HomeMy WebLinkAbout2017CV884 - Chayce Anderson V. Fcps Officer Jason Shutters - 133I - Exhibit 9EXHIBIT 9
Case 1:17-cv-00884-CMA-STV Document 133-9 Filed 07/26/19 USDC Colorado Page 1 of 5
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·1· · · · · ·Q.· ·And what was your -- what were your roles
·2· ·and responsibilities as a physician assistant at
·3· ·Poudre Valley Hospital?
·4· · · · · ·A.· ·To treat patients, to see medical
·5· ·screening examination, to evaluate the patient, order
·6· ·lab work, disposition or admit the patient, depending
·7· ·on -- and I continue in that role.· I've been here
·8· ·since 2014.
·9· · · · · ·Q.· ·Is it fair to say that what you just
10· ·described were the roles and responsibilities you had
11· ·in August of 2015?
12· · · · · ·A.· ·Yes.
13· · · · · ·Q.· ·Were you -- in August 2015, were you
14· ·authorized to make independent medical diagnoses?
15· · · · · ·A.· ·Yes.
16· · · · · ·Q.· ·And did that require the supervision of a
17· ·medical doctor or could you do that independently?
18· · · · · ·A.· ·Yes.· We have supervision of physicians
19· ·at all times.· We have to have -- they have to sign
20· ·off on our charts and any patient that we see.· Now,
21· ·they don't necessarily have to see the patient,
22· ·depending on what -- the severity of the patient.· But
23· ·typically, yeah, they are required to see the charts
24· ·and sign them off.
25· · · · · ·Q.· ·All right.· And in August 2015, were you
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·1· · · · · ·A.· ·I was the provider in this case, yeah.
·2· · · · · ·Q.· ·And who is Tara Hallihan --
·3· · · · · ·A.· ·She was my attending that was on with me.
·4· · · · · ·Q.· ·Did Ms. Hallihan -- or rather
·5· ·Dr. Hallihan, did she also see Mr. Anderson?
·6· · · · · ·A.· ·I don't remember this particular case,
·7· ·but my guess is no.
·8· · · · · ·Q.· ·So this diagnosis was, in all likelihood,
·9· ·made exclusively by you?
10· · · · · ·A.· ·Exclusively by me, yep.
11· · · · · ·Q.· ·And Dr. Hallihan would sign off on it
12· ·after reviewing what you had recorded?
13· · · · · ·A.· ·Right.· At the end of the night, charts
14· ·that came through -- if it wasn't a patient that
15· ·was -- so we have different numbers for patients:· 1,
16· ·2, 3, 4, 5.
17· · · · · · · · The 3, 4s and 5s, the mid-levels, or the
18· ·APPs, the advanced practitioners can see.· And usually
19· ·the 1s are the traumas that come in, that need
20· ·intubation or something of that nature, and that's
21· ·something that the physicians have to see.
22· · · · · ·Q.· ·Now, in your training and experience,
23· ·what does disturbance of skin sensation mean?
24· · · · · ·A.· ·Anything that -- an excoriation.· Any --
25· ·or scratch.· Anything that disturbs the epidermis of
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·1· ·say that -- let's see.· I mean, I can't conclusively
·2· ·say he didn't have any nerve damage, no.
·3· · · · · ·Q.· ·Are diagnostic tests capable of providing
·4· ·conclusive evidence of nerve damage?
·5· · · · · ·A.· ·In this case, probably not.· Because you
·6· ·would have to probably do what's called a needle EMG
·7· ·nerve conduction study, that, you know, is -- you
·8· ·would have -- you would send it off to, you know, have
·9· ·the patient see a neurologist and see if they have any
10· ·nerve damage.
11· · · · · · · · I mean, I could have gotten an MRI, but
12· ·all that's going to show me is if there's any bleed or
13· ·abnormality or swelling or something.· I can't
14· ·conclusively say there's any nerve damage.
15· · · · · · · · And, again, this is emergency medicine,
16· ·so we evaluate the patient to make sure that they
17· ·are -- there's nothing, from our standpoint, that
18· ·needs to be done at that time.
19· · · · · · · · If there's something that's critical,
20· ·that they need to be intubated or life-threatening
21· ·illness, then we evaluate them, we get them
22· ·stabilized, and admit the patient at that point and
23· ·have someone else follow up with them.
24· · · · · · · · But in this case, based on my note, I did
25· ·not see any abnormalities --
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