Expert Witness

TIME: 10:23AM

Law Offices of [redacted] – Columbia, South Carolina

Q – Now, Ms. Adamson, my client has been diagnosed as being in a persistent vegetative state. Have you had any opportunity to visit with or see [the patient]?

A – I saw [the patient] for about an hour yesterday at the hospital.

Q- Would you please relate to me what experiences you had with [the patient]?

A – When I first walked into the room I spent a good hour trying to get him to respond to any signals, patting his arms, touching his face. During that time, a respiratory therapist came into the room. She suctioned his trachea. I noticed the agitation on his face while [the therapist] was doing that, [his] body moving around. He actually opened his eyes a few times while I was there and at one point when I was leaning over I noticed that he had noticed my necklace as it was dangling down and that caught his eye. Other than that, I didn’t see anything else that was going on.

Q – Were you able to generate any sort of communicative response from [the patient]?

A – No.

Q – Now, have you ever been in any similar circumstance yourself?

A – Yes, I have.

Q – Tell me about that.

A – I was completely paralyzed at 33 from a massive stroke where I could not communicate in any way at all. I was completely paralyzed unable to respond.

Q – All right. And where was it that this took place?

A – This took place in Los Angeles.

Q – And how long ago was that?

A – 1995

Q – And you say that you were paralyzed, did you have any awareness of your circumstances or surroundings?

A – I knew that I was in a bed. I could see images, but they were very blurry, I didn’t know – I knew I was in a hospital bed.

Q – Were you able to communicate with the outside world in any way?

A – No.

Q – Were you able to respond to any stimuli?

A – No.


Q – Now was there a period of time when you were aware of your surroundings but unable to communicate or respond in any way?

A –Yes.

Q – And how long a period of time was that?

A – It was about 7-10 days before my husband realized that I was aware, I was actually a person inside the body. I was trying to – trying to communicate in any way that, you know, hey, I’m alive, I’m in here.

Q – And how were you ultimately able to communicate with your husband?

A – Finally through blinking – blinking my eyes. It took an enormous amount of energy, everything that I had inside of me, to be able to communicate, to finally let him know that I’m aware. After that happened, he had a sign made above my bed that said: Please treat her as a human being; she understands everything that’s being said to her.

Q – Was there a period of time thought that despite your efforts you were unable to communicate with your husband or anybody else?

A – I couldn’t do anything. I couldn’t communicate with anyone.

Q – How difficult – or how much effort did it require on your part to actually be able to blink your eyes?

A – It took everything I could to do that, I kept trying, I didn’t quit. I never gave up. That was the one thing that I was trying to focus on. Because I tried to move a finger, I couldn’t move it. I remember being asked if I could wiggle my toe and nothing moved.


Q – [What was the prognosis or likelihood of your condition if you survived?]

A – It was assumed that I was going to be nothing more than a vegetable. They told my husband that I was in a persistent vegetative state. Your wife would not want to be like this, she wouldn’t want to live this way. It was very doubtful that I was going to come out of this condition.

Q- Was any encouragement offered to either you or your husband to try to bring you out of that state?

A – My husband was the only person that believed that I would.

Q – And how was it – how much time did he spend with you in terms of trying to develop some communication or response from you?

A. Every second of the day. He actually closed down his [law] practice to be with me. He was there all the time; he never gave up asking me questions asking me to respond in any way at all.

Q – Between your husband and your doctors, who is the first one to recognize that you actually were able to communicate?

A – My husband.

Q – And after he recognized that, what was done next?

A – Immediately he had that sign made that was put above my bed that stated that this is a person. She understands everything going on please treat her as a person.

Q – Did your doctors ultimately become convinced that you were still in there?

A – Yes.


Q – How long was it after your stroke, Kate, before you were finally able to communicate with your husband?

A – About 7-10 days.

Q – And during that period of time was there anyone else who believed that you were still in there?

A – No.


A – I was just like [patient] lying there. I was turned every two hours. I had a trachea tube; I had a feeding tube inserted. I couldn’t respond or communicate in any way at all.

Q – All right, were people asking you to respond?

A – Uh huh. Yes.

Q – What sorts of things were they asking you to do?

A – Wiggle my toes; move a finger, they would touch my arms.

Q – And were you able to respond?

A – No.

Q – But ultimately you were successful?

A – Eventually.


Q – Were there any medical personnel there monitoring you to see if you were able to develop a response?

A – Only after my husband had insisted that [I was] aware, and in fact in the beginning he even asked me again just to make sure that I understood.

Q – Ok. Now I think you had said ultimately you were sent to rehabilitation?

A – Correct.

Q – And how long after your stroke was it that you were sent there?

A – Not until six weeks.

Q – Okay. And how long were you in rehabilitation?

A – For three months.

Q – And when you first started rehabilitation what was – how would you describe your ability to communicate?

A – By blinking my eyes.

Q – And was that easy or difficult?

A – Difficult. I had nothing but the only ability to communicate was blinking my eyes…


Q – And you say you were in [the patient’s] room yesterday when the respiratory therapist was suctioning his trachea tube; correct?

A – Yes.

Q – And describe for us, again, briefly if you would, what you observed abut [the patient].

A – What I observed was the agitation in his facial expressions when he was being suctioned, the discomfort and the movement in his whole body as he was being suctioned.

Q – Did they ever suction you in a similar fashion?

A – Yes.

Q – And did they do that at the point in time when you were unable to communicate or respond?

A – Yes.

Q- And what sensation if any did you have during the time that they were suctioning you?

A – Extreme pain. My whole body would cringe when they were doing suctioning. [and discussions were held within hearing distance of my bed about the likelihood that I wouldn’t make it or that I would be warehoused; and the extreme pain as they performed surgeries without proper anesthesia and as they were inserting the G-tube; and the pain as the tubes were being pulled because I was being moved carelessly while being diapered, turned and bathed]

Q – All right And were you able to communicate that pain to anybody in any way?

A – No.


Q – Well, you do have an opinion in this case concerning [the patient], do you not?

A – All I can tell you is that it’s possible for someone to be able to feel pain when the doctors have said no one’s inside. Based on [the patient]’s condition, I can’t give a diagnosis on that.

Q – Right. And I appreciate that. And that’s – I appreciate your honesty. You really can’t render an opinion in this case as to whether or not, for example, [the patient] feels pain?

A – No, and I can’t tell you what his condition is and I don’t pretend to. Maybe, however, the Doctors do [pretend to know].


Q – Ms. Adamson, I just have a few follow-ups. How important is it to your recovery that your husband was at your bedside constantly?

A – Extremely important. I had no one else there who believed that I was aware and inside [my paralyzed body].

Q – All right. And was your husband encouraged by your doctors or other care providers to actually be there with you constantly and prompt you?

A – Could you repeat that, I’m sorry?

Q – Yes. Was your husband encouraged by your doctors or your other care providers to be there with constantly trying to prompt you to get some response?

A – The doctors weren’t constantly with me. The only one that was, was my husband, and the fact that he was there tirelessly to sit with me and to see if it was any, anything alt all, any kind of response

Q – Well, I understand that, but do you know if he was encouraged by your doctors to do that or did they ridicule him for doing that?

A – They didn’t encourage him. I think he was seen more as a nuisance. They thought he was crazy. [And that crazy nuisance of a husband who drove the doctors and medical staff crazy with his constant questions, challenges and insistence that I was alive and would make it – in the face of conventional medical wisdom – saved my life. He is the main reason I can and testify as an “expert witness” on behalf of those who represent the interests of, and speak on behalf of, those who cannot speak for themselves.]