P VCM RICHARD SENNEF

These are summaries taken from the Official Court Transcripts:

PLEASE NOTE: IMAGES USED, MAY NOT BE EXACT USED IN COURT:

 

RICHARD SENNEFF

CALLED ON BEHALF OF THE PEOPLE, HAVING BEEN FIRST DULY SWORN, WAS EXAMINED AND TESTIFIED AS FOLLOWS:

 

DIRECT EXAMINATION

MR. WALGREN:

Q         SIR, WHAT DO YOU DO FOR A LIVING?

A         I’M A FIREFIGHTER PARAMEDIC FOR THE CITY OF LOS ANGELES FIRE DEPARTMENT.

Q         HOW LONG HAVE YOU BEEN EMPLOYED AS A LOS CITY FIREFIGHTER?

A         TWENTY-FIVE YEARS.

Q         HOW LONG HAVE YOU WORKED AS A PARAMEDIC?

A         1982.   SO, 26 YEARS, 27 YEARS.

Q         DID YOU COME ONTO THE LOS ANGELES CITY FIRE DEPARTMENT AS A PARAMEDIC?   YOU HAD ALREADY BEEN EMPLOYED AS A PARAMEDIC?

A         THAT IS CORRECT.

Q         WHAT IS YOUR JOB AS A PARAMEDIC ON A DAY-TO-DAY BASIS?

A         AS A FIREFIGHTER PARAMEDIC, I LOOK AFTER THE PEOPLE IN MY COMMUNITY.   WHEN THEY HAVE A PROBLEM, WHEN THEY ARE ILL,   SICK, HAVE AN ACCIDENT, I HELP THEM TO THE BEST I CAN, MEDICALLY SPEAKING, I RIDE ON A RESCUE AMBULANCE PART OF THE TIME, AND THE OTHER PART   I RIDE ON A FIRE ENGINE.   THAT IS A PARAMEDIC ASSESSMENT ENGINE. ALSO, OF COURSE, I’M INVOLVED WITH FIREFIGHTING, FIRE SUPPRESSION, FIRE INSPECTION, THOSE SORT OF THINGS.

Q         DID YOU HAVE A PARTICULAR ASSIGNMENT IN JUNE OF 2009?

A         YES

Q         WERE YOU ASSIGNED TO A PARTICULAR STATION HOUSE?

A         YES

Q         WHAT WAS THAT LOCATION?

A         I WAS ASSIGNED TO FIRE STATION 71 IN BEL AIR, AND ON THAT PARTICULAR DAY I WAS IN THE ATTENDANT POSITION ON THE RESCUE AMBULANCE WORKING AS A PARAMEDIC.

Q         WHERE IS FIRE STATION 71 LOCATED WITHIN BEL AIR?  

A         IT IS AT THE CORNER OF BEVERLY GLEN AND SUNSET BOULEVARD.

Q         THAT IS STILL YOUR ASSIGNMENT?

A         NO, SIR.

Q         WHAT DO YOU DO NOW?

A         I’M AN INSTRUCTOR AT THE ACADEMY, SPECIFICALLY E.M.T., EMERGENCY MEDICAL TECHNICIAN, RECERTIFICATION PROGRAM THAT WE RUN FOR ALL OUR FIREFIGHTERS.

Q         YOU TEACH, IS IT, NEW FIREFIGHTERS AND NEW PARAMEDICS WITH REGARD TO E.M.T. AND EMERGENCY MEDICAL TREATMENT?

A         NOT NEW.   EXPERIENCED ONES. FIREFIGHTERS, ALL E.M.T.’S IN CALIFORNIA HAVE TO DO 24 HOURS OF CERTIFICATION TRAINING EVERY TWO-YEAR CYCLE.   SO FOR THREE DAYS, THEY COME TO OUR ACADEMY AND I INSTRUCT THEM ON BASICS, CPR, AIRWAY MANAGEMENT, THOSE SORT OF THINGS.   AND ALSO ANY NEW TRENDS.   FOR EXAMPLE, I WAS JUST TEACHING CHILDBIRTH BEFORE I CAME TO CLASS TODAY, OR COURT.

Q           SO GOING TO JUNE 25, 2009, YOU WERE WORKING RESCUE AMBULANCE 71?

A         THAT’S CORRECT.

Q         AND DID YOU RECEIVE A CALL RESULTING IN A DISPATCH AT 12:22 TO RESPOND TO A PARTICULAR LOCATION?

A         YES

Q         WHAT WAS THE NATURE OF THE INFORMATION YOU RECEIVED WITH REGARD TO THAT CALL?

A         THE FIRST INFORMATION I RECEIVED CAME OVER THE AUDIO ALARM IN THE STATION, AND IT INVOLVED THE LOCATION AND THE TYPE OF INCIDENT WAS A CARDIAC ARREST.

Q         WHEN YOU GET AN INITIAL CALL, DO YOU GET SOME SORT OF PRINTOUT THAT GIVES YOU SOME OF THE RELEVANT IDENTIFYING INFORMATION THAT YOU NEED IN ORDER TO RESPOND TO THE CALL?

A         YES, WE DO.   WE REFER TO IT AS A TELETYPE OR, SLANG, THE RUN SHEET.   IT IS A PRINTOUT THAT APPEARS ON OUR COMPUTER SCREEN.   WE ALSO GET A HARD COPY ON A PIECE OF PAPER IN THE STATION.

Q         AND DID YOU OBTAIN THAT TELETYPE IN REGARD TO THIS CALL THAT WE HAVE JUST REFERENCED?

A         THAT IS CORRECT.

Q         WOULD THIS SPECIFICALLY BE IN REGARD TO A CALL TO RESPOND TO 100 NORTH CAROLWOOD IN LOS ANGELES?

A         THAT IS CORRECT.

Q         IF YOU COULD BE MORE SPECIFIC, WHAT WAS THE EXACT INFORMATION YOU RECEIVED REGARDING THAT EMERGENCY?

A         WITHOUT IT IN FRONT OF ME, I WOULD SAY SPECIFICALLY IT WILL TELL THE DATE, THE TIME OF DISPATCH, THE ADDRESS, 100.   THE TYPE OF INCIDENT, CARDIAC ARREST. THE CATEGORY OF INCIDENT, WHICH IS IT WILL PROBABLY SAY SOMETHING LIKE 12D/C, OR SOMETHING, WHICH IS THE TYPE OF CARDIAC ARREST.   THEN THERE IS MAP COORDINATES ON IT.

Q        ON THIS DAY, YOU ARE RESPONDING TO A CALL REGARDING CARDIAC ARREST.   WERE YOU AWARE IT WAS A 50-YEAR-OLD MALE?

A         YES.

Q         WHEN YOU RESPONDED TO THAT CALL, WHO WAS DRIVING RESCUE AMBULANCE NO. 71?

A         FIREFIGHTER PARAMEDIC MARTIN BLOUNT.

Q         WHERE WERE YOU SEATED?

A         THE RIGHT SIDE OF THE FRONT OF THE AMBULANCE.

MR. WALGREN:   YOUR HONOR, I HAVE A COPY OF THE TELETYPE HERE.   MAY THIS BE MARKED PEOPLE’S 18 FOR IDENTIFICATION?

THE COURT:   YES.

MR. WALGREN:   MAY I APPROACH THE WITNESS, YOUR HONOR?

THE COURT:   YOU MAY.

MR. WALGREN:  

Q                 SIR, SHOWING YOU WHAT HAS JUST BEEN MARKED PEOPLE’S 18, IS THAT THE TELETYPE THAT YOU JUST REFERENCED?

A         YES

Q         YOU SEE IT IS NOW WATERMARKED WITH “DISTRICT ATTORNEY” ACROSS IT?

A         YES, I SEE THAT.

Q         THAT WAS NOT THE CONDITION IT WAS IN, OBVIOUSLY, WHEN YOU HAD IT?

A         NO,

Q         DOES THAT TELETYPE THEN REFLECT SOME OF THE PERTINENT INFORMATION THAT YOU RELAYED TO US REGARDING THE LOCATION YOU ARE RESPONDING TO, THE AGE OF THE INDIVIDUAL THAT YOU ARE RESPONDING TO, AS WELL AS GENDER?

A         YES

Q         AND DOES IT ALSO REFLECT AN INCIDENT TIME?

A         YES

Q         WHAT TIME IS THAT?

A         12:21.

Q       DOES IT REFLECT A DISPATCH TIME?

A         YES, 12:22.

Q         HOW LONG DID IT TAKE YOU TO GET TO THE LOCATION OF 100 NORTH CAROLWOOD?

A         WE GOT ON SCENE AT 12:26, SO FOUR MINUTES.

Q         SHOWING YOU WHAT WAS EARLIER MARKED PEOPLE’S 2 FOR IDENTIFICATION, DO YOU RECOGNIZE THAT AS THE FRONT COURTYARD AREA AND FRONT DOOR AREA OF 100 NORTH CAROLWOOD?

A         YES

Q         IN PEOPLE’S 2, DOES THAT DEPICT WHERE YOUR RESCUE AMBULANCE PARKED OR CAME TO THE LOCATION?

A         YES, LOOKING AT THE DOOR, TO THE LEFT, THE FRONT BUMPER WOULD HAVE BEEN RIGHT TO WHERE THE BUSHES ARE IN THE FRONT.

Q         IF YOU WANT TO USE THIS LASER POINTER AND JUST INDICATE TO US WHERE YOU PARKED.

A         FRONT BUMPER OF THE RESCUE AMBULANCE WOULD HAVE BEEN RIGHT HERE.   SIDE DOOR THERE.   THE BACK WOULD HAVE BEEN RIGHT HERE.   THE FRONT WAS RIGHT HERE  (INDICATING).

Q         THE FRONT WAS, AS YOU LOOK AT THE PHOTOGRAPH, WAS TO THE LEFT OF THE LEFT PILLAR AREA OF THAT ENTRY-WAY?

A         YES

Q         WERE YOU IMMEDIATELY ESCORTED INTO THE HOUSE?

A         YES.

Q         BY WHOM

A         SECURITY PEOPLE WEARING DARK SUITS, DARK TIES, WHITE SHIRTS.   THERE WERE SEVERAL OF THEM.

Q         AS FAR AS THE RESCUE PERSONNEL THAT RESPONDED, IN ADDITION TO YOURSELF, YOU MENTIONED PARAMEDIC BLOUNT; IS THAT RIGHT?

A         THAT’S CORRECT.

Q         WAS THERE ANOTHER PARAMEDIC?  

A           YES, MARK GOODWIN.   HE WAS RIDING IN THE PARAMEDIC SPOT ON THE ENGINE.

Q         WERE THERE ANY OTHER FIREFIGHTERS RESPONDING AS PART OF YOUR TEAM?

A         YES.   THERE WOULD BE FIREFIGHTER BRET HERRON. AND   FIRE CAPTAIN, JEFF MILLS.     THE ENGINEER AT SOME POINT CAME TO HELP US.     GARY BURGANDY.   AND MY E.M.S. SUPERVISOR, MEDICAL SUPERVISOR,   CAPTAIN BOB LINNEL.

Q         NOW, AS FAR AS THE CARAVAN BEING THE RESCUE AMBULANCE AND THE ENGINE, WOULD THAT HAVE CONTAINED YOURSELF, PARAMEDIC BLOUNT, PARAMEDIC GOODWIN,   FIREFIGHTERS HERRON, MILLS, AND ENGINEER BURGANDY?

A         THAT IS CORRECT.

Q         DO YOU KNOW WHO WAS THE FIRST ONE INTO THE HOME AT 100 NORTH CAROLWOOD OF THAT TEAM?

A         IT WAS ME.

Q         WHERE DID YOU OR WHERE WERE YOU DIRECTED TO GO AS YOU ENTERED THE HOME?

A         UP THE STAIRS.

Q         FROM GOING UP THE STAIRS, WHERE DID YOU GO?

A         IF MEMORY SERVES ME RIGHT, I MADE A RIGHT AT THE TOP THE STAIRS AND DOWN A LITTLE BIT TO A BEDROOM.

Q         SHOWING YOU WHAT HAS BEEN EARLIER MARKED PEOPLE’S 11 FOR IDENTIFICATION, DO YOU RECOGNIZE WHAT IS SHOWN THERE?

A         YES

Q         DOES THAT DEPICT AT THE FORWARD-MOST PORTION OF THAT PHOTO THE ENTRY AS WELL AS THE BEDROOM TO WHICH YOU RESPONDED?

A         YES

Q         SIR, WHAT DID YOU SEE WHEN YOU FIRST CAME INTO THE ROOM DEPICTED IN PEOPLE’S 11?

A         WHEN I WALKED IN THE ROOM, I SAW THE DOCTOR.

Q         WHEN YOU SAY THE DOCTOR, TO WHOM ARE YOUR REFERRING?

A         DR. MURRAY.

Q         COULD YOU IDENTIFY HIM, PLEASE?

A         HE IS SITTING RIGHT THERE.

THE COURT:   POINTING TO AND IDENTIFYING DR. MURRAY,THE DEFENDANT.

MR. WALGREN:

Q         WHERE WAS DR. MURRAY WHEN YOU FIRST CAME IN THE ROOM, IF YOU RECALL?

A         LOOKING AT THE PICTURE AND USING THE LASER POINTER, HE WAS STANDING RIGHT HERE BY THE NIGHTSTAND SIDE OF THE BED REACHING OVER THE PATIENT.

Q         AND FOR THE RECORD, IN PEOPLE’S 11 YOU HAVE POINTED TO THE FAR SIDE OF THE BED AS YOU ENTER THE ROOM?

A         YES, SIR.

Q         WHEN YOU SAY THE PATIENT, WHAT DID YOU SEE IN REGARD TO A PATIENT?

A         I SAW WHAT APPEARED TO ME TO BE A THIN, PALE PATIENT, WEARING PAJAMAS WITH A NIGHT CAP ON, AND A SHIRT OPENED UP, LAYING ON THE BED.

Q         ON THE BED?

A         ON THE BED.   UNDERWEIGHT, YES.

Q         DID YOU SEE ANYTHING HAPPENING AS YOU WALKED INTO THE ROOM?

A        YES.   I SAW THE DOCTOR ATTEMPTING TO MOVE THE PATIENT FROM THE BED TO THE FLOOR.   HE WAS ABOUT HALFWAY BETWEEN THE TWO.

Q         WAS ANYONE ASSISTING HIM?

A         I DID NOT SEE ANYONE ASSISTING HIM.

Q         DO YOU REMEMBER BEING INTERVIEWED BY THE POLICE AND IT WAS AUDIO RECORDED?

A         I DO.

Q         DO YOU RECALL SAYING THAT IT APPEARED TO BE DR. MURRAY AND SOME SECURITY PERSONNEL TRYING TO LIFT HIM OFF THE BED?

A         I DON’T REMEMBER SAYING THAT.   I REMEMBER THAT THERE WAS A SECURITY PERSONNEL THERE.   I DON’T REMEMBER IF THEY WERE HELPING HIM MOVE HIM OFF THE BED.

Q         IT COULD HAVE BEEN?

A         THEY COULD HAVE BEEN, SURE.   THERE WAS A LOT OF CONFUSION.

Q         DID YOU HAVE A PARTICULAR ROLE TO PLAY AS PART OF THIS EMERGENCY RESPONSE TEAM?

A         YES, I DID.  ALL OF OUR JOBS ARE PREDETERMINED BY WHERE WE ARE SITTING IN THE VEHICLE, THE   APPARATUS BEING THE FIRE ENGINE OR THE AMBULANCE.   THAT WAY, IT IS JUST A BIG TIME SAVER WHEN WE GET TO AN EMERGENCY.

Q         YOU WERE THE PASSENGER OF RA-71, CORRECT?

A         THAT’S CORRECT.

Q         AND DID THAT HAVE PARTICULAR MEANING AS TO WHICH ROLE YOU WOULD PLAY UPON RESPONDING TO THE SCENE?

A         IT DOES.   THAT MAKES ME THE RADIO MAN.

Q         WHAT DOES THAT MEAN?

A         THAT MEANS I’M, MEDICALLY SPEAKING, OVERALL IN CHARGE OF THE PATIENT, COMMUNICATIONS, INFORMATION GATHERING, INFORMATION DISPERSION.

Q         WHEN YOU FIRST RESPOND TO A SCENE, WHAT IS THE MOST IMPORTANT INFORMATION YOU ARE TRYING TO OBTAIN?

A         WHAT IS OUR CHIEF COMPLAINT.   WHAT HAS HAPPENED.   WHY ARE WE HERE.

Q         WHEN YOU FIRST CAME ONTO THE SCENE, DID THE DEFENDANT, DR. MURRAY, INTRODUCE HIMSELF TO YOU AS THE PATIENT’S PERSONAL CARDIOLOGIST?

A         HE SAID HE WAS HIS DOCTOR ANYWAY. DID NOT SAY CARDIOLOGIST.

Q         WHEN YOU FIRST CAME ON THE SCENE,   DID YOU OBSERVE ANY TYPE OF ELECTRONIC MEDICAL EQUIPMENT HOOKED UP TO THE PATIENT, ANY TYPE OF HEART MONITOR, ANYTHING OF THAT NATURE?

A         I DID NOT.

Q         DID YOU SEE AN I.V. STAND OR I.V. KIT?

A         I DID.

Q         WHERE WAS THAT?

A         THAT WAS ON THE SAME SIDE OF THE BED AS THE DOCTOR

Q         NOW, AT SOME POINT THEN COMING INTO THE ROOM, ARE YOU TRYING TO OBTAIN INFORMATION FROM SPECIFICALLY DR. MURRAY REGARDING WHAT HAPPENED?

A         YES

Q         BEING THE RADIO MAN AND THE PERSON IN CHARGE, IN THAT ROLE WAS THAT ONE OF YOUR PRIMARY RESPONSIBILITIES TO GET THAT INFORMATION FROM THE DEFENDANT, DR. MURRAY?

A         YES

Q         DID YOU START ASKING HIM QUESTIONS?

A         I DID.

Q         DID YOU ASK HIM WHAT THE UNDERLYING MEDICAL CONDITION WAS?

A         I DID

Q         WHAT DID DR. MURRAY SAY?

THE COURT:   I’M SORRY?

THE WITNESS:   THAT IS ONE OF THE FIRST THINGS I ASKED.

MR. WALGREN:  

Q                 WHAT DID DR. MURRAY TELL YOU?

A         HE DIDN’T ANSWER.     I REPEATED THE QUESTION AGAIN, AND HE SAID, “THERE ISN’T ANY.”

Q         IN RESPONSE TO THE QUESTION OF, “WHAT IS THE UNDERLYING MEDICAL CONDITION,” HE SAID, “THERE ISN’T ANY”?

A         YES.

Q         DID YOU PURSUE QUESTIONING?

A         I DID PURSUE IT BECAUSE IT IS UNUSUAL TO COME SOMEONE’S HOME — I’VE BEEN INTO A LOT OF HOMES THROUGH THE YEARS — AND HAVE AN I.V. POLE AND A PERSONAL DOCTOR THERE.   THAT IS JUST NOT USUAL. AND THE PATIENT, HE APPEARED TO ME TO BE PALE AND UNDERWEIGHT.   I WAS THINKING ALONG THE LINES OF THIS IS A HOSPICE PATIENT.

Q         A HOSPICE PATIENT?

A         A HOSPICE PATIENT.

Q         YOU CONTINUED WITH YOUR QUESTIONING BECAUSE OF KIND OF THE NATURE OF THE CIRCUMSTANCES?

A         IT DIDN’T ADD UP.

Q         AND DID YOU REPEAT THE SAME QUESTION THEN?

A         I DID.

Q         WHAT DID DR. MURRAY SAY, IF ANYTHING?

A         HE SAID, “NO, HE DOESN’T HAVE A PROBLEM.   HE IS FINE.   HE WAS PRACTICING ALL NIGHT.   I’M JUST TREATING HIM FOR DEHYDRATION.”

Q         DID YOU AGAIN FOLLOW UP WITH THAT TO MAKE SURE THAT WAS IT?

A         IT ALL SEEMED TOO SIMPLE.   AGAIN, HE APPEARED, THE PATIENT APPEARED, UNDERWEIGHT, THIN, LAYING IN BED.   IT IS 12:00 NOON.   HE HAS AN I.V. POLE.   HE HAS A DOCTOR.

Q         YOU DON’T MEAN 12:00 NOON EXACTLY?

A         I MEAN IT IS MIDDAY.   IT IS MIDDAY.   AND THERE IS ITEMS AROUND THE HOUSE THERE.   IT LOOKED LIKE SOMEONE WHO WAS UNDER THE CARE OF A PHYSICIAN FOR A CHRONIC ILLNESS.

Q         SO DID YOU CONTINUE YOUR QUESTIONING?

A         I DID.

Q         WHAT DID YOU ASK?

A         I ASKED, “IS HE TAKING ANY MEDICATIONS?”

Q         WHAT DID DR. MURRAY TELL YOU, IF ANYTHING?

A         “NO, NONE.   HE IS NOT TAKING ANYTHING.”

Q         DID YOU FOLLOW UP AGAIN WITH THAT QUESTION?

A         I DID BECAUSE IT DIDN’T ADD UP.   I REPEATED IT.   HE SAID, “WELL, I GAVE HIM A LITTLE BIT OF LORAZEPAM TO HELP HIM SLEEP.”

Q         DID HE TELL YOU ANY OTHER MEDICINE, NARCOTIC AGENTS, OR ANY OTHER THINGS HE GAVE THE PATIENT AT ALL?

A         NO.   AFTER HE ANSWERED THAT, I SAID, “THAT’S IT?”   HE GOES, “THAT’S IT.   NO, NOTHING.”

Q         JUST LORAZEPAM?

A         JUST LORAZEPAM TO HELP HIM SLEEP.

Q         EITHER AT THAT TIME OR AT ANY TIME DID DR. MURRAY EVER TELL YOU HE HAD GIVEN THE PATIENT PROPOFOL?

A         NO, SIR.

Q         LORAZEPAM IS A BENZODIAZEPINE; IS THAT CORRECT?

A         IT IS COMMONLY REFERRED TO AS ATAVAN, A VERY COMMON OVER-THE-COUNTER MEDICATION FOR PEOPLE TO SLEEP. WHETHER IT IS A BENZODIAZEPINE OR NOT, I THINK IT MIGHT BE.   I’M NOT REALLY SURE.

Q        BUT NO OTHER MEDICINES OF ANY NATURE WERE MENTIONED BY DR. MURRAY OTHER THAN LORAZEPAM?

A         THAT’S CORRECT.   NOTHING ELSE.

Q           ONCE HE GAVE YOU THIS INFORMATION REGARDING LORAZEPAM, DID YOU ASK HIM HOW LONG THE PATIENT HAD BEEN IN THIS CONDITION, HAD BEEN DOWN?

A         YES,.

Q         WHAT WERE YOU TOLD?

A         “IT JUST HAPPENED.”

Q         DID HE ELABORATE ON WHAT HE MEANT BY “JUST HAPPENED”?

A         HE SAID, “IT JUST HAPPENED.”

Q         JUST HAPPENED?

