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ShruthiNairCOURT OF COMMON PLEAS
PHILADELPHIA COUNTY
SEPTEMBER TERM, 2022
NO.0839
E.O. a Minor, by his ) DEPOSITION UPON
Parents & Natural )
Guardians, JACE & ) ORAL EXAMINATION
NANCY OLIVERSON, )
) OF
Plaintiffs, )
) NANCY OLIVERSON
- vs - )
)
LITTLE LEAGUE BASEBALL, )
INC., and JOHN SAVOY & )
SON, INC., d/b/a SAVOY )
CONTRACT FURNITURE, )
)
Defendants. )
)
- - - - - - - - - - - - - -
TRANSCRIPT OF VIDEOTAPED DEPOSITION,
taken by and before KATHLEEN MURTAUGH,
Professional Reporter and Notary Public, via ZOOM
CONFERENCING, on Monday, October 14, 2024,
commencing at 10:03 a.m.
ERSA Court Reporters
30 South 17th Street
United Plaza - Suite 1520
Philadelphia, PA 19103
(215) 564-1233
2
A P P E A R A N C E S:
FULGINITI LAW
BY: KEN FULGINITI, ESQUIRE
One Commerce Square
2005 Market Street
Suite 910
Philadelphia, Pennsylvania
Attorneys for the Plaintiffs
McCORMICK LAW FIRM
BY: BRIAN J. BLUTH, ESQUIRE
and
BY: WILLIAM E. BANEY, ESQUIRE
835 West Fourth Street
Williamsport, Pennsylvania 17101
and
MARSHALL, DENNEHEY, WARNER,
COLEMAN & GOGGIN
BY: THOMAS WAGNER, ESQUIRE
2000 Market Street
Suite 2300
Philadelphia, Pennsylvania 19103
Attorneys for the Defendant,
Little League Baseball, Inc.
MARGOLIS EDELSTEIN
BY: JOHN A. LIVINGOOD, JR., ESQUIRE
The Curtis Center
170 S. Independence Mall West
Suite 400E
Philadelphia, Pennsylvania 19106
Attorneys for the Defendant,
John Savoy & Son, Inc., d/b/a Savoy
Contract Furniture
A L S O P R E S E N T:
LUKE SIMPSON, Videographer
3
I N D E X
WITNESS PAGE
NANCY OLIVERSON
By: Mr. Bluth 4,279
By: Mr. Livingood 261
E X H I B I T S
PAGE PAGE
NUMBER DESCRIPTION MARKED ATTACHED
116 Office Notes dated
12/20/22 N/A 286
119 Post-Concussion
Symptoms Checklist
dated 2/21/23 N/A 287
122 Correspondence dated
12/18/23 N/A 288
126 Ambulatory Intake
Forms dated 5/22/24 N/A 289
130 Operative Note dated
12/18/19 37 290
131 Occupational Therapy
Forms 118 291
132 Office Clinic Notes
dated 12/23/22 154 292
4
INDEX (CONT.)
E X H I B I T S
PAGE PAGE
NUMBER DESCRIPTION MARKED ATTACHED
133 Office Clinic Notes
dated 1/23/24 159 293
134 Speech Therapy Forms
dated 3/30/23 173 294
135 Physical Therapy
Forms 179 295
136 Records dated
4/27/23 201 296
5
1 (By agreement of counsel,
2 the signing, sealing, filing, and
3 certification are waived; and all
4 objections, except as to the form of
5 the question, are reserved until the
6 time of trial.)
8 THE VIDEOGRAPHER: The time
9 is now 10:03 a.m. Eastern. The
10 following is a videotaped deposition
11 via Zoom.
12 My name is Luke Simpson from
13 ERSA Court Reporting in Philadelphia,
14 Pennsylvania.
15 This deposition is being
16 taken on Monday, October 14th, 2024,
17 scheduled for 10:00 a.m.
18 This video deposition is for
19 the Court of Common Pleas of
20 Philadelphia County, No. 220900839, in
21 the case of E.O., a minor, by his
22 parents and natural guardians, Jace and
23 Nancy Oliverson versus Little League
24 Baseball, Inc., et al.
6
1 Present for the taking of
2 this videotaped deposition is: The
3 deponent, Nancy Oliverson.
4 All counsel present will be
5 noted on the stenographic record.
6 The court reporter is
7 Kathy Murtaugh of ERSA. The court
8 reporter will now swear in the witness.
9 THE COURT REPORTER: Nancy,
10 will --
11 MR. FULGINITI: Before we do
12 that, sorry, Tom, who are you here for?
13 I apologize for not knowing all counsel
14 of record.
15 MR. WAGNER: Not at all.
16 Good to see you again, Ken. I am also
17 here for Little League Baseball, but I
18 do not intend to participate in the
19 deposition. I am really just
20 listening. Mr. Bluth was intending to
21 introduce me.
22 MR. FULGINITI: Okay. Thank
23 you.
24 MR. WAGNER: You're welcome.
7
1 THE VIDEOGRAPHER: Kathy.
2 THE COURT REPORTER: Nancy,
3 will you raise your right hand to be
4 sworn.
5 Do you swear the testimony
6 you are about to give in this matter
7 will be the truth, the whole truth, and
8 nothing but the truth, so help you God?
9 THE WITNESS: Yes.
10 THE COURT REPORTER: Thank
11 you.
12 THE VIDEOGRAPHER: The time
13 is now 10:05. We will now begin
14 questioning.
15 EXAMINATION BY MR. BLUTH:
16 Q. Good morning, ma'am. Can you hear me
17 okay?
18 A. I can.
19 MR. LIVINGOOD: The usual
20 stipulations? I am not sure we did
21 that yet --
22 THE COURT REPORTER: No.
23 MR. LIVINGOOD: -- just to
24 make sure.
8
1 THE COURT REPORTER: Yeah.
2 Thank you.
3 MR. LIVINGOOD: Yes.
4 MR. BLUTH: Usual
5 stipulation?
6 MR. LIVINGOOD: Is that okay
7 with everybody?
8 MR. BLUTH: Is it okay with
9 you, Ken?
10 MR. FULGINITI: Yes.
11 MR. LIVINGOOD: Yes.
12 BY MR. BLUTH:
13 Q. Ma'am, can you hear me okay?
14 A. I can.
15 Q. Wonderful. My name is Brian Bluth. I
16 am a lawyer in Pennsylvania, and I represent
17 Little League Baseball in the lawsuit that you
18 and your husband have brought over Easton's
19 accident in August 2022 and the injuries that he
20 has been dealing with since then.
21 I am here today with Tom Wagner and
22 William Baney, my associate.
23 A couple of ground rules to make the
24 Zoom deposition go much easier. First off, this
9
1 deposition is being recorded in two ways.
2 The official record of the deposition
3 is being made by the court reporter, who is
4 transcribing everything that we say, and you will
5 have an opportunity to review that transcript
6 after it is prepared, and it is also being video
7 recorded, and can be shown or pieces of it can be
8 shown at the trial of this matter.
9 Part of transcript is -- the written
10 transcript is the official recording of the
11 deposition.
12 And so, it is important that all of
13 your answers be verbal, so that the court
14 reporter can take an -- an accurate recording of
15 what we are all saying.
16 And although in the course of normal
17 conversation, it may be routine for you to use
18 non-verbal responses, such as an uh-huh or uh-uh,
19 or a shake of the head and the hands, and because
20 of the video, we may all have an understanding as
21 to what you mean in terms of a response, if you
22 do that, I or one of the other lawyers may ask
23 you to clarify your response for purposes of the
24 written record, and we mean no disrespect if we
10
1 do that. We just want to make sure that we have
2 a clear understanding of your answers to each of
3 the questions as we proceed.
4 A. Okay.
5 Q. It is important that you hear and
6 understand all of the questions before answering,
7 and that could be a little trickier over this
8 Zoom setting than had we been sitting across a
9 conference room table.
10 But for any reason or at any time, you
11 don't hear the complete question that is posed to
12 you, or, for whatever reason, you don't
13 understand the question that you are being asked,
14 please let us know, and we will repeat the
15 question or rephrase the question or do whatever
16 has to been done to make sure that the question
17 is fully heard and understood by you before you
18 answer. Is that okay with you, ma'am?
19 A. Okay.
20 Q. And for each question for which you
21 answer, we will assume that you've heard and
22 understood the question and are answering
23 truthfully consistent with the oath that the
24 court reporter just administered to you. Okay,
11
1 ma'am?
2 A. Okay. Okay.
3 Q. I don't know how long we will be here,
4 but it will likely be several hours. You are
5 welcome to take a break at any time for any
6 reason, including to talk to your lawyer.
7 The only thing that I would ask is that
8 if you wish to take a break, and there is a
9 question pending, that you will answer the
10 pending question before we take our break. Is
11 that okay --
12 A. Okay.
13 Q. -- with you?
14 A. Yes.
15 Q. The other warning that I will give you
16 is that Zoom can get a little bit tricky. So,
17 if, for whatever reason, you are having any
18 trouble hearing or understanding us, because of
19 the Internet link or anything of that nature,
20 please let us know, and we will work through that
21 before we continue with the deposition.
22 A. Okay.
23 Q. Finally, we have the potential to ask
24 lots of questions about lots of details of events
12
1 that happened over two years ago, and nobody
2 wants you to guess.
3 So, if you know the answer to a
4 question, or can reasonably estimate the answer
5 to a question, please do that, but this isn't
6 meant to be questions that are tricky or
7 confusing, and if a truthful answer to any of our
8 questions is that you don't know or you don't
9 remember, just let us know, and that is fine.
10 Nobody is looking to make up facts. We
11 just want to know what you remember and what you
12 understand from events that happened in August of
13 2022, and with respect to Easton's medical care,
14 events that might precede that or had come after
15 that. Okay, ma'am?
16 A. Okay.
17 Q. Thank you. Can you please state your
18 full name?
19 A. Nancy Genevieve Oliverson.
20 Q. And your current address?
21 A. 1951 West 510 North, St. George, Utah
22 84770.
23 Q. And is that the address at which you
24 are sitting right now?
13
1 A. Yes.
2 Q. Okay. And are you in a room by
3 yourself?
4 A. Yes.
5 Q. Okay. Do you have any papers or any
6 other materials related to the lawsuit in front
7 of you?
8 A. Yes.
9 Q. And what do you have?
10 A. I have some notes.
11 Q. Okay. And --
12 A. So that I can review once everything is
13 off.
14 Q. I'm sorry. I don't understand that.
15 What do you mean when you say notes you can
16 review once everything is off?
17 A. I have some notes written down so that
18 when we take breaks, that I can review these
19 notes.
20 Q. And what's -- are these notes that you
21 took for yourself?
22 A. Yes.
23 Q. And when did you do that?
24 A. The last week.
14
1 Q. And describe for me generally what
2 types of notes did you take for yourself?
3 A. Just notes of key points that I want to
4 make sure to explain.
5 MR. BLUTH: All right. Ken,
6 is that something you'd share with us
7 after the deposition?
8 MR. FULGINITI: Sure.
9 BY MR. BLUTH:
10 Q. Okay. I may ask some questions about
11 that as we go.
12 Other than notes to yourself, ma'am,
13 do you have any other documents in front of you?
14 A. No.
15 Q. Is anyone else in the house at this
16 point?
17 A. My daughter, Blakely.
18 Q. Okay. Anyone other than you and
19 Blakely in the house?
20 A. Not at that point.
21 Q. Your date of birth, please?
22 A. 11/6/86.
23 Q. And are you married?
24 A. Yes.
15
1 Q. My understanding is you are married to
2 Jace Oliverson?
3 A. Yes.
4 Q. And what was the date of your marriage?
5 A. 12/20 of 2009.
6 Q. Have you had any other marriages other
7 than to Jace?
8 A. No.
9 Q. My understanding --
10 A. You know what, I take that back. The
11 year is 2008.
12 Q. Okay.
13 A. Not 2009.
14 Q. I appreciate that. And that prompts me
15 to give you one other instruction, and that is
16 that at any point in the deposition, if you
17 recall that an answer that you previously gave is
18 either incorrect or incomplete, and you would
19 like to supplement that, please let us know, and
20 we will be happy to allow you that opportunity.
21 A. Okay.
22 Q. You and Jace have three children; is
23 that correct?
24 A. Yes.
16
1 Q. Your oldest is Easton?
2 A. Yes.
3 Q. And his date of birth, please?
4 A. 4/26/2010.
5 Q. And then you have another son. Your
6 middle child is Brogan?
7 A. Yes.
8 Q. And his date of birth, please?
9 A. 5/23/2012.
10 Q. And your youngest child is Blakely, as
11 you just mentioned, your daughter, and her
12 birthday, please?
13 A. 12/10/15.
14 Q. Oh, so, Brogan is the youngest. Oh,
15 no. Blakely -- Blakely is the youngest?
16 A. Yes.
17 Q. Got it. All right. And what grade is
18 Easton presently in?
19 A. Ninth grade.
20 Q. And what grade is Brogan presently in?
21 A. Seventh grade.
22 Q. And what grade is Blakely presently in?
23 A. Third grade.
24 Q. Today is Columbus Day. Is today a
17
1 school day for your children?
2 A. Yes.
3 MR. FULGINITI: Indigenous
4 People Day, by the way.
5 MR. BLUTH: What was that,
6 Ken?
7 MR. FULGINITI: It's
8 Indigenous People Day.
9 MR. BLUTH: I stand
10 corrected. I'm sorry.
11 BY MR. BLUTH:
12 Q. Your education history, ma'am, starting
13 with high school and up to any post high school
14 education and degrees that you attained.
15 A. I do have a high school diploma and
16 some college.
17 Q. Okay. And where did you go to high
18 school?
19 A. South Whidbey High School.
20 Q. I'm sorry, ma'am. I didn't hear that.
21 A. South Whidbey High School.
22 Q. And what year did you graduate?
23 A. 2005.
24 Q. Was that a general education high
18
1 school diploma?
2 A. Yes. A public school diploma.
3 Q. And then you mentioned that you have
4 some college. Where did you go to college?
5 A. Southern Utah University.
6 Q. And did you pursue any particular field
7 of study at Southern Utah University?
8 A. Yes.
9 Q. And what? What field of study, or what
10 major did you pursue?
11 A. Hotel, Resort and Hospitality
12 Management.
13 Q. And for which years did you attend
14 classes at Southern Utah University?
15 A. I attended classes there from 2005 to
16 2000 -- on and off until 2010 when Easton was
17 born.
18 Q. Okay. And how many credits did you
19 attain?
20 A. I am not sure. I believe I was a
21 junior.
22 Q. Did you attain or receive any degrees
23 or certifications from Southern Utah University?
24 A. No.
19
1 Q. Okay. Since high school, have you
2 attended any education at any other center,
3 college or university?
4 A. No.
5 Q. Can -- can you please summarize for me
6 your work history since your graduation from high
7 school?
8 A. Yes. I started working at a hotel in
9 Cedar City in 2006, and then I continued working
10 at various hotel properties in Cedar City and in
11 St. George.
12 Q. And when was the last time that you
13 worked?
14 A. I would say probably the year 2015.
15 Q. Did you take time off from work between
16 2010 and '15, as your three children were born?
17 A. Yes.
18 Q. Did you work continuously from 2006
19 until 2010 when Easton was born?
20 A. No. Well, okay. Sorry. I did work
21 from 2010 -- 2006 to 2010. After Easton was born
22 and then until Blakely was born, there were some
23 gaps in there.
24 Q. Okay. What types of jobs did you do
20
1 when you worked for the hotels that you've
2 mentioned?
3 A. I worked at the front desk, and then
4 eventually front office management.
5 Q. When did you start working in a front
6 office management position?
7 A. In 2008, I believe.
8 Q. Prior to that, whenever it was, is
9 it -- is my understanding correct that your work
10 responsibilities were as a front desk attendant?
11 A. Yes, customer service representative.
12 Q. Okay. And then what types of duties
13 would you perform when you transitioned into a
14 front office management position?
15 A. I would train the staff. I would make
16 sure -- I would make the schedules. When
17 management -- when higher management wasn't on,
18 wasn't working, I was in charge of resolving
19 problems.
20 Q. Okay. Anything else that you recall of
21 your job duties from a front office management
22 position?
23 A. No.
24 Q. Did you ever have a job title or a role
21
1 consistent with a general manager of any
2 particular property?
3 A. No.
4 Q. In all of your jobs as working for a
5 hotel at the various places that you worked, did
6 you always have an on-site manager that you
7 reported to?
8 A. No.
9 Q. When you did not have an on-site
10 manager that you reported to, to whom did you
11 report?
12 A. If I didn't have a manager on-site, I
13 was the one in charge. So, if I needed to
14 communicate with them, I would just give them a
15 phone call.
16 Q. Okay. Let me try to clarify my
17 question. When I -- when I meant an on-site
18 manager, I meant somebody whose principal working
19 location was at the same hotel that you were
20 working at as opposed to some corporate office
21 someplace.
22 So, although you may not have been
23 working the same shift or at the same time as
24 that manager, that person's primary
22
1 responsibility would have been at that same site
2 that you were working.
3 A. Yes.
4 Q. So, with that as clarification, let me
5 just ask my question again. In each of the jobs
6 that you had as a front office management -- in
7 front office management, is the person to whom
8 you reported, did that person always work, as a
9 primary work site, at the same hotel that you
10 were at?
11 A. Yes. There was a general manager
12 on-site.
13 Q. Okay. What was the name of the hotel
14 that you last worked in 2015?
15 A. The Courtyard by Marriott, and also the
16 TownePlace Suites by Marriott.
17 Q. And where was each of those hotels
18 located?
19 A. St. George, Utah.
20 Q. Both of them?
21 A. Yes.
22 Q. Do you remember the address of The
23 Courtyard by Marriott?
24 A. I do not.
23
1 Q. Do you remember the address of the
2 TownePlace Suites?
3 A. I do not.
4 Q. Ma'am, I ask the following two
5 questions of any -- of everybody. So, I don't
6 want you to take any personal offense.
7 The first one is: Are you currently
8 taking any medications or drugs that would impact
9 your ability to recall events and testify
10 truthfully?
11 A. No.
12 Q. The second one is: Have you ever been
13 convicted or pled guilty of any crime, not
14 including any traffic or motor vehicle-related
15 offenses?
16 A. No.
17 Q. Other than the notes to yourself that
18 you have in front of you and that we will talk
19 about over the course of the deposition, did you
20 at any other time take any other notes or make
21 any other recordings or memorializations of the
22 events involving Easton's accident and his
23 injuries and recovery thereafter?
24 A. I did vaguely have a journal while
24
1 Easton was in the hospital.
2 Q. Do you still have that journal?
3 A. I don't know if I have it or if we have
4 given it to Ken. I'm not sure.
5 Q. Okay. When was the last time you saw
6 that journal?
7 A. I would say September 15th of 2022.
8 Q. In other words, is it fair to say that
9 the last time you saw that journal was shortly
10 after Easton was discharged as an inpatient from
11 a hospital?
12 A. Yes.
13 Q. What types of information would you
14 record in that journal?
15 A. My feelings, my thoughts.
16 Q. Anything -- anything in the journal
17 that would be related to Easton's injuries, his
18 medical care, and things of -- things
19 specifically related to Easton?
20 A. I haven't gone back and read those
21 entries, because it's very difficult for me. So,
22 I'm not sure exactly what is written in there,
23 because it's just difficult for me to go back and
24 do that, but it was just my raw feelings at that
25
1 moment.
2 Q. I understand. Have you made any
3 entries in the journal since Easton was
4 discharged as an inpatient from a hospital?
5 A. No.
6 Q. Since Easton was discharged as an
7 inpatient from a hospital, have you made any
8 other notes or memorializations or made entries
9 in any calendar about either Easton's course of
10 care and treatment, or how you were feeling in
11 the period of time since his discharge from the
12 hospital?
13 A. No.
14 Q. Do you know whether Jace has made any
15 such recordings for himself of the same nature?
16 A. No.
17 Q. In other words, you do not know one way
18 or the other, or do you know that Jace has not
19 done that?
20 A. I don't know if Jace has done that.
21 Q. Other than your notes that you made to
22 yourself within the last week, did you review any
23 other documents in preparation for today's
24 deposition?
26
1 A. Yes.
2 Q. What did you review?
3 A. I reviewed Jace's deposition.
4 Q. Okay. You read his transcript?
5 A. Yes.
6 Q. Okay. Have you looked at anything else
7 for purposes of preparation for today's
8 deposition?
9 A. I also looked at the exhibits of his
10 deposition.
11 Q. Okay. Anything else?
12 A. No.
13 Q. Other than the excerpts of Easton's
14 medical records that were used at Jace's
15 deposition and attached as exhibits, did you look
16 at any other of Easton's medical records for
17 purposes of preparing for today's deposition?
18 A. No.
19 Q. Have you ever looked at Easton's
20 medical records since his accident and injury on
21 August 15th, 2022?
22 A. I have looked at some records that I
23 have access to via the My Health app.
24 Q. Okay.
27
1 A. But those are just vague records, I
2 would -- when he would get labs done, I would log
3 on to see the lab results before they told them
4 to us.
5 Q. Okay. When was the last time, other
6 than as attached to Jace's deposition transcript,
7 that you last looked at any of Easton's medical
8 records?
9 A. I don't recall.
10 Q. Do you believe that you would have done
11 that in the last year?
12 A. Yes.
13 Q. And, again, other than records attached
14 to Jace's deposition transcript, which of
15 Easton's medical records do you believe that you
16 would have looked at in the last year?
17 A. Just general -- he didn't really see
18 many doctors in the last year. So, just general
19 things when he went and saw his primary care
20 doctor.
21 Q. Okay. We might look at some of those
22 notes over the course of today.
23 A. Okay.
24 Q. Do you have any formal training in any
28
1 medical field, and by that I include CPR, EMT,
2 first-aid, anything like that?
3 A. I'm sure that it is expired, but, at
4 one point, I was CPR trained in order for my
5 front office manager position.
6 Q. Okay. Have you gotten any CPR --
7 formal CPR training since you left that
8 employment in 2015?
9 A. No.
10 Q. All right. Any other medical training
11 that you've had, other than CPR training?
12 A. No.
13 Q. Who, in your household, if there is
14 only one particular person, manages the family's
15 finances?
16 A. Jace.
17 Q. Do you have any role in that, or do you
18 pretty much leave it up to Jace?
19 A. I leave it up to Jace.
20 Q. Do you have any understanding, and if
21 you don't, that is -- just let us know, but do
22 you have any understanding of what your annual
23 household income is?
24 A. I don't.
29
1 Q. Do you have any understanding of the
2 sources of income that comprise your household's
3 income?
4 A. Yes.
5 Q. And from what sources of income does
6 your household income derive?
7 A. From Oliverson's Services.
8 Q. And that is Jace's landscaping
9 business?
10 A. Yes.
11 Q. Other than from Jace's landscaping
12 business, within the last two years, does your
13 family have any income from any other source?
14 A. No.
15 Q. Does Easton have health insurance?
16 A. Yes.
17 Q. Do you know who the health insurer is?
18 A. Select Health.
19 Q. And for how long has Select Health been
20 Easton's health insurer?
21 A. I would say ten years.
22 Q. Is that a -- just because I'm
23 unfamiliar with how things might work in Utah, is
24 that a Medicaid product, or is that a privately
30
1 purchased health plan?
2 A. It is a Medicaid product. It is called
3 Select Health Community Care.
4 Q. Let's say from August of 2022 to the
5 present, has Easton had any health insurance
6 benefit from any source other than Select Health
7 Community Care?
8 A. No.
9 Q. Is that -- as a Medicaid product, do
10 you know whether that is a health insurance plan
11 administered by the State of Utah?
12 A. Yes, it is.
13 Q. Since Easton's accident in August of
14 2022, has your family had to pay any money out of
15 pocket for Easton's medical care, medications,
16 procedures, treatment, anything like that?
17 A. No.
18 Q. So, to the extent that Easton's care
19 has been covered and paid for by Select Health
20 Community Care, is your understanding that the
21 family has had no personal financial contribution
22 towards Easton's care?
23 A. I mean, we -- we do a lot outside of
24 the medical care, so...
31
1 Q. And we'll talk about that, but for
2 right now, we're only talking -- I am only asking
3 you about his medical care or medications.
4 MR. FULGINITI: I'm sorry.
5 His medical care or medications?
6 MR. BLUTH: Or medications,
7 right.
8 THE WITNESS: No. We have
9 not had to pay for medical care or
10 medications.
11 BY MR. BLUTH:
12 Q. We know, obviously, that Easton had
13 medical care in Pennsylvania before he was
14 transferred back home to Utah at the end of
15 August in 2022. Do you know whether the medical
16 care Easton received in Pennsylvania was covered
17 to any degree by Select Health Community Care?
18 A. I don't know.
19 Q. Have you or has Jace, to your
20 knowledge, received any medical bills either from
21 UPMC Williamsport, which is the hospital that
22 Easton went to right from the Little League
23 complex, or from Geisinger Medical Center, which
24 is the hospital to which he was transferred and
32
1 ultimately had two surgeries?
2 A. We have not.
3 Q. Okay. I would like to talk a little
4 bit about Easton's medical history prior to his
5 accident on August 15th, 2022.
6 A. Okay.
7 Q. When you were pregnant with Easton, did
8 you have any complications or problems, other
9 than routine prenatal care?
10 A. No.
11 Q. To your knowledge, were there any
12 issues with your labor and delivery of Easton at
13 the time of childbirth?
14 A. No.
15 Q. Other than what you, as his mother,
16 would describe as normal childhood illnesses, did
17 Easton have any other major childhood medical
18 issues?
19 A. No.
20 Q. I know Easton had, at some point in
21 time, a tonsillectomy and his adenoids removed in
22 December of 2019. Other than that, did Easton
23 have any surgeries prior to August of 2022?
24 A. He did, I believe at two years old,
33
1 have a scope done.
2 Q. Okay. Do you know what the purpose of
3 that procedure was?
4 A. He -- I think he was spitting up a lot
5 as a child. So, the doctor wanted to make sure
6 his esophagus was healthy.
7 Q. So, that was a scope that the doctors
8 put in his mouth and down his esophagus --
9 A. Correct.
10 Q. -- into his stomach?
11 A. Correct.
12 Q. Other than that scope that you
13 described and the tonsillectomy and adenoid
14 removal that I saw in his records, did Easton
15 have any surgeries prior to August of 2022?
16 A. No.
17 Q. Prior to August of 2022, did Easton
18 have any injuries in which he sustained any
19 broken bones?
20 A. Yes.
21 Q. And what did Easton have prior to
22 August of 2022?
23 A. He broke his left wrist.
24 Q. Okay. And when did he do that?
34
1 A. 2019. That's a guess.
2 Q. Even if you don't remember the specific
3 year in which that broken wrist occurred, do you
4 remember how old Easton was when it happened?
5 A. Nine or ten.
6 Q. All right. Other than the broken wrist
7 at ages nine -- at age nine or age ten, did
8 Easton suffer any other injuries prior to August
9 2022 in which he sustained any broken bones?
10 A. No.
11 Q. Prior to August 2022, had Easton
12 sustained any head injury?
13 A. No.
14 Q. Prior to August 2022, did Easton ever
15 suffer from a concussion?
16 A. No.
17 Q. Prior to 2022, and other than the scope
18 at age two, the tonsillectomy, and the left
19 wrist, did Easton have any other medical issues
20 that required treatment beyond going to his
21 pediatrician?
22 A. No.
23 Q. Prior to August 2022, had Easton ever
24 seen a pediatric neurologist?
35
1 A. No.
2 Q. For any reason?
3 A. No.
4 Q. Prior to August 2022, had Easton seen a
5 neurosurgeon for any reason?
6 A. No.
7 Q. Who is Easton's current pediatrician?
8 A. Dr. Kaddu.
9 Q. And that is the pediatrician that
10 Easton has seen from prior to the injury in
11 August of 2022?
12 A. Yes.
13 Q. Okay. Other than the head injury
14 Easton suffered on August 15, 2022, has Easton
15 had any other head injuries since from any
16 incident that might be unrelated to what happened
17 at the Little League complex?
18 A. No.
19 Q. Other than Dr. Kaddu, who else, if
20 anyone, is Easton treating with on a routine
21 basis at present?
22 A. Dr. Kaddu is the only doctor.
23 Q. When was the last time that Easton saw
24 a medical doctor for any reason, other than
36
1 Dr. Kaddu or a provider in the pediatrician's
2 office?
3 A. Are you asking me when was Easton's
4 last appointment with Dr. Kaddu?
5 Q. No. Although I appreciate that you
6 asked for clarification.
7 My question is: When was the last time
8 that Easton saw a medical doctor, other than his
9 pediatrician?
10 A. He saw Dr. Flavin.
11 Q. Okay. And do you --
12 A. And, I believe, that was towards the
13 beginning of the year.
14 Q. Okay. We will talk about Dr. Flavin
15 and his appointments with her as we go through
16 this, and we will talk in more specificity than
17 about his most recent appointments. But --
18 A. Okay.
19 Q. But in terms of medical doctors, other
20 than his pediatrician that Easton has seen, is
21 your understanding that the last one would have
22 been Dr. Flavin regardless of when that
23 appointment took place?
24 A. Yes.
37
1 Q. Okay. When was the last time Easton
2 saw Dr. Kaddu?
3 A. For his well child check in May, I
4 believe.
5 Q. And we'll look at that appointment as
6 well. As we sit here today, does Easton have any
7 scheduled appointments with any medical doctor?
8 A. No.
9 Q. Prior to Easton's accident and the
10 injuries in August 2022, did he have any
11 difficulty sleeping?
12 A. Not that I am aware of. He -- once he
13 fell asleep, he stayed asleep.
14 Q. Did Easton have any problems prior to
15 August 2022 falling asleep?
16 A. No.
17 Q. I want to show you two records. I
18 think the first one we will mark as Exhibit-130,
19 assuming that is what we are up to.
20 (At this time, Operative
21 Note dated 12/18/19 was marked for
22 identification as Exhibit-130.)
23 BY MR. BLUTH:
24 Q. And this is going to require that I
38
1 have some technical skills. So, bear with me for
2 a moment, please. All right. Can you see this
3 record, ma'am?
4 A. Yes.
5 Q. Okay. This is an operative note, as it
6 says at the top, from Dr. Vaughan, who I
7 understand is an ENT surgeon, ear, nose and
8 throat surgeon. Do you know Dr. Vaughan?
9 A. Yes.
10 Q. Okay. And as the record suggests, this
11 is related to his tonsillectomy and -- Easton's
12 tonsillectomy and adenoidectomy in 2019. Do you
13 see that?
14 A. Yes.
15 Q. Okay. There's a statement here that
16 says, Easton -- he, Easton, has also had
17 difficulty sleeping, difficulty during the day,
18 and having nighttime sleep tremors. Do you see
19 that?
20 A. Yes.
21 Q. Do you know how Dr. Vaughan would have
22 learned of this information?
23 A. I don't know.
24 Q. Prior to Easton's 2019 procedure with
39
1 Dr. Vaughan, did you have any discussion with
2 Dr. Vaughan?
3 A. Yes.
4 Q. Did you provide this information to
5 Dr. Vaughan?
6 A. I did not. Easton got his tonsils
7 taken out because he got strep throat frequently.
8 Q. Okay. Did you take Easton to his
9 procedure with Dr. Vaughan on the date indicated,
10 December 18th, 2019?
11 A. I did.
12 Q. Okay. Did any other family members
13 accompany you and Easton to this surgery?
14 A. Yes.
15 Q. Who else was with you?
16 A. Jace came with us, and Brogan had a
17 tonsillectomy at the same time.
18 Q. Oh, wow. So, you had two kids had this
19 procedure on the same day?
20 A. Yes.
21 Q. Okay. Did Jace provide this
22 information to Dr. Vaughan about difficulty
23 sleeping and having nighttime sleep terrors?
24 A. I don't know.
40
1 Q. How do you know, as you sit here today,
2 that you did not provide this information to
3 Dr. Vaughan?
4 A. Because I don't remember him ever
5 having sleep terrors.
6 MR. BLUTH: Okay. I will
7 take this down for now. I'm going to
8 put up what has been previously marked
9 as 116. Hold on. Let me get my
10 bearings here. Give me one moment,
11 please.
12 MR. LIVINGOOD: If you need
13 help, I can pull it up, if you are
14 having trouble.
15 MR. BLUTH: No. I got it.
16 MR. LIVINGOOD: I am trying
17 to serve some purpose here.
18 MR. BLUTH: I'm sure you'd
19 be successful in doing that, and I may
20 need your help at some point, but not
21 right now.
22 I will be first to
23 acknowledge that I am a little slow at
24 the technology. All right. Share
41
1 screen.
2 BY MR. BLUTH:
3 Q. All right. Ma'am, can you see this
4 record?
5 A. I can.
6 Q. Okay. This is a note from Dr. Flavin.
7 You can see the date at the top as 12/20/2022.
8 So, this is after -- this is after Easton's
9 accident while he was treating with Dr. Flavin.
10 Do you see that, ma'am?
11 A. Yes.
12 Q. Okay. And there's a comment here under
13 sleep, that says sometimes has difficulty falling
14 asleep, but this was the case prior to his
15 injury. Do you see that?
16 A. I do.
17 Q. Did you accompany Easton to this visit
18 with Dr. Flavin on December 20, 2022?
19 A. Yes.
20 Q. Did you accompany Easton to all of his
21 medical appointments since his head injury in
22 August of 2022?
23 A. No.
24 Q. Okay. But you recall that you were at
42
1 this one?
2 A. Yes.
3 Q. Were you the source of information to
4 Dr. Flavin that is recorded in this note that
5 Easton was sometimes having difficulty falling
6 asleep, but this was the case prior to his
7 injury?
8 A. No.
9 Q. Okay. And how do you know that you
10 were not?
11 A. I was never concerned about Easton's
12 sleep before his injury.
13 Q. Okay. And then it says in this note,
14 mom and dad report. So, I assume, but please
15 confirm, that Jace was also at that visit?
16 A. Yes.
17 Q. Was Jace the source of this information
18 that Dr. Flavin recorded that Easton sometimes
19 has difficulty falling asleep, but this was the
20 case prior to his injury?
21 A. I don't remember.
22 Q. Did anybody else, other than Jace,
23 accompany you and Easton to this visit?
24 A. No.
43
1 Q. Prior to Easton's head injury on
2 August 15, 2022, was Easton having any difficulty
3 in school?
4 A. No.
5 Q. Was Easton having any issues involving
6 bullying from classmates?
7 A. No.
8 Q. Prior to Easton's head injury in August
9 of 2022, had Easton ever slept in a bunk bed at
10 home?
11 A. Yes.
12 Q. And for what period of time had Easton
13 slept in a bunk bed?
14 A. He slept in a bunk bed, give or take,
15 from 2013 to 2015.
16 Q. Okay. And when Easton was sleeping in
17 a bunk bed during that period of time, did he
18 sleep on the top or the bottom bunk?
19 A. Both.
20 Q. Okay. And was there a particular
21 sibling or family member that would sleep on the
22 other bunk?
23 A. Yes, Brogan.
24 Q. Okay. Did the bunk bed -- was this a
44
1 bunk bed that you had in your house?
2 A. Yes.
3 Q. Did Easton have any falls or injuries
4 related to the use of that bunk bed?
5 A. No.
6 Q. Did that bunk bed have guardrails on
7 it?
8 A. Yes.
9 Q. And the bunk bed that Easton slept in,
10 did the top bunk have -- which sides of the bed,
11 as best as you can describe it, had guardrails?
12 A. All sides.
13 Q. All four sides?
14 A. Yes.
15 Q. Was there a space on one of the sides
16 in which the guardrail did not extend the length
17 of the bed for purposes of getting in and out of
18 the bed?
19 A. Yes. There were stairs by his feet to
20 get in and out. There was no guardrail.
21 Q. And describe for me, please, the stairs
22 that you had affixed or attached to that bunk
23 bed.
24 A. There was just a small set of maybe
45
1 like four steps up to -- actually, probably like
2 five or six up to his top bunk instead of a
3 ladder.
4 Q. And what made those steps, as you just
5 described them, different from a ladder?
6 A. The bottom of the steps had drawers
7 that you could open and store stuff inside.
8 Q. Okay.
9 A. So, each step had a drawer.
10 Q. I see. So, it was -- not only was it
11 used to get in and out of the top bunk, but it
12 was also some type of storage facility?
13 A. Yes.
14 Q. Okay. Has Brogan ever suffered any
15 type of head injury?
16 A. No.
17 Q. Has Brogan ever sustained a concussion?
18 MR. FULGINITI: Just so we
19 are clear, Brogan has not put his
20 medical condition in controversy. So,
21 I don't want to get into his medical.
22 MR. BLUTH: I'm not -- I'm
23 not getting into it, other than these
24 comparative questions.
46
1 MR. FULGINITI: Okay. But
2 these comparative questions are getting
3 into it.
4 I mean, if it was a genetic
5 thing, and you believe that you are
6 entitled to that, but I don't know why
7 Brogan's broken bones or concussions or
8 anything are in any way relevant to --
9 not only are they not relevant, but it
10 is protected HIPAA. It is a child's
11 medical information, and he is not a
12 plaintiff.
13 MR. BLUTH: I think --
14 MR. LIVINGOOD: I just don't
15 want to hear at trial, like, oh, God --
16 and I don't think this is the case, but
17 I don't want to hear at trial, like, we
18 had so much trouble, because Brogan
19 also had this issue or something like
20 that, if the family is going to talk
21 about it, right.
22 So, I think we are entitled
23 to just know -- to make sure that there
24 is not any other things going on with
47
1 the family that increased their stress
2 or increased their distress --
3 MR. FULGINITI: All right.
4 MR. LIVINGOOD: -- more than
5 this already did.
6 MR. FULGINITI: I don't
7 think that every single case opens up
8 ever stress factor that a family may go
9 through that's personal, but I
10 certainly think a child's medical
11 history when that child is not a
12 plaintiff in the case is problematic.
13 I mean, it's really just not
14 something that Brogan has bought into,
15 or Blakely had bought into, for that
16 matter.
17 I mean, there's some
18 evidence that, you know, in the cases
19 that you can't get into a parent's
20 demographics, and I think we've covered
21 that in a Discovery hearing, but not
22 his little brother's medical history.
23 MR. LIVINGOOD: You see
24 where I am coming from a little bit.
48
1 If I -- you know, if I hear at trial
2 like we had all this going on with
3 Easton, but then also we had these
4 issues with Brogan at the same time,
5 and I know he did have, you know,
6 medical conditions that probably
7 increased, you know, what the family
8 was going through, if I am going to
9 hear that at a trial, I think that we
10 get to ask at least a little bit about
11 it.
12 I don't want -- we probably
13 spent more time, the three of us,
14 arguing about than what I would intend
15 to ask about. I don't want to speak
16 for Brian.
17 But, you know, I just don't
18 want to hear at trial, yeah, this is
19 just one of the three things that just
20 made it an awful, awful, even worse
21 than you could imagine in a situation.
22 MR. FULGINITI: We are not
23 going to talk about Brogan's health.
24 We are not going to be talking about
49
1 Brogan's concussion history, if he has
2 any, or broken -- Brogan's broken
3 bones, if he has any.
4 MR. BLUTH: Look for now --
5 MR. LIVINGOOD: Well, I
6 guess the heart surgery, we are not
7 going to talk about; is that what you
8 are telling me?
9 MR. FULGINITI: Not
10 Brogan's.
11 MR. LIVINGOOD: I just want
12 it on the record, so if it comes up at
13 trial, we have something. Thank you.
14 MR. FULGINITI: Okay. Let's
15 move on.
16 MR. BLUTH: For now, these
17 are just yes or no questions. Ken, you
18 are advising your client not to answer?
19 I mean, there are two
20 questions, whether there has been a
21 head injury and whether there has been
22 concussion.
23 If the answer is no, then,
24 obviously, we move on. If the answer
50
1 is yes, then I don't intend, at this
2 juncture, to dive into that in any
3 detail, but they are just yes or no
4 questions for comparison's sake.
5 MR. FULGINITI: Brian,
6 whether it is a yes or no question on a
7 child's medical history that is not a
8 plaintiff to this case does not change
9 the HIPAA rules.
10 I am just trying to
11 understand the relevance. So, maybe
12 explain the relevance to me, because I
13 am not -- I haven't decided what I am
14 going to do at trial yet in response to
15 John Livingood's comments.
16 MR. BLUTH: Well, for now,
17 if -- I mean, if the answer is yes,
18 then perhaps we get to ask questions
19 about the experiences of one child
20 versus the other from a causation
21 perspective, from -- as John mentioned,
22 from a life experiences' perspective,
23 the challenges of dealing with one
24 child with these issues versus two.
