT BAYVIEW KNEW WHAT WAS IN THE CHEMICALS THAT BURNED HER, HOW LONG DID SHE HAVE TO GO WITHOUT MEDICATION?

DAY TWO & THREE 7/29/00 & 7/30/00 SATURDAY & SUNDAY

  • WHAT WAS HER HEART RATE?

DAY FOUR 7/31/00 MONDAY

  • INCREASING RESPIRATORY DISTRESS ?
  • STARTED ON A NON-REBREATHER FACE MASK?

DAY FIVE AUGUST 1, 2000 TUESDAY

  • SURGERY-DESCRIBE
  • HOW DID SHE DO AFTER THE SURGERY?
  • WERE HER BURNS WHAT YOU EXPECTED?
  • AFTER THE SURGERY SHE HAD AN ET TUBE IN ?

DAY SIX AUGUST 2, 2000 WEDNESDAY

  • BETWEEN 8/1/00 AND 8/2/00 DEVELOPED RESPIRATORY ACIDOSIS, WHAT IS THAT?
  • SHE BECAME HYPOTENSIVE, WHAT DOES THAT MEAN?
  • LINES WERE PLACE TO MONITOR HER VIATLS, WHAT IS A SWAN-GANZ CATHETER?
  • WHAT IS A FEMORAL ARTERIAL LINE ?
  • WHAT IS SYSTEMIC INFLAMMATORY RESPONSE SYNDROME?
  • HOW DOES SIRS RELATE TO BURN VICTIMS?
  • WHAT IS SEPSIS, HOW DOES THAT RELATE TO BURN VICTIMS?
  • DEVELOPED HYPOXIA WHAT IS THAT AND HOW DOES THAT RELATE TO BURN VICTIMS?
  • WHY DOES THAT HAPPEN TO BURN VICTIMS?
  • WHEN DID PATSY MARTIN PASS AWAY?
  • WHAT WAS HER CAUSE OF DEATH?

OPINION QUESTIONS

DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL CERTAINTY AS TO WHAT INJURIES PATSY MARTIN SUFFERED FROM AS A RESULT OF HER EXPOSURE TO HOT LIQUID WITH CHEMICALS IN IT?

WHAT IS THAT OPINION?

DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL CERTAINTY AS TO WHETHER THE PAIN AND SUFFERING ENDURED BY PATSY MARTIN WAS AS A RESULT OF HER EXPOSURE TO HOT LIQUID WITH CHEMICALS IN IT?

WHAT IS THAT OPINION?

DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL CERTAINTY AS TO WHETHER THE DEATH OF PATSY MARTIN WAS AS A RESULT OF HER EXPOSURE TO HOT LIQUID WITH CHEMICALS IN IT?

ARE YOU FAMILIAR WITH THE CHARGES OF BAYVIEW HOSPITAL ?

ARE ALL THE CHARGES FAIR REASONABLE, NECESSARY AND CAUSALLY RELATED A RESULT OF HER EXPOSURE TO HOT LIQUID WITH CHEMICALS IN IT?

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