SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO, CENTRAL DIVISION
__________________________________
)
RANDY DALO and KAREN DALO,

)
)

Plaintiffs,

)
)

vs.

) Case No. 37-2018-000017017)

BRADLEY GLENN HAY, M.D.; TAMMY

)

NODLER; TODD ALLEN; GERARD

)

MANECKE, JR; THE REGENTS OF THE

)

UNIVERSITY OF CALIFORNIA, and

)

DOES 3 through 100 inclusive,

)

CU-PO-CTL

)
Defendants.

)

__________________________________)

VIDEO DEPOSITION OF BRADLEY GLENN HAY
San Diego, California
November 14, 2019

Reported by Gina Marie De Luca, CSR No. 6973, RMR, CRR

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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO, CENTRAL DIVISION
__________________________________
)
RANDY DALO and KAREN DALO,
)
)
Plaintiffs,
)
)
vs.
) Case No. 37-2018-000017017)
CU-PO-CTL
BRADLEY GLENN HAY, M.D.; TAMMY )
NODLER; TODD ALLEN; GERARD
)
MANECKE, JR; THE REGENTS OF THE )
UNIVERSITY OF CALIFORNIA, and )
DOES 3 through 100 inclusive, )
)
Defendants.
)
__________________________________)

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INDEX

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WITNESS: BRADLEY GLENN HAY

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EXAMINATION
By Mr. Iredale

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EXHIBITS
MARKED FOR IDENTIFICATION
Exhibit 1 Anesthesia log-in sheet
117
Exhibit 2 Texts between Dr. Hay and Tammy
Nodler

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Exhibit 3 Dalo ED Vitals

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183

Exhibit 4 Printed texts from 1/23/17 through 175
1/27/17
Exhibit 5 Dalo anesthesia records
184
Exhibit 6 Pre Notes
202
Exhibit 7 Declaration of Chih Hsu, PharmD
204

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VIDEO DEPOSITION OF BRADLEY GLENN HAY,
commencing at the hour of 10:15 a.m., on Thursday,
November 14, 2019, at 4660 La Jolla Village Drive,
Tenth Floor, San Diego, California, before Gina Marie
De Luca, Certified Shorthand Reporter in and for the
State of California.

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APPEARANCES:

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For Plaintiffs:

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IREDALE AND YOO, APC
BY: EUGENE G. IREDALE, ESQ.
105 West F Street, Fourth Floor
San Diego, California 92101-6036
619.233.1525
619.233.3221 Fax
egiredale@iredalelaw.com

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For Defendants Tammy Nodler; Todd Allen; Gerard Manecke,
Jr.; The Regents of the University of California:

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128

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PAGE

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LAW OFFICE OF DAVID WEISS LAW
BY: DANIEL FARRUGIA, ESQ.
11340 West Olympic Boulevard, Suite 100
Los Angeles, California 90064
310.575.9566
310.575.9576 Fax
farrugiad@djwlaw.com

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For Defendant Bradley Glenn Hay, MD:
HEGELER & ANDERSON
BY: BARTON H. HEGELER, ESQ.
- and BY: RYAN McCARTHY DAVIS, ESQ.
4660 La Jolla Village Drive, Suite 670
San Diego, California 92122
858.597.9975
858.452.1491 Fax
BartonHegeler@hegeler-anderson.com
rdavis@hegeler-anderson.com

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Also present: Shayne Davidson, Videographer
Karen Dalo
Randall Dalo

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THE VIDEOGRAPHER: This is the beginning of
Disc 1 of the deposition of Dr. Bradley Glenn Hay. The
case caption is Dalo vs. Hay, et al.
My name is Shayne Davidson. I am a partner in
VideoTrack, located at 600 West Broadway, Suite 700,
San Diego, California. The court reporter today is Gina
Chavez [sic].
Today's date is the 14th day of November 2019,
and it is now 10:15 a.m.
Please be aware that the video and audio
recording will take place at all times throughout this
deposition unless all counsel agree to go off the
record.
Would counsel please introduce yourselves and
state who you represent.
MR. IREDALE: Gene Iredale on behalf of the
plaintiffs.
MR. HEGELER: Bart Hegeler on behalf of
Dr. Hay.
MR. FARRUGIA: Dan Farrugia on behalf of The
Regents, Dr. Allen, Dr. Manecke, and Tammy Nodler.
THE VIDEOGRAPHER: And would the reporter
please swear in our deponent.
///
///

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-oOoBRADLEY GLENN HAY,
having been first duly sworn, testified as follows:
-oOoEXAMINATION
BY MR. IREDALE:
Q. Sir, may I ask your full name, please.
A. Bradley Glenn Hay.
Q. And your date of birth?
A. November 3rd, 1975.
Q. Now, I need to cover, if I could with you, some
of your background.
You grew up, I believe, in Omaha, Nebraska?
A. Yes, sir.
Q. Graduated from Millard North High School in
Omaha?
A. Yes, sir.
Q. And that was in the year 1994?
A. Yes, sir.
Q. You then attended the University of Nebraska?
A. Yes, sir.
Q. Earned a Bachelor of Science degree?
A. Yes, sir.
Q. And you earned that degree in 1998?
A. Yes, sir.

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Creighton also located in Nebraska?
A. It's in Omaha.
Q. It's in Omaha as well.
And then you had the opportunity to come to the
University of California at San Diego to do your
residency?
A. Yes.
Q. When did you commence your residency here at
UCSD?
A. On June 30th, 2006.
Q. So your internship lasted from what time to
what time at Creighton?
A. June -- or -- excuse me -- July 1st, 2002, to
June 30th, 2003.
Q. Between 2003 at the end of your internship and
June 30th of 2006, could you tell me what you did for
employment.
A. I was a -- so from 2003 to 2006?
Q. Yes, sir.
A. I was a resident at the University of
California San Diego in the Department of
Anesthesiology.
Q. Very good.
And then your residency concluded June 30th of
2006?

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Q. Thereafter, you went to medical school?
A. Yes, sir.
Q. And you attended medical school at the
University of Nebraska Medical Center?
A. Yes.
Q. Is that in Omaha as well?
A. Yes.
Q. I believe you earned your degree in the year
2002?
A. Yes.
Q. It was an MD degree?
A. Yes.
Q. And then after you earned your MD degree, can
you tell me what you did with respect to employment?
A. Yeah. So after I -- well, during my last year
of medical school, I applied and was accepted to
residency at Creighton University for an internship in
internal medicine, a one-year internship; and then also
at the University of California San Diego Department of
Anesthesiology for an anesthesiology residency.
Q. So did you do your internship at Creighton?
A. Yes.
Q. And that was in the year 2002-2003?
A. Yes.
Q. And Creighton -- would you help me. Is

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A. Yes.
Q. Now, I needed also to ask you have you ever
given a deposition before?
A. One.
Q. And can you tell me in the context of what case
that was?
A. It was a car accident, a motor vehicle
accident.
Q. Were you a party or a witness?
A. Party.
Q. Were you the defendant, or were you the
plaintiff?
A. Defendant.
Q. When was that lawsuit brought?
A. So it was soon after I moved into my residence.
So that would have been -- what is it? -- 2013. So
sometime, like, August 2013 maybe.
Q. And you did give testimony in that lawsuit in
which you were sued as a defendant?
A. Yes, I did.
Q. Did the matter go to trial?
A. No.
Q. Was it concerning an automobile accident?
A. Yes.
Q. And were you the driver of one of the cars?

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Was anyone injured?
Yes.
And the nature of the injury, as you understood

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A. So I hurt my hand. My wife hurt her -- I think
one of her legs. She was also pregnant at the time.
And the other -- I think there was a family in a minivan
in the other car, and the driver hurt her hand.
Q. Were you under the influence at the time of the
accident?
A. No, I was not.
Q. Where did the accident occur?
A. Encinitas at the intersection of Encinitas
Boulevard and El Camino Real.
Q. Now, other than that, have you been involved in
any lawsuits?
A. No.
Q. Of any kind?
A. No.
Q. I understand that you are familiar with the
12-step program?
A. Yes.
Q. And you have participated and are participating
in a 12-step program?

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Q. You understand that you have taken an oath to
tell the truth?
A. Yes, I do.
Q. And in accordance with that oath and in
accordance with the steps that we've just mentioned, you
will tell us the truth today?
A. Yes.
Q. You had a license to practice medicine that was
issued in the State of California on June the 11th of
2004?
A. I believe so.
Q. A physician and surgeon license?
A. Yes.
Q. Now, I need to discuss with you your history of
substance abuse.
Let me say at the beginning the purpose of my
discussion is not to embarrass you or to humiliate you
but because it is an important part of the lawsuit. So
I apologize in advance for any embarrassment or
inadvertent pain that I may cause, but I do need to
inquire.
A. I understand.
Q. Let's discuss, if we could, your history of
substance abuse.
You began initially having problems with

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A. Yes.
Q. You know that the fourth step is to make a
searching and fearless moral inventory of oneself?
A. Correct.
Q. And that the fifth step involves, among other
things, admitting to ourselves and to another human
being the exact nature of our wrongs?
A. Yes.
Q. The eighth step means that you should make a
list of all persons you have harmed?
A. Yes.
Q. And become willing to make amends to them all?
A. Yes.
Q. The ninth step is to make direct amends to such
people wherever possible.
A. Yes.
Q. Is that true?
And the tenth step is to continue to take a
personal inventory and, when wrong, to promptly admit
it?
A. Yes.
Q. You believe in the 12 steps?
A. Yes.
Q. And you endeavor to follow them in your life?
A. To the best of my ability.

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alcohol early in your life?
A. Yes.
Q. And after beginning to drink, you continued to
drink alcohol during college?
A. Yes.
Q. And during medical school?
A. Yes.
Q. Is it true that during medical school it would
be common for you to drink a 12-pack or more of beer?
A. Yes.
Q. During a single sitting?
A. Yes.
Q. And that you would drink a 12-pack or more of
beer between three and five days per week when you were
in medical school?
A. Yes.
Q. And other than beer, did you also use other
forms of alcohol?
A. Yes.
Q. What forms of alcohol other than beer did you
use when you were drinking and in medical school?
A. Hard liquor.
Q. What kind?
A. Various. Nothing in particular. Vodka for the
most part, but other -- I mean, just hard liquor in

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general.
Q. Tequila?
A. I've had tequila.
Q. Now, after you graduated from medical school,
during your internship, you continued to drink?
A. Yes.
Q. At the same rate?
A. Yeah, I believe so. Yeah. Maybe a little
less, but pretty similar.
Q. Is it true that during your internship you
would come to work intoxicated on occasion?
A. Yes.
Q. And during your internship you would come to
work, if not intoxicated, hung over on many occasions?
A. Yes.
Q. The same would be true for the residency you
did at UCSD?
A. Yes.
Q. You worked when you were intoxicated?
A. On a few occasions, yes.
Q. Well, let's talk about "a few."
A. Okay.
Q. Was "a few" during your residency which lasted
a couple of years, as I understand it, or even
three years?

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Q. Three times.
A. Yes, sir.
Q. Did each of the three arrests involve alcohol?
A. Yes.
Q. And one of them, I believe, was being drunk in
public?
A. I -- I think I got a public intoxication when I
was in college.
Q. And then the other two involved arrests that
had to do with being under the influence while driving?
A. Yes.
Q. And in fairness to you, you said you are not
sure whether a criminal conviction resulted from the two
driving incidents or not.
A. Yeah. I mean, I don't know -- I don't know the
language. I just went through diversion program. So I
don't know if that counts as a conviction or not.
Either way, I -- yeah, I had to do -- I -- yeah.
Q. In any event, regardless of whether there was a
formal conviction, you admit that the behavior involved
your driving while you were under the influence of
alcohol?
A. Yes.
Q. And you were arrested twice for that, but it
was a common occurrence?

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A. It was a three-year anesthesia residency.
Q. What was the frequency with which you would
come to work under the influence of alcohol?
A. Maybe two or three times a year.
Q. And what was the frequency with which you would
come to work while being hung over?
A. Probably on average once a week, maybe more.
Q. And when you say "hung over," would you
describe the symptoms that you had. Headache?
A. Yeah, headache. Slight nausea or nausea.
Typical hangover symptoms.
Q. Now, your addiction to alcohol had, among other
things, legal consequences for you?
A. Yes.
Q. You were involved in at least two
alcohol-related driving incidents?
A. Yes.
Q. And did those result in criminal convictions?
A. The -- two of them were -- I was able to go
through diversion, like a diversion program. So I don't
necessarily know if that's a conviction.
One I did get a reckless driving charge for.
Q. So, in other words, you were -- were you
arrested twice?
A. Three times.

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A. Yes.
Q. You drove while you were under the influence on
many occasions?
A. Yes.
Q. Hundreds of occasions?
A. I can't put a number on it, but probably in the
range of a hundred, but I -- it's impossible for me to
know.
Q. I won't press that matter.
A. Okay.
Q. Now, during your residency, you were involved
in giving anesthesia to people?
A. Yes.
Q. It is fair to say, is it not, that the work
that anesthesiologists do involves a high degree of
stress?
A. It can -- yeah, it can be stressful, yes, for
sure.
Q. And, of course, it also involves having access
to controlled substances?
A. Yes.
Q. And are you familiar with the medical
literature in the area regarding the rates of substance
abuse among the various specialties in medicine?
A. I don't know the exact numbers, but I have a

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general idea.
Q. And that one of the highest rates of substance
abuse occurs not as a personal matter as to you, but as
a general matter among doctors who are
anesthesiologists?
A. Yes, that is a fact.
Q. And at least the medical literature attributes
that in part to the high degree of stress of
anesthesiology?
A. Yes.
Q. And to the constant and ready access to
controlled substances?
A. Yeah. I think it's access related more than
anything.
Q. Now, is it fair to say that among doctors, the
knowledge that anesthesiologists have a higher rate of
substance abuse than other specialties is common
knowledge?
A. That -- that, I can't answer. It wasn't -it's -- was never talked about that much, but I think
there were -- there were times where it was brought up
that, you know, anesthesiology were -- anesthesiologists
were specifically at risk to addiction.
Q. Yes.
And when you say it was brought up, do you

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fentanyl was, best as you recall the year?
A. It would have been my first year of anesthesia.
Q. So that would have been -A. 2003.
Q. And that would have been at UCSD?
A. Yes.
Q. Now, fentanyl is a synthetic opioid?
A. Yes.
Q. The literature tells us it's roughly ten times
stronger than heroin?
A. That -- that, I don't know. I -- I don't know
the ratio, but that sounds -- that sounds about right.
Q. And fentanyl, like many of the opiates, is
addictive?
A. Yes.
Q. And people who use fentanyl have a natural
physiological tendency to develop an habituation to it?
A tolerance of it?
A. Yeah.
Q. And a dependence on it?
A. Yes.
Q. And an addiction to it?
A. Yes.
Q. Can you tell me the first time you used
fentanyl was it fentanyl that you had stolen?

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remember any specific conversation or lecture in which
that was discussed?
A. I believe we had a lecture as a resident
regarding substance abuse and within the medical
profession and anesthesiologists, and it was brought up
in one of our first days of orientation.
Q. So you knew, when you were going into
anesthesiology as a specialty, that it had some higher
degree of risk for somebody who might be predisposed to
substance abuse?
A. I don't believe, as a medical student, I knew
the numbers, but I was aware that we have access to
controlled substances.
Q. Yes.
Let me put another question to you: Would you
say, at least among anesthesiologists themselves, they
understand that there is a substantial degree of risk
higher for them than for other subspecialties -A. Yes -Q. -- to become involved in substance abuse?
A. Yes, I would agree with that.
Q. At some point during your residency, you began
to use fentanyl?
A. Yes.
Q. Can you tell me when the first time you used

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A. Yes.
Q. How did you steal it?
A. You know, that was so long ago that -- to -- to
the best of my recollection, it would have been excess
waste that was reported as returned and -- or not
returned. It would have been reported as given that was
not given, and it was stolen by myself.
Q. Now, let me just ask if you could explain the
details of that process, the waste process, and how you
were able to obtain the fentanyl while complying in some
way with the waste procedures. Could you explain that
to us.
A. Yes. So first off, there's been changes in how
you receive the medications and how you waste over the
years. So what was during the early part of my
residency was not the same as later on.
Q. Okay.
A. In the early part of residency or in residency,
we had a box that we had a key to. You would check out
your narcotic medications generally in a form of -- oh,
I can't remember if it was a packet back then or if you
just grabbed what you need. I cannot remember.
But you would get your medication. You'd do
your anesthetic. And let's say the case was -- received
3 cc's of anesthesia, you had 2 left over. You would

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say that was given, and you would keep it, the 2 cc's.
That was one way.
Or if you had a large amount, you could dilute
it and return to the pharmacy the same amount that was
given during the course of the procedure, yet the -what you were returning was a diluted concentration of
fentanyl.
Or you could turn in just saline back to the
pharmacy.
Q. All right. So did you use all three of those
methods -A. Yes.
Q. -- during your residency?
A. I believe so.
Q. Now, understanding that it may not be possible
for you to give me a precise answer -A. Um-hmm.
Q. -- can you give me an estimate as to when that
arrangement that you described that pertained during
your residency for obtaining the drugs -A. Um-hmm.
Q. -- from the locked cabinet changed?
A. I believe it was -- it did not change during
the residency. I don't believe so.
Q. All right. Then let's just talk about what you

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Q. All right. Let's talk about those three
methods.
Throughout the course of your residency, you
stole fentanyl?
A. Yeah. Off and on throughout my residency, yes.
Q. And throughout the course of your residency,
you used fentanyl; is that true?
A. Yes.
Q. And when you used it, did you use it
intravenously?
A. Yes.
Q. With a syringe?
A. Yes.
Q. You -- there are other ways of consuming it, of
course; but you would use it generally intravenously?
A. Exclusively.
Q. Exclusively?
A. Yes.
Q. And, now, when you first started using
fentanyl, you became addicted to it?
A. Yeah. It doesn't take long.
Q. It's a very powerful opioid, synthetic opioid?
A. Yes.
Q. And when you start to use it, it makes you feel
good?

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did during your residency.
A. Okay.
Q. Sometime shortly after your residency began,
you began to use fentanyl?
A. Yes.
Q. About how long after it started?
A. Probably maybe around four months into my
residency.
Q. And can you tell me -- do you remember the
first time you used fentanyl?
A. Yeah, I have some recollection of it.
Q. Did you use it alone, or were you with someone
when you used it?
A. Alone.
Q. Did you ever use fentanyl with another
anesthesiologist -A. No.
Q. -- during your career?
Did you ever use fentanyl with another medical
professional, a nurse or other person?
A. No.
Q. You would always use it yourself?
A. Yeah. I wouldn't -- I did not want anyone to
find out what I was doing. So it was -- I would use by
myself in private.

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A. Yes.
Q. And you want that feeling again?
A. Yes.
Q. And, in fact, you have a craving for the drug?
A. Yes.
Q. And you have a physical need for the drug?
A. Eventually you do have a psychological and
physical need for the drug.
Q. And you got to that point when?
A. Probably within a couple months. I don't -I -Q. Would you -- now, you used multiple times a
day?
A. Eventually it would -- at first it was only
when -- you know, at home. And then, you know, your -your tolerance goes up. So, yeah, it would increase
frequency.
Q. Now, I don't intend to get into your family
life at all, but I do need to ask this: When you were
doing your residency, were you living alone or with
another person?
A. The first half of my residency was alone, and
the second half was I had a roommate.
Q. Okay. And you did not use in front of your
roommate?

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A. No.
Q. So you said when you first began to use
fentanyl, you would steal it and then take it home?
A. Yes.
Q. Did I understand that properly?
A. Yes.
Q. And then would you also steal syringes or
obtain syringes for use?
A. Yes.
Q. And so how would you prepare the fentanyl?
Would it come in an ampule?
A. Yeah, either a glass ampule or, at some point
in time -- I don't know when -- they moved to more of a
vial with a rubber stopper in it. So one of those two
ways.
Q. The ampules were in what size during your
residency, if you recall?
A. I think there was 5-cc ampules. At some point
in time, there was also 20. And I can't remember if
they were 20-cc ampules or 20-cc vials. I just don't
recall.
Q. And so if you had an ampule, you'd simply
open -- crack off the neck and then insert the syringe?
A. Yeah. The needle.
Q. The needle.

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A. -- if that makes sense.
Q. Yes.
In other words, what you brought home generally
would have been the syringe as opposed to the ampule?
A. Yes.
Q. And were those syringes syringes that were
clean or syringes that had been used?
A. Clean.
Q. So then, when you injected it, was the
sensation from the fentanyl nearly instantaneous?
A. Yes.
Q. Describe it to us, please.
A. It's hard to describe. You get a little bit of
a rush and then soon followed by a relaxation. That's
the best -Q. When you say "a rush," any physical sensation
in your head? In your brain?
A. You'd feel a slight -- a slight chest tightness
and then -- oh, it's hard to put into words. I'm sorry.
Yeah, a slight feeling -- well, a feeling of euphoria.
That's the best way to say it.
Q. Now, the first time you used fentanyl, how long
did that feeling of euphoria last, if you recall?
A. I -- I -- I don't know.
Q. After your first use of fentanyl, gradually the

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A. To draw up the medication.
Q. How much did you use the first time you used
fentanyl?
A. To the best of my recollection, it would have
been minimal because I was nervous doing it. So
probably no more -- between 1 and 2 milliliters was what
it would have been.
Q. And did you inject it in your arm, or did you
inject it somewhere else on your person?
A. I -- oh, I don't recall where I injected the
first time. It probably would have been either the -it was either -- oh, you know, it was here (indicating).
It was there, yeah, it was.
Q. Into the vein?
A. Yes, into the antecubital fossa.
Q. And so you would suck up the appropriate amount
for use into the syringe, inject the syringe into the
vein?
A. Well, usually the -- I wouldn't -- usually it
was the diverted amount. So it was already in the
syringe. So I wouldn't at that point -- I wouldn't suck
out of the vial and then inject it. The diversion would
happen between that time and then -- then the
injection -Q. I see.

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dosage increased?
A. Yes.
Q. And you told me that within a couple of months,
then, you were addicted?
A. Yes.
Q. When you were addicted, that would have been
probably fall or early winter of the year 2003?
A. So I think around November is the first time I
used, and then, you know, it started off pretty slow
because, you know, I wasn't too happy with what I was
doing. I knew it was wrong and I shouldn't be doing it.
So it was infrequent at the beginning. But I would say
by halfway through, you know, maybe -- this is all
speculation. It would have been sometime towards the
latter part of my first year of residency is when the
frequency picked up.
Q. Okay. Now -MR. HEGELER: Residency runs from July 1 to -THE WITNESS: July to July.
MR. HEGELER: There you go.
MR. IREDALE: Very good, sir.
MR. HEGELER: Sorry to interrupt. Yeah.
BY MR. IREDALE:
Q. I just need to say this: I'm not permitted to
ask you to speculate, but I am permitted to ask for your

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best recollection and for your best estimate.
A. That's my best estimate.
Q. That's fair. And I appreciate it.
So it was around July 1 of 2004 that the
fentanyl usage picked up?
A. Oh, yeah. Yeah. Yes.
Q. During that period of time between November,
approximately, of 2003 and July the 1st of 2004, you
said you used infrequently.
A. Well, I honest -- I -- it's so long ago, I
can't remember how often I used, but I know, before the
end of my first year of residency, I was addicted.
Q. Fair enough.
Now, when you were addicted, I need to ask you,
during the first four months, five months of your
addiction, what was the average number of times that you
were injecting fentanyl per day?
A. Maybe -- I would -- to my best recollection,
three to five at that point in time.
Q. And all of the fentanyl you obtained from UCSD?
A. Yes.
Q. All of the fentanyl was diverted or stolen?
A. Yes.
Q. And, now, let me talk to you about the way in
which it was acquired.

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Q. Taking it to another place, either your home or
someplace at the hospital itself, and using it.
A. Yes.
Q. You said that there was a second way in which
you could obtain fentanyl. You said that involved
diluting and returning to the pharmacy.
A. Yes.
Q. Would you explain that to me, please.
A. So let's say you have 3 cc's of fentanyl left
over in the case. You could take 2 cc's out, replace
the 2 cc's with 2 cc's of saline, and return that to the
pharmacy.
So, I mean, if you always returned empty
syringes, that might be obvious. So if you returned
some diluted medication, then you wouldn't always be
returning empty syringes.
Q. The return of the diluted medication to the
pharmacy -- would that result in that medication being
used in the future or simply destroyed?
A. Destroyed.
Q. Who, at that time during your residency, would
destroy the unused anesthetic?
A. That, I don't know. It was -- someone within
the pharmacy would pick up our -- would pick up our used
medication at the end of the day, and then it would go

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You basically laid out for me three different
ways in which it could be obtained and then accounted
for.
A. Um-hmm.
Q. One, you say, is that after having obtained the
fentanyl, you would use part of it in the anesthesia.
A. Yes.
Q. And then you would have the medical records
reflect that it had all been used?
A. Yes.
Q. And so you know that that involved telling a
lie.
A. Absolutely.
Q. Falsifying a medical record.
A. Yes.
Q. And potentially putting a patient at risk
because that medical information is supposed to be
accurate.
A. Yes.
Q. And you did that on a daily basis at some
point?
A. Yes.
Q. And so that would result in your obtaining a
syringe which had only been partially used.
A. Yes.

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wherever it goes.
Q. And then you said there was a third way, is to
simply -- instead of diluting, simply turn in saline to
the pharmacy instead of the diluted fentanyl.
A. Yeah. Yes.
And then the other way would be kind of a
combination of -- well, let's say you have 10 cc's left
over. You take 2, turn 8 in, and then chart that. So
it wasn't always you turn in -- it would be all used.
You could still turn in normally concentrated fentanyl,
but you just said you gave 2 more cc's during the case
than you actually did. You'd still be returning a
syringe of fentanyl, if that makes sense.
Q. Yes, it does.
A. Okay.
Q. In other words, you would say that you had
given the patient more fentanyl that [sic] was actually
used -A. Um-hmm.
Q. -- and then take the portion -A. Yes.
Q. -- that was the difference between actual use
and what you reflected on the chart for your own
personal consumption -A. Yes.