51
1 I mean, if they become
2 relevant for causation and damages-type
3 issues. And it is a Discovery
4 deposition.
5 I mean, we've produced --
6 from a Little League perspective, we
7 produced all sorts of medical
8 information from child related to the
9 prior falls, whether we file a motion
10 or what we do with that at trial is a
11 question for another day, but this is a
12 Discovery deposition.
13 MR. FULGINITI: So, you had
14 to produce those records from other
15 falls, because it goes to liability.
16 It goes to recklessness. It goes to
17 punitives.
18 Brogan has not opened his
19 condition up, but that being said, with
20 your comment that it is relevant to the
21 issues in this litigation, then to
22 John's point, I guess I don't want to
23 hear a Motion in Limine later on that
24 we can't get into any issues with
52
1 Brogan.
2 So, go ahead and ask your
3 question as to whether or not he
4 suffered a concussion.
5 BY MR. BLUTH:
6 Q. That's my question. Has Brogan ever
7 suffered a concussion?
8 A. No.
9 Q. Has your daughter ever sustained any
10 type of head injury?
11 A. She had stitches on her forehead.
12 Q. Is that -- and what was the event or
13 injury that resulted in stitches?
14 A. She fell into a door frame and got
15 10 stitches on her forehead.
16 Q. Okay. When did that happen?
17 A. When she was one.
18 Q. Has Blakely ever suffered a concussion?
19 A. No.
20 Q. Switching gears a bit to the events of
21 the summer of 2022. Did you go to the
22 San Bernadino Regional Tournament?
23 A. Yes.
24 Q. And did you go to the entire
53
1 tournament, or were you only there for a period
2 of time?
3 A. I was there for the whole tournament.
4 Q. Okay. And where did you stay?
5 A. In a hotel.
6 Q. Did you ever go into any of the
7 dormitories that were in use at the time for the
8 players in the San Bernadino facility?
9 A. No.
10 Q. Did you ever personally observe any of
11 the bunk beds that were in use in the summer of
12 2022 at the San Bernadino facility?
13 A. No. I was not allowed inside.
14 Q. Okay. Did you ever talk to one of
15 Easton's teammates, Dash Avery, about a fall that
16 we heard about he had from a bunk bed at the
17 San Bernadino facility?
18 A. I never talked to Dash about his fall,
19 no.
20 Q. Okay. Did you ever talk ever to Dash's
21 father -- or stepfather about that fall?
22 A. After Easton got hurt, I did.
23 Q. Okay. And who is Dash's stepfather?
24 A. Kyle Hafen.
54
1 Q. And what did Mr. Hafen tell you about
2 his stepson's fall?
3 A. He said that Dash fell in
4 San Bernadino, and he fell on a pillow, and
5 received a headache.
6 Q. Okay. Anything else at all that
7 Mr. Hafen told you about that incident?
8 A. No. Besides that they reported it.
9 Q. Okay. And to whom did Mr. Hafen say he
10 reported the incident?
11 A. I don't remember.
12 Q. Did Dash Avery, to your knowledge, miss
13 any playing time or any games as a result of that
14 incident?
15 A. No.
16 Q. Okay. Did Mr. Hafen ever indicate to
17 you that he had heard back from anybody at -- any
18 Little League officials at the San Bernadino
19 facility about that accident or that fall?
20 A. I don't recall.
21 Q. When did this conversation with
22 Mr. Hafen about Dash Avery's fall take place?
23 A. Sometime after Easton's injury.
24 Q. Could you estimate how long after
55
1 Easton's injury you spoke to Mr. Hafen on that
2 subject?
3 A. A month.
4 Q. Okay. Since that conversation
5 approximately one month after Easton's fall, have
6 you had any other discussions with Mr. Hafen
7 about Dash Avery's fall at the San Bernadino
8 facility?
9 A. Yes.
10 Q. Okay. When was the next time you spoke
11 with Mr. Hafen about that, that fall?
12 A. I just -- the conversation comes up
13 when we talk about Easton. I -- I don't
14 remember.
15 Q. Okay. In any of those subsequent
16 conversations, has Mr. Hafen shared any
17 information, any additional information with you,
18 that he did not also share with you in that first
19 conversation approximately one month after
20 Easton's fall?
21 A. No.
22 Q. Have you talked with any of Easton's
23 teammates from the summer of 2022 about the
24 Dash Avery fall?
56
1 A. No.
2 Q. Have you talked with any of the other
3 coaches on Easton's team from the summer of 2022
4 about Easton's fall -- about -- excuse me, about
5 the Dash Avery fall?
6 A. I talked to Jace about it, and he was a
7 coach.
8 Q. Right. And what has Jace told you
9 about what he knows about the Dash Avery fall?
10 A. That same thing that I know. He was in
11 the conversation with Kyle.
12 Q. Okay. Did you travel to Williamsport
13 for purposes of the Little League World Series at
14 any time prior to Easton's fall?
15 A. No.
16 Q. My understanding, from Jace's
17 deposition, is that Jace traveled with the team
18 to Williamsport on August 13th, 2022.
19 A. Yes.
20 Q. How many times that day, if you can
21 recall, did you talk to Jace?
22 MR. FULGINITI: On
23 August 13th?
24 MR. BLUTH: Correct.
57
1 THE WITNESS: A lot.
2 BY MR. BLUTH:
3 Q. Okay. What do you recall about what
4 Jace had said on August 13 of 2022?
5 A. He was telling me about how incredible
6 the facility were -- was, how excited Easton was
7 to be there.
8 Q. Okay. Anything else that you remember
9 of those conversations?
10 A. Just their excitement.
11 Q. Did Jace share with you in any of those
12 discussions on August 13, 2022, any concerns that
13 he had might have had about the bunk beds?
14 A. No.
15 Q. Did Jace share with you on August 13,
16 2022, any concerns he might have had about the
17 dormitories in the wake of the Dash Avery fall?
18 A. No.
19 Q. Do you recall how many times you and
20 Jace would have spoken on August 13, 2022?
21 A. Many times. He called me. He
22 FaceTimed me many times, because -- to show their
23 excitement --
24 Q. Okay.
58
1 A. -- and I wanted to see Easton
2 experience these things.
3 Q. Okay. Did any of those -- I think that
4 you said there were some FaceTimes. Were any of
5 those recorded?
6 A. No.
7 Q. Did you, during those FaceTime calls,
8 have an opportunity to visualize Easton over the
9 video?
10 A. I saw him on the videos, yes.
11 Q. And when I'm talking --
12 (Technical difficulty.)
13 (At this time, the court
14 reporter's connection in the Zoom
15 conference was lost. Any testimony
16 during this time is only on the
17 videotape.)
18 (At this time, a break was
19 taken.)
20 MR. BLUTH: Before we go on
21 the video, can we just have the last
22 question read back, not for purposes of
23 an answer, but so that we know where
24 the court reporter dropped off?
59
1 (At this time, the court
2 reporter read from the record as
3 requested.)
4 THE VIDEOGRAPHER: 11:21, on
5 video.
6 BY MR. BLUTH:
7 Q. All right. Ma'am, we had taken a short
8 break, and I think we've got our court reporter
9 back.
10 We were discussing the FaceTime calls
11 that you had on August 13, 2022, during which you
12 were able to visualize Easton, and I think
13 you --
14 A. Yes.
15 Q. -- and I think you told me that during
16 one of those calls, you saw Easton in the stadium
17 at the Little League complex; is that correct?
18 A. Yes.
19 Q. Okay. On August 13, 2022, had you seen
20 Easton during any of these FaceTime calls in any
21 other location?
22 A. On the airplane.
23 Q. Okay. So, in terms of August 13, 2022
24 FaceTime calls, you saw him in the airplane and
60
1 you saw him at the stadium at Little League. Any
2 other locations at which you visualized Easton
3 that day?
4 A. No.
5 Q. Okay. August 14, 2022, was a Sunday, I
6 believe?
7 A. Yes.
8 Q. Did you talk to Jace on that day by
9 phone?
10 A. Yes. Yes.
11 Q. And how many times did you talk to Jace
12 on the phone that day?
13 A. Quite a few.
14 Q. Were any of those FaceTime calls?
15 A. No, I don't remember.
16 Q. Okay. Describe for me what you
17 remember that you and Jace discussed on
18 August 14, 2022?
19 A. On August 14th is when I made my plane
20 ticket, mine and Brogan's plane ticket, to come
21 out to Williamsport on the 16th. So, going back
22 and forth about doing that.
23 Q. Okay. In other words, you were making
24 your travel plans to come to Williamsport to
61
1 observe the Series?
2 A. Yes.
3 Q. Okay. Other than making those travel
4 plans, do you recall any other topic on which you
5 had a conversation with Jace on August 14, 2022?
6 A. Yes. He told me about the ESPN
7 interviews. He sent me pictures of him and
8 Easton together doing these photo shoots.
9 Q. Okay. Do you still have those
10 photographs that Jace sent to you --
11 A. Yes.
12 Q. -- on the events that you just
13 described?
14 A. Yes.
15 Q. Okay. We're going to make a request
16 for those through your attorney after the
17 deposition. So, we will work with Mr. Fulginiti
18 on that.
19 All right. Anything else that you
20 recall that you discussed with Jace on August 14,
21 2022?
22 A. Just how excited they were to be there.
23 Q. Okay. Did -- you mentioned that Jace
24 sent some photographs on August 14, 2022. Did he
62
1 send any photograph from August 13, 2022, the day
2 before?
3 A. Yes.
4 Q. Okay. So, we will make the same
5 request through Mr. Fulginiti for those as well.
6 A. Okay.
7 Q. On August 14, 2022, where was Easton in
8 any of those photographs that you saw?
9 A. He was in a facility doing his ESPN
10 interviews, ESPN photos. He sent me a picture of
11 the whole team. It looks like they are by some
12 World Series signs. He was in -- on the grove.
13 Q. Okay. Were any of those photographs
14 taken inside of Easton's dorm room?
15 A. No.
16 Q. I think that you told me that you do
17 not -- you did not have -- or at least you do not
18 recall having had any FaceTime calls with Jace on
19 that Sunday, August 14; is that correct?
20 A. Not -- I mean I'm sure we did FaceTime,
21 but I don't remember those details.
22 Q. Okay. So, then I will ask you the
23 question, anyway; and that is: Where was Easton
24 in any of the FaceTime videos that you might have
63
1 had with him and Jace that day, if you recall?
2 A. I can't remember --
3 MR. FULGINITI: She just
4 said that she doesn't remember if
5 she --
6 MR. BLUTH: I know. I am
7 just making sure that the record is
8 clear. I'm not looking to trick
9 anybody up.
10 MR. FULGINITI: You were.
11 Well, if she doesn't remember if she
12 had any, how can she say where he was
13 when she doesn't remember if she had
14 any?
15 MR. BLUTH: Then she can say
16 that.
17 MR. LIVINGOOD: She said, I
18 am sure I did. I just don't remember.
19 MR. BLUTH: Right. So, I
20 mean, I get to ask questions that might
21 jog a memory.
22 MR. FULGINITI: Answer the
23 question. It is an unfair question to
24 suggest where he was in a video that
64
1 she doesn't remember seeing, but...
2 MR. BLUTH: I am not
3 suggesting --
4 MR. FULGINITI: It is an
5 unfair question.
6 MR. BLUTH: I am not
7 suggesting where Easton was at any
8 moment in time. I am just asking the
9 question.
10 MR. FULGINITI: You are
11 asking if she saw a video. Answer the
12 question. We don't need to argue it.
13 You can answer the question,
14 Nancy, if you remember.
15 THE WITNESS: I mean, I know
16 he was at the World Series campus. So,
17 somewhere on campus.
18 BY MR. BLUTH:
19 Q. Well, do you have a specific memory of
20 having FaceTime discussions with Jace on
21 August 14, 2022, or are you just assuming, based
22 on your routine ways of communicating with him,
23 that you must have on that day?
24 A. Just history of us communicating, I
65
1 must have on that day.
2 Q. Okay. But is it correct to say that,
3 as you sit here today, you do not have any
4 specific recollection of any FaceTime calls with
5 Jace on August 14, 2022?
6 A. Yes.
7 Q. Okay. All right. Prior to Easton's
8 accident, did you ever see any photographs or any
9 videos of the dorm room in which Easton and his
10 team was staying?
11 A. Yes.
12 Q. Okay. When was that?
13 A. Probably when Jace got there on the
14 14th, he took a video and sent it to me of them
15 coming into the dormitory, of them getting their
16 equipment, and the boys just getting there.
17 MR. BLUTH: Okay. Ken, do
18 you know if that is the video that has
19 already been produced in Discovery?
20 MR. FULGINITI: I don't
21 know.
22 BY MR. BLUTH:
23 Q. Okay. Do you still have that video,
24 ma'am?
66
1 A. Yes.
2 Q. And where do you have it? Is it on a
3 phone?
4 A. Yes.
5 Q. Okay. We will ask you to preserve
6 that, also. Does that video have any audio on
7 it?
8 A. Yes.
9 Q. Okay. All right. And just so that you
10 understand, ma'am, we have seen such a video.
11 That is why I asked your attorney if he knew
12 whether it was the same one that we have already
13 seen.
14 A. Can I answer that?
15 Q. You can.
16 A. Yes. It is the same video.
17 Q. Is it? Is the video that you are now
18 describing the same one that was described during
19 your husband's deposition?
20 A. Yes.
21 Q. Okay. Other than that video, have you
22 seen -- had you seen any photographs or videos of
23 Easton's dorm room at the Little League complex?
24 A. No.
67
1 Q. Okay. Did you -- on August 13 or
2 August 14, 2022, did you have any telephone calls
3 or FaceTime calls with Easton?
4 A. Just via Jace.
5 Q. Okay. And --
6 A. Easton didn't have access. He
7 doesn't -- he didn't have a phone at the time
8 that could do FaceTime.
9 Q. Okay. Did he have a phone at the time
10 at all?
11 A. Yes.
12 Q. Did you have any telephone calls with
13 Easton on August 13 or 14, 2022, using Easton's
14 telephone number?
15 A. No.
16 Q. What, if anything, did Easton say to
17 you directly during the calls that you had with
18 him on August 13 or August 14, 2022?
19 A. I remember him expressing how his dream
20 has become a reality; how cool everything was;
21 how excited he was to play on the field. He was
22 the happiest I have ever seen him.
23 Q. Anything else that you remember that
24 Easton told you during the conversations that you
68
1 had directly with him prior to his accident while
2 he was at the Little League complex?
3 A. That he was excited to see me there to
4 watch him play.
5 Q. Okay. Anything else that you remember?
6 A. No.
7 Q. When was the last time you talked to
8 Jace prior to receiving the call that Easton had
9 been hurt?
10 A. About 10:00 p.m. on August 14th. We --
11 Q. I'm sorry. I did not mean to cut you
12 off. Would you repeat what you said at the end?
13 A. 10:00 p.m. on August 14th.
14 Q. Was that a voice call or a FaceTime
15 call?
16 A. Voice call.
17 Q. What did you and Jace discuss during
18 that call?
19 A. We had a conversation about our parent
20 meeting that I had with the other parents. We
21 had a conversation about how I was getting out
22 there.
23 Q. Now, you mentioned this parent meeting.
24 Describe that for me, please. What is a parent
69
1 meeting?
2 A. The parents had a meeting on that
3 Sunday prior just discussing our Williamsport
4 plans and to continue with our fundraising.
5 Q. When you say "a parent meeting," are
6 these the parents of Easton's teammates?
7 A. Yes.
8 Q. And where did that meeting take place?
9 A. At the Hickmans' home.
10 Q. Was that in Utah?
11 A. Yes.
12 Q. Okay. My understanding is that the
13 team and the three adult coaches went directly
14 from San Bernadino to Williamsport following the
15 conclusion of the regional tournament; is that
16 right?
17 A. Yes.
18 Q. And I think what you are describing to
19 me is that the parents who might have been in
20 San Bernadino to watch that tournament returned
21 to Utah, so that when you had a parents' meeting,
22 it occurred in Utah?
23 A. Yes.
24 Q. Were there discussions among the
70
1 parents for some sort of group travel to
2 Williamsport?
3 A. No. We all traveled to Williamsport
4 separately.
5 Q. Okay. How many -- if you know, how
6 many parents among the parents' group were
7 planning to travel to Williamsport?
8 A. Everybody.
9 Q. Do you know how many people are in that
10 group that you've described as everybody?
11 A. I mean, each parent has a mother -- I
12 mean, each player had a mom and dad that
13 traveled, plus siblings, and some grandparents,
14 some friends.
15 Q. All right. So, your understanding was
16 that of all of Easton's teammates, there was
17 going to be a large contingent of parents,
18 siblings and relatives who were going to travel
19 to Williamsport for this tournament?
20 A. Yes.
21 Q. Other than Jace, who was already in
22 Williamsport, and you, who else in Easton's
23 immediate family was going to travel to
24 Williamsport to watch him play at the Little
71
1 League World Series?
2 A. His little brother, Brogan.
3 Q. Okay. Anybody else?
4 A. No.
5 Q. Was there a plan for somebody to watch
6 Blakely while you and Brogan had joined Easton
7 and Jace in Williamsport?
8 A. Yes.
9 Q. And what was that plan?
10 A. My mother-in-law and father-in-law.
11 Q. These are Jace's parents?
12 A. Yes.
13 Q. And their names, please.
14 A. Kevin and MarJean Oliverson.
15 Q. And where do they live?
16 A. In Utah.
17 Q. And where in Utah?
18 A. Santa Clara, Utah.
19 Q. And how far by car is that from your
20 house?
21 A. Three miles.
22 Q. Okay. So, very short?
23 A. Yes.
24 Q. Okay. All right. So, we were talking
72
1 about that 10:00 p.m. call that you had with Jace
2 on the evening or the nighttime hours of
3 August 14, 2022. You talked about the parents'
4 meeting, and you talked about your own travel
5 plans. Anything else that you and Jace
6 discussed?
7 A. I am sure he told me all about his time
8 with the ESPN interviews, and he told me about
9 his day.
10 Q. And what, if anything, do you
11 specifically remember that Jace described on
12 those subjects?
13 A. He described all the cool equipment
14 they got; all the uniforms they got; how excited
15 the boys were to be there; how excited he was to
16 be there; just he was excited to show me how
17 incredible it was there.
18 Q. Okay. Did you talk to Easton during
19 that call?
20 A. Easton had already gone to sleep.
21 Q. Okay. During that call, did Jace
22 describe for you any concern he might have had
23 about the dorm room or the bunk beds?
24 A. No.
73
1 Q. Okay. At any time prior to -- prior to
2 or including this 10:00 p.m. call, did Jace
3 describe to you any inquiries that anybody on the
4 team made of any Little League official regarding
5 guardrails for bunk beds?
6 A. No.
7 Q. The call that you recall, the telephone
8 call that you recall at ten o'clock, was that
9 Eastern Time, or was the time where you were
10 located in Utah?
11 A. Where I was located.
12 Q. Okay. And what time is it where you
13 are right now?
14 A. 9:38.
15 Q. So, there is a two hour time
16 difference?
17 A. Yes.
18 Q. So, the ten o'clock call that you are
19 describing was -- had taken place at midnight
20 where Jace was located?
21 A. It must have been a little earlier,
22 because I am sure he was in bed by midnight. So,
23 maybe it was probably more like 9:00.
24 Q. Nine o'clock Utah time?
74
1 A. Utah time.
2 Q. Eleven o'clock Eastern Time?
3 A. Yeah.
4 Q. Okay. Had you gone to bed that night
5 prior to the time that you first learned that
6 Easton had suffered an injury?
7 A. Yes.
8 Q. Tell me what you can remember about
9 when and how you learned that Easton had suffered
10 an injury?
11 A. Jace had called me, but my phone was on
12 silent from when I had attended church earlier on
13 Sunday morning, but I woke up and saw that one
14 minute ago that he had called. So, that's when I
15 called him, and he told me.
16 Q. Okay. So, if I understand what you are
17 describing, Jace called while you were sleeping,
18 but your phone was on mute, so you had not heard
19 it at that point?
20 A. No. But when I woke up and saw my
21 phone, it did say that missed call one minute ago
22 from Jace.
23 Q. Is there anything, in particular, that
24 woke you up at that moment?
75
1 A. No.
2 Q. Okay. And what time of day was it when
3 you had that first telephone conversation with
4 Jace?
5 A. Around 12:30 a.m.
6 Q. 12:30 a.m. at the time in Utah where
7 you were located?
8 A. Yes.
9 Q. Okay. And as best as you can recall,
10 and taking as much time as you need, can you
11 describe for me the conversation that you had
12 with Jace at that time?
13 A. The mind -- my mind is really good at
14 blocking out trauma. So, I don't know a lot of
15 the details of that phone call, but I do know
16 that I knew something was wrong, and I remembered
17 yelling no.
18 Q. I'm sorry, ma'am. Are you finished
19 with our answer?
20 A. Yes.
21 Q. Okay. Do you know where Jace was
22 located at the time that you spoke with him?
23 A. He was in a vehicle. He was on his way
24 to the hospital in Williamsport.
76
1 Q. Okay. So, just so that I'm clear, your
2 understanding is that Jace was in a vehicle
3 traveling from the Little League complex to the
4 hospital in Williamsport?
5 A. Yes.
6 Q. Okay. Anything else about that call
7 that you remember?
8 A. My nightmare. It was a nightmare.
9 Q. Any -- did Jace describe for you any
10 details about Easton's fall and the immediate
11 aftermath of that fall?
12 A. Again, I don't -- I blocked out a lot
13 of this conversation due to the trauma that I've
14 had from it, but he just -- he told me that
15 Easton had fallen from his bunk bed, and
16 something was really, really wrong with him.
17 Q. And as I said at the outset, ma'am, we
18 may ask questions regarding specific details, but
19 that is not to suggest that you have to have some
20 memory that you don't already have. So, if we
21 ask a question for which you no longer recall,
22 just let us know.
23 A. Okay.
24 Q. When was the next time you had a
77
1 conversation with Jace?
2 A. When he was then driving to Geisinger,
3 because they Life-Flighted Easton.
4 Q. And what, if anything, do you recall
5 that you and Jace discussed at that time?
6 A. He just -- he told me that things were
7 really serious, and that we needed to pray for
8 Easton.
9 Q. Anything else that you and Jace
10 discussed at that time?
11 A. Jace told me that he was going to call
12 a neighbor and have a neighbor come over to be
13 with me, and to help me make arrangements to be
14 there.
15 Q. And what time was this, was this call
16 while Jace was on his way to Geisinger?
17 A. I don't remember.
18 Q. And did a neighbor ultimately come over
19 to be with you?
20 A. Yes.
21 Q. And who was the neighbor?
22 A. Curt and Shawna Wakefield.
23 Q. Do you know if that is Curt with a K or
24 a C?
78
1 A. A C.
2 Q. And where do they live?
3 A. Just right next-door to us.
4 Q. Do you know their street address?
5 A. No.
6 Q. Okay. During this period of time,
7 other than from Jace, are you learning any
8 information about Easton's injury or condition
9 from anybody else?
10 A. No.
11 Q. Okay. When was the next time that you
12 and Jace spoke about Easton's condition?
13 A. Easton -- he called -- Jace called me
14 after they got to Geisinger, and they had taken
15 Easton back to surgery.
16 Q. Do you know what time this call
17 occurred?
18 A. I don't remember.
19 Q. And can you describe for me anything
20 that you remember about that call, meaning Jace
21 had arrived at Geisinger and Easton was going
22 into surgery?
23 A. He just told me that it was an
24 emergency surgery, and they were going to do
79
1 everything in their power to save his life.
2 Q. Anything else that you remember that
3 you and Jace discussed or information that Jace
4 provided to you during that call?
5 A. No.
6 Q. And then when is the next time that you
7 spoke with Jace?
8 A. Jace had really bad service. So, he
9 had to call me from a phone from the hospital.
10 He just would call me periodically to check on me
11 to make sure that I was doing okay when Easton
12 was still back in his surgery.
13 Q. Okay. During that period of time, had
14 Jace learned any new information about Easton's
15 condition?
16 A. No.
17 Q. Do you recall how many times Jace
18 reached out to you during Easton's first surgery
19 at Geisinger?
20 A. No.
21 Q. During this period of time, meaning
22 when Easton is in that first surgery at
23 Geisinger, were you learning any information
24 about Easton's condition from anyone other than
80
1 your husband?
2 A. No.
3 Q. What is the next thing you remember in
4 terms of learning information about Easton's
5 surgery or his condition?
6 A. Jace called when he was out of surgery
7 and just told me that they -- what had happened,
8 that he had received an epidural hematoma, and
9 that they had to remove a bone flap to let his
10 brain swell, and that he was in a coma fighting
11 for his life.
12 Q. Did Jace describe for you at that point
13 any conversations he had with any of Easton's
14 doctors or medical providers?
15 MR. FULGINITI: Other than
16 what she just said?
17 MR. BLUTH: Correct.
18 THE WITNESS: Talking to him
19 further down the road, yes, but at the
20 time, I didn't -- I didn't remember.
21 BY MR. BLUTH:
22 Q. What do you mean by that, ma'am?
23 A. He told me things that I didn't know he
24 told me those things. My -- like I said, I was
81
1 just trying so hard to protect myself from the
2 trauma that he would tell me things that I didn't
3 accept it, and I couldn't recall those things he
4 was telling me.
5 Q. All right. I just want to make sure
6 that I understand what you are telling me. Are
7 you telling me that Jace provided additional
8 information to you during this call immediately
9 following Easton's surgery that you did not
10 recall at the time, but you have since been
11 reminded that Jace told you at that time?
12 A. Yes.
13 Q. Okay. So, what is it that Jace told
14 you in that first call after Easton's surgery
15 that you may not have remembered at the time, but
16 were subsequently reminded that Jace had said?
17 A. That Easton had a zero percent chance
18 to live before and after the surgery.
19 Q. Okay. Anything else that you now know
20 that Jace communicated to you in that first call
21 immediately following surgery that you did not
22 recall at the time?
23 A. No.
24 Q. Do you know which of Easton's doctors
82
1 had said that he had a zero percent chance to
2 live before and after surgery?
3 A. Dr. Maffei.
4 Q. Dr. Maffei?
5 A. (Witness nods head.)
6 Q. Is that -- you shook your head. Does
7 that mean --
8 A. Yes.
9 Q. -- that you intended to say yes?
10 Mr. Maffei, the pediatrician, that was
11 caring for Easton?
12 A. Yes.
13 Q. On August 15, 2022, meaning the day of
14 Easton's accident and injury and the day of his
15 first surgery, did you have any discussions
16 directly with any of Easton's doctors?
17 A. No.
18 Q. Okay. Is it correct then that all of
19 the information that you learned about how Easton
20 was doing and his surgery, was information
21 communicated to you from or through Jace?
22 A. Yes, until I got there.
23 Q. Okay. And when was it that that you
24 first arrived at Geisinger Medical Center in
83
1 Pennsylvania?
2 A. 6:00 p.m. on August 15th.
3 Q. And to which airport did you fly into?
4 A. Baltimore.
5 Q. And how did you get from Baltimore to
6 Danville, Pennsylvania?
7 A. I rented a car and drove.
8 Q. Did anybody make that trip with you?
9 A. No.
10 Q. You made that trip alone?
11 A. Yes.
12 Q. And when you arrived in Geisinger, was
13 Easton in a hospital room at that point?
14 A. Yes. He was in a PICU.
15 Q. A pediatric intensive care unit bed?
16 A. Yes.
17 Q. And, again, as best as you can, and I
18 understand that it will -- it may be difficult,
19 so please take the time and whatever breaks you
20 may need, describe for me, please, what you
21 observed when you walked into the room.
22 A. He had a breathing tube. He had a huge
23 sore, kind of a burn on his temple. His head was
24 all wrapped up.
84
1 Q. Is your answer finished, ma'am?
2 A. Yeah.
3 Q. Okay. At that point, who was in
4 Easton's room, other than Easton, when you
5 arrived?
6 A. Jace, my brother-in-law and the nurses.
7 Q. And who's your brother-in-law that was
8 present?
9 A. Derek Oliverson.
10 Q. And that's Jace's brother?
11 A. Yes.
12 Q. And when did he -- when he did fly out
13 to Pennsylvania?
14 A. I'm not sure time what time he got
15 there, but he got there before me.
16 Q. Where does Derek live?
17 A. Arizona.
18 Q. Do you know where in Arizona?
19 A. Phoenix area.
20 Q. From the time that you first learned
21 that Easton had suffered an injury until the time
22 that you arrived at Geisinger, did you have any
23 discussions or calls with Jace's brother, Derek?
24 A. No.
85
1 Q. On that -- when you -- when you arrived
2 at Geisinger and saw Easton for the first time,
3 what information did you learn and from whom
4 about Easton's condition?
5 A. I don't remember. I remember just
6 doctors talking to me, and me just kind of
7 staring blankly. I couldn't -- I just couldn't
8 process everything.
9 Q. Did you have an --
10 A. It --
11 Q. Oh, I'm sorry. I didn't mean to cut
12 you off.
13 A. It was I was living a nightmare.
14 Q. Did you have an opportunity to talk to
15 any of Easton's doctors on that first night that
16 you were there?
17 A. Yes.
18 Q. And who did you speak with?
19 A. Dr. Maffei and Dr. Goren.
20 Q. And did you speak with those doctors
21 together or separately?
22 A. I don't remember, and I wouldn't
23 necessarily say I spoke to them. They spoke to
24 me.
86
1 Q. All right.
2 A. I was so numb about the whole situation
3 that I didn't have words. I couldn't respond.
4 Q. Okay. I appreciate that clarification.
5 Thank you.
6 A. Yeah.
7 Q. So, when you -- I guess my question
8 then is: When Dr. Goren and Dr. Maffei were
9 providing information to you, were the two of
10 them together, or were they separate?
11 A. I don't remember.
12 MR. FULGINITI: Objection to
13 form. You can answer.
14 BY MR. BLUTH:
15 Q. And whenever it was that you had that
16 first communication from Easton's doctors, what
17 did they tell you?
18 A. I don't remember.
19 Q. Did either of them say or repeat the
20 comment about a zero percent chance of survival
21 that Jace had communicated to you that he heard
22 from Dr. Maffei?
23 A. I don't remember that information. I
24 learned that information when me and Jace's
87
1 brothers were in the family lounge, and I heard
2 it on the TV talking about Easton, and that's
3 when I learned that information, because I --
4 like Jace had said before, he told me, but I
5 couldn't process that at the time.
6 Q. So, is what you're describing that the
7 first time that you have a specific recollection
8 of hearing that comment about Easton, the zero
9 percent chance of survival, was on some news
10 report on the television in the family waiting
11 room at Geisinger?
12 A. Yes.
13 Q. Do you recall which station or channel
14 the TV was on?
15 A. No.
16 Q. When you heard that on the TV, did that
17 refresh your memory that Jace had communicated
18 that to you at some prior -- during some prior
19 telephone call?
20 A. No. I -- as a matter of fact, I didn't
21 believe it.
22 Q. Why is that?
23 A. I just -- it wasn't something that I
24 could comprehend at the time, and my
88
1 brother-in-law, Derek, had to confirm with me
2 that it was true.
3 Q. It was true, meaning that one of
4 Easton's doctors had said that about a zero
5 percent chance of survival?
6 A. Yes.
7 Q. Okay. Where did you stay, if anyplace,
8 outside of the hospital while Easton was an
9 inpatient at Geisinger?
10 A. I stayed in the hospital every night
11 with him.
12 Q. In Easton's hospital room?
13 A. Yes.
14 Q. Okay. And were you at Easton's side in
15 his hospital room every night until he was
16 transferred by airplane to Utah?
17 A. Yes. And I was in his hospital room in
18 Utah as well --
19 Q. Okay.
20 A. -- every night.
21 Q. Did there come a time while Easton was
22 at Geisinger that you learned from any of his
23 doctors that his chance of survival was no longer
24 zero percent, meaning that his prognosis had
89
1 improved from the original information that you
2 had heard?
3 A. I don't remember.
4 Q. Were you able to speak with Easton's
5 doctors at least on a once-a-day basis every day
6 that you were at Geisinger?
7 A. Yes.
8 Q. With respect to Dr. Goren, who you
9 mentioned earlier, and who we know from the
10 records was Easton's treating neurosurgeon --
11 A. Yes.
12 Q. -- were you able to talk to Dr. Goren
13 at least once a day?
14 A. Yes.
15 Q. And did there come a point in time
16 where Dr. Goren thought that Easton had been
17 improving to any degree?
18 A. Yes.
19 Q. And how soon after Easton's first
20 surgery did Dr. Goren share information along
21 those lines with you?
22 A. I don't remember.
23 Q. Was it at a time that was prior to the
24 Easton's second surgery, meaning the surgery
90
1 where they had to deal with his infection?
2 A. Oh, the second surgery was to put the
3 bone flap back on.
4 Q. You're right.
5 A. The third surgery was the infection.
6 Q. I'm sorry. I misspoke and you
7 corrected me. I appreciate that. The surgery
8 for the infection happened in Utah; is that
9 right?
10 A. Yes.
11 Q. Okay. So, let me back up, because I
12 had an error. Did Dr. Goren discuss with you the
13 idea that he thought Easton was improving prior
14 to the second surgery involving the effort to
15 restore the bone flap?
16 A. Yes.
17 Q. Okay. So, sometime in that period of
18 time between the first surgery at Geisinger and
19 the second surgery at Geisinger, Dr. Goren
20 communicated with you that he thought that Easton
21 was improving in some way or ways?
22 A. Yes.
23 Q. And what is your understanding of -- of
24 the basis on which Dr. Goren thought Easton was
91
1 improving?
2 A. Easton was walking. He was feeding.
3 He was doing well in his occupational therapy,
4 physical therapy. He was healing.
5 Q. And is it your understanding that all
6 of those things were happening prior to when
7 Easton had the bone flap surgery?
8 A. Yes.
9 Q. Okay. Did you ever ask Dr. Goren about
10 Easton's chance of survival, just to use that
11 phrase because we've used it before, at any point
12 in time?
13 A. No.
14 Q. Let's switch to Dr. Maffei. Did you
15 have an opportunity to talk with Dr. Maffei at
16 least once a day while Easton was in Geisinger?
17 A. Yes.
18 Q. And did there come a point in time when
19 Dr. Maffei communicated to you that he thought
20 Easton was improving?
21 A. Yes.
22 Q. Were those conversations at about the
23 same time that you were having those same
24 conversations with Dr. Goren?
92
1 A. The doctors would make rounds in the
2 morning, but they wouldn't come together.
3 Q. Okay.
4 A. That -- yeah. I usually didn't meet
5 them.
6 Q. Is your understanding that Dr. Maffei
7 was also expressing that he thought Easton was
8 improving prior to the bone flap surgery?
9 A. Yes.
10 Q. By the time Easton was discharged from
11 Geisinger, which, I think, was on August 31 of
12 2022, did either Dr. Goren or Dr. Maffei talk to
13 you about what they thought Easton's prognosis
14 was at that time?
15 A. I -- it was just common knowledge that
16 Easton received an epidural hematoma.
17 Q. Right. My question is more designed
18 toward, you know, whether they had expressed to
19 you how they thought Easton might recover after
20 he was discharged from Geisinger?
21 A. No.
22 Q. Did Dr. Goren ever discuss with you
23 that he thought that any of the injuries that
24 Easton suffered might be permanent?
93
1 A. I mean, it's a traumatic brain
2 injury. It's going to be a permanent thing,
3 so...
4 Q. Perhaps. But I'm not asking about
5 general medical knowledge. I'm more interested
6 in conversations that you had with Dr. Goren, and
7 what Dr. Goren might have said to you on those
8 subjects.
9 A. I don't remember. I was experiencing
10 so much trauma, that I just was trying to survive
11 myself.
12 Q. As you sit here today, do you have any
13 recollection of anything that Dr. Goren said to
14 you specifically at any moment in time while you
15 were at Geisinger?
16 MR. FULGINITI: I'm sorry.
17 Could you repeat the question?
18 MR. BLUTH: Sure. Would you
19 please read the question court
20 reporter?
21 (At this time, the court
22 reporter read from the record as
23 requested.)
24 MR. FULGINITI: At what
94
1 time? I'm sorry.
2 (At this time, the court
3 reporter read from the record as
4 requested.)
5 MR. BLUTH: Yeah. That
6 doesn't sound right.
7 MR. FULGINITI: Yes. The
8 question just doesn't make any sense to
9 me. She has already talked quite a bit
10 about her conversations with both
11 doctors.
12 MR. BLUTH: Ma'am, would you
13 like to take a break, a short break?
14 THE WITNESS: Yes.
15 MR. BLUTH: Okay. Let's do
16 that.
17 THE VIDEOGRAPHER: 12:09,
18 off video.
19 MR. BLUTH: Another ten
20 minutes?
21 MR. FULGINITI: Okay.
22 12:20.
23 (At this time, a short break
24 was taken.)
95
1 THE VIDEOGRAPHER: 12:41, on
2 video.
3 BY MR. BLUTH:
4 Q. All right. Ma'am, we were talking
5 about how you stayed with Easton while he was at
6 Geisinger.
7 We were approaching the time when
8 Easton was transferred to Utah to continue his
9 inpatient care.
10 Do you remember the last conversation
11 you had with Dr. Goren prior to Easton's
12 discharge and transfer to Utah?
13 A. I know we had a conversation. I don't
14 remember the specifics of that conversation.
15 Q. Okay. As Easton was prepared to
16 discharge from Geisinger and be transferred to
17 Utah to continue his inpatient care, did you have
18 an understanding from conversations that you had
19 had with Dr. Goren about how Dr. Goren expected
20 Easton to do going forward?
21 A. I don't recall that conversation. I
22 know he was hopeful that Easton would be okay, as
23 we all were hopeful.
24 Q. And then, similarly, do you recall the
96
1 last conversation that you had with Dr. Maffei
2 prior to Easton's discharge from Geisinger and
3 transfer to Utah?
4 A. I mean that -- I know that right before
5 Easton was leaving, Jace was concerned about his
6 swelling on his temple, so we had that
7 conversation which ended that resulting in the
8 infection.
9 Q. Did that conversation about the
10 swelling on the temple occur in Pennsylvania?
11 A. Yes. I had FaceTimed Jace, and Jace
12 was concerned about Easton's swelling.
13 Q. Okay. Did you raise that concern with
14 any of Easton's medical providers at Geisinger?
15 A. Yes.
16 Q. And to whom did you make that concern
17 known?
18 A. Dr. Goren and Dr. Maffei.
19 Q. And what did Dr. Goren tell you, if
20 anything, when you expressed your concern about
21 the bump on Easton's right temp?
22 A. It was just the swelling due to his --
23 the fluid needed to go somewhere, and so it had
24 pocketed there.
97
1 Q. When you raised that concern with
2 Dr. Maffei, did Dr. Maffei say anything different
3 from what Dr. Goren had described?
4 A. No. They were on the same page, and
5 Jace raised that concern not I.
6 Q. Okay. At that point, had Jace returned
7 to Utah with Brogan?
8 A. Yes.
9 Q. And you stayed back in Pennsylvania
10 with Easton?
11 A. Yes.
12 Q. And when did Jace return to Utah with
13 Brogan?
14 A. I don't remember the exact date. It
15 was when the team went home.
16 Q. Did Jace and Brogan go home with the
17 rest of the team?
18 A. Yes.
19 Q. Okay. When did Derek Oliverson leave
20 Pennsylvania?
21 A. He left sometime before his second
22 surgery, but came back to be with us during his
23 second surgery, and then he left Pennsylvania
24 when we left Pennsylvania. So, he was there
98
1 twice.
2 Q. When you say "when we left," do you
3 mean when you and Easton left on August 31?
4 A. Yes.
5 Q. So, if I understand what you are
6 describing, Derek had initially come, and, in
7 fact, had arrived at Geisinger before you were
8 able to get there, but left at some point, but
9 came back at around the time of Easton's second
10 surgery regarding the bone flap?
11 A. Yes.
12 Q. And from that point, from the time of
13 surgery for the bone flap until Easton's
14 discharge and transfer, Derek remained at
15 Geisinger?
16 A. Yes.
17 Q. From the time of Easton's second
18 surgery regarding the bone flap until Easton's
19 transfer from Geisinger, other than -- well
20 strike that. Let me back up for a moment.