A         “IT JUST HAPPENED.”   THAT WAS ENOUGH FOR ME.

Q         DO YOU REMEMBER TELLING THE POLICE, “IT HAPPENED JUST RIGHT WHEN I CALLED YOU”?

A         I DO REMEMBER SAYING THAT.

Q         IS THAT WHAT YOU RECALL HEARING?

A         THAT IS WHAT WAS SAID.

Q         IF YOU ARE TAKING WHAT DR. MURRAY TOLD YOU AS THE TRUTH AT THAT MOMENT, AND YOU KNEW THAT A 911 CALL CAME INTO YOU AT 12:21, IF DR. MURRAY IS TELLING YOU, “IT JUST HAPPENED WHEN I CALLED YOU,” WHAT DOES THAT MEAN AS FAR AS YOUR TREATMENT?

A         WE GO ON A LOT OF CALLS WHERE WE GET THERE AND IT IS AN ELDERLY PERSON.   THEY HAVE HAD CANCER, SOMETHING LIKE THAT.   THEY HAVE BEEN DOWN FOR 15, 20 MINUTES, NO CPR DONE.   AND WE KNOW, EVEN THOUGH WE TRY OUR BEST, IT IS GOING TO BE FUTILE. WHEN HE SAYS, “IT JUST HAPPENED,” AND THERE IS A DOCTOR THERE AND, YOU KNOW, THAT MEANS THERE IS AN ASSUMPTION THERE IS SOME CPR GOING ON, ONLY A FEW MINUTES GET BY, WE GET EXCITED BECAUSE WE WILL GET TO DO SOMETHING.

Q         WHAT DO YOU MEAN BY THAT?

A         THERE IS A STRONG CHANCE THAT WE ARE GOING TO BRING THIS PERSON BACK.   IT KICKS US INTO HIGH GEAR REAL FAST.

Q         THAT IS ASSUMING WHAT DR. MURRAY TOLD YOU WAS THE TRUTH THAT HE HAD JUST BEEN DOWN?

A         YES

Q         NOW, DID YOU OBSERVE THE PATIENT?

A         YES.     I HELPED MOVE THE PATIENT.   I SAW THE PATIENT THERE WHEN I WAS MOVING HIM, LAYING ON THE BED.

Q         AT SOME POINT WAS HE MOVED TO AN AREA TO BE WORKED ON?

A         FIREFIGHTER HERRON WAS RIGHT BEHIND ME.   BIG, STRONG FIREMAN.   I HAD HIM GO AROUND TO THE HEAD OF THE PATIENT, AND HE LIFTED UP THE TORSO, AND I LIFTED UP THE LEGS.   WE MOVED HIM OVER TO THE FOOT OF THE BED.

Q         IS THAT SHOWN ON PEOPLE’S 11 WHERE HE WAS MOVED TO THE FOOT OF THE BED?

A         YES, RIGHT IN THIS AREA HERE.   IT GAVE US A GOOD WORKING AREA.

Q         RIGHT ON THE RUG AREA OF PEOPLE’S 11 AT THE FOOT OF THE BED?

A         THAT’S RIGHT.   THE PATIENT’S FEET WOULD BE TOWARDS US.   THE PATIENT’S HEAD WOULD BE TOWARDS THE FIREPLACE, IN THAT DIRECTION, BUT AT THE FOOT OF THE BED.

Q         NOW, DESPITE DR. MURRAY TELLING YOU THE PATIENT HAD JUST BEEN DOWN WHEN HE CALLED, DID THE PATIENT IN YOUR EXPERT OPINION APPEAR TO HAVE JUST BEEN DOWN?

A         INITIALLY WHEN HE TOLD ME THAT, SURE.   SOUNDS FINE.   THEN AS SOON AS I PICKED HIM UP, HIS LEGS WERE QUITE COOL, COOL TO THE TOUCH.

Q        HOW ABOUT HIS EYES?

A         HIS EYES, THE MOISTURE IN THE EYES, HIS EYES HAD BECOME DRY.

Q         WHAT DOES THAT MEAN?

A         TIME HAS ELAPSED.   AND THEN WE HOOKED HIM UP TO THE EKG, AND ALL WE HAD WAS A FLAT LINE WITH SOME PULSELESS ELECTRICAL ACTIVITY.   JUST A LITTLE BIT, VERY SLOW RATE.

 

Q         WHAT IS AN EKG?

A         IT IS ELECTRICAL TRACING OF THE ELECTRICAL ACTIVITY THAT GOES ON IN THE HEART.   NOT MECHANICAL, BUT ELECTRICAL.

Q        IS THAT WHERE THE TABS ARE PLACED ON THE CHEST OF THE PATIENT?

A         THAT’S CORRECT.

Q         TO READ ESSENTIALLY ELECTRICAL HEART ACTIVITY?

A         THAT’S CORRECT.

Q         WHAT DID THE READING SHOW YOU WHEN THAT WAS FIRST PLACED ON MICHAEL JACKSON?

 A         LIKE I SAY, IT WAS FLAT WITH AN OCCASIONAL SMALL BLIP, WHICH WE CALL P.E.A., PULSELESS ELECTRICAL ACTIVITY.

 

Q         WHAT IS IT?

A         YOUR HEART IS DESIGNED TO KEEP WORKING, SO IT 12  HAS A SERIES OF BACKUP SYSTEMS IN IT.   WHAT IT MEANS, THE    BACKUP SYSTEMS ARE THE HEART’S PACEMAKERS ITSELF.   THERE IS DIFFERENT AREAS.   , IT IS ONE OF THE PACEMAKERS IN THE HEART TRYING TO FIRE OFF A SIGNAL TO START THE WHOLE ELECTRICAL PROCESS THROUGH THE HEART, BUT IT IS NOT SPREADING THROUGHOUT THE REST OF THE HEART.   IT IS NOT CAPTURING AND SPREADING THROUGHOUT AND CAUSING THE OTHER CONTRACTIONS TO OCCUR.   SO YOU JUST GET THE ONE BLIP AND NOTHING HAPPENS.   IT IS A SMALL BLIP.   IT WAS A SMALL BLIP, TOO.

Q         OTHER THAN THE P.E.A. YOU DESCRIBED, YOU HAVE INDICATED THE EKG READINGS WERE FLAT-LINE?

 A         THAT’S CORRECT.

Q         THAT IS ASYSTOLE?

A         THAT IS ASYSTOLE, YES.

Q         AND IS ASYSTOLE CONSISTENT WITH HAVING JUST HAPPENED WHEN DR. MURRAY CALLED 911?

A         IN MY EXPERIENCE, NO, IT IS NOT.

Q         DID YOU MAKE ANY OBSERVATIONS AS TO THE COLOR OF THE HANDS AND FEET OF THE PATIENT?

A         YES, .   HIS HANDS AND FEET WERE TINGED BLUE.

Q         TINGED BLUE?

A         CYANOTIC.

Q         WHAT DID THAT MEAN TO YOU?

A         IT MEANS THAT THERE HASN’T BEEN ANY RESPIRATION GOING ON, AND THE RED BLOOD CELLS AREN’T RED ANYMORE.   THEY ARE TURNING BLUE.   SO THERE IS NO CIRCULATION GOING ON, NO RESPIRATION.   IT MEANS TIME HAS ELAPSED.

Q         BASED ON YOUR OBSERVATIONS OF THE EYES BEING DRY, HOW ABOUT THEIR SIZE AND DILATION?

A         THEY WERE FULLY DILATED.

Q         WHAT DID THAT MEAN TO YOU?

A         IT MEANS THAT THE EYE MUSCLES THEMSELVES HAD RELAXED, WHICH COMMONLY OCCURS AFTER THERE IS LACK OF OXYGEN TO THAT AREA.

Q         IN LAY PERSON’S TERMS, FROM THE TIME YOU WERE AT THE SCENE THROUGHOUT YOUR CARE, IN YOUR OPINION WAS THE PATIENT DECEASED?

A        YES.

Q         THAT WAS BASED ON A NUMBER OF FACTORS, SOME OF WHICH YOU DESCRIBED ALREADY?

A         YES.

Q           YOU HAVE ASKED THE QUESTIONS OF DR. MURRAY AND BEEN TOLD HE HAS ONLY GIVEN HIM LORAZEPAM AND THIS JUST HAPPENED WHEN HE CALLED WHAT ARE THE OTHER PEOPLE ON YOUR TEAM DOING?

A         MARTIN BLOUNT, HE IS SECURING AN AIRWAY THROUGH ENDOTRACHEAL INTUBATION.   BRET HERRON IS STARTING   CHEST COMPRESSIONS, AND MARK GOODWIN IS ATTEMPTING TO GET AN I.V.   I’M HOOKING UP THE ELECTRODES.   MARK IS ACTUALLY HELPING ME DO THAT, TOO.   THE ELECTRODES BEING THE WIRES THAT GIVE US THE EKG READING.   AND THEN I’M CHANGING — THERE IS AN I.V. IN HIS LEG.   I’M CHANGING THE I.V. OUT TO A SYSTEM WE CAN USE.

Q         DID THIS CARE OR ANY PORTION OF THIS CARE BEGIN ON THE SIDE OF THE BED ON THE FLOOR, OR WAS THIS PRIMARILY THE FOOT OF THE BED YOU DESCRIBED WHERE THE PATIENT WAS MOVED?

A         IT WAS ALL AT THE FOOT OF THE BED.

Q         THAT WAS TO GIVE ROOM FOR YOUR TEAM?

A         WE ARE ALL VERY BUSY.   THERE ARE SEVERAL OF US.   WE NEED ROOM.

Q         WHAT DOES IT MEAN FOR A PATIENT’S EYES TO BE BLOWN?

A         BLOWN PUPILS, BLOWN MEANS THAT THE PUPIL IS FULLY DILATED.

Q         IS THAT WHAT YOU OBSERVED ON THIS PATIENT?

A         YES.

Q         TO BE CLEAR, THIS PATIENT WE ARE TALKING ABOUT IS MICHAEL JACKSON.   DID YOU LEARN THAT SUBSEQUENTLY?

A         SUBSEQUENTLY, I DID, YES.

Q         BASED ON YOUR 27 YEARS EXPERIENCE AND THEOBSERVATIONS YOU MADE REGARDING THE ASYSTOLIC CONDITION OF THE PATIENT, THE FLAT LINE, THE TINGED BLUE COLOR OF THE FEET AND HANDS, THE FULLY BLOWN AND FIXED AND DILATED EYES, AS WELL AS THE PATIENT BEING COOL TO THE TOUCH AS WELL AS DRYNESS OF THE EYES, HOW LONG WOULD YOU ESTIMATE   THAT PATIENT HAD BEEN DOWN?

A         IT VARIES FROM INDIVIDUAL TO INDIVIDUAL.   IT DEPENDS ON WHETHER THEY ARE LAYING IN FRONT OF AN AIR CONDITIONER, OR WHETHER THERE IS A HEATER GOING, OR A FAN, ELECTRIC BLANKETS ON THEM OR NOT.   THERE IS A LOT OF LITTLE VARIABLES. BUT ALL I CAN TELL YOU IS IT WAS MY GUT FEELING AT THE TIME THIS DID NOT JUST HAPPEN.   IT HAS BEEN A PERIOD OF TIME.

Q         CAN YOU GIVE A WINDOW OF TIME?

A         IT IS HARD TO SAY.   HONESTLY IS.   I WOULD THINK MORE THAN 20 MINUTES.

Q         FROM THE TIME YOU ARRIVED TO THE PATIENT AT 12:26?

A         RIGHT.   FROM THE TIME I FIRST EXAMINED THE PATIENT, IT OCCURRED TO ME WITHIN SECONDS IT WAS OBVIOUS   THIS HAD NOT JUST HAPPENED.   SOME TIME HAD ELAPSED.

Q         MORE CONSISTENT WITH APPROXIMATELY 20 MINUTES HAVING ELAPSED?

A         YEAH, I WOULD SAY.   NOT AS LONG AS HOURS OR SOMETHING LIKE THAT, BUT

Q         NOW, LET’S TALK ABOUT THE I.V. STAND.   YOU SAW THE I.V.     WAS HOOKED UP TO THE PATIENT

A         YES.

Q         DO YOU RECALL WHERE IT WAS HOOKED UP TO?

A         IT WAS HIS LEFT LEG ON THE CALF, ON THE INSIDE OF HIS LEFT CALF.

Q         DID THAT APPEAR TO BE HOOKED UP TO A STANDARD SALINE BAG OR I.V. BAG?

A         YES, IT DID.   AT A DISTANCE IT APPEARED TO BE A STANDARD SALINE BAG.

Q         IN ADDITION TO THE TREATMENT YOU HAVE ALREADY MENTIONED, WERE DRUGS USED ON THE PATIENT TO TRY TO REVIVE HIM?

A         YES.

Q         WHAT WAS THE FIRST ROUND OF DRUGS USED ON THE PATIENT?

A         EPINEPHRINE AND ATROPINE.

Q         EPINEPHRINE IS ADRENALINE?

A         IT IS ADRENALINE, LAYMAN’S TERMS.

Q         THAT IS FOR WHAT?

A         IT KICK-STARTS THE HEART.

Q         AND THE ATROPINE, WHAT IS THAT?

A        IT DOES THE SAME THING BUT VIA DIFFERENT MECHANISM.   IT BASICALLY TAKES THE BRAKES OFF THE HEART SO THE HEART CAN ACCELERATE.   JUST A DIFFERENT ROUTE.

Q         WHILE THIS FIRST ROUND OF EPINEPHRINE AND ATROPINE ARE USED, ARE THE COMPRESSIONS CONTINUING?

A         YES, THROUGHOUT, AND VENTILATIONS ARE ALSO CONTINUING.

Q         AND THE VENTILATIONS WERE IN THE ENDOTRACHEAL TUBE OR INTUBATION?

 

 

 

 

 

 

 

 

 

A         THAT’S CORRECT.

Q         THAT IS COMMONLY CALLED AN E.T. TUBE?

A         YES

Q         IN SIMPLE TERMS, BASICALLY THE TUBE IS INSERTED INTO THE TRACHEA AND SEALED, THEN PUMPED TO GET AIR DIRECTLY INTO THE PATIENT?

A         YES, SO THE AIR GOES DIRECTLY INTO THE PATIENT’S LUNGS AND NOT INTO THE PATIENT’S STOMACH.   IF    YOU PUT AIR IN A PATIENT’S STOMACH, IT WILL EVENTUALLY FILL UP AND EMPTY STOMACH CONTENTS.   YOU CAN BLOCK THE AIRWAY THAT WAY.   SO THIS WAY, IT GOES STRAIGHT INTO THE LUNGS. THERE IS A BALLOON THAT SEALS RIGHT THERE TO SEAL OFF THE LUNGS SO THAT IT STAYS THERE AND IT ALL WORKS, AND NOTHING GETS IN THERE.

Q         WHO WAS HANDLING THE INTUBATION ON THIS CALL?

A         MARTIN BLOUNT.

Q         WHAT IS CAPNOGRAPHY?

A         CAPNOGRAPHY IS A MEANS TO READ THE CARBON DIOXIDE READINGS FROM THE BODY.   WHEN CELLS BREATHE IN OXYGEN AND RELEASE CARBON DIOXIDE, THE CAPNOGRAPHY READS THAT.

Q         AND WAS THAT PART OF YOUR CARE AND OBSERVATIONS ON THE PATIENT,   ON THIS DAY  TO GET READINGS ON THE CAPNOGRAPHY?

A         YES

Q         AND IS THAT BASICALLY TO DETERMINE HOW EFFECTUAL THE E.T. TUBE IS IN PROVIDING OXYGEN TO THE PATIENT?

A         THAT’S CORRECT.   IF WE WERE TO PLACE THE E.T. TUBE IN THE WRONG PLACE, WE WOULD GET A VERY POOR CAPNOGRAPHY READING SO WE WOULD KNOW THAT WE NEED TO REPOSITION IT.

Q         AND DESCRIBE HOW THE INTUBATION WORKED IN THIS CASE.   WAS IT QUICK?  

A         IT WAS VERY QUICK.   MARTIN DID IT.   AND I WAS SURPRISED HOW QUICKLY HE GOT IT

Q         AND ONCE IT WAS IN, WERE YOU GETTING READINGS ON THE CAPNOGRAPHY?

A         YES

Q         THAT IS AGAIN TO READ WHAT THE C02 EXHALATIONS WERE SO YOU KNOW WHETHER YOU HAVE A GOOD E.T. TUBE?

A         GOOD E.T. TUBE PLACEMENT.

Q         WHAT KIND OF READINGS WERE YOU GETTING ON THE CAPNOGRAPHY?

A         I WOULD HAVE TO LOOK AT MY 902-M.

Q         DID YOU AUTHOR THE 902-M?

A         I DID.

Q         WHAT IS THAT?

A         902-M IS THE MEDICAL SERVICES REPORT THAT WE   CREATE FOR EVERY PATIENT THAT WE HAVE ANY INTERACTION WITH.

Q         AND WOULD IT REFRESH YOUR RECOLLECTION IF YOU WERE TO LOOK AT YOUR 902-M?

A         YES

Q         MR. SENNEFF,TAKE A MOMENT TO LOOK AT THIS REPORT .   DO YOU RECOGNIZE THAT AS THE 902-M THAT YOU AUTHORED?

A         I DO.

Q         AND DOES THAT REFLECT THE CAPNOGRAPHY, THE RELEVANT CAPNOGRAPHY READINGS?

A        IT DOES.

Q         IS YOUR MEMORY REFRESHED?

A         IT IS.

Q         S ONCE THE E.T. TUBE HAD BEEN PLACED, WHAT TYPE OF READINGS WERE YOU GETTING?

A         WE GOT A 16.

Q         WHAT DOES THAT MEAN?

A         NORMAL IS SOMEWHERE AROUND THE RANGE OF 35, 38, UP TO 40.   SIXTEEN IS VERY, VERY LOW.

Q         DID THE READINGS EVER INCREASE?

A         THEY DID.

Q         TO WHAT?

A         UP TO 26.

Q         WHAT DOES THAT MEAN TO YOU?

A         IT MEANS THAT OUR E.T. TUBE WAS IN THE CORRECT PLACE.

Q           YOU MENTIONED IN YOUR INTERVIEW WITH THE POLICE, THAT TAKES A LOT OF STRESS OFF OF YOU AND YOUR TEAM.   WHAT DID YOU MEAN BY THAT?

A         A LOT OF US HERE IN THIS COURTROOM, I’M SURE, HAVE HAD CPR AND STRESS AIRWAY/BREATHING CIRCULATION.   WE HAVE TO GET A GOOD AIRWAY.   WE CAN DO ALL THE OTHER THINGS WE DO.   BUT IF WE CAN’T GET A GOOD AIRWAY, EVERYTHING ELSE IS NAUGHT FOR US.   AS SOON AS WE GET THAT AIRWAY IN PLACE, WE CAN MOVE ON TO THE NEXT STEP AND MOVE FORWARD

Q         MR. SENNEFF, I BELIEVE WE LEFT OFF TALKING ABOUT THE CAPNOGRAPHY READINGS AND WE HAD GOTTEN, I BELIEVE, TO 26 OR 27?

A         TWENTY-SIX, YES, SIR.

Q         THAT WAS A GOOD READING SHOWING GOOD INTUBATION OF THE PATIENT?

A         YES

Q         YOU HAD MENTIONED THEN INITIALLY THERE HAD BEEN AN I.V. ALREADY PLACED IN THE PATIENT’S LEG?

A         YES

Q         WHEN YOU GAVE THE FIRST ROUND OF EPINEPHRINE AND ATROPINE, WAS THAT ADMINISTERED VIA THAT I.V. THAT HAD ALREADY BEEN IN PLACE OR A NEW I.V.?

A         THE I.V. THAT WAS ALREADY IN PLACE.

Q         WAS THERE SOME TYPE OF, I GUESS, RESTRUCTURING OF THE I.V. PORT THAT NEEDED TO BE DONE TO MAKE YOUR EQUIPMENT COMPATIBLE WITH THAT I.V.?

A         YES

Q         COULD YOU DESCRIBE THAT SIMPLY FOR US,PLEASE?

A         THERE IS TWO SYSTEMS FOR ADMINISTERING MEDICATIONS THROUGH I.V.’S.   IT IS WITH A NEEDLE AND WITHOUT A NEEDLE.   COMMONLY REFERRED TO AS NEEDLE-LESS. IN THE PRE-HOSPITAL CARE SETTING, WE CHANGED OVER TO A NEEDLE-LESS SYSTEM YEARS AGO BECAUSE IT IS JUST TOO EASY TO STICK YOURSELF WITH A CONTAMINATED NEEDLE WHEN YOU ARE DRIVING DOWN THE STREET IN THE BACK OF AN AMBULANCE. THE DIFFERENCE IS YOU HAVE THE I.V. CATHETER, THE TUBE THAT IS ACTUALLY IN THE VEIN.   IT HAS A LITTLE HUB ON IT, THEN THE PORT THAT GOES INTO IT.   THAT IS THE DIFFERENCE IS THE TYPE OF PORT. A NEEDLE PORT HAS LIKE A LITTLE RUBBER STOPPER ON THAT YOU PUT THE NEEDLE IN THE CENTER.   A NEEDLE-LESS HAS A VALVE INSIDE.   YOU SCREW THE NEEDLE-LESS SYRINGE ONTO IT, AND THEN THAT RELEASES A VALVE AND YOU PUSH THE SOLUTION IN.   THEN YOU UNSCREW IT TO REMOVE IT. WITH A NEEDLE, YOU SLIDE THE NEEDLE IN, INJECT SOLUTION, AND SLIDE THE NEEDLE BACK OUT.

Q         WHEN YOU GET THERE, THERE IS AN I.V. BAG HANGING FROM THE I.V. STAND?

A         YES

Q         A TUBE IS COMING FROM THAT BAG, AND IT IS ATTACHED TO MICHAEL JACKSON’S LEG AREA?

A         YES

Q         THEN OFF OF THAT TUBE AT SOME LOCATION IS A PORT ALLOWING FOR THE ADMINISTRATION OF DRUGS INTO THAT I.V. TUBING?

A         YES

Q         WHEN YOU FIRST ARRIVED, WAS IT THE NEEDLE SYSTEM KIT OR NEEDLE-LESS?

A         NEEDLE SYSTEM WAS IN PLACE.

Q         AND LAFD HAS GONE TO NEEDLE-LESS?

A         NEEDLE-LESS.

Q         SO WHAT WAS CHANGED TO ALLOW YOUR SYRINGES TO SCREW IN, TO BE ACCESSED VIA THE PORT THAT ALREADY EXISTED?

A         WE REMOVED THE SALINE LOCK ITSELF OF THE PORT SYSTEM.   JUST CHANGE IT OUT.   LEFT THE HUB IN AND PUT A NEW ONE IN.

Q         WHILE LEAVING THE EXISTING TUBE, I.V. BAG?

A         YES.

Q         JUST CHANGED OUT THE PORT?

A         YES.   THE PORT IS WHERE WE ARE GOING TO BE INJECTING OUR MEDICATIONS.