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Q. -- is that right?
A. Yeah. I didn't always take all the leftover
fentanyl.
Q. All right. Now, during this time in your
residency, you would inject yourself while you were at
the hospital and on the job?
A. Yes. It -- I don't know when that first
happened. You know, it progressed from only at home to
maybe a couple times at home to at the end of the day.
And then -- as my addiction progressed and my tolerance
progressed, then eventually it -- that would happen,
yes, I would do it during the day throughout the day.
Q. Then let's talk about that.
You would shoot up in a bathroom, I take it?
A. Yes.
Q. And it would be a bathroom for the use of
physicians?
A. General -- any bathroom.
Q. And would these include bathrooms that would
later be used by patients?
A. Yes.
Q. Bathrooms with multiple stalls?
A. Generally I would try to use a private
bathroom.
Q. And so you would go into the bathroom with the

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Q. -- you then continued to be addicted for a
period throughout the residency?
A. Yes.
Q. And so on a daily basis you would obtain the
fentanyl from the hospital?
A. Yeah. There were periods of sobriety within
there where, you know -- where I would not use for -even for months at a time, and then it would always go
back to that.
Q. Well, let's talk about that for a moment.
What was the longest period after you became
addicted that you were able to abstain during that
period of your residency which ended in -- on June 30th,
2006?
A. To the best of my recollection, it would have
been three to four months.
Q. And after you became addicted on -- what was
the total -- you were roughly "addicted" addicted for a
little more than two years during your residency?
A. Total?
Q. Yes.
A. So two -- probably two -- out of my three years
of residency, probably, I would say, a year and a half
of that. Maybe a year and a quarter to a year and a
half was I using regularly.

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syringe?
A. Yes.
Q. Where did you keep the syringe when you would
go in to shoot yourself up?
A. A pocket of my scrubs.
Q. Then you would go inside the bathroom.
A. Yes.
Q. Inject yourself.
A. Yes.
Q. And then how long generally did that process of
injection take between the time you came in the bathroom
and then the time you would emerge?
A. A few minutes.
Q. Because you would feel the rush and you wanted
to feel that pleasurable sensation and enjoy it?
A. Well, once you're addicted, you don't really
have the rush that you used to have, and it becomes more
of a maintenance.
Q. Yes. In other words, it's like a need. It's
like something that has to be done, and you will be in
pain or discomfort if that need is not satisfied?
A. Yes.
Q. Once you became addicted toward the end of your
first year of residency -A. Um-hmm.

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Q. What was the largest number of injections that
you had in a single day during that period of addiction
for your residency? Best estimate.
A. Six to eight.
Q. And at your heaviest use, what was the largest
single amount of fentanyl that you would inject?
A. The largest I ever used was 10 cc's one time.
And I passed out.
Q. In the bathroom?
A. Yes.
Q. At the hospital?
A. Yes.
Q. How long do you believe that you had passed out
for?
A. Momentarily. It wasn't long.
Q. And then after having passed out, did you then
go out and resume your duties?
A. No. It was at the very -- it was at the end of
the day. I didn't -- I wouldn't use doses like that
during the day, just at the end, like, on the way out
the door.
Q. During the time you were addicted during your
residency, you treated patients under the influence?
A. Yes.
Q. And so you would be treating a patient while

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under the influence and from time to time stealing
fentanyl from that same patient?
A. Yeah.
Q. And then falsifying the patient's record?
A. Yes.
Q. Now, were you ever in a situation where you
believe somebody suspected you were stealing fentanyl?
A. Um -Q. During your residency.
A. Yes.
Q. Tell me about that.
A. Let me think about this for a second.
God. It would have been during my second year
of residency towards the end. I think people in my
department knew I was behaving differently, and I got
asked maybe -- I think there was a pharmacy discrepancy,
and I was asked, you know, "Is everything all right?"
"Is there any problems?" "Do you have anything you want
to tell us about?" "Did you -- I mean, is there any -do you have any opiate addictions or any other
addictions?" I was asked that one time during
residency.
Q. Who was it who asked you that, if you recall?
A. Oh, I believe it was Piyush Patel, one of the
attending anesthesiologists. He was my adviser. And I

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the anesthetic fentanyl?
A. I have -- I -- I cannot put a number on it.
Q. I will not press you except to this extent: It
would be fair to say that it would be hundreds. Yes?
A. Yes.
Q. Now, am I correct that at some point in 2006,
UCSD offered you a job as an attending anesthesiologist?
A. Yes.
Q. In other words, you had completed your
residency? Yes?
A. I was nearing completion.
Q. And you were well liked. Is that fair to say?
A. Well, I'd like to think that; but, I mean, it's
not -Q. Well, you're a nice person?
A. Well, sometimes. Generally.
Q. Well, here's what I want to say to you: We're
talking now about the worst parts of a person's life,
and you went into a federal court and admitted to that.
A. Um-hmm.
Q. That was not an easy thing to do, I'm sure.
A. No.
Q. Despite that, in your dealings with people in
conversations, in daily interactions, you were a nice
person?

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think it was communicated to him and then he
communicated it to me.
Q. Did he say who had talked to him?
A. No.
Q. And when he communicated that to you, that he
was concerned, and he was asking whether everything was
okay and asking, it appears, in an indirect way if you
had a drug problem -A. Yes.
Q. -- what was your response?
A. "Absolutely -- absolutely not." "No." Yeah, I
lied.
Q. You lied.
A. Did not tell the truth.
Q. And in that regard, your conduct was in no way
different from that of many -- many addicts that you
have come to know through AA?
A. Yes.
Q. Addiction comes with lying, or it brings it in
its wake?
A. They -- they're -- they hold hands.
Q. Yes.
Now, during your residency, best estimate,
would it be fair to say that you treated more than 500
patients while you yourself were under the influence of

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A. I tried to be.
Q. And you, as best as you could tell, were well
liked by those people who were your supervisors and
superiors?
A. Yes.
Q. And so you were offered a job.
Who offered you the job as an attending
anesthesiologist?
A. The chair of the department.
Q. Who was that?
A. Jerry Manecke.
Q. Now, I need to take a moment here and talk
about your relationship with Dr. Manecke.
When did you first meet Dr. Manecke?
A. I cannot remember if he interviewed me on my
resident -- or my visit for residency application but
for sure the first day of residency.
Q. Was he the head of anesthesiologists when you
began your residency?
A. No.
Q. When did he become the head of
anesthesiologists, if you know?
A. I don't know. I cannot remember.
Q. Did you see Dr. Manecke throughout your
residency?

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A. Yes.
Q. Would you see him on a daily basis?
A. No.
Q. Would you see him on at least a weekly basis?
A. It all depended on what hospital I was working
at -- working at, what rotation. There were
rotations -- there were times I probably wouldn't see
him for a couple months.
Q. And were the times when you did see him -would that be more frequent that you would see him
during the times that you were at a different hospital
or a different shift?
A. Can you repeat that.
Q. Yes.
In other words, you wouldn't see him for up to
two months, but then were there times when you saw him
frequently?
A. Oh, yeah. Yeah, depending on -- yeah, for
sure.
Q. What was the -- when you were seeing him
frequently, would you see him on a daily basis?
A. If I was working at the hospital he was working
at, I would see him if we were working the same days.
Sometimes he had days off and whatnot. But frequently.
Q. What was the general nature of your interaction

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to be an attending anesthesiologist.
Q. So did you say -- you said Dr. -- you believe
Dr. Manecke offered you the job?
A. I believe so.
Q. And what did you say to him in that regard?
Did you say "I'd like to accept it, but I need a little
time off" or words to that effect?
A. Essentially, yeah. I said, "I need some time
off to" -- I mean, I -- there was a couple things that
happened during the residency. Like, you know, my
brother died of cancer; and so, you know, I kind of used
that as one of the reasons that, you know, I need some
time off, just to get my head straight, essentially, so
that I could perform. I don't know if I used those
words directly to him, but that's kind of what I told
myself.
Q. And did Dr. Manecke agree that you could have
some time off before you began?
A. I kind of just said, you know, "I'll let you
know when I'm ready," and I kind of just didn't say
anything for a while, for a long time.
Q. When your residency ended -- that would have
been 30 June 2006?
A. '6, yes.
Q. When your residency ended, had you or had you

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with Dr. Manecke?
A. Well, unless I was -- unless it was -- I was -he was my attending anesthesiologist, which was
generally only when I did my cardiac anesthesia
rotation. It -- I would just see him in passing, small
conversations.
Occasionally I would have a noncardiac
anesthesia case where I was underneath him as the -- as
the resident, but I can't -- I can't put an exact number
on how -- the frequencies.
Q. You had friendly relations with him?
A. Yes.
Q. Now, have you ever seen him off the job in a
social setting?
A. Only a few times. Maybe anesthesia-related
functions.
Q. Such as Christmas parties?
A. Yes.
Q. You like him?
A. He's a very good man.
Q. Now, you accepted the job as an attending
anesthesiologist?
A. Well, not initially. Because I knew -- I was
not in a very good mindset, and I knew that what I was
doing was wrong. So I tried to be sober if I was going

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not accepted the job offer as an attending
anesthesiologist?
A. Just verbal. Nothing -- no formal acception.
Q. And when you had accepted it verbally, did you
say, "But before I begin, I want some time off"?
A. I -Q. If you recall.
A. I don't recall what I said.
Q. Did you take some time off?
A. Yes.
Q. And you decided to go home and stay in Omaha
for some time with your parents?
A. Yes.
Q. How long did you stay in Omaha with your
parents?
A. 16 months.
Q. During that time, did you use fentanyl?
A. No.
Q. Did you use an opiate of any form?
A. I took some of -- my mom had Vicodin, and I
took some Vicodin on a few occasions. Not very much
because she didn't have much. But yes.
Q. Orally?
A. Yes.
Q. Other than taking your mother's Vicodin, did

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you take any other controlled substances?
A. No.
Q. But during that time while you were with your
parents, you then went back to another substance abuse
practice that you had had, which was excessive drinking?
A. Well, the -- the time frame was -- I finished
residency, and I wasn't feeling too good about myself.
And I knew I could not continue my opiate addiction.
And I drank heavily. This is -- I was still in
San Diego for a time period, and I drank heavily for -I don't know -- a month plus.
And then I called my parents and said, "I have
to come home. I'm not doing well." And so then I went
home.
And for most of that time period, I didn't -there was a few times I drank, but I -- I basically -- I
had nine months of white-knuckle abstinence until I -and then -- until I got back to California.
Q. When you say "white-knuckle abstinence," you
were not in any program?
A. Exactly.
Q. You were not seeking counseling for substance
abuse?
A. No.
Q. You were doing it all on your own?

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There was about two months where I just kind of isolated
and drank by myself before I went home.
Q. And then at home did you drink excessively, or
were you able to avoid that while you were at home?
A. There was a couple times I got pretty drunk
but, you know, make -- I probably drank six times during
that 14 months.
Q. At some point, then, you began working as an
anesthesiologist at UCSD?
A. Yes.
Q. An attending anesthesiologist, no longer a
resident.
A. Yes.
Q. And when did that commence? Best recollection.
A. I can't remember the first day I started, but I
came, oh, some -- like -- for some reason,
November 26th sits -- sits in my head.
Q. November 26th, 2007?
A. Yes.
Q. Now, how long after you resumed work as an
anesthesiologist was it before you were using fentanyl
again?
A. Probably within a couple months. I can't say
the exact amount, but to the best of my recollection,
two months.

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A. Absolutely.
Q. You found it very hard?
A. Well, yeah, it's not fun.
Q. And "white knuckle" is, I believe, a term that
people in AA use from time to time?
A. Yes.
Q. Now, did you for several months drink
approximately a liter of vodka a day?
A. There was about one month I averaged that, and
that was when I was like "I got to go home."
Q. Now, let me just ask you, during your
residency, when you were using fentanyl, were you also
drinking?
A. At that time I would only drink on weekends,
for the most part.
Q. Now, you told me you took off 16 months between
the end of your residency and your beginning to work as
an anesthesiologist at UCSD.
A. Yes.
Q. And during that time, how many months were you
at your parents' home? Was that the nine months you
referred to?
A. No. Those nine months were part of it. I
would -- exact datewise, I don't know, but I would say
probably close to 14 of those months, the last 14.

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Q. Do you remember the time when you used the
fentanyl for the first time after you had returned and
then become an attending anesthesiologist?
A. Not specifically. I don't remember.
Q. And, of course, the pattern, then, repeated
itself. You began, then, to become addicted?
A. Yeah. Exact same pattern as before.
Q. And, now, let me ask if you recall during this
time had the manner of the dispensing of controlled
substances changed at UCSD, if you recall?
A. I cannot recall. I really can't. I wish I
could remember what -- how it was then. I think it was
the same as before where you still had the lockboxes
that you would check out medications from. To the best
of my knowledge, it was still the same.
Q. Now, may I just ask this: If you had a key to
the lockbox -A. Yes.
Q. -- why didn't you just go in the lockbox when
nobody was around, grab some, and lock it up again?
A. Why would you not do that?
Q. Yes.
A. Because you wanted to cover yourself. You did
not want -- let's say I go and use stuff out of the
lockbox. "Oh, Brad, you can go home right now. What

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happened to that 5 cc's of fentanyl?"

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You would only do it associated with certain
cases so you could cover your tracks.

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Q. And then the process of turning in the drugs

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that had not been used involved turning them over to

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another person from pharmacy?

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A. Well, you'd just -- you'd -- whatever was left

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over, you'd have a sheet with the amount of drugs you

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gave associated with the patient's medical record that

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record and the amount given and then the amount returned

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per case and for the overall day.

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MR. IREDALE: All right. We've been at it now

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for 59 minutes. So I was going to propose that we take

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about a five-minute break every hour.

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THE WITNESS: Okay.

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MR. IREDALE: Plan on taking, if we could, a

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45-minute break for lunch at 12:15.

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And then why don't we resume, if we could, in
five minutes. Thank you so much.

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MR. HEGELER: Thank you.

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THE VIDEOGRAPHER: Off the record at 11:14 a.m.

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(Recess)

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facility, Thornton, or both?
A. I believe both.
Q. What was her job?
A. She was a certified nurse anesthetist.
Q. Now, may I ask you, as a general matter, is
there a division of labor between the anesthetist and
the -- the anesthesiologist and the certified nurse
anesthetist?
A. Yes.
Q. Describe it to me, please.
A. They are -- the certified nurse anesthetist is
legally under our supervision, if that makes sense.
They're fairly independent providers, but ultimately
they have to have -- there has to be supervision from an
anesthesiologist.
Q. The reason for that rule, as you understand it?
A. The reason?
Q. Yes.
A. I think it just mainly has to do with
education. Not skill or anything like that. It just -safety because of we -- you know, we -- MDs have longer
education and more training.
Q. Well, as an MD, then, you went through
four years of medical school, an internship -A. Um-hmm.

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11:25 a.m.

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BY MR. IREDALE:

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Q. All right. Doctor, when you did your

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residency, was that done at the Hillcrest UCSD facility?
A. Several facilities. Mainly Hillcrest but also

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UCSD Thornton Hospital in La Jolla, the VA Hospital in

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La Jolla, and one month at Children's.

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Q. Then when you became an attending

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anesthesiologist --

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A. Yes.

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Q. -- beginning sometime in late November 2007 --

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A. Yes.

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Q. -- and up through July of 2008, where were you

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working?

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A. Generally Hillcrest but also Thornton Hospital,
those two.

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Q. Now, I need to ask you do you know a person
named Tammy Nodler?

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A. Yes, I do.

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Q. And how long have you known Ms. Nodler?

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A. I think, when I started, she was there when I

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started working as an attending, so

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November-Decemberish.

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Q. When you say "there," was she at the Hillcrest

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Q. -- and then multiple years of residency?
A. Yes.
Q. And what is the common training, if you know,
for certified nurse anesthetists?
A. They have to do at least a couple years of some
kind of critical care or acute care-related clinical
nursing. And then they go to their nurse anesthetist
school. And, gosh, if I remember, I believe it's
two years -- but it might be three, but I think two -two years of -- it's very similar to an anesthesia
residency but shorter. And then -Q. You've worked with Certified Nurse Anesthetist
Tammy Nodler for years?
A. Yes.
Q. On many, many cases?
A. Yes.
Q. Are you friends with her?
A. Well, I used to be.
Q. And did you have a relationship where you felt
that you could share certain things with her?
A. Yes.
Q. For instance, at one point did you tell her,
"Yeah, I was or am involved with an addiction to
fentanyl"?
A. Yeah, I -- I told her that I was addicted at

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one point in time when I was sober.
Q. And did you ever see her in a social context
outside the job?
A. On a few occasions.
Q. Nature of those occasions?
A. Mainly anesthesia related. But I think I went
out with some -- you know, just people from residency
and, like, a bar or something like that, just social.
Q. Do you know Dr. Allen?
A. Yes.
Q. And how long have you known Dr. Allen?
A. We -- he was -- I believe he did his orthopedic
residency the same time I did my anesthesia residency.
There was some overlap. So, you know, since then.
Q. How often have you worked with him since the
time you met?
A. Easily 50 or more times.
Q. Good relations with him?
A. Yeah. Cordial.
Q. All right.
A. Collegial. Not anything other than work
related.
Q. Not a close relationship or closer relationship
as you might have with Tammy Nodler, whom you saw more
frequently?

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also known as Special K, if you know?
A. Yes.
Q. And that is actually an anesthetic for animals.
A. And humans.
Q. Dilaudid. You said you've injected Dilaudid.
Best estimate, how many occasions?
A. I don't know. Well, a lot. I mean -Q. 200?
A. If that was available and fentanyl wasn't, if
we used Dilaudid for a case -- yeah, I don't know. I
cannot put a number. But a lot. Like, hundreds. How
about that?
Q. Fair enough. Hundreds.
You said you've used sufentanil twice?
A. Yes.
Q. Morphine. Best estimate, hundreds of times for
morphine?
A. Less than -- yeah, less than the Dilaudid.
Just whatever you use -- whatever case and whatever the
indicated opiate was, you would -- that's what I would
do.
Q. And then you said midazolam or Versed, which is
a benzodiazepine?
A. Yeah.
Q. Not technically an opiate, but a depressant?

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A. Yes.
Q. Now, let me, if I could, go back now to the
year 2008.
At some point in 2008, you became involved in
use of fentanyl and then addiction?
A. Yes.
Q. I need to ask you this as well: Other than
fentanyl, have you ever injected any other controlled
substances?
A. Yes.
Q. What?
A. I think I've injected ketamine on two
occasions. I've injected other opiates like Dilaudid,
sufentanil on two occasions, and morphine; and
midazolam, which is Versed, or benzodiazepine.
THE REPORTER: Which is a what?
THE WITNESS: Benzodiazepine.
THE REPORTER: What did you say before that?
THE WITNESS: Versed or -- yeah.
BY MR. IREDALE:
Q. Versed -- I think you said Versed or
midazolam -A. Midazolam.
Q. -- which is a benzodiazepine.
You said you've injected ketamine, which is

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A. Yeah, a controlled substance, depressant.
Q. Now, other than ketamine, Dilaudid, sufentanil,
morphine, and midazolam, any other drugs that you have
injected?
A. No.
Q. Any other controlled -A. Oh, yeah. I think I did dexmedetomidine, like,
maybe three or four times during the last episode of my
addiction. So that would have been in 2016, '17.
Q. All right. Help me, because that's a tongue
twister for me. Dexmededozaline?
A. Dexmedetomidine.
Q. Dexmedetomiline?
A. -tomidine.
Q. -tomidine. Dexmedetomidine?
A. Yes.
Q. All right. Now, how many times did you use
dexmedetomidine?
A. Five.
Q. And what is dexmedetomidine?
A. What is it? It's an alpha-2 agonist. It's a
sedative.
Q. And used in anesthesia?
A. Yes.
Q. I take it all of the drugs that we've been

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speaking of -- ketamine, Dilaudid, dexmedetomidine,
morphine, sufentanil, midazolam -- all of those were
drugs you obtained from the hospital?
A. Yes.
Q. You've never gone out and bought drugs?
A. I have never bought pills or heroin or any
drugs off the street -Q. And, of course -A. -- as far as opiates.
Q. Yes.
Marijuana?
A. I've had marijuana.
Q. Other than marijuana, any drugs you bought off
the street?
A. I've done cocaine. I've done -- what else?
Ecstasy. Those other ones.
Q. Well, ecstasy is an empathogen and an
entactogen and is used -- could be used in therapy.
A. Yeah.
Q. So -- and cocaine is a party drug.
A. Yeah.
Q. But you never were under the influence of
cocaine at your work?
A. (Shakes head.)
Q. The midazolam, best estimate, use in the 20s?

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attending anesthesiologist.
And as I understood your answer, you worked
both at UCSD Thornton and Hillcrest?
A. Yes.
Q. Was there one of those locations that was more
regular for you than the other?
A. They were close. It's hard -- I don't know.
Q. May I ask you a question: During 2008, how
many cases would you average per day in which you
administered anesthesia?
A. It would depend on if I was working by myself
or if I had a resident or a CRNA under my -- or -- or
more -- under my supervision. So -Q. Fair enough. Let me break it down, then.
If you were working by yourself, the average or
typical number of cases that you would do in 2008?
A. Three to four.
Q. And then if you had a resident and a CRNA
available to work with you?
A. On average -- just double that.
Q. Six to eight?
A. Yeah, probably, yeah.
Q. Now, when you worked by yourself during that
time, you would be the only person who was involved in
the anesthesia aspect of the surgery?

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40s? hundreds?
A. Tens.
MR. HEGELER: Mr. Iredale, can we just -- I
want to show him something here.
MR. IREDALE: Of course.
MR. HEGELER: Ask if it refreshes his -What about this?
THE WITNESS: Oh. Yeah. Modafinil. It's a
prescription drug.
BY MR. IREDALE:
Q. But it's a stimulant.
A. Yes.
Q. It's like Adderall?
A. Not quite. It's not a -- it's not an
amphetamine. It more acts like caffeine, I believe; but
it's stronger than caffeine.
Q. Yes.
And I think you actually began using Modafinil
in 2016.
A. Yeah. That's what kind of set off the whole
chain of events.
Q. Let me now, in an attempt to organize myself
clearly and chronologically, go back to the year 2008.
A. Yeah.
Q. During this time, you were working as an

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A. Minus a break, like, if you were breaked.
Someone would give you, like, a lunch break or a
bathroom break. But yeah.
Q. And then if you had a CRNA working with you or
a resident as well working with you, what would be your
general pattern of work?
Is that a clear question?
A. Like -Q. In other words, what -- if you had your CN- -CRNA and a resident, would there be a generally
applicable division of labor or responsibility?
A. Yes.
Q. Tell me what that was.
A. Well, we tried to let our residents and CRNAs
do as much as possible under supervision; but, you know,
you would watch them do the whole case, essentially, and
help -- help them if they needed help. But other -- and
you were around at all important parts of the case:
induction, incision. If it were -- or if it was a
complicated procedure, you were there more often. If it
was a less complicated procedure, you were there a lot
less.
If someone was a good nurse anesthetist, you
would pretty much leave them alone. If they were not,
you would be in the room more often. And same with the

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residents. You have people that just started, and you
have residents that have been there and about ready to
graduate -- graduate.
So it -- the main things are you are there on
the important aspects of the case and then gave it some
autonomy throughout the rest.
Q. And the important aspects, from your point of
view -- you said induction is -A. Yeah, induction.
Q. Incision?
A. Induction, intubation. Often you would wait
till after incision to leave the -- or you'd come back
to the room for incision, depending on the case. If you
were getting a little mole taken off, it wouldn't be
that big of a deal. And if patients were sick, you
would be in the room a lot more.
When they're -- when they're getting ready to
start waking up the patient to make sure everything is
okay -- that's called emergence -- and then extubation,
you would want to be there if at all possible at those
times. Not -- you weren't always there for all that,
but those were the -- those are the important times
during a procedure.
Q. Now, if you had a CRNA and a resident, would
there be times when there were two procedures going on

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immediate and decisive way?
A. Um-hmm.
Q. "Yes"?
A. Yes.
Q. And forgive me. I -- I didn't go through the
normal drill, but "Um-hmm" or "Hmm-um" sounds very
similar.
A. It's not going to -Q. And I'm certain that your lawyer, who is
skilled, respected, and the dean of the San Diego Bar,
would have talked to you about this before, in any
event. So forgive me for bringing it up.
A. Okay. Sorry. And I know better.
Q. Were there occasions when procedures were going
on in which you would go to the bathroom, inject
yourself, and come back out?
A. Yes.
Q. Was that frequent when you were under your
addiction?
A. Yes.
Q. Would it be true that during the times when you
were addicted, you would be under the influence for the
treatment of patients throughout your entire shift?
A. Yes.
Q. Now, in 2008, at some point did somebody say to

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simultaneously which you were to be supervising?
A. Yeah, off -- I mean, we always covered a
minimum of two people, whether CRNAs -- sometimes we
would cover more even, especially at the end of the day.
Q. And when you say "cover," in other words,
there's a CRNA in one operating room, possibly a
resident in another, and you're required to be
supervising in two places?
A. Yes.
Q. Did you have a monitor or a room which you
would use to be able to watch via video what was going
on?
A. No.
Q. You would have to shuttle back between one room
and the other?
A. Yeah. And then you'd be available via pager so
you could react in a minute or two or less, hopefully.
And then there's other ways. Let's say something bad
was going on. They could do an overhead call, and then
you and -- for you or who -- whatever anesthesiologist
or anyone available.
Q. And from time to time emergencies would occur,
I take it?
A. Yeah. Yeah.
Q. And you would be summoned and have to act in an

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you that they believed you were using drugs?
A. Yes.
Q. Would you describe to me where that occurred.
A. I believe it occurred in, like, a UCSD medical
office in La Jolla. Not at the hospital, but kind of
was several people from the Well-Being Committee. And
then our department chair at that time told me I had to
be there. And I had a -- I knew what it was about.
Q. All right. In other words, you were told to
show up at a particular place?
A. Yes.
Q. And at a particular time?
A. Yes.
Q. And you said that there were several people
there?
A. Yes.
Q. Who were the people that you remember being
there?
A. The chair of the department.
Q. Was that Dr. Manecke at that point?
A. I believe so, yeah.
And then Robin Seaberg. She is another
anesthesiologist of the Well-Being Committee.
Dr. Chavez, Shannon Chavez. She was the head
of the Well-Being Committee.