21 At the time of Easton's second surgery,
22 was Jace still present in Pennsylvania?
23 A. Jace had gone home at the time of
24 Easton's second surgery.
99
1 Q. Okay. That's what I thought. And so,
2 from the time of Easton's second surgery until
3 his discharge, is it correct that Easton's family
4 in Pennsylvania consisted of you and Derek and
5 nobody else?
6 A. Derek's wife, Angie, was also there
7 when Derek came back.
8 Q. Okay. Other than you and Derek and
9 Angie, were there any other family members
10 present in Pennsylvania between the time of
11 Easton's second surgery and the time of his
12 discharge and transfer?
13 A. Before Easton's second surgery, he had
14 two cousins there. Derek's daughter and Derek's
15 son were also there.
16 Q. Okay. What are their names?
17 A. Katelyn Suesue and Eric Oliverson.
18 Q. Suesue is a last name, a family name?
19 A. Yes. That is Katelyn's last name.
20 She's married.
21 Q. Okay. Can you say that, please, for
22 the purposes of the court reporter?
23 A. I think it is S-U-E-S-U-E.
24 Q. Do you know how old those cousins --
100
1 Easton's cousins are?
2 A. Eric would have been 11 or 12 at the
3 time. Katelyn, in her early 20s.
4 Q. And do you know for how long, meaning
5 how many days, those cousins stayed in
6 Pennsylvania to be with Easton?
7 A. I would say four or five days.
8 Q. Did -- did they travel with their
9 father --
10 A. No.
11 Q. -- to Pennsylvania?
12 They came separately?
13 A. Yeah. They -- I'm not sure if they
14 went home with him, but, yes, they came
15 separately. Eric flew from Phoenix and then
16 Katelyn flew from Florida.
17 Q. You believe that Eric, who you
18 described as age 11 at the time, would have flown
19 from Phoenix to Pennsylvania by himself?
20 A. Yes. I know he met up with his sister,
21 Katelyn, and I don't know if they met up in
22 Pennsylvania, or if they met up in a different
23 airport.
24 Q. Okay.
101
1 A. But yeah.
2 Q. Meaning an airport in which they were
3 meeting, and then made the rest of the trip
4 together to Pennsylvania?
5 A. Yes.
6 Q. Okay. I understand. Thank you.
7 At the time that Easton was discharged
8 from Geisinger, do you have any understanding of
9 whether any of Easton's doctors had concern about
10 a possible infection at that point?
11 A. No, no concern.
12 Q. Well, when you described that Jace had
13 some concern about the bump on Easton's temple,
14 that you pointed out to Dr. Maffei and Dr. Goren,
15 is it correct that those doctors did not have
16 concern about infection at that point in time?
17 A. They didn't express it to me if they
18 did have concern.
19 Q. Understood. Ultimately, Easton was
20 transported by airplane from Pennsylvania to
21 Primary Children's Hospital?
22 A. Yes.
23 Q. Did you accompany Easton on the
24 airplane trip?
102
1 A. Yes.
2 Q. Do you know who or what entity paid for
3 that medical transport?
4 A. The Larry H. Miller Group.
5 Q. And what is the Larry H. Miller Group?
6 A. It's just a family that owns a lot of
7 car dealerships and movie theaters in Utah.
8 Q. Okay. And how were you connected with
9 the Larry H. Miller Group for purposes of
10 arranging the airplane transfer for Easton?
11 A. They reached out their services to
12 Jace.
13 Q. All right.
14 A. And Jace was in contact with them.
15 Q. And did you have, or did your family
16 have any social or other relationship with
17 Larry H. Miller Group prior to this event?
18 A. No.
19 Q. Is it correct to say that they were
20 people who were interested and concerned about
21 Easton's care and wanted to help?
22 A. Yes.
23 Q. Is the family responsible, meaning your
24 family, responsible for any part of the expense
103
1 related to Easton's flight, medical flight, from
2 Pennsylvania to Utah?
3 A. As far as I'm aware, Larry H. Miller
4 Group, they donated that to us.
5 Q. Okay. And in terms of the donation,
6 just so that I understand, did they own the
7 airplane that made Easton's transport to Utah, or
8 did they pay some other group or entity to do
9 that?
10 A. They paid for it. It was an
11 Intermountain Healthcare flight, plane, medical
12 plane.
13 Q. Do you have any understanding of what
14 the cost was that was paid by anybody, including
15 by the Robert H. Miller Group, so that Easton
16 could travel home to Utah on a -- on a medical
17 airplane?
18 A. I mean, I have my guesses, but, no, I
19 don't know how much it cost.
20 Q. Yeah. Like I said at the beginning,
21 we're not interested in a guess, but if you have
22 a factual basis on which you can estimate, then
23 you can answer the question.
24 A. I don't know. It wasn't a concern at
104
1 that time.
2 Q. Sure. All right. When Easton was at
3 Primary Children's Hospital, as an inpatient, at
4 some point he developed an infection in his head?
5 A. Yes.
6 Q. And how was it, to your knowledge, that
7 that infection was identified?
8 A. Dr. Bollo could tell by the swelling of
9 it, and he took blood draws, too, and he was able
10 to determine that he had an infection.
11 Q. Was Easton making any complaints of
12 pain or discomfort that were new or different in
13 terms of his recovery that indicated that he was
14 developing an infection in his head?
15 A. He would complain about pain and
16 discomfort the whole time. So, it was nothing
17 out of the ordinary.
18 Q. Okay. And that was exactly my
19 question, meaning did you have any new
20 complaints. I'm sure his recovery was painful
21 and uncomfortable.
22 Okay. My understanding is that
23 Easton's infection was initially treated by a
24 surgery that was done at Primary Children's
105
1 Hospital; is that right?
2 A. Yes.
3 Q. And then Easton had a PICC line placed,
4 meaning he had a line through which his doctors
5 could give him antibiotics for a period of weeks;
6 is that right?
7 A. Yes.
8 Q. And, ultimately, Easton was discharged
9 from Primary Children's Hospital with that PICC
10 line in place?
11 A. Yes.
12 Q. And then Easton was followed for an
13 additional period of time by some home health
14 nurses who would manage his line and antibiotics
15 until that treatment was completed; is that
16 right?
17 A. Yes.
18 Q. Okay. I want to talk about Easton's
19 course of care and recovery since he was
20 discharged from Primary Children's Hospital in
21 the middle of September of 2022. Okay?
22 A. Okay.
23 Q. My understanding he was discharged home
24 on September 13, 2022; is that right?
106
1 A. I believe so.
2 Q. Okay. Describe for me that day,
3 meaning the day that Easton left the hospital and
4 was able to come home for the first time since
5 his initial injury.
6 A. We were -- Jace and I were up north,
7 and we drove down, and Derek was also with us,
8 and we drove down to St. George, and we didn't --
9 we didn't tell Brogan or Blakely that we were
10 coming home. So, we surprised them.
11 They -- the reunion between Brogan and
12 Easton, how happy that we were to be together,
13 and how happy Easton was to be home, and to sleep
14 in his own bed, but we actually -- we are afraid
15 to tell people we were home, because we were
16 worried about our privacy. We were worried about
17 news stations.
18 So, Easton and I secluded ourselves for
19 a week, so that people didn't know that we were
20 home, because we just wanted to be together as a
21 family.
22 Q. And when you say secluded yourself,
23 what do you mean by that?
24 A. We stayed inside our house.
107
1 Q. Now, you had mentioned that you were up
2 north at the time of Easton's discharge. Where
3 were you?
4 A. Saying up north, as we were at
5 St. Lake City at Primary Children's.
6 Q. Oh, I see. Okay. So, when you said
7 "up north," you were -- you were with Easton, but
8 that was up north relative to the family home?
9 A. Yes.
10 Q. Got it. Did you -- much like you did
11 at Geisinger, did you spend every night that
12 Easton was in Primary Children's Hospital with
13 Easton in his hospital room?
14 A. Yes.
15 Q. Did Jace?
16 A. No. He -- for the majority of the
17 time, he stayed in a hotel close to the hospital.
18 He did go home to be with our other kids for the
19 short couple days, but then came back.
20 Q. And who was watching or caring for
21 Brogan and Blakely while you and Jace were in
22 Salt Lake City with Easton in the hospital?
23 A. Jace's mom and dad, Jace's sister --
24 and both of Jace's sisters' families took care of
108
1 them.
2 Q. Were Brogan and Blakely staying in your
3 family home during this period of time, or were
4 they staying with their relatives who were
5 watching them?
6 A. They were staying at our house.
7 Q. Okay. So, to the extent that different
8 family members were caring for them, and watching
9 them while you were busy with Easton, those
10 family members were staying in your house as well
11 with your children; is that right?
12 A. Yes.
13 Q. Okay. Do you have any videos or family
14 photos of the day of Easton's discharge from
15 Primary Children's Hospital and the reunion
16 between Easton and Brogan that you just
17 described?
18 A. Yes.
19 Q. We are going to ask you -- do you still
20 have those videos or photographs?
21 A. Yes.
22 Q. And which are they? Are they videos,
23 photographs, or both?
24 A. Both.
109
1 Q. Okay. We are going to ask you to hold
2 onto those, and provide them to Mr. Fulginiti,
3 and we will make requests through him to see
4 those.
5 A. Okay.
6 Q. Easton was -- when he was discharged
7 from Primary Children's Hospital, who were his
8 doctors, as of the day that he was discharged?
9 A. Dr. Flavin, Dr. Bollo, and then his
10 primary care doctor, Dr. Kaddu.
11 Q. Okay. Did Dr. Kaddu follow Easton
12 while he was in the hospital at all?
13 A. Yes. He was aware.
14 Q. Did Dr. Kaddu see Easton personally in
15 the hospital while he was at Primary Children's
16 Hospital?
17 A. No.
18 Q. Dr. Bollo is a neurosurgeon; is that
19 right?
20 A. Yes.
21 Q. And Dr. Flavin is a rehabilitative
22 doctor; is that right?
23 A. Yes.
24 Q. Okay. And those were the two doctors
110
1 who were primarily caring for Easton at -- when
2 he was an inpatient at Primary Children's
3 Hospital?
4 A. There was another doctor, I can't
5 recall his name, but an infectious disease
6 doctor.
7 Q. I was just going to ask you about that.
8 Easton -- Easton, because he had an infection
9 that required a surgery or a PICC line, had an
10 infectious disease doctor, but you do not recall
11 the name at this point?
12 A. Yes.
13 Q. All right. We can look in the records
14 and get that name.
15 But after -- after Easton was
16 discharged from the hospital, did he -- did
17 Easton ever see the infectious disease doctor
18 again?
19 A. Via Zoom, yes.
20 Q. Okay. When was the last time Easton
21 saw an infectious disease doctor?
22 A. The end of October '22 --
23 Q. Okay.
24 A. -- when he got his PICC line taken out.
111
1 Q. And has Easton -- has Easton had any
2 recurrence of the infection that he had in his
3 head since he last saw the infectious doctor and
4 finished his course of antibiotics?
5 A. No. He has not developed MRSA.
6 Q. Okay. Easton also had various
7 therapies that were recommended at the time that
8 he was discharged from Primary Children's
9 Hospital. Do you remember that?
10 A. Yes.
11 Q. And, at least according to the records,
12 that included occupational therapy, physical
13 therapy and speech therapy; is that right?
14 A. Correct.
15 Q. Were there any other therapies that
16 were recommended for Easton at that time that he
17 was discharged from the hospital?
18 A. No.
19 Q. Okay. How about any type of counseling
20 recommendation? Did any -- did any of Easton's
21 providers, medical providers, when he was in the
22 hospital, suggest any type of outpatient
23 counseling for Easton?
24 A. While he was at Primary Children's,
112
1 somebody came in and did a screening for his
2 mental health, and they determined that he didn't
3 need mental health therapy at that time.
4 Q. Okay.
5 A. And he -- he thought he didn't need it
6 either.
7 Q. Who thought he didn't need it either?
8 A. Easton.
9 Q. Okay. Did you -- while Easton was an
10 inpatient at Primary Children's Hospital, meaning
11 until September 13, 2022, did you have any
12 discussions with Dr. Flavin or Dr. Bollo on the
13 subject of whether Easton would benefit from any
14 type of counseling or mental healthcare?
15 A. I'm sure that came up. I know that
16 that has been important to me that Easton does
17 have mental healthcare.
18 Q. Okay. Describe for me the
19 circumstances in which it came up while Easton
20 was still an inpatient at Primary Children's
21 Hospital.
22 A. Jace and I were concerned about his
23 mental health. And so, that's when someone came
24 over -- came into his room and did a screening.
113
1 Q. Okay.
2 A. And they said he seemed fine.
3 Q. When you say "they," are you referring
4 to the provider that did that screen?
5 A. Yes.
6 Q. So, we know from the records that
7 Easton had a neuropsychological evaluation on
8 September 11, 2022, which would have been about
9 two days prior to his discharge from the
10 hospital. Is that the screen that you are
11 referring to?
12 A. No. It was a separate.
13 Q. Okay. What -- when was the screen
14 that you are referring to that occurred when
15 Easton was an inpatient at the hospital in Utah,
16 Salt Lake City, Utah?
17 A. It happened while he was an inpatient
18 there. I don't know on what date that occurred.
19 Q. Do you know what type of provider
20 performed that screen, meaning was it a
21 psychiatrist, a psychologist, a social worker, a
22 therapist, anything like that?
23 A. I don't remember.
24 Q. Okay. It was -- but whoever it was is
114
1 your understanding that it was that person who
2 suggested to you that Easton did not need
3 counseling services after he was discharged from
4 the hospital?
5 A. I believe they meant like counseling
6 services while he was at the hospital.
7 Q. Right. And I think you told me a
8 little bit earlier that Easton had a screen, but
9 whoever did the screen thought -- you might have
10 said Easton was fine.
11 I mean, your transcript will reflect
12 what you said, but my real question is: Is it
13 that person who did the screen that said to you
14 that Easton did not need counseling services
15 after he left the patient as an inpatient?
16 MR. FULGINITI: Object to
17 the form. I object to that, but you
18 can answer it if you understand it. It
19 was a lengthy question. It had a
20 preamble to it. Go ahead.
21 THE WITNESS: I don't
22 remember what the guidelines were on
23 that exam.
24 I know that Jace and I were
115
1 both worried about his mental health,
2 and we wanted to pursue mental health
3 therapy after he came home from the
4 hospital.
5 BY MR. BLUTH:
6 Q. Okay. We will talk about that in a
7 little -- in a little bit.
8 As I said to you a little earlier,
9 though, the medical record will show that Easton
10 had a neuropsychological assessment on
11 September 11, 2022. Do you remember that?
12 A. Yes.
13 Q. Did you ever have a conversation with
14 the provider who performed that assessment?
15 A. Yes.
16 Q. Do you have -- at the time, did you
17 have any understanding as to the recommendations
18 for follow-up care that the provider who
19 performed the neuropsychological testing was
20 recommending?
21 A. He wanted us to follow up with him in a
22 year --
23 Q. Okay.
24 A. -- to do another exam.
116
1 Q. Did that follow-up with that provider
2 ever happen?
3 A. Not with that particular provider.
4 Q. Okay. Prior to Easton's recent
5 evaluation by Dr. Goldstein, did Easton have any
6 follow-up or repeat neurological --
7 neuropsychological testing?
8 A. No.
9 MR. FULGINITI: No. You
10 said -- did you misspeak and said
11 neurological? Neuropsych, is that what
12 you meant to say?
13 MR. BLUTH:
14 Neuropsychological.
15 MR. FULGINITI:
16 Neurological, and then I think you
17 changed it to neuropsych. I just
18 wanted to make that wasn't a compound
19 question and about neuropsych.
20 MR. BLUTH: It wasn't a
21 compound question. I was asking only
22 about neuropsych.
23 BY MR. BLUTH:
24 Q. Ma'am, did you understand my question,
117
1 or would you like me to repeat it?
2 A. He did not receive -- besides the exam
3 from Dr. Goldstein, he did not receive any other
4 neuropsych exam.
5 Q. Okay. So, we're on the same page. All
6 right. When was Easton's last occupational
7 therapy visit?
8 A. I don't remember. I know that he --
9 that was his first therapy he graduated from, was
10 occupational therapy.
11 Q. Okay. The last record that I have seen
12 in Easton's medical records regarding an
13 occupational therapy visit or treatment was dated
14 November 7, 2022.
15 Do you have any reason to disagree that
16 that is -- that is when Easton's last
17 occupational therapy appointment was?
18 A. I have no reason to disagree.
19 Q. Okay. Where did Easton have his
20 outpatient occupational therapy?
21 A. At the Health & Performance Building at
22 Intermountain Healthcare.
23 Q. And which location?
24 A. 60 Regional.
118
1 Q. I'm sorry. I missed the first word of
2 that.
3 A. 60 Regional.
4 Q. And where is that located?
5 A. In St. George, Utah.
6 Q. Okay. I know that Easton had some home
7 health for a little bit of time after he was
8 discharged from the hospital. Did the home
9 health providers work with Easton at all on
10 occupational therapy?
11 A. No. Those providers were specifically
12 for his PICC line and blood draws.
13 Q. Okay. So, I'm going to share my screen
14 again.
15 MR. BLUTH: We are going to
16 mark this as 131.
17 (At this time, Occupational
18 Therapy Forms were marked for
19 identification as Exhibit-131.)
20 BY MR. BLUTH:
21 Q. All right. Can you see this note,
22 ma'am?
23 A. Yes.
24 Q. All right. And you see at the top it
119
1 says Occupational Therapy Forms?
2 A. Uh-huh.
3 Q. Is that a yes?
4 A. Yes.
5 Q. And then it says that this is an
6 Occupational Therapy Outpatient Pediatric Daily
7 Doc, it says, on the date I described,
8 November 7, 2022. Do you --
9 A. Yes.
10 Q. -- see that?
11 Okay. And on this date under Clinical
12 Assessment on the third page, it says -- I wonder
13 if I am highlighting here. Oh, yeah. Do you see
14 where I am highlighting?
15 A. Yes.
16 Q. Okay. It says, Clinical Assessment
17 Summary Occupational Therapy, patient would
18 benefit from continued skilled occupational
19 therapy treatment in order to continue to address
20 the deficits noted above. Do you see that
21 language?
22 A. Yes.
23 Q. Okay. I have not seen any additional
24 records of occupational therapy for Easton
120
1 after this visit. Do you know if there was
2 any?
3 A. There was not. He was cleared from
4 occupational therapy by Dr. Flavin.
5 Q. Okay.
6 A. To discontinue the therapy.
7 Q. And do you know when Dr. Flavin would
8 have discontinued or discharged Easton from
9 occupational therapy?
10 A. I believe he visited with Dr. Flavin
11 the first part of November, and that's when she
12 released him from occupational therapy.
13 Q. Okay. Do you believe that that visit
14 with Dr. Flavin was before or after November 7 of
15 2022, when this occupational therapy visit took
16 place?
17 A. After.
18 Q. I will take it down.
19 We will put up what -- ma'am, the last
20 visit that I've seen regarding any home health
21 appointment by Easton was on November 29 of 2022.
22 Does that sound about right to you for Easton's
23 last home health visit?
24 A. Yeah. I think it was a blood draw.
121
1 Q. And you said this earlier, the home
2 health nurses and providers were taking care of
3 Easton solely for his PICC line and his
4 antibiotics?
5 A. Yes.
6 Q. And as of the time of Easton's last
7 home health visit on November 29, 2022, had his
8 infection, to your knowledge, completely
9 resolved?
10 A. Yes. He got his PICC line removed at
11 the end of October.
12 Q. Right. And since then, has Easton had
13 any concern for infection that you're aware of
14 related to his head injury and related surgeries?
15 A. No.
16 MR. FULGINITI: Well,
17 objection.
18 MR. BLUTH: I'm sorry. Ken,
19 did you say something?
20 MR. FULGINITI: Well,
21 concern, I didn't know what you meant
22 by did he have any concern. You meant
23 did he have --
24 THE COURT REPORTER: I can't
122
1 hear you, Ken.
2 MR. BLUTH: We can't hear
3 you.
4 THE COURT REPORTER: We
5 can't hear you.
6 MR. FULGINITI: Can you hear
7 me now?
8 THE COURT REPORTER: Yes.
9 MR. BLUTH: Yes, sir.
10 MR. FULGINITI: Like I have
11 been hearing everything.
12 MR. BLUTH: You are cutting
13 in and out.
14 MR. FULGINITI: Can you hear
15 me?
16 MR. BLUTH: Yes. My
17 question, if it helps, was whether
18 Mrs. Oliverson, his mother, had any
19 concern for infection since the PICC
20 line was removed and the home health
21 treatment has ended.
22 MR. FULGINITI: It's about
23 the word "concern," meaning did he
24 have --
123
1 THE COURT REPORTER: You are
2 going in and out.
3 MR. FULGINITI: -- like
4 maybe an infection.
5 MR. BLUTH: We are not
6 hearing -- we are not hearing you in
7 complete sentences, Ken.
8 MR. FULGINITI: Can you hear
9 me now?
10 THE COURT REPORTER: Yes.
11 MR. BLUTH: Very loudly.
12 MR. FULGINITI: All right.
13 My concern was just the word "concern,"
14 was did she have any concern for an
15 infection.
16 I am assuming you mean, was
17 there anything going on with him that
18 she thought maybe was an infection?
19 MR. BLUTH: Correct. That
20 is what I meant.
21 BY MR. BLUTH:
22 Q. Is that how you understood my question,
23 ma'am?
24 MR. FULGINITI: That was my
124
1 objection. Can you hear me?
2 THE WITNESS: Yes. I can
3 hear you, Ken.
4 BY MR. BLUTH:
5 Q. Ma'am, is that how you understood --
6 MR. FULGINITI: Wait. Wait.
7 Wait. Can you hear me?
8 MR. BLUTH: Yes.
9 THE COURT REPORTER: I can
10 hear you.
11 MR. FULGINITI: All right.
12 Did you hear my objection?
13 MR. BLUTH: Yes.
14 MR. FULGINITI: Go ahead.
15 I'm sorry.
16 MR. BLUTH: No worries.
17 BY MR. BLUTH:
18 Q. Ma'am, is that how you understood my
19 question, meaning to ask you whether you had any
20 concerns?
21 MR. FULGINITI: After all --
22 THE WITNESS: His infection
23 was gone, but, yes, I did have concerns
24 that he would grow a new infection,
125
1 because his white blood count was so
2 low.
3 BY MR. BLUTH:
4 Q. All right. But since -- my question
5 is: Since November 29 of 2022, when Easton's
6 home health visits related to that infection had
7 ended, did you have any concern, as his mother,
8 that he was developing another infection as a
9 result of his head injury or the surgeries that
10 followed?
11 A. No.
12 Q. All right. This has been previously
13 been marked as Exhibit-116. Do you see this
14 note, ma'am?
15 A. Yes.
16 Q. This is, as you can see, a
17 December 20, 2022 note of a visit that Easton had
18 with Dr. Flavin. Do you see that?
19 A. Yes.
20 Q. Okay. Now, you had mentioned earlier
21 that Easton had an appointment with Dr. Flavin at
22 which she recommended that Easton discontinue his
23 occupational therapy. Do you believe that that
24 recommendation of Dr. Flavin came before
126
1 December 20, 2022?
2 A. No. It was most likely from this
3 visit.
4 Q. Okay. So, I'm on the second page of
5 this exhibit, under a heading called Therapy. Do
6 you see that?
7 A. Yes.
8 Q. All right. It says, is currently doing
9 physical therapy to work on balance. Do you see
10 that?
11 A. Yes.
12 Q. Then it says, occupational therapy and
13 speech therapy to work on cognition. Do you see
14 that?
15 A. Yes.
16 Q. Then it says, plan to transition --
17 transition Easton into a Pathways Program to help
18 him get back into sports. Do you see that?
19 A. Yes.
20 Q. Okay. What is a Pathways Program, if
21 you know?
22 A. It's a program here called
23 Acceleration. It is a speed and agility program
24 that he would transfer to after he was done with
127
1 his physical therapy.
2 Q. Did Easton ever participate in a
3 Pathways Program?
4 A. He did.
5 Q. And who was the provider or what
6 organization put on the program that Easton
7 attended?
8 A. Intermountain Healthcare.
9 Q. And at which location did Easton
10 participate in that program?
11 A. He participated in the location at the
12 Be Well Complex on -- in St. George.
13 Q. Okay. Was there a medical provider or
14 a doctor that was overseeing the program?
15 A. I'm not sure.
16 Q. What type of person, in terms of their
17 experience or credentials, did Easton work with
18 when he participated in the Pathways Program?
19 A. Jace took him to those sessions, but I
20 do know that they have personal trainers at those
21 sessions.
22 Q. Okay. So, personal trainer is one type
23 of person that Easton worked with. Any other
24 type of provider or service that you are aware of
128
1 that Easton worked when he was in the Pathways
2 Program?
3 A. Not what I'm aware of.
4 Q. Okay. Do you remember the dates during
5 which Easton participated in the Pathways
6 Program?
7 A. I don't.
8 Q. Could you generally estimate the dates,
9 even if just by month and year?
10 A. Maybe the second quarter of '23.
11 Q. Would that generally be in the March to
12 June vicinity of 2023?
13 A. Yes.
14 Q. Okay. According to this note, anyways,
15 it seems as if Dr. Flavin intended Easton to
16 continue occupational therapy. Is your
17 understanding different from that?
18 MR. FULGINITI: Objection to
19 the form. You can answer as to your
20 understanding, not his interpretation.
21 THE WITNESS: If Dr. Flavin
22 recommended something to us for
23 Easton's therapy, we followed through
24 with those recommendations.
129
1 So, we discontinued
2 occupational therapy because
3 Dr. Flavin cleared Easton from that
4 therapy.
5 BY MR. BLUTH:
6 Q. All right. And we were talking a
7 little earlier about when Dr. Flavin would have
8 done that.
9 You had originally thought that it
10 might have been in November, and then you saw
11 this note, and you thought your recollection
12 might be refreshed -- refreshed that it was at
13 this visit.
14 Does looking at this note now provide
15 any further refreshment of your recollection as
16 to when Dr. Flavin would have suggested that
17 Easton discontinue occupational therapy?
18 MR. FULGINITI: Objection to
19 the preamble, but you can answer the
20 question.
21 THE WITNESS: I don't know.
22 BY MR. BLUTH:
23 Q. According to this note, Dr. Flavin also
24 wrote that Easton has a 504 Plan for
130
1 accommodations at school. Do you see that?
2 A. Yes.
3 Q. Did Easton have a 504 Plan for
4 accommodations at school as of December of
5 2022?
6 A. No.
7 Q. Do you know why or -- excuse me. Do
8 you know how Dr. Flavin would have learned that
9 Easton had a 504 Plan as of December of 2022?
10 A. Jace talked about a 504 in progress.
11 So, that's probably where she got that
12 information from.
13 Q. Okay. Up until this past summer,
14 meaning prior to Easton entering the ninth grade,
15 had Easton ever had an 504 Plan for
16 accommodations at school from the time of his
17 injury until prior to starting the ninth grade
18 this school year?
19 A. No.
20 Q. Does Easton have a 504 Plan or
21 accommodation in school in place now?
22 A. No. He has an IEP.
23 Q. Okay. When did Easton first have an
24 IEP?
131
1 A. The summer going into his freshman
2 year, his ninth grade year.
3 Q. All right. So, the IEP is something
4 that was in place for the first time over the
5 past month or two; is that correct?
6 A. Yes. It started in August of '24.
7 Q. Okay. And is that IEP in writing?
8 A. Yes.
9 Q. And do you have a copy?
10 A. Yes.
11 Q. Okay. That is something else that we
12 will make a request for through Mr. Fulginiti.
13 And so, if you can hold onto that, or provide a
14 copy to him, that would be helpful.
15 But just so I understand, the IEP that
16 was put in place for Easton in August of 2024 is
17 the first IEP that Easton has ever had; is that
18 correct?
19 A. Yes.
20 Q. Okay. Then under Activity, as of
21 December of 20 -- December 20 of 2022, it says,
22 mom and dad report that he, meaning Easton, was
23 cleared for baseball by Dr. Bollo. Do you see
24 that?
132
1 A. Yes.
2 Q. When did Dr. Bollo first clear Easton
3 to play baseball?
4 A. I don't recall when that time exactly
5 was.
6 Q. Did Dr. Bollo first clear Easton to
7 play baseball prior to December 20 of 2022?
8 A. I don't recall.
9 Q. Do you have any reason to dispute the
10 accuracy of the statement in Dr. Flavin's note of
11 this date that says, mom and dad report that he
12 was cleared for baseball by Dr. Bollo as of
13 December 20, 2022?
14 A. No. It wasn't baseball season at that
15 time.
16 Q. Okay.
17 A. He was not playing baseball at that
18 time.
19 Q. Was Easton not playing baseball at that
20 time because it was not baseball season?
21 MR. FULGINITI: Objection to
22 form. You can answer.
23 THE WITNESS: Yes. It was
24 not baseball season. So, he didn't
133
1 have the opportunity to play baseball.
2 BY MR. BLUTH:
3 Q. Okay. When is baseball season in your
4 geographic location?
5 A. Baseball season goes all year-round.
6 It is just a discrepancy of when the teams choose
7 when to play.
8 Q. So, then what is it that you meant when
9 you said it wasn't baseball season in December of
10 2022 -- excuse me, that it wasn't baseball season
11 when Dr. Bollo cleared Easton to play baseball?
12 A. Easton's team plays in the spring,
13 and -- that he was on at that time, the
14 RoadRunners, they play in the spring and summer.
15 Q. Okay.
16 A. But they take the fall off for football
17 and the winter off as well.
18 Q. Okay. So, following -- following
19 December 20, 2022, at least as of the time of
20 this visit with Dr. Flavin, is the next time that
21 Easton would have had an opportunity to play
22 baseball was the spring of 2023 when his team
23 resumed play?
24 A. Yes.
134
1 Q. And did Easton play baseball with his
2 team in the spring of 2023, whenever play
3 resumed?
4 MR. FULGINITI: Objection to
5 form, but you can answer.
6 THE WITNESS: He practiced,
7 yes.
8 BY MR. BLUTH:
9 Q. Okay. Practiced with his team?
10 A. Yes.
11 Q. And when was the first time that Easton
12 played in a baseball game against another team?
13 A. The summer of 2023.
14 Q. Okay. And with this discussion about
15 Easton's baseball, and when he started playing,
16 does that refresh your recollection at all as to
17 when Dr. Bollo would have cleared Easton to play
18 baseball?
19 MR. FULGINITI: Objection.
20 I'm sorry. What do you mean?
21 MR. BLUTH: Well, she didn't
22 remember earlier when it was that
23 Dr. Bollo had cleared Easton to play
24 baseball.
135
1 Now that we have seen the
2 notes and gotten into some of the
3 details, I am asking whether that
4 refreshes her recollection.
5 MR. FULGINITI: Same
6 objection. You can answer, if you
7 understand.
8 THE WITNESS: No.
9 BY MR. BLUTH:
10 Q. Further down -- further down in
11 Dr. Flavin's note, it says the family is pursuing
12 counseling with a friend at the start of the
13 year. Do you see that?
14 A. Yes.
15 Q. Did that counseling ever take place?
16 A. Mental health counseling was difficult
17 for us to find Easton a match for. Jace had a --
18 had a friend that we were hoping to get him set
19 up with his business, but it was never a good fit
20 for Easton.
21 It was hard enough to get a -- you
22 know, Easton to therapy, let alone trying to find
23 someone that he felt comfortable talking about
24 his situation with.
136
1 Q. Now, when you say "hard enough to get
2 Easton to therapy," are you talking specifically
3 about some sort of mental health counseling or
4 therapy?
5 A. Yes. He didn't want to participate in
6 mental health therapy.
7 Q. And what is your understanding as to
8 why Easton did not want to participate?
9 A. Because most -- what teenaged boy wants
10 to sit and talk to a stranger about their
11 feelings.
12 Q. Okay.
13 A. It just wasn't something --
14 Q. I'm sorry.
15 A. It just wasn't something that he was
16 interested in.
17 Q. Okay. All right. So, this note
18 references a family friend -- excuse me. It
19 references that the family is pursuing counseling
20 with a friend. What was that name of the friend
21 that the family was pursuing counseling with?
22 A. Ryan Ruud.
23 Q. And is it correct that Easton never had
24 any counseling sessions with Mr. Ruud?
137
1 A. Correct.
2 Q. If Mr. Ruud had authored a letter that
3 suggested that Easton was regularly seeing him
4 for counseling, that would be incorrect?
5 A. Yes.
6 Q. Do you know why Mr. Ruud would write
7 such a letter that said that Easton was in
8 counseling with him when he was not?
9 A. I do not.
10 Q. Are you aware that such a letter
11 exists?
12 A. No.
13 Q. Did you see that letter that was used
14 as an exhibit at Jace Oliverson's deposition?
15 A. No. I didn't attend Jace Oliverson's
16 deposition. I did review it, though.
17 Q. Right. And that is my question. I
18 know that you weren't there, but my question is:
19 When you read the transcript, and looked at the
20 exhibits, did you see the letter that Ryan Ruud
21 authored?
22 A. I did not look at that specific
23 exhibit.
24 Q. Okay. Has Easton had counseling at any
138
1 time up until the present?
2 A. Mental health counseling?
3 Q. Correct.
4 A. Yes.
5 Q. Okay. And who was -- who was or is the
6 provider of Easton's mental health counseling?
7 A. Dr. Sam Goldstein.
8 Q. Okay. Anybody else?
9 A. He had a couple of sessions over at
10 Southwest Behavioral Health trying to find a good
11 match, but those are initial sessions, repeat
12 sessions he has had with Dr. Goldstein.
13 Q. Okay. We will talk about Southwest
14 Behavioral Health in a little while. My
15 understanding is that Dr. Goldstein did
16 neuropsychologic testing on Easton; is that
17 correct?
18 A. Yes.
19 Q. And is Dr. -- to your understanding, is
20 Dr. Goldstein also providing counseling or mental
21 health counseling to Easton, in addition to the
22 neuropsychologic testing?
23 A. Yes. The neuropsychologic testing was
24 done in the summer, but now, he is continuing
139
1 mental health therapy with Dr. Goldstein.
2 Q. And how frequently does Easton see
3 Dr. Goldstein for the mental health counseling?
4 A. Bi-monthly.
5 Q. And when you say "bi-monthly," is that
6 to mean twice a month?
7 A. Yes.
8 Q. Okay. And are those in-person or video
9 visits?
10 A. Both.
11 Q. And when did the mental health
12 counseling services with Dr. Goldstein start?
13 A. I would say July of 2024.
14 Q. And when Easton has the mental health
15 counseling sessions with Dr. Goldstein twice a
16 month, do you participate in those?
17 A. I do not.
18 Q. Are those sessions, to your
19 understanding, in which Easton is alone with
20 Dr. Goldstein, and the two of them are speaking
21 privately without any parent present?
22 A. Yes.
23 Q. How many sessions of mental health
24 counseling with Dr. Goldstein has Easton had?
140
1 A. Four or five.
2 Q. Has Easton described for you anything
3 that has been discussed during those sessions?
4 A. Yes.
5 Q. And what has Easton described to you
6 about his sessions with Dr. Goldstein?
7 A. He told me about Dr. Goldstein getting
8 some baseball cards that he found at a thrift
9 store. They reviewed these baseball cards.
10 He told me of a time that he was
11 explaining to Dr. Goldstein about an experience
12 he had, and Dr. Goldstein explained to him that
13 he had a panic attack.
14 Q. Okay. Anything else that you are aware
15 of that Easton has discussed with Dr. Goldstein?
16 A. No. I let him choose if he wants to
17 talk to me about it or not.
18 Q. Okay. When was the panic attack
19 episode that Easton described to Dr. Goldstein?
20 A. A few weeks ago.
21 Q. So, something very recent?
22 A. Yes.
23 Q. Okay. Were you present when Easton had
24 that panic attack?
141
1 A. No.
2 Q. Was anybody present, to your knowledge?
3 A. Yeah. Yes.
4 Q. Who was present?
5 A. His baseball team.
6 Q. Was the panic attack something that
7 happened at baseball practice or a game?
8 A. It was him reviewing the batting order,
9 and him being at the last of the batting order.
10 Q. All right. I just want to make sure
11 that I understand that. Some coach or manager of
12 the team was reviewing the batting order for a
13 game; is that correct?
14 MR. FULGINITI: Objection to
15 the form. You can answer.
16 THE WITNESS: Easton saw the
17 batting order, and he experienced a
18 panic attack.
19 BY MR. BLUTH:
20 Q. Okay. A panic attack upon -- your
21 understanding is that Easton experienced a panic
22 attack upon learning that he was listed last in
23 the batting order?
24 A. Yes.
142
1 Q. Okay. And what type of complaints or
2 symptoms did Easton have at the time of the panic
3 attack?
4 A. He told me he just felt overwhelmed.
5 He had a hard time breathing. He just had a hard
6 time. Yeah.
7 Q. Did you -- did you ever have a
8 conversation with Easton about this panic attack?
9 MR. FULGINITI: You mean
10 after -- I don't understand what you
11 mean. She is talking to you about the
12 conversation that she had with Easton.
13 MR. BLUTH: Well, I wasn't
14 clear on that. That's why I am asking.
15 MR. FULGINITI: I mean,
16 everything that she has related to you
17 is what Easton told her from the
18 doctor's appointment, but you can go
19 ahead and ask again.
20 MR. BLUTH: Well, that is
21 what I am unclear about, is whether
22 these are things that Easton described
23 to the doctor, or whether these are
24 things that Easton described to his
143
1 mother.
2 MR. FULGINITI: Or both.
3 MR. BLUTH: Right, or both.
4 MR. FULGINITI: You can
5 answer.
6 THE WITNESS: We had this
7 conversation after he had a
8 conversation with Dr. Goldstein. He
9 told me about.
10 BY MR. BLUTH:
11 Q. Okay.
12 A. Yes.
13 Q. So, prior to -- well, let me strike
14 that.
15 From the time of the panic attack until
16 the time that Easton first discussed it with
17 Dr. Goldstein, did Easton tell you he had this
18 feeling of being overwhelmed upon seeing his name
19 at the bottom of a batting order?
20 A. No.
21 Q. Okay. Did you first learn of this
22 panic attack from Easton or from Dr. Goldstein or
23 from some other source?
24 A. From Easton.
144
1 Q. Okay. So, if I understand this, after
2 the panic attack and after Easton described it to
3 Dr. Goldstein in one of his mental health
4 counseling sessions with him, then Easton
5 described for you what he had experienced?
6 A. Yes.
7 Q. Okay. Did Easton ever specify for you
8 what it was about seeing his name at the bottom
9 of a batting order that made him feel
10 overwhelmed?
11 A. Frustration. His name used -- before
12 August 15, his -- he was always at the beginning
13 of the batting order, nowhere near the end.
14 Q. Okay. And, to your knowledge, had
15 Easton had a panic attack prior to this occasion?
16 A. No.
17 Q. And do you know the date on which this
18 panic attack happened?
19 A. I don't.
20 Q. But could you estimate based on any
21 other facts?
22 A. A few weeks ago.
23 Q. Okay. All right. There is a comment
24 here about sleep, which we talked about earlier,
145
1 and then under neuropsychiatric testing, it says,
2 follow up in one year, although I think you
3 already explained that the next neuropsych
4 testing that Easton had after his discharge from
5 Primary Children's Hospital was with
6 Dr. Goldstein; is that correct?
7 A. Yes.
8 Q. And then it says, pursue the TOPS
9 Program. Is that different from the Pathways
10 Program described earlier?
11 A. I don't know what the TOPS Program is.
12 Q. Okay. And then Dr. Flavin -- excuse
13 me, Flavin recommended that Easton avoid contact
14 and high velocity activity. Do you see that?
15 A. Yes.
16 Q. Did there come a point in time that
17 Easton was cleared for contact sports?
18 A. What do you consider contact sports?
19 Q. Well, such as wrestling.
20 MR. FULGINITI: Objection to
21 form, but you can answer as to
22 wrestling.
23 THE WITNESS: He was -- he
24 needed to wait a year after to do
146
1 wrestling, according to Dr. Bollo.
2 BY MR. BLUTH:
3 Q. Okay. And was it Dr. Bollo that
4 cleared Easton to play wrestling?
5 A. Yes.
6 Q. And do you know when Dr. Bollo cleared
7 Easton to participate in wrestling?
8 A. For the -- it was a year after his
9 injury. So, it would be August of 2023.