Q         HOW MANY ROUNDS OF EPINEPHRINE AND ATROPINE WERE PUT INTO THAT PORT THAT EXISTED UPON YOUR ARRIVAL?

A         COULD I LOOK AT MY 902?

Q         PLEASE.  

A         OKAY.   I’M GOING TO SAY TWO ROUNDS.

Q         OF BOTH EPINEPHRINE AND ATROPINE?

A         THAT’S CORRECT.

Q         IN RESPONSE TO THESE TWO ROUNDS OF EPINEPHRINE AND ATROPINE WAS THE ASYSTOLIC NATURE OF THE PATIENT CHANGING AT ALL?

A         EKG RHYTHM DID NOT CHANGE APPRECIABLY.

Q         STILL FLAT LINE?

A         YES

Q         AT SOME POINT THEN AFTER THESE TWO ROUNDS, DID THE LEG I.V. — WAS IT COMPROMISED IN SOME WAY?

A         YES

Q         DID YOU SEE HOW THAT HAPPENED?

A         YES

Q         WHAT HAPPENED?

A         DR. MURRAY TOOK SOME OF OUR MEDICINE, AND HE USED THE I.V. PORT AND INJECTED INTO THAT.  BUT HE IS USED TO A —

Q         DON’T SPECULATE ABOUT WHAT HE IS USED TO. TELL ME WHAT YOU SAW.

A         IN USING IT, HE PULLED IT OUT.   HE PULLED THE I.V. OUT.

Q         WHAT HAPPENED THEN?

A         I STARTED ANOTHER I.V.

Q         WAS ONE OF THE OTHER PARAMEDICS ASSISTING YOU IN ATTEMPTING TO START A NEW I.V.?

A         WHEN WE FIRST GOT THERE, MARK GOODWIN STARTED ATTEMPTING TO GET AN I.V. ACCESS.     BECAUSE WE DON’T NORMALLY TRUST ANOTHER I.V. THAT IS IN PLACE.   BUT I HAD CHECKED IT, AND IT APPEARED TO BE WORKING FINE, SO I USED IT UNTIL HE COULD GET A BETTER ONE.   BUT BEFORE HE GOT A BETTER ONE, THIS ONE WAS COMPROMISED.  

Q         DID YOU OBSERVE PARAMEDIC GOODWIN ATTEMPTING TO GET AN I.V. INTO THE ARMS OF THE PATIENT

A         YES BOTH ARMS.

Q         WHAT WAS HE DOING IN REGARD TO THAT?

A       PUTTING A TOURNIQUET AROUND THE ARM, FEELING FOR VEINS, STICKING THE NEEDLE IN.  

Q         TO BE CLEAR THEN, MARK GOODWIN THEN IS LITERALLY INSERTING THE NEEDLE, PUNCTURING THE SKIN IN VARIOUS LOCATIONS OF BOTH MICHAEL JACKSON’S ARMS TO TRY TO PLACE AN I.V.?

A         THAT IS CORRECT.

Q         AND THIS WAS ON BOTH THE RIGHT AND LEFT ARM IN MULTIPLE LOCATIONS?

A         YES.

Q         WAS HE ABLE TO GET A GOOD I.V. LOCATION

A         NO

Q         AT SOME POINT DID YOU TRY TO GET AN I.V. IN THE JUGULAR AREA OF THE PATIENT?

A         YES

Q         WHERE EXACTLY?

A         LEFT SIDE OF THE NECK.

Q         YOU ARE RUBBING YOUR NECK BELOW THE EAR AREA?

A         YES.

Q        DID YOU DO THAT PERSONALLY?

A         I DID.

Q         WERE YOU ABLE TO GET THE I.V. SET UP IN THE JUGULAR AREA?

A         YES

Q           WERE ADDITIONAL ROUND OR ROUNDS OF EPINEPHRINE AND ATROPINE INJECTED INTO THE PATIENT?

A         YES.

Q         WOULD THAT HAVE A DIFFERENT EFFECT IF IT IS BEING PUT IN IN THE JUGULAR AS OPPOSED TO, FOR EXAMPLE, THE LEG OR ARM?

A         YES, IT WOULD BE A PREFERRED ROUTE BECAUSE IT IS A LARGER VEIN AND MORE DIRECT ROUTE TO THE HEART.

Q         THE PATIENT WOULD MORE QUICKLY REACT TO IT IF THE PATIENT WAS GOING TO REACT TO IT?

A         THAT’S CORRECT.

Q         DID YOU GET ANY RESULTS FROM THAT ROUND OF EPINEPHRINE AND ATROPINE?

A         NO

Q           IN THE TIME THAT YOU WERE AT THE LOCATION,   DID YOU EVER FEEL A PULSE ON MICHAEL JACKSON?

A         NO

Q         DID ANY OF YOUR TEAM OF PARAMEDICS AND FIREFIGHTERS   EVER INDICATE TO YOU THAT THEY FELT A PULSE ON THE PATIENT?

A         NO

Q         WAS THERE ONE PERSON WHO CLAIMED TO FEEL A PULSE?

A         YES

Q         WHO WAS THAT?

A         DR. MURRAY.

Q         WHERE DID HE CLAIM TO FEEL A PULSE?

A         I THINK HE WAS CHECKING THE CAROTID, THE NECK.  

Q         DO YOU RECALL SAYING HE FELT A FEMORAL PULSE?

A         YES.   YES, HE DID.   I REMEMBER NOW BECAUSE AFTER HE CHECKED, I PUT MY HAND ALSO ON THE FEMORAL PULSE.   I DIDN’T FEEL ANYTHING.

Q         WHILE THIS TREATMENT IS GOING ON WITH THE EKG, THE COMPRESSIONS, STARTER DRUGS, IS THAT EPINEPHRINE AND ATROPINE?

A         YES, TO START WITH.

Q           WHILE ALL THIS IS GOING ON, YOU MAKING CONTACT DIRECTLY WITH THE BASE STATION AT UCLA?

A       I CALLED THEM ON THE CELL PHONE.

Q         WHAT IS THE PROCEDURE YOU TYPICALLY FOLLOW IN THAT REGARD?

A         THAT DOCTOR IS AT THE BASE STATION AT THE HOSPITAL.   THEY COMMUNICATE WITH US VIA   RADIO OR PHONE.   THERE IS PROTOCOLS THAT ARE IN PLACE AND SPECIALLY TRAINED NURSES WHO WILL ANSWER THE RADIOS AND GIVE OUT STANDARD ORDERS,   THEY HAVE A DOCTOR RIGHT THERE IF THEY HAVE GOT ANY ISSUES OR ANY PROBLEMS, ANY QUESTIONS. SO WE CALL THEM, AND THEY GIVE US ORDERS.   WE CARRY OUT THE ORDERS.     WE ARE THEIR EYES, EARS, AND HANDS.

Q         WERE YOU IN DIRECT CONTACT WITH THE UCLA BASE STATION IN REGARD TO YOUR TREATMENT OF MICHAEL JACKSON

A         YES

Q         YOU ARE RELAYING, FOR EXAMPLE, THAT WE ARE DOING A NEW ROUND OF STARTER DRUGS, THINGS OF THAT NATURE?

A         YES

Q         CAPNOGRAPHY READINGS, THINGS OF THAT NATURE?

A         YES.   EVERY TIME WE DO SOMETHING THAT INVOLVES MEDICATION, WE TELL THEM.

Q         AT 12:57 P.M., WERE YOU ADVISED BY UCLA ALL FUTURE ATTEMPTS TO REVIVE MICHAEL JACKSON WOULD BE FUTILE?

A         I’M NOT SURE OF THE EXACT TIME, YES.

Q         IS THAT INDICATED ON YOUR 902 FORM ANYPLACE, OR WAS IT JUST ON THE BASE STATION RECORDING?

A         I WOULD BELIEVE IT WOULD BE ON THE BASE STATION RECORDING.   I WOULD JOURNALIZE IT IN OUR JOURNAL, AND I WOULD PROBABLY HAVE IT ON PAGE 2.   THIS IS PAGE 1.

Q         YOU ARE REFERRING TO PAGE 1 OF THE 902?

A         THAT’S CORRECT.

Q         I’LL HAND YOU PAGE 2 TO LOOK AT BY YOURSELF TO SEE IF THAT REFRESHES YOUR RECOLLECTION.

A         I HAVE WRITTEN DOWN HERE, BUT I DON’T SEE A TIME, BUT THAT IS APPROXIMATELY CORRECT.   RIGHT AROUND THEN.

Q       AT SOME POINT IF IT WAS INSTRUCTED BY UCLA ALL FUTURE ATTEMPTS WOULD BE FUTILE,

A         YES

Q         AT SOME POINT DID THAT TAKE PLACE WHERE UCLA TOLD YOU ESSENTIALLY, “YOU HAVE DONE ALL YOU CAN, AND WE WILL CALL IT”?

A         YES.

Q         AT THAT POINT, WHAT HAPPENED?

A         I TOLD THEM THAT WE HAD A VERY HIGH PROFILE V.I.P.   WE WOULD BE MUCH MORE COMFORTABLE TRANSPORTING THE PATIENT TO THE HOSPITAL

Q         HAD YOU ADVISED UCLA THE PERSONAL PHYSICIAN WAS ON SCENE?

A         YES.

Q         WHAT WAS SAID IN REGARD TO THE PERSONAL PHYSICIAN, DR. MURRAY, ASSUMING CARE OF THE PATIENT IF THE CARE WAS GOING TO CONTINUE?

A         THE PHYSICIAN ON SCENE HERE, IS NOT COMFORTABLE WITH THAT.   HE WOULD LIKE TO TRANSPORT.” SO AT UCLA, THE NURSE THERE SPOKE TO THE PHYSICIAN THERE.   AND THE PHYSICIAN AT UCLA SAID, “NO, WE ARE DONE.   WE ARE GOING TO CALL IT.”   DR. MURRAY SAID, “NO, I DON’T WANT TO.   LET’S GO TO THE HOSPITAL.” SO I EXPLAINED THAT TO THE BASE STATION,     THE BASE STATION ASKED, “IS DR. MURRAY A PHYSICIAN ON SCENE WILLING TO ASSUME COMPLETE CONTROL OF THE CALL?” AND I SAID, “JUST A MOMENT.   YOU CAN TALK TO HIM.” I EXPLAINED TO DR. MURRAY THIS WAS THE BASE STATION, AND HE TALKED TO THEM.

Q         AFTER THAT CONVERSATION, WERE YOU INFORMED THAT THE DEFENDANT, DR. MURRAY, WAS ASSUMING CARE?

A         THAT’S CORRECT

Q         FOLLOWING THAT, WERE ADDITIONAL ROUNDS OF STARTER DRUGS GIVEN?

A         THAT’S CORRECT, IN THE BACK OF THE AMBULANCE.

Q         WAS IT FOLLOWING THAT OR SHORTLY THEREAFTER THAT YOU BEGAN TO PREPARE TO TRANSPORT THE PATIENT?

A         THAT’S CORRECT.

Q         WAS DR. MURRAY INSTRUCTED THAT HE WOULD HAVE TO ACCOMPANY THE PATIENT IN THE AMBULANCE IF HE WAS GOING TO ASSUME CARE?

A         THAT’S CORRECT.   THAT IS PART OF THE PROTOCOL.

Q         WERE YOU INVOLVED THEN IN GETTING THE PATIENT, ON A GURNEY AND TRANSPORTED OUT OF THE HOUSE?

A         YES

Q         CAN YOU DESCRIBE THAT, PLEASE?

A         A FLAT IS A METAL FRAME WITH CANVAS STRETCHER, VINYL. WAS LAID NEXT TO HIM.   WE SLID THE PATIENT ONTO THE FLAT, SECURED HIM, AND MOVED HIM AND AS MUCH EQUIPMENT AS WE COULD DOWN THE STAIRS TO THE GURNEY, THEN SECURED HIM ONTO THE GURNEY.

Q         ONCE THE PATIENT, WAS PLACED INTO THE AMBULANCE, DID YOU HAVE REASON TO RUN BACK UP THE STAIRS TO WHERE YOU HAD BEEN TREATING THE PATIENT AS SHOWN IN PEOPLE’S 11?

A         AS SOON AS WE GOT HIM DOWN THE STAIRS, I KNEW HE WAS SAFELY ON THE GURNEY, I TURNED AROUND, WENT BACK UP THE STAIRS BECAUSE I DON’T WANT TO LEAVE ANY EQUIPMENT BEHIND, SOMETHING WE NEED ON THE WAY THERE.  

Q         WHEN YOU WENT BACK UP THE STAIRS TO CHECK ON YOUR EQUIPMENT, DID YOU SEE DR. MURRAY UP IN THE ROOM?

A         I DID.

Q         WHAT WAS HE DOING?

A         HE WAS STANDING AGAIN ON THE OTHER SIDE OF THE BED HERE BY THE NIGHTSTAND AND HE HAD A BAG.   I WANT TO SAY WHITE, LIKE A PLASTIC TRASH BAG TYPE THING.   HE WAS STRAIGHTENING UP, PICKING THINGS UP.

Q         PICKING THINGS UP?

A         YES

Q         COULD YOU TELL WHAT HE WAS PICKING UP?

A         NO

Q         WHEN YOU WENT BACK IN THE ROOM DID YOU SEE ANY VENTILATORS, ANY HEART MONITORS, OR ANY TYPE OF EQUIPMENT THAT HAD BEEN IN THE RESIDENCE ASIDE FROM LAFD EQUIPMENT?

A         I SAW THE I.V. POLE, THE I.V. STAND, OXYGEN THING, OXYGEN BOTTLE.

Q         A TANK?

A         A TANK.   WE CALL THEM BOTTLES.   AN OXYGEN TANK.   THAT WAS IT.   I DIDN’T SEE ANYTHING ELSE.   THERE WAS A LOT OF DEBRIS.

Q         NOW, DESCRIBE WHERE WERE YOU IN THE R.A. AS YOU TRANSPORTED THE PATIENT   TO UCLA MEDICAL CENTER?

A         I WAS AT THE HEAD OF THE GURNEY.   THE PATIENT’S HEAD WAS BETWEEN MY KNEES WHERE I COULD MONITOR HIS AIRWAY.

Q         YOU ARE IN THE BACK OF THE R.A. VEHICLE?

A         FACING BACKWARDS TOWARDS THE REAR WINDOWS.   MY BACK IS TO THE BACK OF THE DRIVER.   WE ARE BACK-TO-BACK, AND I’M JUST FACING BACKWARDS.

Q         WHO ELSE WAS IN THERE WITH YOU?

 A         THE OTHER TWO PARAMEDICS, MARK GOODWIN AND MARTIN BLOUNT. DR. MURRAY

Q         DESCRIBE THE SCENE AS YOU TRANSPORT THE PATIENT TO UCLA.   WERE YOU BEING FOLLOWED BY VEHICLES?

A         IT WAS UNBELIEVABLE, TO SAY THE LEAST.   , THERE WAS A TOUR BUS OUT FRONT.     THERE WAS SECURITY PEOPLE. . WE WENT UPSTAIRS AND CAME BACK OUT.   IT WAS LIKE THE ROSE PARADE.   SO MANY PEOPLE THERE.     WHEN WE WERE DRIVING,   THERE IS PEOPLE RUNNING DOWN THE STREET TAKING PICTURES, THEN AS WE WENT DOWN THE STREET, THERE WERE LOTS OF OTHER RANDOM CARS PASSING US ON THE RIGHT, PASSING US ON THE LEFT, TRYING TO DRIVE NEXT TO US.   IT WAS JUST INSANE.

Q           ABOUT THE TELETYPE WE MENTIONED EARLIER THAT IS PEOPLE’S 18.   AGAIN, THIS IS KIND OF A COMPUTER GENERATED PRINTOUT ON THAT FORM?

A         YES

Q         THERE IS ALSO HANDWRITTEN NOTES ON THAT FORM. WHO WROTE THOSE NOTES?

A         I WROTE THOSE NOTES.

Q         AND AMONG OTHER HANDWRITTEN NOTES IS THE TIME OF 12:57 HANDWRITTEN ON THAT FORM?

A         YES

Q         DOES THAT REFRESH YOUR RECOLLECTION AS TO THE TIME UCLA WAS ADVISING TO CALL IT?

A         YES, THAT WILL BE CORRECT.   THAT’S WHY I WOULD WRITE THAT.

Q         AND DOES THIS FORM ALSO INDICATE IN SUMMARY FASHION WHAT DR. MURRAY TOLD YOU IN REGARD TO ANY MEDICATIONS HE HAD GIVEN THE PATIENT?

A         YES.   WHEN I GO INTO A CALL, I HAVE THIS IN MY HAND BECAUSE THIS HAS ALL THE PERTINENT INFORMATION, ADDRESSES OR APARTMENT NUMBERS, OR PHONE NUMBERS.   AND SO WHEN I WALK IN, I HAVE THIS IN MY HAND.   SO IT IS A NATURAL PIECE OF SCRATCH PAPER.   THEN I USE THIS WHEN I FILL OUT 902 LATER.   I USE INFORMATION THAT IS ON THIS TO FILL OUT THE 902.   SO YES.

Q        DOES IT REFLECT IN YOUR OWN HANDWRITTEN PEN THE MEDICATIONS THAT DR. MURRAY TOLD YOU AT THE TIME?

A         YES, IT DOES.

Q         YOU WROTE THIS RIGHT AT THAT MOMENT AT THE RESIDENCE?

A         AT THE MOMENT WHILE I’M SPEAKING TO HIM THE FIRST COUPLE MINUTES WHEN I’M IN THE ROOM.

Q         SHOWING YOU — YOU HAVE A COPY OF PEOPLE’S 18 IN FRONT OF YOU.   IF WE CAN USE THE LASER POINTER TO SHOW ON YOUR TELETYPE WHERE IT INDICATES LORAZEPAM AS BEING THE ONLY NARCOTIC THAT DR. MURRAY INFORMED YOU ABOUT.

A         THAT WOULD BE RIGHT HERE (INDICATING).

Q         THE LETTERS ABOVE THAT, HYD HYPHEN?

A         I WAS IN A HURRY.   THAT IS HYDRATION.   HE WAS TREATING THE PATIENT FOR DEHYDRATION.   HE WAS HYDRATING HIM.

Q         THAT IS WHAT HE TOLD YOU?

A         THAT’S WHAT HE TOLD ME.

Q        AND HE TOLD YOU HE GAVE HIM LORAZEPAM, AND THAT IS WHAT YOU NOTED THERE?

A         YES, SIR.

Q         AND THE TOP RIGHT SIDE THERE, EPI.   IS THAT EPINEPHRINE?

A         YES.

Q         ON THE RIGHT SIDE OF PEOPLE’S 18?

A         YES, RIGHT HERE.

Q         ATRO FOR ATROPINE?

A        YES.

Q         AND WHAT IS THAT?   SODIUM BICARBONATE?   IS THAT THE THIRD THING?

A         YES.

Q         WHAT IS SODIUM BICARBONATE?

A         IT IS AN ALKALINE LIKE BAKING SODA.   WHEN YOUR BODY CELLS AREN’T BREATHING, THEY GO INTO WHAT IS CALLED ANABOLIC RESPIRATION.   THEY PRODUCE LACTIC ACID AS A RESULT.   THE LONGER YOU ARE NOT BREATHING, THE HIGHER THE ACID LEVEL BUILDS UP IN YOUR BLOODSTREAM.   AS THAT HAPPENS, IT BECOMES INCOMPATIBLE WITH LIFE.   THE HEART DOESN’T RESPOND AS WELL.   THE OPPOSITE OF ACID IS BASE. THAT IS WHAT BICARBONATE IS.   IT BRINGS ACIDS INTO NORMAL RANGE.

Q         DOES THIS FORM, YOUR TELETYPE WITH YOUR HANDWRITTEN NOTES, DOES THIS ADDITIONALLY REFLECT WHAT TIME YOU INITIALLY ARRIVED ON SCENE?

A         YES, IT DOES.3.

Q         WHAT TIME WAS THAT?

A        12:25.

Q         WHEN YOU SAID 12:26, IS THAT WHEN YOU ARE ACTUALLY AT THE PATIENT UPSTAIRS?

A         THAT’S CORRECT.

Q         AND DOES THIS ALSO REFLECT THE TIME YOU TRANSPORTED OUT OF THE LOCATION?

A         YES, IT DOES.

Q         WHAT TIME IS THAT?

A         13:07.

Q        THEN THE REFERENCE OF 13:13 HSP, WHAT IS THAT REFERENCING?

A         THAT WAS ARRIVAL TIME AT THE HOSPITAL.

Q         NOW, FROM THE POINT OF YOUR BEING ON THE PATIENT AT 12:26 TO THROUGHOUT THE TREATMENT AND YOUR ARRIVAL AT THE HOSPITAL AT 13:13, WHICH WOULD BE 1:13 P.M., DID THE PATIENT’S CONDITION EVER CHANGE FROM BEING FLAT-LINED, ASYSTOLIC?

A         NO, SIR.

Q         DURING THAT SAME PERIOD OF TIME, DID YOU EVER OR ANY YOUR EMERGENCY TEAM DETECT A PULSE IN THE PATIENT?

A         NO, SIR.

Q         WERE ANY OF YOUR ATTEMPTS THROUGH THE VARIOUS MEANS YOU DESCRIBED EVER SUCCESSFUL IN REVIVING THE PATIENT?

A         NO, SIR.

Q         WHAT DID YOU DO WHEN YOU FIRST ARRIVED AT UCLA THEN?

A         I WAS AT THE HEAD OF THE PATIENT.   WE BACKED UP TO THE DOOR.   OBVIOUSLY, THERE WAS A WHOLE LOT OF PEOPLE THAT SHOWED UP AT THE HOSPITAL.   HOSPITAL SECURITY HADN’T DEPLOYED YET, SO THE PRIVATE SECURITY DID.   THEY CREATED A CORRIDOR. DR. MURRAY ASKED IF WE COULD PUT A TOWEL OR SOMETHING OVER MICHAEL’S FACE.   SURE, SO WE DID.   WE OPENED THE BACK DOORS AND WE ROLLED HIM THROUGH THE SECURITY CORRIDOR RIGHT INTO THE BACK DOORS OF THE HOSPITAL AND INTO THE EMERGENCY ROOM.

Q         DID YOU ADVISE ONE OF THE EMERGENCY ROOM DOCTORS OF THE TREATMENT YOU HAD GIVEN AS A PARAMEDIC ON SCENE?

A         I STARTED JUST NORMAL ROUTINE.   HOW MANY EPI’S, HOW MANY ATROPINES, BICARBS, WHEN THE LAST BICARB WAS, THE LAST THINGS I STARTED.

Q         DID YOU OBSERVE ONE OF THE UCLA DOCTORS TALK DIRECTLY TO DR. MURRAY?

A         THAT’S CORRECT, I DID.

Q         WHILE YOU WERE EN ROUTE FROM CAROLWOOD TO THE UCLA HOSPITAL, DID YOU EVER SEE DR. MURRAY WHILE IN THE BACK OF THE RIG SPEAKING ON A CELL PHONE?

A         I DID.