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And I think that was who was there at that
point in time.
Q. You went into the room?
A. Yeah.
Q. And tell me what was said.
A. Can't come up with exact words, but the general
line of questioning and commenting was, "Are you okay?"
It started out like that. And then, "What's going on
with you?"
And then I lied. "I'm depressed. I'm this.
I'm that. There's things going on," like that.
And then they're like "Well, we have reason to
believe that you're diverting drugs."
Of course, I denied, denied, denied.
And then it ended up, "You have to be at Betty
Ford for an evaluation on this date, or we're going to
fire you and tell the Medical Board," essentially.
Q. Who conducted the meeting, if there was
somebody who generally spoke more than the others?
A. Probably -- probably Shannon Chavez.
Q. Was Dr. Manecke present throughout?
A. I believe so.
Q. He heard you deny that you had a substance
abuse problem?
A. Yes.

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did you admit that you had a drug addiction problem?
A. Yes.
Q. And did you disclose the nature of that drug
addiction problem?
A. Yes.
Q. All right. And during the time you were there,
you engaged in, among other things, treatment?
A. Yes.
Q. And that involved 12-step or 12-step-like
program?
A. It was 12-step-based rehab.
Q. And it involved disclosure and honesty on your
part?
A. Yes.
Q. You admitted during the course of that the
nature of your addiction?
A. Yes.
Q. The amount of drugs that you had been using?
A. Yes.
Q. The fact that you had been using on a daily
basis?
A. Yes.
Q. That you had been stealing?
A. Yes.
Q. That you had been falsifying medical records?

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Q. He heard you deny that you had diverted drugs?
A. Yes.
Q. He heard you give an excuse that any unusual or
noticeable behavior was the result of depression or some
other problem, not drug addiction?
A. Yes.
Q. He heard you lie?
A. Yeah.
Q. And you were ordered to report to the Betty
Ford Center?
A. Yes.
Q. And you did so?
A. Yes.
Q. May I ask if you recall when that was in 2008,
approximately.
A. Oh, I remember. July 3rd.
Q. July 30?
A. 3rd.
Q. 3rd.
A. Yes.
Q. The day before the Fourth of July.
A. Yes.
Q. And how long were you at Betty Ford?
A. Four months.
Q. When you went to Betty Ford, can you tell me

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A. Yes.
Q. That you had been treating patients under the
influence?
A. Yes.
Q. And you stayed there four months?
A. Yes.
Q. And then you returned to work at UCSD in 2008,
November of 2008, I believe.
A. I got out the day before Halloween.
Q. So you went in -(Simultaneous colloquy)
THE WITNESS: -- the day -- yeah, I got -Fourth of July and Halloween.
BY MR. IREDALE:
Q. The day before the Fourth and the day before
Halloween.
A. That's how I can remember 'em.
And I think it took a couple months for me to
start back at work so I could get, you know, acclimated
to being sober in San Diego and try to develop some
connections within recovery population and then -- so
yeah. And then I started back to work slowly, and they
brought me along slowly.
Q. And when you say "they," are you referring to
the Well-Being Committee?

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A. The Well-Being Committee and those
knowledgeable of my situation within the department.
Q. And those knowledgeable within the department
were Dr. Manecke among others?
A. Yeah. I still to this day don't know who knew
what or what. So -- but, yeah, people that did the
scheduling. I think a lot, a lot of people knew, but I
don't know for sure.
Q. All right. Well, I don't want you to
speculate, but let me ask who, in your mind, you believe
knew.
A. Jerry Manecke. Robin Seaberg, because she was
on the Well-Being Committee. I would assume Leon Chang.
He was the -- I believe, the clinical director at that
time. After that, it would all be pure speculation.
Q. Then why don't we leave it at that.
A. Okay.
Oh, Anush Minokadeh, because he was -- he
actually -- I'd have a work site monitor.
Q. How do you spell Mr. Aminokadeh's [sic] last
name, if you know?
A. M-i-n-o-k-a-d-e-h.
Q. And he was your monitor?
A. Yeah, he was a work site monitor.
Q. Tell me what a work site monitor does.

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Q. Which would be a time period during which you
felt abnormally increased activity or energy for at
least four consecutive days?
A. Yes.
Q. And it also involved feeling such as a
decreased need for sleep?
A. Yes.
Q. Being more talkative than usual?
A. Yes.
Q. Flight of ideas or subjective experience that
thoughts are racing -- did you ever have that?
A. Yes.
Q. Distractibility?
A. Maybe not -- that, I don't know. I don't
believe so.
Q. And excessive involvement in activities that
have a high potential for painful consequences?
A. Yes.
Q. And then -MR. HEGELER: Mr. Iredale?
MR. IREDALE: Yes.
MR. HEGELER: Could I have just a moment. I
need to take a call. I apologize.
MR. IREDALE: Of course. Why don't we suspend
for a couple of minutes. That's fine.

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A. You have to meet with him. And basically how
are you doing, put a pair of eyeballs on you so that
they could hopefully detect behavior changes or things
like that ahead of time, before the problem is
discovered other ways.
Q. Now, at Betty Ford, you were given a diagnosis?
A. Yes.
Q. One of -- well, the diagnosis that you were
given was Bipolar II disorder?
A. Yes.
Q. And in that regard, you began to see a
psychiatrist when you got out of Betty Ford?
A. Yes.
Q. Bipolar II is a diagnosis in the DSM-5.
Are you familiar with that?
A. (Nods head.)
Q. Yes?
A. Yes. Sorry.
Q. And so it talks about, in DSM-5, that the
diagnostic criteria involved, in part, the occurrence of
what's called a hypomanic episode?
A. (Nods head.)
Q. Did you experience from time to time hypomanic
episodes?
A. I believe so.

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MR. HEGELER: Super. Thanks.

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THE VIDEOGRAPHER: Off the record at 11:53 a.m.
***

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LUNCHEON RECESS

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***

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THE VIDEOGRAPHER: We are back on the record at

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12:56 p.m.

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BY MR. IREDALE:

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Q. Before we started, Dr. Hay, your attorney told

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me that there was something you felt you should correct

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in order to avoid any misleading inference or

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appearance.

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So you -- please feel free to do that.
A. So I wanted to clarify when and -- well, kind

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of how I became under suspicion. And there -- we only

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spoke of one time, and there was a second time. So I

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just didn't want anything to get missed. And I kind of

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combined them into one, even though they're -- not

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completely, but part of 'em. And so I just wanted to

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make sure that there -- these two things are two

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separate events.

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Q. Thank you. I appreciate your conscientious
focus on accuracy.
So in light of that, let me ask you some
additional questions.

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A. Yes.
Q. You said that there were actually two incidents
that were involved in the discovery by others of your
substance use.
Let's talk about the first one. Can you tell
me about that first incident.
A. So the first one was the Piyush Patel one where
I -- he asked me, kind of took me aside, "Is everything
going okay? What's going on with you? Are you" -- and
he never outright asked me whether I was using or doing
this or doing that, just "People are questioning your
behavior a little bit."
And I just said, "Oh, you know, my brother is
really sick. My mom's crazy." And I just came up with
a bunch of excuses to deflect.
So that was the first time.
Q. Yes, sir.
May I ask was Mr. Patel a fellow
anesthesiologist, or was he in some other area of
medicine?
A. He was an anesthesiologist. He was, like, my
mentor or whatever. You get paired up with an attending
adviser. "Adviser" -- that's the correct word.
Q. Very good.
So that was the first time. And he expressed

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It was more of a formal sit-down. "There's behavioral
questions. We want to make sure everything is okay. Is
there anything going on? Are you -- is there any
substance abuse problems?"
And I denied, denied, denied, denied. And they
gave me a drug test, for which I was clean. And then I
had several drug tests afterwards throughout my -- the
rest of the residency.
So I believe that was pretty -- right around
the time my brother had passed. So it was sometime
during my third year of residency that they did that.
And I got drug tested for the last several months, and I
believe -- I mean, everything was clean at that point in
time. I really cut down my usage, obviously, so I
wouldn't fail a drug test.
Q. Yes.
So there was actually a meeting with the
Well-Being Committee -A. Not the whole committee. A few members.
Q. And the few members you mentioned included
Shannon Chavez?
A. Um-hmm.
Q. And as I understand it, she was the Well-Being
Committee head?
A. Yes.

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interest or curiosity or even suspicion.
Would that be fair?
A. He wanted to make sure -- I didn't -- I can't
speak to his suspicion or what he was suspicious of, but
that he expressed concern.
Q. Now, did he mention to you anything that he
felt had led to his questions? That is, that he had
seen some physical symptom or some behavioral conduct?
A. I believe that someone else had spoken to him
about behavior or that kind of thing. I don't -- I
can't speak to what he was told, when or how or who said
it or how many or if it was one. I don't know.
Q. All right. Now -- and then you said there was
a second incident where this came up.
And this was the incident at which you were
asked to come to the meeting?
A. So yeah. So I just wanted to clar- -- because
we also got into when I was an attending. And so I
went -- I got -- I went to the Well-Being Committee as a
resident as well. That's where I was sat down. I
believe it was Dr. Manecke; Robin Seaberg, who was the
anesthesia person on the Well-Being Committee; Shannon
Chavez; and then another gentleman -- I cannot remember
his name -- that were part of the Well-Being Committee.
And they said, "There's behavioral questions."

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Q. And then was Robin Seaberg at that meeting when
you were a resident?
A. Yes.
Q. And she is an anesthesiologist?
A. Yes.
Q. And who else was present that you remember
other than Shannon Chavez and Robin Seaberg?
A. I know Ben Atwater was there. He was our
residency director at the time. And then I would -- I
want to say Dr. Manecke was there, but I cannot
remember.
Q. And in any event, the committee -- strike that.
It was not the entire Well-Being Committee. It
was some smaller number of persons.
A. Yes. They never throw 15 people in front of
you. I mean, they would just scare people to tell the
truth.
Q. Yes.
And as I understand it, in addition to asking
you questions, they asked you to take a drug test?
A. Yes.
Q. And was that in the form of a request, or was
it in the form of an order, if you recall?
A. A -- it felt like an order, but it was a
request.

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Q. And you said that you passed the drug test.
A. I mean, no one -- they never told me my results
of the drug testing, but I'm assuming I passed.
Q. And you said for several months thereafter you
were tested?
A. Um-hmm.
Q. Yes?
A. Yes.
Q. And can you tell me was that on a random basis?
A. They would basically page me, I think, and say,
"Hey, I need you to go take a drug test."
Q. The frequency of the testing, if you can
recall?
A. Don't know. I can't -- I don't know. At
least -- more than twice a month, I believe.
Q. And you said that the testing, then, took place
over a period of several months.
Did I understand that properly?
A. Yeah.
Q. Yes?
A. Yes. Sorry. I keep doing that.
Q. And you were able to pass all of the tests,
apparently?
A. Yes.
Q. Were you using during that time?

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A. Yes.
Q. Before we broke, we were talking about the stay
at Betty Ford in the year 2008, July the 3rd through
October the 30th of 2008.
A. Yes.
Q. And you said that while there, you participated
in therapy and received a diagnosis of suffering from
Bipolar II disorder.
A. Yes.
Q. I had gone through some of the criteria in the
DSM-5 regarding a part of that diagnosis having to do
with the occurrence of a hypomanic episode, and I was
going to talk about the other criteria and ask you some
questions about those. Those involve a major depressive
episode.
And as you understand it, both of those things
are necessary for a diagnosis of Bipolar II?
A. Yes.
Q. And do you believe that you had suffered from
Bipolar II disorder for a matter of some years at least
as of the time you went to Betty Ford?
A. Yes.
Q. You were told that -- strike that.
The DSM-5 says that the criteria for a major
depressive episode includes depressed mood most of the

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A. Yes.
Q. And how do you believe you were able to have
continued your fentanyl use and maintained the ability
to get past the urinalysis?
A. I would only do it on a Friday. So it was out
of my system by Monday.
Q. Oh, and I should have asked you: The tests to
which you were subjected, I take it urinalysis?
A. Yes.
Q. You said that at that meeting with a number of
persons, including Robin Seaberg, Shannon Chavez, and
Ben Atwater -A. Um-hmm.
Q. -- you believe but are not sure that
Dr. Manecke was there.
A. Yeah.
Q. Did I understand that properly?
A. Yes. But -- yeah. I believe. But -Q. And then that was while you are a resident.
Between your residency and the time you
actually began as an attending anesthesiologist, you
told us about the 16 months that you took off.
A. Yes.
Q. And that during that time, you were able to
maintain, at least with respect to fentanyl, sobriety.

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day nearly every day for a period of two weeks or more.
Did you have that at one point?
A. Yes.
Q. Markedly diminished interest or pleasure in all
or almost activ- -- most all activities during the day?
A. Yes.
Q. Significant weight loss when not dieting or
weight gain when not attempting to gain weight?
A. No.
Q. Insomnia or hypersomnia nearly every day?
A. Yes.
Q. Psychomotor agitation or retardation nearly
every day?
A. Yes.
Q. Fatigue or loss of energy nearly every day?
A. Yes.
Q. Feelings of worthlessness or excessive or
inappropriate guilt nearly every day?
A. Yes.
Q. Diminished ability to think or concentrate or
indecisiveness nearly every day?
A. No.
Q. Recurrent thoughts of death or suicidal
ideation?
A. There were time periods where I had CD --

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suicidal ideation.
Q. Now, at some point were you also given a
diagnosis of opioid use disorder?
A. Yes.
Q. And are you familiar with the diagnostic
criteria for that disorder?
A. Yes.
Q. I need to ask you some questions about that.
According to the DSM-5, the criteria for opioid
use disorder include, among other things, that opioids
are taken in larger amounts or over a longer period than
was intended?
A. Yes.
Q. There is a persistent desire to cut down or
control opioid use?
A. Yes.
Q. A great deal of time is spent in activities
necessary to obtain the opioid, use it, or recover from
its effects?
A. Yes.
Q. Craving or a strong desire or urge to use
opioids?
A. Yes.
Q. Recurrent opioid use resulting in a failure to
fulfill major role obligations at work, school, or home?

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withdrawal syndrome or opioids are taken to relieve or
avoid the withdrawal syndrome?
A. Yes.
Q. There is also a diagnostic criteria set forth
for what is called opioid intoxication, and I would like
to discuss those criteria with you.
One is recent use of an opioid.
The second is clinically significant
problematic behavioral or psychological changes such as
euphoria followed by apathy, dysphoria, psychomotor
agitation or impaired judgment that developed during or
shortly after opioid use?
A. Yes.
Q. Pupillary constriction (pupillary dilation due
to anoxia from severe overdose) and one or more of the
following signs or symptoms developing during or shortly
after opioid use: drowsiness or coma, slurred speech or
impairment in attention or memory?
A. Probably the -- I'd say the attention and the
memory wasn't really -- I think I took too much to where
I was in a coma once, but it was briefly -- as a
resident. So the -- I don't know how you would define
that. There wasn't -- other than that, it didn't occur.
And what was the first one?
Q. Well, actually, let me break that down.

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A. Yes.
Q. Continued opioid use despite having persistent
or recurrent social or interpersonal problems caused or
exacerbated by the effects of opioids?
A. Yes.
Q. Important social, occupational, or recreational
activities are given up or reduced because of opioid
use?
A. Yes.
Q. Recurrent opioid use in situations in which it
is physically hazardous?
A. Yes.
Q. Continued opioid use despite knowledge of
having a persistent or recurrent physical or
psychological problem that is caused or exacerbated by
the use of the substance?
A. Yes.
Q. Tolerance as defined by one of these two
things: A need for markedly increased amounts of
opioids to achieve intoxication or desired effect and/or
a markedly diminished effect with continued use of the
same amount of an opioid?
A. Yes.
Q. And then, finally, withdrawal as manifested by
either of the following: The characteristic opioid

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A. Pupillary was -- oh, sorry.
Q. Pupillary constriction is one of the signs or
symptoms?
A. That wasn't readily obvious in me.
Q. And then drowsiness?
A. I would attempt to only use -- I wouldn't want
to be drowsy. I would not want to be obviously -obvious drowsy. So I would only do that at home or
before I went home. But -- so there were times I was
drowsy.
Q. Slurred speech?
A. I can't answer that.
Q. Impairment in attention or memory?
A. Yes.
Q. And I need to ask you was one of the uses for
the Modafinil -A. Um-hmm.
Q. Was one of the uses for that to give you a
stimulant at the same time you were under the influence
of an opiate so that you would be able to maintain
consciousness?
A. No. They were separate. So the -- it was soon
after I had a baby, and sleep deprivation and working
too much and just not taking good care of myself led me
to order that from -- I had it shipped over from India.

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And I took that and then started actually to abuse it
and then stopped or ran out of it. And then there was a
time -- few-month time period, and then after that I
picked up the opiates again.
Q. Now let me also discuss with you opioid
withdrawal.
From time to time, you would be able to cease
your use of the fentanyl.
A. Yes.
Q. During those times, did you suffer symptoms of
opioid withdrawal?
A. Yes.
Q. And did those include a dysphoric mood?
Feeling sad or depressed?
A. Yes.
Q. Nausea or vomiting?
A. No.
Q. Muscle aches?
A. No.
Q. Lacrimation, meaning tearing or rhinorrhea?
A. No.
Q. Pupillary dilation or sweating?
A. Some night sweats.
Q. Diarrhea?
A. No.

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A. Okay.
Q. Let me ask you now to recount what you recall
of that meeting when those three persons, which included
Dr. Manecke, came to your house in 2008.
A. Okay. So the night before -- oh, was it the
night before? So there was suspicion based on pharmacy
alter- -- record alterations that I had been diverting.
And then the following day, I had called in sick to
work, and then that raised their suspicions as well.
And then I got a call from one of them -- I
can't remember which -- and I didn't answer on purpose
because at that point in time I figured I was caught.
And then they kept calling and calling. And then -because they -Then they had a well -- a well-being check from
a police officer come by.
And I said, "No, I'm fine. I'm okay."
And then either that day or the next day they
came -- they stopped by where I was living, the house
where I had several roommates. And then -- so that's
when they confronted me about my opiate use.
Q. And now let me ask you, then, the three people
that you recall being there at that meeting at your
home. Or -A. I think it might have only been two. I don't

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Q. Yawning?
A. I don't know.
Q. Fever?
A. No.
Q. Insomnia?
A. Yes.
Q. Now, I would like to go back to briefly discuss
with you the meeting that you had with members of the
Well-Being Committee after you were directed to come to
a meeting, and this would be the second meeting which
occurred in 2008 before the referral to Betty Ford.
A. Okay.
Q. Dr. Manecke was at that meeting, and you are
sure of that?
A. So this is where -- this is where I got
confused. So the -- the -- we need -- meeting -- the
Well-Being actual Committee meeting was that one during
residency, but this time it was actually Ben Atwater and
Robin Seaberg and Manecke came to my house.
Q. All right. Good. Now, let's do this so that
we can make sure that we're clear.
A. Yeah.
Q. And, again, I thank you for your scrupulosity
in stating the facts, and I understand that some years
have passed. So there's no suggestion of any blame.

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know. But Manecke and Seaberg for sure.
Q. All right. And then possibly someone else?
Shannon Chavez?
A. No, not -- that one at my house, I believe, was
only Robin, who was on the Well-Being Committee; and
then Dr. Manecke.
Q. All right. And then tell me as best as you can
remember everything that happened during that meeting
with Robin and Manecke.
A. There was a -- I, like -- I think I forged a -which is weird. I forged a vial of fentanyl that fell
on the floor and just absolutely disappeared. Me and a
resident were actually looking at it for a long period
of time, and I just couldn't find it. And so I was,
like, "What do I do?" And it was weird. It was the
actual fentanyl I didn't -- I didn't use.
Q. You were actually innocent of any wrongdoing?
A. This time. But I forged that it was -- that it
was wasted in front of somebody. And then that -- I
think they had their suspicions leading up to it, but
then that was inaccurate, and I got caught based on
that.
And then they came to my house, confronted me.
Of course, I denied, denied, denied. And that's when
they game me the ultimatum, "You have to go to Betty

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Ford, or you're fired and we're calling the Medical
Board."
And then I was like "Okay."
And so then the next day I was at Betty Ford.
Q. Then we've -- we've covered, I think, the
approximately four months' stay that you had at Betty
Ford.
A. Yes.
Q. And then, as I recall your testimony, at the
end of November, you then came back to work?
A. Sometime around then.
Q. And when you came back -- well, let me ask a
couple of things.
One, was your treatment at Betty Ford, to your
knowledge and with your consent, disclosed to anybody at
the hospital?
A. That, I can't answer. The -- I knew the major
players in my department knew about it, but then at that
time I -- I don't know, but I don't think it was
disclosed to the rest of the hospital. I think it was
kept within the department, and the, I think, Pharmacy
Department knew about it or -- or knew something about
it, at least the discrepancy, and I don't know what they
knew about beyond that.
Q. All right. Fair enough.

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A. Yes.
Q. Was Leon Chang on the Well-Being Committee?
A. No. He was our clinical director of
anesthesiology.
Q. And Anush Minokadeh -A. Minokadeh.
Q. -- Minokadeh -- was he on the Well-Being
Committee?
A. No.
Q. What was his role in monitoring you?
A. I had to pick someone who I worked with
regularly and disclose, you know, why I wanted -- why I
needed a work site monitor, and then they had to agree
to it. And then I think he would report every three
months and then -- unless there was a behavior change in
the meantime -- to someone on the Well-Being Committee.
Q. And you did not know to whom?
A. Well, it's a small committee. So probably all
of them would get a copy of the report. I don't -- I
don't know.
Q. All right. And then, when you came back, you
understood that it was important from the point of view
of public safety that your conduct be monitored?
A. Yes.
Q. And that it was important that you be held to

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Within your department, let's talk about your
understanding of what Dr. Manecke knew.
Did you at any point talk to Dr. Manecke and
disclose to him what had occurred at Betty Ford?
A. I disclosed it to my doctors' group at the
Well-Being Committee and members of the Well-Being
Committee. I didn't feel the obligation to throw my
life story to everybody, but I told people through the
Well-Being Committee. So they knew. But the specifics
of the addiction was not discussed.
Q. The fact of the addiction, the general nature
of it, and the treatment was discussed, but not
necessarily -A. The extent.
Q. -- the particular details?
A. The extent. I didn't want to talk about how
much because I felt bad about it. But it was -- I mean,
with those players, it was -- they had knowledge of what
went on.
Q. Now, let me ask you was Dr. Manecke on the
Well-Being Committee?
A. No.
Q. Robin Seaberg was on the Well-Being Committee?
A. Yes.
Q. And she was an anesthesiologist?

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certain standards of conduct?
A. Yes.
Q. And you agreed to that?
A. Yes.
Q. What was done that you know about to monitor
your conduct?
A. So to monitor -- so I already discussed the
work site monitor.
Q. Yes.
A. Secondly, I had drug tests, random drug tests,
I think once -- it was either once a week or once every
two weeks at that time. God, I can't remember. Yeah,
random drug tests. I would have to check in online or
call the number every single day and randomly get
assigned to -- to go to the bathroom in a cup.
I was attended -- required to attend 12-step
program meetings, have a psychiatrist, have a
psychologist.
What else? Just -- yeah. I think that was
mainly it.
And then I had to attend a once-a-week group
meeting with other monitored physicians.
Q. And were those other monitored physicians all
from UCSD, or were they from the San Diego County area?
A. A majority were UCSD, but there was those from

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elsewhere.
Q. Now, were there any drug tests which you failed
in the year 2009?
A. (Shakes head.)
Q. 2010?
A. No. No.
Q. 2011?
A. No.
Q. 2012?
A. No.
Q. When did the drug testing regime stop, if at
all?
A. I -- after three years, the drug testing was
cut in half. Supposedly that's the standard for a
physician monitoring at the time. So it went from once
a week to once every two weeks, but I still had to check
in every day.
After -- over five years in the -- from signing
on to the program, that was when I was able to,
quote/unquote, "graduate," and then to no longer being
monitored.
Q. So at that five-year mark, there was no longer
somebody monitoring you on a regular basis that you know
of?
A. No.

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yourself and your sobriety through 2013?
A. Yes.
Q. Now let's go to the year 2014.
How about 2014?
A. Sober.
Q. During 2013, did you continue, on your own but
without compulsion, to attend any 12-step program?
A. Yeah, I went to meetings. It started -everything slowly started dwindling away after maybe
six months to a year, somewhere around there.
Q. And during that 2013 period, did you continue,
albeit at a lesser frequency, to see your therapist?
A. Yes.
Q. Did you continue from time to time to go to the
monthly meetings?
A. No. We -- you kind of didn't -- at that point
in time, you didn't -- oh, the monthly meetings? Which
ones?
Q. Of the impaired doctors, or the substance abuse
doctors?
A. That was a weekly meeting.
Q. I apologize. I misunderstood.
A. Okay. Gotcha. So I was a little confused
about what you were referring to.
So that's a weekly meeting. But, no, you no

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Q. No longer any drug testing?
A. No.
Q. No longer any requirement for psychiatric or
psychological treatment?
A. No.
Q. And no longer any requirement for the monthly
meetings with other doctors who were dealing with
substance abuse issues?
A. Yeah. Correct.
Q. And no longer any requirement for a 12-step
program?
A. Correct.
Q. When did that five-year mark and the cessation
of all of these requirements occur?
A. I think it went a little over five years. I
can't -- I can't tell you the date. I'd have to look
back at the records. I won't -- I haven't seen them,
but I -- I don't know what the reported date was, but it
was over five years, I would say. So it was
October 30th. It was sometime November or December five
years later.
Q. And so that would have been in late 2013 or
early 2014? Would that be fair?
A. Yeah, late 2013, I'm assuming.
Q. All right. And then were you able to maintain

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longer go there because they're -- an anonymity thing.
It's, like, they're in it. You're no longer in it.
Just to keep everyone comfortable, once you've finished
the program, then -- then you're no longer required to
go to that.
Q. And the testing regime had completely ceased as
of 2013?
A. Yeah.
Q. 2014. Are you seeing a therapist at all?
A. Probably not, no.
Q. 2014. 12-step program attendance?
A. Dwindling.
Q. Anything else that you were doing in 2014 to
actively work on your continued sobriety?
A. I just tried to exercise, but no 12-step, no -no active recovery.
Q. In 2015, did you begin using drugs again?
A. I have to look at the date. It was -- I think
it was -- I thought it was April 2016 was when I started
diverting again. God, the dates -- and the Modafinil
was, like, in October of that year, I believe.
Q. Let me do this. In fairness to you, you
stipulated to the imposition of discipline with the
Medical Board.
A. Um-hmm.