10 Q. Okay. My question is: At which visit
11 did -- or at what time did Dr. Bollo communicate
12 to you that he was clearing Easton to play
13 wrestling?
14 A. I don't remember. I would have to go
15 through and look at the records.
16 Q. Okay. According to the records I see,
17 Easton's last visit with Dr. Bollo was on
18 April 17 of 2023; does that sound right to you?
19 A. Yes.
20 Q. Okay. So, is it fair to say that it
21 was either at that visit or some time prior to
22 that that Easton was cleared to play wrestling?
23 A. Yes.
24 MR. FULGINITI: Objection.
147
1 You can answer.
2 BY MR. BLUTH:
3 Q. I'm sorry. Did you answer, ma'am?
4 A. Yes.
5 Q. And what was your answer?
6 A. Yes. At one of those visits is
7 when Dr. Bollo would have cleared him to
8 wrestle.
9 Q. But if I understand what you are
10 telling me, it's not that Dr. Bollo cleared
11 Austin to participate in wrestling immediately,
12 it sounds like whenever it was that Dr. Bollo
13 cleared Easton to participate in wresting, it was
14 in the context of waiting at least a year after
15 his injury to participate in wrestling; is that
16 correct?
17 MR. FULGINITI: Objection to
18 form. You can answer.
19 THE WITNESS: He was not --
20 he was able to practice, but not able
21 to participate in live wrestling until
22 Dr. Bollo clear him to do that.
23 BY MR. BLUTH:
24 Q. Okay. So, when was it that Dr. Bollo
148
1 cleared Easton to participate in wrestling
2 matches?
3 A. A year after his injury.
4 Q. Okay. Right. I understand when Easton
5 could start participating in wrestling matches,
6 but my question is: When did it -- when did
7 Dr. Bollo clear Easton to participate in any
8 matches at any time, as differentiating, as you
9 just did, from wrestling practice?
10 A. I don't remember.
11 Q. But regardless of when it -- when it
12 was, your understanding that it was Dr. Bollo who
13 cleared Easton to participate in wrestling
14 practice, and Dr. Bollo who cleared Easton to
15 eventually participate in wrestling matches; is
16 that correct?
17 A. Yes.
18 Q. And when was it that Easton first
19 participated in a wrestling match after his
20 injury?
21 A. I don't remember. He did a lot of
22 practicing. I don't remember when his first
23 actual match was. I -- I didn't necessarily
24 like watching it -- those. I really don't
149
1 remember.
2 Q. And what is it about Easton's wrestling
3 matches that you don't like to watch?
4 A. I mean, I never liked to watch
5 wrestling matches before. It is just not
6 something, as a mother, you like watching.
7 Q. I understand. All right. I'll close
8 this one.
9 MR. FULGINITI: Is it a good
10 time for a break?
11 MR. BLUTH: Sure.
12 THE VIDEOGRAPHER: 1:29, off
13 video.
14 MR. BLUTH: You want another
15 ten minutes?
16 MR. FULGINITI: Yes. That
17 would be fine.
18 MR. BLUTH: Okay. See
19 everybody at 1:40.
20 (At this time, a short break
21 was taken.)
22 (At this time, a discussion
23 was held off the record.)
24 THE VIDEOGRAPHER: 1:40, on
150
1 video.
2 BY MR. BLUTH:
3 Q. All right. Ma'am, to your knowledge,
4 did Easton ever have a seizure?
5 A. Yes.
6 Q. And when did Easton have a seizure?
7 A. It was -- happened at home in
8 September.
9 Q. Okay. Of what year?
10 A. 2022. When we tried to get him off of
11 his Keppra medication, to wean him off.
12 Q. And did that happen on one occasion or
13 more than one occasion?
14 A. It happened twice.
15 Q. Okay. And how far apart were the two
16 occurrences?
17 A. I don't remember. It was less than a
18 week apart, though.
19 Q. And were they both in September of
20 2022?
21 A. Yes.
22 Q. And did any of Easton's medical
23 providers confirm for you that what happened at
24 home was, in fact, a seizure?
151
1 A. Yes.
2 Q. And who was that?
3 A. It would have been someone at
4 Dr. Bollo's office.
5 Q. Okay. And did you observe either of
6 these seizures?
7 A. He came up to me and told me that he
8 felt weird, that his left side, he couldn't feel,
9 his left side of his face went numb.
10 Q. All right. So, and that's Easton
11 telling you that?
12 A. Yes.
13 Q. And Easton's complaint about the left
14 side of his face going numb, was that the same
15 complaint he made to you relative to both of the
16 seizures?
17 A. Yes. He told me that he was feeling
18 the same thing again.
19 Q. Did you observe either of these
20 seizures, or is this something that Easton
21 described for you after the fact?
22 A. So, I don't recall exactly what these
23 seizures were called, but it wasn't like a
24 convulsing seizure. It was just like his left
152
1 side went numb.
2 Q. For how long during each of these
3 occurrences did Easton's left side go numb?
4 A. We didn't keep track of the time.
5 Q. Okay. Do you have any way to estimate?
6 I mean, was this seconds, or minutes, or hours,
7 or anything else?
8 A. Minutes.
9 Q. Each occasion lasted a duration of
10 minutes?
11 A. Yes.
12 Q. Did you seek medical care on an
13 immediate basis following either of these two
14 seizures?
15 MR. FULGINITI: Objection as
16 to immediate, but you can go ahead and
17 answer.
18 THE WITNESS: We did report
19 back to the neurosurgeon's office after
20 he occurred these, yes.
21 BY MR. BLUTH:
22 Q. And when you say "report back," was
23 that a visit, or a phone call, or some message
24 through a patient portal, or something else?
153
1 A. A phone call.
2 Q. Okay. On the days that these seizures
3 happened, the two seizures happened, was Easton
4 seen by a doctor on the same day that the seizure
5 occurred?
6 A. He spoke to a doctor, but he was not
7 seen by a doctor.
8 Q. Okay. When you say Easton spoke to a
9 doctor, explain to me how that was accomplished.
10 A. A phone call.
11 Q. Okay. Was it a video visit or just a
12 phone call?
13 A. Just a phone call.
14 Q. And is that -- was it just a phone call
15 for both of the seizure occasions?
16 A. Yes.
17 Q. Dr. -- according to his notes, anyway,
18 Dr. Bollo started weaning Easton off of Keppra at
19 the end of November 2022. Is that consistent
20 with your recollection?
21 A. Yes.
22 Q. Okay. And once Easton started to wean
23 from Keppra at the end of November of 2022, did
24 he have any other complaints that you understood
154
1 to be consistent with a possible seizure?
2 A. No.
3 Q. Has any of Easton's doctors told you
4 Easton has had a seizure at any time since
5 Dr. Bollo started weaning Easton off Keppra at
6 the end of November of 2022?
7 A. No.
8 MR. BLUTH: Okay. All
9 right. This is -- we are going to mark
10 this as the Exhibit-132.
11 THE COURT REPORTER:
12 Correct.
13 (At this time, Office Clinic
14 Notes dated 12/23/22 were marked for
15 identification as Exhibit-132.)
16 BY MR. BLUTH:
17 Q. Can you see this note, ma'am?
18 A. Yes.
19 Q. Okay. This is Easton's -- this is an
20 office note from Dr. Kaddu on 12/23/2022. Do you
21 see that?
22 A. Yes.
23 Q. So, this would have been three days
24 after the Dr. Flavin note that we looked at in
155
1 the last exhibit. Did you accompany Easton to
2 this visit?
3 A. I don't remember.
4 Q. Okay. Can you see the top of this page
5 it says, was on Keppra for post-trauma seizures?
6 A. Yes.
7 Q. But being weaned, and will be off in
8 the next week to ten days. Do you see that?
9 A. Yes.
10 Q. And then Dr. Kaddu wrote back in school
11 full-time and starting physical activity. Do you
12 agree that Austin by December 23, 2022, was back
13 in school full-time?
14 MR. FULGINITI: Objection to
15 form. And you keep calling him Austin.
16 BY MR. FULGINITI:
17 Q. Oh, I am sorry. I apologize. I don't
18 mean to do that.
19 Do you agree, ma'am, that Easton was
20 back in school full-time by December 23, 2022?
21 A. No. He would be on Christmas break,
22 but he would go back to school full-time once
23 they went back to school in January.
24 Q. Okay. Prior to Christmas break in
156
1 December of 2022, had Easton been -- had Easton
2 returned to school full-time?
3 A. No.
4 Q. Okay. As of Christmas break in
5 December of 2022, had Easton started physical
6 activity?
7 MR. FULGINITI: Objection to
8 form. You can answer, if you know what
9 that means.
10 THE WITNESS: What -- what
11 do you -- I mean, he would -- as soon
12 as he got his PICC line out, he would
13 throw the baseball around with Jace.
14 He would -- you know, he was doing
15 physical activity at physical therapy.
16 BY MR. BLUTH:
17 Q. Okay.
18 A. So, yes. He was doing physical
19 therapy --- activity.
20 Q. We talked earlier that Easton's PICC
21 line came out at the end of October of 2022; is
22 that right?
23 A. Yes.
24 Q. And so, is it correct to say that
157
1 Easton started throwing a baseball at some point
2 shortly thereafter?
3 A. Playing catch with his father, yes.
4 Q. Okay. And I think we already discussed
5 that as of December 23, 2022, Easton had been
6 cleared for sports?
7 MR. FULGINITI: Objection.
8 I think we discussed that he was
9 cleared to practice baseball. I think
10 that we discussed that he was not
11 cleared for wrestling. So, I think to
12 generalize it like that is confusing.
13 MR. BLUTH: Okay. All
14 right. I'll move on. We have already
15 talked about those subjects.
16 BY MR. BLUTH:
17 Q. And Easton continued to be followed by
18 Dr. Bollo, his neurosurgeon, correct?
19 A. As recommended, we did all the
20 follow-ups with Dr. Bollo, correct.
21 Q. Okay. As of December 23, 2022, who
22 were Easton's medical providers? Dr. Bollo, for
23 example, Dr. Flavin, we know he was treating
24 with.
158
1 A. And then Dr. Kaddu, his primary care
2 doctor.
3 Q. Okay. Anybody else?
4 A. Being treated by a doctor, those were
5 the three doctors that he was being treated by.
6 Q. Okay. Then Dr. Kaddu's assessment and
7 plan for this well child check visit, do you see
8 that, ma'am?
9 A. Yes.
10 Q. Okay. He said that the plan was to
11 continue multiple specialist visits as requested.
12 And I think that you said that you were doing
13 that, correct?
14 A. Yes.
15 Q. Okay. And then he recommended start
16 counseling ASAP. Did that happen?
17 A. Is he referring to mental health
18 counseling? I don't -- I don't really know
19 exactly what he is referring to in that note.
20 Q. Well, that is how I read the note, but
21 how I read the note is largely irrelevant. Did
22 you have any understanding as of December 23,
23 2022, what this recommendation from Dr. Kaddu
24 meant?
159
1 MR. FULGINITI: Objection,
2 as to the preamble of what your -- what
3 your recollection -- or your
4 understanding is, and there is also no
5 indication that she even knew that that
6 was an assessment or a plan of
7 Dr. Kaddu on December 23rd, 2022.
8 BY MR. BLUTH:
9 Q. Okay. Well, ma'am, did you -- did you
10 know that Dr. Kaddu had a recommendation for
11 Easton to start counseling ASAP as of
12 December 23, 2022?
13 A. I wasn't -- I don't know. We always
14 wanted to pursue mental health counseling for
15 Easton.
16 MR. BLUTH: Okay. All
17 right. I'm trying to move it along a
18 little -- a little more quickly.
19 We'll close this and share
20 this. All right. We will mark this as
21 Exhibit-133.
22 (At this time, Office Clinic
23 Notes dated 1/24/23 were marked for
24 identification as Exhibit-133.)
160
1 BY MR. BLUTH:
2 Q. This is a note from Dr. Kaddu's office
3 dated 1/24/2023. Do you see that, ma'am?
4 A. I do.
5 Q. Okay.
6 MR. LIVINGOOD: Before we do
7 this, can we take a two minute break?
8 My computer just did an update and I'm
9 frozen.
10 THE VIDEOGRAPHER: 1:53, off
11 record.
12 MR. LIVINGOOD: Just enough
13 for me to turn it off and turn it back
14 on. I apologize.
15 (At this time, a short break
16 was taken.)
17 THE VIDEOGRAPHER: 1:58, on
18 video.
19 BY MR. BLUTH:
20 Q. All right. Ma'am, we were talking
21 about Exhibit-133, and this was a note of
22 Dr. Kaddu dated January 24, 2023, and you can see
23 that at the top of this page. Do you see that,
24 ma'am, the date?
161
1 A. I do.
2 Q. Okay. And then here it says that
3 Easton was no longer taking the Keppra. Do you
4 see that?
5 A. I do.
6 Q. Do you agree that as of January 24,
7 2023, Easton was no longer taking the seizure
8 medication?
9 A. Yes.
10 Q. Okay. And is it also true that Easton
11 has not taken any seizure medication since he was
12 weaned off the Keppra back in the early part of
13 2023?
14 A. Yes. Wait. That would be the late
15 part of 20 -- oh, no. No. You're right. The
16 early part of 2023, yes.
17 Q. Has any of Easton's healthcare
18 providers in the last year or so suggested that
19 Easton may need to go back on antiseizure
20 medication at any point in the future?
21 A. No.
22 Q. I will take that down.
23 All right. Easton had a -- according
24 to the records, anyway, Easton had a speech
162
1 therapy appointment on February 21, 2023. Did
2 you participate -- did you take him to that
3 appointment?
4 A. I don't know if I took him to that
5 specific appointment. Jace and I did a lot of --
6 he did some. I did some. But the majority of
7 them were Jace taking him.
8 Q. Okay. At this appointment, and this
9 was previously marked as Exhibit-119, someone
10 completed a Post-Concussion Symptom Checklist for
11 Easton. Do you see that?
12 MR. FULGINITI: Objection --
13 THE WITNESS: I do.
14 MR. FULGINITI: -- to form.
15 Just with regard to you saying someone
16 took him to an appointment, but you can
17 go ahead.
18 MR. BLUTH: Well, I imagine
19 Easton didn't take himself.
20 MR. FULGINITI: Okay. I am
21 just making my objection, counsel.
22 BY MR. BLUTH:
23 Q. Have you -- have you ever seen this
24 form before, ma'am?
163
1 A. I have.
2 Q. And when did you -- when was the first
3 time that you saw it?
4 A. Reviewing Jace's deposition.
5 Q. Had you ever seen it from Easton's
6 medical records prior to Jace's deposition?
7 A. No.
8 Q. Did you ever take Easton to a speech
9 therapy appointment?
10 A. Yes.
11 Q. And during any of the appointments with
12 the speech therapist, at which you were present,
13 did the speech therapist ask history-related
14 questions about how Easton was doing?
15 MR. FULGINITI: Object to
16 the form. You can answer.
17 THE WITNESS: Any
18 appointment I take Easton to, they ask
19 me how Easton is doing.
20 BY MR. BLUTH:
21 Q. Okay.
22 A. So, yes.
23 Q. And would the -- specifically with
24 respect to a speech therapy appointment, would
164
1 the speech therapist also ask Easton about how
2 Easton is doing?
3 A. Yes.
4 Q. Okay. Do you know who provided the
5 information that was used to respond to the
6 various areas that are rated on this
7 Post-Concussion Syndrome Checklist?
8 A. This form was not filled out by a
9 physical therapist. This form was filled out by
10 a nurse practitioner at Dr. Bollo's office, and
11 these questions were asked to Easton via Zoom.
12 Q. Okay. And were you present during that
13 assessment?
14 A. Yes.
15 Q. Okay. Were you participating, meaning
16 that you could interact with the nurse
17 practitioner at Dr. Bollo's office in the same
18 way that Easton could at the time?
19 A. Yes.
20 Q. And were you present when Easton was
21 answering the questions that the nurse
22 practitioner would pose that ended up as the
23 various scores on this checklist?
24 A. Yes.
165
1 Q. Okay. At any point during that
2 discussion or question/answer session between the
3 nurse practitioner and Easton, did you say
4 anything to the nurse practitioner?
5 A. Yes.
6 Q. And what --
7 A. It was a Zoom call, and I did interact
8 with the nurse practitioner.
9 Q. Okay. As Easton was providing
10 information and answers to the nurse
11 practitioner's questions, did you suggest to the
12 nurse practitioner that Easton was getting it
13 wrong and was providing information that wasn't
14 factual for one reason or another?
15 A. You have to take this form into
16 consideration, because if you look at the top
17 part of it, it says the past two days.
18 Q. Okay.
19 A. So, I don't -- I don't know exactly
20 what Easton was doing in these past two days.
21 Was he having -- like, did he have school that
22 day? I don't know what day of the week it was.
23 And so, maybe he didn't have any
24 balance problems, because he wasn't doing any
166
1 physical activity and stuff like that.
2 And so, yeah. This form is the last
3 two days of whenever this form was taken that he
4 filled this out.
5 Q. Okay. So, through the lens that the
6 form is specifically asking Easton to provide
7 information in various categories as to how he
8 was doing or what he was experiencing over the
9 preceding two days --
10 A. Yes.
11 Q. -- as you sit here today, do you have
12 any reason to believe that any of the answers
13 that Easton gave were wrong?
14 MR. FULGINITI: Objection to
15 the form. You can answer, if you
16 remember.
17 THE WITNESS: I don't
18 remember, because I don't remember what
19 he did the two days before this form
20 was filled out.
21 But I would say -- I mean
22 difficulty concentrating, difficulty
23 remembering, feeling slowed down, he
24 feels that every day. He feels that
167
1 every day since August 15th.
2 So, I wouldn't agree with
3 the way he filled out this form. He is
4 a very optimistic kid. And so, he --
5 when he filled out this form, was he
6 feeling better than he was August 15th,
7 absolutely.
8 BY MR. BLUTH:
9 Q. But if -- and I understand that, and I
10 appreciate that explanation, but if at the time
11 that Easton was describing his symptoms to a
12 medical provider, you knew that what he was
13 saying was inaccurate, for whatever reason, would
14 you correct Easton and provide the correct
15 information to the provider at the time, assuming
16 you knew that there was an error in the moment?
17 MR. FULGINITI: Objection to
18 the form of the question. Again, if
19 you know and recall and all that stuff.
20 THE WITNESS: They were
21 asking Easton these questions. So,
22 they wanted to know how Easton felt,
23 not how I felt that Easton should
24 feel.
168
1 BY MR. BLUTH:
2 Q. I understand that, yes. But for --
3 just as an for example, if you have would known
4 that within the past two days that Easton had
5 complained to you that he had had a headache, and
6 then the nurse practitioner asks Easton, in the
7 last two days, did you have a headache, and
8 Easton says no, are you the type of mother who
9 would interject at that point and say, now,
10 remember, Easton, you told me yesterday that you
11 had a headache, that kind of thing?
12 MR. FULGINITI: Objection to
13 form, but you answer.
14 THE WITNESS: No. Because
15 they were asking Easton these
16 questions.
17 BY MR. BLUTH:
18 Q. Okay. So, just so that I understand
19 how to review the form, if Easton was providing
20 information to a medical provider that you knew
21 at the time was not correct, you would not
22 correct the information that the healthcare
23 provider was getting, because they were asking
24 Easton?
169
1 MR. FULGINITI: That's not
2 the way --
3 THE WITNESS: It depends.
4 MR. FULGINITI: Counsel, you
5 are mixing up. You are saying in
6 general, and you are being very broad,
7 and you are not specifying what she has
8 been talking about, and she may -- you
9 may be talking about if he was actively
10 vomiting or something like that and
11 said he wasn't vomiting or something as
12 opposed to are you talking about this
13 form on February 21st, 2023?
14 MR. BLUTH: I'm talking
15 about this form. I'm just -- I am
16 trying to understand generally how to
17 interpret the information on this form.
18 In other words, if her
19 testimony is Easton gave the answers,
20 and I allowed Easton to give the
21 answers, and I wouldn't correct
22 anything if I knew Easton was providing
23 information that was wrong, fine. That
24 is what I am trying to figure out.
170
1 MR. FULGINITI: For this
2 form, for those two days, I think she
3 has answered that question, but you can
4 answer as to this form on that visit.
5 MR. BLUTH: My -- my
6 question isn't limited to this specific
7 visit.
8 I am trying to understand
9 how she would interact with Easton's
10 healthcare providers for purposes of
11 understanding how to review the
12 information on this form.
13 MR. FULGINITI: No. No.
14 No. You're -- that is why I
15 interjected. Your question was about
16 this form, and then you made it very
17 general, are you the kind of mother,
18 and that's why I objected, because then
19 that could apply to anything ever in
20 the world of -- in the history of
21 anything Easton ever said.
22 So, if you are asking her
23 about this form, and what she did or
24 didn't do, that is one thing.
171
1 Are you asking her in
2 general if she ever hears Easton ever
3 said anything inaccurate to a doctor,
4 would she interject, that could be
5 something totally different. That is a
6 different question.
7 That is what I am trying to
8 understand your claim that you are
9 trying to understand this form.
10 MR. BLUTH: All right. I
11 will try it a different way.
12 BY MR. BLUTH:
13 Q. Ma'am, with respect to the symptoms
14 that are identified on this form, in the context
15 of the nurse practitioner visit that you've
16 described these questions were asked, if Easton
17 was providing information about how he was
18 feeling over the preceding two days, that you
19 understood at the time was not correct, would you
20 have corrected him and provided the accurate
21 information to the nurse practitioner?
22 A. It depends on my audience. Like, it
23 depends -- I need to give Easton a voice, so that
24 he feels like his voice is heard, and not just
172
1 something that I contradict what he feels and he
2 thinks. So, it would have -- it would depend on
3 the situation.
4 Q. Well, the situation that we are
5 describing is February 21, 2023, when the nurse
6 practitioner was asking Easton for his symptoms
7 over the preceding two days as recorded on this
8 form.
9 A. On this form, yes. I let him fill out
10 this form how he perceived his last two days, how
11 he was feeling.
12 Q. All right. So, for example, you
13 mentioned difficulty concentrating and difficulty
14 remembering and feeling slowed down as things
15 that you perceive Easton experiences on a
16 everyday basis, correct?
17 A. Yes.
18 Q. So, as Easton was answering these
19 questions none, is that fair to say that you
20 would not suggest to the nurse practitioner
21 asking these questions that Easton has these
22 things on a everyday basis?
23 A. When they were asking Easton these
24 questions, no, I did not tell them that. If they
173
1 were to ask me personally my opinion, yes, I
2 would share that information, but they were
3 asking Easton how he felt and his opinion.
4 Q. Okay. So, your testimony is just, so I
5 understand, we should read this form as
6 suggesting how Easton perceived his condition in
7 response to those questions, which might be
8 different from how you, as his mother, understood
9 the same circumstances?
10 A. Yes.
11 MR. BLUTH: Okay. I
12 understand. All right. We will mark
13 this as 130 --
14 THE COURT REPORTER: 134.
15 MR. BLUTH: Oh, we will mark
16 this 134.
17 (At this time, Speech
18 Therapy Forms dated 3/21/23 were marked
19 for identification as Exhibit-134.)
20 BY MR. BLUTH:
21 Q. This is a -- again, we were talking
22 about --
23 THE COURT REPORTER: Oh, I
24 am sorry. No. Okay.
174
1 MR. BLUTH: Are we okay?
2 THE COURT REPORTER: Yes.
3 BY MR. BLUTH:
4 Q. Ma'am, this is a speech therapy note
5 from March 21 of 2023. Do you see that?
6 A. Yes.
7 Q. And this is, according to the records,
8 Easton's last speech therapy visit. He was --
9 and after this visit, he was discharged.
10 MR. FULGINITI: What is the
11 question?
12 MR. BLUTH: It is not a
13 question. I am providing context.
14 MR. FULGINITI: Okay.
15 BY MR. BLUTH:
16 Q. Did you attend this speech therapy
17 visit with Easton?
18 A. I don't recall. Either I attended or
19 Jace attended.
20 Q. Okay.
21 A. But, most likely, it was Jace.
22 Q. Okay. And why do you say that?
23 A. He -- Jace took Easton to most of his
24 therapy appointments.
175
1 Q. All right. At this visit, the speech
2 therapist wrote that the patient would not
3 benefit from continued speech language pathology
4 treatment, because he has returned to baseline
5 functioning and is thriving in school and his
6 personal life. Do you see that?
7 A. I do.
8 Q. Okay. Did you see this note prior to
9 today?
10 A. I did not.
11 Q. Okay. Did you understand in or around
12 March of 2023 that Easton was being discharged
13 from speech therapy?
14 A. Yes.
15 MR. FULGINITI: Can we --
16 THE WITNESS: I believe so.
17 MR. FULGINITI: I'm sorry.
18 I need to take a quick break off
19 camera.
20 THE VIDEOGRAPHER: 2:13, off
21 video.
22 (At this time, a short break
23 was taken.)
24 (At this time, the court
176
1 reporter read from the record as
2 requested.)
3 THE VIDEOGRAPHER: 2:23, on
4 video.
5 BY MR. BLUTH:
6 Q. All right. Ma'am, and what was your
7 understanding of the reason that Easton was being
8 discharged from speech therapy in March of 2023?
9 A. Because he no longer needed speech --
10 speech therapy services.
11 Q. Okay. As his mother, do you agree that
12 Easton's speech had returned to where it was
13 before his injury at the time of his discharge in
14 March 2023 from speech therapy?
15 MR. FULGINITI: Objection to
16 the form. You can answer.
17 THE WITNESS: No. It's
18 never going to be the same as it was
19 before his injury.
20 I think that they had to
21 come to an agreement that he plateaued,
22 and there was -- they were not seeing
23 improvement from where he was at, and
24 so why continue therapy, if they are
177
1 not seeing improvement from the
2 therapy.
3 BY MR. BLUTH:
4 Q. When you say "they came to an
5 agreement," who are you referring to?
6 A. Sorry. The speech therapist.
7 Q. The speech therapist and whom?
8 A. Just the speech therapist.
9 Q. Okay. Do you have an understanding of
10 what it means when a medical provider has
11 concluded that someone has returned to baseline?
12 MR. FULGINITI: Objection to
13 form. You can answer.
14 THE WITNESS: I mean, I
15 guess everybody has their own meaning
16 of that, but I'm assuming that --
17 MR. FULGINITI: Nancy, if
18 you don't know --
19 THE WITNESS: No. Yeah.
20 BY MR. BLUTH:
21 Q. All right. I might have missed
22 something in there, because Mr. Fulginiti
23 interjected.
24 But my question was: Do you know what
178
1 it means when a medical provider has concluded
2 that a patient has returned to baseline?
3 MR. FULGINITI: And same
4 objection.
5 MR. BLUTH: Right.
6 THE WITNESS: No. I don't
7 know what specifically his speech
8 therapist means when she says it
9 returned to baseline. It's kind of an
10 opinion.
11 BY MR. BLUTH:
12 Q. Okay. Since March 21, 2023, has Easton
13 seen anybody for purposes of additional speech
14 therapy?
15 A. No.
16 Q. Has any of Easton's treating medical
17 providers suggested to you that Easton would
18 benefit from any additional speech therapy
19 treatment?
20 A. No.
21 Q. I'll take that down.
22 Do you know when Easton had his last
23 physical therapy appointment?
24 A. I don't know. I would have to go back
179
1 and look at records.
2 MR. BLUTH: Okay. We will
3 mark this as 135.
4 (At this time, Physical
5 Therapy Forms were marked for
6 identification as Exhibit-135.)
7 MR. BLUTH: And we will
8 e-mail all of the exhibits to the court
9 reporter and counsel at the conclusion
10 of the deposition, so as long as,
11 Kathleen, I get your e-mail address
12 before we part company later.
13 BY MR. BLUTH:
14 Q. I will share my screen. All right.
15 Can you see this note, ma'am?
16 A. Yes.
17 Q. Okay. This is a physical therapy note
18 dated March 22, 2023. Did you see that?
19 A. I do.
20 Q. And I will represent to you that this
21 is the last physical therapy note that I found in
22 Easton's records.
23 Are you -- do you have any knowledge
24 that Easton had any physical therapy subsequent
180
1 to March 22 of 2023?
2 A. If they are not in his records, then
3 no.
4 Q. Okay. On page three of this exhibit,
5 there is a note from the physical therapist that
6 says Easton was encouraged to begin Bridge
7 Program next week. Do you see that?
8 A. Yes.
9 Q. Do you know what the Bridge Program is?
10 A. So, once Easton advanced from physical
11 therapy, that's what he advanced to the
12 Acceleration Program.
13 Q. All right. Is this --
14 A. So, it looks like everyone is kind of
15 calling it a different thing.
16 Q. Right. That was my next question. So,
17 it is your understanding that the Acceleration
18 Program that we talked about earlier in
19 connection with Dr. Flavin is the same as the
20 Bridge Program that is mentioned in the physical
21 therapy note?
22 A. Yes.
23 Q. And seeing that comment about Easton
24 was encouraged to begin the Bridge Program next
181
1 week, does that refresh your recollection as to
2 whether this might have been Easton's last
3 physical therapy appointment?
4 A. Yes.
5 Q. Okay. And do you now believe, after
6 seeing this additional information, that
7 March 22, 2023, was Easton's last physical
8 therapy appointment?
9 A. Yes. He says that he is now advanced.
10 So, that would make it his last physical therapy
11 appointment.
12 Q. All right. And then there is a
13 Clinical Assessment Summary Physical Therapy on
14 the next page. Can you see that?
15 A. Yes.
16 Q. Okay. And the physical therapy wrote,
17 and I am just reading, he, meaning Easton, seems
18 improving his balance through increased amount of
19 time and single leg balance on the Bosu ball
20 while throwing a tennis ball back and forth. Do
21 you see that?
22 A. Yes.
23 Q. Okay. Patient would benefit from
24 being sent to the Bridge Program through
182
1 Acceleration and help with skill acquisition
2 and further training. Is that the same program
3 that you described earlier at Intermountain
4 Health?
5 A. Yes.
6 Q. Where there was at least a personal
7 trainer involved in Easton's care?
8 A. Yes.
9 Q. Okay. And then the plan, the physical
10 therapist's plan was to follow up with Easton
11 after eight sessions with Acceleration. Do you
12 see that?
13 A. I do.
14 Q. Did Easton complete eight sessions with
15 Acceleration?
16 A. I believe he only completed four,
17 because that's what our insurance covered.
18 Q. Okay. And --
19 A. Then he moved on to Brogan Secrist.
20 Q. Brogan Secrist to continue his either
21 personal or athletic training?
22 A. Yes.
23 Q. Did Easton ever return to the physical
24 therapist for a follow-up after he finished with
183
1 Acceleration?
2 A. No. We did see his physical therapist
3 like in public, and we talked, but never another
4 appointment.
5 Q. And have any of Easton's treating
6 medical providers suggested to you that he would
7 benefit from any further physical therapy
8 treatments?
9 A. I don't know. Jace was at this
10 appointment.
11 Q. All right. But my question really
12 isn't specific to this appointment, but rather
13 since March 22, 2023, when Easton had his last
14 physical therapy appointment, have any of his
15 medical providers suggested to you that Easton
16 should go back or resume physical therapy
17 treatments?
18 A. No.
19 Q. If any of those medical providers had
20 recommended that Easton resume physical therapy,
21 you would have made those appointments; is
22 that -- isn't that correct?
23 A. Absolutely.
24 Q. Okay. And is it correct that Easton
184
1 has not had any physical therapy appointments
2 since March 22 of 2023?
3 MR. FULGINITI: Objection to
4 form, but you can answer.
5 THE WITNESS: Not with
6 Brandon.
7 BY MR. BLUTH:
8 Q. With anyone?
9 A. Yes. He has not received physical
10 therapy since this appointment on March 22nd.
11 Q. Right. But you have qualified your
12 answer with Brandon. Has Easton had physical
13 therapy care from any provider since March 22 of
14 2023?
15 MR. FULGINITI: I'm
16 sorry. You said not counting
17 Brogan's Secrist?
18 MR. BLUTH: Well, my
19 understanding -- is Brogan Secrist a
20 physical therapist?
21 MR. FULGINITI: Well, you
22 didn't limit it to physical therapist.
23 You said physical therapy.
24 MR. BLUTH: Well, I mean, I
185
1 don't want to mince words, but my
2 understanding is that a physical
3 therapy treatment is rendered by a
4 physical therapy provider.
5 MR. FULGINITI: Yeah. That
6 is why I wanted to clarify, because I
7 have done physical therapy at home when
8 I hurt my shoulder. Like, you don't
9 have to go to a physical therapist to
10 do therapy.
11 MR. BLUTH: All right.
12 MR. FULGINITI: That's my
13 objection.
14 BY MR. BLUTH:
15 Q. Okay. My question stands. Has Easton
16 had any physical therapy treatments since
17 March 22 of 2023?
18 MR. FULGINITI: I will
19 object to the form of the question and
20 his definition of physical therapy, but
21 you can answer.
22 THE WITNESS: No. Easton
23 has not received physical therapy from
24 a physical therapist since this.
186
1 BY MR. BLUTH:
2 Q. Okay. I'll take this down.
3 According to the records I've seen,
4 Easton's last appointment with Dr. Bollo was
5 April 17, 2023; is that correct?
6 A. Yes.
7 Q. And as we sit here today, does Easton
8 have any appointments scheduled with
9 Dr. Bollo or anyone from Dr. Bollo's office?
10 A. No.
11 Q. There are some communication notes in
12 Easton's medical record with Dr. Kaddu's office,
13 and you may have seen them attached to Jace's
14 deposition transcript regarding a request for a
15 medication so Easton can focus at school. Do you
16 remember -- do you remember seeing that?
17 A. Yes.
18 Q. Tell me about how that request to
19 Dr. Kaddu's office came about.
20 A. We have a friend that suggested it to
21 Jace and I. And so, Jace followed through with
22 that and talked to Dr. Kaddu.
23 I had a -- I had a different opinion on
24 a stimulant. And so, I did not follow through
187
1 with that paperwork. I needed to know for
2 myself. I needed to research it more.
3 But then Dr. Goldstein had mentioned
4 that we can put him on a low dose of a stimulant,
5 and that we could control it a lot to just times
6 that he needed that, so just on school days, and
7 once talking to Dr. Goldstein, it did open up my
8 mind to pursue that.
9 Q. Okay. And when did you have that
10 discussion with Dr. Goldstein about a low dose
11 stimulant?
12 A. I believe it was back in August. So, I
13 have been doing some research about it to see if
14 that is an option we want to go with.
15 Q. Okay. As of today, is Easton on any
16 type of low dose stimulant or other medication to
17 help him focus in school?
18 A. He is not now. I need to make an
19 appointment with his primary care doctor to make
20 that happen.
21 Q. That would be with Dr. Kaddu or someone
22 in Dr. Kaddu's office?
23 A. Yes.
24 Q. Okay. So, this was marked as
188
1 Exhibit-122 previously. Can you see this, ma'am?
2 A. Yes.
3 Q. All right. These were the notes we
4 were -- that I was referencing, the communication
5 notes in Dr. Kaddu's records on August -- excuse
6 me, on April 18, 2024. Do you see the date?
7 A. Yes.
8 Q. The note reads, dad left a message
9 wondering how he can get patient on medication,
10 so that he can focus in school, specifically
11 Adderall. Do you see that?
12 A. Yes.
13 Q. And who was the family friend that made
14 the initial suggestion that Easton might benefit
15 from something like that?
16 A. Erika Tebbs.
17 Q. And is Erika Tebbs someone with medical
18 training?
19 A. No.
20 Q. Do you know on what basis Erika Tebbs
21 thought that such a medication would be good for
22 Easton?
23 A. She saw it benefit her husband after
24 her husband had a brain tumor.
189
1 Q. Okay. Then the message back or within
2 the office from Dr. Kaddu was, we cannot
3 prescribe unless we have a diagnosis, and that
4 he -- I have that her mom, I think he probably
5 meant his mom, come pick up teacher and parent
6 packets. Did you ever pick up the parent and
7 teacher packets from Dr. Kaddu's office?
8 A. I did not.
9 Q. Okay. Were you aware that they were
10 available to pick up?
11 MR. FULGINITI: Objection to
12 form. You can answer, if you know.
13 THE WITNESS: Yes.
14 BY MR. BLUTH:
15 Q. Okay. And that is consistent with what
16 you told us earlier, which is you knew Jace had
17 made this inquiry of Dr. Kaddu, but you weren't
18 at that moment in time sure that that was a
19 direction you wanted to go; is that accurate?
20 MR. FULGINITI: Objection to
21 form. You can answer.
22 THE WITNESS: Yes.
23 BY MR. BLUTH:
24 Q. Okay. And then Ashly Shumway called.
190
1 Do you know who Ashly Shumway is?
2 A. No.
3 Q. Someone, apparently, who works in
4 Dr. Kaddu's office?
5 MR. FULGINITI: Objection.
6 THE WITNESS: I don't know.
7 BY MR. BLUTH:
8 Q. Do you remember receiving a call from
9 someone in Dr. Kaddu's office, even if you did
10 not remember the name of the person who called as
11 a follow-up to this issue about Adderall?
12 A. Yes.
13 Q. Okay. And then on April 18, that
14 person put a note in the chart that said, reached
15 out, mom answered the phone. I informed her.
16 She stated that she is already talking to a
17 different doctor about this. Do you see that?
18 A. Yes.
19 Q. Okay. And then Ashly Shumway also
20 wrote, called dad, also, and let him know so he
21 was aware of the situation. He knows that -- I
22 think that should be we, but have packets -- have
23 left packets up front if they would like to come
24 pick them up. Do you see that note?
191
1 A. Yes.
2 Q. Okay. Who was the different doctor
3 that you were speaking to about this issue as of
4 April 18 of 2024?
5 MR. FULGINITI: Objection to
6 form, but you can answer.
7 THE WITNESS: I wouldn't be
8 speaking to a different doctor on
9 April 18th, because I hadn't met
10 Dr. Goldstein yet.
11 BY MR. BLUTH:
12 Q. Okay. Did you tell the person from
13 Dr. Kaddu's office on April 18, 2024, that you
14 were speaking with a different doctor about this,
15 even though at that point you had not yet been?
16 A. Can you repeat the question?
17 Q. Sure. Did you tell Ms. Shumway or
18 whoever it was who you spoke with on the phone on
19 April 18, 2024, even if you don't remember their
20 name, that you were talking to a different doctor
21 about this issue, even if at that point you
22 really hadn't been speaking with another doctor?
23 MR. FULGINITI: Objection to
24 the form.
192
1 THE WITNESS: No.
2 MR. FULGINITI: You can
3 answer.
4 THE WITNESS: No.
5 BY MR. BLUTH:
6 Q. All right. Eventually, Easton had a
7 visit with Southwest Behavioral Health; is that
8 right?
9 A. Yes.
10 Q. And how many visits did Easton have?
11 A. Two.
12 Q. And do you remember when they were?
13 A. The year 2023.
14 Q. Can you estimate any more specifically
15 than that?
16 A. I believe one visit that I took him to
17 was during the summer.
18 Q. Okay. And how about the other visit?
19 A. I don't recall.
20 Q. We recently acquired records from
21 Southwest Behavioral Health. Can you see this,
22 ma'am?
23 A. Yes.
24 Q. Okay. And did you attend all visits at
193
1 Southwest Behavioral Health Center with Easton?
2 A. I only attended one.
3 Q. And do you know whether that was the
4 first or the second of the two visits?
5 A. The second.
6 Q. There are 12 pages of records that we
7 got, and I will tell you -- I will represent to
8 you that they all have the same date of service,
9 which is April 27, 2023. Did you see that date,
10 ma'am?
11 A. Yes.
12 Q. Okay. Do you have any reason to
13 believe that date is inaccurate?
14 MR. FULGINITI: Wait.
15 THE WITNESS: No.
16 MR. FULGINITI: You can go
17 ahead and answer.
18 THE WITNESS: I'm wondering,
19 we took Brogan and Blakely, and maybe
20 I'm not remembering correctly, but I
21 thought Easton came with us, but it
22 might have just Brogan and Blakely that
23 came in.
24 I thought it was the three
194
1 of them, but now that I -- I think it
2 was just two of them. It was just
3 Brogan and Blakely.
4 BY MR. BLUTH:
5 Q. Okay. Does that help refresh your
6 recollection of how many visits with Southwest
7 Behavioral Health Center that Easton had?
8 A. Yes. It was just the one.
9 Q. Okay. And was that one visit on
10 April 27, 2023?
11 A. Yes.
12 Q. Okay. And were you present for that
13 visit?