Q         YOU DON’T KNOW TO WHOM HE WAS SPEAKING, DO YOU?

A         NO.

Q         NOW, DO YOU RECALL DESCRIBING DR. MURRAY’S CONDITION WHEN YOU ARRIVED AND THROUGHOUT THIS TREATMENT AS, QUOTE, SPINNING

A         I PROBABLY COULD HAVE USED A BETTER WORD, BUT IT IS A SLANG TERM WE USE.   HE WAS SPINNING.

Q         WHAT DOES THAT MEAN?

A         HYPERKINETIC, MOVING AROUND, VERY NERVOUS, VERY BUSY.   HE WAS SWEATING.   HE WAS PALE.   MULTI-TASKING AT A HIGH RATE OF SPEED.

Q         AND LASTLY, AT ANY TIME THEN FROM YOUR FIRST CONTACT WITH DR. MURRAY TO YOUR DEPARTURE FROM UCLA, DID DR. MURRAY EVER ADVISE YOU OR ANYONE IN YOUR PRESENCE, ADVISE YOUR TEAM, THAT HE HAD ADMINISTERED PROPOFOL TO MICHAEL JACKSON?

A         NO, SIR.

MR. WALGREN:   THANK YOU.   NOTHING FURTHER,

 

CROSS-EXAMINATION

MR. LOW:

Q         GOOD AFTERNOON, SIR.

A         GOOD AFTERNOON.

Q         PARAMEDIC FOR 27 YEARS, 25 OF WHICH IS WITH LAPD?

A        LAFD.   YES, SIR.

Q         OKAY.   NOW, I HEARD YOU SAY EARLIER THAT AS A PARAMEDIC, YOU DON’T HAVE, IF YOU WILL, ALL THE DISCRETION OVER ALL THE THINGS THAT MAYBE A DOCTOR CAN DO.   YOU SAID SOME WORDS TO THAT EFFECT?

A         THAT’S CORRECT.   I’M NO DOCTOR.

Q         BUT TO GIVE YOURSELF SOME CREDIT I THINK YOU DESERVE, YOU WORK IN A MUCH DIFFERENT ENVIRONMENT THAN THE DOCTORS DO; IS THIS TRUE?

A         THAT IS VERY TRUE.

Q         FOR YOU, YOU HAVE TO GO OUT IN THE FIELD, RIGHT?

A         THAT’S TRUE.

Q         I MEAN, IF YOU THINK ABOUT IT, YOU HAVE TO GO OUT INTO AN ENVIRONMENT THAT IS COMPLETELY UNEXPECTED TO YOU IN A LOT OF WAYS?

A         THAT’S TRUE.

Q         YOU HAVE TO DEAL WITH PEOPLE YOU DON’T KNOW?

A         YES, SIR.

Q         YOU HAVE TO WORK AROUND OFTEN VERY CHAOTIC SITUATIONS AND PEOPLE WHO ARE COMPLETELY UNPREDICTABLE?

A         YES, SIR.

Q         NOT ONLY DO YOU HAVE TO WORK WITH YOUR TEAM TO TRY AND ADMINISTER AND SAVE THE LIFE OF SOMEONE UNDER STRESS, YOU ALSO HAVE TO BE MINDFUL OF EVERYTHING GOING ON AROUND YOU?

A         YES, SIR.

Q         IN FAIRNESS TO YOU, A DOCTOR IN A HOSPITAL, HE WORKS WITH THE SAME TEAM THAT HAS BEEN TRAINED WITH HIM OVER AND OVER AND OVER?

A         YES, SIR.

Q         AND THAT TEAM BRINGS YOU SECURITY AND CERTAINTY BECAUSE YOU GET A PRETTY GOOD IDEA HOW PEOPLE WILL BEHAVE AND HOW THEY WILL ACT?

A         YES, SIR.

Q         WHAT IS EVEN BETTER, IT IS A CONTROLLED ENVIRONMENT.   YOU HAVE SEEN THEM.   THEY HAVE THE BIG LIGHTS AND ALL THE MACHINES THEY HAVE TRAINED ON?

A         YES, SIR.

Q         AND THEY HAVE A LOT OF SECURITY AROUND?

A         YES, SIR.

Q         YOU DON’T GET ANY OF THAT, DO YOU?

A         SOME OF IT.   THE TEAM THAT I’M WORKING WITH, ENGINE COMPANY 71, WE TRAIN.   WE PRACTICE.   WE HAVE WORKED TOGETHER FOR YEARS.   MARTIN BLOUNT, I RECRUITED HIM TO COME TO 71 BECAUSE I THOUGHT SO HIGHLY OF HIM.   SO WE DO HAVE THAT.   BUT YOU ARE RIGHT.   THE REST OF IT IS SPOT ON.

Q         AND, IN FACT, BECAUSE OF YOUR EXPERIENCE AND HOW WELL YOU HAVE DONE FOR THE YEARS, THEY HAVE YOU NOW TRAINING NOT ONLY SOMETIMES NEW PEOPLE BUT PRIMARILY YOU ARE UPDATING AND CONTINUING TO TRAIN SEASONED PARAMEDICS BECAUSE YOU ARE SO GOOD AT IT?

A         YES, SIR.

Q         NOW, IF I UNDERSTAND EXACTLY WHAT YOUR CALLTO DUTY IS, IF WE CAN SAY IT THAT WAY, IS TO GO OUT AND SEE IF YOU CANNOT FIND SOME WAY TO BRING LIFE BACK TO SOMEBODY?

A         YES, SIR.

Q         SOMETIMES YOU APPEAR ON AN ACCIDENT SCENE. THEY HAVE GOT CUTS AND BRUISES.   YOU PATCH THOSE UP, RIGHT?

A         RIGHT.

Q         BUT ULTIMATELY, YOUR PRIMARY GOAL AS A PARAMEDIC IS TO FIND SOMEBODY WHO IS IN DISTRESS, WHO IS SUFFERING, WHO IS HURT, AND STABILIZE THEM?

A         YES, SIR.

Q         STABILIZE THEM, MEANING MAKE SURE THEY HAVE ENOUGH FLUIDS, IF YOU WILL, AND OXYGEN SO THEIR BODY DOESN’T SLIP INTO SHOCK?

A         YES, SIR.

Q         IF IT SLIPS INTO SHOCK, THEN BAD THINGS CAN HAPPEN?

A         YES, SIR.

Q         IF BAD THINGS HAPPEN, THEN THEIR ORGANS MAY STOP WORKING?

A         YES, SIR.

Q         IF ORGANS STOP WORKING, THEY MAY STOP BREATHING?

A         YES, SIR.

Q         IF THEY STOP BREATHING, THE HEART MAY STOP?

A         YES, SIR.

Q        AND I WOULD EXPECT OVER THE 28-PLUS YEARS OR 28 SOME ODD YEARS, YOU HAVE HAD PLENTY OF OCCASIONS WHERE WHEN YOU GOT TO THE SCENE, IN FACT, THE PERSON WASN’T BREATHING?

A         YES, SIR.

Q         AND THROUGH YOUR SKILL AND TRAINING AND EXPERTISE, YOU WERE ABLE TO GET HIM TO START BREATHING AGAIN?

A         YES, I HAVE.

Q         SOMETIMES YOU CAN COME ON THE SCENE AND FIND OUT THEIR HEART IS NOT BEATING PROPERLY?

A         YES.

Q         AND THROUGH YOUR TRAINING AND EXPERIENCE ANDSKILL, YOU ARE ABLE TO GET THE HEART TO START WORKING AGAIN?

A         YES.

Q         IN FACT, A LOT OF TIMES WHEN YOU COME OUT AND FIND SOMEONE WHOSE HEART IS NOT BEATING PROPERLY OR STOPPED, TECHNICALLY YOU CAN SAY THEY ARE DEAD?

A         YES.

Q         AND, IN FACT, THAT IS KIND OF WHAT WE ARE DEALING WITH IN THIS SITUATION.   YOU COME TO THE SCENE, FIND OUT AT SOME POINT THAT THE PERSON YOU LATER FIND IS MICHAEL JACKSON, HIS HEART IS NOT WORKING PROPERLY.   IT STOPPED?

A         YES, SIR.

Q         YOU SAID EARLIER ON DIRECT, THAT IS WHY YOU SAID THEY WERE DEAD.   OTHER PEOPLE, WHEN YOU COME OUT AND FIND THE HEART NOT WORKING, YOU CAN CALL AND SAY THEY ARE DEAD?

A         YES, SIR.

Q         BUT YOU DON’T GIVE UP THERE, DO YOU?

A         NO.

Q         THAT IS YOUR WHOLE CALL AND WHOLE PASSION, IF YOU WILL, TO HELP PEOPLE —

A         YES, SIR.

Q         AND BRING LIFE BACK WHERE IT APPEARS TO BE GONE?

A         YES, SIR.

Q         WHAT DO YOU DO WHEN YOU FIRST GET TO THE SCENE IN ORDER TO TRY TO DO THIS?   YOU LOOK.   FIRST OF ALL, YOU HAVE TO FIGURE OUT WHAT IS CAUSING THE DISTRESS?

A         YES, SIR.   THAT’S IMPORTANT, BUT THERE ARE TIMES WHEN IT IS LESS IMPORTANT.   IF THEY ARE NOT BREATHING, FIRST THING YOU ARE GOING TO DO IS BREATHE FOR THEM.   IF THEY LOOK LIKE THEY ARE ABOUT TO STOP BREATHING, THEN, YEAH, YOU CAN STOP THE PROBLEM BEFORE IT STOPS THEM FROM BREATHING.

Q         YES, SIR.   THANK YOU, AND I WILL BE EVEN A LITTLE MORE GENERAL. YOU HAVE TO FIGURE OUT DO THEY HAVE A HEAD INJURY.   ARE THEY CUT AND BLEEDING SOMEWHERE.   MAYBE THEY ARE UNDER THE INFLUENCE OF A DRUG THAT MAKES THEM ACT ODD.   YOU TRY TO FILTER THAT OUT TO FIND THE SOURCE?

A         YES, SIR.

Q         AND THEN ONCE YOU FIGURE THAT OUT, YOU CAN ASSESS AS TO WHAT YOU MAY HAVE TO DO IN ORDER TO GET THEM SUSTAINED, GET THEM STABILIZED?

A         YES, SIR.

Q         ONCE YOU UNDERSTAND THAT, THEN YOU KNOW WHAT TECHNIQUES AND PROTOCOLS YOU HAVE BEEN TAUGHT TO USE IN ORDER TO DO THAT?

A         YES, SIR.

Q         BECAUSE THE HOSPITAL AND THE DOCTORS AND THE TRAINING HAVE GIVEN YOU, IF YOU WILL, PROTOCOLS AS TO WHAT YOU ARE TO DO AND HOW YOU ARE TO DO IT DEPENDING ON THE SITUATION?

A         IT IS A TEAM EFFORT.

Q         YES, SIR.   BUT SOMETIMES DOCTORS HAVE THE EITHER ABILITY OR THE PERMISSION TO SOMETIMES GO OUTSIDE OF CERTAIN PROTOCOLS.   THEY ARE GIVEN THAT GIFT; IS THAT RIGHT?

A         YES, SIR, GUIDELINES.

Q         BUT FOR THE MOST PART, THEY DON’T NECESSARILY ALLOW YOU TO DO THAT SOMETIMES?

A         WE HAVE GUIDELINES THAT WE FOLLOW THAT WE ARE ALLOWED TO INTERPRET, BUT WITHIN NARROW PARAMETERS.

Q         DURING SOME OF THE TIMES YOU HAVE HAD TO RESPOND AS A PARAMEDIC, YOU HAVE COME OUT AND SEEN SOME PEOPLE.   WHEN YOU FIRST LOOK AT THEM, THEY LOOK PRETTY HEALTHY?

A         YES, SIR.

Q         AS YOU COME TO FIND OUT, THEY HAVE MAYBE A CUT ON THE HEAD, OR BRAIN INJURY TO SOME DEGREE, THINGS LIKE THIS, CORRECT?

A         YES, SIR.

Q         OTHER PEOPLE YOU COME OUT TO SEE, THEY LOOK QUITE SICKLY WHEN YOU GET THERE?

A         YES, SIR.

Q         IN FACT, YOU CAN TELL THAT THEY ARE PROBABLY, WELL, IN A HOSPICE?

A         YES, SIR.

Q         IN OTHER WORDS, IT IS A PLACE WHERE THEY HAVE KIND OF GONE TO DIE?

A         YES, SIR.

Q         BECAUSE THEY HAVE GOT SOME TYPE OF ILLNESS?

A         THE END IS NEAR.

Q         OFTENTIMES, THEY DIE AT HOME.   OFTENTIMES, YOU GO TO A HOME AND THEY ARE MAYBE SPENDING THE LAST DAYS THERE TO DIE?

A         YES.

Q         AND THE WAY THAT SOMETIMES YOU ARE ABLE TO TELL IS ON THE WAY THEY PHYSICALLY LOOK TO YOU?

A         YES, SIR.

Q         I MEAN, YOU LOOK AT THEM AND THEY ARE UNDER-NOURISHED?

A         YES, SIR.

Q         THEY ARE VERY THIN?

A         YES, SIR.

Q         THEIR EYES ARE SHRUNKEN?

A         YES, SIR.

Q         SOMETIMES MISSING HAIR?

A         YES, SIR.

Q         THEY LOOK LIKE, I THINK YOU EVEN SAID, AS A CANCER PATIENT?

A         HOSPICE PATIENT INCLUDES CANCER, OR H.I.V., A.I.D.S., ANY NUMBER OF THINGS.

Q         AND ONE OF THE REASONS IT IS IMPORTANT FOR YOU TO UNDERSTAND THIS AND BE THAT OBSERVANT IS BECAUSE ONE OF THE QUESTIONS YOU HAVE TO ASK WHEN YOU START OUT IS, DOES THIS PERSON HAVE A DO NOT RESUSCITATE ORDER?

A         YES, SIR.

Q         I’M SORRY.   I CUT YOU OFF.

A         YES, SIR.

Q         THAT IS IMPORTANT FOR YOU TO UNDERSTAND OR TO KNOW BECAUSE THAT MEANS THIS PERSON DOESN’T WANT TO BE HELPED.   THEY WANT TO JUST BE ALLOWED TO DIE NATURALLY?

A         YES, SIR.

Q         BECAUSE YOU CARE ABOUT A PERSON, A PATIENT, AND THEIR RIGHTS AND PRIVACY, THAT IS IMPORTANT FOR YOU TO TRY TO ASCERTAIN SO YOU DO THE RIGHT THING BY THEM?

A         YES, SIR.

Q         THAT IS WHAT A GOOD DOCTOR AND GOOD HEALTH CARE ATTENDANT WOULD DO, JUST LIKE YOU DID?

A         YES, SIR.

Q         IN FACT, YOU DID THAT IN THIS CASE, DIDN’T YOU?

A        YES, SIR.

Q         YOU ASKED THOSE QUESTIONS JUST LIKE YOU ARE SUPPOSED TO?

A         YES, SIR.

Q         YOU FOUND OUT THAT, IN FACT, THERE WAS NOT A DO NOT RESUSCITATE ORDER.   THAT MAY BE A DOUBLE NEGATIVE. IN OTHER WORDS, WHEN YOU ASKED THE QUESTION, WHAT WERE YOU TOLD?

A         I ASKED IF THERE WAS AN ADVANCE LIFE DIRECTIVE.   ADVANCE LIFE DIRECTIVE CAN MEAN DO NOT RESUSCITATE, BUT IT CAN ALSO MEAN OTHER LEVELS.   IT IS OKAY TO HYDRATE THEM, OKAY TO GIVE THEM OXYGEN, BUT DON’T DO COMPRESSIONS.   DON’T DO ANYTHING.   BUT I DID ASK THAT, YES, AND I WAS TOLD, “NO, THERE IS NOT.”

Q         AGAIN, YOU HAVE ALSO HAD TO SOMETIMES GO OUT TO HOMES.   AND YOU FIND WHEN YOU GET THERE THAT THE PERSON IS HAVING A BAD EXPERIENCE WHICH YOU LATER FIND OUT MAY HAVE RELATED TO DRUGS?

A        YES.

Q         SOMETIMES CAN BE STREET DRUGS THAT THEY ARE HAVING A BAD REACTION TO?

A         YES, SIR.

Q         SOMETIMES THEY CAN BE PRESCRIPTION DRUGS IF THEY ARE HAVING A BAD REACTION?

A         YES, SIR.

Q         AND AT TIMES THEY CAN JUST BE SOMETHING YOU GET, LIKE ALCOHOL, VARIETY OF DIFFERENT THINGS?

A         YES, SIR.

Q         IN FACT, YOU HAVE SEEN PEOPLE, EVEN MAYBE SOME PEOPLE WHO NORMALLY YOU FIND ON THE STREET WHO ARE QUITE SICKLY AND QUITE UNHEALTHY AS A RESULT OF CHRONIC DRUG USE?

A         YES, SIR.

Q         AND THAT IS SOMETHING AGAIN YOU WANT TO KNOW IT HELPS YOU UNDERSTAND WHAT YOU ARE DEALING WITH?

A         YES, SIR.

Q         NOW, SIR, WHEN YOU GOT OUT HERE ON THIS — I’LL BE SPECIFIC.   WHEN YOU GET OUT TO THE HOUSE AT 100 CAROLWOOD DRIVE, DO YOU RECALL WHO THE VERY FIRST PERSON WAS THAT YOU SAW THERE AT THE RESIDENCE?

A         SECURITY PERSON.

Q         DO YOU RECALL IF THEY GAVE YOU A NAME?

A         NO.   NO, THEY DIDN’T.

Q         FAIR ENOUGH.   OUT OF FAIRNESS TO YOU, THIS IS A YEAR AND A HALF AGO.

A         IT IS NOT THAT I DON’T RECALL.   IT IS THE PERSON DID NOT GIVE ME A NAME.

Q         FAIR ENOUGH.   OKAY.   DO YOU RECALL WHAT THEY MAY HAVE LOOKED LIKE?

A         I’D SAY AFRICAN-AMERICAN, FIVE-NINE-ISH, FIVE-TEN, MEDIUM BUILD, DARK SUIT, WHITE SHIRT.

Q         WONDERFUL.   AND DO YOU RECALL WHAT IT WAS OR WAS THERE ANY CONVERSATION OR EXCHANGE BETWEEN THE TWO OF YOU WHEN YOU FIRST GET THERE

A         YES, SIR.

Q         DO YOU RECALL WHAT IT WAS?

A         YES, SIR.

Q         PLEASE TELL US.

A         WE PULLED UP.   WE STOPPED IN THE DRIVEWAY.   I OPENED THE DOOR, AND HE SAID TO ME, “SOMEBODY SHOULD DO CPR.”

Q         DID YOU RESPOND?

A         AND AS I WAS EXITING, GOING TO GRAB MY EQUIPMENT, I SAID, “SOMEBODY SHOULD START.”

Q         DID HE SAY ANYTHING IN RESPONSE TO THAT?

A         I DID NOT HEAR WHAT HE SAID.  I WAS GRABBING MY EQUIPMENT AND HEADED INTO THE HOUSE.

Q         AND WHEN YOU SAID THAT TO HIM, “SOMEBODY SHOULD START,” DID YOU MEAN TO SAY THAT YOU WERE KIND OF TELLING HIM, “BOY, YOU CAN GO START IT AS WELL”?

A         WHAT I MEANT WAS THAT I ACKNOWLEDGED CPR IS IMPORTANT, ABSOLUTELY.   SOMEBODY SHOULD BE DOING IT.   I CAN’T DO IT RIGHT AT THIS MOMENT BECAUSE I HAVE OTHER THINGS I’M DOING.

Q         WHEN YOU SAY CPR IS IMPORTANT AND SOMEBODY DO IT, IT IS BECAUSE THAT TECHNIQUE IS DESIGNED TO MOVE AIR IN AND OUT OF THE LUNGS, CORRECT?

A         YES.

Q         AND IF AIR IS MOVING IN AND OUT OF THE LUNGS, IT IS THEN ABLE TO EXCHANGE WITH THE BLOOD VESSELS AROUND THE LUNGS?

A         YES.

Q         IF IT IS ABLE TO EXCHANGE WITH THE BLOOD VESSELS, THAT MEANS THAT THE CO2 BAD AIR COMES OFF CELLS AND GOOD AIR GOES BACK ON?

A         YES, SIR.

Q         IF THAT HAPPENS, THOSE CELLS CAN CARRY IT TO THE REST OF THE BODY AND FUEL IT WITH AIR?

A         YES, SIR.

Q         ALSO CPR IS DESIGNED TO COMPRESS THE HEART; IS THIS CORRECT?

A         YES, SIR.

Q         IF YOU DO THAT, THAT MEANS YOU CAN MOVE THE BLOOD?

A         YES, SIR.

Q         IF YOU CAN MOVE THE BLOOD, THEN YOU CAN TAKE THOSE FRESH OXYGENATED BLOOD CELLS AND MOVE THEM TO DIFFERENT PARTS OF THE BODY

A         YES, SIR.

Q         IF THIS IS GOING ON AND THIS IS HAPPENING, NOW YOU HAVE A BETTER CHANCE OF BEING ABLE TO RESTORE THAT LIFE?

A         YES, SIR.

Q         SO AT SOME POINT DO YOU GO UPSTAIRS TO FIND WHERE THE PROBLEM IS AND FIND THE PERSON WHO NEEDS THE HELP?

A         YES, SIR.   OF COURSE.

Q         AND YOU ARE LED UP THERE BY ONE OF THE SECURITY PEOPLE?

A         YES, SIR.

Q         WHEN YOU GET THERE, YOU LOOK IN THE BEDROOM?

A         YES, SIR.

Q         YOU CAN SEE HIM BEFORE YOU?

A         YES, SIR.

Q         ONE OF THE THINGS YOU SEE IS WHAT APPEARS TO BE THE PERSON WHO MAY BE IN STRESS LAYING ON A BED?

A         YES, SIR.

Q         THE WAY THEY ARE LAYING, IT APPEARS TO BE ON THEIR BACK AND FACE UP?

A         YES, SIR.

Q         OKAY.   AND THERE IS SOMEBODY STANDING OVER THE PERSON LAYING ON THE BED?

A         YES, SIR.

Q         THAT PERSON IS FROM YOUR RECOLLECTION AN AFRICAN-AMERICAN GENTLEMAN?

A         YES, SIR.

Q         FAIRLY TALL PERSON?

A         YES, SIR.

Q         AND IT APPEARS THAT PERSON IS PERFORMING CPR ON THEM?

A         THE CPR TO ME WOULD BE MEANING PRESSING ON THE CHEST, PUSHING DOWN, BLOW INTO THE MOUTH.   THAT IS NOT WHAT I SAW.   WHAT I SAW —

Q         TELL US WHAT YOU SAW.

A         WHAT I SAW WAS THE GOOD DOCTOR TAKING HIS SHOULDERS AND LOOKED LIKE HE WAS APPEARING TO SLIDE HIM OFF THE EDGE OF THE BED TO THE FLOOR.