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Q. Is that right?
A. Yeah.
Q. And as part of that, you stipulated to the
truth of the allegations in the accusation?
A. Yes.
Q. Would it refresh your recollection if I
permitted you to see that accusation, which does have a
chronology?
A. Yes, please.
Q. Let me give it to you. It's on page 7 of the
accusation.
A. Yeah. So April 2016. "Respondent began to
steal fentanyl from UCSD for his own use."
So that is correct. I think my dates were all
right. But several months before that was the
Modafinil.
Q. Fair enough.
In October 2015, did you stop seeing your
psychiatrist?
A. Yeah.
Q. And did you begin prescribing yourself
psychiatric medications?
A. Yeah. I continued my regimen, but I prescribed
for myself and did not seek medicine management from a
psychiatrist.

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A. Yes.
Q. And you had shared with us that Modafinil is a
controlled substance?
A. Yes.
Q. And you told us earlier, I believe, that it is
a stimulant?
A. Yes.
Q. Then you told me in April of 2016 you began to
use fentanyl again?
A. Yes.
Q. And, again, that involved stealing from UCSD to
obtain the fentanyl for your own use?
A. Yes.
Q. Now I need to talk to you about a couple of
questions.
At some point did you yourself become a member
of the Well-Being Committee?
A. Yes.
Q. When did you become a member of the Well-Being
Committee?
A. So I think -- to the best of my recollection,
there's, like -- kind of like a year term for the most
part. So you start -- like, everything starts on
July 1st, it seems, at the hospital. So it wouldn't
have been that first July, but the following July after

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Q. But in fairness to you, the prescriptions that
you gave yourself were not controlled substances but
either Lexapro or Lamictal?
A. Yes, both of those.
Q. And those were the drugs that you had been
prescribed and been using for several years.
Lexapro to combat depression?
A. Um-hmm.
Q. Is that true?
A. Yes.
Q. And Lamictal in order to stabilize your mood?
A. Yes.
Q. And so instead of having your psychiatrist
monitor you and prescribe those medications, you began
to prescribe them for yourself?
A. Yes.
Q. But at least in -- in October, when you stopped
seeing your psychiatrist, you were not at that point
prescribing yourself controlled substances or drugs of
abuse?
A. No.
Q. But then, in January 2016, you said you began
ordering the Modafinil -- Modafinil -- from India?
A. Yes.
Q. And using it on your own?

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I had graduated. So I'm trying to think of the exact
year and date, but it was a year and a half after I got
out of being -- my monitoring.
Q. Were you on the committee at the time you began
to use fentanyl again?
A. Yes.
Q. Now, could you tell me exactly what your
understanding of the role of the Well-Being Committee
is.
A. What's -- I'd have to look at the mission
statement, but essentially what the Well-Being Committee
does is try to ensure a physician's well-being; whether
substance abuse related or psychiatric related or any
other kind of possible impairment, to evaluate a
possibly impaired physician in order to protect the
public from that person and also as a way to anonymously
report yourself if you are -- have one of those
conditions so you can kind of divert from that
punishment. So, it's a -- yeah, it's a go-between
between, like, a -- the hospital and the physician.
Q. And at one point there was in existence a
formalized substance abuse program run by the State, if
you know?
A. Yeah, there used to be a diversion program, but
that was dissolved and right before I think I went to

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Betty Ford the first time.
Q. Yes.
And then do you know if the Well-Being
Committee was initiated in light of the ending of the
diversion program?
A. Yeah. So a lot of hospital systems or
community groups formed a supplement basically trying to
mimic what the State was doing to -- so that there could
be monitoring of impaired physicians.
Q. So -- and the purpose, as you understand it, of
the Well-Being Committee is to enhance the well-being of
the doctors and to protect the safety of the public?
A. Yeah. And, you know, the hospital's interests
as well. But mainly to -- I would say, you know, they
all go together. So -Q. Yes.
And then I need to ask you how did you get
nominated or appointed to the Well-Being Committee?
A. Like, because I had graduated, people that
continue to work there -- they either ask or people that
have gotten out of it ask to join the Well-Being
Committee.
Q. Did you ask to join, or were you asked to join?
A. Both.
Q. Both?

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Q. And is there a formal system of meetings of the
committee?
A. Once a week.
Q. How long does each meeting last?
A. Between one and two hours.
Q. And without getting into any of the specifics
of any discussion, but as a general matter, what is
discussed at the meetings?
A. Generally, patients -- if someone is being
monitored or a question of being monitored or a
behavioral issue or this or that, usually there is two
people assigned to that person. And, you know, if
they're continuing to have issues, let's say, with
depression, you just check in on them, making sure
everything was okay. So that.
Or new evaluations -- you would go see someone
that was recommended to the Well-Being Committee.
Whether if it's a legal thing or an angry physician at
the workplace, you would go and question them, do an
evaluation, and come back to the committee the following
week and say what you think is going on.
Q. Does the committee either make recommendations
as to continued employment or have the power to act on
terminating someone?
A. The Well-Being Committee cannot term- --

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A. Both.
Q. And so when you were on the Well-Being
Committee, you said it was a term of a year.
A. Or -- it -Q. Approximately.
A. Yeah, you can stay on as long as you want, but
the appointments are usually on that July 1st date.
Q. Who was on the Well-Being Committee when you
were on the Well-Being Committee?
A. I'd have to look at the list.
Q. As best as you recall.
A. Oh, God. I haven't thought of these names in
so long.
Robin Seaberg was the chair of the Well-Being
Committee at the time.
Q. And she was an anesthesiologist?
A. Yeah. There was several psychiatrists, some -like, one or two family medicine, a couple internal
medicine. Some were from OB-GYN. I don't know all
their names off the top of my head, but there was a
representation of all -- kind of all departments but
with a focus on psychiatry.
Q. And then may I ask the approximate number of
members when you were on the Well-Being Committee.
A. 12.

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terminate anyone. They can recommend, I believe, to the
Medical Staff Executive Committee on what to do, but
they don't have any -- they can make -- they can make
their recommendations.
Q. And is it their obligation to monitor? The
Well-Being Committee -- is -- is there an obligation
that they have to monitor the persons who are being
monitored?
A. To monitor -- they -- it's -- they don't
formally monitor the patient directly. That's what the
Health Professional Program is for. That does more of
the -- the "monitoring" monitoring. And then the person
who directs that reports back to the Well-Being
Committee.
Q. Tell me about the Health Profession -- Program?
A. Yeah. So that was more -- essentially is,
like, a smaller diversion program. So what used to be
diversion for the State of California, people formed
hospital systems, public groups, formed -- formed these
Health Professionals Program. And then it's usually ran
by a therapist with a medical director and a psychiatry
director. And then that would be -- like, whatever
happened, that monitoring gets referred back to the
hospital system's Well-Being Committee.
Q. And who was the therapist during the year

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you -- or strike that.
Who was the therapist when you were on the
Well-Being Committee for the Health Professional
Program?
A. Ann Glassmoyer.
Q. And I think Ms. Glassmoyer actually wrote a
letter on your behalf to Judge Huff for your sentencing?
A. Yes.
Q. And then who was the medical director for the
Health Professional Program when you were on the
Well-Being Committee?
A. I don't even know.
Q. Do you know who the psych director was?
A. No, I don't remember their name.
Q. In any event, from some point in April of 2016
through October of 2016, you used fentanyl and became
addicted?
A. Yes.
Q. And during that time, your use escalated to the
point of five to eight times per day?
A. Yes.
Q. Was it fentanyl, or was it also including
Dilaudid and the other drugs?
A. Addictive? Morphine, Dilaudid, and fentanyl
but mainly fentanyl.

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Then you'd check out a packet of anesthesia
drugs. There was, like, a general anesthesia packet.
There was a cardiac anesthesia packet. And then you'd
check out the appropriate packet. And it would have a
supply to do -- you'd generally do at least a couple
cases, sometimes more, depending on what kind of
surgical procedure you were doing. So -Q. And, in other words, with that single packet,
you could do a couple of cases?
A. Yeah.
Q. And after you'd check it out, the system would
keep track of what has been checked out based on the
biometric data or the pass code that is used to obtain
the packet?
A. So -- yeah. So you would get your -- get your
packet, and then inside of it there was a sheet where
you would write the patient's name down, medical record
number, and then you would put the doses you gave and
what was wasted.
Q. Now, let's talk about that.
With respect to the dosages that are used, you
would typically falsify the records at least with
respect to the drugs that you were using and stealing?
A. Yes.
Q. And so those records concerning the amount of

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Q. Now, let's talk, if we could, for a moment now
about in the year 2016 and the year 2017.
The institutional arrangements by which drugs
were dispensed for use in anesthesiology -A. Um-hmm.
Q. -- could you tell me in those years was the
same system used, or did it change at some point?
A. It had changed to a Pyxis-type system.
Q. P-y-x-i-s?
A. Yes.
Q. And it involved what's called an OCD, which
means a dispenser of the drugs?
A. Yeah. There was -- yeah, it was a dispenser.
Q. And can you tell me, then, how that worked. In
other words, you have a surgery coming up. You're going
to be the anesthesiologist.
How do you obtain the drugs from the Pyxis
system?
A. So you could -- so you would go there. You
would -- either a pass code but generally biometric
data, so, like, a fingerprint -- some areas didn't have
the fingerprint system. I don't -- I can't remember
what hospital parts, but maybe, like, the Eye -- Shiley
Eye Center. But basically you would use your
fingerprint, and it would identify you that way.

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drug that was used would be false entries in the medical
records?
A. Yes.
Q. And you understood, of course, that that was
wrong?
A. Yes.
Q. And illegal?
A. Yes.
Q. And then there was also a provision for the
so-called wasting of the drug?
A. Um-hmm.
Q. Is that true?
A. Yes.
Q. Wasting means that the drugs that are not used
in the anesthesia, as opposed to being put back in and
used at a later time, are to be disposed of?
A. Yes.
Q. Now, in the year 2016 and the year 2017, was
there a procedure or a protocol for the wasting of
unused anesthetic drugs?
A. Yes.
Q. Would you describe it to me, please.
A. You would have to have -- someone who is
certified to log into a Pyxis machine would sign in, and
you would type -- and certify that the amount you wasted

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was what was wasted.
Q. And did that person have to be a different
person from the person who had checked out the packet?
A. Yes. Or -- yeah, it had to be different from
the person who checked out the package.
Q. Now, under this new system, you had to use a
different way to deal with obtaining the drugs?
A. (Nods head.)
Q. Tell me the ways in which you were able to
obtain drugs for your personal use and could still
comply with this system.
A. I mean, you would -- it was basically the exact
same thing that I did before. You were -- rather than
turning it directly back into the pharmacy, you would
waste it in either -- either the trash. There was a
receptacle that was used mostly -- most of the time.
Sometimes people would -- I mean, just a sink, wherever
you could be witnessed.
But before that time period, I would have -Q. Substituted saline?
A. -- taken -- yeah. Yes.
Q. So there were multiple ways in which you
continued to act.
A. Yeah.
Q. One would be to falsify the amount of

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A. Yeah. They'd basically log in and agree that
the 5 cc's was wasted.
Q. And they would basically take your say-so for
that?
A. Um-hmm.
Q. Is that true?
A. Yeah.
Q. Did anybody, in the year 2016 or 2017, say,
"Just a second. I want to test this to make sure it is
what you say it is"?
A. How could they do that? Like -- oh. No, no
one said, "Oh, hey, let's take that and get it inspected
and see the concentration of fentanyl in there."
Q. Yes.
A. No.
Q. For instance, or is there some difference in
the consistency of fentanyl from saline solution?
A. No, none at all.
Q. But nobody ever questioned you?
A. No.
Q. How many different people would you estimate
signed documentation reflecting that the drug had been
wasted?
A. Over what time period?
Q. Over the period of 2016 in April through

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anesthetic that was used in anesthetizing the patient?
A. Yes.
Q. So, for instance, if you wanted to obtain
1 milliliter of fentanyl and administered 1 milliliter
of fentanyl in the anesthesia, you could put down that
2 milliliters had been used to anesthetize the patient?
A. Yes.
Q. And then that would allow you to keep the 1 and
still comply with the apparent -A. Yes.
Q. -- propriety of the records?
A. Yes.
Q. A second thing you could do would be to use the
amount and actually appropriately reflect the amount
used but to divert or secrete the unused portion and
then substitute, in place of the drug, saline solution?
A. Yes.
Q. And then the saline solution in the syringe
could be disposed of in front of somebody.
A. Yes.
Q. And you would say, "I need" -A. 5 cc's. And then you'd -Q. Squirt it in the toilet?
A. -- sign in -- yeah. Yeah.
Q. And then they would certify it?

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January 27th of 2017.
A. 50.
Q. And of those 50 people, not a single one ever
tested you or questioned you?
A. No.
Q. They took your word for it?
A. (Nods head.)
Q. "Yes"?
A. Yes.
Q. And they then certified that in their presence,
the requisite amount, the amount that had not been used,
had been appropriately wasted?
A. Yes.
Q. And likewise, I take it, from time to time you
would certify for other anesthesiologists or nurse
anesthesiologists -- nurse "anestheticians" -- forgive
me -A. It's okay.
Q. -- you would certify that they had wasted the
amount that they were saying?
A. Yes.
Q. And for your own part, you never questioned
them?
A. No.
Q. During that time period from April through

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October of 2016, you were injecting yourself five to
eight times per day?
A. For what -- what time period?
Q. Actually, you started using again in April, and
it would have escalated over time until you began using
five to eight times per day?
A. There was a time period of, like, in the middle
there, a couple two or three months where I was able to
not -- not use anymore, and I started actually to go to
some -- some meetings, AA meetings. But after, you
know, a couple months, then I started back up on my own.
Q. All right. And during that time when you are
stealing fentanyl and using it five to eight times per
day -A. Yes.
Q. -- you were actually on the Well-Being
Committee?
A. Yes.
Q. Charged with the responsibility of helping
others who have substance abuse issues?
A. Yes.
Q. And charged with the responsibility of
safeguarding the public health and the safety of the
patients?
A. Yes.

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A. I actually did not complete it.
Q. I see.
How long was the program expected to be?
A. Well, they usually expect you to do this high,
long hours; and then you do -- after that, then you
do -- go half -- or half days afterwards, sometimes
three days a week, sometimes five, depending on the
recommendation. But I didn't want to miss work that
long.
Q. Were -- and so you then came back to work at
the end of October?
A. Yeah.
Q. And how long after you came back to work did
you relapse?
A. Probably -- I think it was a month, maybe month
and a half, somewhere in that range.
Q. And did you then become addicted once more?
A. Yeah, same pattern as the other times.
Q. And by the end of the year, you're using five
to eight times a day?
A. Yes.
Q. You're shooting up in the bathrooms there at
the hospital?
A. Correct.
Q. And probably using the bathroom to shoot up

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Q. And in October, between the 4th of October and
the 26th of October, you tried to treat yourself for
your addiction; is that true?
A. Yes.
Q. And you checked into a program called Casa
Palmera?
A. Yes.
Q. Where is Casa Palmera?
A. San Diego.
Q. And was it a residential treatment program?
A. They have both residential and intensive
outpatient treatment programs.
Q. What did you do during the period you were at
Casa Palmera?
A. So initially, because the opioid addiction,
they wanted to treat me inpatient because they were
worried about withdrawal symptoms, stuff like that.
After two days, they realized that my withdrawal wasn't
that bad. So they allowed me to do an outpatient
program where it was, like, all day Monday through
Friday for eight hours, ten hours, something along that
lines.
Q. In meetings and intensive therapy?
A. Yeah.
Q. And you completed that program?

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four or five times a day?
A. Correct.
Q. And treating patients while you're under the
influence?
A. Correct.
Q. And stealing drugs that are either intended for
use for the patients or stealing from the hospital?

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A. Yes.

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Q. And falsifying the medical records?

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A. Correct.
MR. IREDALE: All right. Let us, if we could,

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take a five-minute break, and we'll resume at

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2:00 o'clock p.m. Thank you.

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THE VIDEOGRAPHER: Off the record at 1:53 p.m.

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(Recess)

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THE VIDEOGRAPHER: We are back on the record at
2:03 p.m.
(Exhibit 1 marked)
BY MR. IREDALE:
Q. Dr. Hay, I have shown you a document which, I

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believe, is some 21 -- 22 pages in length. And it has a

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list of dates; a list of anesthesia provider, which

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lists yourself; and then a column that says "Anesthesia

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Start" and "Anesthesia Stop."

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A. Yes.

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Q. Now, I don't know. Have you ever seen this
document at any time?
A. I've seen the format, but I haven't gone
through the whole document.
Q. Let me, if I could, discuss with you some parts
of it.
Now, let me ask this: Where it says "Log ID,"
can you tell me what that refers to, if you know? In
the top column -A. I have -- I have -- I don't know. I have no
idea.
Q. And then next to that it has "MRN."
A. I know that.
Q. What is that?
A. Medical record number.
Q. And that is a reference to the patient's
medical reference -- medical record number?
A. Yes.
Q. And if you know, does this document show for
each particular patient the medical record number, the
time of the start of anesthesia, and the stop of
anesthesia?
A. Yes.
Q. Now, could you tell me -- you do anesthesia or
did anesthesia for all kinds of surgeries?

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Q. Very good.
Now, let me, if I could, just discuss the
entries here for the date which is the first date on
page 1 of Exhibit 1 that I have shown you.
A. Yes.
Q. It's for the date of the 5th of April of 2016.
A. Um-hmm.
Q. And it shows that on that date you were the
anesthesiologist on ten separate procedures?
A. That's what it says.
Q. And would that have been a number which would
have been typical or, in any event, not unusual for you?
A. Not unusual.
Q. The Anesthesia Start -- is that the time at
which induction occurs, as you had said?
A. No. It's when you assume care of the patient.
THE REPORTER: Could you repeat that.
THE WITNESS: It is the time when you assume
care of the patient.
BY MR. IREDALE:
Q. And Anesthesia Stop -- what is your
understanding of what that means?
A. That's when you relinquish care of the patient
to the postoperative care unit.
Q. Now, the Anesthesia Start for the first entry

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A. Yes.
Q. From things involving, I take it, the removal
of benign lesions to heart surgery?
A. I didn't do heart surgery but almost everything
but.
Q. Tell me the kinds of surgeries you have done.
A. Any -- oh, I mean, anything but heart surgery,
basically. So you could -- any kind of orthopedic
procedure; urologic procedure; OB-GYN; neurosurgery;
eyeballs, like ophthalmic surgery. Anything and
everything but hearts. Anything you can think of.
Q. And -A. Sedation procedures like scopes or -- which is
monitored anesthesia care without full general
anesthesia. Sedation for patients with nerve blocks
getting a peripheral surgery like an arm or a leg. Just
basically everything.
Q. Is there a reason why cardiac surgery requires
some special kind of anesthesiologist?
A. They do intraoperative echocardiograms, and you
have to get training, formal training, in that to be
able to do them, basically. Anyone can do them, but to
be certified and to actually bill for them, you have
to -- you have to do a residency and pass a -- pass a
test.

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is at 8:58 and Anesthesia Stop at 10:32.
Do you see that?
A. Yes.
Q. If you'll look at the fourth entry, Anesthesia
Start is at 7:18, and Anesthesia Stop is at 1526 hours,
which would be 3:26 p.m.?
A. Yes.
Q. And that involves a time period which is
coincidental in part with the first.
A. Yes.
Q. And then if you will look down to the sixth
entry, you'll see that there's an Anesthesia Start at
7:11.
A. Um-hmm.
Q. And an Anesthesia Stop at 9:08.
A. Yes.
Q. And that is coincidental with both the first
and the fourth entries that we've discussed?
A. You are correct.
Q. And then if you'll continue down at the seventh
entry, showing a start at 9:24 and a stop at 11:13 -A. Um-hmm.
Q. -- that is coincidental, I believe, with the
first and the fourth entries.
Am I correct in that?

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A. Yes.
Q. So that at this time, at some point you were
involved in monitoring three separate surgeries?
A. Yes.
Q. And if -- that would involve your going from
one room to another room to another room?
A. Yes.
Q. And being paged in the event of an emergency or
an emergent need.
A. Yes.
Q. Now, after you came back in April, you said
within about a month of your return you were addicted
again.
Did I understand that properly?
A. So I think you're speaking of October and when
I returned from -Q. I'm sorry. You're absolutely right.
You -- in April, May, June, and July, save for
that period when you were able to wean yourself off -A. Yes.
Q. -- during that period of April through
October 3rd or 4th, I believe, through the 26th, when
you were at Casa Palmera, you were using five to eight
times a day?
A. At the peak, yes.

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said.
A. Yeah, November, probably December. I can't
ver- -- know the dates, but it would have been
sometime -- I'm trying to think in relationship -- using
Christmas as a -- as a reference point.
Q. With you, it would be Christmas Eve.
A. Why -Q. Well, everything is -A. Everything -(Simultaneous colloquy)
BY MR. IREDALE:
Q. The 3rd of July, Halloween eve.
A. That would have been -- yeah. I would have
gone back to rehab on Christmas Eve. I understand.
Yeah, I -- somewhere in between -- so probably
sometime in December would have been when I relapsed
again.
Q. And so by January, you would have been fully
addicted and using five to eight times a day?
A. Yeah, at some point in time in January I
will -- yes.
Q. And now I need to ask you can you tell me would
the medical records of many, if not most, of the
patients reflected in this exhibit have been falsified
with respect to the amount of anesthesia that was

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Q. And so, for example, if you were using five to
eight times at the peak, you were under the influence
for the majority, if not all, of the surgeries on any
given day.
A. Correct.
Q. Would that be fair to say?
A. Correct.
Q. And then while you were under the influence and
monitoring one surgery and then another and then
possibly even a third, you were also involved in
obtaining drugs for the next time you would shoot up?
A. Yes.
Q. And falsifying the records to cover the
obtaining of the drugs for the time when you would shoot
up?
A. Yes.
Q. And then -- and forgive me. You're exactly
right on the chronology. I apologize. Because -- and
you told us that from the 4th of October through the
26th of October, you were involved in the Casa Palmera
drug treatment?
A. Yeah, I don't know -- yeah, I don't know what
day I got out, but most of the month of October.
Q. You came back, and you were able to avoid using
in most or all of the month of November, I think you

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administered?
A. Yes. When I was using, many of them would be.
Many to most, yes.
Q. And then may I ask, if you know, does the
hospital charge the patient for drugs that are checked
out and wasted but not used in the surgery?
A. I have no idea.
Q. You don't know?
A. (Shakes head.)
Q. Well, knowing those in medical -- I'm not going
to -- I withdraw that. Medical billing is where true
criminals reside.
A. I won't argue with that.
Q. Now, I need to ask you, in the year 2016, at
any point did Dr. Manecke talk to you about whether you
were having problems with substance abuse?
A. I do not believe so.
Q. In 2015, did he talk to you?
A. I do not believe so.
Q. And in 2017, before the date of the 27th of
January, did he talk to you to ask how you were doing
with respect to your substance abuse?
A. I don't believe so.
Q. In 2017, did anybody from the Wellness [sic]
Committee or anybody else check in with you and say,

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"How are you doing?"
A. No. They didn't have any suspicions.
Q. Well, yes. But, you know, the DSM III -- have
you looked at it with respect to opioid abuse?
A. I've -- I've read it before. Not anytime
recently, but, yeah, I've -- I've gone through it.
Q. And we've agreed that among all the medical
specialties, anesthesiology has a particular
vulnerability to substance abuse.
A. You're correct.
Q. Not only the stress, but the availability and
the ready availability of substances that are addictive
in nature?
A. You are correct.
Q. And as a matter of fact, you have, I believe, a
sponsor right now who is a former anesthesiologist,
Dr. Fischbach?
A. Yes.
Q. And he himself had a problem while he was an
anesthesiologist with substance abuse?
A. Yes.
Q. And always on the Well-Being Committee, there
was at least one person from anesthesia?
A. Yes.
Q. And we know that relapse is not something that

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A. No.
Q. And in fairness to a certain extent, you
yourself were to blame because at one and the same time
you were stealing from the hospital, falsifying records,
and serving as a member of the Wellness Committee?
A. Yeah, I was a -- I felt like a fraud. And the
last thing I wanted to do was to be found out. So I did
everything I could to hide it from -- from everybody.
Q. Which is also typical, is it not? I think
earlier in the day you told me lying and opioid abuse go
hand in hand.
A. Yes.
Q. And you used an even more vivid metaphor, as I
recall.
A. I think I said they hold hands.
Q. Yes.
Now, I need to mark as Exhibit 2 another
document, which is a four-page document. We'll take
care of it.
(Exhibit 2 marked)
BY MR. IREDALE:
Q. Give it to you.
A. Thank you.
Q. Now, let me ask you this: Do you recognize
Exhibit 2?

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is by any means unusual. In fact, it's the normal
pattern for opioid abuse.
A. Yes.
Q. Is that fair to say?
A. Yes, that's fair to say.
Q. And is that a well-known fact?
A. Yes.
Q. And yet -- and you had gone, at least for some
period of time, without a relapse, but you ultimately
did relapse.
A. Yes.
Q. And when you needed most the help of others,
nobody helped you?
MR. HEGELER: That may be argumentative but -MR. FARRUGIA: Join.
MR. IREDALE: Well, it's the first objection of
the afternoon, maybe of the day.
MR. HEGELER: Of the day.
MR. IREDALE: It would be churlish of me to
press it.
BY MR. IREDALE:
Q. Let me ask you this, though: In that last year
before what happened in this case, did anybody, anybody
in authority at the hospital, come up to you and say,
"How are you doing with your problems?"