14 A. I was not.
15 Q. Okay. What understanding do you have,
16 if any, as to the treatment recommendations that
17 were made for Easton following this visit?
18 A. They recommended that Easton get mental
19 health treatment.
20 Q. Through their services or through
21 somebody else or maybe they didn't make a
22 recommendation as to who the provider would be,
23 but do -- tell me as specifically as you recall
24 what the recommendation was for mental health
195
1 counseling from Southwest Behavioral Health
2 Center.
3 A. I wasn't there. So, I don't know what
4 they specifically asked for. I know that when
5 Easton and Jace came home from this appointment,
6 they both felt uncomfortable with the whole
7 facility.
8 Q. Okay. And is that the reason why
9 Easton never followed up for counseling sessions
10 with Southwest Behavioral Health Center?
11 A. Yes. He felt uncomfortable and he --
12 he didn't like it.
13 Q. Okay. Did you or Jace take any steps
14 to try to connect Easton with a different mental
15 health counseling provider, meaning other than
16 Southwest Behavioral Health Center?
17 MR. FULGINITI: And other
18 than Dr. Goldstein?
19 MR. BLUTH: Well, if that is
20 the answer to the question, then that's
21 the answer, but I don't have to limit
22 himself to Dr. Goldstein at this point.
23 We are talking
24 recommendations that were made on or
196
1 around April 27 of 2023.
2 MR. FULGINITI: I am just
3 making sure. I didn't know if you were
4 including what she has already
5 testified about over the last five
6 hours.
7 MR. BLUTH: I just want her
8 answer --
9 THE WITNESS: Yes.
10 MR. BLUTH: -- to the
11 question.
12 MR. FULGINITI: She's given
13 it.
14 THE WITNESS: We inquired --
15 MR. BLUTH: I agree that she
16 is giving it, Ken.
17 MR. FULGINITI: I said that
18 she has given it. She already has
19 given it, but I am allowing her to
20 answer. I have not instructed her not
21 to answer.
22 THE WITNESS: Yes. We
23 inquired about mental health therapy
24 through Dr. Goldstein, and he is
197
1 currently a patient of his.
2 BY MR. BLUTH:
3 Q. Okay. Prior to connecting with
4 Dr. Goldstein, did you or Jace contact any other
5 provider as a potential place that Easton could
6 get mental health counseling?
7 MR. FULGINITI: How about
8 when?
9 MR. BLUTH: I will rephrase
10 the question.
11 BY MR. BLUTH:
12 Q. From the time that Easton was
13 recommended to pursue mental health counseling by
14 Southwest Behavioral Health Center and up until
15 the time that Easton was connected with
16 Dr. Goldstein, did you or Jace make any other
17 efforts to connect Easton to a provider of mental
18 health counseling services?
19 A. Jace tried to get him with Crimson
20 Counseling.
21 Q. And when was that?
22 A. I don't remember.
23 Q. I think you told us earlier that Easton
24 never saw Ryan Ruud for counseling; is that
198
1 right?
2 A. Yes.
3 Q. And what was the reason that Easton
4 never saw Ryan Ruud for counseling?
5 A. Easton didn't feel comfortable and
6 Easton didn't want to.
7 Q. All right. Do you have any
8 understanding as to why Easton was uncomfortable
9 with a potential counseling provider that Easton
10 had never met?
11 MR. FULGINITI: Objection to
12 the form, but you can answer to the
13 best of your ability.
14 THE WITNESS: Easton had met
15 Ryan Ruud.
16 BY MR. BLUTH:
17 Q. Okay.
18 A. He had spoke with me on the phone.
19 Q. Was Easton's only contact --
20 A. Ryan --
21 Q. I'm sorry. I didn't mean --
22 A. Ryan Ruud would have not been the
23 therapist that he saw. It would have been
24 somebody else in the office. So, he never met
199
1 the therapist.
2 Easton was -- gave us a lot of pushback
3 about doing mental health therapy. He didn't
4 want to.
5 Q. Okay. And was there any reason other
6 than that Easton didn't want to have mental
7 health counseling services at that time, any
8 other reason that Easton did not meet with the
9 provider affiliated with Mr. Ruud that he would
10 have treated with?
11 A. That whole time frame about we
12 needed -- in order for insurance to cover it, we
13 needed to get approval from Southwest Behavioral
14 Health, and they had a glitch within their
15 system, and it just kind of -- I'm not sure. It
16 got lost from there.
17 Q. What do you mean when you say "it got
18 lost from there"?
19 A. We -- we didn't pursue it any longer.
20 Q. Okay. Until such time as Easton was
21 connected with Dr. Goldstein?
22 A. Yes.
23 Q. Okay. The last note of Dr. Flavin that
24 I've seen in Easton's records is dated
200
1 November 28, 2023. Is -- has Easton seen
2 Dr. Flavin since that date?
3 A. No.
4 Q. Okay. As we sit here today, does
5 Easton have any appointments scheduled into the
6 future with Dr. Flavin?
7 A. No.
8 Q. Is your understanding that Easton has
9 been discharged from Dr. Flavin's care?
10 A. Yes.
11 Q. Are there any signs or symptoms that,
12 as his parents, you are -- you were instructed to
13 look out for, and if they occur, then to reach
14 out to Dr. Flavin for another appointment?
15 MR. FULGINITI: Objection to
16 the form. You can answer, if you
17 understand.
18 THE WITNESS: Yeah. I don't
19 really understand the question.
20 BY MR. BLUTH:
21 Q. Sure. When Easton was discharged from
22 Dr. Flavin's care, did Dr. Flavin say to you, I'm
23 discharging you from his care, but if any of
24 these things come up again, please call my
201
1 office, and we will make another appointment?
2 MR. FULGINITI: Objection to
3 form. You can answer.
4 THE WITNESS: No. She
5 wasn't specific about those things.
6 THE COURT REPORTER: I'm
7 sorry. One second. Were you marking
8 the Southwest?
9 MR. BLUTH: Oh, thank you.
10 Yes. We will mark that as 136.
11 (At this time, Records dated
12 4/27/23 were marked for identification
13 as Exhibit-136.)
14 BY MR. BLUTH:
15 Q. All right. And I think you told us
16 earlier, Mrs. Oliverson, that Easton's most
17 recent appointment at Dr. Kaddu's office was in
18 May of 2024; is that right?
19 A. Yes.
20 Q. Did you take Easton to that visit?
21 A. I did.
22 Q. Was anyone else present at that visit,
23 other than you or -- you and Easton?
24 A. Brogan was also at that visit. He had
202
1 a well child check as well.
2 Q. Okay. At this visit, did the providers
3 in Dr. Kaddu's office ask Easton certain
4 questions about how he was doing?
5 A. Yes.
6 Q. And were you present when those
7 questions were asked and Easton answered them?
8 A. Yes.
9 Q. All right. I'm going to show you what
10 has been previously marked as Exhibit-126. Can
11 you see this document, ma'am?
12 A. Yes.
13 Q. Okay. There are all sorts of questions
14 here where Easton was asked whether he had
15 trouble falling or staying asleep, and he said --
16 the answer is not at all. Do you see that?
17 A. I do.
18 Q. Were you present when Easton was asked
19 and answered this question?
20 A. He was not asked the question. It was
21 a survey he filled out. And, yes, I was sitting
22 next to him. I was not looking at how he was
23 filling out the survey, though, because they had
24 asked him to fill it out.
203
1 Q. Okay. And what type of device was this
2 survey completed on?
3 A. A piece of paper with a clipboard and a
4 pencil.
5 Q. Okay. And did Easton -- where was
6 Easton located when he was filling this out?
7 A. We were -- the three of us were sitting
8 in the waiting room at the pediatrician's office,
9 and both boys individually were filling out the
10 form.
11 Q. Your two sons were filling out their
12 own forms?
13 A. Correct.
14 Q. And I think you described that you were
15 allowing them to fill them out without any input
16 from you?
17 A. Yes. They've asked the children to
18 fill out the forms themselves.
19 Q. Okay. And do you have any reason to
20 believe that the answers on this form are not
21 reflective of how Easton filled out the paper?
22 MR. FULGINITI: Are you
23 asking her if they transcribed it
24 correctly?
204
1 MR. BLUTH: I'm asking her
2 if she has any reason to believe that
3 Easton answered differently than is
4 reflected on this form.
5 MR. FULGINITI: Okay. So,
6 just so she understands, you're asking
7 if she has seen the original and
8 compared it to this copy. If you have
9 you done that, Nancy --
10 MR. BLUTH: That is not my
11 question.
12 MR. FULGINITI: That guided
13 your question, counselor. You are
14 asking if what he put on the paper is
15 the same as what appears in print here.
16 MR. BLUTH: No. I am not
17 asking that. I am asking her whether
18 she has any basis to believe that it is
19 not.
20 MR. FULGINITI: It is not
21 what?
22 MR. BLUTH: The same.
23 MR. FULGINITI: That is what
24 I am saying. She would have to compare
205
1 the original to the copy.
2 MR. BLUTH: She does not.
3 If you would just let her answer the
4 question, please.
5 MR. FULGINITI: I let her
6 answer questions for six hours -- or
7 five hours.
8 Okay. I think it is unfair
9 if she has never seen the original, or
10 maybe even a copy, how is she supposed
11 to know, in fairness to her, whether
12 this is an accurate transcription of
13 what he wrote on a piece of paper that
14 she has never seen.
15 MR. BLUTH: Then she can say
16 that she has no basis to know one way
17 or the other. It is a fair answer to
18 the question.
19 MR. FULGINITI: Well, that
20 is not your question. Your question
21 was not that.
22 Your questions was
23 misleading. That's why I have to
24 interject. Every now and again,
206
1 counselor, I have to serve some purpose
2 here.
3 So, the question is: Did
4 you ever see the original document that
5 Easton filled out and compared it to
6 see if these were the same answers that
7 they typed up?
8 MR. BLUTH: That's not the
9 question, and you know that is not the
10 question.
11 MR. FULGINITI: It is what
12 she would have to have done to answer
13 your question.
14 You are being tricky and you
15 are being sneaky. And I have let this
16 go on for five hours. She can answer
17 the question if she compared the two
18 documents.
19 MR. BLUTH: My question
20 stands as asked, and you objected, and
21 you are allowed to do that, and now she
22 can answer the question, if you allow
23 her to do so.
24 MR. FULGINITI: I will allow
207
1 her to answer my question, which was
2 whether or not she's -- she ever saw
3 the original, the answers that Easton
4 was putting down, to see if this is the
5 same thing that Easton put down on the
6 original.
7 MR. BLUTH: And then she can
8 answer both questions. I have never
9 been one to elevate form over
10 substance.
11 THE WITNESS: I did not see
12 the answers to the questions that
13 Easton filled out. That is something
14 that he did and -- on his own, and he
15 handed it to the medical professional,
16 and then, no, I have not seen the
17 transcript of his responses.
18 THE COURT REPORTER: One
19 second. We lost Luke. I just got a
20 text that his electric went out. Oh,
21 he is connecting back on. Okay.
22 MR. LIVINGOOD: So, Kathy
23 became the host maybe like four or five
24 questions ago, so we might have lost
208
1 the last four or five questions of
2 video.
3 MR. FULGINITI: Well, not
4 really. It was probably just our
5 banter.
6 THE COURT REPORTER: We
7 did -- we lost him, but I was taking it
8 down.
9 MR. LIVINGOOD: That would
10 be merciful if it was, but I can't
11 exactly remember, but I did see that.
12 I thought that was strange, but I
13 didn't see -- it was like off, because
14 we have the document up, so...
15 THE COURT REPORTER: He
16 texted when the objections were going
17 on, but not the question, but the last
18 answer, he would not have been on. He
19 was coming on at the last answer.
20 MR. FULGINITI: Can you
21 repeat your answer, Nancy, if you
22 remember it?
23 MR. LIVINGOOD: Let's just
24 make sure we are all on the same page
209
1 in the playbook, because we would have
2 dropped the video.
3 I have no problem picking up
4 the video where it is, but if there is
5 a question or two that is just on the
6 paper record, that is fine by me, but I
7 am only one vote here.
8 MR. BLUTH: It is fine by
9 me.
10 MR. FULGINITI: Yes.
11 MR. LIVINGOOD: Okay. Now I
12 am going to mute myself and stay out of
13 it.
14 THE VIDEOGRAPHER: I am back
15 on guys. Sorry for that. The back-up
16 host, who is Kathy, has continued to
17 record even though I was no longer
18 here.
19 So, I think everything is
20 fine from the standpoint of the
21 recording, but I will just need to be
22 renamed the host, because I believe the
23 host then went to the co-host, Kathy.
24 So, I just need you to re -- put me in
210
1 as the host.
2 THE COURT REPORTER: Okay.
3 I don't have anything that says I was
4 recording. So, I was recording on the
5 stenographic record.
6 THE VIDEOGRAPHER: I am
7 showing we are recording right now. We
8 will have to edit those portions of the
9 video later.
10 THE COURT REPORTER: Okay.
11 THE VIDEOGRAPHER: Just make
12 me the host.
13 THE COURT REPORTER: You are
14 the host.
15 THE VIDEOGRAPHER: I am
16 going to pause the recording here.
17 THE COURT REPORTER: I am
18 off the record.
19 (At this time, a discussion
20 was held off the record.)
21 THE VIDEOGRAPHER: 3:02, on
22 video.
23 BY MR. BLUTH:
24 Q. All right, ma'am. Does -- as we sit
211
1 here today, does Easton have any appointment
2 scheduled with Dr. Kaddu's office?
3 A. No.
4 Q. Okay. As we sit here today, does
5 Easton have any medical appointments of any
6 nature whatsoever scheduled at any point in the
7 future?
8 A. No.
9 Q. Does Easton continue to see
10 Dr. Goldstein for mental health counseling?
11 A. Yes.
12 Q. And does he have appointments with
13 Dr. Goldstein scheduled for that purpose?
14 A. Yes.
15 Q. Other than Dr. Goldstein, is Easton
16 seeing any medical or counseling provider for any
17 injury or medical issue that you understand is in
18 any way connected to his head injury?
19 A. No.
20 Q. Does Easton complain to you that he has
21 physical pain or discomfort from any injury that
22 you understand is related to his head injury?
23 A. Periodically, he gets headaches.
24 Q. Okay. Anything other than headaches,
212
1 in terms of physical pain or discomfort that he
2 complains to you about?
3 A. No.
4 Q. How frequently does Easton have
5 headaches?
6 A. Three or four headaches a month.
7 Q. And when Easton has a headache, does he
8 take any medication to help alleviate the
9 symptoms of it?
10 A. Occasionally, he will take Ibuprofen.
11 Q. Okay. Any medication for headaches,
12 other than Ibuprofen?
13 A. No.
14 Q. Now, when you say "occasionally, he
15 will take Ibuprofen," does that mean that there
16 are some times that Easton will have a headache
17 for which he takes no medication?
18 A. Yes. He tries to relieve the headache
19 on his own. He will try to hydrate, go into a
20 dark, quiet room to what he calls a brain break,
21 and try to get it to go away on its own.
22 Q. Okay. As best as you can estimate, how
23 frequently does Easton take Ibuprofen to help
24 relieve a headache?
213
1 A. I would say three out of the four
2 headaches that he has a month.
3 Q. And how often or how frequently does
4 Easton try to alleviate the symptoms of a
5 headache by taking a brain break?
6 A. Every time.
7 Q. So, regardless of whether Easton uses
8 Ibuprofen for the three or four times a month
9 that he has a headache, he will take a brain
10 break?
11 A. Yes. He tries to relieve it on his own
12 naturally.
13 Q. And you were present for Easton's
14 deposition, correct?
15 A. Yes.
16 Q. And you heard Easton describe, in his
17 own words, what a brain break is to him?
18 A. Yes.
19 Q. Is that a fairly accurate description
20 of what Easton does when he takes a brain
21 break?
22 MR. FULGINITI: Objection to
23 form. If you remember.
24 THE WITNESS: Yes.
214
1 BY MR. BLUTH:
2 Q. Okay. When Easton takes a brain break,
3 for how long does he go into a dark room?
4 A. It's kind of dependent on if he -- I
5 feel like he usually tries for 10, 15 minutes to
6 see if he can relieve it naturally with fluids
7 and a dark room. And then if he can't, he will
8 take some Ibuprofen.
9 Q. Okay. Is a typical brain break for
10 Easton 10 or 15 minutes, as you've described?
11 A. Yes.
12 Q. You've also mentioned, and Easton
13 mentioned at his deposition, that he has a bump
14 on the right side of his eye around the right
15 temple. Does Easton still have that bump or
16 raised area?
17 A. Yes.
18 Q. Is that bump painful for Easton, if you
19 know?
20 A. Physically, not painful. He's very,
21 very self-conscious about his bump.
22 Q. Okay. Describe that to me, when you
23 say that he is self-conscious about it.
24 A. He's worried that people notice it and
215
1 wonder what's wrong with his face.
2 Q. Okay.
3 A. It alters his appearance of his face,
4 and he doesn't like it.
5 Q. Okay. Just so I understand, how does
6 the bump -- I mean, other than it being visible,
7 how else, if at all, does that bump alter the
8 appearance of Easton's face?
9 A. It's raised.
10 Q. Okay. Has that gotten better? Has the
11 bump gotten better over time?
12 MR. FULGINITI: Objection.
13 THE WITNESS: Compared to
14 August 15th, but --
15 BY MR. BLUTH:
16 Q. I am sorry. I didn't hear --
17 A. -- it's still visible.
18 Q. I didn't hear the beginning of your
19 answer.
20 A. Compared to August 15th, yes. It has
21 gotten better over time, but it's still very much
22 visible.
23 Q. Okay. Do you know whether Easton's
24 medical providers expect that it will continue to
216
1 get better into the future?
2 A. No. They say it is just a spot that
3 fluid has -- like spinal fluid has just come, and
4 it's -- it's done what it's done, and it is
5 permanent now.
6 Q. Okay. So, the bump we observed at
7 Easton's deposition at the end of June of this
8 year, your understanding is that's what Easton's
9 doctors expect will be his permanent situation
10 into the future?
11 A. Yes.
12 Q. Okay. Have you appreciated any
13 difference in Easton's school performance in the
14 seventh and eighth grades versus before his head
15 injury in August of 2022?
16 A. So, Easton started off his seventh
17 grade year taking core classes online. Once
18 these classes were over, he -- you know, he
19 explained to me that he kind of treated these
20 classes like an open book class.
21 Like, everything was open book. He had
22 a lot of assistance with these online teachers.
23 He had a lot of tutoring sessions with them each
24 week.
217
1 When he went back -- during the second
2 semester of school in seventh grade, he went back
3 full-time. He -- he worked really, really hard
4 to get to where he was at.
5 If you look at eighth grade, you see
6 that he kind of started out, this grades were
7 predominantly As and Bs, but by the end of fourth
8 quarter, they were a lot lower.
9 And, you know, like, any general school
10 setting, you have your initial review, kind of,
11 of what you learned the year before, and then it
12 just builds upon each concept, and Easton lacks
13 the memory to remember these things. And so, his
14 grades had fallen a lot by the fourth quarter of
15 his eighth grade year.
16 And then now, in ninth grade, when he
17 does have his IEP, it's -- it enables him to do
18 better, but it's giving him an advantage because
19 of his disadvantage.
20 So, right now, we are seeing his grades
21 a lot better than when it was in eighth grade
22 before he had his IEP.
23 Q. Okay. What are the types of
24 accommodations described in Easton's IEP that you
218
1 believe are contributing to his better
2 performance in school in the ninth grade?
3 A. He is in a specialized math class that
4 he gets specialized help during that math class.
5 He has to render an elective, so he could take a
6 math lab, and, again, have tutoring during that
7 math lab.
8 He -- his first period every day is --
9 his homeroom period is that of his special math
10 teacher who oversees all of his classes to make
11 sure that he has got all of his assignments
12 turned in; that he knows what to expect; he knows
13 when to expect a test; and what his teachers are
14 expecting of him.
15 Q. Okay. Now, you mentioned special
16 education teacher. Is Easton still in mainstream
17 classes?
18 MR. FULGINITI: Objection to
19 the form, but you can answer.
20 THE WITNESS: He is not in
21 mainstream math. His math lab is
22 special education; and his advisory
23 class or homeroom class is special
24 education.
219
1 BY MR. BLUTH:
2 Q. Okay. Other than math and homeroom, is
3 Easton in mainstream classes for the rest of his
4 subjects?
5 A. Yes.
6 Q. Okay. Do you have any understanding
7 whether the material that Easton is being taught
8 in his special education math class, is that
9 different from other students in the ninth grade,
10 or is he learning the same material, but perhaps
11 doing it in an environment that is different than
12 other ninth graders?
13 MR. FULGINITI: Objection to
14 the form. You can answer.
15 THE WITNESS: He is learning
16 the same material. It is a standard
17 curriculum that all ninth graders have
18 to learn, but instead of going deep
19 into these concepts, they are just kind
20 of going surface level.
21 BY MR. BLUTH:
22 Q. Surface level on the math topics?
23 A. Yes.
24 Q. Okay. And if I understand correctly,
220
1 you described his homeroom as additional support
2 to understand and remember his homework
3 assignments and deadlines and tests in his other
4 classes as well; is that correct?
5 A. Correct.
6 Q. Okay. In terms of accommodations under
7 the IEP, you have mentioned the math class and
8 the homeroom special education. Are there any
9 other accommodations that Easton has under the
10 IEP?
11 A. If he needs more time for a test, if he
12 needs to go into a quieter area, he is allowed to
13 do that.
14 Q. Okay. Do you know whether Easton has
15 asked for accommodation thus far this school
16 year?
17 A. He has not. He hadn't felt comfortable
18 doing that. He doesn't want his peers to know
19 that he's struggling.
20 Q. Okay. What is your under -- with the
21 accommodations that Easton has under the IE --
22 under the current IEP, what is your understanding
23 of how Easton is struggling in school?
24 A. He has a processing delay. And so, he
221
1 can't remember concepts. I mean, he is --
2 socially, he is -- he's nervous that his friends
3 will find out that he isn't the same. He can't
4 process things the way he used to.
5 He has completely changed his friends'
6 group. He was friends with all of his baseball
7 buddies before his accident, but now he feels
8 like he can't keep up with them.
9 He doesn't have the athleticism of all
10 of his baseball friends. And so, he has kind of
11 gotten this new group of friends, which I love
12 these boys, but they are not -- they are more of
13 your school-type, nerd-type friends that aren't
14 athletic.
15 And so, it's just seeing him with his
16 peers, it's just an example to us that the gap
17 just keeps getting bigger, that they keep
18 improving, they keep advancing, they keep
19 maturing, and Easton is just kind of stagnant,
20 and that he is just always trying to play
21 catch-up compared to his peers.
22 Q. Okay. So, what you are describing in
23 terms of Easton's struggles at school is beyond
24 academic performance, but also involves his
222
1 friends, his social environment; am I
2 understanding correctly?
3 A. Yeah. He lacks confidence. He lacks
4 his identity. I mean, it's -- the poor kid, he
5 wants to go to school and wants to be known as
6 Easton Oliverson, the kid that made it to the
7 Little League World Series, but because of this
8 accident he is known as the bunk bed kid.
9 Q. Any other areas in which you have
10 observed Easton struggling with respect to
11 school?
12 A. I mean, physically, at school there's
13 things that are, you know, physically demanding
14 on him, that are hard, emotionally demanding on
15 him.
16 You know, he -- during his deposition,
17 he expressed how he goes to the bathroom at
18 school and he washes his hands and he sees his
19 scar. He sees -- and it just frustrating to him.
20 He just -- it's just something that
21 like he can't fix, and it's -- it is just -- I
22 just feel bad for him. Yeah. He is just like so
23 frustrated.
24 Q. You mentioned that he has been
223
1 struggling physically in school. What did you
2 mean by that?
3 A. I mean just as far as school work,
4 it's -- it's hard for him to remember to do
5 things. He doesn't have the cognitive things.
6 It's watching his peers advance when he
7 is just watching that gap get bigger and bigger,
8 I think it affects him.
9 Q. When you say watching his peers advance
10 and the gap getting bigger, can you provide me a
11 few examples of what you mean by that?
12 A. Yes. When he had a church activity
13 over the summertime that involved some
14 registration, some like signing up for classes,
15 and I stood back trying to allow him to do this
16 on his own, and just watching his peers flourish
17 and being able to handle this on his own -- their
18 own, where Easton just gets so overwhelmed.
19 He lacks confidence, and he just -- he
20 doesn't know. He gets embarrassed to have to ask
21 people, can you repeat yourself, or he gets
22 embarrassed to ask people, I don't remember, can
23 you help me. He gets embarrassed.
24 He just wants to be like his peers. He
224
1 doesn't want to need -- he doesn't want to have
2 an IEP. He doesn't want to have someone to be
3 there to assist him. He doesn't want me or Jace
4 having to be there to back him up.
5 He just -- you know, once he goes into
6 the work force, we won't be able to be there.
7 You know, there aren't IEPs in the work force.
8 And so, that is why we are so, so concerned about
9 his future. We don't -- we don't know.
10 We know -- doctors have talked about
11 that he -- dementia will be a problem in his
12 future, but that is the thing, we don't know when
13 that dementia will come. Will it come in his
14 20s? We don't know.
15 Q. Have you noticed any changes in
16 Easton's behaviors at school? In other words, is
17 Easton getting in trouble now with any more
18 frequency than before or anything along those
19 lines?
20 MR. FULGINITI: Objection.
21 THE WITNESS: His
22 behavior --
23 MR. FULGINITI: You can
24 answer.
225
1 THE WITNESS: His behaviors
2 at school haven't changed. His
3 behavior at home has changed. He is
4 very short-tempered with his siblings.
5 He's -- he's quick to anger.
6 And I don't -- it's hard for
7 to him to watch his little brother
8 excel at baseball at school.
9 It -- I mean, can you
10 imagine how Easton felt when he was
11 laying helpless in a hospital, and he
12 sees his brother going up to bat for
13 him at the Little League World Series?
14 I think you can't fathom --
15 BY MR. BLUTH:
16 Q. Have you --
17 A. -- how a 12-year-old felt.
18 Q. Have you had any conversations with
19 Easton about how he felt in those moments?
20 A. Yes.
21 Q. And how did Easton describe that to
22 you?
23 A. At that moment, he asked me to turn off
24 the TV. He didn't -- he didn't want to watch it.
226
1 Q. All right. Well, we will talk about
2 Easton's behavior at home in a moment, but back
3 to school, you mentioned that Easton is getting
4 tutoring. Is Easton getting tutoring at this
5 point in any of his subjects?
6 A. Yes.
7 Q. And which subjects?
8 A. Any -- specifically, math, he gets
9 tutoring at his math lab, but if he needs help in
10 any of his classes, they will help him as well.
11 Q. And I appreciate that under the IEP,
12 that there is a plan to provide that assistance
13 to Easton if he needs it, but has Easton needed
14 it in any of his classes, other than math, to
15 this point this year?
16 A. I haven't asked him. I don't know.
17 Q. Okay. All right. So, in terms of
18 accommodations at school, we talked about the
19 math and the homeroom, and more time for
20 test-taking if he -- if Easton would ask for it.
21 Are there any other accommodations in the IEP to
22 help Easton perform better at school?
23 MR. FULGINITI: She talked
24 about other stuff as well. You're
227
1 asking anything that she hasn't talked
2 about so far?
3 MR. BLUTH: Correct.
4 THE WITNESS: No, not
5 that -- nothing more than I've
6 previously stated.
7 BY MR. BLUTH:
8 Q. Okay. All right. So then, let's
9 transition to changes in -- that you have
10 observed in Easton's behavior at home. You
11 talked about he gets frustrated easily and
12 with --
13 A. Yes. And quick anger, very frustrated
14 very easily. He has a hard time multitasking, so
15 if I ask him to do multiple things.
16 He has a hard time when there is excess
17 noise around. He -- his processing delays,
18 he's -- you know, he is working -- he's 80
19 percent sponge, 20 percent brick.
20 And so, it is like we are trying --
21 trying to tell him these things, and he can't
22 remember, and he is -- we ask him to write it
23 down, but that doesn't get far, so...
24 Q. When you say "80 percent sponge,
228
1 20 percent brick," what do you mean by that?
2 A. Well, he has had a brain injury. So,
3 his brain is not going to work the same way as my
4 brain works, because I haven't had a brain
5 injury.
6 Q. Okay. I just am not understanding
7 the -- either that description or the analogy
8 that you were trying to use about sponge versus
9 brick.
10 A. His brain doesn't work the same that it
11 did on August 14th of 2022 as it does now.
12 Q. Okay. We've heard people say that
13 Easton is triggered easily. Are there -- is
14 there anything in your experience that would
15 routinely trigger Easton?
16 A. Absolutely. His brother, his little
17 brother, and I think that is due to jealousy.
18 Q. Okay. Anything other than or in
19 addition to his little brother's behaviors that
20 would trigger Easton, based on your observations
21 and experiences?
22 A. I mean, just, in general, at home. I
23 mean, it's triggering for him to be on the
24 baseball field, and to know that he will never be
229
1 the same baseball player that he was on
2 August 14th of 2022.
3 For him to have these huge goals and
4 aspirations to be a major league baseball player,
5 and for him to realize that this isn't going to
6 happen anymore.
7 Q. Okay.
8 A. That's triggering to him. I don't know
9 anything in his life that isn't triggering to
10 him, because of this accident it has affected
11 every aspect of his life.
12 Q. You described earlier that Easton would
13 take brain breaks when he gets a headache. Are
14 there reasons or circumstances that Easton would
15 take a brain break when he is not having a
16 headache?
17 A. If he just feels overwhelmed, if he
18 feels like he needs a break, then yes. He can
19 take a brain break any time. They -- that is
20 also in his IEP, if he needs to take a break,
21 he's allowed to.
22 Q. Okay. Has Easton taken a break at
23 school under the accomodation in the IEP since of
24 the beginning of this semester?
230
1 A. I haven't asked him.
2 Q. Are there any places that Easton avoids
3 going to because the circumstances at that place
4 might trigger a reaction from him?
5 A. Hospitals.
6 Q. And what is it about hospitals --
7 A. The beeping of the --
8 Q. -- that triggers him?
9 A. Yes. The beeping of the heart rate
10 monitors, the smells. He's afraid that if he
11 goes into the hospital, that he is going to be
12 admitted again. He just -- the anxiety.
13 Q. Okay. Any -- I mean, obviously -- I
14 shouldn't say obviously. But if Easton needs to
15 go to a medical appointment at a hospital, would
16 he go to that medical appointment, even with
17 those anxieties?
18 A. Yes. He has no other option. His
19 primary care doctor is in the hospital.
20 Q. Okay. So, other than hospitals, are
21 there places that Easton would prefer to avoid
22 going to because it triggers him in some way?
23 A. I think it's just hospitals.
24 Q. Okay. Are there places, for example,
231
1 that Easton might avoid going to because the
2 noise would be overwhelming to him?
3 A. No.
4 Q. I know that you described that Easton
5 has trouble multitasking, and if you were to
6 provide to him a list of chores, he might not
7 remember them all, but --
8 A. Correct.
9 Q. -- when Easton completes chores at
10 home, is there any difference in the way that he
11 completes them from before versus after his head
12 injury?
13 A. He will ask more questions about, maybe
14 he doesn't remember how things need to be done.
15 Q. Okay. And with those prompting from
16 whomever he is asking the question, is Easton
17 then able to complete the chores the same way he
18 would have prior to his injury, his head injury?
19 A. I mean, sometimes they're different
20 chores. I don't -- you know, when before his
21 head injury, he was doing different types of
22 chores, now that he is 14, and not 12, but I
23 mostly mean, like, if he cleans his room the way
24 at the age 14 than he did 12.
232
1 Q. What types of chores is Easton doing
2 around the house at present in addition to
3 cleaning his room?
4 A. His laundry, emptying the dishwasher,
5 helping with the dishes, vacuuming. He's
6 cleaning his bathroom.
7 Q. Okay. And is Easton --
8 A. Take --
9 Q. -- able to complete them?
10 A. -- of the dog --
11 THE COURT REPORTER: I'm
12 sorry?
13 BY MR. BLUTH:
14 Q. I'm sorry.
15 THE COURT REPORTER: I
16 didn't get that.
17 BY MR. BLUTH:
18 Q. What was the last one?
19 THE COURT REPORTER: I
20 didn't hear it.
21 THE WITNESS: He takes care
22 of the dog.
23 THE COURT REPORTER: Thank
24 you.
233
1 BY MR. BLUTH:
2 Q. Oh, he takes care of his dog. And what
3 type of dog does Easton have?
4 A. Goldendoodle.
5 Q. And how large is that dog?
6 A. Seven pounds.
7 Q. Oh, a little one.
8 A. Uh-huh.
9 Q. And all of the chores that you listed,
10 is Easton able to complete them even if he has to
11 ask questions or needs prompting from time to
12 time?
13 A. Yes. He is able to complete his
14 chores.
15 Q. Okay. If you -- if you combine the
16 brain breaks that Easton takes at home because of
17 headaches with the frequency of brain breaks he
18 takes for other reasons, are you able to estimate
19 the number of brain breaks Easton takes over a
20 period of a month, on average?
21 A. Seven or eight.
22 Q. And as you described earlier, are the
23 brain breaks that Easton takes, because he has
24 been triggered or overwhelmed by something, about
234
1 the same 10 or 15 minutes as he takes when he
2 takes a brain break for a headache?
3 MR. FULGINITI: Objection to
4 the form of the question. You can
5 answer.
6 THE WITNESS: Yes.
7 BY MR. BLUTH:
8 Q. I know from talking to Jace that Easton
9 is active in the church; is that correct?
10 A. Yes. Yes. He is an active member of
11 the Church of Jesus Christ of Latter Day Saints.
12 Q. Has Easton's activities at the church
13 changed in any way since his head injury?
14 A. The youth group at our church has --
15 have done activities that we won't allow to
16 Easton to do.
17 Q. Okay. What are the activities that the
18 church youth group is doing, but, as parents,
19 you've decided that Easton should not participate
20 in those, for whatever the reason?
21 A. Inner tubing, skiing.
22 Q. Any others?
23 A. Not that I can remember.
24 Q. And although it might be obvious, what
235
1 is it about inner tubing or skiing that you think
2 is an activity that Easton should not do?
3 A. Well, we don't want him to inner tube
4 because we are worried about head injuries; and
5 skiing, we didn't allow to go on the skiing trip
6 the first time they went after his accident, but
7 we did allow him to go the second time after his
8 accident.
9 He had to wear a helmet, and he did
10 have a physician's assistant who worked for a
11 neurosurgeon with him.
12 So, we trusted that in -- with the
13 neurosurgeon assistant, that he would help make
14 good choices.
15 And our church group is all very
16 familiar with Easton's situation, and everyone
17 looked after him. And so, we knew we could trust
18 them and trust him to make decisions that kept
19 him safe.
20 Q. Okay. And did Easton go skiing on that
21 second occasion?
22 A. He did.
23 Q. And when was that?
24 A. Winter of 2024.
236
1 Q. So, earlier this year?
2 A. Yes.
3 Q. And did I understand that you said
4 Easton had a physician's assistant that went with
5 him skiing?
6 A. Yes. He's in his -- he is a leader in
7 his youth group.
8 Q. The physician's assistant in the
9 neurosurgery office is also a leader in the
10 church youth group that Easton participates in;
11 is that correct?
12 A. Yes. But the neurosurgeon's office is
13 here in St. George, and they never treated
14 Easton.
15 Q. Okay. And did Easton enjoy skiing?
16 A. Very much.
17 Q. Okay. Did you ever ask any physician
18 or medical provider whether Easton can engage in
19 the activity of tubing?
20 A. Not specifically, no.
21 Q. Okay. That was something, if I
22 understand correctly, that, as parents, you
23 thought would not be a good idea for him because
24 of the fear of a repeated head injury; is that
237
1 right?
2 A. Yes.
3 Q. In terms of Easton's activities of
4 daily living, his getting dressed, his brushing
5 his teeth, bathing, toileting, things like that,
6 have you noticed any change in his ability to
7 complete those activities from before or after
8 the accident?
9 A. No. He can take care of himself well.
10 Q. Okay. Other than Ibuprofen for
11 headaches, as you have previously described, is
12 Easton taking any medication at present that you
13 understand is related to some injury he suffered
14 as a result of the head trauma?
15 A. No.
16 Q. Okay. We know, from Dr. Bollo's
17 record, that there was some concern back in the
18 early part of 2023 about whether his body was
19 accepting or rejecting the bone flap in his
20 skull. Do you remember that?
21 A. Yes.
22 Q. Is your understanding that that issue
23 has resolved at this point?
24 A. Dr. Bollo has told us that his body has
238
1 accepted his bone flap.
2 Q. Okay. We know that -- well, strike
3 that.
4 Is your understanding that any concern
5 that Easton may need a prosthetic bone flap in
6 his skull is in the past?
7 A. I mean, anything can happen, but the
8 bone flap he has right now, his body has accepted
9 and will continue to do its job.
10 Q. I saw in Dr. Goldstein's recent report
11 that Easton has started complaining of
12 stomachaches; is that accurate?
13 A. I think -- yes. I think that those
14 stomachaches he's explaining are more of an
15 anxiety.
16 Q. Okay. Have you talked to Easton about
17 his complaints of stomachaches?
18 A. No. I was not aware of these
19 stomachaches.
20 Q. Until I just mentioned them?
21 A. Yes.
22 Q. Okay. In other words, up until today,
23 it is -- stomachaches is not something that
24 Easton has complained to you about?
239
1 A. Yes.
2 Q. In other words, what I said is correct?
3 I just want to make sure --
4 A. Yes.
5 Q. -- the record is clear.
6 Okay. Since Easton was discharged from
7 Primary Children's Hospital in the middle of
8 September of 2022, has he seen any
9 ophthalmologist or neuro-ophthalmologist for
10 other issues related to his vision?
11 A. Yes.
12 Q. And who has Easton seen?
13 A. I don't recall the doctor's name.
14 Q. Do you remember at which facility that
15 eye care provider was located?
16 A. I believe it was the University of
17 Utah.
18 Q. Any particular location or campus?
19 A. It was near Primary Children's.
20 Q. In Salt Lake City?
21 A. Yes.
22 Q. When was the last time Easton saw an
23 ophthalmologist or a neuro-ophthalmologist?
24 A. In the year '22, maybe the first part
240
1 of '23.
2 Q. Okay. Does Easton have any complaints
3 about his vision at present?
4 MR. FULGINITI: Objection to
5 the form. You can answer to the extent
6 you understand.
7 THE WITNESS: Yes. He
8 struggles with hand-eye coordination.
9 He struggles tracking a baseball.
10 BY MR. BLUTH:
11 Q. And is Easton seeing any medical
12 provider for those complaints?
13 A. No.
14 Q. What was the purpose for which Easton
15 saw an eye care provider at the end of 2022 or
16 the early part of 2023?
17 A. It was either Dr. Flavin or Dr. Bollo
18 recommended that he follow up with the eye
19 doctor.
20 Q. And did you take Easton to that eye
21 doctor appointment or appointments, whenever they
22 were?
23 A. I did not. Jace did.
24 Q. Okay. Do you have any understanding as
241
1 to what findings, if any, the eye doctor made?
2 A. I believe his findings -- yes. Yes.
3 His findings came back normal.
4 Q. Okay. So, if I understand you
5 correctly, since that eye evaluation, Easton has
6 now complained to you about trouble with hand-eye
7 coordination and seeing the spin on a baseball as
8 you've just described; is that correct?
9 MR. FULGINITI: Are you
10 suggesting that it only happened after
11 the eye examination?
12 MR. BLUTH: No. But I will
13 ask that question.
14 BY MR. BLUTH:
15 Q. Did Easton have complaints of, as
16 you've just described, with hand-eye coordination
17 or tracking a baseball at the time that he saw
18 the eye care provider at the University of Utah?
19 A. Yes.
20 Q. And was the eye care provider at the
21 University of Utah asked to evaluate Easton for
22 those complaints?
23 A. I think -- I don't know. I was not
24 present at the appointment. They were following
242
1 through with an eye check that he had received
2 while at Primary Children's.
3 Q. While at Primary Children's as an
4 inpatient?
5 A. Yes.
6 Q. Okay.
7 A. There was multiple times after Easton's
8 surgery that his -- his eye was so swollen that
9 he couldn't see out of it.