Q       ARE YOU AWARE, SIR, AT THIS MOMENT IN TIME WHEN YOU ARE LOOKING IN THE BEDROOM SEEING THIS, ARE YOU  AWARE ONE WAY OR THE OTHER IF ANYONE IN THAT ROOM HAD PERFORMED ANY CPR UP TO THAT POINT?

A         NO, I’M NOT.

Q         DID YOU ASK ABOUT THAT?

A         NO.

Q         WHEN THE PERSON COMES DOWN ON FLOOR, WHAT DO YOU SEE NEXT?

A         MEANING?

Q         YOU ARE LOOKING IN THE ROOM.   YOU SAID YOU SAW THE GENTLEMAN TRYING TO SLIDE THE PERSON OFF THE BED ONTO THE FLOOR.   WHAT DO YOU SEE NEXT?

THE DOCTOR MOVING AWAY AND MY FIREFIGHTER COMING IN TO MOVE MICHAEL FROM THE FLOOR.   TO PICK HIM UP BEHIND HIS SHOULDERS WHILE I GRABBED BEHIND HIS KNEECAPS AND MOVE HIM AROUND.

Q         CAN I FREEZE YOU THERE IN THAT MOMENT IN TIME.   HIT THE PAUSE BUTTON. FROM LOOKING AT THAT PICTURE THERE IN THAT MOMENT WHEN YOU HAVE NOW MOVED THE PERSON FROM THE BED DOWN TO THE FLOOR, DO YOU SEE ANY MEDICAL LOOKING EQUIPMENT IN THE SCENE?

MR. WALGREN:   OBJECTION.   MISSTATES THE TESTIMONY.

THE COURT:   OVERRULED.   YOU MAY ANSWER.

MR. LOW:   I’M ASKING IF HE SAW ANY MEDICAL EQUIPMENT.   THAT IS ALL I ASKED.

THE COURT:   DO YOU UNDERSTAND IT?

THE WITNESS:   NO, SIR.   I’M CONFUSED.

THE COURT:   SUSTAINED.   REASK.

MR. LOW:   YES, SIR.

Q                 WE ARE LOOKING AT THE SCENE.   WE HAVE JUST SEEN, LIKE YOU SAID, THE GOOD DOCTOR —

A         YES, SIR.

Q         MOVING THE PERSON DOWN ON THE FLOOR?

A         YES.

Q         AS YOU ARE LOOKING AT THAT SCENE, WERE YOU   ABLE TO SEE IF THERE IS ANY MEDICAL LOOKING EQUIPMENT ANYWHERE AROUND?

A         THE I.V. POLE WITH THE SALINE BAG.

Q         AGAIN, STOP AND LET ME ASK YOU ABOUT THAT.

 A         SURE.

Q         WHERE, IN RELATION TO THE PERSON IN THE ROOM, IS WHERE THAT I.V. BAG IS?

A         IT IS ADJACENT TO THE BED, APPROXIMATELY WHERE THE PATIENT’S KNEES ARE.

Q         ARE YOU ABLE TO APPROXIMATE DISTANCE INSIDE   THE BEDROOM OR FROM THE PATIENT?

A         WITHIN A FOOT.

Q         ALL RIGHT.   SO IT IS TRUE THAT THE PATIENT GETS LOWERED TO THE FLOOR, CORRECT?

A         YES, SIR.

Q         THERE IS AT LEAST THREE PEOPLE TRYING TO DO THAT?

A         YES.

Q         OFF OF THE BED?

A         I WAS FOCUSED ON THE DOCTOR.

Q         WHICH MEANS YOU DON’T KNOW OR —

A         IT MEANS I DON’T KNOW.

Q         I THOUGHT I HEARD YOU SAY SOMEONE FROM YOUR TEAM WENT OVER?

A         AFTER HE WAS ONTO THE FLOOR, THEN SOMEONE FROM MY TEAM.

Q         I’M SORRY.   ALL RIGHT.   THEN IS IT TRUE THAT ONCE HE IS ON THE FLOOR, HE IS ALONG THE SIDE OF THE BED. IS THIS TRUE?

A         YES, SIR.

Q         IF I’M STANDING AT THE FOOT OF THE BED LOOKING AT THE HEADBOARD, WOULD HE BE OFF TO THE LEFT?

A         YES.

Q         IS IT FAIR TO SAY THERE WASN’T A LOT OF ROOM THERE.   AS A RESULT, THE INDIVIDUALS MOVED THE PATIENT OUT FROM THE SIDE OF THE BED AND THEN OUT TO WHERE ON THE FLOOR THE FOOT OF THE BED IS?

A         YES, SIR.

Q         THERE IS MORE ROOM TO WORK?

A         YES, SIR.

Q         THERE IS PEOPLE THERE TO WORK?

A         YES, SIR.

Q         YOU AND YOUR TEAM?

A         YES, SIR.

Q         THREE OF YOU?

A         INITIALLY, WE HAVE FOUR ON THE ENGINE.   TWO ON THE RESCUE.   ONE STAYS BEHIND ON THE ENGINE.   SO FIVE OF US.

Q         FIVE OF YOU?

A         YES.

Q         PLUS HOW MANY IN THE ROOM BESIDES THE FIVE OF YOU?

A         SECURITY PEOPLE.   THERE IS THE DOCTOR.   THERE IS WHAT I BELIEVE TO BE A HEAD SECURITY PERSON WITH A PHONE AND SOME OTHER PEOPLE STANDING BACK IN THE DOORWAY.

Q         NOW, YOU HAVE MENTIONED THAT WHILE YOU WERE SEEING THE PATIENT MOVED FROM THE BED ONTO THE FLOOR, YOU REFERRED TO THAT PATIENT AS MICHAEL JACKSON; IS THATCORRECT?

A         YES, SIR.

Q         BUT AT THE TIME THIS IS HAPPENING, IN REAL TIME, YOU HAVE NO IDEA WHO IT IS, DO YOU?

A         NO, SIR.

Q         YOU DO GET A CHANCE OF SEEING HIM PHYSICALLY, THOUGH, CORRECT?

A         YES, SIR.

Q         AND WHEN YOU LOOK AT IT — I’M SORRY.   WHEN YOU LOOK AT THE SCENE AND WHEN YOU SEE THE PERSON, THE PATIENT LYING ON THE BED, YOU ARE ABLE TO NOTICE THE PHYSICAL ATTRIBUTES ABOUT THAT PERSON?

A         YES, SIR.

Q         AND WHAT IS IT YOU NOTICE ABOUT THAT PERSON?

A         I’M AT THE FOOT OF THE BED ON THE OTHER SIDE OF THE ROOM.   WHAT I CAN SEE IS FEET, LEGS, TORSO. REALLY CAN’T SEE THE FACE VERY CLEARLY.   WHAT I SEE IS PAJAMA BOTTOMS ON.   PAJAMA TOP OPEN.   SHOWER CAP. SURGICAL CAP, THAT SORT OF THING, ON THE HEAD.   AND THE PATIENT APPEARED TO BE VERY PALE, AND IT LOOKED — HE

LOOKED VERY UNDERWEIGHT.

Q         WHEN YOU SAY VERY UNDERWEIGHT, WHAT DO YOU MEAN?

A         WELL, SOME PEOPLE SAY THEY NEED TO DROP A FEW POUNDS.   I WOULD SAY HE NEEDED TO GAIN A FEW POUNDS TO BE WHAT I WOULD THINK IS AN AVERAGE HEALTHY PERSON.   MEANING THERE IS A LARGE VARIATION THERE, BUT HE JUST LOOKED VERY THIN TO ME.

Q         ANYTHING ELSE?

A         I DON’T KNOW WHAT YOU MEAN, SIR.

Q         DID YOU NOTICE ANYTHING ELSE OTHER THAN WHAT YOU HAVE ALREADY SAID ABOUT HIM?

A         COLOR OF THE HANDS, COLOR OF THE FEET WERE CYANOTIC, BLUISH.

Q         ANYTHING ELSE, SIR?

A         NOT ESPECIALLY THAT I RECALL.

Q         DID YOU FORM ANY OPINIONS OR CONCLUSIONS AT THAT TIME BASED ON WHAT YOU HAVE JUST SEEN AS TO WHAT THAT MEANS TO YOU?

A         WELL, THE I.V. POLE WAS THERE.   THE DOCTOR IDENTIFIED HIMSELF AS A DOCTOR.   SO MY INITIAL IMPRESSION WAS THIS WAS POSSIBLY A HOSPICE PATIENT.

Q         BECAUSE, IN FACT, WHEN YOU LOOKED DOWN AT THIS PERSON, I THINK YOU HAVE ACTUALLY CHARACTERIZED IT, ONCE BEFORE, AS:     “LYING ON THE BED WHAT I   SAW WAS SOMEONE IN PAJAMAS WITH   LIKE A MEDICAL SCRUB SURGICAL SHOWER CAP TYPE THING ON THEIR HEAD, LOOKING VERY, VERY, VERY UNDERWEIGHT, LIKE — LIKE WHAT YOU SEE WHEN YOU SEE A TERMINAL CANCER PATIENT TOWARDS THE END OR TERMINAL A.I.D.S. PATIENT, OR SOMETHING, SOMETHING TERMINAL.” IS THAT KIND OF WHAT YOU SAID, SIR, BACK ON JULY 1ST, 2009 WHEN YOU WERE ASKED WHAT YOU SAW WHEN YOU LOOKED AT THE GENTLEMAN WHO WAS LAYING ON THE BED?

A         YES, SIR.   THAT IS WHAT I SAID.

Q         THAT PERSON LOOKED REAL SICK TO YOU?

A         YES, SIR.

Q         NOT JUST PALE.   I MEAN REALLY THIN?

A         YES, SIR, AS IN I COULD SEE RIBS.

Q         THAT IS UNUSUAL, ISN’T IT?

A         YES, SIR.   IT IS UNUSUAL IN TOTAL, IN CONTEXT WITH THE FACT THAT THERE IS A DOCTOR THERE.   THERE IS AN I.V. POLE THERE, THESE THINGS.   IT IS NOT ANY ONE.   IT IS NOT THE WHOLE PUZZLE.   JUST A PIECE OF THE PUZZLE.

Q        IT IS ALSO NOT UNUSUAL WHEN YOU FIND SOMEONE WHO HAS BEEN A DRUG ADDICT FOR A LONG TIME EITHER, IS IT?

A         NO, SIR.

Q         AT THAT POINT AFTER LOOKING AT THIS PATIENT AND SEEING ALL OF THIS, YOU WEREN’T EVEN ABLE TO RECOGNIZE WHO IT WAS.   YOU DIDN’T RECOGNIZE ANYTHING ABOUT HIM?

A         NO, SIR.

MR. WALGREN:   ASSUMES FACTS NOT IN EVIDENCE.

THE COURT:   THE OBJECTION IS SUSTAINED.  

MR. LOW:  

Q                 LET ME SEE IF I CAN ASK IT THIS WAY.   AT THAT MOMENT THAT DAY, YOU ARE LOOKING AT THIS PERSON NOTICING EVERYTHING YOU HAVE, WERE YOU ABLE TO RECOGNIZE THAT FACE?   HAD YOU EVER SEEN IT BEFORE?

MR. WALGREN:   ASSUMING FACTS NOT IN EVIDENCE, THAT HE TRIED TO RECOGNIZE THE PATIENT.

THE COURT:   I’M GOING TO OVERRULE THE OBJECTION. ARE YOU TALKING ABOUT AT ANY POINT DURING THE TREATMENT?

MR. LOW:     NO, SIR.  

Q                 AT THAT MOMENT, THAT TIME WHERE WE ARE IN TIME.   YOU HAVE JUST COME IN THE ROOM, STARING AT THE PERSON.   YOU ARE MAKING A PHYSICAL CHECKLIST YOU HAVE JUST MENTIONED.

AT THIS POINT IN TIME WERE YOU ABLE TO RECOGNIZE ONE WAY OR THE OTHER WHO THAT PERSON MAY BE?

A         NO, SIR

Q         NOW, IF I CAN ASK YOU THIS.   BEFORE JUNE 25,2009, HAD YOU EVER SEEN A PICTURE OF MICHAEL JACKSON ANYWHERE?

A         YES, SIR.

Q         MAYBE MORE THAN ONE?

A         YES, SIR.

Q         MAYBE A CONSIDERABLE NUMBER?

A         YES, SIR.

Q         DID THAT PERSON IN THAT MOMENT IN THAT TIME WHERE WE ARE RIGHT NOW LOOK ANYTHING LIKE —

MR. WALGREN:   OBJECTION.   RELEVANCE.

THE COURT:   I’LL SUSTAIN THE OBJECTION.   350, 352.

MR. LOW:   I’LL MOVE ON, SIR.

THE COURT:  

MR. LOW:  

Q                 THE PERSON IS ON THE FLOOR. RIGHT ABOUT THE TIME NOW WHERE AGAIN I JUST WANT TO MAKE SURE BECAUSE I’VE STOPPED YOU FOR A WHILE, I WANT TO RE-ORIENT YOU, THEN MOVE ON. WE MOVE THE PERSON ON THE GROUND.   WE ARE ATTHE FOOT OF THE BED.   NOW, IS IT TRUE SORRY.   IS IT TRUE THE AFRICAN-AMERICAN GENTLEMAN, AT THIS TIME YOU DON’T KNOW WHO HE IS?

A         HE IDENTIFIED HIMSELF AS HIS DOCTOR.

Q         DID HE TELL YOU HIS NAME?

A         NO, SIR.

Q         WOULD IT BE ALL RIGHT IF I CALLED HIM DR. MURRAY NOW AND ASSUME THAT IS THE PERSON YOU SAW HELPING MOVE?

A         YES, SIR.   THAT WOULD BE FINE.

THE COURT:   YOU DON’T HAVE TO ASSUME.   WAS THAT THE INDIVIDUAL YOU SAW?

THE WITNESS:   YES, SIR.

THE COURT:   THANK YOU.

MR. LOW:   THANK YOU, JUDGE.

Q         DID DR. MURRAY TELL YOU THAT HE WANTED SOMETHING DONE AT THAT PARTICULAR POINT IN TIME?

A         YES, HE DID.

Q         WAS THAT THAT HE WANTED SOMEBODY TO INTUBATE THIS PERSON?

A         YES.

Q         THAT MEANS THAT HE ALLOWED YOU TO CONDUCT THE PROCEDURE WHERE ONE OF YOUR TEAM WILL TAKE AN APPARATUS LIKE A PIPE, IF YOU WILL, AND SLIP IT INTO THE PERSON’S MOUTH SO THAT YOU CAN CREATE AN AIRWAY?

A         YES, SIR.

Q         THIS IS ONE OF THE FIRST STEPS THAT YOU CAN USE TO SECURE A BREATHING WAY OR AIRWAY SO THAT YOU CAN START GETTING MORE EFFECTIVE CPR AND ULTIMATELY AIR INTO THE LUNGS?

A         YES, SIR.

Q         SOMETIMES WITH CPR, THE TONGUE GETS BLOCKED. YOU HAVE TO TILT THE HEAD?

A         YES, SIR.

Q         OR THERE COULD BE A BLOCKAGE BECAUSE HE SWALLOWED SOMETHING, AND YOU DON’T KNOW?

A         YES, SIR.

Q         IN FACT, SOMEONE FROM YOUR TEAM DID THAT?

A         YES, SIR.

Q         DO YOU RECALL THAT PERSON’S NAME?

A         YES, SIR.   FIREFIGHTER PARAMEDIC MARTIN BLOUNT.

Q         THANK YOU, SIR. OUT OF FAIRNESS TO YOU, YOU WERE AMAZED OR IMPRESSED WITH HOW QUICKLY HE WAS ABLE TO DO THAT?

A         YES, SIR.   I WAS.

Q         HE IS VERY GOOD AT WHAT HE DOES?

A         YES, SIR.

Q         IT IS IN.   NOW WE HAVE AN UNOBSTRUCTED AIRWAY?

A         YES, SIR.

Q         NOW, IS THIS ABOUT THE TIME WHERE YOU START ASKING QUESTIONS OF DR. MURRAY AND ANYONE ELSE IN THE AREA SO YOU CAN TRY AND FIGURE OUT WHAT IS CAUSING THIS PERSON TO BE UNCONSCIOUS?

A         I STARTED ASKING QUESTIONS AS SOON AS I WAS WALKING IN THE DOOR.   AS SOON AS I WAS IN THE ROOM AND BEFORE I EVEN PLACED THE EQUIPMENT ON THE FLOOR.

Q         DID YOU ASK ANY OF THE SECURITY GUARDS ANY QUESTIONS ABOUT WHAT WAS WRONG WITH THE PERSON?

A         YES.

Q         WHAT DID YOU ASK THEM?

A         “WHAT’S GOING ON?”

Q         WHAT DID THEY TELL YOU?

A         “THERE IS A MAN WHO NEEDS YOUR HELP UPSTAIRS.”

Q         DID YOU ASK ANY OF THEM IF HE HAD TAKEN ANY DRUGS OR NOT?

A         NO, SIR.

Q         DID YOU ASK DR. MURRAY THAT?

A         I’M NOT SURE.   IT WOULD BE A STANDARD QUESTION FOR ME TO SAY, “IS THERE ANY RECREATIONAL DRUGS INVOLVED?”   I DON’T RECALL WHETHER I ASKED THAT OR NOT.

Q         AGAIN, THE REASON YOU ARE ASKING IS AGAIN YOU UNDERSTAND WHAT IT IS YOU MAY HAVE TO DO TO TRY AND STABILIZE THE PERSON?

A         THAT’S CORRECT.

Q         BRING THEM BACK TO LIFE?

A         TIME IS OF THE ESSENCE.

Q         IS IT TRUE THAT MANY TIMES IN YOUR PAST WHEN TRYING TO HELP PEOPLE WHO LATER YOU FIND OUT WERE UNDER THE INFLUENCE OF DRUGS, A LOT OF TIMES THE PEOPLE AROUND THEM, THEIR OWN FAMILY MEMBERS, AREN’T AWARE OF WHAT IS INSIDE OF THEM?

A         THAT’S TRUE, SIR.

Q         ONE THING ABOUT DRUG ADDICTS, THEY ARE ADEPT AT KEEPING SECRET ABOUT THE TYPE OF DRUGS THEY TAKE?

A         YES, SIR.

Q         IT IS NOT UNUSUAL TO ASK PEOPLE AND THEY HAVE NO IDEA?

A         YES, THAT’S TRUE.

Q         YOU DID, THOUGH, ASK THE DOCTOR IF HE IS MICHAEL JACKSON FOR ANYTHING, ANY TYPE OF SICKNESS OR ILLNESS?

A         YES, SIR.

Q         THAT IS SOMETHING YOU WANT TO KNOW BECAUSE HE LOOKS LIKE HE IS PRETTY SICK?

A         YES, SIR.

Q         NOT JUST IN DISTRESS, BUT PHYSICALLY SICK AND ILL?

A         YES, SIR.

Q         AND YOU SEE THE OBVIOUS THINGS?

A         YES.

Q         YOU SEE THE I.V.?

A         YES.

Q         YOU HAVE A DOCTOR WHO IS THERE?

A         YES.

Q         ALL THINGS SUGGEST THIS PERSON IS PRETTY SICK?

A         YES, SIR.

Q         AND IT MUST HAVE BEEN PRETTY ODD FOR YOU OR ODD TO YOU, IF I CAN SAY IT THAT WAY, TO FIND OUT THAT DR. MURRAY SAID TO YOU, “NO UNDERLYING HEALTH ISSUE”?

A         YES.

Q         YOU CAN SIMPLY LOOK AND CLEARLY SEE THE PERSON IS PRETTY SICK?

A         YES, SIR.

Q         YOU MENTIONED ON DIRECT EXAMINATION THAT WHEN DR. MURRAY FINALLY DID GIVE YOU AN ANSWER, AT FIRST HE DIDN’T RESPOND RIGHT AWAY, DID HE?

A         NO.

Q         IT LOOKED LIKE HE HAD TO THINK IT OVER A LITTLE BIT?

A         I DON’T KNOW WHAT HE WAS DOING.   HE JUST DIDN’T RESPOND RIGHT AWAY.   HE WAS BUSY RIGHT THEN.   I WAS BUSY RIGHT THEN.   I DON’T KNOW WHAT HE WAS THINKING, SIR.

Q         FAIR ENOUGH.   AT SOME POINT, I THINK YOU SAID ON DIRECT, HE SAID HE WAS TREATING HIM FOR DEHYDRATION?

A         YES, SIR.

Q         DID HE MENTION ANY OTHER THING HE WAS TREATING HIM FOR?

A         NO, SIR.

Q         SIR, YOU MADE A STATEMENT BACK IN JULY OF ’09.   AGAIN, THAT WAS A LONG TIME AGO, SO I UNDERSTAND THAT.   IS IT POSSIBLE, THOUGH, THAT ON THAT TIME YOU MAY HAVE RELAYED TO AN OFFICER WHO ASKED IF, IN FACT, WHAT YOU WERE TREATING HIM FOR, AND HE SAID DEHYDRATION AND EXHAUSTION?

A         HE DID SAY EXHAUSTION.

Q         WHAT WAS YOUR UNDERSTANDING AS TO WHAT THAT MEANS, EXHAUSTION?

 MR. WALGREN:   OBJECTION.   RELEVANCE.

THE COURT:   SUSTAINED.

MR. LOW:  

Q                 WHEN YOU HEARD HIM SAY THAT HE WAS TREATING HIM FOR EXHAUSTION, WHAT, IF ANYTHING, DID THAT MEAN TO YOU WITH REGARDS TO THE PROTOCOL, THE TREATMENT YOU WERE GOING TO ADMINISTER AT THAT TIME?

A         IT WAS SOMETHING THAT I TOOK INTO CONSIDERATION.   IT DIDN’T EXPLAIN CARDIAC ARREST TO ME, BUT IT MADE SOME SENSE FOR SOMEONE BEING UNDERWEIGHT. WOULD IT CHANGE HOW I TREATED A CARDIAC ARREST?   NO, NOT INITIALLY.   BUT IT IS AN IMPORTANT PART OF THE PUZZLE THAT I CAN TELL THE DOCTORS ON THE RADIO, AND THE DOCTORS MAYBE NEED THAT INFORMATION.

Q         IT CAN BE A VERY IMPORTANT PART OF THE PUZZLE?

A         YES, SIR.   ANYTHING CAN BE.   THAT IS ONE THING I’VE LEARNED IN ALL MY YEARS.   SOMETIMES THE LITTLEST THING IS THE MOST IMPORTANT.

Q         YES.   IN THAT MOMENT, YOU DO LEARN THAT THIS PERSON HAS RECEIVED SOME AMOUNT OF LORAZEPAM, WHAT YOU ALSO CALLED ATAVAN?

A         YES.

Q         TO SOME DEGREE, THAT IS A MILD SEDATIVE?

A         YES, SIR, ANTI-ANXIETY, MILD SEDATIVE.   WE DON’T CARRY THAT IN OUR BOX.   SO IT IS SOMETHING I’M FAMILIAR WITH, BUT NOT SOMETHING I USE.   SO MY KNOWLEDGE ON IT IS LIMITED.