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A. Yes. Well, it looks like a text conversation
with Tammy Nodler.
Q. Between yourself and Tammy Nodler?
A. Yes.
MR. HEGELER: May I interrupt for just a
second.
MR. IREDALE: Yes.
MR. HEGELER: Did you get what we sent to your
office yesterday? There was an additional piece of the
text. Did you get that?
MR. IREDALE: Yes, I did.
MR. HEGELER: I just want to make sure you have
it. And -- I don't know if it's significant, but we had
missed it before. I apologize.
MR. IREDALE: Yes. Let me see if we can handle
that at the break. I think I have it in another file,
and I appreciate it.
MR. HEGELER: Yeah. Sure. Of course.
BY MR. IREDALE:
Q. At some point did you get off your phone this
conversation?
A. Yes, I believe so. Yes.
Q. And now I need to talk to you about it.
A. Yes.
Q. You can see that the date at the top -- below

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where it says "To: Tammy Nodler," it says 1/23/17,
9:44 A.M."
Do you see that?
A. Yes.
Q. And it says "You and I have a request case
Friday. Randy Dalo. Hope that's okay!"
And the response is "Ok. What is it? I had to
put an IV I [sic] him once, and it was difficult under
ultrasound."
Did I read that -A. You read that correctly.
Q. Who is the person sending the first text, if
you can tell? Is that you to her or her to you?
A. No. 1 -- on the left side of the paper is
Tammy. On the right side of the paper is myself.
Q. So she said to you, "You and I have a request
case Friday. Randy Dalo. I hope that's okay!"
A. Yes.
Q. And your response is (as read) "Ok. What is
it? I had to put an ID -- an IV," and then, as is
common, you didn't write out the whole word. It just
has a capital "I," meaning "in" -A. Yeah.
Q. -- "him once, and it was difficult under
ultrasound."

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Karen had said they mentioned awake fiber."
A. Yes.
Q. Can you tell me what "awake fiber" means?
A. That stands for an awake fiber intubation.
Q. And your response to this is "Yeah, he's a
mess."
A. Yes.
Q. Now, you knew Karen Dalo?
A. Yes.
Q. How long have you known Karen?
A. Since 2006.
Q. And can you tell me how -A. Or 2003. Sorry.
Q. 2003?
A. Yeah.
Q. When you first were an intern?
A. Yeah, my first year of residency.
Q. Residence. I'm sorry. Residence.
A. Okay. Yeah.
Q. And you have a good relation with her?
A. Well, I used to.
Q. Well, found her to be a friendly person?
A. Very much so.
Q. A little mean from time to time, in fairness.
You're under oath, after all.

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A. Um-hmm.
Q. And had you, in fact, put an IV in Randy
once -A. Yes.
Q. -- while he was under ultrasound?
A. Yes.
Q. You said, "I think he's got some heart failure
too."
A. Yes.
Q. And then on the left side, is this her response
back?
A. Yes.
Q. She writes "C4-7 acdf."
A. Yes.
Q. Can you tell me what you understand that to
mean?
A. Cervical Spine Levels 4 through 7 and then an
anterior cervical discectomy and fusion.
Q. And then below that it says, "Afib copd
morbidly obese."
A. Yes.
Q. Those are referring, as you understood it, to
medical conditions of Mr. Dalo?
A. Yes.
Q. And then she writes "Look at his neck MRI.

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A. That's what we liked about her.
MR. HEGELER: I'll bet.
BY MR. IREDALE:
Q. And -- and you liked her?
A. Yes.
Q. And you know that she liked you?
A. Yeah.
Q. And after you say "Yeah, he's a mess," she says
"I know." And then there's an emoji there with a
serious face.
A. Um-hmm.
Q. "Lmk what do you want to do for airway
tomorrow!"
"Let me know what you want to do"?
A. Um-hmm.
Q. Yes?
A. Yes.
Q. And so that was a question about how you're
going to either intubate him or do something so that
he'll be able to breathe during his surgery?
A. Yes.
Q. Your response is "Sleep fiber?"
Her response is "Only fear is mask ventilation
because of beard."
Your response "Use sux," s-u-x, "and get the

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tube in quick and have glide available."
She says "Okay. Perfect."
And that was that conversation that took place
in the morning hours of the 23rd, which, I believe,
would have been a Monday. Yes, that would have been the
Monday preceding the Friday, the 27th.
A. Yeah, Monday and then Thursday afternoon and
evening.
Q. That's right.
The next one -- it appears to be -- yes. It
appears to be -- I'm sorry. You're exactly right. The
statement "Let me know what you want to do for airway
tomorrow!" is Thursday. And then your response to that
is at 6:00 p.m. -- 6:10 p.m. on that same date,
Thursday.
A. Yes.
Q. Then the next text appears to be Tammy Nodler
to you asking, "You here?"
A. Um-hmm.
Q. And your response about an hour and 15 minutes
later is "Ready."
A. That was her on the left, "Ready."
Q. Oh, you're right. She's saying "Ready."
A. Yes.
Q. Meaning she's ready or the patient is ready?

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stronger than fentanyl?
A. Yes.
Q. And fentanyl is between -- about 10 times
stronger than heroin.
Yes?
A. Yes.
Q. So sufentanil is a very powerful drug.
A. Yes.
Q. She is writing you here saying, "The sufenta
wasn't on. I turned it up to 0.6 mcg per kilogram per
hour"?
A. Yes.
Q. Now, can you tell me was -- was that sent at a
time that was immediately after the opening of the
conversation?
A. I don't know without inspecting the time -- I
don't know because the -- the time isn't displayed. I
can't remember when exactly that -- that was discussed.
Q. All right. And now let me just ask you some
technical questions.
A. Um-hmm.
Q. "Mcg" is microgram?
A. Yes.
Q. And milligram is "mg"?
A. Yes.

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A. Yes.
Q. Let's go to the next page.
Right here it says, "The sufenta" -- on the
second page, top of the page -- "The sufenta wasn't on.
I turned it on 0.6 micrograms per kilogram per hour."
Do you see that?
A. Yes.
Q. Now, what time did you start work on the 27th,
if you recall?
A. I don't -- so it was a Friday. It would have
been -- those are 7:30, 7:20 start. So I would have
been there sometime after 7:00 or some- -- between 6:30
and 7:00 o'clock.
Q. Now, we had earlier talked about the substance
sufentanil.
A. Yes.
Q. And you said, as I recall, that you had used it
two times.
A. Yes.
Q. And the second time, the last time you used it,
was on that date, the 27th?
A. Yes.
Q. When was the first time you used sufentanil?
A. Sometime during the residency -- my residency.
Q. And sufentanil is between 5 and 15 times

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Q. Milligram means 1,000th of a gram?
A. Yes.
Q. 1/1,000 of a gram?
A. Yes.
Q. And microgram is how much?
A. 1/1,000 of a gram. A microgram -- so a gram -let's say gram's 1. There's a thousand milligrams in a
gram and a thousand micrograms in a milligram.
Q. So it's a tiny amount?
A. Yes.
Q. She says -- after she says "The SUFENTA wasn't
on," did you understand that to mean that she had not
for some reason turned on the sufentanil for
administration during the anesthetic process?
A. Yeah, that's what it looks like.
Q. And when is your understanding of when the
sufentanil was supposed to be administered during the
course of his operation?
A. It -- sometime early on, as soon as you can.
There was other anesthetics at the same time and -other anesthetics with induction at the beginning of the
case. So I don't know when it was -- when that was
started or how long after the beginning of the case. I
can't -- I can't answer that from here.
Q. I appreciate that.

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My question is -MR. IREDALE: Did you have an objection?
MR. HEGELER: Oh, no. No.
But do you want him to look at the anesthesia
record?
MR. IREDALE: We're going to do that later.
MR. HEGELER: All right.
BY MR. IREDALE:
Q. My question now is not when it, in fact, was,
but rather when is your understanding of when it's
supposed to be typically in an operation involving a
cervical discectomy?
A. Usually -- I mean, you give -- you give your
standard induction dose for induction, and then after
you get everything situated, you start giving your -you start your infusion. So pretty soon after the
patient's intubated, you start your infusions.
Q. And when you say "your infusion," would you
tell me what that means.
A. So you have medicines that go in at a constant
rate either with a syringe pump or a bag pump. And they
administer the same concentration of drug so there's no
variation in the amount given, so at a constant rate,
constant dose.
Q. She then says (as read), "Do you mean for

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cutting it with a pocket knife, and it got caught on a
chunk of cinnamon sugar and busted through it, and then
I cut my finger. I still have a jacked-up finger to
this day from that.
Q. And so then you yourself were in need of
medical treatment?
A. Yeah.
Q. Do you recall what time of the morning that
occurred?
A. Pretty early on. I'd have to -- without
having -- being able to see the times associated with
the conversation, I can't -- I can't be certain, but it
was early -- it wasn't too long after the case had
already started. It was fairly -- fairly early in
the -- in the procedure.
Q. Next she writes, on the left-hand side, "They
told me 85% burst suppression as he bucked."
A. Yes.
Q. Do you see that?
A. Um-hmm.
Q. Tell me your understanding of what "85 percent
burst suppression" means.
A. So "85 percent burst suppression" means -- when
you're monitoring the electroencephalogram, which is,
short form, EEG, your brain waves have distinct

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weight to be 60, or may I turn it up?"
Could you tell me what you understood that to
mean.
A. So she is referring -- the weight of the
patient -- do you want it to be 60 kilograms or -- the
pump we use is a dial pump for sufentanil, and you could
pick patient weight, and then you can pick -- pick
concentration rate to be administered. So she's
referring to 60 kilogram as a setting on the dial.
Q. 60 kilograms would be about 130, 135 pounds?
A. Yeah, give or take.
Q. Randy is a tad heavier than that.
A. Yeah.
Q. You say, "Turn it up."
A. Yes.
Q. She says, "I did."
Then in this same text conversation, you write,
on the right-hand side, "I cut open my finger cutting a
bagel and am in the ER."
A. Yes.
Q. And where were you when you cut your finger?
A. I was in the anesthesia attending office.
Q. And you inadvertently cut yourself?
A. Yeah. I brought bagels that day for the staff
and everybody and was sitting in the office and was

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patterns. And burst suppression is a pattern of brain
activity and then kind of a flat line and then brain
activity and then a flat line. The amount of the flat
line in relationship to the activity is considered burst
suppression.
So 85 percent burst suppression is a
significant amount of -- it's more of a monitor of
sedation than anything else. You can't -- station
anesthesia are similar but different, but it's a monitor
of how awake or asleep a person is.
So if you have zero burst suppression, you can
be mild anesthesia or awake. If you have 85 percent,
you're pretty asleep. If you have zero -- if you have
85, you're very asleep. If you have zero, you're in,
like -- you're so sedated you're either dead or in,
like, a severe, severe coma.
Q. Would that be zero or a hundred?
A. Sorry. You're right. I'm saying it backwards.
A hundred percent burst suppression would be no brain
activity.
Q. And then it says "as he bucked."
A. Uh-huh.
Q. Is that a term of art?
A. So that just means they're -- usually -- the
most -- probably the most stimulating thing you can have

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done to you is have something stuck down your windpipe
and your trachea. So it's common for a patient to cough
even under -- especially at the beginning of the case,
at the initial period of anesthesia when everything is
getting going, it's common for someone to cough,
especially if they have COPD or they're a smoker. They
just have more reactive airways, more secretions. We
can cause a cough reflex. But that doesn't mean
anything other than they coughed. It has no basis in
how asleep they are.
Q. Then below that she says "Oh, no" apparently in
reaction to your statement regarding the finger.
A. Yeah.
Q. "Stitches?"
You then later respond, "Dan Lee is watching
the room while I get stitches."
Who is Dan Lee?
A. He's a -- I think -- he was a fellow attending.
He's another anesthesiology attending. And so he was
covering my room until otherwise told not to.
Q. And then her response is, "Oh hell. That
sucks."
A. Um-hmm.
Q. Does she not like Dan Lee, to your knowledge?
A. I think it's more a reference to that I cut my

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Q. After induction and before you went to get
stitched up, had you checked back into the surgery room
where Mr. Dalo was being operated?
A. So after induction?
Q. After induction but -A. I believe so. I -- you know, I -- I believe -well, it's cust- -- my -- customarily, yes, I do that.
But that day is a little -- a little weird in my mind.
I can't be 100 percent sure, but it is my custom and
practice to go back into the room and make sure
everything is okay after the case gets started and is
settled.
Q. All right. Now, if we could go to the fourth
page, we see that she's talking to you still about the
cut. "Ouch.
"You get any nerves?
"Looks deep."
A. Uh-hmm.
Q. Appears to be still in reference to the issue
about your having cut yourself.
A. Um-hmm.
Q. Is that fair?
A. Yes.
Q. And then at 10:44:39 a.m., she asks, "They
still stitching you up?"

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finger. But maybe. I can't answer that.
Q. And then you have apparently texted her a vivid
copy of your injury.
A. Yeah.
Q. And then can we go to the next page.
And on this next page, we see that the time is
reflected at 9:51:47 a.m. on the 27th.
Do you see that?
A. Where is this one?
Q. On the third page, there's another photograph.
A. Oh, yeah. 9:51, yeah.
Q. And did you take the two photographs at about
the same time?
A. Yeah. Just looking at 'em, yeah, they're at
the same time.
Q. And then she replies, in response to the second
and -- photograph, "Oh my god.
"Is that with your crazy knife?"
A. Yeah, I keep a pocket knife in my bag.
Q. Was it with your crazy knife -A. Yes.
Q. -- that you had cut yourself?
A. Yes.
Q. All right. Could we now go to the fourth page.
A. Yes.

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Do you see that?
A. Um-hmm.
Q. So that it appears, at least from the evidence
we have on the text, that you were being stitched up at
least as of 9:51.
A. Um-hmm.
Q. Yes?
And that you were still being stitched as of
9:44 [sic] or still in treatment of some kind.
A. Yeah. I went to the emergency room and was
inspected there. Then I was taken to the orthopedic
surgery clinic. They did a nerve block so that they can
kind of peel stuff open and look around. And so it took
quite a while. And then they, yeah, stitched me up.
Q. Then you say, "Yeah, I should be done soon.
How much longer up there?"
And her response is, "Putting plate in now. So
30-60."
Do you see that on the front page?
A. Yes.
Q. "30-60" -- is that a reference to 30 to 60
minutes, if you know?
A. Yes.
Q. And your response is, "I kinda want to finish
it."

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A.
Q.
A.
Q.

Yes.
Referring to -The proce- -- the anesthetic.
And then her response then is, "I get that.
"I'll text you when they shoot final X rays."
A. Um-hmm.
Q. And then she says, "Probably 10 minutes until
closing."
"Closing" meaning closing the surgical cut?
A. Yes.
Q. And then at 1:28 p.m., it says "Engy believing
it."
Do you see that?
A. Engy.
Q. Engy. What does "Engy" mean?
A. That's a person's first name.
Q. And Engy is whom?
A. Engy Said, S-a-i-d. She's just another
anesthesiologist.
Q. And it says, "Engy believing it,"
meaning -- what did you take that to mean?
A. I -- I don't -- I don't remember what that was
in reference to. Who knows. I wish I -- I do not know.
Q. Now, for some reason, you decided that day to
try sufentanil for the second time.

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Q. -- Dalo?
A. Somewhere in that. Yeah, around there.
Q. But in order to know accurately how much has
been used, it would be necessary for you to know exactly
when the infusion started?
A. When it started, when it stopped, and if there
were any adjustments made during the procedure.
Q. Did you make any calculations on those things?
A. The only calculation I made was at the very end
of the procedure to make the amount of drug administered
equal 1, if that makes sense.
Q. Yes. Because you wanted it to be so that -A. It zeroed out.
Q. -- it zeroed out.
And then you would have three of the ampules
for your use?
A. Yeah.
Q. Not necessarily use at one time, but you would
available for you?
A. No. Yeah.
Q. Now, were you present when Mr. Dalo was brought
to the recovery room?
A. Yes.
Q. And how long were you there?
A. I basically walked him into the recovery room

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Is that fair?
A. Yes.
Q. And the sufentanil was sufentanil that had been
checked out for the surgery of Mr. Dalo?
A. Yes, sir.
Q. And you had gotten that from the Pyxis machine?
A. Yes.
Q. And as I understand it, you ordered more than
you believed would be necessary for the surgery?
A. (Nods head.)
Q. Yes?
A. (Nods head.)
Q. And how much, in fact, was used? How much
sufentanil was used in the surgery, if you know?
A. I would say around a fourth of what I checked
out was administered.
Q. And you checked out, I believe, four separate
5-milligram ampules?
A. So there are 50 micrograms per ml. And each
vial had 5 mls in it, and four vials were checked out.
So it would have been 1 milligram or a thousand
micrograms.
Q. And so you would have used, you believe, about
250 micrograms in the surgery of Mr. -A. Yeah.

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and -- oh my god. This is just embarrassing. I walked
him into the recovery room, and rather than going all
the way to the bed, I turned right and went to the
bathroom, and that's where I used the sufentanil and
then woke up later.
Q. Now, may I just ask you this: Why did you
decide that day to choose to steal the sufentanil as
opposed to fentanyl?
A. There -- there wasn't any exact reason. I
thought he would be a good patient for sufentanil. And
also, you know, I'm in the middle of my addiction, and
it was like "I have only done it once." Who knows? But
maybe I wanted, you know, a combination of those two.
They kind of work together.
He would be a good patient for sufentanil
because it doesn't last as long as fentanyl. So someone
with obstructive sleep apnea -- they would have the
potential to not have systemic opiate effects for as
long of a time period postoperatively.
Q. And he also would be ideal because of his
weight, you could claim with some plausibility that more
had been used than would, in fact, have been used?
A. Oh, that didn't -- that didn't -- that was not
part of the equation. It was -- I checked out enough
that I knew there was going to be some left over unless

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the procedure went a very, very, very long time, like
that 12-hour one you saw -- or 10-hour one you saw
earlier.
Q. Now, did you ask Tammy Nodler to falsify any
medical record?
A. Her in particular? Well, I think the only
thing I said, "Well, let's just make these numbers work
out to 1."
And then she -You know, as her attending, I told her that.
And then she signed off on that.
And I injected what I had replaced that was
saline into -- I think it was the sharps receptacle and
squirted it in there when that was actually saline at
that point in time. And I had the 15 cc's of sufentanil
in my pocket already.
Q. And did you ask Ms. Nodler to sign as being the
other person who was -- witnessed the wasting?
A. I don't believe if all the medication is -equals out to zero, you're not technically wasting
anything.
Does that make sense?
So if all -- if it says all the medication that
was removed from the Pyxis was wasted -- or not wasted.
Sorry. Let me start over.

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A. Well, there was 15 cc's left over. So 5 mls
plus a little bit more were administered.
Does that make sense?
So if there's 15 left, 5 was given out of the
20.
Q. So how many syringes are there with sufentanil?
A. So at some point in time, there's -- there was
a cc -- there was one syringe with 10 cc's and one
syringe -- and a 10-cc syringe with 5 cc's in it.
Q. And how do we know that the second syringe had
5 cc's?
A. That's just my recollection. I can't -- I
can't -Q. Because what we know is that you used that
second syringe and injected it.
A. Yes.
Q. We know that there was one syringe that had
10 cc's that you had not used.
A. Yes.
Q. We know that there was one syringe which was
empty and had not been used at all.
A. Yes.
Q. And we know that there was the final syringe,
which was ultimately found to have 2 mls remaining.
A. Yes.

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If all of it was used during the case, if it
says that, then there's nothing to waste even though -it's confusing.
Do you understand what I'm saying?
Q. I don't.
A. Okay.
Q. Let's see if we can calculate it out.
You checked out four 5-ml ampules.
A. Um-hmm.
Q. Right?
A. Yes.
Q. For a total of -MR. HEGELER: Ml. Is that right? Ml?
BY MR. IREDALE:
Q. -- 20 mls?
A. Yes.
Q. Ml.
A. Yes.
Q. And one of the four, in part or in whole, was
used during the surgery.
A. Yes.
Q. We don't know exactly how much of that one was
used during the surgery.
A. (Nods head.)
Q. Fair?

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Q. And the rest had gone into your body?
A. Yes.
Q. And you had seen the amount of mls in that
before you shot it up?
A. Yeah. There was, like -- it was between 4 and
5 mls.
Q. Now, with respect to what was used during the
surgery -A. Yes.
Q. -- as I understand it, after you check out the
ampules, you take the sufentanil from the ampule and put
it into a syringe?
A. Yes.
Q. And then you use that syringe to inject it into
a portal or into the solution that is going to go into
the patient?
A. There's bolus doses, and then there's an
infusion dose. So bolus dose goes into the portal, and
infusion dose goes through, like, a tube. And that
injects to kind of a side port so that -- that goes into
the side of the saline that goes into the patient so
it's taken in at a constant rate.
Q. All right. And you had talked to Tammy Nodler
at what point about having her make a particular entry
as to what, in fact, had been used in the anesthesia of

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Mr. Dalo?
A. Like, when -- when -- at the point when the
record became falsified?
Q. Yeah.
Well, when did you talk to her about that?
A. At the very, very end of the case. Like, at
the -- yeah, at the -- at the -- right towards the end.
I gave her a break so I could take the unused sufentanil
and change it all out so where I had the 15 cc's and the
other 15 cc's were saline so that when we got rid of
it -Q. She would see the 15 cc's of saline -A. Yeah.
Q. -- and believe that you had gotten rid of the
15 -A. Yes.
Q. -- cc's of -A. Sufentanil.
Q. -- sufentanil?
A. And whereas it was in my back pocket.
Q. Now, did you conceive of this plan early in the
morning before you took out the sufentanil?
A. I mean, originally -- when I originally checked
it out, I thought that it was not 50 mcg's per ml. I
thought it was 5 mcg's per ml. But then once I realized

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whoever else might use fentanyl as a bolus to make sure
that they didn't, like, give an improper dose -- I don't
know if that makes sense -- they're more comfortable
with bolusing SUFENTA -- or with bolusing fentanyl, and
SUFENTA would be a little easier and more forgiving as
an infusion.
Q. Now, at some point during the surgery, to your
knowledge, did Ms. Nodler make a charting error
regarding the amount of sufentanil administered the
patient?
A. What I remember is her -- I don't know for
sure. I think I -- I remember her mentioning something
about, like, the amounts were not equaling out because
the dial for the pump of sufentanil, the -- where you
dial it on is in mcg's per kilogram per hour whereas the
infusion on the chart is in mcg's per kilogram per
minute.
Q. Minute.
A. So you have to do the calculation either in
your head or on a calculator to make those -- you know,
with a factor of 60 -- to make them equal out. And I
don't know if she got confused with that or what.
Q. Let me just read this to you. It's from the
statement of facts in the accusation before the Medical
Board.

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that there was going to be that much left over, that was
kind of when it hit me, "Oh, there's going to be a lot
left over. I might as well steal it."
Q. So at some point during the surgery itself?
When did you come upon that idea?
A. Oh, when I drew up the medication and realized
the concentration.
Q. Early in the morning?
A. Yeah.
Q. When you -- or shortly after you got it out of
the Pyxis?
A. Yeah.
Q. Now, let me ask you this: Was fentanyl also
used during that surgery?
A. Yes.
Q. And is it common to use both fentanyl and
sufentanil during surgeries?
A. I mean, a lot of times for the induction you'll
use a fentanyl just because you have more -- especially
a nurse anesthetist would have more experience using
that opiate. And sufentanil maybe is a little -- not
used as much is the best way to put it. It's not used
as much.
So with a bolus dose, the person administering,
if it's a nurse anesthetist or who else might -- or

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A. Yes.
Q. And you remember you agreed that all of those
facts were true.
A. Yes.
Q. And do you know where they got those facts?
Had they, in fact, interviewed you at some point?
A. That was -- I think those facts were not from
me. They were from the interview of someone else. I
believe so. I would have to read it again, but I don't
think -- I don't remember saying what was in there to a
Medical Board -Q. Fair enough.
In fairness to you, I am going to show you
page 8.
A. Yeah.
Q. And if you would just read paragraph 35 to
yourself, and then I am going to ask if that refreshes
your recollection.
A. Yeah.
Q. At some point did Tammy Nodler, to your
understanding, make a charting error?
A. Well, the error was in the concentration given.
It didn't reflect the actual amount that was given
because of the conversion between micrograms per
kilogram per hour versus minutes.

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Q. Did you see that on the chart or on the
computer at some point?
A. I don't remember, but -- I don't remember, but
I think I -- I would have seen it. She would have
talked to me about it.
And from my response afterwards of "Well, let's
just make it equal 1," kind of how I explained it to you
earlier, if you set the dose at this rate for this
amount of time, it equals 1, and then there's no waste.
Q. So the statement says "When respondent,"
meaning you, "noted the error, he told Tammy Nodler,
'We'll never get the dose right now. So let's make the
record say we gave the whole amount.'"
A. Yes.
Q. Did you say words to that effect -A. Yes.
Q. -- to Ms. Nodler?
A. Yes.
Q. And the anesthesia record shows that 1.02
micrograms of sufentanil -A. I think it's milli- -- milligrams.
Q. -- milligrams -- was administered to the
patient.
MR. HEGELER: Look at what he's looking at, if
they are the same.

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while -- if the patient is coding or, you know, some
other event is going on. So you go back and say, "Well,
I think I started it about this time at this rate." And
then -- so you can go back and alter stuff that had been
in there before.
Q. So in this case it appears that Ms. Nodler was
supposed to start the infusion at a given time and
didn't start it at the right time.
Is that fair from her text?
A. Sure. Yes.
Q. And so the entry that she made would have been
such a reconstructed entry that you're talking about?
A. Well, that -- she could have -- the -- the -where it started the sufentanil, I -- I can't speak for
what she did in the computer record at that time. So I
can't.
So where she said the SUFENTA was started, I
can't say that is exactly when the sufentanil was
started. It could have started before. It could have
started after. It could have started at that time.
Q. All right. Let me ask you approximately three
to five days after Mr. Dalo's surgery, did you edit his
medical records?
A. No.
Q. You're sure of that?