10 Q. While he was an inpatient?
11 A. Yes.
12 Q. Has Easton had that problem since his
13 discharge from September 13th, 2022, meaning his
14 eye was -- his right eye was so swollen that he
15 could not see out of it?
16 A. No.
17 Q. Okay. So, did Easton -- at the
18 University of Utah, did Easton have one or more
19 than one appointment?
20 A. He had one appointment while a patient
21 at Primary Children's, and then a separate
22 appointment once he was released from Primary
23 Children's.
24 Q. Okay. So, since his discharge from
243
1 Primary Children's, Easton has had only one
2 outpatient appointment with an eye doctor; is
3 that correct?
4 A. Yes.
5 Q. Okay. And I think you were describing
6 earlier that you do not know whether the eye
7 doctor evaluated Easton for his complaints of
8 tracking a baseball and hand-eye coordination; is
9 that correct?
10 A. Yes.
11 Q. But, regardless, your understanding is
12 that the eye doctor made findings that were
13 normal for Easton; is that correct?
14 A. They -- for his vision, yes.
15 Q. Okay. Since that time, has Easton
16 complained of problems with his vision, as you've
17 described, tracking a baseball and hand-eye
18 coordination?
19 MR. FULGINITI: That's how
20 this all started.
21 THE WITNESS: Yeah.
22 MR. BLUTH: I didn't hear
23 you, Ken.
24 MR. FULGINITI: That is how
244
1 this whole line of questioning started,
2 was that she was saying he has problems
3 with hand-eye coordination and tracking
4 a baseball.
5 MR. BLUTH: I understand
6 that, but you suggested I haven't laid
7 a foundation, so we had to go
8 backwards. So, now, we are back to
9 where we were before.
10 MR. FULGINITI: I did not
11 suggest that you had to lay a
12 foundation. I just wanted to -- you
13 asked the question of since this
14 incident, he's now indicated that he
15 has this issue, and I was clarifying
16 whether or not you meant that it
17 started after the doctor's appointment.
18 So, I was clarifying that.
19 But I think for the last
20 20 minutes we've established that he
21 has problems with tracking a baseball
22 and hand-eye coordination.
23 BY MR. BLUTH:
24 Q. All right. Since the one outpatient
245
1 appointment with the eye care provider at the
2 University of Utah, has Easton been evaluated by
3 anybody else for his complaints of tracking a
4 baseball or hand-eye coordination?
5 A. No.
6 MR. FULGINITI: An
7 ophthalmologist.
8 THE WITNESS: Not as an
9 ophthalmologist.
10 BY MR. BLUTH:
11 Q. Has Easton treated with anybody that
12 you understood to be an eye care provider with
13 any level of credentials for those complaints?
14 A. Yes. He was seen at the University of
15 Utah for a follow-up.
16 Q. Right. My question is since that time.
17 A. No.
18 Q. I mean, I understand that there are
19 different levels of eye care providers, from
20 optician to optometrist to ophthalmologist to
21 neuro-ophthalmologist.
22 Has Easton seen any of those types of
23 providers for his complaints of tracking --
24 related to tracking a baseball or hand-eye
246
1 coordination subsequent to the one appointment he
2 had as an outpatient at the University of Utah?
3 A. No. I -- I personally feel the reason
4 why he is having these issues is due to a
5 processing delay.
6 Q. Has any medical provider said that to
7 you?
8 A. I don't remember.
9 Q. In other words, has any of Easton's
10 medical providers since his -- since his head
11 injury have said to you that these complaints,
12 these visual complaints that Easton is making,
13 might be caused by a processing delay as a result
14 of his head injury?
15 MR. FULGINITI: Objection to
16 the form. You can answer to the extent
17 you remember.
18 THE WITNESS: I mean, if you
19 look at, you know, the effects, what
20 people -- the effects of after a
21 traumatic brain injury, it is in line
22 with that.
23 BY MR. BLUTH:
24 Q. And that may or may not be correct, but
247
1 my question is really whether any of the medical
2 providers, who have evaluated Easton, have
3 suggested that to you.
4 MR. FULGINITI: Objection to
5 form.
6 THE WITNESS: I don't
7 remember.
8 MR. FULGINITI: You can
9 answer. Go ahead. She said, I said
10 does not remember.
11 MR. BLUTH: Yes. That's
12 what she said.
13 All right. Let's take a
14 short break, and then I will finish up.
15 THE VIDEOGRAPHER: 3:47, off
16 video.
17 (At this time, a short break
18 was taken.)
19 THE VIDEOGRAPHER: 3:56, on
20 video.
21 BY MR. BLUTH:
22 Q. All right. Ma'am, I expect that we are
23 in the home stretch. So, I will thank you now
24 for your patience throughout the day, and I
248
1 probably will do that again when we are finished.
2 Since Easton's head trauma, have you
3 noticed whether he has shown any sensitivity to
4 light?
5 MR. FULGINITI: She has
6 already talked about this. So, are you
7 asking again?
8 MR. BLUTH: No. She talked
9 about noise. I don't recall that she
10 talked about light.
11 MR. FULGINITI: She did.
12 She said she'll go -- he will go into a
13 dark room.
14 MR. LIVINGOOD: Yeah. But
15 she never said anything about sensitive
16 to light.
17 MR. BLUTH: That is not
18 sensitivity to light. That is trying
19 to alleviate the symptoms that
20 triggered him or his headache or
21 something like that.
22 MR. FULGINITI: She can
23 answer. It's just we have been here
24 for six hours, and we are covering a
249
1 lot of the same territory.
2 MR. BLUTH: I don't believe
3 that we are covering any of the same
4 territory.
5 MR. FULGINITI: You may not.
6 You say, you just said, and then you
7 repeat your questions three times, but
8 go ahead, Nancy.
9 THE WITNESS: Yes. When
10 Easton experiences his headaches, he is
11 very sensitive to light, and that is
12 why he likes to go into a dark place
13 that is quiet, so that he can try to
14 relieve that pain.
15 BY MR. BLUTH:
16 Q. Okay. Other than when Easton is
17 experiencing a headache, are there other -- any
18 other circumstances in which you have observed
19 him to have a sensitivity to light?
20 A. He has -- when he is not experiencing a
21 headache, he has not communicated to me if that
22 bothers him or not.
23 Q. Okay. When Easton talks to you about
24 his life's experiences before versus after his
250
1 head trauma in August of 2022, is there anything
2 that he describes to you that you have not
3 already expressed to us?
4 MR. FULGINITI: Wait. What
5 was your question? Easton -- his
6 life's experiences before the incident?
7 MR. BLUTH: When Easton -- I
8 will rephrase the question.
9 BY MR. BLUTH:
10 Q. When Easton talks to you about his life
11 before versus after the August 2022 head trauma,
12 does he talk to you about anything that you have
13 not already described to us?
14 MR. FULGINITI: I'll object.
15 I am going to tell her not to answer
16 that question.
17 She has been talking for six
18 hours, and she has answered your
19 questions.
20 And now, you are basically
21 saying, is there anything else you want
22 to say, which would require her to
23 remember the last six hours of answers
24 that she has given, some of which she
251
1 has given really emotionally, some of
2 which were five hours ago.
3 So, if you have a specific
4 question, she will answer the question.
5 BY MR. BLUTH:
6 Q. Okay. Is there anything that Easton
7 cannot do now at all that he could do before his
8 accident?
9 A. He cannot play football.
10 Q. Okay.
11 MR. FULGINITI: You know, in
12 addition to everything that she has
13 already testified to for the last six
14 hours.
15 MR. BLUTH: Well, we haven't
16 talked about football yet.
17 MR. FULGINITI: I am saying
18 everything in addition to what, this is
19 an addition to what she hasn't talked
20 about before.
21 BY MR. BLUTH:
22 Q. Did Easton play football before his
23 accident?
24 A. He -- I wouldn't allow him to play
252
1 tackle football at the time. He did play flag
2 football.
3 Q. Okay. And since his head injury, he
4 does not play flag football anymore; is that
5 correct?
6 A. Yes.
7 Q. Okay. Anything else that Easton would
8 do prior to the accident that he does not do at
9 all anymore?
10 MR. FULGINITI: Objection to
11 the form. You can answer, in addition
12 to the six hours of testimony that you
13 provided.
14 THE WITNESS: I mean, I
15 won't allow -- we won't allow him to
16 ride dirt bikes. He's -- anything that
17 might cause him to get hurt.
18 BY MR. BLUTH:
19 Q. Sure. And I understand that, but I
20 mean, are there specific things that Easton wants
21 to do, and he has expressed to you he wants to do
22 that, as parents, as concerned parents, you say,
23 no, because of this injury, you can't do that?
24 You mentioned football. You mentioned
253
1 dirt bikes. Is there anything else?
2 MR. FULGINITI: Objection.
3 THE WITNESS: All of his
4 buddies --
5 MR. FULGINITI: You can
6 answer. I think she also mentioned
7 other things, but you can go ahead, and
8 you can answer.
9 THE WITNESS: All of his
10 buddies that are out on their
11 Onewheels. We won't allow him to get
12 on a Onewheel.
13 All of his buddies ride
14 around on Sur-Rons. We won't allow him
15 to get on one of those. I mean, his
16 whole life is impacted.
17 BY MR. BLUTH:
18 Q. We've talked about baseball. We've
19 talked about wrestling. At present, outside of
20 school, does Easton have any other hobbies or
21 activities that he likes to do? His father
22 mentioned fishing, for example, at his
23 deposition.
24 A. Yes. He loves to fish.
254
1 Q. Is Easton still able to fish, go
2 fishing?
3 A. Yes.
4 Q. To your knowledge, has Easton's ability
5 to go fishing been impacted at all by his head
6 injury?
7 MR. FULGINITI: You mean his
8 current ability?
9 MR. BLUTH: His current
10 ability, correct.
11 THE WITNESS: I mean, he is
12 no professional fisherman, but, yes, he
13 is able to fish off-shore at a local
14 pond.
15 BY MR. BLUTH:
16 Q. Is Easton still playing -- at present,
17 is Easton still playing baseball?
18 A. Yes.
19 Q. And at present, is Easton still
20 competing in wrestling matches?
21 A. He is not competing in wrestling
22 matches at this time, and it is not wrestling
23 season.
24 Q. Okay. When did wrestling season end
255
1 most recently?
2 A. February.
3 Q. Okay. When does wrestling season start
4 again?
5 A. November.
6 Q. And is the current plan for Easton to
7 resume wrestling matches in November when the
8 season starts?
9 A. He will try out for the wrestling team,
10 and if he has an opportunity to wrestle, he will.
11 Q. Okay. And that tryout, and whether he
12 is selected for the team, is that a school-based
13 team?
14 A. Yes.
15 Q. And is it correct that whether he makes
16 the team is a function of his performance at
17 tryouts?
18 A. I believe everyone will make the
19 wrestling team. It is just if he will perform
20 wrestling matches. For his weight class, he has
21 to earn that spot.
22 Q. Okay. And is that -- the wrestling
23 matches in his weight class, is that what you
24 were referring to when you said if he gets an
256
1 opportunity to participate?
2 A. Yes.
3 Q. Okay. Jace described that Easton will
4 no longer play certain positions on a baseball
5 field since his accident; is that correct?
6 MR. FULGINITI: Objection.
7 THE WITNESS: Yes.
8 MR. FULGINITI: He said
9 that, or he is starting to hear him do
10 that?
11 BY MR. BLUTH:
12 Q. What positions does Easton no longer
13 play on the baseball field since his accident?
14 A. He doesn't play infield, because his
15 reaction time isn't quick enough.
16 Q. Okay. Does Easton still pitch?
17 A. In an inter squad, intermural game, he
18 has gotten the opportunity to pitch.
19 Q. Okay.
20 A. But if it's like an actual game, very
21 seldom.
22 Q. Okay. And so, at present, when Easton
23 plays baseball, is there a position that he would
24 usually or typically play?
257
1 A. When he gets a chance to play, he's
2 playing most of the time in the left field.
3 Q. Okay. Is your observation that Easton
4 is getting an opportunity to play baseball in
5 competitive games is -- has been diminished since
6 prior to his head injury?
7 A. Absolutely. He was a star pitcher. He
8 played center field. He played third base.
9 Like, he was -- I mean, look at his statistics.
10 He was an amazing baseball player.
11 Q. Is -- even though it is the offseason
12 for wrestling, does Easton continue to workout or
13 condition or train for the wrestling season that
14 is upcoming?
15 MR. FULGINITI: Objection to
16 form, whatever you mean by condition,
17 or train or workout.
18 But go ahead, you can
19 answer, at least if you know what he
20 means.
21 THE WITNESS: His main --
22 his main focus is baseball.
23 BY MR. BLUTH:
24 Q. Okay.
258
1 A. So, he is focusing on baseball.
2 Baseball is his love and his passion. He does
3 wrestling so he can be a better baseball player.
4 Q. Have you had any discussions with
5 Easton's medical providers since he has been
6 discharged from Primary Children's Hospital on
7 September 13, 2022, about the chances or
8 likelihood that Easton might develop some sort of
9 dementia in the future?
10 A. Yes. Every doctor's appointment, we
11 talk about, you know, what are his deficiencies,
12 what can we expect. Yeah. They talk about it a
13 lot.
14 Q. And, specifically, which of Easton's
15 physicians have you spoken with about the
16 potential for an early onset dementia?
17 A. His neurosurgeon, his pediatric doctor.
18 Q. And what has Dr. Bollo said to you
19 about the possibility that Easton may develop a
20 dementia in the future?
21 A. It is just the course after a traumatic
22 brain injury that this is -- this is a huge
23 possibility that this will happen.
24 Q. Okay. And what has Dr. Kaddu, his
259
1 pediatric provider, said to you on that
2 subject?
3 A. Something very similar.
4 Q. Is it something that, as a family, you
5 are keeping an eye out for as you go forward with
6 Easton's care, I imagine?
7 A. Yes. It's not -- it's not like if.
8 It's when.
9 Q. In other words, has Dr. Bollo
10 specifically said to you that it is only a
11 function of when, but not if, Easton will develop
12 a dementia in the future?
13 A. I don't know the exact verbiage he
14 used, but we do know that the lingering effects
15 of a traumatic brain injury is dementia.
16 Q. Right. But just because of the way you
17 phrased your answer, I'm -- did Dr. Bollo tell
18 you that it was 100 percent sure thing that this
19 will happen at some point in the future?
20 MR. FULGINITI: Objection to
21 the form.
22 THE WITNESS: I --
23 MR. FULGINITI: If you don't
24 remember the exact words, you have
260
1 already said.
2 BY MR. LIVINGOOD:
3 Q. You can answer the question.
4 A. I don't remember.
5 Q. The last subject, ma'am, have you ever
6 spoken with anyone from the Michael Curran
7 family?
8 A. No.
9 MR. BLUTH: All right.
10 Those are all the questions I have at
11 this time.
12 Thank you very much for your
13 patience and your cooperation over the
14 course of the last several hours.
15 THE WITNESS: You're
16 welcome.
17 MR. LIVINGOOD: Good for me
18 to go a little bit?
19 MR. BLUTH: What was that,
20 John?
21 MR. LIVINGOOD: All set?
22 MR. BLUTH: I am done.
23 MR. LIVINGOOD: Good for me
24 to go.
261
1 BY MR. LIVINGOOD:
2 Q. Okay. Mrs. Oliverson, are you good if
3 I continue now, or do you need a break?
4 A. I'm good.
5 Q. Okay. I didn't get to introduce myself
6 formally a few hours ago. My name is
7 John Livingood. I represent John Savoy & Son,
8 Contract Furniture, one of the entities that has
9 been sued, a defendant in the case.
10 I have some questions for you. I'm not
11 going to be nearly as long. There are just a
12 couple issues that I just want to focus on and
13 make sure that your answers are clear, and I get
14 all the information.
15 So, I am not trying prolong this, and I
16 really do appreciate your time and patience with
17 us here today.
18 Let me start out with school a little
19 bit right now and activities. So, Easton started
20 ninth grade this past August; would that be fair
21 to say?
22 A. Yes.
23 Q. Okay. And so, we are, I don't know,
24 two-and-a-half or so months into the school year
262
1 for Easton for his freshman year of college -- or
2 high school. What specific classes is he taking
3 right now?
4 MR. FULGINITI: When you say
5 "two-and-a-half months," do you mean --
6 I don't know that she said that he
7 started August 1st.
8 MR. LIVINGOOD: All right.
9 I will take that out. Let me ask it
10 again.
11 BY MR. LIVINGOOD:
12 Q. In this first -- first semester --
13 first of all, is Easton's high school broken up
14 into a first semester and a second semester?
15 A. Mostly, first quarter, second quarter,
16 and then, yeah, semesters.
17 Q. So, are we -- are you into the second
18 quarter yet?
19 A. I believe the first quarter will be
20 ending this week.
21 Q. Okay. So, we are still in -- we are
22 close, but we are still in the first quarter.
23 A. Yes.
24 Q. And what does -- do Easton's classes
263
1 change each quarter, or does he keep all of those
2 classes at least for the first and second
3 quarters?
4 A. He does change elective classes
5 throughout the quarter -- new quarter, but his
6 core classes are the same.
7 Q. So, I'm going to ask you about both of
8 them. What core classes is Easton taking right
9 now in ninth grade?
10 A. I don't know exactly. He's taking a
11 math. He's taking a science, a Language Arts.
12 Those are the ones that I can recall.
13 Q. Is the math class he's taking algebra,
14 calculus, something else?
15 A. It is just Math 9.
16 Q. And do you know what the subject matter
17 of that is?
18 A. I -- no.
19 Q. Do you know --
20 A. I don't know what that is.
21 Q. And what science is Easton taking right
22 now?
23 A. I don't know.
24 Q. Okay. And Language Arts, is that a
264
1 foreign language, or is that what we used to call
2 English?
3 A. It's what we would call English.
4 Q. Okay. Are there any other core classes
5 that Easton is taking right now?
6 A. I'm not sure.
7 (Technical difficulty.)
8 BY MR. LIVINGOOD:
9 Q. The math core classes, then he would,
10 if he did not have an IEP?
11 MR. FULGINITI: I'm sorry.
12 What was your question?
13 THE WITNESS: I didn't --
14 MR. LIVINGOOD: Did I break
15 up? I'm sorry.
16 BY MR. LIVINGOOD:
17 Q. Is he taking -- just tell me if I do.
18 Is he taking any less core classes now because of
19 his IEP than he would if he did not have an IEP?
20 A. No. He gets less elective classes,
21 because of his IEP.
22 Q. Are there other core classes you don't
23 remember right now, or is it just the three core
24 classes that he is taking?
265
1 MR. FULGINITI: If you know.
2 MR. LIVINGOOD: Thank you.
3 THE WITNESS: I don't know.
4 BY MR. LIVINGOOD:
5 Q. What elective classes is Easton taking
6 right now in this first semester of ninth grade?
7 A. Spanish, and he takes a seminary class,
8 which is a church class, and then Manufacturing
9 Technology.
10 Q. What is -- what is Manufacturing
11 Technology? What is he studying or learning?
12 THE COURT REPORTER: I
13 think -- Nancy, did you freeze?
14 MR. FULGINITI: She froze.
15 THE COURT REPORTER: I think
16 she froze.
17 THE VIDEOGRAPHER: 4:15, off
18 video.
19 THE COURT REPORTER: Oh,
20 there she goes.
21 (At this time, a short
22 recess was taken.)
23 (At this time, a discussion
24 was held off the record.)
266
1 BY MR. LIVINGOOD:
2 Q. Can you hear me okay now,
3 Mrs. Oliverson? We froze for a second there.
4 A. Yes. I can hear you now.
5 Q. Thank you.
6 THE VIDEOGRAPHER: Let me
7 get us back on now, John. One second.
8 MR. LIVINGOOD: Okay.
9 THE VIDEOGRAPHER: 4:15, on
10 video.
11 BY MR. LIVINGOOD:
12 Q. I think the question that we froze on
13 was: What is he learning in Manufacturing
14 Technology?
15 A. It's similar to a shop class.
16 Q. Okay. And then --
17 A. I believe he built a boomerang, is the
18 last project I know he did.
19 Q. And then Spanish, has Easton ever taken
20 a foreign language before ninth grade?
21 A. He has not.
22 Q. Now, since we are coming up on the end
23 of the first quarter, what changes -- what
24 classes would change -- are going to change for
267
1 Easton going into the second quarter with the --
2 you said the electives may change?
3 A. So, it would be Manufacturing
4 Technology would change, and possibly Spanish,
5 but I think he's continuing Spanish as an
6 elective again.
7 Q. What class is he going to take instead
8 of Manufacturing Technology?
9 A. I don't know what class he is taking
10 instead of that one.
11 Q. Were the electives that Easton is
12 taking now this first quarter any different
13 because of his IEP? Like, he is taking less, or
14 they are a different level, or anything like
15 that?
16 MR. FULGINITI: She already
17 said that he is taking less, because he
18 has to use the electives for the IEP.
19 MR. LIVINGOOD: Well, I
20 think that is homeroom that he is using
21 for the elective, but thank you.
22 BY MR. LIVINGOOD:
23 Q. He is taking less electives; is that --
24 A. He has -- he is taking less electives,
268
1 because he has to use his math lab as an
2 elective.
3 Q. And is the math lab, it's something
4 different than the actual math class? So, almost
5 getting --
6 A. Yes.
7 Q. -- two maths?
8 A. Yes.
9 Q. Okay. With the IEP, did you or
10 somebody on behalf of Easton have to submit
11 medical records or a doctor's opinion?
12 A. Yes. We had to submit forms from his
13 primary care doctor.
14 Q. Dr. Kaddu submitted forms in order to
15 qualify for the IEP?
16 A. Yes.
17 Q. And did any other healthcare provider
18 submit any forms, other than Dr. Kaddu?
19 A. No.
20 Q. Did Dr. Goldstein have any involvement
21 in getting -- applying or forming Easton's IEP?
22 A. Yes. Dr. Goldstein did.
23 Q. What involvement did he -- does he have
24 or did he have?
269
1 A. There were tests that needed to be done
2 that the school would have done normally, but
3 since Dr. Goldstein did the tests, he -- we
4 provided those tests that Dr. Goldstein did to
5 the school. So, we were able to get that IEP in
6 place within a few days.
7 Q. Did Dr. Goldstein participate in the
8 actual -- creating the actual plan, or is it just
9 that he submitted the test results?
10 MR. FULGINITI: Objection to
11 form. You can answer if you
12 understand.
13 THE WITNESS: I am not sure
14 how the test results were submitted, if
15 Jace submitted them or if Dr. Goldstein
16 submitted them.
17 BY MR. LIVINGOOD:
18 Q. Other than submitting test results,
19 whether Jace did or Dr. Goldstein did it
20 directly, did Dr. Goldstein have any other
21 involvement in Easton's -- in the formation or
22 the actual plan for Easton's IEP?
23 MR. FULGINITI: Objection to
24 the form. You can answer, if you
270
1 understand.
2 THE WITNESS: He
3 communicated with Jace and I what he
4 believes would be a good plan for
5 Easton as far as an IEP. And so, we
6 then communicated that with the school.
7 BY MR. LIVINGOOD:
8 Q. And was that part of what was put into
9 place for Easton?
10 A. Yes.
11 Q. Find Dr. Goldstein?
12 THE COURT REPORTER: I'm
13 sorry?
14 BY MR. LIVINGOOD:
15 Q. How did you find Dr. Goldstein?
16 A. Through Ken.
17 Q. Ken who?
18 MR. FULGINITI: Fulginiti.
19 THE WITNESS: My attorney.
20 BY MR. LIVINGOOD:
21 Q. Oh, through your attorney. Okay.
22 Sorry. Sometimes I am slow on the uptake.
23 That IEP will last for the entire ninth
24 grade?
271
1 MR. FULGINITI: Objection to
2 form. You mean only the ninth grade,
3 or does it have to be renewed? What
4 are you asking?
5 MR. LIVINGOOD: Well, that
6 is going to be my next question. Yeah.
7 MR. FULGINITI: So, what is
8 your question?
9 THE WITNESS: He --
10 MR. LIVINGOOD: The first
11 one, the one I asked.
12 MR. FULGINITI: It wasn't
13 really a question. It was a statement.
14 That is why I am just trying to get
15 clarification.
16 BY MR. LIVINGOOD:
17 Q. Is that IEP only for the ninth grade?
18 A. He will have to renew his IEP every
19 year in August to see if he still qualifies.
20 Q. Okay. In this first -- or fall
21 semester, or fall quarter of ninth grade, is
22 Easton participating in any kind of
23 extracurricular activities at the school?
24 MR. FULGINITI: Objection.
272
1 You mean baseball?
2 MR. LIVINGOOD: I didn't say
3 baseball. I said anything.
4 MR. FULGINITI: Well, I
5 don't know what an extracurricular
6 activity would include. Does it
7 include sports?
8 MR. LIVINGOOD: Anything.
9 BY MR. LIVINGOOD:
10 Q. Did you understand what I mean by an
11 extracurricular activity?
12 MR. FULGINITI: Objection,
13 John. I really do. Okay. An
14 extracurricular activity may mean
15 something to you. It may mean
16 something different to them. It may
17 mean something different to me.
18 I am just trying to
19 understand. She has already talked
20 about baseball ad nauseam, and
21 wrestling and what not. I am just
22 trying --
23 MR. LIVINGOOD: That
24 question had nothing -- that was not my
273
1 question.
2 MR. FULGINITI: So, that is
3 why I don't understand it. I am
4 asking, does it include sports?
5 BY MR. LIVINGOOD:
6 Q. Any extracurricular -- do you know what
7 an extracurricular activity is, Mrs. Oliverson?
8 Have you ever heard that term?
9 A. Yes, I have.
10 Q. Okay. And do you understand what that
11 term means?
12 A. He's -- he's been participating in fall
13 ball or baseball. He participates in our church
14 youth group where they will do service
15 activities.
16 Q. Is that it? I --
17 THE COURT REPORTER: You
18 know, we didn't hear that, John.
19 MR. LIVINGOOD: I didn't
20 know if I cut her off. It's just I
21 have fall ball and church youth
22 services activity, is what I heard.
23 THE WITNESS: Yes.
24 THE COURT REPORTER: That's
274
1 what she said.
2 THE WITNESS: That's
3 correct.
4 BY MR. LIVINGOOD:
5 Q. Is the fall ball through his school or
6 through some other organization not affiliated
7 with his school?
8 A. It's through his school.
9 Q. And I -- forgive me if Mr. Bluth asked
10 you this. What is the name of the Easton's
11 school?
12 A. Snow Canyon High School, but he
13 actually attends the middle school. In
14 St. George, ninth grader attend Snow Canyon
15 Middle School, but they are not part of Snow
16 Canyon High School sports.
17 Q. So, for fall ball for Easton, did you
18 have to try out for that team?
19 A. No. Everyone makes the team. They
20 allow the eight graders to play as well.
21 Q. And going -- going backwards, when I
22 had the opportunity to spend some time with
23 Mr. Oliverson, I believe that might have been
24 back in June, for this summer, this past summer,
275
1 has Easton played any baseball for any teams,
2 organizations?
3 A. Yes.
4 Q. And who did he play for this summer?
5 A. He played for the RoadRunners.
6 Q. RoadRunners. And has fall ball ended
7 for Snow Canyon?
8 A. No. It goes -- I think they have their
9 championship game the first part of November.
10 Q. And then would Easton roll right into
11 wrestling after the championship of fall ball?
12 A. If his team makes it to the
13 championship, but, yes, once the championship is
14 over, he will be starting wrestling in a few
15 weeks.
16 Q. And then from wrestling, is it Easton's
17 goal to play spring baseball for --
18 A. Yes.
19 Q. -- for Snow Canyon?
20 A. He will try out for the Snow Canyon
21 High School baseball team.
22 Q. And that -- would that be a tryout
23 where not everybody makes the team?
24 A. Yes. I -- actually, I take that back.
276
1 I'm not sure. It's the freshman/sophomore team.
2 I am not sure if they take cuts on that
3 freshman/sophomore team, because they do the
4 freshman/sophomore, the junior varsity and the
5 varsity team.
6 Q. Is Easton still working out with
7 Ryan Secrist?
8 A. He is working out with Brogan Secrist,
9 yes.
10 Q. Oh, I'm sorry. Ryan was -- Ryan was
11 the Crimson Counseling. Okay. Brogan Secrist,
12 is he still working out with Brogan Secrist?
13 A. Yes.
14 Q. How often does he work out with
15 Mr. Secrist?
16 A. Usually, three times a week.
17 Q. Are these weekdays or weekends or some
18 combination?
19 A. All weekdays.
20 Q. Is that at a particular time, like
21 right after school, or 7:00 at night, or
22 something else?
23 A. Right after school.
24 Q. Has Easton taken, at school, any
277
1 standardized testing this year in ninth grade?
2 A. No.
3 Q. I'd gotten to talk to Mr. Oliverson a
4 little bit about Easton's sort of career goals
5 and aspirations.
6 What was your understanding of, you
7 know, to use the term, what Easton wanted to do
8 when he grew up, grows up? What is your
9 understanding?
10 MR. FULGINITI: Before --
11 THE WITNESS: Without a
12 doubt, Easton --
13 MR. FULGINITI: I'm sorry.
14 I just wanted to have a time frame,
15 John. Before he got hurt, what did he
16 want to do?
17 MR. LIVINGOOD: Thank you.
18 Yes.
19 THE WITNESS: Before he got
20 hurt, Easton, without a doubt, wanted
21 to be a major league baseball.
22 BY MR. LIVINGOOD:
23 Q. Did he have any --
24 A. He had it. He had --
278
1 Q. -- other plans or aspirations?
2 A. -- the drive. He had the drive. He
3 had the academics to get into a really good
4 college. He had support from his family. He had
5 the talent.
6 Q. Has Easton expressed any kind of career
7 goals or aspirations now since his injury?
8 A. He has. He would like to be a physical
9 therapist, because of his therapist, his physical
10 therapist, Brandon, was such a huge impact on
11 him.
12 Q. And is that Mr. Secrist, or some
13 other when he was back at Primary Children's?
14 A. No. Brandon was his physical therapist
15 at Dixie -- Dixie Regional here in St. George.
16 I mean, we -- I hope he could do that,
17 but, I mean, let's -- let's like make it a
18 reality.
19 Like, I would love for him to be a
20 physical therapist, but someone that, you know,
21 needs to have an IEP, and get into the work
22 force, I don't have the heart to tell him that's
23 probably, you know, not going to happen, but
24 that's his goal.
279
1 MR. LIVINGOOD: Okay. That
2 is all I have. I do appreciate your
3 patience with a very long day talking
4 about, you know, tough subjects, and I
5 really appreciate you spending the
6 time. Thank you.
7 THE WITNESS: You're
8 welcome.
9 MR. FULGINITI: Is that it?
10 MR. BLUTH: I have a couple
11 of follow-ups, in three areas.
12 BY MR. BLUTH:
13 Q. Ma'am, is there a -- let me ask it this
14 way: Why did Easton not have an IEP until the
15 2024-2025 school year?
16 A. We wanted Easton to be as normal as
17 possible, but once school started getting harder,
18 once he -- that we could tell the decline of his
19 grades, once he was in ninth grade, we really
20 needed him to have the support, because these are
21 the grades that count to get him into college,
22 and we wanted to help him in any way. He already
23 has a disadvantage trying to compete with his
24 peers to get into college.
280
1 The school did not make it easy for us
2 to do this for him. And so, once we had the
3 support from the school -- we had to reach out to
4 the school district, and once we had the support
5 from the school district, we were quick to make
6 it happen for his freshman year.
7 Q. Were there particular obstacles that
8 you encountered that made it difficult to have an
9 IEP in place in any of the prior school years?
10 MR. FULGINITI: Objection to
11 the form. Are you asking if she tried
12 to have an IEP put in place in prior
13 school years?
14 MR. BLUTH: Well, that's one
15 way to ask it, but, specifically, I was
16 asking whether -- I will ask it that
17 way.
18 BY MR. BLUTH:
19 Q. Did you try to have an IEP either in
20 Easton's seventh grade year or eighth grade year?
21 A. Yes.
22 Q. And what was it about the process in
23 either of those prior school years that
24 ultimately resulted in Easton not having an IEP
281
1 in those years?
2 A. The school didn't follow up with us.
3 The school wasn't -- it is a lot of work. Now
4 that we have done it, it is a lot of work for the
5 school.
6 So, the school was giving us drawback
7 from it. And so, that is when we ultimately
8 reached out to the school district, and then we
9 were able to make it happen quickly.
10 Q. Changing subjects, earlier, much
11 earlier in the deposition when I was asking you
12 about money that the family has had to spend out
13 of pocket regarding Easton since his accident,
14 you asked for clarification whether I was talking
15 about just medical expenses, and at that time I
16 was.
17 I want to circle back now and ask you,
18 other than for medical expenses or medication,
19 has the family spent its own personal finances
20 for Easton's recovery in any way?
21 A. Yes. His training with Brogan Secrist
22 is something that we have been paying for.
23 Q. Okay. And how much does Mr. Secrist's
24 work with Easton cost the family?
282
1 A. I don't know. Jace has that
2 information.
3 Q. Okay. Other than Easton's work with
4 Brogan Secrist, has the family spent other moneys
5 out of pocket as part of Easton's recovery from
6 his injuries?
7 A. I mean, we have boughten him like work
8 books to try to help his brain. He have boughten
9 something like -- we've boughten stuff to try
10 to -- like baseball stuff to try to help him
11 develop that, to develop where he was before, to
12 help him from his injury.
13 I mean, there's -- we are trying to do
14 everything that we can that we have had to
15 financially cover.
16 Q. And when you say "baseball," you have
17 purchased baseball things for Easton, what types
18 of things have you purchased to help him along in
19 his baseball skills?
20 A. Various tees, various nets. It's --
21 it's not my expertise.
22 Q. Okay. And then, at very outset of the
23 deposition, you said that you had some personal
24 notes in front of you to make sure that you got
283
1 to say everything that you wanted to say.
2 As you review those personal notes now,
3 have you gotten to say everything that you wanted
4 to remind yourself to say during this deposition?
5 MR. FULGINITI: Object to
6 the form. You are not asking her if
7 there is anything else that she wants
8 to say in the deposition; you are
9 asking her if there is anything else
10 that is on the notes that you -- that
11 she hasn't said?
12 MR. BLUTH: Correct, the
13 notes.
14 THE WITNESS: I mean, I'm
15 feeling very overwhelmed by this whole
16 situation.
17 So, I definitely have not
18 expressed in the way I would have liked
19 to, but I -- it's been a lot, and I
20 have done the best that I can.
21 BY MR. BLUTH:
22 Q. I'm sure you have, ma'am. And, again,
23 we will ask you to send a copy of those notes to
24 Mr. Fulginiti, and we will make a formal request
284
1 of him for those notes.
2 But without -- I'm not asking you to
3 repeat anything that you have already said, but
4 are there subject matters on your list of notes
5 that we have not talked about in this deposition,
6 regardless of how you were able to express your
7 answers?
8 A. No.
9 MR. BLUTH: Okay. Those are
10 all my questions. Thank you very much
11 again.
12 MR. FULGINITI: No
13 questions.
14 THE VIDEOGRAPHER: 5:26,
15 this is the conclusion of the video.
16
17 - - - - - - - -
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1 C E R T I F I C A T I O N
4 I, KATHLEEN MURTAUGH, Registered
5 Professional Reporter and Notary Public, do
6 hereby certify that the foregoing is a true and
7 accurate transcript of the stenographic notes
8 taken by me in the aforementioned matter.
