HomeMy WebLinkAbout2017CV884 - CHAYCE ANDERSON V. FCPS OFFICER JASON SHUTTERS - 137C - EXHIBIT·1· · · · · · ·IN THE UNITED STATES DISTRICT COURT
· · · · · · · · ·FOR THE DISTRICT OF COLORADO
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· · ·Civil Action No. 17-CV-00884-CMA-STV
·3· ·______________________________________________________
·4· ·DEPOSITION OF:· ERIN CARNAHAN - June 3, 2019
· · ·______________________________________________________
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· · ·CHAYCE AARON ANDERSON,
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· · ·Plaintiff,
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· · ·v.
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· · ·JASON SHUTTERS,
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· · ·Defendant.
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· · · · · · · ·PURSUANT TO NOTICE, the deposition of
12· ·ERIN CARNAHAN was taken on behalf of the Plaintiff at
· · ·1024 South Lemay Avenue, Fort Collins, Colorado 80524,
13· ·on June 3, 2019, at 11:09 a.m., before Lisa B. Kelly,
· · ·Registered Professional Reporter, Certified Realtime
14· ·Reporter, and Notary Public within Colorado.
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SUPPLEMENTAL EXHIBIT 2
Case 1:17-cv-00884-CMA-STV Document 137-3 Filed 08/19/19 USDC Colorado Page 1 of 4
∑1∑ ∑authorized to make independent decisions about
∑2∑ ∑treatment for patients?
∑3∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑Yes.
∑4∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑And, again, with the same sort of caveats
∑5∑ ∑about having a physician sign off?
∑6∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑That's correct.∑ That's correct.
∑7∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑All right.∑ Now, it looks like you have
∑8∑ ∑Exhibit 15 in front of you.∑ And if you just want to
∑9∑ ∑take a second to look at it.∑ I'm just going to ask
10∑ ∑you if you recognize that document.
11∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑This is -- yeah.∑ This is the note that I
12∑ ∑had from the 2015 -- August 28, 2015.
13∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑Okay.∑ And this was the note for Chayce
14∑ ∑Anderson?
15∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑Yes.∑ That's the name on the top of
16∑ ∑the -- I assume, yeah.
17∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑Okay.∑ Can you tell me what you remember
18∑ ∑about August 28, 2015?
19∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑I do not remember anything about
20∑ ∑August 28, 2015.
21∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑Can you tell me if you remember anything
22∑ ∑about Mr. Anderson's medical care?
23∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑I do not remember anything about this
24∑ ∑patient.
25∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑So anything that you would know about
Erin Carnahan· ·06/03/2019
CHAYCE AARON ANDERSON v. JASON SHUTTERS
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Court Reporting, Legal Videography, and Videoconferencing
Erin Carnahan· ·06/03/2019
CHAYCE AARON ANDERSON v. JASON SHUTTERS
Page 9
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Court Reporting, Legal Videography, and SUPPLEMENTAL Videoconferencing EXHIBIT 2 YVer1f
Case 1:17-cv-00884-CMA-STV Document 137-3 Filed 08/19/19 USDC Colorado Page 2 of 4
∑1∑ ∑this patient would just be what you would read from
∑2∑ ∑the record?
∑3∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑Yes.∑ I've seen thousands of patients
∑4∑ ∑since this time, so it's hard to remember one, unless
∑5∑ ∑it stands out, and this one does not stand out in my
∑6∑ ∑memory.
∑7∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑Fair enough.∑ All right.∑ Well, let's
∑8∑ ∑just take a look really quickly at this record just to
∑9∑ ∑understand it, and hopefully we can let you go.
10∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ All right.∑ So if you turn to -- well,
11∑ ∑there are two page numbers at the bottom.∑ I'm going
12∑ ∑to refer to the ones that say "Anderson."
13∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑Okay.
14∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑So Anderson 13.∑ It's actually the
15∑ ∑first -- probably the first page.
16∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑Okay.
17∑ ∑ ∑ ∑ ∑ ∑Q.∑ ∑Yep.∑ And I just want to understand,
18∑ ∑where is all this information -- who entered this
19∑ ∑information?∑ Let's look specifically at the patient
20∑ ∑information section.
21∑ ∑ ∑ ∑ ∑ ∑A.∑ ∑The patient information is going to be --
22∑ ∑so we have a PAR, that's actually in the emergency
23∑ ∑room with us, that gets all the patient information,
24∑ ∑goes in, talks to the patient.∑ Or if the patient has
25∑ ∑a name tag, date of birth, you know.
Erin Carnahan· ·06/03/2019
CHAYCE AARON ANDERSON v. JASON SHUTTERS
Hunter + Geist, Inc.· · ·800.525.8490· · ·scheduling@huntergeist.com
Court Reporting, Legal Videography, and Videoconferencing
Erin Carnahan· ·06/03/2019
CHAYCE AARON ANDERSON v. JASON SHUTTERS
Page 10
Hunter + Geist, Inc.· · ·800.525.8490· · ·scheduling@huntergeist.com
Court Reporting, Legal Videography, and SUPPLEMENTAL Videoconferencing EXHIBIT 2 YVer1f
Case 1:17-cv-00884-CMA-STV Document 137-3 Filed 08/19/19 USDC Colorado Page 3 of 4
∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑REPORTER'S CERTIFICATE
∑2∑ ∑STATE OF COLORADO∑ )
∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ) ss.
∑3∑ ∑COUNTY OF LARIMER∑ )
∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑I, LISA B. KELLY, Registered Realtime
∑ ∑ ∑Reporter, Registered Professional Reporter and Notary
∑5∑ ∑Public ID 19934018358, State of Colorado, do hereby
∑ ∑ ∑certify that previous to the commencement of the
∑6∑ ∑examination, the said ERIN CARNAHAN was duly sworn by
∑ ∑ ∑me to testify to the truth in relation to the matters
∑7∑ ∑in controversy between the parties hereto; that the
∑ ∑ ∑said deposition was taken in machine shorthand by me
∑8∑ ∑at the time and place aforesaid and was thereafter
∑ ∑ ∑reduced to typewritten form; that the foregoing is a
∑9∑ ∑true transcript of the questions asked, testimony
∑ ∑ ∑given, and proceedings had.
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∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑I further certify that I am not employed
11∑ ∑by, related to, nor of counsel for any of the parties
∑ ∑ ∑herein, nor otherwise interested in the outcome of
12∑ ∑this litigation.
13∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑IN WITNESS WHEREOF, I have affixed my
∑ ∑ ∑signature this 14th day of June, 2019.
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∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑My commission expires September 4, 2019.
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17∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ __________________________
∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ Lisa B. Kelly
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20∑ ∑_____∑ Reading and Signing was requested.
21∑ ∑__X__∑ Reading and Signing was waived.
22∑ ∑_____∑ Reading and Signing was not required.
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Erin Carnahan· ·06/03/2019
CHAYCE AARON ANDERSON v. JASON SHUTTERS
Hunter + Geist, Inc.· · ·800.525.8490· · ·scheduling@huntergeist.com
Court Reporting, Legal Videography, and Videoconferencing
Erin Carnahan· ·06/03/2019
CHAYCE AARON ANDERSON v. JASON SHUTTERS
Page 45
Hunter + Geist, Inc.· · ·800.525.8490· · ·scheduling@huntergeist.com
Court Reporting, Legal Videography, and SUPPLEMENTAL Videoconferencing EXHIBIT 2
Case 1:17-cv-00884-CMA-STV Document 137-3 Filed 08/19/19 USDC Colorado Page 4 of 4