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THE WITNESS: Well, I -- yeah, I read it. I
know what it is.
MR. HEGELER: The same thing.
BY MR. IREDALE:
Q. And then did you -- let me ask you, with
respect to making medical records, do you make those on
a computer?
A. Yes.
Q. And you made them on a computer in this case?
A. Yes.
Q. The system, the recordkeeping system, is known
as Epic, E-p-i-c?
A. Yes.
Q. And are you able to go in and edit Epic if
there's a mistake that's made?
A. Yes.
Q. Does the computer reflect who made the edit, if
you know?
A. Not on anything necessarily we have access to
immediately. It's stored somewhere, and I think you can
get it, but generally we don't see the exact second -like this was changed to here on this. You didn't -you didn't mark in the chart you had started the
infusion here and then -- because you get busy doing
other stuff and you can't always hit start, start

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A. Yes. 100 percent positive.
Q. Now, I need to ask you about the recordkeeping
system for the anesthesia.
For instance, we've been just talking about
what's called about the infusion of the sufentanil.
And there was also, I believe, an infusion at
some point of propofol?
A. Yes.
Q. Is there a mechanism by which the machine that
is doing the infusion communicates with the computer?
A. No.
Q. So that record is based on an observation that
is entered into the computer by the anesthesiologist or
the nurse anesthetician?
A. Yeah. And, you know, in a perfect world, right
after you're -- you started something, you would enter
it in the computer, but in a -- in a world where stuff
happens at different times, you, to your best of your
ability, write what was given and at what time.
Q. Unless you want to cover for the theft of
something, in which case you might use some falsity?
A. True. Very true.
MR. IREDALE: All right. Let's -- it's now
3:00 o'clock. Why don't we take a five-minute break,
and then we'll come back.

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MR. IREDALE: And I think if we push, we can

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MR. HEGELER: Swell.

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THE VIDEOGRAPHER: Off the record at 3:00 p.m.

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(Recess)

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THE VIDEOGRAPHER: We are back on the record at

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BY MR. IREDALE:

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Q. All right. Now, I was informed that there was
something that you wished to say.

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A. Yes.

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Q. Please feel free.

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A. So your last question was if I went back in and

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did something to the record. And the only thing that I

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would have -- would have done or have recollection of

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doing would have been to close the chart out, which

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has to basically say the case was done. And I believe I

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got a notification to close the chart out.

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Q. All right. Now, let me refer you to Exhibit 1.

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A. Yes.

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Q. And let's go, if we could, to the next-to-last

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page.

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A. Yes.

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Q.
A.
Q.
A.
Q.

And the same on the 27th?
Yeah. Well, based on availability.
And, now, on the 27th, you had two surgeries -Yes.
-- according to this record.
Do you remember what the other surgery was
besides Mr. Dalo's?
A. I don't.
Q. Do you remember if you abstracted any
medication from that?
A. I don't believe I did. I don't -- honestly
don't even remember what the other was -- I might not
have even gone in that room.
Q. All right. Now, I need to ask if we could talk
about that day. The 27th we've talked about is -- was a
Friday.
A. Yes.
Q. May I ask about what time did you come into
work?
A. We have a conference every morning at 7:00 -or -- excuse me -- 6:40 to 7:00 o'clock, and we're
supposed to be in the operating room at 7:20.
So depending on whether I went to conference or
not, it would have either been 6:40 or -- sometime
between 6:40 and 7:00 o'clock I would have been there,

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Q. And if we could look at the entries for the
26th of January.
A. Yes.
Q. According to this, you were involved in three
surgeries on that day?
A. It appears so.
Q. And the day before is the 25th of January.
Do you see that?
A. Yes.
Q. As I count, that you were involved in some
15 surgeries on that day.
Would you check and see if I'm right.
A. It appears so. So on the 25th, without
counting, there -- that number -- I believe you.
Q. Don't. I think it's 14.
A. 14 is -- you are right.
Q. Now, on the 25th, you were still using fentanyl
and opioids five, six, seven, eight times a day?
A. Yes.
Q. And still regularly using the bathrooms at the
hospital to inject yourself?
A. Yes.
Q. The same thing would have been true on the
26th?
A. Yes.

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maybe 7:10.
Q. At what time did you obtain the packet for
Mr. Dalo's surgery?
A. Well, the only thing, I believe, I checked out
was the sufentanil. I think the rest of the drugs were
checked out by Tammy.
Q. And when did you prepare the sufentanil, if you
did?
A. I drew it up, to the best of my recollection.
The sufentanil had to be taken out of the Pyxis machine
that was in the anesthesia workroom. That was the only
place that had the sufentanil. And I believe I went
into the operating room and that's where I drew up the
medication.
Q. Now, what time did you do that, approximately?
A. The exact -- I can't be exact on that time. I
don't know if it was before induction or immediately
after.
Q. Did you prepare any of the other anesthetic
agents?
A. I don't believe so.
Q. Did Tammy Nodler, if you know?
A. I believe so.
Q. Now, can you tell me what you remember about
any contact you had at first with Mr. Dalo, where he

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was, where you were.
A. He was in the preoperative area.
Q. And was he alone or with anybody?
A. I believe he was with Karen.
Q. Did you say hello to Karen?
A. I think so.
Q. And did you talk to Mr. Dalo?
A. I think so.
Q. What, if anything else, did you do with
Mr. Dalo?
A. I know we spent a lot of time trying to get an
intravenous line. Between Tammy, me, and another
resident and pulling out an ultrasound, we all tried to
do that. Other than that, there was the standard
anesthesia interview and informed consent.
Q. In obtaining the informed consent, did you tell
Mr. Dalo that you intended to falsify his medical
record?
A. No.
Q. Did you tell him that you intended to steal
some of the anesthetic agent that was going to be used?
A. No.
Q. Did you tell him that you would be using the
drug and might be under the influence of -A. No.

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for the procedure.
Q. Does what "awake central line" mean?
A. A central line goes into a big -- well,
depending on what vein you put it in, it goes into a big
vein in the neck that is easily findable with
ultrasound. And because it's big, it's fairly easy to
access.
You can put a catheter in there that's larger
than you'd normally do, but it would be able to last for
the entirety of his stay in the hospital. So hopefully
he would not need another IV for the whole time.
So after thinking about that, thought was the
best option with him, because even if he did get an IV,
he would have to get stick again because it would have
stopped working.
Q. And so is that the manner in which the
anesthetic was administered to him?
A. Yeah. It was -- yeah, that was the IV access.
Q. And tell me what you did, then, after that was
done.
A. After it was placed?
Q. Yes.
A. So it was -- he -- that was done in the
operating room for sterile conditioning. Get operating
table, positioning reasons, and then the ultrasound. So

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Q. -- the drug -(Simultaneous colloquy)
THE WITNESS: No, I did not.
BY MR. IREDALE:
Q. And, of course, you knew that those were all
material things on whether he would agree to consent to
a surgery?
A. Absolutely.
Q. These were things that certainly you would want
to know if you were the patient?
A. Yes.
Q. And you didn't tell him that?
A. True.
Q. After you did the informed consent advisal, he
agreed to the surgery.
A. Um-hmm.
Q. And to the administration of anesthesia; is
that true?
A. Yes.
Q. What else happened next?
A. I believe that was when we -- when the IV -difficult IV placements commenced. And with three of us
trying, we couldn't -- we were unable to get the IV. So
I brought up the idea of doing an awake central line in
the operating room so we could have safe, good IV access

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that was done there.
After it was verified being in the correct
position by blood drawback and being able to see the -the catheter in the appropriate vein, it would have been
sutured up to the skin so it wouldn't -- would not come
out ever.
We were to switch from a -- I'm not entirely
sure, but it would have been our normal practice to have
an oxygen mask while he was draped with a central line
going on. That would have been traded out for an
anesthesia mask, which provides a good seal, and you can
administer 100 percent oxygen through it. So we would
have just done our standard induction.
Q. Yes.
Now, you say "we would have."
Do you have a specific recollection, or are you
just relating to me what you believe in the ordinary
course -- course and normal procedure?
A. Oh. So we didn't -- so for this -- do you want
me to start from after the central line was placed to
intubation? How would you like me to approach this?
Q. No.
I'm just asking you do you recall specifically
what you've told me?
A. Yes.

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Q. All right. Now, were you there for the
induction?
A. Yes.
Q. And tell me what happened with that.
A. So we had the central line. We placed him in a
good intubating position. Sometimes if you're a little
on the larger size, you've got to get the positioning
right to be able to get the tube in safely, quickly, and
appropriately.
We were to induce with 100 percent oxygen for
several minutes to wash out the room air. If there's a
period of apnea, you get -- there's a larger safety
margin if you have 100 percent oxygen for five minutes,
three minutes. They don't -- the patient doesn't
desaturate as quickly.
MR. HEGELER: Can you keep your voice up,
please.
THE WITNESS: Oh, I'm sorry.
So after that, we would have induced in the
typical -- well, we induced in the typical manner, which
is an IV induction. Usually there's Versed first
followed by an amount of fentanyl and then propofol.
And in this case we talked about doing the asleep
fiberoptic intubation, which was the plan and is what -is what we did.

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can't -- I can't answer that with certainty.
Q. When you left, where did you go?
A. To the bathroom.
Q. And what did you do in the bathroom?
A. I injected 2 cc's of fentanyl.
Q. And where had you obtained the fentanyl?
A. It was the -- what was left over after
induction.
Q. And was that your first injection of the day,
or had you injected earlier -A. That was my only -Q. -- that day?
A. -- injection of the day until the event.
Q. And then how long did it take for you to inject
yourself and leave the bathroom?
A. A couple minutes.
Q. Now, we had talked about the first time you
used fentanyl, and we -- you had told me you used it in
the -A. Yes.
Q. -- vein that's in the crook of the elbow.
A. Um-hmm.
Q. Yes.
But you had not done that for some time; is
that true?

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The reason for a sleep fiberoptic intubation is
so you get minimal neck extension. Someone with
cervical spine disease -- you don't want to be the cause
of a problem. You want to prevent any kind of -anything happening to the cervical spine.
So he was induced with midazolam, fentanyl,
propofol, and then succinylcholine was administered
immediately after that as a -- as a muscle relaxant.
BY MR. IREDALE:
Q. And then how long after that did you remain in
the room?
A. Well, we did the fiberoptic intubation. I hung
around for the arterial line getting placed. It was
placed by the -- there was a resident involved in this
case too. Because it was a good learning case, he got
to do a central line, he got to do a fiberoptic
intubation, and he got to do an arterial line.
So after all those were -- were done, the
patient was stable, positioned, it was my general
practice to wait until the neuromonitoring was done so
that I knew that the neuro- -- neurophysiological
monitoring was appropriate. Then that is my general
practice, to leave the room at that time.
Q. And did you?
A. More -- I -- I -- more likely than not, but I

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A. True.
Q. You did not want to have the telltale scarring
that -A. Yeah, you don't want to have bruising,
scarring, something that's obvious.
Q. So you were at this time using your femoral
artery in which to shoot up?
A. Femoral vein.
Q. The femoral vein.
A. Yes, sir.
Q. And that is located where?
A. Well, it starts -- it's your iliac vein
somewhere in your pelvis, and then once it gets to the
inguinal canal, it becomes the femoral vein and then
travels down. So somewhere in the groin.
Q. In the groin.
And how long had you been using the femoral
vein?
A. Well, exclusively for -- when I used, I would
use that because I could hide it.
Q. And you said that the fentanyl that you used
was fentanyl that was not used in the induction?
A. Yes.
Q. Did the medical records reflect that all of the
fentanyl had been used in the induction?

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A. Yes.
Q. And who made that entry, if you know?
A. I don't know. It was either Tammy or I. I
can't answer that.
Q. And after you injected yourself, then what did
you do next?
A. Went and cut myself a bagel.
Q. And in cutting yourself a bagel, you cut
yourself?
A. Yes.
Q. And it was at that point that you then went to
the emergency room?
A. Yes.
Q. And how long was that process, best estimate,
during which you were being attended to and stitched?
A. I think I was back somewhere -- I mean, my best
estimate is 30 minutes before extubation, but that -- I
mean, that's not exact. But I remember there being
maybe 20 minutes -- enough time for me to give Tammy a
10-minute break and then extubate.
Q. All right. Now, we had discussed -- and let me
do this, if I could.
MR. HEGELER: How can I help?
MR. IREDALE: It's all right. If you don't
mind giving the witness just a copy to refer to.

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A. Um-hmm.
Q. -- you see that at 9:17 a.m., Tammy Nodler sent
to you this text that says, quote, "The SUFENTA wasn't
on. I turned it on 0.6 micrograms per kilogram per
hour."
Do you see that?
A. Yes.
Q. And I believe you have the chart there; is that
true?
A. Um-hmm.
Q. Would you look at the chart and tell me
whether, according to the chart that is prepared that
shows the sufentanil infusion -A. Yes.
Q. -- that the chart reflects that the infusion
was done at the weight of 0.05 -A. Yes.
Q. -- micrograms per kilogram per hour.
A. Yes.
Q. And the chart shows that it actually was begun
at some point between 8:30 a.m. and 8:45 a.m.
A. That says -- yes, you are correct.
Q. And yet we know that at 9:17 a.m., she said,
"The SUFENTA wasn't on. I turned it on at
0.6 micrograms per kilogram per hour."

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MR. HEGELER: (Nods head.)
BY MR. IREDALE:
Q. And your counsel has been kind enough to print
out from your phone -And, also, let me thank you, Doctor.
Technically you're an adversary party, and your manner
and your forthcoming testimony has been much
appreciated.
A. Thank you.
Q. And so you were kind enough to let your counsel
take off of your phone all of the text messages from the
23rd through the 27th of January referring to Mr. Dalo's
operation; is that true?
A. Yes.
Q. And in this second document, which we will mark
as Exhibit 4, the document has a time stamp beside each
of the texts reflecting when the text was sent?
A. Yes.
(Exhibit 4 marked)
BY MR. IREDALE:
Q. Now, I need to discuss one of those entries
with you. If you will look on what I have marked as
Exhibit 4 -A. Um-hmm.
Q. -- on the second page --

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Do you see that?
A. Yes, you are correct.
Q. But, in fact, the medical record reflects a
different figure, albeit only 1 microgram, 0.5.
Is that fair to say?
A. Well, it's -- yeah. You're saying it says 0.05
mcg's per milligram per minute.
Q. Per minute.
MR. HEGELER: Yeah.
THE WITNESS: Yeah.
So that's where some of that confusion came
from with the dosages.
BY MR. IREDALE:
Q. Let's make sure we've got the math right.
There are a thousand milligrams in 1 gram.
A. Yes.
Q. And a thousand micrograms in 1 milligram.
A. Yes.
Q. And she writes to you that she's giving 0.6
micrograms per kilogram per hour.
A. Yes.
Q. And in fact, in two minutes, she's giving
10 micrograms per kilogram; is that right? Well -A. So this is per minute. So you've got to divide
this number by 60, and that would be the equivalent dose

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over here because there's 60 minutes in an hour. But
remember, at the end of the case, I made that equal 1.
So at this point in time, it got changed to .05 when, in
reality, the dose was probably closer to .01, .013,
somewhere in that range.
The dose -- the pump we use is in mcg's per
kilogram per hour. What is said in the record is mcg's
per kilogram per minute. So there's -- I don't know if
that makes sense now.
Q. All right. Well, when she said 0.6 micrograms
per kilogram per hour -A. Yes.
Q. -- is that the same as 0.5 micrograms per
kilogram per -A. No. You're saying 0.05. So that would -- if
you convert it -- if you divide it by 60, which there's
60 minutes in an hour, that would actually equate to
0.01 mcg's per kilogram per hour.
Q. If you take .05 times 60 -A. Yes.
Q. -- you're going to get the rate per hour?
A. Yes. Or vice versa.
Q. And your math says that if you take .05 times
60, you get 1.0?
A. No. If you divide 0.6 divided by 60.

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falsified; right?
A. Those are the only two ways that I have direct
knowledge.
Q. Well, do you believe that there are other ways
in which the records are, if not falsified, inaccurate?
A. The -- everything else is the standard manner
in which a case like this would have proceeded. So I
have no -- other than the two things I have direct
knowledge of, these -- everything else in there I would
believe to be accurate based on my standard practice.
Q. Now, after you had your hand stitched up -- by
the way, were they able to give you any analgesic or
anesthetic for the cut?
A. They just gave me lido- -- they injected
lidocaine.
Q. Lidocaine?
A. Yeah. No opiates.
Q. That would be dangerous, especially -A. I know.
Q. So after that, what did you do next?
A. I came over and finished the case essentially
with -- for twofold reason: I wanted to and main -- and
the other one, probably major reason, is because I would
be able to divert narcotics.
Q. And so it was both for reasons of

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So what Tammy wrote in the -- so these numbers
don't match by a factor of 5.
Q. Yes.
And -- and the records don't match what really
happened -A. True.
Q. -- right?
A. You are correct.
Q. So the records are false; right?
A. Well, I can't say the entire record is false.
Q. Well, we know that with respect to the
sufentanil, that's false; right?
A. Yes.
Q. And with respect to the fentanyl, that's false;
right?
A. Yes.
Q. Because we needed to change the record and
falsify it to cover up for your stealing the sufentanil;
right?
A. Yes. Yes.
Q. And change the record and falsify it for your
stealing the fentanyl that you used?
A. Yes.
Q. And so you're telling me that that's the only
two ways that you believe the records have been

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professionalism and the need to get drugs that you did
that?
A. Well, I wouldn't -- I wouldn't say there was a
ton of professionalism going on but -Q. All right. In any event, when you came back
from having your finger stitched -A. Um-hmm.
Q. -- where was the sufentanil?
A. It was in the pump, hanging there with -- to
the best of my knowledge, disconnected from the patient.
Q. And what did you do to get the sufentanil?
A. I offered and gave Tammy a break, and while it
[sic] was gone, I traded it out into a 10-cc syringe and
a 5-cc syringe, for a total of somewhere around 14 to 15
mls of the 50 mcg's per -- 50 mcg's per ml of the
sufentanil, and I replaced that with saline so that when
she came back in, the waste would be saline.
Q. Yes.
Could you describe to me the container from
which you removed the sufentanil, its appearance.
A. Then? Or, like, when the initial drug came out
of it or when the -- at the time where I did the switch?
Q. At the time you did the switch.
A. It would have been a 20-cc syringe. I believe
the pump calls for a 20-cc syringe for sufentanil at

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that concentration.
So I would have taken the 20-cc syringe,
injected it in a -- finished it off into two syringes,
and then filled that 20-cc syringe with an equal amount
of saline.
Q. And are you -- well, after you did that, did
Ms. Nodler return?
A. Yes.
Q. And after she returned, did you have the
discussion then with her about the records being
difficult because of the problems that had arisen with
the sufentanil?
A. Yeah. I believe -- it's my best understanding
that the problem was related to the conversion factor,
and I said the easiest way to do it was have it equal to
all that was given because that solves two problems:
One, all the drug is gone, and so it's just easier for
me to divert. And the other, it makes the numbers equal
out in the log here. So you could -- you could pick
your -- basically pick the time period and the rate to
make it equal 1.
Q. And that's what you did?
A. Yes.
Q. And you asked her to have the records reflect
that?

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(Exhibit 5 marked)
BY MR. IREDALE:
Q. Let me refer you, however, now to Exhibit 3.
A. Um-hmm.
Q. May I ask you to go to page No. 1327. You'll
see it on the lower right-hand corner of that page.
Can you tell me what "Anesthesia Record ID"
means?
A. I don't know. It's probably just the number
they cited -- assigned to the -- the -- the case. I
don't know what that number means for sure.
Q. All right. And then it says "Encounter
Status." And it says "Closed by Hay, Bradley Glenn, MD,
on 2/3/17 at 10:32 a.m."
And you had earlier mentioned to me that you
had been asked to close the record?
A. Sometimes they ask us. I knew -- we get, like,
an automated -- I don't know if it's -- it was from Epic
or from our -- one of our administrators, but I was
like, "Well, I'm probably not going to be working at
UCSD anymore if I have any outstanding charts. So I
might as well take care of them right now." And I -- I
don't know if this was the only one I signed off on or
if there was a couple others.
Q. Did you have to go into the hospital to sign

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A. Yes.
Q. And then, having done that, did you make any
other entries into the computer for the medical records?
A. Without -- what I normally would at that time
was fill out a postop note. I don't know if I did it or
not. Most people fill it out ahead of time and then
sign it once the case is over.
Q. All right.
A. And I believe that is what I ended up signing
along with the case after -- you know, a few days later.
Q. All right. Now, let me then give you
Exhibit 4.
A. Yeah.
(Exhibit 3 marked)
MR. IREDALE: And now I want to give you a new
exhibit which I've marked as Exhibit 3.
MR. HEGELER: Thank you.
MR. IREDALE: I'll give a copy to counsel.
BY MR. IREDALE:
Q. And what we'll also do in the interest of
completeness is mark as Exhibit 5 the copy of the
amended or edited medical record that is made in a form
that's easier to follow that was provided to me earlier
today by your counsel.
A. Yes.

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off?
A. No. I could do it remotely.
Q. And you did it remotely?
A. Yeah. I would not have done it -- I would not
have gone back to the hospital.
Q. All right. Now, let me ask you to look at
page 1328.
A. Yes.
Q. This chart graphs certain physical parameters,
including heart weight and blood pressure?
A. Yes.
Q. And does it do pulse as well?
A. Yes.
Q. And how is this chart generated, if you know?
A. It's automatically taken from the -- our
digital anesthesia monitor. It's transferred to Epic
and recorded.
Q. Now, may I refer you to the next page.
A. Yes.
Q. This is page 1329 -A. Um-hmm.
Q. -- of Exhibit 3.
On the left-hand side, you'll see that there
are a list of various items, including nitrous oxide,
air, midazolam, fentanyl, "propolol" -- propofol,

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lidocaine, sufentanil, phenylephrine, et cetera.
A. Um-hmm.
Q. Now, to the right of the chart, there are
certain numbers that are shown. For instance, by
fentanyl, it shows 150.
A. Yes.
Q. It says "fentanyl injection 150."
Do you see that?
A. Yes.
Q. Now, that's also, according to the left-hand
column, in micrograms?
Is that properly reflected there as being in
micrograms?
A. Yes.
Q. And it says 150, but that is not entirely
accurate.
Is it because you took 2 micrograms -- or you
took a certain amount -- how many -A. So this 150 is accurate. The 100 is not after
it. So the 150 I remember being given with induction,
and I took the rest and said it was given.
Q. So it reflects that there was a fentanyl
injection of 100 sometime between 8:45 and 9:00 o'clock.
And, in fact, that injection was not made?
A. Yes.

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Q. Did you tell Tammy Nodler that you had, in
fact, injected or administered that second dose of
fentanyl?
A. I believe so.
Q. Now, there's also a reflection of
phenylephrine.
A. Um-hmm.
Q. Do you see that?
A. Yes.
Q. Was that also an entry made by a human?
A. Yes.
Q. And so are -- can you tell me the manner in
which these entries are typically made? That is to say,
does the person who makes the entry take notes to
reflect the time or -A. You go back and -- a lot of times you could
make close approximation by changes in blood pressure.
So if you look here at the blood pressure drop, that
was -- I can almost guarantee that was when induction
occurred. So you could say, "Well, that's when I gave
this drug, this drug, this drug, and this drug." And
then you're like "Okay. Intubated -- it took this
amount of time to do this. So that's when I started
these infusion, this infusion, this infusion, this
infusion." And then you enter that in.

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Q. And, in fact, that fentanyl was -- well, there
was an injection made, but it wasn't into Randy;
correct?
A. Yes.
Q. Now, there's also a reflection that there was a
propofol -- and I believe that's an infusion?
A. Yes.
Q. It says 150.
And it shows that the time also is at some
point between 8:30 and 8:45 a.m.?
A. Yes.
Q. Now, is this generated by an entry from a human
being, or is this generated by some automatic -A. Human.
Q. Human.
And so that depends upon the accuracy of the
human making the entry?
A. Yes.
Q. Did you make that entry?
A. I don't know. I don't remember.
Q. How about the fentanyl injection? Did you make
the first entry?
A. I -- I do not remember.
Q. Did you make the second entry?
A. I do not remember.

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Nothing is usually instantaneous. If you're
doing one thing once, you can go "dink" and hit a -- hit
a button, pick your drug, pick your infusion rate.
Patient's weight is automatically populated so that it
will -- it will tally up the amount and say the rate as
that straight line.
But not everything is an exact science because
often you're doing multiple things at once.
Q. So insofar as this page of the records is
concerned, some of the data is reconstructed ex post
facto?
A. Yes.
Q. Some of the data is not based on specific
recording at the time the event occurs, but an inference
based on the other data from the chart?
A. Yeah. Sometimes you can hit -- hit a touch
screen and do more instantaneous, but it is all
dependent on what's going on. And each case and
procedure is different on what you can do all at once,
what you have to wait to do, what you have to
guesstimate to the best of your ability. The vital
signs are pulled in automatically. So those are not -MR. HEGELER: Mr. Iredale, have you established
who customarily makes those entries?
MR. IREDALE: No, I have not. Let's ask that

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question.
BY MR. IREDALE:
Q. Who customarily makes those entries?
A. Usually it's not the attending because it's
considered busywork.
Q. So would you -A. But sometimes, to help out, an attending would
do it. So I -- I cannot remember who did it in this
case.
Q. So you can't tell us whether you may have done
it?
A. I can't.
Q. Or whether Ms. Nodler did it?
A. I can't.
Q. Or whether, as part of his learning experience,
the resident did it?
A. No. I -- I mean, there's probably a 33 to
50 percent chance I did it, but I don't -- I wish I
could tell you, but I don't know.
Q. All right. Let's go, if we could, to
page 1331.
A. Oh. Sorry. Yes.
Q. There we go.
Now, according to this, this sufentanil
infusion has continued from 9:15 through to 10:45; is

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afterward?
A. So usually if you adjusted the rate -- see
where it says on the propofol on page 1- -- on 1333 that
it went from 125 to 160? That would have been -- I
mean, you'd have to ask her, but that would be the time
where she increased the rate of propofol.
Q. I understand. I'm talking now about the
records and how the records reflect or do not reflect
what goes on in a precise way.
And my question is, as a general matter, is the
record that we see -- for example, on 1333, that kind of
record -- is that made at the end of the surgery?
A. Simple calcula- -- or not calculated. Simple
entries like this, if you do -- they would not be
changed at the end of the procedure.
Q. And how are the entries made?
A. You just -- there's a -- you pick your drug.
There's, like, a Pharmacy tab. Think of it like
Windows. And you hit the Pharmacy tab, and then there's
a list of frequently used medications, and you can pick
your drug based on that. Or you click on the screen
with an arrow on the infusion rate. So you click here
with your mouse, and then you -- it would pop up, and
then you can change your fusion rate in a matter of
seconds.

