0001
 1          IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
 2                        FOR THURSTON COUNTY
     ____________________________________________________________
 3   
     ADVANCED HEALTH CARE, INC,   ) 
 4                                 )
                  Plaintiff,       )
 5                                 )
           vs                     )     NO 07-2-00599-1
 6                                 )
     T ARTHUR GUSCOTT,            )
 7                                 )
                  Defendant       )
 8   _____________________________________________________________
 9                  DEPOSITION UPON ORAL EXAMINATION 
10                                 OF 
11                AMANDA CARMIER CICHANSKI, MN, RN
     _____________________________________________________________
12   
                         9:14 AM - 10:17 AM 
13   
                      Thursday, September 24, 2009
14   
                           920 Fawcett Avenue
15   
                           Tacoma, Washington
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23   LORRAINE M MILLAY, CCR/RPR
24   
25        Seattle Deposition Reporters, LLC * (206) 622-6661
0002
 1   APPEARANCES:
 2   
 3   FOR THE PLAINTIFF:      CHRISTOPHER J MARSTON
 4                           Attorney of Davies Pearson
 5                           920 Fawcett Avenue
 6                           Tacoma, Washington 98401
 7   
 8                           RICHARD S LOWELL
 9                           Attorney of Magnuson Lowell
10                           16398 NE 85th Street, Suite 200
11                           Redmond, Washington 98073-3037
12   
13   FOR THE DEFENDANT:      CARL A TAYLOR LOPEZ
14                           Attorney of Lopez & Fantel
15                           1510 14th Avenue
16                           Seattle, Washington 98122
17   
18   ALSO PRESENT:           RON BODE
19                           JULIANNE FERGUSON
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0003
 1                             I N D E X 
 2   EXAMINATION                                         PAGE 
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 4   Mr Lopez                                              4
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0004
 1                 BE IT REMEMBERED that on Wednesday,     
 2      September 24, 2009, at 9:14 am at 920 Fawcett Avenue, 
 3      Tacoma, Washington, before LORRAINE M MILLAY, Notary 
 4      Public in and for the State of Washington, appeared AMANDA 
 5      CARMIER CICHANSKI, MN, RN, the witness herein;
 6                 WHEREUPON, the following proceedings were had, 
 7      to wit:
 8   
 9   AMANDA CARMIER CICHANSKI,  having been first duly sworn by
10                              the Notary, testified as follows:    
11   
12                            EXAMINATION 
13   BY MR LOPEZ:
14   Q  Could you state your name and address, please?  
15   A  Amanda Carmier Cichanski, C-I-C-H-A-N-S-K-I  And my 
16      address is 4655 Lighthouse Drive Northeast, Tacoma, 98422  
17   Q  I have your CV and I'd like to ask you a few questions 
18      about it  I notice that from 2001 until the present you've 
19      been working as a legal nurse consultant, and could you 
20      tell me what you do in that capacity?  
21   A  I'm contacted by attorneys to review medical records  
22      Pretty much 99 percent of them have been long-term care  
23      Well, they're all geriatric in some manner, I should say  
24      But they're nursing homes, assisted living, adult family 
25      homes, some home health, I've had one or two hospitals  
0005
 1            The first part of it is to say was there a breach of 
 2      the standard of nursing, and then if they want me to be a 
 3      testifying expert then they ask me to do that  
 4   Q  Now in this case do you think there was a breach of the 
 5      standard of nursing that you saw from the records?  
 6   A  I don't believe that there was, no  
 7   Q  Do you have some criticisms of the nursing that you saw in 
 8      the records?  
 9   A  I think that there's -- there's always more documentation 
10      that nursing could do  I think that there's some areas 
11      that the communications between family -- Ms Edwards says 
12      that it's her usual practice to document, but I don't see 
13      that she's documented all of her communications with the 
14      family  
15   Q  What about with respect to the care plans that you saw?  
16   A  The care plans are pretty much standard for what you see in 
17      a home health -- actually, there's two types of home 
18      health  
19            So when I say home health, I'm not speaking to the 
20      Medicare, Medicaid certified end  The home health ca