Q         YOU ARE ON THE SCENE.   YOU GET THE AIRWAY OPEN?

A         YES, SIR.

Q         YOU START GETTING AIR MOVING IN AND OUT; IS THAT RIGHT?

A         YES, SIR.

Q         NOW, ONE OF THE THINGS SO YOU CAN BE PROFICIENT AND EFFICIENT IS YOU WANT TO MAKE SURE IS NOT ONLY THE AIRWAY THERE BUT MOVING THE AIR WELL?

A         YES, SIR.

Q         ONE OF THE WAYS YOU CAN DO THAT IS THEY GIVE YOU THIS MACHINE.   IT IS CALLED — I CAN’T SAY IT.

A         CAPNOGRAPHY.

Q         CAPNOGRAPHY?

A         YES, SIR.

Q         THAT TELLS YOU, LOOK, THE BLOOD CELLS ARE, IN FACT, EXCHANGING GOOD GAS OR BAD GAS?

A         YES.

Q         CO2?

A         YES, SIR.

Q         YOU HAVE TO GET A BASE LINE SO YOU KNOW WHERE YOU START, SO YOU SEE WHERE YOU HAVE TO GET TO?

A         YES, SIR.

24               Q         THEY GIVE YOU SOME GENERAL GUIDELINES.   ONE OF THEM IS IF YOU HAVE A NUMBER THAT IS, SAY, DOWN IN THE TEENS, BECAUSE THE HIGHER THE NUMBER THE BETTER WE ARE, CORRECT?

A         YES, SIR.

Q         WE ARE DOWN IN THE TEENS.   WE ARE NOT DOING SO WELL?

A         NO, SIR.

Q         YOUR JOB IS TO GET THAT NUMBER UP?

A         YES, SIR.

Q         YOU WOULD LIKE TO SEE IF YOU CAN’T GET UP TO 30?

A         YES, SIR.

Q         BECAUSE YOU FOUND IN A NORMAL HEALTHY PERSON, 30 IS WHERE YOU WILL FIND THE NUMBER OR SOMETIMES HIGHER?

A         YES, SIR.

Q         YOU FIGURE OUT USING THE MACHINE YOU ARE RIGHT AROUND 16 AT THIS POINT?

A         YES, SIR.

Q         YOU GET THE APPARATUS TO WORK, GET THE AIR MOVING IN AND OUT?

A         YES, SIR.

Q         THAT NUMBER CHANGES, DOESN’T IT?

A         YES, SIR.

Q         AT THAT POINT YOU ARE DOING SO WELL WITH IT, GOT IT GOING SO QUICKLY.   YOU GET THAT NUMBER ALL THE WAY UP TO 26?

A         YES, SIR.

Q         ALMOST 30?

A         YES.

Q         THAT IS GOOD CONDITIONS IF YOU BRING LIFE BACK INTO THIS PERSON?

A         YES, SIR.

Q         NOW, THE NEXT STEP, NOW WE HAVE THE AIR GOING, IS WE HAVE TO SEE IF WE HAVE THAT PUMP, THAT HEART WORKING.   NOW, WE ARE GETTING THE BLOOD OXYGENATED. BETTER MOVE IT AROUND THE BODY?

A         CAN I STOP YOU FOR A SECOND?

Q         YOU SURE CAN.

A         WE DO COMPRESSIONS IMMEDIATELY.   IN FACT, IN CPR NOW THEY ARE GETTING AWAY FROM TEACHING ABC.   THEY ARE TEACHING CAB.   COMPRESSIONS FIRST. AS SOON AS WE MOVED MICHAEL, WE STARTED DOING COMPRESSIONS RIGHT AWAY.   THAT IS ONGOING WHILE THE E.T.   TUBE IS GETTING SET UP AND PLACED, AND WE ARE VENTILATING PRIOR TO PLACING THE E.T. TUBE.   VENTILATING INTO THE MOUTH WITH THE AMBU BAG.   ALL THINGS ARE GOING ON SIMULTANEOUSLY.   COMPRESSIONS START FIRST, WHILE E.T. TUBE IS SETTING UP BECAUSE IT TAKES A MOMENT.

Q         THIS TEAM THAT IS TRYING TO DO THESE THINGS, YOU MENTIONED YOU HAVE A TEAM LEADER?

A         YES.

Q         THAT WAS YOU THAT NIGHT?

A         YES, SIR.

Q         AND THE TEAM LEADER WOULD SAY TO SOMEONE, “HEY, I WANT YOU TO DO THE COMPRESSIONS, OR I WANT YOU TO DO THIS”?

A         YES.

Q         YOU WILL BE FACILITATING OR ORCHESTRATING THE WHOLE EVENT, BUT NOT ALL THE TIME DOING IT YOURSELF?

A         YOU CAN’T DO IT ALL YOURSELF.   BUT WAS I DOING THINGS, YES.

Q         IT IS QUITE COMMON FOR SOMEONE WHO IS USED TO BEING IN CHARGE TO SAY, “COME OVER.   HELP ME WITH CPR.” YOU GET TIRED OR WANT TO ORCHESTRATE AND MANAGE, HAVE TO TELL PEOPLE WHAT TO DO?

A         YES, SIR.

Q         SO IF YOU HEARD FACTS THAT SUGGEST THE DOCTOR TOLD SOMEONE, “HEY, DO YOU KNOW CPR?   WILL YOU HELP ME WITH CPR,” YOU WOULD EXPECT THAT?

A         YES, SIR.   THAT WOULD NOT ONLY BE – THAT WOULD JUST BE NORMAL.   IF I’M DOING CPR, I CAN’T DO EVERYTHING ELSE I NEED TO DO.

Q         THANK YOU. IN FACT, IS IT TRUE THAT SOMETIMES THEY TEACH YOU WHEN THERE IS AN EMERGENCY SITUATION AND 911 NEEDS TO BE DIALED, THE PERSON WHO IS OVERSEEING THE PERSON WILL ACTUALLY DIRECT SOMEONE.   “YOU GO CALL 911.”   ACTUALLY TELL YOU, POINT AT THEM, LOOK AT THEM.   “GO CALL THEM.” RIGHT?

A         YES, SIR.

Q         NOW, AT THAT POINT, THOUGH, YOU WANT TO UNDERSTAND WHAT THE HEART IS DOING, RIGHT?

A         YES, SIR.

Q         BECAUSE I BELIEVE THAT TELETYPE SAID HERE HOW WE START RIGHT ON THE TELETYPE.   IT SAYS, “NOT BREATHING AT ALL.”   CORRECT?

THE COURT:   THE WITNESS IS REVIEWING THE DOCUMENT.

MR. LOW:   YES, SIR.   I BELIEVE IT IS PEOPLE’S EXHIBIT 18 FOR IDENTIFICATION.

A         (EXAMINING DOCUMENT)   YES, SIR.   LET ME EXPLAIN THAT FOR A MOMENT.

Q         SURE.

A         JUST PRIOR TO THAT WHERE IT SAYS, “NOT BREATHING AT ALL,” IT HAS A CATEGORY 9E1.   THAT IS A PROTOCOL NUMBER THAT THE DISPATCHER DISPATCHES OFF OF. THAT IS THE NOT BREATHING AT ALL.

THAT IS NOT AN INDIVIDUAL CASE-BY-CASE.   THIS IS THE CATEGORY THAT IT FELL UNDER.   SO SOMEONE TOLD THE DISPATCHER THAT HE IS NOT BREATHING, SO THEY DISPATCHED A CALL AS A 9E1 CATEGORY, NOT BREATHING AT ALL.

 Q         THANK YOU. WHEN YOU GET SOMETHING LIKE THIS AND YOU FIND OUT WHEN YOU SEE HIM NOT BREATHING, SOMETHING ELSE YOU WANT TO CHECK IS HOW THEIR HEART IS DOING?

A         THAT’S CORRECT.

Q         YOU HAVE A MACHINE THAT HELPS YOU DO THAT AS WELL?

A         YES, SIR.

Q         THE MACHINE IS DESIGNED WHERE YOU HOOK WIRES UP TO THE PERSON WHO IS NOT DOING SO WELL, AND IT TELLS YOU WHAT THE HEART IS DOING?

A         YES, SIR.

Q         LISTENS TO THE HEART?

A         YES, SIR.

Q         METAPHOR, OF COURSE.

A         YES, I GET METAPHORS.

Q         WHAT IT WILL DO IS DOES IT HAVE A SCREEN ONIT, OR JUST THE PAPER PRINTOUT?

A         IT HAS BOTH.

Q         AND IT ALLOWS YOU TO LOOK AT THE SCREEN AND PAPER PRINTOUT AND GIVES YOU SOME IDEA AS TO CHARACTERS OR THE HEALTH OR INEFFICIENCY THAT HEART IS CURRENTLY UNDER?

A         IT SHOWS THE ELECTRICAL TRACINGS OF THE HEART.   DOESN’T SHOW ANYTHING MECHANICAL.   SO YOU CAN THEORETICALLY — ACTUALLY, NOT THEORETICALLY — YOU COULD HAVE A PERFECT EKG OR CLOSE TO IT OF LIFE SUSTAINING EKG BUT HAVE NO PULSE WITHIN IT AT ALL.

Q         THE PERSON WHO ANALYZES THAT TYPE EKG, IF YOU   WILL, REALLY LOOKS AT SUBTLETIES IN AN EKG.   THAT IS A SCIENCE AND ART, READING THE EKG ITSELF?

A         YES, SIR.

Q         YOU NEED A LOT OF SCHOOLING?

A         BASICALLY, AN EKG IS NOT A BIG DEAL.   IT IS THE ACTUAL BASIC RHYTHMS ARE NOT A BIG DEAL. WHERE IT COMES INTO IS EACH INDIVIDUAL HAS A DIFFERENT HEART, AND THERE WILL STILL BE SUBTLE CHANGES. EACH INDIVIDUAL MAY HAVE DIFFERENT MEDICATIONS THEY TAKE THAT CAN CHANGE IT.   SO INDIVIDUALLY, YOU CAN GET CHANGES.

SO ON A TECHNICAL BASIS, SUCH AS MYSELF, WE CAN GET VERY PROFICIENT AT NORMAL EKG’S VERY QUICKLY. BUT THERE ARE SPECIALISTS OUT THERE THAT WILL SEE THINGS THAT I WOULD NOT SEE.

Q         RIGHT.   YOU ARE WELL TRAINED AND WELL SKILLED AT RECOGNIZING THINGS YOU NEED TO TO BRING LIFE BACK TO THAT PERSON?

A         YES, SIR.

Q         IF SOMEONE WANTS TO SPECIALIZE IN THAT AREA, THOUGH, AND TREAT ILLNESSES, YOU JUST CAN’T TELL BECAUSE THE PERSON IS WALKING AROUND.   THERE IS A LOT MORE?

A         YES, SIR.

Q         WHEN DID YOU COME TO FIND OUT DR. MURRAY IS THE KIND OF SPECIALIST HE WAS?

MR. WALGREN:   OBJECTION.   RELEVANCE.

THE COURT:   SUSTAINED.

MR. LOW:  

Q                 DID YOU COME TO FIND OUT THAT DR. MURRAY WAS A CARDIOLOGIST?

MR. WALGREN:   OBJECTION.   RELEVANCE.

THE COURT:   SUSTAINED.

MR. LOW:  

Q                 SIR, AT ANY POINT ON THAT DAY THAT YOU WERE THERE AT MICHAEL JACKSON’S HOUSE, WHILE YOU WERE TRYING TO WORK ON THE PATIENT, DID YOU LEARN WHAT DR. MURRAY DID FOR A LIVING?

A         YES, SIR.

Q         WHAT WAS IT YOU LEARNED?

A         HE IS A CARDIOLOGIST.

Q         NOW, LOOKING AT THE MACHINE —

A         COULD I BACK UP A SECOND?

Q         SURE, YOU CAN.

A         I REMEMBER HIM SAYING THAT HE WAS HIS DOCTOR. I REMEMBER HIM REQUESTING THINGS.   I DON’T — I KNOW I FOR SURE EVENTUALLY LEARNED HE IS A CARDIOLOGIST.   I JUST DON’T REMEMBER WHEN.

Q         FAIR ENOUGH.   THAT IS WHY I’LL DO IT FOR YOU THIS WAY.   AT SOME POINT DURING THAT DAY, DID YOU LEARN WHAT HE MAY DO FOR A LIVING?

A         I DON’T KNOW IF IT WAS DURING THAT DAY.

Q         YOU HAVE HAD TO REVIEW THIS A NUMBER OF ?

A         THIS?

Q         THE FACTS?

A         SOME, YES.

Q         ALL RIGHT, THEN.   NOW, IS IT TRUE THAT THE MACHINE THAT IS READING THE HEART OR THE HEART’S ACTION CAN ALSO DELIVER AN ELECTRIC SHOCK IF YOU DO SOME THINGS WITH THE MACHINE AND USE IT THAT WAY?

A         YES, SIR.   IF YOU USE THE RIGHT BUTTONS, TURN ON THE RIGHT SWITCH.

Q         AT NO POINT DID YOU EVER EMPLOY THAT TECHNIQUE ON THIS INDIVIDUAL?

A         WE DID NOT DEFIBRILLATE MICHAEL.

Q         PLEASE TELL US WHY YOU COULDN’T DO IT BECAUSE, IN FACT, YOU DID NOT DO IT.   COULD YOU?

A         NO.

Q         PLEASE TELL US WHY.

A         DEFIBRILLATION YOU SEE IN THE MOVIES ALL THE TIME ON TV SHOWS, ET CETERA.   ANY TIME SOMEONE HAS A HEART ATTACK IN THE MOVIES, THEY GET DEFIBRILLATED BECAUSE IT IS A VERY DRAMATIC THING TO DEMONSTRATE. BUT WHAT IT IS, IS THAT THERE IS MULTIPLE CARDIAC RHYTHMS, DYSRHYTHMIAS, THAT CAN HAPPEN, ARYTHMIAS.   WHAT IT IS, IS YOUR HEART HAS ITS PACEMAKER AND HAS ITS BACKUP PACEMAKERS.   IT FIRES OUT ORDERLY ELECTRICAL PATTERNS.   SOMETIMES IT GETS CONFUSED AND STARTS FIRING DISORDERLY PATTERNS, AND THE HEART WILL NO LONGER PUMP IN SEQUENCE.   AND, THEREFORE, YOUR BLOOD PRESSURE DROPS AND SO DO YOU. WHEN YOU DEFIBRILLATE, IT BRIEFLY STOPS THE HEART, GIVES IT A CHANCE FOR THE HEART’S PRIMARY PACEMAKER TO TAKE OVER AGAIN AND START BEATING.   WE DID NOT SEE VENTRICULAR FIBRILLATION.   THAT IS WHY WE DID NOT SHOCK.

Q         YOU DID SEE SOMETHING?

A         P.E.A

Q         WHAT IS P.E.A. AGAIN?   YOU SAID IT WAS PULSELESS ELECTRICAL ACTIVITY?

A        YES, SIR.

Q         THAT TELLS YOU THAT THERE IS A SPARK, IF YOU WILL, FIRING, TRYING TO GET THAT HEART TO RESUSCITATE AND PUMP?

A         YES, SIR.

Q         THAT SPARK IS MUCH LIKE THE ONE I PUNCH ON MY BARBECUE WHEN I WANT TO LIGHT IT UP AND GET WARM?

A         YES.

Q         YOU DON’T WANT TO USE THE DEFIB PADDLES. THAT WILL INTERRUPT THAT SPARK?

A         YES.

Q         THAT SPARK IS THE SPARK OF LIFE THAT HELPS YOU BREATHE MORE LIFE BACK INTO THIS PERSON?

A         YES, SIR.

Q         SO USING THE PADDLES WOULD BE THE WORST THING YOU COULD DO?

A         YES, SIR.

Q         THAT IS WHY YOU DIDN’T DO IT?

A         YES, SIR.

Q         OR ANYBODY ELSE?

A         YES, SIR.

Q         BUT DO YOU SEE THAT, IN FACT, ON THE MACHINE ON THE SCREEN AND ON THE PRINTOUT?   IT REGISTERS THERE WILL BE SOME TYPE OF THING.   IT IS A GRAPH THAT COMES UP SHOWING YOU THE SPARK IS THERE?

A         YES, SIR.

Q         SO WHEN WE HEARD THE TERM BY MR. WALGREN FLAT-LINE, WE ACTUALLY LOOK AT THE PRINTOUT.   IT IS NOT ENTIRELY FLAT, IS IT?

A         NO, SIR.

Q         THAT WAS A MISCHARACTERIZATION?

A         I —

Q         THAT IS ARGUMENTATIVE AND UNFAIR TO HIM.

THE COURT:   ARE YOU SUSTAINING YOUR OWN OBJECTION?

MR. LOW:   I THINK I SHOULD BE.   IF IT IS RIGHT, IT IS RIGHT.

Q         NOW, THE NEXT THING YOU CAN DO WHEN YOU HAVE GOT A PERSON WHO IS NOT ABLE TO BREATHE ON THEIR OWN LIKE THIS INDIVIDUAL AND THE HEART IS NOT WORKING PROPERLY LIKE THIS INDIVIDUAL IS YOU ADMINISTER SOME CHEMICALS THAT IF THEY GO INTO THE BODY MAY HELP GET THIS PROCESS STARTED AGAIN.   THE BODY TAKES OVER AND IS SELF-SUFFICIENT, RIGHT?

A         YES, SIR.

Q         ONE OF THE THINGS YOU MENTIONED YOU CAN DO IS THAT THING CALLED ATROPINE?

A         YES, SIR.

Q         THAT IS THE THING LIKE WE SAW IN “PULP FICTION.”   SUPPOSEDLY, IT SHOCKS YOU TO LIFE.   A LITTLE EXAGGERATED?

A         WE SAW THAT MOVIE IN THE FIRE STATION LATE AT NIGHT AFTER WE HAD DONE ALL OUR OTHER WORK.   WE JUST CRINGED AT THAT SCENE.

Q         THERE IS A LOT THAT COULD GO WRONG WITH THAT?

A         YES.

Q         GENERALLY SPEAKING, THAT CHEMICAL IS DESIGNED TO GET THE BODY FIRED UP AND KICK IT IN AND GET IT GOING?

A         GETTING THE HEART GOING.   YES, SIR.

Q         THE OTHER CHEMICAL YOU PUT IN THERE SO YOU CAN USE BODY CHEMISTRY TO HELP AS WELL IS BICARBONATE?

A         YES, SIR.   THAT IS LATER IN THE GAME, THOUGH. INITIALLY, WE WANT TO USE EPINEPHRINE, THEN ATROPINE. THEN LATER AS ACID BUILDS UP IN THE BODY, WE USE BICARB.

Q         AND I BELIEVE I HEARD YOU SAY THAT THERE WAS TWO ROUNDS OF THIS GOING ON AT SOME POINT?

A         YES, SIR.   WE EVENTUALLY, AS IN MY TEAM, WE GAVE THREE ROUNDS TOTAL.

Q         AND THE REASON WHY YOU WENT FROM ROUND ONE, THEN TWO, AND THEN FROM TWO TO THREE, IS BECAUSE YOU ARE TRYING?

A         YES, SIR.

Q         SOMETIMES THAT HAS WORKED IN THE PAST?

A         SURE.   YEAH, WE WANT IT TO WORK.

Q         YOU WANT IT TO WORK, AND YOU TRY WITHIN REASON, OF COURSE?

A         YES, YES.

Q         BUT IT DIDN’T WORK?

A         NO, SIR.

Q         PART OF YOUR PROTOCOL IS TO GET ON A PIECE OF COMMUNICATION TO CALL THE HOSPITAL?

A         YES, SIR.

Q         AND YOU CALLED IN TO THE HOSPITAL BECAUSE THERE THEY HAVE WHAT THEY CALL AN EMERGENCY TEAM?

A         YES, SIR.

Q         AND THE IDEA IS THEY ARE THERE TO HELP YOU AND ASSIST IN ANY WAY IF YOU HAVE QUESTIONS OR YOU HAVE SOME IDEAS YOU MIGHT WANT TO TRY.   THAT IS FOR THEM?

A         YES.

Q         YOU DO THAT.   YOU CALL THEM?

A         YES, SIR.

Q         AND AT SOME POINT DURING THAT CONVERSATION, YOU LEARN THAT THEY ALSO HAVE ACCESS TO WHAT YOUR MACHINE IS TELLING YOU ABOUT THE HEART?

A         THEY HAVE ACCESS TO IT?

Q         YES.   DO THEY KNOW WHAT THE MACHINE IS TELLING YOU WITH REGARD TO THAT?

A         WE ARE TELLING THEM WHAT WE ARE SEEING.

Q         RIGHT.   SO YOU HAVE TOLD THEM WHAT YOU RECEIVE FROM THE HEART?

A         YES.

Q         WHAT YOU HAVE SEEN FROM THE LUNGS?

A         YES.

Q         YOU TELL THEM ABOUT HOW LONG YOU HAVE BEEN THERE?

A        YES, SIR.

Q         YOU TELL THEM ABOUT THE ROUNDS OF THE CHEMICALS YOU PUT IN?

A         YES.

Q         ALL THE THINGS YOU HAVE USED BEFORE?

A         YES.

Q         AND THE PERSON ON THE OTHER END OF THE PHONE SAYS, “YOU KNOW WHAT.   JUST CALL IT.   JUST LET HIM   GO.”

A        YES, SIR.   THAT IS CORRECT.

Q         THEY GIVE YOU THAT DISCRETION, HAVEN’T THEY?

A         WHEN WE MAKE BASE STATION CONTACT, THEN IT BECOMES THEIR PATIENT.   AND SO WE ARE DOING IT UNDER THEIR ORDERS IF WE CALL IT UNDER THOSE CIRCUMSTANCES. WE DO HAVE THE DISCRETION NOT TO START.   FOR EXAMPLE, IF IT IS AN INCINERATION VICTIM, OR RIGOR MORTIS, AND DECAPITATION, SOMETHING OBVIOUS LIKE THAT. BUT NORMALLY, THEY ARE THE ONES.   IT IS THEIR DECISION TO CALL IT, NOT OURS.

Q         YES, SIR.   NOW, IF WE THINK ABOUT OVER THE TIME OF YOUR CAREER, ISN’T IT TRUE THAT IT USED TO BE ANYTIME YOU HAD A PATIENT THAT PRESENTED THESE TYPE SYMPTOMS OR PROBLEMS, THAT YOU WERE REQUIRED OR AT LEAST PROTOCOL WAS YOU LOAD THEM UP INTO THE AMBULANCE, TAKE THEM TO THE HOSPITAL, AND THE HOSPITAL IS THE ONE THAT CALLS IT AND SAYS, “WE WILL NOT DO IT ANYMORE”?

A         THAT IS ABSOLUTELY RIGHT.

Q         OVER THE LAST TEN, 15 YEARS, THAT HAS CHANGED?

A         YES, SIR.