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that correct?
A. Yes.
Q. And the rate is reflected as being 0.05.
A. Yes.
Q. And as I understand your testimony, that is
referring to units per minute on this chart.
A. Yes.
Q. 1333. Could I refer you to that page.
A. Yes.
Q. And according to this, the sufentanil stopped
being administered at about 11:07 or 11:08 a.m.
A. That's what it says.
Q. And with respect again to this page, would your
answers be the same as with respect to the earlier
pages? You don't know who made that particular entry?
A. I -- this, I would -- more likely than not it
would have been Tammy.
Q. Because you were -A. Gone.
Q. -- having your finger stitched?
A. Yeah. I was gone.
Q. Now, typically are these entries on -- that
we've seen on page 1329, 1331, and 1333 which shows the
time, rate, and amount of anesthesia administered -- are
they typically made during the surgery, or are they made

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So if you don't have a bunch of things on at
once, usually there's no time delay in your -- in your
changes. At the beginning of the case, at the very end
of the case, when a bunch of things are happening at
once, sometimes you change -- you enter your data after
the fact. But practitioners, to their best ability, try
to get the -- the times and the doses correct.
Q. Now, let's go, if we could, to page 1336.
A. Yes.
Q. Do you see on that page where it says
"sufentanil"?
A. Yes.
Q. It says "Sufentanil 1,000 micrograms in sodium
chloride."
A. Um-hmm.
Q. And a dosing weight of 140 kilograms.
A. Yes.
Q. And then it says Total dose as of 1/27/17,
193.33 micrograms.
Did I read that properly?
A. Where does it say that?
Q. Do you see -- oh, I'm sorry. I'm reading in
the wrong place.
It says 10 -- .02 -A. Yeah.

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Q. -- milligrams.
A. Yes.
Q. "Mg" means milligram; right?
A. Yes.
Q. And 1 milligram is a thousand micrograms.
A. Yes, sir.
Q. Now, do you see that there is a notation of a
"New Bag, Intravenous" at 8:41 a.m.? By sufentanil -under sufentanil.
A. Oh.
Q. Go across, if you would, from left to right.
A. Oh, it says "New Bag."
Q. And then a rate change is reflected at 10:58.
A. Yes.
Q. And then it says "Stopped" at 11:06.
A. Yes.
Q. Do you see that?
Now, and there's a notation of Tammy Nodler on
the far right-hand side.
A. Yes.
Q. What does the reference to Tammy Nodler mean?
A. It -- it means that she was the person logged
into the computer system at that time.
Q. And beside her name, it says "Edited."
A. Yes.

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A. Yes.
Q. And then there's a column that is to the right
of "Event" that says "Last Edited."
Do you see that?
A. Yes.
Q. And then at the bottom of that column, under
1330 hours, "Anesthesia Stop."
At the bottom of the Last Edited column, the
date is February the 3rd, 2017, at 10:31.
Do you see that?
A. Yes.
Q. And beside that on the right is your name,
Bradley Glenn Hay; is that correct?
A. Yes.
Q. Could we go to page 1338.
A. Yes.
Q. This has Attestation Information.
Do you see that?
A. Yes.
Q. And is this also a typical entry in records
that you fill out?
A. Yes.
Q. And so, for instance, you have attested that
the induction occurred at 8:41 a.m.?
A. Yeah.

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Q. "Edited."
And "Edited" means that there was a change made
at some point by someone?
A. Yes.
Q. And is that done in the Epic computer -A. Yes.
Q. -- if you know?
And does the Epic computer preserve a record of
who does the editing?
A. I'm sure it does, but I have never seen the -that part of the Epic. So I don't -- I mean, I'm sure
it does, but I -- I -- I've never seen it. I don't know
where it is, where it goes, anything like that.
Q. All right. Let me refer you now to the next
page.
A. Um-hmm.
Q. You see where it says "Events" -A. Yes.
Q. -- in the middle of the page. And then it has
a chronology by hour -A. Um-hmm.
Q. -- and minute on the next column -A. Yes.
Q. -- after the date and then a series of events.
Do you see that?

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Q. And that there was continuous monitoring and
you were immediately available during the procedure?
A. Yes.
Q. It says, under the Attestation Text, "I was
present for induction (if applicable) and critical
events and immediately available throughout"?
A. Yes.
Q. "Continuously monitoring and immediately
available throughout" is below that where it says
"Emergence Attestation."
A. Yes.
Q. All right. Now, at some point, Ms. Nodler came
back after you had removed the 15 ml from the 20 ml
syringe and put it into two separate syringes.
A. (Nods head.)
Q. And at that point, did you discuss anything
with her?
A. I would have discussed, like, how to -- the
wasting of the drug, but I don't remember particulars.
Q. And did you waste the drug in her presence?
A. Well, we made the numbers equal 1. So
everything that was removed from the Pyxis machine
equaled what was given, and the rest was -- I -- to the
best of my recollection, I squirted it into the sharps
container which is above the anesthesia machine. And,

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you know, you didn't have to do the whole fingerprint
stuff because 1 -- it equaled the amount taken out of
the -- taken out. So you don't have to waste if there's
no waste on the anesthesia record.
Q. But forgive me. You took out four -A. Yes.
Q. -- 5 mls?
A. Yes.
Q. You used, during the surgery, according to the
record, one of those four.
A. Yes.
Q. So there are three remaining.
A. Yes.
Q. You have to account for the three.
A. So if you do the math, the rate of 0.05 is not
the rate that was done through the case. That's way,
way more than anyone would actually ever use during the
course of an anes- -- that would be too much sufentanil.
But I either had Tammy do it or I did it, made
that number, which was probably closer to 0.01, or
0.01333 in reality -- to make the 1 milligram of
sufentanil look like it was given to the patient, that
number was changed to equal out to 1 milligram at the
end of the case.
Q. So, in other words, you had it so that it would

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Q. -- was false.
A. Yes.
Q. And it was designed to be false so that it
could make it appear that everything that had been
checked out, the four units, had all been used.
A. Yes.
Q. And therefore, instead of that, only one unit
or thereabouts was, in fact, used?
A. Yes.
Q. In order to placate her or make it look as
though there was nothing wrong going on, you disposed of
saline -A. Yes.
Q. -- under the impression that she would believe
it to be sufentanil?
A. Yes.
Q. And that she would then go along with this
falsification of the records because there would be no
harm done?
A. No harm, no foul.
Q. Unless in some way a doctor needed to go back
and get an accurate reading on how much was, in fact,
used because of some issue with the patient's health.
A. Yeah.
Q. In which case there would have been false

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reflect that all of the sufentanil that had been checked
out -A. Was given.
Q. And so when you squirted it out into the
sharps, was anybody present to see that?
A. Tammy.
Q. But if she saw you squirt it out, wouldn't that
constitute the wasting of the sufentanil?
A. Well, no. What I said was, "Well, you know,
let's just make this equal 1. And, look, I'm squirting
this out in here so it doesn't look like I'm take -- not
taking it."
Q. So, in other words, you were saying to her,
"Instead of dealing with the complexities of working
this out, let's just say it equaled everything that we
checked out."
A. And, "Look, I'm not" -- I'm going through the
charade that I'm squirting out the sufentanil when, in
all reality, it was saline.
Does that make sense now?
Q. I understand what you're saying, yes.
A. Okay.
Q. In other words, the rate that was put in
here -A. Um-hmm.

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information.
A. Yes.
Q. Now, did -- and -- and Ms. Nodler agreed to do
that; right? In other words, she agreed -A. Well, yeah. I said, "Let's just do this." I
didn't order her to, but I'm -- I don't know if she
thought it was shady or what she thought. I can't speak
to her. But, yeah, I mean, she -- as far as I know, she
agreed to it. And I don't know if she told anyone else
or did anything like that. So -- but -Q. Did you ever have any other similar arrangement
with Ms. Nodler in the past?
A. No.
Q. With any other nurse anesthetician, have you
done similar arrangements in the past under the guise of
making everything easier?
A. Yes.
Q. How many times? 20? 50? Best estimate.
A. 50, 100, 150. I don't know. Enough to where
it was a sneaky way of me being able to divert narcotics
in a different manner, to have multiple different ways
of doing it so that one way wasn't repetitive.
Q. Yes.
And how many separate nurse anestheticians do
you think were involved in these 100 to 150 occasions in

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which --

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A. 15. I don't know. I -- 25. That happened

2

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with residents too. It happened on cases I did by

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myself. So it was just random.

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Q. All right. And as far as you know, no nurse

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anesthetician ever reported you for seeking to falsify

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records?

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A. No.

9

Q. And as far as you know, no resident ever

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reported you for seeking to falsify records?

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A. As far as I know.

11

MR. IREDALE: All right. Why don't we take a
five-minute break.

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THE VIDEOGRAPHER: Off the record at 4:09 p.m.

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(Recess)

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THE VIDEOGRAPHER: We are back on the record at

16

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4:16 p.m.

17

(Exhibit 6 marked)

18

BY MR. IREDALE:

19

Q. Let me, if I could, show you Exhibit 6.

20

MR. HEGELER: Thank you.

21

BY MR. IREDALE:

22

23

Q. And could I refer you to page 1347.

23

24

A. Yes.

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Q. At the bottom of the page, there's a section

25

MR. HEGELER: You may have misspoke. You said
he came in, and I think he said he did it -THE WITNESS: From home.
BY MR. IREDALE:
Q. You said the opposite. From your home.
A. From home.
Q. Yes. Forgive me. I misspoke.
MR. HEGELER: It's all right.
BY MR. IREDALE:
Q. Now let me give you an exhibit that I will mark
as 7 -A. Yeah.
Q. -- the first page of which says "Declaration of
Chih Hsu, PHARM" -- or "PharMD."
(Exhibit 7 marked)
MR. HEGELER: Thanks.
BY MR. IREDALE:
Q. I do not know if you have ever seen this
document.
Can you tell me whether you have.
A. I never have.
Q. All right. With that understanding, I'm
nonetheless going to ask your assistance in helping me
to decipher it and give me whatever information you can
concerning the entries in it.

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that says in bold "Anesthesia Transfer of Care Notes."
A. Um-hmm.
Q. Can you tell me what that means?
A. Handing over the care of the patient from
anesthesia to the post-anesthesia care unit and nursing
department.
Q. And below that, Anesthesia Post Note.
A. That's just the note describing what you see
there, the procedure, type of anesthesia, where the
patient is now, whether there's any complications or
pain issues or anything like that.
Q. Did you make this entry, if you know?
A. I think -- yeah, I'm the only one who can.
Q. And can you tell me when you made the entry?
A. I -- with -- it looks like on the 3rd of
February.
Q. So it -A. Is that what it says?
Q. It says "All Post Notes. Last Edited 2/3/17,
10:32."
A. Yeah, on February 3rd of 2017.
Q. So you came in, and in addition to closing the
file or as part of that, you made this entry?
A. Yeah. You have to -- you can't close the file
until you do a Post Note.

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A. Um-hmm.
Q. The first page is a declaration by Chih Hsu -it says "PharmD." And he states that he is "authorized
to certify the Anesthesia Waste Records of Bradley Hay,
MD, from April 1, 2016, through April 27, 2017, to be
produced by Defense Counsel to Plaintiffs' counsel on
June 28, 2019, attached hereto as Exhibit 'A'."
A. Um-hmm.
Q. And then he goes on to say that the copy of the
records provided is a true and accurate copy of the
report on -- in the possession of UCSD Medical Center,
with redactions made to preserve the privacy of third
parties, and that the records were made by personnel of
UCSD in the ordinary course of business.
A. Um-hmm.
Q. He then says that the report is identified by
pages 1 through 22.
Now, let me just ask you, with respect to
anesthesia waste, can you tell me in 2017 what your
understanding was of the policy or the protocol
regarding documentation of waste of controlled
substances.
A. You would -- so the amount that was -- would be
recorded based on what you entered into the -- the Epic
charting, and there would be numbers there about -- that

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said the amount that was administered during the
procedure. And also you would do a handwritten record
on a chart that had the different drugs and the
patient's name and medical record number. And basically
those two numbers had to equal out.
And waste -- on -- as far as wasting the
drugs -Q. Yes.
A. -- the -- whoever it was checked out to would
have to have a witness log in or biometric data that
said that, yes, they witnessed the -- the -- whoever
checked out the drug, that they either wasted it in
front of him or vice versa, and that was a witness
waste.
Q. All right. Now, at no time in any of your
career was there ever a request to have you turn over
what you said was waste so it could be tested to see
what it was?
A. No.
Q. And on, would you say, at least a thousand
occasions you substituted saline in place of waste?
A. That sounds like a lot, but yes.
Q. I won't press unduly. Would you say at least
800?
A. Yes. Yes.

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Q. -- who would attest to it.
A. Yes.
Q. And the question your counsel asked me to press
is when did that happen? When did that change occur, as
best as you remember?
A. Sometime probably -- I can't remember if it was
before -- probably before we got our Epic program, but I
honestly -- I don't even -- don't even remember when -when we made the switch. But later in my attending
career. Like, maybe in the last three years, sometime
around there maybe. But I -- I haven't -- I've never
thought about it. So I don't -- everything was habit.
Q. All right. Were you ever told, by anyone
before the 27th of January, that the amount of
anesthetic waste you generated was, according to the
records, three times as great as that of any other
anesthesiologist?
A. No.
Q. Would it surprise you to know that?
A. No.
Q. Do you know if anybody was keeping track of
that before the 27th of January there at UCSD?
A. I have no idea.
Q. No one ever approached you about it?
A. No.

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Q. And how many of those times occurred after the
procedure change which required you to have somebody
affirm that they had seen the waste be disposed of?
A. How many times? Well, a lot of times you -- I
can't speak to numbers. All I can say is you're in the
ballpark, that 800 number. I don't know what it is.
But the next question -- could you repeat it.
Q. Yes.
Now, at some -- can you tell me of those
times -MR. HEGELER: When did -- when did the
procedure change? Have we laid that foundation? I'm
not sure.
MR. IREDALE: No. That's the question.
BY MR. IREDALE:
Q. You described the procedure in effect which
involved giving back the waste to the pharmacist -A. Yeah.
Q. -- when you were a resident.
A. Yeah.
Q. And then at some point that changed -A. Yeah.
Q. -- so that it was required that the wasting be
done in front of a witness -A. Yeah.

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Q. No one ever says -- said to you or asked you
why is there such a great amount of materials left over
from your administrations of anesthesia as opposed to
anybody else?
A. No.
Q. Okay. Now, understanding that this is the
first time you've seen the document, I'm going to just
ask you to look at it. It says "CareAreaName" on
page 1.
A. Um-hmm.
Q. The column says "CareAreaName," and then there
are some things that say "HC Anes."
Any idea what that means?
A. Hillcrest Anesthesia. That might have been -that might be a packet. I don't know the difference.
One's -- yeah, I honestly don't know which one's which.
Q. Yes.
And then beside that, it says "Location," and
there's just -A. Yeah.
Q. -- a string of "not applicable" there.
A. Yeah.
Q. Beside that, it says "StationName."
A. Um-hmm.
Q. Do you know what "Station" refers to or could

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refer to? Understanding that you didn't do this
document.
A. Well, the -- so Anesthesia 2, Anesthesia
Workroom would be where there's a Pyxis dispensary in
the Anesthesia Workroom. Same Day Surgery 2 would be
OR-2 and Same Day Surgery 2. HC_OR-4 would be the -probably be the Pyxis machine and the fourth OR at
Hillcrest. And you just go down the line and -- I think
those are where the Pyxis machine is located.
Q. Very good.
But then the Pyxis machine has to do from where
you obtain the substance -A. Yeah.
Q. -- is that right?
A. So -Q. Because the disposal can take place anywhere so
long as it's witnessed; right?
A. I believe so. You just pick the case and then
say it's witnessed.
Q. So, for instance, people have disposed of
controlled substances by throwing them down the sink?
A. Yeah. By -- yeah, by sink, trash can, sharps
container.
Q. Toilet? Sharps container?
A. Well, usually not the toilet because there's no

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biometric -- or sometimes they don't read very well.
You type in the code, and it works. So I'm assuming
those are the two differences.
BY MR. IREDALE:
Q. Yes, sir.
Let me now ask you if I could refer you to
page 3.
A. Um-hmm.
Q. Under "UserType," it says Anesthesiology -"Anesthesiologist"; "PatientName, Anesthesia OR"; and
then there's a "PatientID."
A. I don't know what -- it's gibberish to me.
Q. Any idea what reference that would have to the
waste disposal?
A. No idea.
Q. And on page 4, there's a notation
"Anesthesiologist" and then "Dalo, Randall Timothy."
A. Um-hmm.
Q. Let me take you to page 5, if I could.
A. Um-hmm.
Q. Now, this has, on the left-hand column, things
that say "Return Item," "Vend," and "Waste."
A. Um-hmm.
Q. "Return Item" means, in your mind, if anything?
A. Usually you turn back -- well, it looks like

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toilets in the OR.
Q. Oh, all right.
But in any event -- and any public health
concern about putting controlled substances in the water
supply?
A. I don't think so. I think it's standard
practice.
Q. All right. In any event, there's no strict
requirement that the waste take place in any particular
centralized location?
A. Well, there is a centralized waste container on
the Pyxis machine, but I don't -- it didn't get used all
the time.
Q. Transaction time and date -- would that refer
to the time when the material was taken out of the
Pyxis, if you know?
A. I believe so.
Q. "UserName" -- it has your name, and then,
beside that, "UserID," 51020.
Do you know -(Simultaneous colloquy)
THE WITNESS: That was my user ID. So
someone -- sometimes you -- I think if you do a
biometric scan, it would probably say "B. Hay." And if
I typed in "51020" on the machines that doesn't have

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it's your anesthesia kit. So in certain locations you
can check out a kit, which had, like, a -- rather than
one, single, individual item, it had, like, a large
number of, like, five to seven or nine fentanyl vials,
Versed, some morphine, some Dilaudid, some of this, some
of that. And so you had to return the kit. So if you
look at return, usually it's the anesthesia kit that is
given back to the station.
Q. And is it given back empty, or is it given back
with the items unused in it?
A. The -- it's given back -- because, remember,
you record your waste to the Pyxis machine. So what's
given back is your unused, unopened vials. So you
return that to the Pyxis machine so it can be used at a
later date.
I think some drugs -- I don't remember which -you're not able to -- I don't know if you can't waste
them, and so you actually have to return the unused drug
because you're not -- for some reason you're not allowed
to waste them based on volume maybe. Then you have to
turn those back in through the -- as part of your kit.
Q. All right. And then "Vend," V-e-n-d?
A. Was dispensed.
Q. Do you know what "Demand Count" refers to?
A. No.

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Oh. I believe -- so sometimes if you're in a
Pyxis machine in the operating room, you say I want 5
cc's of fentanyl, and it clicks and opens up, and you
have to verify that the number in the machine matches
the number of empty spaces or full spaces. So sometimes
they don't match up.
So let's say it says -- the machine says
there's nine vials left but there's only eight or
there's more vials than are -- are there. And you have
to -- you have to say, "Hey, this isn't right."
Q. Very good.
May I refer you now to page 7.
A. Yes.
Q. And this is just with respect to the middle two
columns. It says "MedAltID1" and "MedAltID2."
Do you know what those refer to?
A. No.
Q. The numbers below the second column -- any idea
what that refers to?
A. No idea.
Q. It appears as though this document has been
deliberately written in a cryptic way to make it
impossible -- impossible to understand what it means.
A. Yeah. I -- this whole thing seems kind of
worthless, this whole document.

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A. Yes.
Q. It says "DiscrepancyResolutionDESC" and below,
toward the bottom of the page, "UNDER - User with prior
access cancelled removal, but still removed medication."
No idea?
A. Yeah, I don't know.
Q. Page 15.
A. Um-hmm.
Q. The same notation on the left lower portion.
Any idea what that refers to?
A. No.
Q. There is a column on page 15 that says
"WitnessUserName," but that's all blacked out.
A. Um-hmm.
Q. Then page 21.
A. Um-hmm.
Q. The column on the left says "OverrideReason."
Any idea what "Override" means in connection
with Pyxis or waste?
A. No idea.
Q. Thank you.
Let's now, if we could, go to the 27th.
And do you remember at about what time it was
that you injected the sufentanil in the restroom that
was right off the recovery room?

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Q. Could we go to page 9.
A. Yeah.
Q. And this has a column that says
"DrawerSubDrawer" and "Pocket."
A. Um-hmm.
Q. Any idea what that refers to?
A. I -- this is all an assumption. So you have a
drawer that has fentanyl in it. It's got a number. And
within that -- let's say there's ten pockets within that
drawer. So it's referring to the drawer and then the
space within the drawer.
Q. And then "DispenseAmount" refers to either the
kit or the amount of the drug that was dispensed out?
A. Yes.
Q. Could I ask you just to look now at page 11.
A. Yeah.
Q. The columns reads as follows: "Quantity,"
"BeginCount," "EndCount," "UnitCost," "ExtendedCost,"
"DiscrepancyDifference."
Any idea what that refers to?
A. I mean, it's probably the amount of whatever -yeah, I don't know. Whatever -- it says there's 50
vials of something in there and 3 were taken out, so now
there's 47. And -- yeah, but I don't know.
Q. Could I ask you to go to page 13.

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A. I don't know. I'd have to look at the -anesthesia end time was about 1315. It was probably -I'd have to see when extubation was. And that was at
1306. It looks like we left the operating room at 1310.
So it was probably 1315, which is going by how this
looks and me walking the patient to the PACU and then
basically going to the bathroom immediately.
Q. All right. You went inside the restroom.
A. Yes.
Q. Locked the door?
A. I don't know.
MR. HEGELER: Well, I guess it lacks foundation
that there was a lock on the door. I don't know. I'm
not trying to hassle you.
THE WITNESS: Well, I don't know how they got
in there.
MR. IREDALE: Well, then just don't hassle.
THE WITNESS: I don't know if I locked it.
MR. IREDALE: All right. That's fair. The
objection was well-taken. Your response is appropriate.
Now we're going to have to stay till 7:00.
MR. HEGELER: That's two today; right?
MR. IREDALE: That's fair. That's fair.
BY MR. IREDALE:
Q. So tell me what you remember.

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You went inside the bathroom.
A. Um-hmm.
Q. You don't remember if you locked it.
Was there a lock on the door? Let's answer the
critical question in this case. Let's crack this case
wide open. Was there or was there not a lock on that
door?
A. Yes.
Q. Did you or did you not lock the door?
A. I don't know. Well, people came into the room.
I don't know -- into the bathroom at some point. So I
don't know if it was locked or if they unlocked it
themselves. I have no idea what happened at that point.
Q. Tell me what you remember before everything
went dark.
A. My -- I was -- my idea was "I'm just going to
use a little bit of sufentanil." My head had switched
back to it being only 5 micrograms per ml, when, in
fact, it was 50. So my plan was just to give myself a
little bit and then go home.
But I injected a factor of 10 more than I
thought I did. And I did it in my usual spot in my
femoral vein, and then I remember thinking, "Oh my god,
this is not -- something's not right," because I felt
too much right away. And the next thing I know I stood

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question.
When you came to, when you regained
consciousness, what do you remember?
A. Well, I remember voices. And I looked around,
and there was people everywhere. And then I looked on
the floor, and I saw syringes. I saw vomit. And I saw
blood on the wall from my finger wrapping had come done.
And I don't know how -- when or how that happened. And
I was just, "Well, I'm caught. I'm -- the gig's up."
Q. You said you noticed colleagues around you?
A. Yeah.
Q. Which colleagues do you remember?
A. I remember seeing Tony, who was the resident
who was part of the case.
God, I don't remember who else. I remember
there was a -- one of the PACU nurses was there. I
don't remember her name.
A couple of other people in the depart- -- I
don't -- I -- other than Tony and -- that's all I
vividly remember. And maybe there was one other
attending. I can't remember his name. It's an Indian
guy. I can't -- can't remember.
Q. Was there Dr. Bryzenski who was there, who
arrived there at some point?
A. I don't remember seeing her, but if any -- she

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up and then woke up on the floor with a bunch of

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colleagues around me.

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Q. Now, when you woke up --

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A. Um-hmm.

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Q. -- what do you remember?

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A. What do I remember?

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Q. Um-hmm. Yes.

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A. Well --

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MR. HEGELER: Can I talk to him for just one
second.

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MR. IREDALE: Yes.

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MR. HEGELER: Just take a second.

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Watch your --

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THE WITNESS: Oh, sorry.

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THE VIDEOGRAPHER: Do you want to go off the

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record?

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MR. IREDALE: No.

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Well, actually, you know what, yes. We can go

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right back on. I just don't want anybody to leave.

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THE VIDEOGRAPHER: Off the record at 4:38 p.m.

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(Brief recess)

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THE VIDEOGRAPHER: We are back on the record at

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4:39 p.m.

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BY MR. IREDALE:

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Q. Now, I need to ask you, Dr. Hay, the same

25

would have been there. I think she was running the
floor. She would have been one of the first people
there.
Q. Do you recall her at some point looking at the
syringes and saying that that was lidocaine in there or
words to that effect?
A. No.
Q. Now, did you remain on the floor, or were you
helped to your feet at some point?
A. I think I sat -- well, I pulled my pants up,
and then I sat down. And then people wanted me to go to
the emergency room.
Q. And did you go to the emergency room?
A. No.
Q. And what else do you remember happening after
you came to?
A. Just people making sure I was -- asking if I
was okay and then, "You need to go to the emergency room
to get seen." And -- that's about all I remember.
And then I was like, "I just need a couple
minutes." And then the last thing I wanted to do was go
to the emergency room. I just wanted to get home and
get away from everything.
Q. Were you able to stand at that point?
A. Oh, yeah.