10
11
12
13
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15
16
17 DATED: 10/28/24 _________________________
18 KATHLEEN MURTAUGH
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297
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a.m 1:19 5:9,17 75:5,6 ad 272:20 alter 215:7
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254:4,8,10 addition 138:21 228:19 232:2 amazing 257:10
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106:4 147:20,20 223:17 additional 55:17 81:7 105:13 amount 181:18
224:6 231:17 232:9 233:10 119:23 178:13,18 181:6 analogy 228:7
233:13,18 254:1,13 269:5 220:1 anger 225:5 227:13
281:9 284:6 address 12:20,23 22:22 23:1 Angie 99:6,9
absolutely 167:7 183:23 78:4 119:19 179:11 annual 28:22
228:16 257:7 adenoid 33:13 answer 10:18,21 11:9 12:3,4
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281:13 aforementioned 285:8 206:12,16,22 207:1,8
accommodation 130:21 afraid 106:14 230:10 208:18,19,21 215:19 218:19
220:15 aftermath 76:11 219:14 224:24 234:5 240:5
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217:24 220:6,9,21 226:18 ages 34:7 251:4 252:11 253:6,8
226:21 agility 126:23 257:19 259:17 260:3 269:11
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42:23 101:23 155:1 agree 155:12,19 161:6 167:2 202:19 204:3 250:18
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273:15 alleviate 212:8 213:4 248:19 anybody 42:22 54:17 63:9
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272:11,14 273:7,22 allowed 53:13 169:20 206:21 anymore 229:6 252:4,9
actual 148:23 256:20 268:4 220:12 229:21 anyplace 88:7
298
anyway 62:23 153:17 161:24 226:16 230:1 241:21 244:13 35:11,14 37:10,15 41:22
anyways 128:14 271:11 274:9 281:14 43:2,8 56:18,23 57:4,12,15
apart 150:15,18 asking 31:2 36:3 64:8,11 93:4 57:20 59:11,19,23 60:5,18
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apparently 190:3 171:1 172:6,21,23 173:3 68:10,13 72:3 82:13 83:2
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appears 204:15 227:1 231:16 248:7 271:4 146:9 167:1,6 187:12 188:5
apply 170:19 273:4 280:11,16 281:11 215:14,20 216:15 228:11
applying 268:21 283:6,9 284:2 229:2 250:1,11 261:20
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117:17 120:21 125:21 asleep 37:13,13,15 41:14 42:6 Austin 147:11 155:12,15
142:18 162:1,3,5,8,16 163:9 42:19 202:15 authored 137:2,21
163:18,24 178:23 181:3,8 aspect 229:11 available 189:10
181:11 183:4,10,12,14 aspirations 229:4 277:5 average 233:20
184:10 186:4 187:19 195:5 278:1,7 Avery 53:15 54:12 55:24
200:14 201:1,17 211:1 assessment 115:10,14 119:12 56:5,9 57:17
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242:19,20,22 243:2 244:17 181:13 avoid 145:13 230:21 231:1
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approval 199:13 attached 3:12 4:11 26:15 78:15 79:12 90:3,11 97:9,22
approximately 55:5,19 27:6,13 44:22 186:13 98:9,20 99:7 107:19 126:18
April 146:18 186:5 188:6 attack 140:13,18,24 141:6,18 152:19,22 155:10,12,20,22
190:13 191:4,9,13,19 193:9 141:20,22 142:3,8 143:15 155:23 160:13 161:12,19
194:10 196:1 143:22 144:2,15,18 178:24 181:20 183:16
area 84:19 214:16 220:12 attain 18:19,22 187:12 189:1 207:21 209:14
areas 164:6 222:9 279:11 attained 17:14 217:1,2 223:15 224:4 226:2
argue 64:12 attend 18:13 137:15 174:16 237:17 241:3 244:8 266:7
arguing 48:14 192:24 274:14 274:24 275:24 278:13
Arizona 84:17,18 attendant 20:10 281:17
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arrived 78:21 82:24 83:12 attends 274:13 bad 79:8 222:22
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ASAP 158:16 159:11 Attorneys 2:6,15,20 ball 181:19,20 273:13,21
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299
baseball 1:9 2:15 5:24 6:17 241:2 249:2 255:18 262:19 162:22 163:20 167:8 168:1
8:17 131:23 132:3,7,12,14 266:17 274:23 168:17 169:14 170:5 171:10
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225:8 228:24 229:1,4 240:9 Bernadino 52:22 53:8,12,17 189:14,23 190:7 191:11
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based 64:21 144:20 228:20 beyond 34:20 221:23 219:21 225:15 227:3,7
baseline 175:4 177:11 178:2 bi-monthly 139:4,5 232:13,17 233:1 234:7
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beginning 36:13 103:20 8:12,15 14:5,9 17:5,9,11 bone 80:9 90:3,15 91:7 92:8
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227:10 58:20 59:6 63:6,15,19 64:2 book 216:20,21
Behavioral 138:10,14 192:7 64:6,18 65:17,22 80:17,21 books 282:8
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behaviors 224:16 225:1 118:15,20 121:18 122:2,9 Bosu 181:19
228:19 122:12,16 123:5,11,19,21 bothers 249:22
believe 18:20 20:7 27:10,15 124:4,8,13,16,17 125:3 bottom 43:18 45:6 143:19
32:24 36:12 37:4 46:5 60:6 129:5,22 133:2 134:8,21 144:8
87:21 100:17 106:1 114:5 135:9 141:19 142:13,20 bought 47:14,15
120:10,13 125:23 166:12 143:3,10 146:2 147:2,23 boughten 282:7,8,9
175:16 181:5 182:16 187:12 149:11,14,18 150:2 152:21 boy 136:9
192:16 193:13 203:20 204:2 154:8,16 156:16 157:13,16 boys 65:16 72:15 203:9
204:18 209:22 218:1 239:16 159:8,16 160:1,19 162:18 221:12
300
brain 80:10 93:1 188:24 bunk 43:9,13,14,17,18,22,24 catch-up 221:21
212:20 213:5,9,17,20 214:2 44:1,4,6,9,10,22 45:2,11 categories 166:7
214:9 228:2,3,4,4,10 229:13 53:11,16 57:13 72:23 73:5 causation 50:20 51:2
229:15,19 233:16,17,19,23 76:15 222:8 cause 252:17
234:2 246:21 258:22 259:15 burn 83:23 caused 246:13
282:8 business 29:9,12 135:19 Cedar 19:9,10
Brandon 184:6,12 278:10,14 busy 108:9 center 2:18 19:2 31:23 82:24
break 11:5,8,10 58:18 59:8 193:1 194:7 195:2,10,16
94:13,13,23 149:10,20 C 197:14 257:8
155:21,24 156:4 160:7,15 C 2:1 77:24 78:1 285:1,1 certain 202:3 256:4
175:18,22 212:20 213:5,10 calculus 263:14 certainly 47:10
213:17,21 214:2,9 229:15 calendar 25:9 certification 5:3
229:18,19,20,22 234:2 call 21:15 68:8,14,15,16,18 certifications 18:23
247:14,17 261:3 264:14 72:1,19,21 73:2,7,8,18 certify 285:6
breaks 13:18 83:19 229:13 74:21 75:15 76:6 77:11,15 challenges 50:23
233:16,17,19,23 78:16,20 79:4,9,10 81:8,14 championship 275:9,11,13
breathing 83:22 142:5 81:20 87:19 152:23 153:1 275:13
Brian 2:8 8:15 48:16 50:5 153:10,12,13,14 165:7 chance 81:17 82:1 86:20 87:9
brick 227:19 228:1,9 190:8 200:24 264:1,3 88:5,23 91:10 257:1
Bridge 180:6,9,20,24 181:24 called 30:2 57:21 74:11,14,15 chances 258:7
broad 169:6 74:17 78:13,13 80:6 126:5 change 50:8 237:6 263:1,4
Brogan 16:6,14,20 39:16 126:22 151:23 189:24 266:24,24 267:2,4
43:23 45:14,17,19 46:18 190:10,20 changed 116:17 221:5 225:2
47:14 48:4 51:18 52:1,6 calling 155:15 180:15 225:3 234:13
71:2,6 97:7,13,16 106:9,11 calls 58:7 59:10,16,20,24 changes 224:15 227:9 266:23
107:21 108:2,16 182:19,20 60:14 62:18 65:4 67:2,3,12 Changing 281:10
184:19 193:19,22 194:3 67:17 84:23 212:20 channel 87:13
201:24 276:8,11,12 281:21 camera 175:19 charge 20:18 21:13
282:4 campus 64:16,17 239:18 chart 190:14
Brogan's 46:7 48:23 49:1,2 Canyon 274:12,14,16 275:7 check 37:3 79:10 158:7 202:1
49:10 60:20 184:17 275:19,20 242:1
broke 33:23 car 71:19 83:7 102:7 checklist 3:15 162:10 164:7
broken 33:19 34:3,6,9 46:7 cards 140:8,9 164:23
49:2,2 262:13 care 12:13 24:18 25:10 27:19 child 16:6,10 33:5 37:3 47:11
brother 71:2 84:10,23 225:7 30:3,7,15,18,20,22,24 31:3 50:19,24 51:8 158:7 202:1
225:12 228:16,17 31:5,9,13,16,17 32:9 83:15 child's 46:10 47:10 50:7
brother's 47:22 228:19 95:9,17 102:21 105:19 childbirth 32:13
brother-in-law 84:6,7 88:1 107:24 109:10 115:18 121:2 childhood 32:16,17
brothers 87:1 152:12 158:1 182:7 184:13 children 15:22 17:1 19:16
brought 8:18 187:19 200:9,22,23 230:19 108:11 203:17
brushing 237:4 232:21 233:2 237:9 239:15 Children's 101:21 104:3,24
Bs 217:7 240:15 241:18,20 245:1,12 105:9,20 107:5,12 108:15
buddies 221:7 253:4,10,13 245:19 259:6 268:13 109:7,15 110:2 111:8,24
Building 117:21 career 277:4 278:6 112:10,20 145:5 239:7,19
builds 217:12 caring 82:11 107:20 108:8 242:2,3,21,23 243:1 258:6
built 266:17 110:1 278:13
bullying 43:6 case 5:21 41:14 42:6,20 46:16 choices 235:14
bump 96:21 101:13 214:13 47:7,12 50:8 261:9 choose 133:6 140:16
214:15,18,21 215:6,7,11 cases 47:18 chores 231:6,9,17,20,22
216:6 catch 157:3 232:1 233:9,14
301
Christ 234:11 college 17:16 18:4,4 19:3 231:17 232:9 233:10,13
Christmas 155:21,24 156:4 262:1 278:4 279:21,24 237:7
church 74:12 223:12 234:9 Columbus 16:24 completed 105:15 162:10
234:11,12,14,18 235:15 coma 80:10 182:16 203:2
236:10 265:8 273:13,21 combination 276:18 completely 121:8 221:5
circle 281:17 combine 233:15 completes 231:9,11
circumstances 112:19 173:9 come 12:14 60:20,24 77:12 complex 31:23 35:17 59:17
229:14 230:3 249:18 77:18 88:21 89:15 91:18 66:23 68:2 76:3 127:12
City 19:9,10 107:5,22 113:16 92:2 98:6 106:4 145:16 complications 32:8
239:20 176:21 189:5 190:23 200:24 compound 116:18,21
claim 171:8 216:3 224:13,13 comprehend 87:24
Clara 71:18 comes 49:12 55:12 comprise 29:2
clarification 22:4 36:6 86:4 comfortable 135:23 198:5 computer 160:8
271:15 281:14 220:17 concentrating 166:22 172:13
clarify 9:23 21:16 185:6 coming 47:24 65:15 106:10 concept 217:12
clarifying 244:15,18 208:19 266:22 concepts 219:19 221:1
class 216:20 218:3,4,23,23 commencing 1:19 concern 72:22 96:13,16,20
219:8 220:7 255:20,23 comment 41:12 51:20 86:20 97:1,5 101:9,11,13,16,18
263:13 265:7,8 266:15 87:8 144:23 180:23 103:24 121:13,21,22 122:19
267:7,9 268:4 comments 50:15 122:23 123:13,13,14 125:7
classes 18:14,15 216:17,18,20 Commerce 2:4 237:17 238:4
218:10,17 219:3 220:4 common 1:1 5:19 92:15 concerned 42:11 96:5,12
223:14 226:10,14 262:2,24 communicate 21:14 146:11 102:20 112:22 224:8 252:22
263:2,4,6,8 264:4,9,18,20 communicated 81:20 82:21 concerns 57:12,16 124:20,23
264:22,24 265:5 266:24 86:21 87:17 90:20 91:19 concluded 177:11 178:1
classmates 43:6 249:21 270:3,6 conclusion 69:15 179:9
cleaning 232:3,6 communicating 64:22,24 284:15
cleans 231:23 communication 86:16 186:11 concussion 34:15 45:17 49:1
clear 10:2 45:19 63:8 76:1 188:4 49:22 52:4,7,18
132:2,6 142:14 147:22 Community 30:3,7,20 31:17 concussions 46:7
148:7 239:5 261:13 company 179:12 condition 45:20 51:19 78:8
cleared 120:3 129:3 131:23 comparative 45:24 46:2 78:12 79:15,24 80:5 85:4
132:12 133:11 134:17,23 compare 204:24 173:6 257:13,16
145:17 146:4,6,22 147:7,10 compared 204:8 206:5,17 conditions 48:6
147:13 148:1,13,14 157:6,9 215:13,20 221:21 conference 10:9 58:15
157:11 comparison's 50:4 CONFERENCING 1:18
clearing 146:12 compete 279:23 confidence 222:3 223:19
client 49:18 competing 254:20,21 confirm 42:15 88:1 150:23
Clinic 3:23 4:14 154:13 competitive 257:5 confusing 12:7 157:12
159:22 complain 104:15 211:20 connect 195:14 197:17
Clinical 119:11,16 181:13 complained 168:5 238:24 connected 102:8 197:15
clipboard 203:3 241:6 243:16 199:21 211:18
close 107:17 149:7 159:19 complaining 238:11 connecting 197:3 207:21
262:22 complains 212:2 connection 58:14 180:19
co-host 209:23 complaint 151:13,15 consider 145:18
coach 56:7 141:11 complaints 104:11,20 142:1 consideration 165:16
coaches 56:3 69:13 153:24 238:17 240:2,12 consisted 99:4
cognition 126:13 241:15,22 243:7 245:3,13 consistent 10:23 21:1 153:19
cognitive 223:5 245:23 246:11,12 154:1 189:15
COLEMAN 2:12 complete 10:11 123:7 182:14 CONT 4:2
302
contact 102:14 145:13,17,18 239:2 241:8 243:3,9,13 254:8,9 255:6
197:4 198:19 246:24 252:5 254:10 255:15 currently 23:7 126:8 197:1
context 147:14 171:14 174:13 256:5 274:3 283:12 curriculum 219:17
contingent 70:17 corrected 17:10 90:7 171:20 Curt 77:22,23
continue 11:21 69:4 95:8,17 correctly 193:20 203:24 Curtis 2:18
119:19 128:16 158:11 219:24 222:2 236:22 241:5 customer 20:11
176:24 182:20 211:9 215:24 Correspondence 3:17 cut 68:11 85:11 273:20
238:9 257:12 261:3 cost 103:14,19 281:24 cuts 276:2
continued 19:9 119:18 counsel 5:1 6:4,13 162:21 cutting 122:12
157:17 175:3 209:16 169:4 179:9
continuing 138:24 267:5 counseling 111:19,23 112:14 D
continuously 19:18 114:3,5,14 135:12,15,16 D 3:1
Contract 1:10 2:21 261:8 136:3,19,21,24 137:4,8,24 d/b/a 1:10 2:20
contradict 172:1 138:2,6,20,21 139:3,12,15 dad 42:14 70:12 107:23
contributing 218:1 139:24 144:4 158:16,18 131:22 132:11 188:8 190:20
contribution 30:21 159:11,14 195:1,9,15 197:6 daily 119:6 237:4
control 187:5 197:13,18,20,24 198:4,9 damages-type 51:2
controversy 45:20 199:7 211:10,16 276:11 Danville 83:6
conversation 9:17 54:21 55:4 counselor 204:13 206:1 dark 212:20 214:3,7 248:13
55:12,19 56:11 61:5 68:19 count 125:1 279:21 249:12
68:21 75:3,11 76:13 77:1 counting 184:16 Dash 53:15,18 54:3,12,22
95:10,13,14,21 96:1,7,9 County 1:1 5:20 55:7,24 56:5,9 57:17
115:13 142:8,12 143:7,8 couple 8:23 107:19 138:9 Dash's 53:20,23
conversations 55:16 57:9 261:12 279:10 date 14:21 15:4 16:3,8 39:9
67:24 80:13 91:22,24 93:6 course 9:16 23:19 25:9 27:22 41:7 97:14 113:18 119:7,11
94:10 95:18 225:18 105:19 111:4 258:21 260:14 132:11 144:17 160:24 188:6
convicted 23:13 court 1:1,21 5:13,19 6:6,7,9 193:8,9,13 200:2
convulsing 151:24 7:2,10,22 8:1 9:3,13 10:24 dated 3:13,16,17,19,20,24
cool 67:20 72:13 58:13,24 59:1,8 93:19,21 4:15,18,23 37:21 117:13
cooperation 260:13 94:2 99:22 121:24 122:4,8 154:14 159:23 160:3,22
coordination 240:8 241:7,16 123:1,10 124:9 154:11 173:18 179:18 199:24
243:8,18 244:3,22 245:4 173:14,23 174:2 175:24 201:11 285:17
246:1 179:8 201:6 207:18 208:6 dates 128:4,8
copy 131:9,14 204:8 205:1,10 208:15 210:2,10,13,17 daughter 14:17 16:11 52:9
283:23 232:11,15,19,23 265:12,15 99:14
core 216:17 263:6,8 264:4,9 265:19 270:12 273:17,24 day 16:24 17:1,4,8 38:17
264:18,22,23 Courtyard 22:15,23 39:19 51:11 56:20 60:3,8,12
corporate 21:20 cousins 99:14,24 100:1,5 62:1 63:1 64:23 65:1 72:9
correct 15:23 20:9 33:9,11 cover 199:12 282:15 75:2 82:13,14 89:5,13 91:16
56:24 59:17 62:19 65:2 covered 30:19 31:16 47:20 106:2,3 108:14 109:8 153:4
80:17 82:18 99:3 101:15 182:17 165:22,22 166:24 167:1
102:19 111:14 123:19 131:5 covering 248:24 249:3 218:8 234:11 247:24 279:3
131:18 136:23 137:1 138:3 CPR 28:1,4,6,7,11 days 100:5,7 107:19 113:9
138:17 141:13 145:6 147:16 creating 269:8 153:2 154:23 155:8 165:17
148:16 154:12 156:24 credentials 127:17 245:13 165:20 166:3,9,19 168:4,7
157:18,20 158:13 167:14,14 credits 18:18 170:2 171:18 172:7,10
168:21,22 169:21 171:19 crime 23:13 187:6 269:6
172:16 183:22,24 186:5 Crimson 197:19 276:11 deadlines 220:3
203:13 213:14 220:4,5 Curran 260:6 deal 90:1
227:3 231:8 234:9 236:11 current 12:20 35:7 220:22 dealerships 102:7
303
dealing 8:20 50:23 100:18 101:12 108:17 119:7 disagree 117:15,18
December 32:22 39:10 41:18 140:2,5,19 142:22,24 144:2 discharge 25:11 95:12,16
125:17 126:1 130:4,9 144:5 145:10 151:21 171:16 96:2 98:14 99:3,12 107:2
131:21,21 132:7,13 133:9 182:3 203:14 214:10 217:24 108:14 113:9 145:4 176:13
133:19 155:12,20 156:1,5 220:1 229:12 231:4 233:22 242:13,24
157:5,21 158:22 159:7,12 237:11 241:8,16 243:17 discharged 24:10 25:4,6
decided 50:13 234:19 250:13 256:3 92:10,20 101:7 105:8,20,23
decisions 235:18 describes 250:2 109:6,8 110:16 111:8,17
decline 279:18 describing 66:18 69:18 73:19 114:3 118:8 120:8 174:9
deep 219:18 74:17 87:6 98:6 167:11 175:12 176:8 200:9,21
defendant 2:15,20 261:9 172:5 221:22 243:5 239:6 258:6
Defendants 1:11 description 3:12 4:11 213:19 discharging 200:23
deficiencies 258:11 228:7 discomfort 104:12,16 211:21
deficits 119:20 designed 92:17 212:1
definitely 283:17 desk 20:3,10 discontinue 120:6 125:22
definition 185:20 detail 50:3 129:17
degree 31:17 89:17 details 11:24 62:21 75:15 discontinued 120:8 129:1
degrees 17:14 18:22 76:10,18 135:3 Discovery 47:21 51:3,12
delay 220:24 246:5,13 determine 104:10 65:19
delays 227:17 determined 112:2 discrepancy 133:6
delivery 32:12 develop 258:8,19 259:11 discuss 68:17 90:12 92:22
demanding 222:13,14 282:11,11 discussed 60:17 61:20 72:6
dementia 224:11,13 258:9,16 developed 104:4 111:5 77:5,10 79:3 140:3,15
258:20 259:12,15 developing 104:14 125:8 143:16 157:4,8,10
demographics 47:20 device 203:1 discussing 59:10 69:3
DENNEHEY 2:12 diagnosis 189:3 discussion 39:1 134:14
depend 172:2 difference 73:16 216:13 149:22 165:2 187:10 210:19
dependent 214:4 231:10 265:23
depends 169:3 171:22,23 different 45:5 97:2 100:22 discussions 55:6 57:12 64:20
deponent 6:3 104:12 108:7 128:17 145:9 69:24 82:15 84:23 112:12
deposition 1:4,15 5:10,15,18 171:5,6,11 173:8 180:15 258:4
6:2,19 8:24 9:1,2,11 11:21 186:23 190:17 191:2,8,14 disease 110:5,10,17,21
14:7 15:16 23:19 25:24 191:20 195:14 219:9,11 dishes 232:5
26:3,8,10,15,17 27:6,14 231:19,21 245:19 267:12,14 dishwasher 232:4
51:4,12 56:17 61:17 66:19 268:4 272:16,17 dispute 132:9
137:14,16 163:4,6 179:10 differentiating 148:8 disrespect 9:24
186:14 213:14 214:13 216:7 differently 204:3 distress 47:2
222:16 253:23 281:11 difficult 24:21,23 83:18 district 280:4,5 281:8
282:23 283:4,8 284:5 135:16 280:8 dive 50:2
Derek 84:9,16,23 88:1 97:19 difficulty 37:11 38:17,17 Dixie 278:15,15
98:6,14 99:4,7,8 106:7 39:22 41:13 42:5,19 43:2 Doc 119:7
Derek's 99:6,14,14 58:12 166:22,22 172:13,13 doctor 27:20 33:5 35:22,24
derive 29:6 264:7 36:8 37:7 109:10,22 110:4,6
describe 14:1 32:16 44:11,21 diminished 257:5 110:10,17,21 111:3 127:14
60:16 68:24 72:22 73:3 diploma 17:15 18:1,2 142:23 153:4,6,7,9 158:2,4
75:11 76:9 78:19 80:12 direction 189:19 171:3 187:19 190:17 191:2
83:20 106:2 112:18 213:16 directly 67:17 68:1 69:13 191:8,14,20,22 230:19
214:22 225:21 82:16 269:20 240:19,21 241:1 243:2,7,12
described 33:13 45:5 61:13 dirt 252:16 253:1 258:17 268:13
66:18 70:10 72:11,13 97:3 disadvantage 217:19 279:23 doctor's 142:18 239:13
304
244:17 258:10 268:11 159:7,10 160:2,22 164:10 32:12,17,20,22 33:14,17,21
doctors 27:18 33:7 36:19 164:17 180:19 186:4,9,9,12 34:4,8,11,14,19,23 35:4,10
80:14 81:24 82:16 85:6,15 186:19,22 187:3,7,10,21,22 35:14,14,20,23 36:8,20 37:1
85:20 86:16 88:4,23 89:5 188:5 189:2,7,17 190:4,9 37:6,14 38:16,16 39:6,8,13
92:1 94:11 101:9,15 105:4 191:10,13 195:18,22 196:24 41:17,20 42:5,18,23 43:2,5
109:8,24 154:3 158:5 216:9 197:4,16 199:21,23 200:2,6 43:9,12,16 44:3,9 48:3
224:10 200:9,14,22,22 201:17 53:22 55:13 57:6 58:1,8
document 202:11 206:4 202:3 211:2,10,13,15 59:12,16,20 60:2 61:8 62:7
208:14 237:16,24 238:10 240:17,17 62:23 64:7 65:9 67:3,6,13
documents 14:13 25:23 258:18,24 259:9,17 268:14 67:16,24 68:8 71:6 72:18,20
206:18 268:18,20,22 269:3,4,7,15 74:6,9 76:15 77:3,8 78:13
dog 232:10,22 233:2,3,5 269:19,20 270:11,15 78:15,21 79:11,22 81:17
doing 40:19 60:22 61:8 62:9 draw 120:24 82:11,19 83:13 84:4,21 85:2
79:11 82:20 91:3 126:8 drawback 281:6 87:2,8 88:8,21 89:16 90:13
156:14,18 158:12 163:14,19 drawer 45:9 90:20,24 91:2,7,16,20 92:7
164:2 165:20,24 166:8 drawers 45:6 92:10,16,19,24 95:5,8,15,20
187:13 199:3 202:4 219:11 draws 104:9 118:12 95:22 96:5 97:10 98:3
220:18 231:21 232:1 234:18 dream 67:19 100:6 101:7,19,23 102:10
donated 103:4 dressed 237:4 103:15 104:2,11 105:3,8,12
donation 103:5 drive 278:2,2 106:3,12,13,18 107:7,12,13
door 52:14 driving 77:2 107:22 108:9,16 109:6,11
dorm 62:14 65:9 66:23 72:23 dropped 58:24 209:2 109:14 110:1,8,8,15,17,20
dormitories 53:7 57:17 drove 83:7 106:7,8 111:1,1,6,16,23 112:8,9,13
dormitory 65:15 drugs 23:8 112:16,19 113:7,15 114:2,8
dose 187:4,10,16 due 76:13 96:22 228:17 246:4 114:10,14 115:9 116:5
doubt 277:12,20 duration 152:9 117:19 118:6,9 119:24
Dr 35:8,19,22 36:1,4,10,14 duties 20:12,21 120:8,21 121:3,12 125:17
36:22 37:2 38:6,8,21 39:1,2 125:21,22 126:17 127:2,6,9
39:5,9,22 40:3 41:6,9,18 E 127:17,23 128:1,5,15 129:3
42:4,18 82:3,4 85:19,19 E 2:1,1,9,22,22 3:1,10 4:7 129:17,24 130:3,9,14,15,20
86:8,8,22 89:8,12,16,20 285:1 130:23 131:16,17,22 132:2
90:12,19,24 91:9,14,15,19 e-mail 179:8,11 132:6,19 133:11,21 134:1
91:24 92:6,12,12,22 93:6,7 E.O 1:4 5:21 134:11,17,23 135:17,20,22
93:13 95:11,19,19 96:1,18 ear 38:7 136:2,8,23 137:3,7,24
96:18,19 97:2,2,3 101:14,14 earlier 73:21 74:12 89:9 138:16,21 139:2,14,19,24
104:8 109:9,9,10,11,14,18 114:8 115:8 121:1 125:20 140:2,5,15,19,23 141:16,21
109:21 112:12,12 116:5 129:7 134:22 144:24 145:10 142:2,8,12,17,22,24 143:16
117:3 120:4,7,10,14 125:18 156:20 180:18 182:3 189:16 143:17,22,24 144:2,4,7,15
125:21,24 128:15,21 129:3 197:23 201:16 229:12 145:4,13,17 146:4,7,12,22
129:7,16,23 130:8 131:23 233:22 236:1 243:6 281:10 147:13 148:1,4,7,13,14,18
132:2,6,10,12 133:11,20 281:11 150:4,6 151:10,20 153:3,8
134:17,23 135:11 138:7,12 early 100:3 161:12,16 237:18 153:18,22 154:4,5 155:1,19
138:15,19,20 139:1,3,12,15 240:16 258:16 156:1,1,5 157:1,5,17 159:11
139:20,24 140:6,7,11,12,15 earn 255:21 159:15 161:3,7,10,19,23,24
140:19 143:8,17,22 144:3 easier 8:24 162:11,19 163:8,14,18,19
145:6,12 146:1,3,6,11,17 easily 227:11,14 228:13 164:1,2,11,18,20 165:3,9,12
147:7,10,12,22,24 148:7,12 Eastern 5:9 73:9 74:2 165:20 166:6,13 167:11,14
148:14 151:4 153:17,18 Easton 16:1,18 18:16 19:19 167:21,22,23 168:4,6,8,10
154:5,20,24 155:10 157:18 19:21 24:1,10,19 25:3,6 168:15,19,24 169:19,20,22
157:20,22,23 158:1,6,23 29:15 30:5 31:12,16,22 32:7 170:21 171:2,16,23 172:6
305
172:15,18,21,23 173:3,6 81:9,14,24 82:14,16 84:4 employment 28:8
174:17,23 175:12 176:7 85:4,15 86:16 88:4,12,14 emptying 232:4
178:12,17,22 179:24 180:6 89:4,10,19,24 91:10 92:13 EMT 28:1
180:10,23 181:17 182:10,14 95:11 96:2,12,14,21 98:9,13 enables 217:17
182:23 183:13,15,20,24 98:17,18,21,24 99:2,3,11,13 encountered 280:8
184:12 185:15,22 186:7,15 100:1 101:9,13 102:21 encouraged 180:6,24
187:15 188:14,22 192:6,10 103:1,7 104:23 105:18 ended 96:7 122:21 125:7
193:1,21 194:7,17,18 195:5 107:2 108:14 111:20 116:4 164:22 275:6
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198:3,5,6,8,9,14 199:2,6,8 125:5 128:23 133:12 134:15 English 264:2,3
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201:23 202:3,7,14,18 203:5 151:13 152:3 154:3,19 ENT 38:7
203:6,21 204:3 206:5 207:3 156:20 157:22 161:17 163:5 entering 130:14
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212:4,7,16,23 213:4,7,16,20 179:22 181:2,7 182:7 183:5 entities 261:8
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217:12 218:16 219:3,7 201:16 213:13 215:8,23 entity 102:2 103:8
220:9,14,21,23 221:19 216:7,8,13 217:24 221:23 entries 24:21 25:3,8
222:6,10 223:18 224:17 224:16 226:2 227:10 234:12 environment 219:11 222:1
225:10,19,21 226:3,4,13,13 235:16 237:3 242:7 246:9 epidural 80:8 92:16
226:20,22 228:13,15,20 248:2 254:4 258:5,14 259:6 episode 140:19
229:12,14,22 230:2,14,21 262:13,24 268:21 269:21,22 equipment 65:16 72:13
231:1,4,9,16 232:1,7 233:3 274:10 275:16 277:4 280:20 Eric 99:17 100:2,15,17
233:10,16,19,23 234:8,16 281:20 282:3,5 Erika 188:16,17,20
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240:2,11,14,20 241:5,15,21 education 17:12,14,24 19:2 ESPN 61:6 62:9,10 72:8
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exam 114:23 115:24 117:2,4 express 101:17 284:6 107:8 108:3,8,10,13 135:11
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excitement 57:10,23 eye 214:14 239:15 240:15,18 father-in-law 71:10
excuse 56:4 130:7 133:10 240:20 241:1,5,11,18,20 fathom 225:14
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exhibit 126:5 137:14,23 245:1,12,19 259:5 February 162:1 169:13 172:5
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Exhibit-116 125:13 286:1 F feeding 91:2
Exhibit-119 162:9 287:1 F 285:1 feel 144:9 151:8 167:24 198:5
Exhibit-122 188:1 288:1 face 151:9,14 215:1,3,8 214:5 222:22 246:3
Exhibit-126 202:10 289:1 FaceTime 58:7 59:10,20,24 feeling 25:10 143:18 151:17
Exhibit-130 37:18,22 290:1 60:14 62:18,20,24 64:20 166:23 167:6 171:18 172:11
Exhibit-131 118:19 291:1 65:4 67:3,8 68:14 172:14 283:15
Exhibit-132 154:10,15 292:1 FaceTimed 57:22 96:11 feelings 24:15,24 136:11
Exhibit-133 159:21,24 FaceTimes 58:4 feels 166:24,24 171:24 172:1
160:21 293:1 facility 45:12 53:8,12,17 221:7 229:17,18
Exhibit-134 173:19 294:1 54:19 55:8 57:6 62:9 195:7 feet 44:19
Exhibit-135 179:6 295:1 239:14 fell 37:13 52:14 54:3,4
Exhibit-136 201:13 296:1 fact 87:20 98:7 150:24 felt 135:23 142:4 151:8
exhibits 26:9,15 137:20 179:8 151:21 167:22,23 173:3 195:6,11
exists 137:11 factor 47:8 220:17 225:10,17,19
expect 215:24 216:9 218:12 facts 12:10 144:21 field 18:6,9 28:1 67:21
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expected 95:19 fair 24:8 146:20 172:19 fighting 80:10
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expense 102:24 fairly 213:19 file 51:9
expenses 281:15,18 fairness 205:11 filing 5:2
experience 58:2 127:17 fall 53:15,18,21 54:2,19,22 fill 172:9 202:24 203:15,18
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experiences 50:19 172:15 271:20,21 273:12,21 274:5 207:13
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experiences' 50:22 fallen 76:15 217:14 Finally 11:23
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expired 28:3 familiar 235:16 find 135:17,22 138:10 221:3
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explaining 140:11 238:14 70:23 87:1,10 99:3,9,18 149:17 169:23 209:6,8,20
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307
finished 75:18 84:1 111:4 182:10 186:24 240:18 281:2 frequently 39:7 139:2 212:4
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fisherman 254:12 128:19 132:22 134:5 141:15 Frustration 144:11
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fit 135:19 162:14,24 163:16 164:8,9 14:8 17:3,7 31:4 45:18 46:1
five 45:2 100:7 140:1 196:5 165:15 166:2,3,6,15,19 47:3,6 48:22 49:9,14 50:5
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fix 222:21 170:23 171:9,14 172:8,9,10 80:15 86:12 93:16,24 94:7
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fly 83:3 84:12 213:1,8 213:22 215:12 218:18
focus 186:15 187:17 188:10 fourth 2:9 217:7,14 219:13 224:20,23 226:23
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focusing 258:1 freeze 265:13 243:24 244:10 245:6 246:15
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functioning 175:5 53:6 58:20 96:23 97:16 gotten 28:6 135:2 215:10,11
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genetic 46:4 267:1,7 271:6 274:21,21 guess 12:2 34:1 49:6 51:22
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geographic 133:4 Goldendoodle 233:4 guesses 103:18
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handle 223:17 healthy 33:6 220:1,8 226:19 267:20
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happiest 67:22 hearing 11:18 47:21 87:8 110:3,16 111:9,17,22
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harder 279:17 helmet 235:9 Hospitality 18:11
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impact 23:8 278:10 injuries 8:19 23:23 24:17 introduce 6:21 261:5
impacted 253:16 254:5 33:18 34:8 35:15 37:10 involved 182:7 223:13
important 9:12 10:5 112:16 44:3 92:23 235:4 282:6 involvement 268:20,23
improved 89:1 injury 26:20 34:12 35:10,13 269:21
improvement 176:23 177:1 41:15,21 42:7,12,20 43:1,8 involves 221:24
improving 89:17 90:13,21 45:15 49:21 52:10,13 54:23 involving 23:22 43:5 90:14
91:1,20 92:8 181:18 221:18 55:1 74:6,10 78:8 82:14 irrelevant 158:21
in-person 139:8 84:21 93:2 106:5 121:14 issue 46:19 190:11 191:3,21
inaccurate 167:13 171:3 125:9 130:17 146:9 147:15 211:17 237:22 244:15
193:13 148:3,20 176:13,19 211:17 issues 32:12,18 34:19 43:5
incident 35:16 54:7,10,14 211:18,21,22 216:15 228:2 48:4 50:24 51:3,21,24
244:14 250:6 228:5 231:12,18,18,21 239:10 246:4 261:12
include 28:1 272:6,7 273:4 234:13 236:24 237:13
included 111:12 246:11,14,21 252:3,23 J
including 11:6 23:14 73:2 254:6 257:6 258:22 259:15 J 2:8
103:14 196:4 278:7 282:12 Jace 1:5 5:22 15:2,7,22 25:14
income 28:23 29:2,3,5,6,13 inner 234:21 235:1,3 25:18,20 28:16,18,19 31:19
incomplete 15:18 inpatient 24:10 25:4,7 88:9 39:16,21 42:15,17,22 56:6,8
incorrect 15:18 137:4 95:9,17 104:3 110:2 112:10 56:17,21 57:4,11,15,20 60:8
increased 47:1,2 48:7 181:18 112:20 113:15,17 114:15 60:11,17 61:5,10,20,23
incredible 57:5 72:17 242:4,10 62:18 63:1 64:20 65:5,13
Independence 2:18 input 203:15 67:4 68:8,17 70:21 71:7
INDEX 4:2 inquired 196:14,23 72:1,5,11,21 73:2,20 74:11
indicate 54:16 inquiries 73:3 74:17,22 75:4,12,21 76:2,9
indicated 39:9 104:13 244:14 inquiry 189:17 77:1,5,9,11,16 78:7,12,13
indication 159:5 inside 45:7 53:13 62:14 78:20 79:3,3,7,8,14,17 80:6
Indigenous 17:3,8 106:24 80:12 81:7,11,13,16,20
individually 203:9 instructed 196:20 200:12 82:21 84:6 86:21 87:4,17
311
96:5,11,11 97:5,6,12,16 keep 152:4 155:15 221:8,17 224:5,7,9,10,12,14 226:16
98:22,23 101:12 102:12,14 221:18,18 263:1 227:18 228:24 229:8 231:4
106:6 107:15,21 112:22 keeping 259:5 231:20 234:8 237:16 238:2
114:24 127:19 130:10 keeps 221:17 241:23 243:6 246:19 251:11
135:17 137:14,15 156:13 Ken 2:3 6:16 8:9 14:5 17:6 257:19 258:11 259:13,14
162:5,7 174:19,21,23 183:9 24:4 49:17 65:17 121:18 261:23 262:6 263:10,16,19
186:21,21 189:16 195:5,13 122:1 123:7 124:3 196:16 263:20,23 265:1,3 266:18
197:4,16,19 224:3 234:8 243:23 270:16,17 267:9 272:5 273:6,18,20
240:23 256:3 269:15,19 Keppra 150:11 153:18,23 277:7 278:20,23 279:4
270:3 282:1 154:5 155:5 161:3,12 282:1
Jace's 26:3,14 27:6,14 29:8 kept 235:18 knowing 6:13
29:11 56:16 71:11 84:10,23Kevin 71:14 knowledge 31:20 32:11 54:12
86:24 107:23,23,24 163:4,6key 14:3 92:15 93:5 104:6 121:8
186:13 kid 167:4 222:4,6,8 141:2 144:14 150:3 179:23
January 155:23 160:22 161:6 kids 39:18 107:18 254:4
jealousy 228:17 kind 83:23 85:6 168:11 known 96:17 168:3 222:5,8
Jesus 234:11 170:17 178:9 180:14 199:15 knows 56:9 190:21 218:12,12
job 20:21,24 238:9 214:4 216:19 217:6,10 Kyle 53:24 56:11
jobs 19:24 21:4 22:5 219:19 221:10,19 271:22
jog 63:21 278:6 L
John 1:9 2:17,20 50:15,21 knew 66:11 75:16 159:5 L 2:22
260:20 261:7,7 266:7 167:12,16 168:20 169:22 lab 27:3 218:6,7,21 226:9
272:13 273:18 277:15 189:16 235:17 268:1,3
John's 51:22 know 10:14 11:3,20 12:3,8,9 labor 32:12
joined 71:6 12:11 15:10,19 24:3 25:14 labs 27:2
journal 23:24 24:2,6,9,14,16 25:17,18,20 28:21 29:17 lacks 217:12 222:3,3 223:19
25:3 30:10 31:12,15,18 32:20 ladder 45:3,5
JR 2:17 33:2 38:8,21,23 39:24 40:1 laid 244:6
July 139:13 42:9 46:6,23 47:18 48:1,5,5 Lake 107:5,22 113:16 239:20
juncture 50:2 48:7,17 56:10 58:23 63:6 landscaping 29:8,11
June 128:12 216:7 274:24 64:15 65:18,21 70:5,9 75:14 language 119:21 175:3
junior 18:21 276:4 75:15,21 76:22 77:23 78:4 263:11,24 264:1 266:20
78:16 80:23 81:19,24 84:18 large 70:17 233:5
K 89:9 92:18 95:13,22 96:4 largely 158:21
K 77:23 99:24 100:4,20,21 102:2 Larry 102:4,5,9,17 103:3
Kaddu 35:8,19,22 36:1,4 103:19,24 106:19 112:15 lasted 152:9
37:2 109:10,11,14 154:20 113:6,18,19 114:24 117:8 late 161:14
