HomeMy WebLinkAbout2020CV30363 - Stuward Cross And Katrina Richman V. City Of Fort Collins - 041A - Exhibit 1 - Cross DepositionPage 89
·1· ·collision.
·2· · · · A· · Okay.
·3· · · · Q· · Why did you go to Concentra?
·4· · · · A· · Concentra is the treating physician for
·5· ·Yellow Cab.· That's where they told me to go.· I needed
·6· ·to go in order to treat anything on a Workmen's Comp
·7· ·claim basis.
·8· · · · Q· · And is there a reason you decided to go to
·9· ·Concentra at that time?
10· · · · A· · Well, as I mentioned, I was hurt, and I was
11· ·asking what I could do about it.· The cab company had
12· ·literally just told me, Okay, well, this is where you
13· ·need to go.· So I followed their advice and went there.
14· · · · Q· · Do you ever remember telling any of your
15· ·medical providers that you went to the doctor because
16· ·your attorney told you to?
17· · · · · · ·MR. HARRIS:· Objection.· Foundation.· You can
18· ·answer.
19· · · · A· · No.· I don't recall saying, because my
20· ·attorney told me to.· I might have, like, in
21· ·conversational terms, said that it was a good idea. I
22· ·followed up.· I'm doing this, that, and the other with
23· ·my attorney, but not by any direct means have they told
24· ·me to come in.
25· · · · Q· · (By Mr. Callahan)· So you went to Concentra.
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·1· ·I'm going to show you a couple of records here.· My
·2· ·review of the records is that your initial complaint
·3· ·was for the neck -- the left side, neck, and shoulder
·4· ·pain; is that correct?
·5· · · · A· · Yes, sir.
·6· · · · Q· · All right.· And you had not had any prior
·7· ·issues with your neck or shoulder?
·8· · · · A· · No.· I haven't.
·9· · · · Q· · All right.· I see that you did have some
10· ·chronic low back pain?
11· · · · A· · On occasion.· You know, I -- you spend your
12· ·life being the biggest guy anybody can see.· I'm, like,
13· ·6-3 and 270.· You know, you get a lot of family that's,
14· ·like, Hey, you're a good guy.· Help me out with this.
15· ·So, of course, I have thrown out my lower back here and
16· ·there.
17· · · · · · ·And also, I had a lot of problems, what they
18· ·call compensator issues, because I do have a previous
19· ·injury where my knee was shot out in '98.· So having a
20· ·fully repaired right knee and I'm not sure both my legs
21· ·are the same length.· I limp a little bit, and that
22· ·puts a lot of stress through your lower back.
23· · · · Q· · So you were shot in 1998.
24· · · · A· · Yes, sir.
25· · · · Q· · What did they have to do to fix your knee?
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·1· · · · A· · Full arthroscopic reconstruction, the top of
·2· ·the tibia was crushed.
·3· · · · Q· · And how long has that been causing you low
·4· ·back pain?
·5· · · · · · ·MR. HARRIS:· Objection.· Form.· You can
·6· ·answer.
·7· · · · A· · Initially, it was more a matter of, you know,
·8· ·my leg and the feeling.· It took me almost two years to
·9· ·be, you know, up and walking again.· So at that point,
10· ·I was stiff and hardly mobile, and it's just a natural
11· ·progression of forcing my body to work.· I've always,
12· ·since that injury, had some trouble with my lower back.
13· ·But no more so than your pinch here and there, you
14· ·know.
15· · · · · · ·It's not like it's put it in a constant
16· ·state.· I just tend to be a little tense and crampy in
17· ·my lower back, because it depends on my activity level.
18· ·You know, if I'm out hiking in the woods, yeah, my
19· ·back's going to hurt that night.· You know.
20· · · · · · ·THE WITNESS:· Cat, bug off.· Cat's going
21· ·crazy.
22· · · · Q· · (By Mr. Callahan)· Okay.· Do you remember
23· ·telling Concentra that you could not take off work
24· ·because you have 10 people to support at home?
25· · · · · · ·THE WITNESS:· Sorry for the cat removal.
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·1· · · · · · ·MR. CALLAHAN:· That's all right.
·2· · · · A· · That would have to be situational, because,
·3· ·of course, I had my wife, my two daughters, my nephew,
·4· ·at one point, my sister-in-law was living with me and
·5· ·her spouse and child.· Ten seems like the wrong number.
·6· ·I was probably in pain and exaggerating a bit, but five
·7· ·to six plus.· And yeah, that was a large portion of my
·8· ·medical treatment and concern, because I was behind on
·9· ·the cab, because I had to feed my children, and because
10· ·I couldn't fail and I had to do it absolutely every
11· ·day.
12· · · · · · ·The doctor's office is only scheduled from
13· ·8:00 to 5:00.· Well, guess what.· That's when people
14· ·who want rides might call for rides, is from 8:00 to
15· ·5:00.· If I'm in a cab, I need to be out there during
16· ·business hours when these people are active.· Because I
17· ·could go out after 5 p.m. after all the business is
18· ·closed and sit there for four to five hours without a
19· ·phone call, because guess what, there ain't nothing
20· ·happening in the world.
21· · · · · · ·And I had the utmost problem in continuing my
22· ·physical therapy and continuing my treatment and even
23· ·getting back to the doctors because, as conveniently
24· ·located as Centerra is, or Concentra -- I'm sorry, I
25· ·get that wrong.· It's still a matter, from a driver's
Meadors Court Reporting
Stuward Cross· - 05/27/2021
Meadors Court Reporting
Stuward Cross· - 05/27/2021 89 to 92
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DATE FILED: October 11, 2021 9:41 PM
FILING ID: DA8F83C2EB94C
CASE NUMBER: 2020CV30363