118




         1

         2                       THE COURT:  GOOD AFTERNOON LADIES AND

         3           GENTLEMEN.  MR. LAYSER, YOU WERE CROSS EXAMINING

         4           DR. CRANE.

         5                       MR. LAYSER:  MAY I HAVE THE COURT

         6           REPORTER READ BACK THE LAST QUESTION?

         7                             - - -

         8           (WHEREUPON THE COURT REPORTER READ BACK THE LAST

         9           QUESTION.

        10                             - - -

        11    BY MR. LAYSER:

        12    Q.     BY THE WAY, DR. CRANE, YOU ARE SCHEDULED TO COME

        13    TO DELAWARE COUNTY IN MAY IN THE CASE OF VERELLA VERSUS

        14    DESANTIS (PHONETIC); IS THAT RIGHT?

        15    A.     I DON'T KNOW.

        16    Q.     YOU DIDN'T GET THAT TRIAL DATE YET?

        17    A.     NO.

        18    Q.     DO YOU HAVE THAT SECOND DR. SNYDER REPORT HANDY?

        19    A.     YES.

        20    Q.     I DON'T THINK I HAVE EVER GOTTEN A COPY OF THAT.

        21    I'M GOING TO MARK THAT D-8 FOR IDENTIFICATION.  I MAY

        22    HAVE SOME QUESTIONS FOR DR. GENNER TOMORROW.

        23                       THE COURT:  YOU'VE ALREADY PRE-MARKED

        24           OTHERS I TAKE IT IT?
 

                                                                   119




         1                       MR. LAYSER:  RIGHT.

         2                       THE COURT:  D-8 IS DR. SNYDER'S

         3           REPORT.

         4                       MR. LAYSER:  JULY 28TH, 1994

         5    BY MR. LAYSER:

         6    Q.     NOW, ON DIRECT YOU TALKED ABOUT PAIN ORDERS AND

         7    MEDICATION FOR PAIN; DO YOU RECALL THAT?

         8    A.     YES.

         9    Q.     YOU WERE SHOWN THIS BLOW-UP THAT LISTS THE

        10    DEMEROL AND VISTARIL?

        11    A.     YES.

        12    Q.     JUST SO I AM CLEAR, VISTARIL IS GIVEN WITH

        13    DEMEROL SO THAT THE EFFECTS OF DEMEROL CAN GET THROUGH A

        14    PATIENT'S SYSTEM AND RELIEVE THE PAIN; IT ENHANCES,

        15    AUGMENTS THE DEMEROL?

        16    A.     IT AUGMENTS -- DEMEROL CAN BE GIVEN ALONE, BUT

        17    VISTARIL AUGMENTS IT.

        18    Q.     BUT YOU DON'T GIVE VISTARIL ALONE?

        19    A.     YOU CAN.

        20    Q.     FOR PAIN?

        21    A.     NOT FOR PAIN.

        22    Q.     YOU POINTED OUT THAT ALL THESE ORDERS SAY P.R.N.?

        23    A.     YES.

        24    Q.     P.R.N. BASICALLY MEANS AS NEEDED?
 

                                                                   120




         1    A.     YES.

         2    Q.     SO A NURSE IS NOT GOING TO GIVE THESE INJECTIONS

         3    UNLESS THE PATIENT TELLS HER I AM IN PAIN.  I WANT A

         4    SHOT?

         5    A.     YES.

         6    Q.     ALSO, ON THE BOTTOM OF ORDER NUMBER TWO IT SAYS

         7    TYLENOL NUMBER THREE, ONE TO TWO TABS P.O.  P.R.N.

         8    TYLENOL NUMBER THREE IS AN ORAL MEDICATION?

         9    A.     YES.

        10    Q.     SO IF A PATIENT HAD REQUESTED A PAIN PILL HE

        11    WOULD HAVE GOTTEN THAT INSTEAD OF AN INJECTION?

        12    A.     YES.

        13    Q.     ONCE AGAIN, P.R.N. MEANS AS NEEDED?

        14    A.     YES.

        15    Q.     SO THE FACT IT SAYS EVERY THREE OR FOUR HOURS

        16    DOESN'T MEAN HE GOT PAIN MEDICATION EVERY THREE OR FOUR

        17    HOURS; IT ONLY MEANS HE MAY GET IT IF HE REQUESTS IT?

        18    A.     THAT'S RIGHT.  I THINK HE DID GET FROM A

        19    DIFFERENT PART OF THE RECORD THAT HE DID GET SOME

        20    DEMEROL AND VISTARIL.  THAT WAS MY IMPRESSION.

        21    Q.     IT'S NOT UNUSUAL TO GET DEMEROL OR VISTARIL,

        22    GIVEN THE TRAUMA AND SURGERY THAT HE HAD?

        23    A.     WELL, I THINK IT'S UNUSUAL FROM TWO WEEKS AFTER

        24    SURGERY TO STILL BE GETTING DEMEROL AND VISTARIL.  IT'S
 

                                                                   121




         1    POSSIBLE IT'S JUST FROM SURGERY THAT -- THE PAIN IS JUST

         2    FROM SURGERY, BUT THIS WAS TWO WEEKS AFTER SURGERY.

         3    Q.     THEN AN ORTHOPEDIST WOULD BETTER BE ABLE TO SAY

         4    HOW LONG THEY WOULD EXPECT THE PAIN?

         5    A.     YES.

         6    Q.     PAIN FROM AN INFECTION IS TYPICALLY DIFFERENT

         7    THAN PAIN FROM TRAUMA?

         8    A.     THAT MAY BE DIFFICULT FOR A PATIENT TO DETERMINE.

         9    PAIN IS PAIN.  WHAT I AM TALKING ABOUT IS DEEP PAIN IN

        10    THE JOINT, COMING FROM THE JOINT.

        11    Q.     IF YOU HAVE DEEP PAIN IN THE JOINT YOU ARE GOING

        12    TO HAVE TROUBLE MOVING YOUR JOINT ON TH