Direct-Examination of Dr. Henry

(Medical Doctor in Wrongful Death)

QUALIFICATIONS

• FULL NAME AND BUSINESS ADDRESS
• TELL US ABOUT YOUR EDUCATIONAL BACKGROUND
• WHERE DID YOU GO TO MEDICAL SCHOOL?
• WHEN DID YOU GRADUATE?
• WHERE DID YOU DO YOUR RESIDENCY?
• WHERE WERE YOU EMPLOYED AFTER YOUR RESIDENCY?
• HOW LONG HAVE YOU BEEN IN PRIVATE PRACTICE?
• BRIEF SUMMARY OF YOUR PRIVATE PRACTICE
• WHAT TYPE OF MEDICAL DOCTOR ARE YOU ?
• DO YOU PERFORM SURGERIES?
• HOW OFTEN ?
• DO YOU HAVE HOSPITAL PRIVILEGES ?
• ARE YOU BOARD CERTIFIED IN ANY SPECIALTY?
• ARE ALL DOCTORS BOARD CERTIFIED?
• HAVE YOU BEEN QUALIFIED TO TESTIFY AS AN EXPERT BEFORE?

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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