Q         I BELIEVE YOU SAID THAT AS A RESULT NOW BECAUSE OF LOW MANPOWER, NOT ENOUGH HUMAN RESOURCES AND, UNFORTUNATELY, MONEY, THAT NOW THEY GIVE YOU THE DISCRETION OUT IN THE FIELD TO CALL IT. SO YOU DON’T EVEN HAVE TO BRING THEM TO THE HOSPITAL ANYMORE TO TRY THERE.   YOU TAKE THEM TO THE MORGUE?

A         NO.   WHERE DO I START WITH THAT?

Q         LET ME SEE IF I CAN ASK IT THIS WAY.   I MIGHT MAKE IT EASIER. AS YOU SAID BEFORE, “I’VE BEEN DOING THIS FOR A LONG TIME”?

 A         I HAVE SAID THAT.

Q         AND THINGS HAVE CHANGED A GREAT DEAL?

A         YES, SIR.

MR. WALGREN:   I OBJECT.

THE COURT:   JUST A MOMENT, PLEASE. WHAT IS THAT?

MR. WALGREN:   I OBJECT TO SIMPLY READING THE TRANSCRIPT.

THE COURT:   IT IS NOT A PRIOR INCONSISTENT STATEMENT, SO REFINE AND REASK, PLEASE.

MR. LOW:   YES, SIR.   THANK YOU.

Q        SIR, IS IT TRUE AS FAR AS YOUR UNDERSTANDING THAT IT INCURS A LOT OF COST AT THE HOSPITAL, TAKES UP ROOM AND MANPOWER?

A         YES, SIR.

Q         IS IT ALSO TRUE THAT THEY DON’T HAVE ROOM, THEY BEING THE HOSPITAL, MANPOWER, OR MONEY?

MR. WALGREN:   OBJECTION.   RELEVANCE.

THE COURT:   I’M SUSTAINING THE OBJECTION.   I DON’T UNDERSTAND THE RELEVANCE.   IT IS ALSO 352.

MR. LOW:  

Q                 SIR, IS IT TRUE THAT NOW YOU DON’T HAVE TO TAKE THEM TO THE HOSPITAL ANYMORE BECAUSE IT CAN TAX THE HOSPITAL’S MANPOWER AND MONEY?

MR. WALGREN:   I OBJECT.   RELEVANCE. THE PATIENT WAS TAKEN TO THE HOSPITAL.   IT IS IRRELEVANT.

THE COURT:   I’LL OVERRULE THE OBJECTION.   YOU MAY ANSWER THE QUESTION BASED ON YOUR STATE OF MIND.

THE WITNESS:   I’M NOT SURE WHAT THAT MEANS, YOUR HONOR.   DO I JUST ANSWER THE QUESTION?

THE COURT:   DO YOU UNDERSTAND IT?

THE WITNESS:   I’M CONFUSED WHAT HE WANTS ME TO ANSWER.

MR. LOW:   I’LL REASK IT, SIR.

THE COURT:   ALL RIGHT.

MR. LOW:  

Q                 AND IS IT ALSO TRUE, SIR, THAT A COMMON PROBLEM WITH REGARDS TO TAKING A PERSON TO THE HOSPITAL IS BECAUSE IT TAKES UP ROOM AND MANPOWER AT THE HOSPITAL, AND TAKES A LOT OF MONEY FROM THE HOSPITAL.   IS THAT ALSO YOUR UNDERSTANDING, SIR?

A         YES, SIR.   THAT WOULD BE MY UNDERSTANDING.

Q         WHEN THEY TOLD YOU, THE HOSPITAL TOLD YOU — YOU KNOW WHAT, SIR.   I’M GOING TO STOP THERE, JUDGE, IF THAT IS ALL RIGHT.   I CAN STOP AND DO THAT IN THE MORNING.

———————————————

Richard Senneff returned next Morning January 6th:

 

(CROSS-EXAMINATION (RESUMED)

 

MR. LOW:

Q           GOOD MORNING, SIR.

A           GOOD MORNING.

Q           IF I CAN, I BELIEVE WE LEFT OFF YESTERDAY AFTERNOON IN THAT MOMENT OF TIME ON THE 25TH WHERE YOU ALL HAD JUST CALLED INTO THE HOSPITAL, AND THEY SAID YOU CAN CALL IT IF YOU WANT TO. DOES THAT REFRESH YOUR RECOLLECTION AS TO WHERE WE LEFT OFF, SIR?

A           YES, SIR.

Q           OKAY.   AND SO AT THAT MOMENT, THE HOSPITAL GAVE YOU THE CHOICE AS PROTOCOL AND THEY ARE ALLOWED TO DO. AND IT’S TRUE THAT YOU, YOU MADE THE DECISION THAT, “WELL, YOU KNOW WHAT, I DON’T WANT TO GIVE UP.   I’D LIKE TO KEEP TRYING ON THIS PERSON?”

A           THAT’S NOT CORRECT.

Q          OKAY.   WHAT IS CORRECT?

A           I HAD — WE HAD GIVEN OUR THIRD ROUND OF MEDICATION.   WE HAD UPDATED — AFTER WE GIVE MEDICATION, WE UPDATE VITAL SIGNS, ANY CHANGES.   AND WE NOTIFY THE HOSPITAL. SO I NOTIFIED THEM THAT THE THIRD ROUND OF WAS ONBOARD.   THIS IS WHAT WE HAVE FOR THE EKG. THIS IS WHAT OUR CAPNOGRAPHY READING WAS.   THAT THERE BASICALLY, ESSENTIALLY, THERE WAS NO CHANGE IN THE PATIENT. AND THEY SAID, “WE WOULD LIKE TO CALL IT AT THIS TIME THEN.”   AND IT’S THEIR CALL. AND I SAID, “NO, WE ARE NOT COMFORTABLE WITH THIS.” AND THEY SAID, WELL, WE — I’LL NEED TO SPEAK TO THE PHYSICIAN.   THEY SPOKE TO THE PHYSICIAN.   NOW THE PHYSICIAN WOULD LIKE TO CALL IT. AND I SAID, “BE ADVISED THIS IS A VERY HIGH PROFILE VIP.   WE WOULD BE MORE COMFORTABLE TRANSPORTING TO YOUR FACILITY.”   AND THEY SAID, “NO.   WE ARE GOING TO GO AHEAD AND CALL IT.” AND I SAID, “WELL, THE PHYSICIAN, PERSONAL PHYSICIAN HERE IS ON-SCENE.   AND HE DOES NOT WANT TO CALL IT.   WOULD YOU LIKE TO SPEAK WITH HIM?”   AND I PUT DOCTOR MURRAY ON THE LINE WITH UCLA BASE STATION. AND THEN DOCTOR MURRAY SPOKE WITH THEM AND HANDED THE PHONE BACK TO ME.   AND THE BASE STATION SAID DOCTOR MURRAY WAS ASSUMING THE CALL AND THAT WE WOULD BE TRANSPORTING TO THE FACILITY.   IN A NUTSHELL.

Q           YES, SIR. SO YOU DIDN’T WANT TO CALL IT EITHER, DID YOU?

A           NO.

Q           AND DOCTOR MURRAY WAS LISTENING TO THE CONVERSATION YOU HAD WITH THE HOSPITAL.   AND HE WAS SAYING THE WHOLE TIME, “NO, NO, I DON’T WANT TO CALL IT.   I WANT TO KEEP TRYING?

A           THAT’S CORRECT.

Q           SO AT THAT POINT, THERE IS A PROCEDURE, I BELIEVE — AND I THINK YOU JUST SAID A LITTLE BIT ABOUT IT THAT THE HOSPITAL CAN GIVE CUBITAL CONTROL OF, IF YOU WILL, SOME SAY TO THE PHYSICIAN ONSITE WHICH IN THIS CASE WAS DOCTOR MURRAY?

A           THAT’S CORRECT.

Q           SO YA’LL CALLED THE PROCEDURE LIKE YOU ARE SUPPOSED TO, AND HE ASSUMED CONTROL?

A           YES, SIR.

Q           GOT ON THE PHONE AND THEY READ SOME WORDS TO HIM OR WHATNOT, AND YOU COULD HEAR HIM SAY “YES, I AM WILLING TO ACCEPT RESPONSIBILITY AND CONTROL?”

A           YES, SIR.

Q           AND THAT IS WHAT HE DID?

A           THAT IS WHAT HE DID, YES, SIR.

Q           AFTER THAT PROCEDURE GETS CLEARED UP AND WHATNOT, DOCTOR MURRAY NOW HAS SOME IDEAS. ONE IDEA WAS THAT HE SAID THAT HE WANTED TO ADMINISTER A CENTRAL LINE; IS THIS TRUE, SIR?

A           THAT’S TRUE.

Q           AND A CENTRAL LINE IS A LINE THAT ACTUALLY GOES RIGHT INTO A BLOOD VESSEL NEAR THE HEART.   I BELIEVE IT’S THE AORTA.   AND THE IDEA IS TO GET, YOU KNOW, SOME CHEMICALS CLOSE TO THE HEART AND FASHIONED TO THE HEART; IS THIS TRUE, SIR?

A           MORE OR LESS, YES.   IT GOES INTO AN ARTERY. BUT YES, IT’S A DIRECT ROUTE.

Q           THANK YOU. I KNOW I AM OVERSIMPLIFYING IT.   BUT ANYTIME YOU NEED TO ADD MORE, PLEASE DO SO.

A           OKAY.

Q           OKAY.   THANK YOU. ANOTHER IDEA THAT DOCTOR MURRAY HAD WAS TO ADMINISTER MAGNESIUM, ANOTHER TYPE OF CHEMICAL THAT MAY HELP?

A           YES, SIR.

Q           OKAY.   NOW THE EQUIPMENT THAT YOU HAD TO WORK WITH ON THE SCENE WAS BASICALLY WHAT THE COUNTY AND THE CITY IS WHAT THEY GIVE YOU, CORRECT?

A           YES, SIR.

Q           RIGHT. AND THEY GIVE YOU EQUIPMENT THAT HELPS YOU DO EVERYTHING YOU ARE SUPPOSED TO DO AND EVERYTHING YOU NEED TO DO ACCORDING TO PROTOCOL AND PROCEDURE?

A           YES, SIR.

Q           BUT THEY ARE NOT — THEY DON’T GIVE YOU ALL THE EQUIPMENT THAT A HOSPITAL HAS, DO THEY?

A           THAT’S CORRECT.

Q           RIGHT. I MEAN, THAT IS WHAT HOSPITALS ARE FOR, RIGHT?

A           YES, SIR.

Q           OKAY.   AND YOU DON’T DO ALL THE PROCEDURES THAT A HOSPITAL DOES.   YOU GUYS ARE JUST THERE TO SUSTAIN AND GET THE PERSON STABILIZED SO THAT THE HOSPITAL CAN LATER DO THEIR JOB?

A           YES, SIR.

Q           SO WHEN DOCTOR MURRAY ASKED FOR THE CENTRAL LINE, THAT IS NOT YOU ALL’S JOB? YOU DON’T DO THAT, RIGHT?

A           WE ARE NOT TRAINED IN CENTRAL LINES.   I AM FAMILIAR WITH THEM BECAUSE OF MY YEARS OF EXPERIENCE.   BUT I HAVE NEVER BEEN TRAINED IN IT.   I HAVE NEVER READ UP ON THEM.   AND WE CERTAINLY DON’T HAVE THE EQUIPMENT.   AND IT IS WITH OUT OF OUR RANGE OF PROTOCOL.   WE WOULD BE WORKING ESSENTIALLY OUT OF SCOPE.

Q           YES, SIR. SO IT’S AN IDEA, BUT THERE IS NO WAY YOU ALL CAN DO IT BECAUSE THAT’S JUST NOT YOUR JOB?

A           IT’S BEYOND OUR SCOPE OF TRAINING.

Q           YES, SIR, OF COURSE. THE OTHER IDEA AGAIN IS WITH THE MAGNESIUM, AGAIN, YOU CAN’T DO THAT BECAUSE AGAIN IT’S NOT YOUR JOB; AND YOU DON’T HAVE THAT KIND OF EQUIPMENT?

A           THAT’S CORRECT.

Q           ALL RIGHT. SO THESE ARE THINGS THAT WE SHOULD DO AT THE

HOSPITAL?

A           YES.

Q           RIGHT. SO AFTER TRYING THESE IDEAS AND WE DON’T HAVE THE EQUIPMENT, MAYBE IT WAS YOUR IDEA OR SOMEONE ELSE’S, IT’S TIME NOW TO TRY TO GET HIM TO THE HOSPITAL; IS THIS TRUE?

A           THAT’S CORRECT, YES.

Q           AND SO YOUR TEAM AS WELL AS DOCTOR MURRAY,   YA’LL GATHERED MICHAEL JACKSON UP AND BEGIN TO TAKE HIM DOWN TO THE AMBULANCE.   IT’S ALREADY THERE.   IT CAME WITH YOU?

A           YES, SIR.

Q           SO YOU WERE READY TO GO?

A           YES, SIR.

Q           ALL RIGHT. NOW ONE LAST PIECE I WOULD LIKE TO ASK YOU ABOUT BEFORE WE GO TO THE HOSPITAL, AT SOME POINT WHILE YOU ARE WORKING ON –

THE COURT:   WE HAD A COUGH.   COULD YOU REPEAT THAT?

MR. LOW:   YES, SIR.   SORRY.

Q           AT ONE POINT WHILE YOU ARE WORKING ON THE PATIENT, YOU DO COME TO BE TOLD BY DOCTOR MURRAY THE NAME OF THE PATIENT; IS THIS TRUE, SIR?

A           YES, SIR.   IT WAS EARLIER IN THE CALL, BUT WE WERE TOLD THE NAME OF THE PATIENT.   I’M NOT SURE EXACTLY WHO SAID THE NAME, WHETHER IT WAS MARTIN WHO SAID IT OR DOCTOR MURRAY WHO SAID IT.   SOMEBODY SAID IT IN THE ROOM.   AND YEAH, I’M NOT SURE EXACTLY WHO SAID IT.   I HEARD IT IN THE ROOM.

Q           FAIR ENOUGH.

A           IT WAS MUMBLED.

Q           YES, SIR.   IT WAS MUMBLED. IN OTHER WORDS, AT NO POINT DURING THIS PROCEDURE WAS ANYONE STANDING UP AND SAYING THINGS LIKE “YOU BETTER DO, YOU KNOW, WE BETTER KEEP GOING, OR WE BETTER WORK HARD BECAUSE YOU KNOW WHO THIS IS, THIS IS MICHAEL JACKSON, WE GOT TO KEEP GOING.” THE WAY IT REALLY WENT DOWN IS THAT SOMEONE MUMBLED IT, KIND OF WHISPERED IT, “THIS IS MICHAEL JACKSON.”   AND THAT IS HOW YOU KNEW TO SAY THIS IS A VIP OVER THE PHONE TO THE HOSPITAL?

MR. WALGREN:   OBJECTION.   ASSUMES FACTS NOT IN EVIDENCE.   COUNSEL IS TESTIFYING.

THE COURT:  I WILL OVERRULE THE OBJECTION. IS THAT HOW IT CAME OUT OR NOT?

THE WITNESS:   ESSENTIALLY, YES.   SOMEBODY MENTIONED IT.   I’M NOT SURE WHO.   AND THAT’S HOW WE BECAME AWARE.   NOBODY WAS INSISTING THAT WE DO ANYTHING BECAUSE OF WHO THIS WAS.

MR. LOW:

Q           YES, SIR.   THANK YOU.   ALL RIGHT. NOW ANYTHING SIGNIFICANT OR EVENTFUL THAT YOU THINK WE NEED TO KNOW WITH REGARDS TO JUST GETTING THE PATIENT MICHAEL JACKSON FROM THE SECOND LEVEL HOUSE IN AN AMBULANCE?

A           NOT THAT I DIDN’T MENTION YESTERDAY.   IT TAKES ALL HANDS.   IT’S A BIT OF WORK TO GET EVERYTHING, THE EQUIPMENT, THE PATIENT DOWNSTAIRS SAFELY.

Q           ALL RIGHt AND DID DOCTOR MURRAY ASSIST AND ACCOMPANY YA’LL WHEN YOU WENT DOWN WITH THE GURNEY TO GET INTO THE AMBULANCE?

A           NO, NOT AT THAT POINT, NO.

Q           AND AT SOME POINT, HE DID?

A           HE CAME DOWNSTAIRS AND MET US AT THE AMBULANCE.

Q           OKAY.

A           AT SOME POINT.

Q           YOU SAID AT ONE POINT YOU WENT BACK UPSTAIRS TO GATHER YOUR GEAR?

A           THAT’S CORRECT.

Q           AND DOCTOR MURRAY WAS THERE?

A           YES.

Q           AND DID YOU LEAVE THE ROOM BEFORE OR AFTER HE DID?

A           I LEFT THE ROOM BEFORE HE DID?

Q           ALL RIGHT. AND HOW LONG WERE YOU DOWN AT THE AMBULANCE BEFORE DOCTOR MURRAY GOT DOWN THERE SO YOU ALL COULD LEAVE TOGETHER?

A           I CAME — I LEFT THE PATIENT AT THE BOTTOM OF THE STAIRS WITH MY CREW.   I WENT UP THE STAIRS, GATHERED A FEW THINGS, SHOVED THEM IN THE BOX UNTIL THE BOX WOULD CLOSE, TOOK ONE LAST SCAN FOR EQUIPMENT, WENT BACK DOWN THE STAIRS.   AND AT THAT POINT, I BELIEVE THEY WERE PUTTING THE GURNEY INTO THE BACK OF THE AMBULANCE. SO MAYBE TWO MINUTES, SOMETHING, SOMETHING AROUND THAT, YEAH.   NOT SURE EXACTLY.

Q          FAIR ENOUGH.   I KNOW IT’S A LONG TIME AGO.

MR. LOW:   OKAY.   AND IF I CAN, JUDGE, I AM GOING TO APOLOGIZE TO YOU.   I JUST LOOKED AT MY OUTLINE.

Q           I FORGOT ONE OTHER AREA WHILE YOU WERE STILL WORKING ON THE PATIENT UPSTAIRS.   I WOULD LIKE TO JUST GO .   AND I AM SORRY.

A           OKAY.

Q           THAT OTHER AREA, AT SOME POINT AGAIN WHILE YOU ALL WERE STILL WORKING ON THE PATIENT, IS IT TRUE THAT DOCTOR MURRAY SAID, “LOOK, I THINK I HAVE FOUND A PULSE?”

A           YES.   HE SAID, “I THINK THERE IS A PULSE,” YES.

Q           AND IT APPEARED THAT HE WAS, HOW HE FOUND IT WAS BY USING HIS HAND?

A           YES, SIR.

Q           TO DETECT?

A           YES, SIR.

Q           AND THAT HAND WAS LOCATED IN THE PATIENT’S GROIN AREA?

A           YES, SIR.

Q           AND THE REASON FOR THAT IS THERE IS AN ARTERY IN THAT AREA CALLED THE FEMORAL ARTERY IN THE GROIN AREA, THAT IF YOU TOUCH IT AND PUT PRESSURE ON IT, YOU CAN FIND THAT MAYBE SOMETIMES THERE IS PULSE?

A           YES, SIR.

Q           AND CERTAINLY, ON SOMEONE, YOU SAID THIS BEFORE, YOU MIGHT BE ABLE TO FEEL IT?

A           I WOULD HOPE SO, SIR.

Q           YES.   OKAY. SO WITH THAT, YOU, I BELIEVE YOU ACTUALLY CHECKED AND LOOKED ON THE MACHINE TO SEE IF THERE WAS ANY CHANGE IN THE MACHINE, THE HEART DETECTOR, CORRECT?

A           EXACTLY.   SOON AS HE SAID IT, THE FIRST THING I DID WAS LOOK AT THE MONITOR.

Q           BUT YOU DIDN’T SEE ANY SIGNIFICANT CHANGES, DID YOU?

A           NO, SIR.

Q           OKAY.   AND IN FACT, I BELIEVE SOME OF THE OTHER TEAM ACTUALLY STOPPED DOING COMPRESSIONS OR THE AIRWAY BREATHING; IS THAT TRUE?

A           NO.

Q           OKAY.   SAY WHAT IS TRUE.

A           OKAY.   WE DID WHAT WE — WE GIVE COMMANDS BACK AND FORTH.   AND WHEN YOU DO GOOD CPR, IT’S COMMON TO GET A FEMORAL PULSE FROM THE CPR.   IT’S WEAK, BUT THE CPR DOES PROVIDE SOME LEVEL OF BLOOD PRESSURE, SOME LEVEL OF PULSE. SO ON THE OTHER HAND, THE BREATHING IS STILL IMPORTANT.   AND THE BREATHING IS NOT IMPACTING FEELING THE PULSE AND THE FEMORAL ARTERY.   SO I BELIEVE WHAT I SAID WAS, “STOP COMPRESSIONS, CONTINUE VENTILIZATIONS.   “

Q           THANK YOU.   THAT’S MORE ACCURATE. SO MY POINT WAS THAT IN ORDER TO FIND OUT IF THAT PULSE, TO BETTER ASCERTAIN THAT PULSE, WE THOUGHT IF YOU STOPPED WITH COMPRESSIONS THAT THAT MIGHT BE CONTRIBUTING TO THE PULSE; AND THAT IS WHY YA’LL STOPPED   IT, RIGHT?

MR. WALGREN:   OBJECTION.   ASSUMES FACT NOT IN EVIDENCE THAT THERE WAS ACTUALLY A PULSE.

THE COURT:   SUSTAINED.

MR. LOW:

Q           IF THERE WAS A PULSE YOU JUST HEARD THE DOCTOR SAY THAT HE THOUGHT FELT, WHAT YOU DECIDED TO DO WAS JUST STOP COMPRESSIONS AND SEE IF THAT WAS POSSIBLY CONTRIBUTING TO IF THERE WAS A PULSE; IS THAT TRUE

A           TRYING TO FIND OUT WHETHER THERE WAS ACTUALLY A PULSE.   IF YOU STOP COMPRESSIONS AND YOU FEEL A PULSE, THEN OBVIOUSLY, IT’S NOT THE CHEST COMPRESSIONS. SO, YES.   IT TAKES TWO SECONDS, STOP COMPRESSIONS, CONTINUE VENTILIZATIONS, PUT YOUR HANDS THERE, FEEL FOR FIVE SECONDS, NOTHING, CONTINUE COMPRESSIONS.

Q           THANK YOU.   ALL RIGHT.

A           IF I MAY ADD, IT ALSO GIVES YOU A CLEAR VIEW OF THE MONITOR AT THAT TIME, TOO, THE EKG DEVICE.   BECAUSE WHEN YOU DO COMPRESSIONS, IT MOVES THE WIRES, AND IT TENDS TO PUT SOME ARTIFACT, SOME EXTRA, EXTRA CHARACTERS ONTO THE SCREEN.   SO IT GIVES YOU AN OPPORTUNITY TO GET A CLEAR VIEW OF THE EKG SCREEN.

Q          THANK YOU, SIR.   ALL RIGHT. NOW THE DIFFERENCE — WE ARE DOWNSTAIRS.   WE ARE AT THE AMBULANCE.   THAT IS WHERE THESE QUESTIONS ARE GOING TO COME FROM.

