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         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?
 

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         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 PRN?

        23    A     YES

        24    Q     PRN BASICALLY MEANS AS NEEDED?
 

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         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 PO  PRN

         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, PRN 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
 

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         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