155:10 158:1,23 159:7,10 118:6 120:1,7 121:21 laundry 232:4
160:22 186:22 187:21 189:2 126:21 127:20 129:21 130:7 LAW 2:3,7
189:17 258:24 268:14,18 130:8 135:22 137:6,18 lawsuit 8:17 13:6
Kaddu's 158:6 160:2 186:12 144:17 145:11 146:6 156:8 lawyer 8:16 11:6
186:19 187:22 188:5 189:7 156:14 157:23 158:18 lawyers 9:22
190:4,9 191:13 201:17 159:10,13 162:4 164:4 lay 244:11
202:3 211:2 165:19,22 167:19,22 177:18 laying 225:11
Katelyn 99:17 100:3,16,21 177:24 178:7,22,24 180:9 leader 236:6,9
Katelyn's 99:19 183:9 187:1 188:20 189:12 league 1:9 2:15 5:23 6:17
Kathleen 1:16 179:11 285:4 190:1,6,20 193:3 195:3,4 8:17 31:22 35:17 51:6
285:18 196:3 205:11,16 206:9 54:18 56:13 59:17 60:1
Kathy 6:7 7:1 207:22 209:16 214:19 215:23 216:18 217:9 66:23 68:2 71:1 73:4 76:3
209:23 220:14,18 222:13,16 223:20 222:7 225:13 229:4 277:21
312
learn 85:3 143:21 219:18 51:6 54:18 56:13 59:17 281:3,4 283:19
learned 38:22 74:5,9 79:14 60:1 66:23 68:2 70:24 71:2 lots 11:24,24
82:19 84:20 86:24 87:3 73:4,21 76:3 114:8 115:7,7 loudly 123:11
88:22 130:8 217:11 115:8 118:7 129:7 138:14 lounge 87:1
learning 78:7 79:23 80:4 159:18,18 222:7 225:7,13 love 221:11 258:2 278:19
141:22 219:10,15 265:11 228:16,19 233:7 260:18 loves 253:24
266:13 261:18 277:4 low 125:2 187:4,10,16
leave 28:18,19 97:19 live 71:15 78:2 81:18 82:2 lower 217:8
leaving 96:5 84:16 147:21 Luke 2:24 5:12 207:19
left 28:7 33:23 34:18 97:21 living 85:13 237:4
97:23,24 98:2,3,8 106:3 Livingood 2:17 3:6 7:19,23 M
114:15 151:8,9,13,24 152:3 8:3,6,11 40:12,16 46:14 ma'am 7:16 8:13 10:18 11:1
188:8 190:23 257:2 47:4,23 49:5,11 63:17 160:6 12:15 14:12 17:12,20 23:4
leg 181:19 160:12 207:22 208:9,23 38:3 41:3,10 59:7 65:24
length 44:16 209:11 248:14 260:2,17,21 66:10 75:18 76:17 80:22
lengthy 114:19 260:23 261:1,7 262:8,11 84:1 94:12 95:4 116:24
lens 166:5 264:8,14,16 265:2,4 266:1,8 118:22 120:19 123:23 124:5
let's 30:4 49:14 91:14 94:15 266:11 267:19,22 269:17 124:18 125:14 147:3 150:3
208:23 227:8 247:13 278:17 270:7,14,20 271:5,10,16 154:17 155:19 158:8 159:9
278:17 272:2,8,9,23 273:5,19 274:4 160:3,20,24 162:24 171:13
letter 137:2,7,10,13,20 277:17,22 279:1 174:4 176:6 179:15 188:1
level 219:20,22 245:13 Livingood's 50:15 192:22 193:10 202:11
267:14 local 254:13 210:24 247:22 260:5 279:13
levels 245:19 located 22:18 73:10,11,20 283:22
liability 51:15 75:7,22 118:4 203:6 239:15 Maffei 82:3,4,10 85:19 86:8
life 50:22 79:1 80:11 175:6 location 21:19 59:21 117:23 86:22 91:14,15,19 92:6,12
229:9,11 250:10 253:16 127:9,11 133:4 239:18 96:1,18 97:2,2 101:14
life's 249:24 250:6 locations 60:2 main 257:21,22
Life-Flighted 77:3 log 27:2 mainstream 218:16,21 219:3
light 248:4,10,16,18 249:11 long 11:3 29:19 54:24 100:4 major 18:10 32:17 229:4
249:19 152:2 179:10 214:3 261:11 277:21
liked 149:4 283:18 279:3 majority 107:16 162:6
likelihood 258:8 longer 76:21 88:23 161:3,7 making 60:23 61:3 63:7
likes 249:12 253:21 176:9 199:19 209:17 256:4 104:11 162:21 196:3 246:12
Limine 51:23 256:12 Mall 2:18
limit 184:22 195:21 look 26:15 27:21 37:5 49:4 manage 105:14
limited 170:6 110:13 137:22 146:15 management 18:12 20:4,6,14
line 105:3,4,10,14 110:9,24 165:16 179:1 200:13 217:5 20:17,17,21 22:6,7
118:12 121:3,10 122:20 246:19 257:9 manager 21:1,6,10,12,18,24
156:12,21 244:1 246:21 looked 26:6,9,19,22 27:7,16 22:11 28:5 141:11
lines 89:21 224:19 137:19 154:24 235:17 manages 28:14
lingering 259:14 looking 12:10 63:8 129:14 Manufacturing 265:8,10
link 11:19 202:22 266:13 267:3,8
list 231:6 284:4 looks 62:11 180:14 March 128:11 174:5 175:12
listed 141:22 233:9 lost 58:15 199:16,18 207:19 176:8,14 178:12 179:18
listening 6:20 207:24 208:7 180:1 181:7 183:13 184:2
litigation 51:21 lot 30:23 33:4 57:1 75:14 184:10,13 185:17
little 1:9 2:15 5:23 6:17 8:17 76:12 102:6 148:21 162:5 MARGOLIS 2:17
10:7 11:16 31:22 32:3 187:5 199:2 216:22,23 MarJean 71:14
35:17 40:23 47:22,24 48:10 217:8,14,21 249:1 258:13 mark 37:18 118:16 154:9
313
159:20 173:12,15 179:3 112:10 113:20 122:23 187:3 214:12,13 218:15
201:10 124:19 130:14 131:22 220:7 222:24 226:3 238:20
marked 3:12 4:11 37:21 40:8 164:15 177:15 181:17 252:24,24 253:6,22
118:18 125:13 154:14 195:15 242:13 merciful 208:10
159:23 162:9 173:18 179:5 means 156:9 177:10 178:1,8 message 152:23 188:8 189:1
187:24 201:12 202:10 257:20 273:11 met 100:20,21,22 191:9
Market 2:4,13 meant 12:6 21:17,18 114:5 198:10,14,24
marking 201:7 116:12 121:21,22 123:20 Michael 260:6
marriage 15:4 133:8 158:24 189:5 244:16 middle 16:6 105:21 239:7
marriages 15:6 Medicaid 29:24 30:2,9 274:13,15
married 14:23 15:1 99:20 medical 12:13 24:18 26:14,16 midnight 73:19,22
Marriott 22:15,16,23 26:20 27:7,15 28:1,10 30:15 miles 71:21
MARSHALL 2:12 30:24 31:3,5,9,13,15,20,23 Miller 102:4,5,9,17 103:3,15
match 135:17 138:11 148:19 32:4,17 34:19 35:24 36:8,19 mince 185:1
148:23 37:7 41:21 45:20,21 46:11 mind 75:13,13 187:8
matches 148:2,5,8,15 149:3,5 47:10,22 48:6 50:7 51:7 mine 60:20
254:20,22 255:7,20,23 80:14 82:24 93:5 96:14 minor 1:4 5:21
material 219:7,10,16 102:3 103:1,11,16 111:21 minute 74:14,21 160:7
materials 13:6 115:9 117:12 127:13 150:22 minutes 94:20 149:15 152:6
math 218:3,4,6,7,9,21,21 152:12 157:22 163:6 167:12 152:8,10 214:5,10 234:1
219:2,8,22 220:7 226:8,9,14 168:20 177:10 178:1,16 244:20
226:19 263:11,13,15 264:9 183:6,15,19 186:12 188:17 misleading 205:23
268:1,3,4 207:15 211:5,16,17 215:24 missed 74:21 118:1 177:21
maths 268:7 230:15,16 236:18 240:11 misspeak 116:10
matter 7:6 9:8 47:16 87:20 246:6,10 247:1 258:5 misspoke 90:6
263:16 285:8 268:11 281:15,18 mixing 169:5
matters 284:4 medication 150:11 161:8,11 mom 42:14 70:12 107:23
maturing 221:19 161:20 186:15 187:16 188:9 131:22 132:11 189:4,5
McCORMICK 2:7 188:21 212:8,11,17 237:12 190:15
mean 9:21,24 13:15 30:23 281:18 moment 25:1 38:2 40:10 64:8
46:4 47:13,17 49:19 50:17 medications 23:8 30:15 31:3 74:24 93:14 98:20 167:16
51:1,5 62:20 63:20 64:15 31:5,6,10 189:18 225:23 226:2
68:11 70:11,12 80:22 82:7 meet 92:4 199:8 moments 225:19
85:11 93:1 96:4 98:3 meeting 68:20,23 69:1,2,5,8 Monday 1:18 5:16
103:18 106:23 114:11 69:21 72:4 101:3 money 30:14 281:12
123:16 134:20 139:6 142:9 member 43:21 234:10 moneys 282:4
142:11,15 149:4 152:6 members 39:12 99:9 108:8 monitors 230:10
155:18 156:11 166:21 108:10 month 55:3,5,19 128:9 131:5
177:14 184:24 198:21 memorializations 23:21 25:8 139:6,16 212:6 213:2,8
199:17 212:15 215:6 221:1 memory 63:21 64:19 76:20 233:20
222:4,12 223:2,3,11 225:9 87:17 217:13 months 261:24 262:5
228:1,22,23 230:13 231:19 mental 112:2,3,14,17,23 morning 7:16 74:13 92:2
231:23 238:7 245:18 246:18 115:1,2 135:16 136:3,6 mother 32:15 70:11 122:18
252:14,20 253:15 254:7,11 138:2,6,20 139:1,3,11,14,23 125:7 143:1 149:6 168:8
257:9,16 262:5 271:2 272:1 144:3 158:17 159:14 194:18 170:17 173:8 176:11
272:10,14,15,17 278:16,17 194:24 195:14 196:23 197:6 mother-in-law 71:10
282:7,13 283:14 197:13,17 199:3,6 211:10 motion 51:9,23
meaning 78:20 79:21 82:13 mentioned 16:11 18:3 20:2 motor 23:14
88:3,24 89:24 100:4 101:2 50:21 61:23 68:23 89:9 mouth 33:8
102:23 104:19 105:4 106:3 107:1 125:20 172:13 180:20 move 49:15,24 157:14 159:17
314
moved 182:19 neuropsychologic 138:16,22 13:17,19,20 14:2,3,12 23:17
movie 102:7 138:23 23:20 25:8,21 27:22 135:2
MRSA 111:5 neuropsychological 113:7 153:17 154:14 159:23
multiple 158:11 227:15 242:7 115:10,19 116:7,14 186:11 188:3,5 282:24
multitasking 227:14 231:5 neurosurgeon 35:5 89:10 283:2,10,13,23 284:1,4
Murtaugh 1:16 6:7 285:4,18 109:18 157:18 235:11,13 285:7
mute 74:18 209:12 258:17 notice 214:24
neurosurgeon's 152:19 noticed 224:15 237:6 248:3
N 236:12 November 117:14 119:8
N 2:1,22 3:1 285:1 neurosurgery 236:9 120:11,14,21 121:7 125:5
N/A 3:14,16,17,19 never 42:11 53:18 135:19 129:10 153:19,23 154:6
name 5:12 8:15 12:18 22:13 136:23 149:4 176:18 183:3 200:1 255:5,7 275:9
99:18,18,19 110:5,11,14 195:9 197:24 198:4,10,24 numb 86:2 151:9,14 152:1,3
136:20 143:18 144:8,11 205:9,14 207:8 228:24 number 3:12 4:11 67:14
190:10 191:20 239:13 261:6 236:13 248:15 233:19
274:10 new 79:14 104:12,19 124:24 nurse 164:10,16,21 165:3,4,8
names 71:13 99:16 221:11 263:5 165:10,12 168:6 171:15,21
Nancy 1:6,7 3:4 5:23 6:3,9 news 87:9 106:17 172:5,20
7:2 12:19 64:14 177:17 next-door 78:3 nurses 84:6 105:14 121:2
204:9 208:21 249:8 265:13 night 74:4 85:15 88:10,15,20
natural 1:5 5:22 107:11 276:21 O
naturally 213:12 214:6 nightmare 76:8,8 85:13 O 2:22 285:1
nature 11:19 25:15 211:6 nighttime 38:18 39:23 72:2 o'clock 73:8,18,24 74:2
nauseam 272:20 nine 34:5,7,7 73:24 oath 10:23
near 144:13 239:19 ninth 16:19 130:14,17 131:2 object 114:16,17 163:15
nearly 261:11 217:16 218:2 219:9,12,17 185:19 250:14 283:5
necessarily 85:23 148:23 261:20 263:9 265:6 266:20 objected 170:18 206:20
need 40:12,20 64:12 75:10 270:23 271:2,17,21 274:14 objection 86:12 121:17 124:1
83:20 112:3,5,7 114:2,14 277:1 279:19 124:12 128:18 129:18
161:19 171:23 175:18 NO.0839 1:2 132:21 134:4,19 135:6
187:18 209:21,24 224:1 nods 82:5 141:14 145:20 146:24
231:14 238:5 261:3 noise 227:17 231:2 248:9 147:17 152:15 155:14 156:7
needed 21:13 77:7 96:23 non-verbal 9:18 157:7 159:1 162:12,21
145:24 176:9 187:1,2,6 normal 9:16 32:16 241:3 166:14 167:17 168:12
199:12,13 226:13 269:1 243:13 279:16 176:15 177:12 178:4 184:3
279:20 normally 269:2 185:13 189:11,20 190:5
needs 220:11,12 226:9,13 north 12:21 106:6 107:2,4,7 191:5,23 198:11 200:15
229:18,20 230:14 233:11 107:8 201:2 213:22 215:12 218:18
278:21 nose 38:7 219:13 224:20 234:3 240:4
neighbor 77:12,12,18,21 Notary 1:17 285:5 246:15 247:4 252:10 253:2
nerd-type 221:13 note 3:20 37:21 38:5 41:6 256:6 257:15 259:20 269:10
nervous 221:2 42:4,13 118:21 125:14,17 269:23 271:1,24 272:12
nets 282:20 128:14 129:11,14,23 132:10 280:10
neuro-ophthalmologist 135:11 136:17 154:17,20,24 objections 5:4 208:16
239:9,23 245:21 158:19,20,21 160:2,21 observation 257:3
neurological 116:6,11,16 174:4 175:8 179:15,17,21 observations 228:20
neurologist 34:24 180:5,21 188:8 190:14,24 observe 53:10 61:1 151:5,19
neuropsych 116:11,17,19,22 199:23 observed 83:21 216:6 222:10
117:4 145:3 noted 6:5 119:20 227:10 249:18
neuropsychiatric 145:1 notes 3:13,23 4:14 13:10,15 obstacles 280:7
315
obvious 234:24 57:3,8,24 58:3 59:19,23 218:15 219:2,6,24 220:6,14
obviously 31:12 49:24 230:13 60:5,16,23 61:3,9,15,23 220:20 221:22 226:17 227:8
230:14 62:4,6,13,22 65:2,7,12,17 228:6,12,18 229:7,22
occasion 144:15 150:12,13 65:23 66:5,9,21 67:1,5,9 230:13,20,24 231:15 232:7
152:9 235:21 68:5 69:12 70:5 71:3,22,24 233:15 234:17 235:20
occasionally 212:10,14 72:18,21 73:1,12 74:4,16 236:15,17,21 237:10,16
occasions 153:15 75:2,9,21 76:1,6,23 78:6,11 238:2,16,22 239:6 240:2,24
occupational 3:21 91:3 79:11,13 81:13,19 82:18,23 241:4 242:6,17,24 243:5,15
111:12 117:6,10,13,17,20 84:3 86:4 88:7,14,19 90:11 249:16,23 251:6,10 252:3,7
118:10,17 119:1,6,17,18,24 90:17 91:9 92:3 94:15,21 254:24 255:3,11,22 256:3
120:4,9,12,15 125:23 95:15,22 96:13 97:6,19 99:1 256:16,19,22 257:3,24
126:12 128:16 129:2,17 99:8,16,21 100:24 101:6 258:24 261:2,5,23 262:21
occur 96:10 200:13 102:8 103:5 104:18,22 263:24 264:4 266:2,8,16
occurred 34:3 69:22 78:17 105:18,21,22 106:2 107:6 268:9 270:21 271:20 272:13
113:14,18 152:20 153:5 108:7,13 109:1,5,11,24 273:10 276:11 279:1 281:23
occurrences 150:16 152:3 110:20,23 111:6,19 112:4,9 282:3,22 284:9
October 1:18 5:16 110:22 112:18 113:1,13,24 115:6 old 32:24 34:4 99:24
121:11 156:21 115:23 116:4 117:5,11,19 oldest 16:1
off-shore 254:13 118:6,13 119:11,16,23 Oliverson 1:6,7 3:4 5:23 6:3
offense 23:6 120:5,13 125:20 126:4,20 12:19 15:2 71:14 84:9
offenses 23:15 127:13,22 128:4,14 130:13 97:19 99:17 122:18 201:16
office 3:13,23 4:14 20:4,6,14 130:23 131:7,11,20 132:16 222:6 261:2 266:3 273:7
20:21 21:20 22:6,7 28:5 133:3,15,18 134:9,14 274:23 277:3
36:2 151:4 152:19 154:13 136:12,17 137:24 138:5,8 Oliverson's 29:7 137:14,15
154:20 159:22 160:2 164:10 138:13 139:8 140:14,18,23 on-site 21:6,9,12,17 22:12
164:17 186:9,12,19 187:22 141:20 142:1 143:11,21 once 13:12,16 37:12 89:13
189:2,7 190:4,9 191:13 144:1,7,14,23 145:12 146:3 91:16 153:22 155:22 180:10
198:24 201:1,17 202:3 146:10,16,20 147:24 148:4 187:7 216:17 224:5 242:22
203:8 211:2 236:9,12 149:18 150:9,15 151:5 275:13 279:17,18,19 280:2
official 9:2,10 73:4 152:5 153:2,8,11,22 154:8 280:4
officials 54:18 154:19 155:4,24 156:4,17 once-a-day 89:5
offseason 257:11 157:4,13,21 158:3,6,10,15 ones 263:12
oh 16:14,14 39:18 46:15 159:9,16 160:5 161:2,10 Onewheel 253:12
85:11 90:2 107:6 119:13 162:8,20 163:21 164:4,12 Onewheels 253:11
155:17 161:15 173:15,23 164:15 165:1,9,18 166:5 online 216:17,22
201:9 207:20 233:2,7 168:18 173:4,11,24 174:1 onset 258:16
265:19 270:21 276:10 174:14,20,22 175:8,11 open 45:7 187:7 216:20,21
okay 6:22 7:17 8:6,8,13 10:4 176:11 177:9 178:12 179:2 opened 51:18
10:18,19,24 11:2,2,11,12,22 179:17 180:4 181:5,16,23 opens 47:7
12:15,16 13:2,5,11 14:10,18 182:9,18 183:24 185:15 operative 3:20 37:20 38:5
15:12,21 17:17 18:18 19:1 186:2 187:9,15,24 189:1,9 ophthalmologist 239:9,23
19:20,24 20:12,20 21:16 189:15,24 190:13,19 191:2 245:7,9,20
22:13 24:5 26:4,6,11,24 191:12 192:18,24 193:12 opinion 173:1,3 178:10
27:5,21,23 28:6 32:3,6 33:2 194:5,9,12,15 195:8,13 186:23 268:11
33:24 35:13 36:11,14,18 197:3 198:17 199:5,20,23 opportunity 9:5 15:20 58:8
37:1 38:5,10,15 39:8,12,21 200:4 202:2,13 203:1,5,19 85:14 91:15 133:1,21
40:6 41:6,12,24 42:9,13 204:5 205:8 207:21 209:11 255:10 256:1,18 257:4
43:16,20,24 45:8,14 46:1 210:2,10 211:4,24 212:11 274:22
49:14 52:16 53:4,14,20,23 212:22 214:2,9,22 215:2,5 opposed 21:20 169:12
54:6,9,16 55:4,10,15 56:12 215:10,23 216:6,12 217:23 optician 245:20
316
optimistic 167:4 200:12 234:18 236:22 perceived 172:10 173:6
option 187:14 230:18 252:22,22 percent 81:17 82:1 86:20
optometrist 245:20 parents' 69:21 70:6 72:3 87:9 88:5,24 227:19,19,24
ORAL 1:5 part 9:9 102:24 120:11 228:1 259:18
order 28:4 119:19 141:8,9,12 161:12,15,16 165:17 179:12 perform 20:13 226:22 255:19
141:17,23 143:19 144:9,13 237:18 239:24 240:16 270:8 performance 117:21 216:13
199:12 268:14 274:15 275:9 282:5 218:2 221:24 255:16
ordinary 104:17 participate 6:18 127:2,10 performed 113:20 115:14,19
organization 127:6 274:6 136:5,8 139:16 146:7 period 25:11 43:12,17 53:1
organizations 275:2 147:11,13,15,21 148:1,7,13 78:6 79:13,21 90:17 105:5
original 89:1 204:7 205:1,9 148:15 162:2 234:19 256:1 105:13 108:3 218:8,9
206:4 207:3,6 269:7 233:20
originally 129:9 participated 127:11,18 128:5 periodically 79:10 211:23
outpatient 111:22 117:20 148:19 permanent 92:24 93:2 216:5
119:6 243:2 244:24 246:2 participates 236:10 273:13 216:9
outset 76:17 282:22 participating 148:5 164:15 person 22:7,8 28:14 114:1,13
outside 30:23 88:8 253:19 271:22 273:12 127:16,23 190:10,14 191:12
overseeing 127:14 particular 18:6 21:2 28:14 person's 21:24
oversees 218:10 43:20 74:23 116:3 239:18 personal 23:6 30:21 47:9
overwhelmed 142:4 143:18 276:20 280:7 127:20,22 175:6 182:6,21
144:10 223:18 229:17 passion 258:2 281:19 282:23 283:2
233:24 283:15 pathology 175:3 personally 53:10 109:14
overwhelming 231:2 Pathways 126:17,20 127:3,18 173:1 246:3
owns 102:6 128:1,5 145:9 perspective 50:21,22 51:6
patience 247:24 260:13 Philadelphia 1:1,23 2:5,14,19
P 261:16 279:3 5:13,20
P 2:1,1,22 patient 114:15 119:17 152:24 Phoenix 84:19 100:15,19
p.m 68:10,13 72:1 73:2 83:2 175:2 178:2 181:23 188:9 phone 21:15 60:9,12 66:3
PA 1:23 197:1 242:20 67:7,9 74:11,18,21 75:15
packets 189:6,7 190:22,23 pause 210:16 79:9 152:23 153:1,10,12,13
page 3:3,12,12 4:10,10 97:4 pay 30:14 31:9 103:8 153:14 190:15 191:18
117:5 119:12 126:4 155:4 paying 281:22 198:18
160:23 180:4 181:14 208:24 pediatric 34:24 83:15 119:6 photo 61:8
pages 193:6 258:17 259:1 photograph 62:1
paid 30:19 102:2 103:10,14 pediatrician 34:21 35:7,9 photographs 61:10,24 62:8
pain 104:12,15 211:21 212:1 36:9,20 82:10 62:13 65:8 66:22 108:20,23
249:14 pediatrician's 36:1 203:8 photos 62:10 108:14
painful 104:20 214:18,20 peers 220:18 221:16,21 223:6 phrase 91:11
panic 140:13,18,24 141:6,18 223:9,16,24 279:24 phrased 259:17
141:20,21 142:2,8 143:15 pencil 203:4 physical 4:20 91:4 111:12
143:22 144:2,15,18 pending 11:9,10 126:9 127:1 155:11 156:5
paper 203:3,21 204:14 Pennsylvania 2:5,10,14,19 156:15,15,18 164:9 166:1
205:13 209:6 5:14 8:16 31:13,16 83:1,6 178:23 179:4,17,21,24
papers 13:5 84:13 96:10 97:9,20,23,24 180:5,10,20 181:3,7,10,13
paperwork 187:1 98:22 99:4,10 100:6,11,19 181:16 182:9,23 183:2,7,14
parent 68:19,23,24 69:5 100:22 101:4,20 103:2 183:16,20 184:1,9,12,20,22
70:11 139:21 189:5,6 people 17:4,8 70:9 102:20 184:23 185:2,4,7,9,16,20,23
parent's 47:19 106:15,19 214:24 223:21,22 185:24 211:21 212:1 278:8
parents 1:5 5:22 68:20 69:2,6 228:12 246:20 278:9,14,20
69:19 70:1,6,17 71:11 perceive 172:15 physically 214:20 222:12,13
317
223:1 257:2 171:21 172:6,20
physician 236:17 plays 133:12 256:23 practitioner's 165:11
physician's 235:10 236:4,8 Plaza 1:22 pray 77:7
physicians 258:15 Pleas 1:1 5:19 preamble 114:20 129:19
PICC 105:3,9 110:9,24 please 10:14 11:20 12:5,17 159:2
118:12 121:3,10 122:19 14:21 15:19 16:3,8,12 19:5 precede 12:14
156:12,20 38:2 40:11 42:14 44:21 preceding 166:9 171:18
pick 189:5,6,10 190:24 68:24 71:13 83:19,20 93:19 172:7
picking 209:3 99:21 200:24 205:4 predominantly 217:7
picture 62:10 pled 23:13 prefer 230:21
pictures 61:7 plus 70:13 pregnant 32:7
PICU 83:14 pocket 30:15 281:13 282:5 prenatal 32:9
piece 203:3 205:13 pocketed 96:24 preparation 25:23 26:7
pieces 9:7 point 14:16,20 15:16 28:4 prepared 9:6 95:15
pillow 54:4 32:20 40:20 51:22 74:19 preparing 26:17
pitch 256:16,18 80:12 83:13 84:3 89:15 prescribe 189:3
pitcher 257:7 91:11,18 97:6 98:8,12 present 6:1,4 30:5 35:21 84:8
place 36:23 54:22 69:8 73:19 101:10,16 104:4 110:11 98:22 99:10 138:1 139:21
105:10 120:16 130:21 131:4 145:16 157:1 161:20 165:1 140:23 141:2,4 163:12
131:16 135:15 197:5 230:3 168:9 191:15,21 195:22 164:12,20 194:12 201:22
249:12 269:6 270:9 280:9 211:6 226:5,15 237:23 202:6,18 213:13 232:2
280:12 259:19 237:12 240:3 241:24 253:19
placed 105:3 pointed 101:14 254:16,19 256:22
places 21:5 230:2,21,24 points 14:3 presently 16:18,20,22
plaintiff 46:12 47:12 50:8 pond 254:14 preserve 66:5
Plaintiffs 1:7 2:6 poor 222:4 pretty 28:18
plan 30:1,10 71:5,9 126:16 portal 152:24 previously 15:17 40:8 125:12
129:24 130:3,9,15,20 158:7 portions 210:8 162:9 188:1 202:10 227:6
158:10 159:6 182:9,10 pose 164:22 237:11
226:12 255:6 269:8,22 posed 10:11 primarily 110:1
270:4 position 20:6,14,22 28:5 primary 21:24 22:9 27:19
plane 60:19,20 103:11,12 256:23 101:21 104:3,24 105:9,20
planning 70:7 positions 256:4,12 107:5,12 108:15 109:7,10
plans 60:24 61:4 69:4 72:5 possibility 258:19,23 109:15 110:2 111:8,24
278:1 possible 101:10 154:1 279:17 112:10,20 145:5 158:1
plateaued 176:21 possibly 267:4 187:19 230:19 239:7,19
play 67:21 68:4 70:24 132:3,7 post 17:13 242:2,3,21,22 243:1 258:6
133:1,7,11,14,21,23 134:1,2 Post-Concussion 3:15 162:10 268:13 278:13
134:17,23 146:4,12,22 164:7 principal 21:18
221:20 251:9,22,24 252:1,4 post-trauma 155:5 print 204:15
256:4,13,14,24 257:1,4 potential 11:23 197:5 198:9 prior 20:8 32:4,23 33:15,17
274:20 275:4,17 258:16 33:21 34:8,11,14,17,23 35:4
playbook 209:1 pounds 233:6 35:10 37:9,14 38:24 41:14
played 134:12 257:8,8 275:1 power 79:1 42:6,20 43:1,8 51:9 56:14
275:5 practice 141:7 147:20 148:9 65:7 68:1,8 69:3 73:1,1
player 70:12 229:1,4 257:10 148:14 157:9 74:5 87:18,18 89:23 90:13
258:3 practiced 134:6,9 91:6 92:8 95:11 96:2
players 53:8 practicing 148:22 102:17 113:9 116:4 130:14
playing 54:13 132:17,19 practitioner 164:10,17,22 130:17 132:7 143:13 144:15
134:15 157:3 254:16,17 165:3,4,8,12 168:6 171:15 146:21 155:24 163:6 175:8
318
197:3 231:18 252:8 257:6 211:16 236:18 239:15 124:19 125:4 129:20 137:17
280:9,12,23 240:12,15 241:18,20 245:1 137:18 146:10 148:6 167:18
privacy 106:16 245:12 246:6 259:1 268:17 170:3,6,15 171:6 174:11,13
privately 29:24 139:21 providers 80:14 96:14 111:21 177:24 180:16 183:11
probably 19:14 45:1 48:6,12 111:21 118:9,11 121:2 185:15,19 191:16 195:20
65:13 73:23 130:11 189:4 150:23 157:22 161:18 196:11 197:10 200:19
208:4 248:1 278:23 170:10 178:17 183:6,15,19 202:19,20 204:11,13 205:4
problem 209:3 224:11 242:12 202:2 215:24 245:19,23 205:18,20,20 206:3,9,10,13
problematic 47:12 246:10 247:2 258:5 206:17,19,22 207:1 208:17
problems 20:19 32:8 37:14 providing 86:9 138:20 165:9 209:5 231:16 234:4 241:13
165:24 243:16 244:2,21 165:13 168:19 169:22 244:13 245:16 247:1 250:5
procedure 33:3 38:24 39:9 171:17 174:13 250:8,16 251:4,4 260:3
39:19 psychiatrist 113:21 264:12 266:12 271:6,8,13
procedures 30:16 psychologist 113:21 272:24 273:1
proceed 10:3 public 1:17 18:2 183:3 285:5 question/answer 165:2
process 85:8 87:5 221:4 pull 40:13 questioning 7:14 244:1
280:22 punitives 51:17 questions 10:3,6 11:24 12:6,8
processing 220:24 227:17 purchased 30:1 282:17,18 14:10 23:5 45:24 46:2
246:5,13 purpose 33:2 40:17 206:1 49:17,20 50:4,18 63:20
produce 51:14 211:13 240:14 76:18 163:14 164:11,21
produced 51:5,7 65:19 purposes 9:23 26:7,17 44:17 165:11 167:21 168:16
product 29:24 30:2,9 56:13 58:22 99:22 102:9 171:16 172:19,21,24 173:7
professional 1:17 207:15 170:10 178:13 202:4,7,13 205:6,22 207:8
254:12 285:5 pursue 18:6,10 115:2 145:8 207:12,24 208:1 231:13
prognosis 88:24 92:13 159:14 187:8 197:13 199:19 233:11 249:7 250:19 260:10
program 126:17,20,22,23 pursuing 135:11 136:19,21 261:10 284:10,13
127:3,6,10,14,18 128:2,6 pushback 199:2 quick 175:18 225:5 227:13
145:9,10,11 180:7,9,12,18 put 33:8 40:8 45:19 90:2 256:15 280:5
180:20,24 181:24 182:2 120:19 127:6 131:16 187:4 quickly 159:18 281:9
progress 130:10 190:14 204:14 207:5 209:24 quiet 212:20 249:13
project 266:18 270:8 280:12 quieter 220:12
prolong 261:15 putting 207:4 quite 60:13 94:9
prompting 231:15 233:11
prompts 15:14 Q R
properties 19:10 qualified 184:11 R 2:1,22 285:1
property 21:2 qualifies 271:19 raise 7:3 96:13
prosthetic 238:5 qualify 268:15 raised 97:1,5 214:16 215:9
protect 81:1 quarter 128:10 217:8,14 rate 230:9
protected 46:10 262:15,15,18,19,22 263:1,5 rated 164:6
provide 39:4,21 40:2 109:2 263:5 266:23 267:1,12 raw 24:24
129:14 131:13 166:6 167:14 271:21 reach 200:13 280:3
223:10 226:12 231:6 quarters 263:3 reached 79:18 102:11 190:14
provided 79:4 81:7 164:4 question 5:5 10:11,13,15,15 281:8
171:20 252:13 269:4 10:16,20,22 11:9,10 12:4,5 reaction 230:4 256:15
provider 36:1 113:4,19 21:17 22:5 36:7 50:6 51:11 read 24:20 26:4 58:22 59:2
115:14,18 116:1,3 127:5,13 52:3,6 58:22 62:23 63:23,23 93:19,22 94:3 137:19
127:24 138:6 167:12,15 64:5,9,12,13 76:21 86:7 158:20,21 173:5 176:1
168:20,23 177:10 178:1 92:17 93:17,19 94:8 103:23 reading 181:17
184:13 185:4 194:22 195:15 104:19 114:12,19 116:19,21 reads 188:8
197:5,17 198:9 199:9 116:24 122:17 123:22 real 114:12
319
reality 67:20 278:18 recording 9:10,14 209:21 relieve 212:18,24 213:11
realize 229:5 210:4,4,7,16 214:6 249:14
really 6:19 27:17 47:13 75:13 recordings 23:21 25:15 remained 98:14
76:16,16 77:7 79:8 148:24 records 4:23 26:14,16,20,22 remember 12:9,11 22:22
158:18 183:11 191:22 27:1,8,13,15 33:14 37:17 23:1 34:2,4 40:4 42:21
200:19 208:4 217:3,3 247:1 51:14 89:10 110:13 111:11 54:11 55:14 57:8 60:15,17
251:1 261:16 271:13 272:13 113:6 117:12 119:24 146:15 62:21 63:2,4,11,13,18 64:1
278:3 279:5,19 146:16 161:24 163:6 174:7 64:14 67:19,23 68:5 72:11
reason 10:10,12 11:6,17 35:2 179:1,22 180:2 186:3 188:5 74:8 76:7 77:17 78:18,20
35:5,24 117:15,18 132:9 192:20 193:6 199:24 201:11 79:2 80:3,20 85:5,5,22
165:14 166:12 167:13 176:7 268:11 86:11,18,23 89:3,22 93:9
193:12 195:8 198:3 199:5,8 recover 92:19 95:10,14 97:14 111:9
203:19 204:2 234:20 246:3 recovery 23:23 104:13,20 113:23 114:22 115:11 117:8
reasonably 12:4 105:19 281:20 282:5 128:4 134:22 146:14 148:10
reasons 229:14 233:18 recurrence 111:2 148:21,22 149:1 150:17
recall 15:17 20:20 23:9 27:9 references 136:18,19 155:3 166:16,18,18 168:10
41:24 54:20 56:21 57:3,19 referencing 188:4 186:16,16 190:8,10 191:19
61:4,20 62:18 63:1 73:7,8 referring 113:3,11,14 158:17 192:12 197:22 208:11,22
75:9 76:21 77:4 79:17 81:3 158:19 177:5 255:24 213:23 217:13 220:2 221:1
81:10,22 87:13 95:21,24 reflect 114:11 223:4,22 227:22 231:7,14
110:5,10 132:4,8 151:22 reflected 204:4 234:23 237:20 239:14 246:8
167:19 174:18 192:19 reflective 203:21 246:17 247:7,10 250:23
194:23 239:13 248:9 263:12 refresh 87:17 134:16 181:1 259:24 260:4 264:23
receive 18:22 117:2,3 194:5 remembered 75:16 81:15
received 31:16,20 54:5 80:8 refreshed 129:12,12 remembering 166:23 172:14
92:16 184:9 185:23 242:1 refreshes 135:4 193:20
receiving 68:8 190:8 refreshment 129:15 remind 283:4
recess 265:22 regard 162:15 reminded 81:11,16
recklessness 51:16 regarding 73:4 76:18 98:10 removal 33:14
recollection 65:4 87:7 93:13 98:18 117:12 120:20 186:14 remove 80:9
129:11,15 134:16 135:4 281:13 removed 32:21 121:10
153:20 159:3 181:1 194:6 regardless 36:22 148:11 122:20
recommendation 111:20 213:7 243:11 284:6 renamed 209:22
125:24 158:23 159:10 regional 52:22 69:15 117:24 render 218:5
194:22,24 118:3 278:15 rendered 185:3
recommendations 115:17 Registered 285:4 renew 271:18
128:24 194:16 195:24 registration 223:14 renewed 271:3
recommended 111:7,16 regularly 137:3 rented 83:7
125:22 128:22 145:13 rehabilitative 109:21 repeat 10:14 68:12 86:19
157:19 158:15 183:20 rejecting 237:19 93:17 116:6 117:1 138:11
194:18 197:13 240:18 related 13:6 24:17,19 38:11 191:16 208:21 223:21 249:7
recommending 115:20 44:4 51:8 103:1 121:14,14 284:3
record 6:5,14 9:2,24 24:14 125:6 142:16 211:22 237:13 repeated 236:24
38:3,10 41:4 49:12 59:2 239:10 245:24 rephrase 10:15 197:9 250:8
63:7 93:22 94:3 115:9 relationship 102:16 report 21:11 42:14 87:10
117:11 149:23 160:11 176:1 relative 107:8 151:15 131:22 132:11 152:18,22
186:12 209:6,17 210:5,18 relatives 70:18 108:4 238:10
210:20 237:17 239:5 265:24 released 120:12 242:22 reported 21:7,10 22:8 54:8
recorded 9:1,7 42:4,18 58:5 relevance 50:11,12 54:10
172:7 relevant 46:8,9 51:2,20 reporter 1:17 6:6,8,9 7:2,10
320
7:22 8:1 9:3,14 10:24 58:24 26:2 137:16 168:19 170:11 Ruud 136:22,24 137:2,6,20
59:2,8 93:20,22 94:3 99:22 217:10 283:2 197:24 198:4,15,22 199:9
121:24 122:4,8 123:1,10 reviewed 26:3 140:9 Ryan 136:22 137:20 197:24
124:9 154:11 173:14,23 reviewing 141:8,12 163:4 198:4,15,20,22 276:7,10,10
174:2 176:1 179:9 201:6 ride 252:16 253:13
207:18 208:6,15 210:2,10 right 7:3 12:24 14:5 16:17 S
210:13,17 232:11,15,19,23 28:10 31:2,7,22 34:6 38:2 S 2:1,18,22,22 3:10 4:7
265:12,15,19 270:12 273:17 40:21,24 41:3 46:21 47:3 S-U-E-S-U-E 99:23
273:24 285:5 56:8 59:7 61:19 63:19 65:7 safe 235:19
reporter's 58:14 66:9 69:16 70:15 71:24 Saints 234:11
Reporters 1:21 73:13 78:3 81:5 86:1 90:4,9 sake 50:4
Reporting 5:13 92:17 94:6 95:4 96:4,21 Salt 107:22 113:16 239:20
represent 8:16 179:20 193:7 102:13 104:2 105:1,6,16,24 Sam 138:7
261:7 108:11 109:19,22 110:13 San 52:22 53:8,12,17 54:4,18
representative 20:11 111:13 114:7 117:6 118:21 55:7 69:14,20
request 61:15 62:5 131:12 118:24 120:22 121:12 Santa 71:18
186:14,18 283:24 123:12 124:11 125:4,12 save 79:1
requested 59:3 93:23 94:4 126:8 129:6 131:3 136:17 Savoy 1:9,10 2:20,20 261:7
158:11 176:2 137:17 141:10 143:3 144:23 saw 24:5,9 27:19 33:14 35:23
requests 109:3 146:18 148:4 149:7 150:3 36:8,10 37:2 58:10 59:16,24
require 37:24 250:22 151:10 154:9 156:22 157:14 60:1 62:8 64:11 74:13,20
required 34:20 110:9 159:17,20 160:20 161:15,23 85:2 110:21 111:3 129:10
research 187:2,13 171:10 172:12 173:12 175:1 141:16 163:3 188:23 197:24
reserved 5:5 176:6 177:21 178:5 179:14 198:4,23 207:2 238:10
resolved 121:9 237:23 180:13,16 181:12 183:11 239:22 240:15 241:17
resolving 20:18 184:11 185:11 188:3 192:6 saying 9:15 107:4 162:15
Resort 18:11 192:8 198:1,7 201:15,18 167:13 169:5 204:24 244:2
respect 12:13 89:8 163:24 202:9 210:7,24 214:14,14 250:21 251:17
171:13 222:10 217:20 226:1,17 227:8 says 38:6,16 41:13 42:13
respond 86:3 164:5 237:1 238:8 242:14 244:24 119:1,5,7,12,16 126:8,12,16
response 9:21,23 50:14 173:7 245:16 247:13,22 259:16 131:21 132:11 135:11 145:1
responses 9:18 207:17 260:9 261:19 262:3,8 263:8 145:8 155:5 161:2 165:17
responsibilities 20:10 263:21 264:5,23 265:6 168:8 178:8 180:6 181:9
responsibility 22:1 275:10 276:21,23 210:3
responsible 102:23,24 road 80:19 scar 222:19
rest 97:17 101:3 219:3 RoadRunners 133:14 275:5 scheduled 5:17 37:7 186:8
restore 90:15 275:6 200:5 211:2,6,13
result 54:13 125:9 237:14 Robert 103:15 schedules 20:16
246:13 role 20:24 28:17 school 17:1,13,13,15,18,19,21
resulted 52:13 280:24 roll 275:10 18:1,2 19:1,7 43:3 130:1,4
resulting 96:7 room 10:9 13:2 62:14 65:9 130:16,18,21 155:10,13,20
results 27:3 269:9,14,18 66:23 72:23 83:13,21 84:4 155:22,23 156:2 165:21
resume 183:16,20 255:7 87:11 88:12,15,17 107:13 175:5 186:15 187:6,17
resumed 133:23 134:3 112:24 203:8 212:20 214:3 188:10 216:13 217:2,9
return 97:12 182:23 214:7 231:23 232:3 248:13 218:2 220:15,23 221:23
returned 69:20 97:6 156:2 rounds 92:1 222:5,11,12,18 223:1,3
175:4 176:12 177:11 178:2 routine 9:17 32:9 35:20 224:16 225:2,8 226:3,18,22
178:9 64:22 229:23 253:20 261:18,24
reunion 106:11 108:15 routinely 228:15 262:2,13 269:2,5 270:6
review 9:5 13:12,16,18 25:22 rules 8:23 50:9 271:23 274:5,7,8,11,12,13
321
274:15,16 275:21 276:21,23 seen 34:24 35:4,10 36:20 setting 10:8 217:10
276:24 279:15,17 280:1,3,4 59:19 66:10,13,22,22 67:22 Seven 233:6,21
280:5,9,13,23 281:2,3,5,6,8 117:11 119:23 120:20 135:1 seventh 16:21 216:14,16
school-based 255:12 153:4,7 162:23 163:5 217:2 280:20
school-type 221:13 178:13 186:3,13 199:24 shake 9:19
science 263:11,21 200:1 204:7 205:9,14 share 14:6 40:24 55:18 57:11
scope 33:1,7,12 34:17 207:16 239:8,12 245:14,22 57:15 89:20 118:13 159:19
scores 164:23 sees 222:18,19 225:12 173:2 179:14
screen 41:1 113:4,10,13,20 seizure 150:4,6,24 151:24 shared 55:16
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2024 1:18 5:16 131:16 139:13
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2024-2025 279:15 5/23/2012 16:9
20s 100:3 224:14 5:26 284:14
21 162:1 172:5 174:5 178:12 504 129:24 130:3,9,10,15,20
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287 3:16 9 263:15
288 3:17 9:00 73:23
289 3:19 9:38 73:14
29 120:21 121:7 125:5 910 2:5
290 3:20
291 3:22
292 3:24
293 4:15
294 4:18
295 4:21
296 4:24
3
3/21/23 173:18
3/30/23 4:18
3:02 210:21
3:47 247:15
3:56 247:19
30 1:21
31 92:11 98:3
37 3:20
4
4,279 3:5
4/26/2010 16:4
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