A           YES, SIR.

Q           AS YOU ALL WERE MAKING YOUR WAY OUT TO THE AMBULANCE, AS I HEARD YOU SAY YESTERDAY AFTERNOON THAT THERE IS A SIGNIFICANT DIFFERENCE IN THE NUMBER OF PEOPLE OUT THERE NOW?

A           THERE IS.

Q           AND A LOT OF THEM HAVE CAMERAS?

A           YES, SIR.

Q           AND A LOT OF THEM APPEAR TO BE THOSE TYPE OF INDIVIDUALS WHO TAKE PHOTOS AND DO THINGS WITH THEM AND SELL THEM TO PEOPLE, RIGHT?

A           THERE’S A TOUR BUS OUT THERE.   THERE’S JUST A LOT OF PEOPLE, A LOT OF CAMERAS, LOT OF COMMOTION.

Q           WOULD IT BE ACCURATE TO DESCRIBE WHAT YOU SAW, WOULD THE GENERAL TERM APPEAR TO BE “PAPARAZZI?”

A           PAPARAZZI, TOURISTS, BIG CAMERAS, LITTLE CAMERAS, VIDEO CAMERAS, STILL CAMERAS.   JUST A LOT.

Q           OKAY.   AND THOSE ARE THE TYPE OF — THIS IS THE TYPE OF SITUATION WHERE ARGUABLY IT INFRINGED ON SOMEONE’S PRIVACY. WITH THE PAPARAZZI THERE, IT IS NOT AS PRIVATE AS MAYBE YOU’D LIKE TO HAVE?

MR. WALGREN:   OBJECTION.   RELEVANCE.

THE COURT:   SUSTAINED.

MR. LOW:   OKAY.   I WILL MOVE ON FROM THAT.

Q           DID YA’LL GET IN THE AMBULANCE?

A           YES, SIR.

Q           AND INSIDE THE AMBULANCE IS YOURSELF?

A           YES, SIR.

Q           CERTAINLY THE PATIENT?

A          YES, SIR.

Q           DOCTOR MURRAY?

A           YES, SIR.

Q           AND WHO ELSE?

A           FIREFIGHTER PARAMEDIC MARK GOODWIN, FIREFIGHTER PARAMEDIC MARTIN BLOUNT.

Q           JUST BALLPARK FIGURE, ABOUT HOW LONG DID IT TAKE YOU TO GET THERE?

A           7 MINUTES BALLPARK.

Q           ANYTHING SIGNIFICANT, TREATMENT-WISE GOING ON IN THE AMBULANCE?

A           YES, SIR.

Q           GO AHEAD.

A           DOCTOR MURRAY ASKED US TO GIVE ANOTHER ROUND OF EPINEPHRINE AND ATROPINE.

Q           AND DID THAT HAPPEN?

A           IT DID.   WE DID DO THAT EN ROUTE.

Q           OKAY.   WAS THAT THE SAME METHOD THROUGH THE LOCKING —

A           RIGHT.   THROUGH THE SALINE, RIGHT.

Q           ALL RIGHT. NOW ONCE YA’LL GET TO THE HOSPITAL, YOU ARE GETTING OUT OF THE AMBULANCE WHERE THAT HAPPENS, THE EXCHANGE AT THE E.R; IS THAT TRUE?

A           YES, SIR.

Q           SAME PLACE YOU ALWAYS GO WHEN YOU HAVE AN EMERGENCY?

A           YES, SIR.

Q           AND WHEN YOU GOT THERE, DID YOU NOTICE IF THERE WAS ANY PAPARAZZI IN THAT AREA?

A           THERE WAS.

Q           IN FACT, DID ONE OF THEM RUN UP TO THE SIDE OF THE AMBULANCE AND TRY AND SNAP SOME PICTURES THROUGH THE WINDOW IN THE AMBULANCE?

A           THAT WAS — THEY WERE ALL OVER THE PLACE. WHEN WE WERE INITIALLY LEAVING THE RESIDENCE, WHEN WE WERE DRIVING THERE AND WHEN WE GOT TO THE HOSPITAL, JUST ALL OVER.

Q           AND AT THAT POINT, IS IT TRUE THAT DOCTOR MURRAY SAID, “WELL, CAN WE TAKE A TOWEL OR SOMETHING AND COVER MICHAEL’S FACE WITH IT BECAUSE I DON’T WANT THEM TO HAVE ACCESS TO WHO THIS IS?”   HE WANTED TO TRY AND PROTECT HIM?

A           HE DIDN’T SAY THE LAST PART OF THAT STATEMENT.   BUT HE DID SAY, “COULD WE PUT A TOWEL OVER AND COVER HIS FACE?”

Q           AND DID YOU THINK THAT WAS REASONABLE?

A           VERY REASONABLE.

Q           AND WHAT DID YOU THINK, WHAT WAS YOUR UNDERSTANDING AS TO WHY YA’LL WERE DOING THAT?

A           WHEN WE FIRST BACKED OUT OF THE RESIDENCE, WE WANTED TO GET TO THE HOSPITAL.   THERE’S ALL THESE PEOPLE IN THE WAY.   IT’S HARD FOR THE DRIVER BACKING UP. THEN WE START — IT’S JUST, IT’S A CIRCUS OUT THERE.   IT’S UNBELIEVABLE. AND THEN WE START TO DRIVE AWAY.   AND AN INDIVIDUAL CAME RUNNING DOWN THE STREET, PUT HIS CAMERA LENS AGAINST THE OUTSIDE WINDOW.   AND IT WAS A BIG CAMERA AND STARTS FILMING WHILE HE IS SPRINTING DOWN THE STREET. JUST AMAZING.   AND IT JUST SEEMED WRONG.

Q           YES, SIR.

A           SO WHEN DOCTOR MURRAY SUGGESTED WE PUT A TOWEL OVER HIS FACE AT THE HOSPITAL, IT SEEMED A VERY REASONABLE REQUEST.

Q           THANK YOU. SIR, ONCE YOU GET INTO THE HOSPITAL, YOU ARE MET BY THE HOSPITAL STAFF?

A           YES, SIR.

Q           AND ACCORDING TO PROCEDURE, THAT IS USUALLY WHEN THEY TAKE OVER; AND THEY BEGIN TO DO WHATEVER PROCEDURES THEY DO?

A           YES, SIR.

Q           DID YOU WAIT — I BELIEVE YOU DID WAIT BEHIND AT THE HOSPITAL JUST TO SEE HOW THINGS ARE GOING AND DO SOME PAPERWORK AND WHATNOT, IS THIS TRUE?

A           RIGHT.   OUR GOAL IS TO GET READY FOR ANOTHER RESPONSE, CONTINUATION OF CARE.   IF THE HOSPITAL HAS ANY QUESTIONS ABOUT THE PATIENT, WE HAVE PAPERWORK TO DO.   WE HAVE GOT TO GET OUR RIG READY TO RESPOND IN CASE THERE IS ANOTHER EMERGENCY, JUST MULTIPLE THINGS LIKE THAT.

Q           YES, SIR. AND AT SOME POINT, IT’S TRUE YOU LEARNED THAT THE HOSPITAL BEGAN TO WORK IN TRYING TO AGAIN BRING LIFE BACK INTO MICHAEL JACKSON?

A           THEY, THEY, RIGHT WHEN WE WALKED IN THE DOOR, THEY WERE ON IT.

Q          THEY WENT THROUGH ALL THE MEASURES AND STEPS THEY GO THROUGH?

A           SO WHAT WE WERE DOING, WE HAD CPR IN PROGRESS AND MEDICATIONS.   AND THEY JUST TOOK RIGHT OVER. THEY DIDN’T STOP.

Q           AT SOME POINT WHILE YOU WERE AT THE HOSPITAL, DID YOU LEARN THAT, IN FACT, THAT THE HOSPITAL EVENTUALLY HAD CALLED IT AND PRONOUNCED MICHAEL JACKSON DEAD?

A           YES, SIR.

Q           AND AS BEST YOU CAN ESTIMATE, ROUGHLY ABOUT HOW MUCH TIME WAS THAT AFTER YOU ARRIVED WAS THAT THAT YOU HEARD THAT NEWS?

A           I REALLY DON’T KNOW.   45 MINUTES, AN HOUR, SOMEWHERE AROUND THERE.

Q           OKAY.

A           I DON’T REALLY KNOW

Q           AND SIR, I THINK IT’S — WELL, YOU TELL US. IS IT FAIR TO SAY THAT YOU AND YOUR TEAM NOT ONLY DID EVERYTHING POSSIBLE THAT YOU KNEW HOW TO DO, BUT YOU WENT ABOVE AND BEYOND THE CALL OF DUTY TRYING TO RESUSCITATE MICHAEL JACKSON?

A           THAT WOULD BE A VERY FAIR.   I WAS REALLY PROUD OF THE GUYS.

Q           YOU JUST DIDN’T WANT TO GIVE UP ON HIM BECAUSE THERE JUST MIGHT BE A CHANCE?   THAT IS WHAT YOU ARE TRAINED TO DO?

A           IT’S NOT THAT IT WAS MICHAEL JACKSON, THE CELEBRITY.   IT’S SOMEBODY’S SON.   THAT SIMPLE.

Q           YOU’D DO THAT FOR ANYBODY YOU CAME IN CONTACT WITH, WOULDN’T YOU?

A           WE TRY TO.

Q           YEAH. BUT SOMETIMES, SIR, IS IT TRUE THAT NO MATTER HOW HARD YOU WORK, SOME PEOPLE, ONCE IT’S THERE TIME TO GO, IT’S THEIR TIME TO GO?

A           THAT’S CORRECT.   THAT IS CERTAINLY SOMETHING YOU LEARN ON THIS JOB.

MR. LOW:   THANK YOU. JUDGE, I APPRECIATE.   THAT IS ALL WE HAVE AT THIS TIME.

                 

REDIRECT EXAMINATION

 

MR. WALGREN:

Q           GOOD MORNING, SIR.

A           GOOD MORNING.

Q           I JUST HAVE A FEW FOLLOWUP QUESTIONS.   LET ME ASK YOU FIRST ABOUT THE FEMORAL PULSE THAT DOCTOR MURRAY CLAIMED TO HAVE FELT. NOW JUST TO MAKE SURE FROM THE QUESTIONING BY MR. LOW THAT I HAVE AN ACCURATE UNDERSTANDING OF WHAT TOOK PLACE, SO AT SOME TIME DURING THE TREATMENT, THE DEFENDANT, DOCTOR MURRAY TOLD YOU HE FELT A FEMORAL PULSE?

A           THAT’S CORRECT.

Q           OKAY.   AND TO THAT, AT THAT POINT IN TIME, NEITHER YOURSELF NOR ANY OTHER PARAMEDICS HAD INDICATED THEY FELT A PULSE; IS THAT CORRECT?

A           THAT’S CORRECT.

Q           OKAY.   ONCE YOU HEARD FROM DOCTOR MURRAY THAT HE CLAIMED TO HAVE FELT A PULSE, YOU HAD THE COMPRESSION STOP TO ESSENTIALLY MAKE SURE THIS WASN’T AN ARTIFICIALLY, AN ARTIFICIAL PULSE AS A RESULT OF COMPRESSIONS?

A           THAT WOULD BE CORRECT.

Q           OKAY.   AND THAT TAKES A COUPLE SECONDS TO DO WHAT YOU ARE DOING?

A           YES, SIR.

Q           OKAY.   SO YOU HAVE THE COMPRESSIONS STOP. THE ENDOTRACHEAL INTUBATION IS CONTINUING.   SO WE KNOW THE PATIENT IS GETTING AIR?

A           THAT’S CORRECT.

Q           AND THEN DID YOU PHYSICALLY FEEL FOR A FEMORAL PULSE?

A           YES, SIR, I DID.

Q           DID YOU FEEL A PULSE?

A           NO, SIR, I DID NOT.

Q           OKAY.   YOU WERE ALSO ASKED ABOUT THE CENTRAL LINE. NOW THE DEFENDANT, DOCTOR MURRAY, ASKED YOU TO DO OR COULD YOU DO A CENTRAL LINE?

A           YES, HE DID.

Q           OKAY.   DID DOCTOR MURRAY OFFER UP A CENTRAL LINE FROM SOME EQUIPMENT HE HAD?

A           NO, SIR.

Q           OKAY.   DID DOCTOR MURRAY, THE TREATING PHYSICIAN, OFFER UP MAGNESIUM FROM HIS EQUIPMENT?

A           NO, SIR.

Q           I WANT TO TALK ABOUT YOUR OBSERVATIONS REGARDING THE PATIENT IN YOUR OPINION BEING ILL. NO. 1, WHEN MR. LOW WAS ASKING YOU ABOUT YOUR OBSERVATIONS AND YOUR OPINION THAT THE PATIENT SEEMED ILL, AT WHAT POINT IN TIME DID YOU MAKE THAT OBSERVATION?

A           FIRST TWO SECONDS I WALKED INTO THE ROOM.

Q           OKAY.   AND WHEN YOU FIRST WALKED INTO THE ROOM, DID YOU SEE DOCTOR MURRAY, AT LEAST, HE IDENTIFIED HIMSELF AS THE PERSONAL DOCTOR OF THE PATIENT?

A           YES, SIR, I DID.

Q           THAT IS UNUSUAL?

A           THAT IS UNUSUAL, YES.

Q           YOU SAW AN I.V. STAND WITH SOME TYPE OF I.V. KIT?

A           YES, SIR.

Q           WAS THAT UNUSUAL IN A HOME SETTING LIKE THAT?

A           THAT IS VERY UNUSUAL IN A HOME SETTING.

Q           AND THEN WERE THOSE TWO IMPORTANT FACTORS THAT STANDING ALONE LED YOU TO BELIEVE YOU WERE DEALING WITH AN ILL PATIENT?

A           YES.

Q           OKAY.

A           ABSOLUTELY.

Q           AS FAR AS ACTUAL PHYSICAL OBSERVATIONS, YOUR IMMEDIATE PHYSICAL OBSERVATIONS OF THE PATIENT, YOU INDICATED HE WAS QUITE THIN, CORRECT?

A           YES, SIR.

Q           OKAY.   YOU HAVE SEEN THIN PATIENTS BEFORE?

A           YES, I HAVE.

Q           YOU HAVE SEEN OVERWEIGHT PATIENTS?

A           YES, I HAVE.

Q           AND THIS PATIENT SEEMED THIN TO YOU?

A           YES, SIR.

Q           OKAY.   HE SEEMED PALE?

A           YES, SIR.

Q           IS IT FAIR TO SAY THAT YOUR OPINION REGARDING THE HEALTH OR ILLNESS OF THIS PATIENT WAS BASED ON THE SURROUNDING CIRCUMSTANCES OF THE DOCTOR BEING PRESENT, THE I.V. STAND, THE OXYGEN BOTTLE, AS WELL AS THE THINNEST AND PALENESS OF THE PATIENT?

A           THAT WOULD BE —

MR. LOW:   OBJECTION.   LEADING, SIR.

THE COURT:   THE WITNESS IS AN EXPERT UNDER 801.OVERRULED.

MR. WALGREN:

Q           IS THAT ACCURATE?

A           THAT WOULD BE VERY ACCURATE.

Q           OKAY.

A           THE WHOLE PICTURE, ALL THE PIECES OF THE PUZZLE.

Q           OKAY.   AND AS FAR AS THE IMMEDIATE PHYSICAL OBSERVATIONS OF THE PATIENT AGAIN, IT WAS JUST THAT HE WAS QUITE THIN AND HE WAS PALE?

A           YES, SIR.

Q           OKAY.   AND IN FACT, WHAT YOU LEARNED BASED ON ALL YOUR TREATMENT AND THE EKG READINGS AND CAPNOGRAPHY IS, IN YOUR OPINION, THE PATIENT WAS DEAD, RIGHT?

A           YES, SIR.

Q           OKAY.   IS PALENESS CONSISTENT WITH SOMEONE WHO IS DEAD?

A          YES, SIR.

Q           SO YOU HAD NO OTHER INFORMATION, NO OTHER INDICATION OF ANY TYPE OF ILLNESS OR DRUG USAGE OR ANYTHING OTHER THAN THIS PATIENT IS THIN, THE OTHER PHYSICAL ITEMS YOU SAW, AND THE DEFENDANT TELLING YOU HE GAVE LORAZEPAM?

A           NO, I DID NOT HAVE ANY OTHER INDICATIONS THAT HE WAS A DRUG USER.

Q           OR ANY OTHER HEALTH ISSUE?

A           OR ANY OTHER HEALTH ISSUES.   NO, SIR.   IT’S JUST UNUSUAL TO SEE A DOCTOR IN SOMEONE’S HOME WITH THE I.V. AND AN OXYGEN BOTTLE AND THAT SORT OF THING.

Q          SO ON YOUR FIRST OBSERVATIONS, YOU ARE MAKING ASSUMPTIONS BASED ON WHAT YOU ARE OBSERVING IN THE ROOM?

A           YES, SIR.

Q           NOW YOU ARE ASKED TO ESTIMATE APPROXIMATELY HOW LONG — WELL, STRIKE THAT. YOU INDICATED YOU THOUGHT THAT IT WAS

INACCURATE WHEN DOCTOR MURRAY TOLD YOU THE PATIENT HAD JUST GONE DOWN AT THE TIME OF THE CALL. DO YOU REMEMBER THAT?

A           YES, SIR.

Q           OKAY.   AND YOU ESTIMATED HE COULD HAVE BEEN DOWN PROBABLY FOR 20 MINUTES?

A           YES, SIR.

Q           OKAY.   NOW IS IT FAIR TO SAY THERE ARE A LOT OF VARIABLES TO CONSIDER WHEN DETERMINING HOW LONG A PATIENT HAS BEEN DOWN?

A           YES, SIR, THERE ARE A LOT OF VARIABLES.

Q           OKAY.   AND FROM THE TIME YOU WERE ON-SCENE WITH THE PATIENT WHICH IS 12:26 P.M. ACCORDING TO YOUR TESTIMONY —

A           YES, SIR.

Q           — IS THERE A WINDOW OF TIME WHERE YOU WOULD FEEL MOST COMFORTABLE SAYING THE PATIENT HAD BEEN DOWN?

A           I WOULD SAY 20 MINUTES TO AN HOUR.

Q           AT ANYTIME, AT ANYTIME FROM THE POINT OF YOUR ARRIVAL AT THE PATIENT AT 12:26 P.M. UNTIL YOUR DELIVERY OF THE PATIENT TO UCLA PERSONNEL, DID YOU OR YOUR TEAM EVER ONCE FEEL, READ, OR OBSERVE A VIABLE HEART RHYTHM ON THAT PATIENT?

A           NO, SIR.

MR. WALGREN:   THANK YOU. NOTHING FURTHER, YOUR HONOR.

 

RECROSS-EXAMINATION

MR. LOW:

Q           AGAIN, SIR, YOU ALL GOT THERE SO QUICK THAT YOU ARRIVED ROUGHLY AROUND 12:26?   IS THAT ACCURATE?

A           YES, SIR.   WITHOUT LOOKING AT MY 902, THE MEDICAL REPORT, I WOULD SAY THAT’S CORRECT.

Q           AND ACCORDING TO — THE QUESTION THAT MR. WALGREN ASKED YOU TO AGREE WITH, YOU BELIEVE THAT THE PERSON MICHAEL JACKSON MAY HAVE BEEN IN THAT STATE FOR ABOUT HOW LONG, SIR?

A           20 MINUTES TO AN HOUR.

Q           SO IF YOU FOUND OUT MAYBE THAT THE, SOMEONE ASKED 911 OR ANSWERED A CALL BE MADE ROUGHLY AROUND 12:00, 12:05, 12:10, DOES THAT FIT WITHIN THE TIMELINE I AM TALKING ABOUT?

MR. WALGREN:   OBJECTION.   RELEVANCE.   IMPROPER HYPOTHETICAL.   NO FACTS. THE COURT:   I WILL OVERRULE THE OBJECTION. YOU MAY ANSWER IT.

THE WITNESS:   SO YOU ARE ASKING ME THAT WHEN THE 911 CALL WAS MADE HYPOTHETICALLY AT 12:05, WOULD THAT, COULD THAT HAVE FALLEN INTO MY RANGE OF POSSIBLE DEATH OCCURRING?   IS THAT WHAT YOU ARE ASKING ME?

MR. LOW:

Q           YES, SIR.

MR. WALGREN:   OBJECTION.   RELEVANCE.   THE 911 CALL, THAT IS ABSOLUTELY IRRELEVANT TO IMPOSE AND AN IMPROPER AND INACCURATE HYPOTHETICAL.

THE COURT:   OVERRULED.

THE WITNESS:   SURE.  12:05 COULD HAVE BEEN THE TIME OF ARREST.   SO IF A CALL WAS MADE RIGHT AT THE TIME OF ARREST, SURE.

MR. LOW:   THANK YOU. NOTHING FURTHER.

 

FURTHER REDIRECT EXAMINATION

 

MR. WALGREN:

Q           WHAT TIME WAS THE 911 CALL?   WAS IT 12:20 OR 12:21 P.M.? 12:21 P.M, I BELIEVE.

MR. WALGREN:   THANK YOU. NOTHING FURTHER.

 

FURTHER RECROSS-EXAMINATION

 

MR. LOW:

Q           THAT WAS ACTUALLY WHEN IT WAS TRANSFERRED TO YOU NOT WHEN IT WAS ACTUALLY MADE?   IS THAT ACCURATE?

A           IF YOU SHOW ME THE TELETYPE, I CAN TELL YOU EXACTLY WHAT THE TIME WAS THAT IT WAS TRANSMITTED TO US.

Q           YES, SIR. THAT IS MR. WALGREN ‘S EXHIBIT.   AND I WILL ASK HIM IF I CAN BORROW THAT FROM HIM IF I CAN SHOW IT TO YOU.

THE COURT:   IS THIS 18?

MR. WALGREN:   YES.

MR. LOW:   I BELIEVE IT IS, SIR.   I WILL LOOK AT THE STICKER.   IT SAYS 18, YES, SIR.   PEOPLE’S EXHIBIT 18 FOR IDENTIFICATION. MAY I APPROACH, SIR?

THE COURT:   YES.

MR. LOW:

Q           SIR, I AM SHOWING YOU PEOPLE’S EXHIBIT 18 FOR IDENTIFICATION. IS THAT THE TELETYPE YOU ASKED TO SEE?

A           THAT IS CORRECT.

Q           DOES THAT REFRESH — I’M SORRY. TAKE A MOMENT TO LOOK AT IT.

A           IT SHOWS THAT THE CALL WAS RECEIVED AT 12:21, AND WE WERE DISPATCHED AT 12:22.

Q           AND YOU ARE SO FAST, YOU GOT THERE 4 MINUTES LATER, 12:26?

A           YES, SIR.   IT’S A VERY EASY STREET TO FIND, AND IT’S CHOSE TO THE FIRE STATION.   WE ALL KNOW WHERE CAROLWOOD IS- –

MR. LOW:   THANK YOU, SIR. THAT’S IT.

COURT:   MR. WALGREN, YOU MAY CALL YOUR NEXT