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Q. And at any time at the hospital that day after
you had passed out and then come to, were you asked to
submit to a fitness examination?
A. I don't know. I don't remember being asked
to -- that's a fairly specific phrase. So I don't -- I
can't answer -- I mean, I had just done a lot of
sufentanil. So I can't -- I mean, my recollection of
that time period is not perfect.
Q. Well, yes, you had because you had made a
mathematical error -A. Um-hmm.
Q. -- by a factor of 10.
A. Um-hmm.
Q. And sufentanil is 10 times at least stronger
than fentanyl, and fentanyl is 10 times at least
stronger than heroin.
A. Um-hmm.
Q. And so I accept your answer.
Do you recall leaving the hospital?
A. Yes.
Q. And do you recall how long a period of time
passed between the time you noticed your colleagues
around you and came to and the time you left?
A. As soon as I could get out of there. So I'm
thinking, from my first memory to being out of the

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confusion; and then Ann Glassmoyer, who was -- I called
those three people in addition to my wife to come get
me.
Q. And was your sponsor at that time
Dr. Fischbach?
A. Yeah.
Q. Do you recall what you said to him?
A. Well, I just told him what happened.
Q. The same with Dr. Seaberg?
A. Yeah.
Q. And Ms. Glassmoyer?
A. Yeah.
Q. You then went home.
Any communication with anybody from the
hospital the following day?
A. I can't remember. I know I had a couple phone
calls -- or I guess I can remember. I had a couple
phone calls with Ann Glassmoyer and Robin Seaberg.
Basically they were trying to get me into -- into rehab
as soon as possible. But I had to get surgery on my
finger. So I was like "I've got to get this taken care
of. I wish I could go right now." So there was, you
know, that communication.
Q. At some point did you speak with the head of
anesthesia, Dr. Manecke?

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hospital, it was probably five to seven minutes.
Q. Did you drive?
A. No.
Q. How did you get home?
A. Well, I was accompanied out by another
attending, and he wanted -- he's like "If you're
leaving, I'm not going to let you drive."
And I'm like "Believe me, after this, I'm not
going to drive. I just want to call my wife and have
her come get me. I promise you I won't drive."
But he wanted to -- he didn't trust me to not
drive away.
Q. Who was that? May I ask.
A. Nav Sandhu.
Q. And so did you call your wife?
A. Yeah.
Q. Did she come and pick you up?
A. Yes.
Q. And she drove you home from the hospital?
A. Yes.
Q. From the time you called her till the time she
arrived, what did you do, if anything?
A. I called my sponsor. I called my -- Robin
Seaberg, the head of the Well-Being Committee, just to
let her know what happened and clear up if there's any

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A. Oh, God. I don't think so. I don't remember.
I don't believe so.
Q. Was there any later communication between you
and any hospital official?
A. Official? Not directly. Only through a
lawyer.
Q. Who was the lawyer? Was it Mr. Zeigen?
A. Yes.
Q. At some point did you come to understand that
there had been a report made to the Medical Board?
A. Yes.
Q. How did you gain that understanding? But -- I
don't want to ask any communications with your counsel,
but were you -- were you given to understand by anybody
that the hospital had reported the incident?
A. The hospital either told my -- I think they
told my lawyer that this was a reportable offense and
that's how I learned about it. So I don't know if I
heard before or after they reported, but I knew that it
had happened or was happening.
Q. And did you have any communication with anybody
from the hospital regarding your employment status?
A. The only thing I did was try to go out on sick
leave so that I could possibly get disability before I
was fired. So I called and wrote an e-mail and said

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that I wanted to go on sick leave.
Q. Was that permitted?
A. Yes.
Q. And were you able to get disability?
A. Yeah, for a time period.
Q. Now, at some point, the Medical Board did bring
charges against you?
A. Yes.
Q. And you are aware that your conduct violated a
variety of laws?
A. Yes.
Q. And you admitted that fully.
A. Yes.
Q. You understood that the commission of any act
involving dishonesty or corruption substantially related
to the functions or duties of a physician or surgeon
could be grounds for the loss of your license?
A. Yes.
Q. And that a violation of a federal statute
regarding dangerous drugs or controlled substance is
unprofessional conduct?
A. Yes.
Q. Prescribing or administering a drug to yourself
is unprofessional conduct?
A. Yes.

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A. Yes.
Q. And that it was in violation of both federal
law and state law?
A. Yes.
Q. And you pled guilty in federal court to a
felony offense?
A. Yes.
Q. In violation of Title 21 -A. Yes.
Q. -- 843(b)(3), which is obtaining a controlled
substance by fraud.
A. Yes.
Q. And in that regard, you admitted completely
that you were guilty?
A. Yes.
Q. And I believe you were sentenced to a period of
probation.
A. Yes.
Q. And in connection with your sentencing, you
submitted letters that had been written on your behalf
by various persons.
A. Yes.
Q. Including Ms. Glassmoyer?
A. Yes.
Q. And Kai McDonald?

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Q. Making or signing a certificate or other
document that falsely represents certain facts related
to the practice of medicine is unprofessional conduct?
A. Yes.
Q. Altering or modifying the medical record of a
person with fraudulent intent or creating a false
medical record constitutes unprofessional conduct?
A. Yes.
Q. The failure to maintain adequate and accurate
records constitutes unprofessional conduct?
A. Yes.
Q. Practice of medicine while under the influence
of a narcotic drug in such a way that your ability is
impaired to conduct the practice of medicine is
unprofessional conduct?
A. Yes.
Q. Prescribing or administering or furnishing a
controlled substance for yourself is unprofessional
conduct?
A. Yes.
Q. Obtaining controlled substances by fraud or
deceit or misrepresentation is unprofessional conduct?
A. Yes.
Q. And you recognize, of course, that you violated
statutes related to obtaining controlled substances?

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A. Yes.
Q. Kerri Berengrude?
A. Yes.
Q. And also Drs. McDonald and Frost?
A. Yes.
Q. Now, finally, I just need to discuss with you
some policies and whether you were given any information
or training in these particular policies.
Were you at any time trained on the UCSD Health
controlled substance distribution and control policy?
It came into effect in September of 2016.
A. Not that I know of.
Q. May I ask if you know what CURES, C-U-R-E-S,
means?
A. I -Q. I can suggest Controlled Substance Utilization
Review and Evaluation System?
A. I've heard of it. I don't know what its role
is. I don't -- I know -- I've heard the name. That's
it.
Is that -- I don't know if that's, like, the
state government, how they monitor prescribed narcotics.
I think that's what it is but -Q. You're exactly right, I believe. Yes.
All right. Were you familiar that there were

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supposed to be regular audits conducted on the use of
controlled substances there at the hospital?
A. Audits have been spoken of, but I did not know
the frequency, what they looked at, or how -- or how
they were done.
Q. During 2016 or 2017, were you ever asked any
questions by anybody who was conducting an audit of
controlled substance use?
A. Not that I recall.
MR. IREDALE: I think I need to let everyone go
home now. Thank you so much.
THE WITNESS: Thank you.
MR. IREDALE: I know that this has not been
easy for you, and I appreciate your attempts to be as
honest as possible.
And if you want, I'll let your counsel propose
a stipulation concerning the deposition.
MR. HEGELER: Shall we use -- shall we use the
same stipulation that we used yesterday that she's got?
Is that okay with you?
MR. IREDALE: That's fine with me.
MR. HEGELER: All right. Let's go ahead and do
that before we leave.
Is that okay with you?
MR. FARRUGIA: That's fine.

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I, Bradley Glenn Hay, do hereby declare under
penalty of perjury under the laws of the State of
California that I have read the foregoing transcript;
that I have made such corrections as noted herein, in
ink, initialed by me, or attached hereto; that my
testimony as contained herein, as corrected, is true and
correct.
Executed this _____ day of ____________, _____,
at _______________, _________________.

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___________________________________
Bradley Glenn Hay

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MR. HEGELER: All right. Fine.
THE VIDEOGRAPHER: Off the record at 4:55 p.m.,
and this marks the end of this deposition.
(Discussion off the record)
THE REPORTER: And do you need your own copy?
MR. HEGELER: Yes.
THE REPORTER: And you as well?
MR. FARRUGIA: Yes.
(Whereupon, the deposition concluded at 4:56 p.m.)
*****

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: : : CERTIFICATE OF REPORTER : : :
I, GINA MARIE DE LUCA, a Certified Shorthand
Reporter, holding a valid and current license issued by
the State of California, CSR No. 6973, duly authorized
to administer oaths, do hereby certify:
That the witness in the foregoing deposition
was administered an oath to testify to the whole truth
in the within-entitled cause;
That said deposition was taken down by me in
shorthand at the time and place therein stated and
thereafter transcribed into typewriting, by computer,
under my direction and supervision.
Should the signature of the witness not be
affixed to the deposition, the witness shall not have
availed himself/herself of the opportunity to sign or
the signature has been waived.
I further certify that I am neither counsel for
nor related to any party in the foregoing deposition and
caption named nor in any way interested in the outcome
thereof.
Dated: This 24th day of November 2019
at San Diego, California.
__________________________________
Gina Marie De Luca
CSR No. 6973, RMR, CRR

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A
A' 205:7
a.m 2:21 5:9
50:24 51:2
73:2 130:2
143:7 144:24
176:2,21,21,23
184:14 187:10
191:11 194:8
196:24
AA 39:17 47:5
114:10
ability 11:25
79:3 81:20
161:19 189:21
193:6 227:13
able 15:19 21:10
36:12 48:4
63:11 78:22
79:2,24 85:20
86:7 94:19
95:25 110:9
114:8 119:22
122:19 123:24
133:20 140:11
159:14 168:9
169:3 170:8
180:12,24
201:20 213:17
221:24 226:4
abnormally
72:2
absolutely 31:13
39:11,11 47:1
89:12 122:17
167:8
abstain 36:12
abstinence
46:17,19
abstracted
164:9
abuse 12:15,24
17:24 18:3,17
19:4,10,20
46:4,23 66:24
76:4 86:1 95:8
96:19 99:20
101:13,22

114:20 125:16
125:22 126:4,9
126:20 127:2
128:10
accept 44:6
222:18
accepted 7:16
43:21 45:1,4
acception 45:3
access 17:19
18:11,13 19:12
159:19 167:25
168:7,18 216:4
accident 9:7,8
9:23 10:11,13
acclimated
69:19
accompanied
223:5
account 198:14
accounted 31:2
accuracy 73:23
187:16
accurate 31:18
180:10 186:16
186:19 200:22
205:10 227:9
accurately
148:3
accusation 98:4
98:7,11 156:24
acdf 131:13
aches 86:18
achieve 83:20
acquired 30:25
act 63:25 104:23
110:23 226:14
activ- 81:5
active 97:16
actively 97:14
activities 72:16
81:5 82:17
83:7
activity 72:2
141:2,3,4,20
acts 59:15
actual 33:22
87:17 89:16

157:23
acute 53:6
Adderall 59:13
addicted 24:20
29:4,6 30:12
30:14 35:16,23
36:1,12,17,18
36:18 37:22
49:6 53:25
64:22 106:17
116:17 122:12
124:19
addiction 15:12
18:23 20:22
30:16 34:10
37:2 39:19
46:8 53:23
55:5 57:9
64:19 67:5
68:1,4,16
91:10,11 115:3
115:15 149:11
addictions 38:20
38:21
addictive 20:14
106:24 126:12
addicts 39:16
addition 77:19
203:22 224:2
additional 73:25
129:9
adequate 227:9
adjusted 192:2
adjustments
148:7
administer
138:22 169:12
233:4
administered
60:10 111:4
125:1 137:17
139:8 147:16
148:10 152:2
156:9 158:22
168:17 171:7
188:2 191:11
191:24 206:1
233:5

administering
155:24 226:23
227:17
administration
137:14 167:17
administrations
209:3
administrators
184:19
admit 11:19
16:20 68:1
admitted 40:19
68:15 226:12
228:13
admitting 11:6
advance 12:19
adversary 175:6
advisal 167:14
adviser 38:25
74:23,23
affirm 207:3
affixed 233:9
Afib 131:19
afternoon
127:17 134:7
afterward 192:1
agent 166:21
agents 165:20
agitation 81:12
84:11
ago 21:3 30:10
agonist 57:21
agree 5:12 19:21
44:17 92:13
112:1 167:6
agreed 93:3
126:7 157:2
167:15 201:3,4
201:9
ahead 71:4
183:6 230:22
air 170:11
185:25
airway 133:12
134:12
airways 142:7
al 5:3
albeit 96:12

Imagine Reporting 619.888.0297

177:4
alcohol 13:1,4
13:18,20 15:3
15:12 16:3,22
alcohol-related
15:16
allegations 98:4
Allen 1:7 2:7 3:8
5:21 54:9,11
allow 111:8
allowed 115:19
213:19
alpha-2 57:21
alter 160:4
alter- 88:7
alterations 88:7
Altering 227:5
amended 183:22
amends 11:12
11:14
Aminokadeh's
70:20
amount 22:3,4
27:16,20 37:6
48:24 50:8,13
50:13 68:18
83:22 108:25
109:25 110:25
111:14,14
113:11,11,20
124:25 137:9
138:23 141:3,7
148:10 153:3
156:9 157:23
158:9 170:22
182:4 186:18
188:23 189:5
191:24 198:2
205:23 206:1
208:14 209:2
215:13,21
amount.' 158:13
amounts 82:11
83:19 156:13
amphetamine
59:15
ampule 26:11,12
26:22 28:4

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153:11
ampules 26:16
26:18,20
147:18 148:15
151:8 153:11
analgesic 180:12
and/or 83:20
ANDERSON
3:15
anes- 198:18
Anes 209:12
anesthesia 4:10
4:15 15:1
17:12 20:2
21:25 31:6
43:4,8 53:10
54:6,13 57:23
60:10,25 75:22
108:1,2,3
109:15 111:5
117:22,23,24
118:21,22,24
118:25 119:14
119:15 120:14
120:21,25
121:1,4,5,12
121:15 124:25
126:23 138:4
139:22 141:9
141:12 142:4
153:25 158:19
161:3 165:11
166:15 167:17
169:11 184:7
185:16 191:24
196:7 197:25
198:4 203:1,5
203:7,9 205:4
205:19 209:3
209:14 210:3,3
210:5 212:10
213:1,7 217:2
224:25
anesthesia-rel...
43:15
anesthesiologist
23:16 40:7
41:8 43:3,22

44:1 45:2
47:18 48:9,11
48:21 49:3
51:10 52:7,15
60:1 63:20
65:23 74:19,21
77:4 79:21
91:25 103:16
107:16 119:19
120:9 126:16
126:20 146:19
161:13 162:18
208:17 212:10
212:17
anesthesiologi...
17:15 18:5,16
18:22 19:5,16
38:25 41:18,22
113:15,16
anesthesiology
7:20,20 8:22
18:9,22 19:8
92:4 107:4
126:8 142:19
212:9
anesthetic 21:24
32:22 40:1
56:3 109:20
111:1 137:14
146:3 165:19
166:21 168:17
180:13 208:15
anesthetician
161:14 201:14
202:6
anestheticians
113:16 201:24
anesthetics
137:20,21
anesthetist 52:4
52:6,8,11 53:7
53:12 61:23
155:20,25
anesthetists
53:4
anesthetize
111:6
anesthetizing

111:1
Angeles 3:11
angry 104:18
animals 56:3
Ann 106:5 224:1
224:18
anonymity 97:1
anonymously
101:16
anoxia 84:15
answer 18:19
22:16 60:2
85:12 88:11
90:17 137:24
143:1 172:1
174:4 218:4
222:6,18
answers 191:14
antecubital
27:15
anterior 131:18
Anush 70:18
92:5
anybody 90:15
112:8 125:24
125:25 127:23
127:23 166:3
199:5 208:21
209:4 219:19
224:14 225:14
225:21 230:7
anymore 114:9
184:21
anytime 126:5
apathy 84:10
APC 3:3
apnea 149:17
170:12
apologize 12:19
72:23 96:22
123:18 129:14
apparent 111:9
apparently
78:23 142:11
143:2
appear 200:4
appearance
73:12 181:20

APPEARAN...
3:1
appears 39:7
134:10,11,17
144:19 145:3
160:6 163:6,13
214:21
applicable 61:11
197:5 209:21
application
41:16
applied 7:16
appointed
102:18
appointments
103:7
appreciate 30:3
73:22 129:17
137:25 230:14
appreciated
175:8
approach
169:21
approached
208:24
appropriate
27:16 108:4
169:4 171:22
217:20
appropriately
111:14 113:12
170:9
approximate
103:23
approximately
30:8 47:8
67:15 90:6
103:5 160:21
165:15
approximation
188:17
April 97:19
98:12 100:8
106:15 112:25
113:25 114:4
120:6 122:11
122:18,21
205:5,5

Imagine Reporting 619.888.0297

area 17:23 74:19
93:24 166:2
areas 107:21
argue 125:13
argumentative
127:14
arisen 182:11
arm 27:8 119:16
arrangement
22:19 201:11
arrangements
107:3 201:15
arrested 15:24
16:24
arrests 16:3,9
arrived 220:24
223:22
arrow 192:22
art 141:23
arterial 171:13
171:17
artery 173:7
aside 74:8
asked 38:16,17
38:21,23 74:8
74:10 75:16
77:20 79:7
102:23 182:24
184:16 208:3
209:1 222:2,4
230:6
asking 39:6,7
77:19 134:18
169:23 221:17
asks 144:24
asleep 141:10,13
141:14 142:10
170:23
aspect 60:25
aspects 62:5,7
assigned 93:15
104:12 184:10
assistance
204:23
associated 50:2
50:9 140:11
assume 70:13
120:16,18

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assuming 78:3
95:24 212:2
assumption
215:7
attached 205:7
232:5
attempt 59:22
85:6
attempting 81:8
attempts 230:14
attend 93:16,21
96:7
attendance
97:11
attended 6:20
7:3 93:16
174:15
attending 38:25
40:7 41:7 43:3
43:21 44:1
45:1 48:11
49:3 51:9,23
60:1 74:22
75:18 79:21
139:22 142:18
142:19 150:10
162:18 190:4,7
208:9 220:21
223:6
attention 84:18
84:19 85:13
attest 208:1
Attestation
196:17 197:4
197:10
attested 196:23
attorney 73:9
attributes 18:7
Atwater 77:8
79:12 87:18
audio 5:10
audit 230:7
audits 230:1,3
August 9:17
authority
127:24
authorized
205:3 233:4

automated
184:18
automatic
187:13
automatically
185:15 189:4
189:22
automobile 9:23
autonomy 62:6
availability
126:11,12
164:2
available 56:9
60:19 63:16,21
134:1 148:19
197:2,6,9
availed 233:9
average 15:7
30:16 60:9,15
60:20
averaged 47:9
avoid 48:4 73:11
84:2 123:24
awake 132:1,3,4
141:10,12
167:24 168:2
aware 5:10
19:12 226:9
B
B 4:8 211:24
baby 85:23
Bachelor 6:22
back 21:21 22:8
36:9 46:4,18
51:1 55:2
59:23 62:12
63:14 64:16
69:19,22 73:6
87:7 90:10,12
92:21 95:17
104:20 105:13
105:23 109:15
110:14 114:11
116:10,13
117:16 122:11
123:24 124:14
131:11 144:2

144:10 154:20
160:2,4 161:25
162:7,14
174:16 181:5
181:17 185:5
188:16 197:13
200:21 202:16
207:17 212:25
213:8,9,9,11
213:13,21
218:18 219:19
219:22
background
6:12
backwards
141:18
bad 63:18 91:17
115:19
bag 138:21
143:19 194:8
194:12
bagel 139:19
174:7,8
bagels 139:24
ballpark 207:6
bar 54:8 64:10
Bart 5:18
BARTON 3:15
BartonHegele...
3:19
based 88:6
89:21 108:12
161:12 164:2
180:10 189:13
189:15 192:21
205:24 213:20
basically 31:1
46:16 71:1
78:10 102:7
107:24 110:12
112:1,3 119:8
119:17,22
148:25 162:19
182:20 206:4
217:7 224:19
basis 31:20 36:4
42:2,4,21
68:21 78:9

94:23 142:9
bathroom 34:14
34:16,18,24,25
35:6,11 37:9
61:3 64:15
93:15 116:25
149:4 172:3,4
172:15 217:7
218:1,11
bathrooms
34:19,22
116:22 163:20
beard 133:24
bed 149:3
beer 13:9,14,17
13:20
began 12:25
19:22 23:3,4
26:2 41:19
44:18 48:8
49:6 59:18
71:11 79:21
98:12 99:14,22
100:8 101:4
114:5
BeginCount
215:18
beginning 5:1
12:16 13:3
29:12 47:17
51:12 137:21
137:23 142:3
193:3
begun 176:20
behalf 5:16,18
5:20 106:7
228:20
behaving 38:15
behavior 16:20
67:4 71:3
74:12 75:10
92:15
behavioral 75:8
75:25 76:1
84:9 104:11
believe 6:13 7:8
11:22 12:11
14:8 16:5 19:3

Imagine Reporting 619.888.0297

19:11 22:14,23
22:24 37:13
38:7,24 44:2,4
47:4 52:2 53:8
54:12 59:15
65:4,21 66:13
66:22 69:8
70:10,14 71:25
72:15 75:9,21
76:9,13 78:15
79:2,14,18
80:19 89:4
97:21 100:5
105:1 117:21
121:23 122:22
125:17,19,23
126:15 129:22
134:4 144:6,6
147:17,23
150:19 154:14
157:9 161:6
162:19 163:14
164:11 165:4
165:12,21,23
166:4 167:21
169:17 176:8
179:25 180:4
180:10 181:24
182:13 183:9
187:6 188:4
200:14 210:18
211:17 214:1
223:8 225:2
228:16 229:24
believed 65:1
147:9
believing 146:11
146:20
Ben 77:8 79:12
87:18
benign 119:3
benzodiazepine
55:15,17,24
56:23
Berengrude
229:2
best 11:25 20:1
21:4 27:4

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28:15,21 30:1
30:1,2,18
36:15 37:3
39:23 41:2
48:14,24 49:14
56:6,16 58:25
89:7 100:21
103:11 155:22
161:18 165:9
168:13 174:14
174:16 181:10
182:13 189:21
193:6 197:24
201:18 208:5
bet 133:2
better 64:13
Betty 66:15 67:9
67:23,25 71:6
71:12 80:3,21
87:11 89:25
90:4,6,14 91:4
102:1
beyond 90:24
big 62:15 168:3
168:4,6
bill 119:23
billing 125:11
biometric
107:20 108:13
206:10 211:24
212:1
Bipolar 71:9,14
80:8,17,20
birth 6:9
bit 28:13 74:12
152:2 218:17
218:20
blacked 216:13
blame 87:25
128:3
block 145:12
blocks 119:15
blood 169:3
185:10 188:17
188:18 220:7
Board 66:17
90:2 97:24
156:25 157:11

225:10 226:6
body 153:1
bold 203:1
bolus 153:17,18
155:24 156:1
bolusing 156:4,4
bottom 196:6,8
202:25 216:3
bought 58:5,6
58:13
Boulevard 3:10
10:15
box 21:19 50:12
Brad 49:25
Bradley 1:7,16
2:7,20 3:14 4:3
5:2 6:2,8
184:13 196:13
205:4 232:1,12
brain 28:17
140:25 141:1,2
141:19
break 50:17,20
60:14 61:1,2,3
84:25 117:12
129:16 154:8
161:24 174:20
181:12 202:13
breaked 61:1
breathe 133:20
Brief 219:21
briefly 84:21
87:7
bring 226:6
bringing 64:12
brings 39:19
Broadway 5:5
broke 80:2
brother 44:11
74:13 76:10
brought 9:14
18:21,25 19:5
28:3 69:23
139:24 148:21
167:24
bruising 173:4
Bryzenski
220:23

90:1
calls 181:25
224:17,18
Camino 10:15
canal 173:14
cancelled 216:4
cancer 44:11
capital 130:22
caption 5:3
233:11
car 9:7 10:9
cardiac 43:4
108:3 119:18
C
care 53:6 85:24
C-U-R-E-S
119:14 120:16
229:13
120:19,23,24
C4-7 131:13
128:19 184:22
cabinet 22:22
203:1,4,5
caffeine 59:15
224:21
59:16
care-related
calcula- 192:13
53:6
calculate 151:7 CareAreaName
calculated
209:8,11
192:13
career 23:18
calculation
206:16 208:10
148:9 156:19
cars 9:25
calculations
Casa 115:5,8,14
148:8
122:23 123:20
calculator
case 1:6 2:6 5:3
156:20
9:5 21:24
California 1:1,8
32:10 33:11
1:17 2:1,8,23
43:8 50:14
2:25 3:5,8,11
56:10,19 61:16
3:17 5:6 7:19
61:18 62:5,13
8:5,21 12:9
127:23 130:5
46:18 105:18
130:17 137:22
232:3 233:4,15
137:23 140:13
call 63:19 72:23
142:3 144:11
88:10 93:14
151:1 154:6
223:9,15
159:9 160:6
called 46:12
161:21 162:19
62:19 71:21
170:23 171:15
84:5 88:8
171:15 178:2
107:11 115:5
180:7,21 183:7
161:5 223:21
183:10 184:10
223:23,23
189:18 190:9
224:1 225:25
193:3,4 198:16
calling 88:13,13
198:24 200:25
bucked 140:17
141:21
bunch 74:15
193:1,4 219:1
burst 140:17,22
140:23 141:1,4
141:6,11,19
business 205:14
busted 140:2
busy 159:24
busywork 190:5
button 189:3

Imagine Reporting 619.888.0297

210:18 218:5,5
220:14
cases 50:3 53:15
60:9,16 108:6
108:9 202:3
catheter 168:8
169:4
caught 88:12
89:21 140:1
220:9
cause 12:20
142:8 171:3
233:6
caused 83:3,15
cc 152:8
cc's 21:25 22:1
32:9,10,11,11
33:7,11 37:7
50:1 111:22
112:2 150:15
152:1,8,9,11
152:18 154:9
154:10,12,17
172:5 214:3
CD 81:25
cease 86:7
ceased 97:6
Center 7:4
67:10 107:24
205:11
central 1:2 2:2
167:24 168:2,3
169:9,20 170:5
171:16
centralized
211:10,11
certain 50:2
53:20 64:9
93:1 128:2
140:12 185:9
186:4,18 213:1
227:2
certainly 167:9
certainty 172:1
certificate 227:1
233:1
certified 2:24
52:4,7,11 53:4

 Page 238
53:12 109:24
113:10 119:23
233:3
certify 109:25
111:25 113:15
113:19 205:4
233:4,10
cervical 131:17
131:18 138:12
171:3,5
cessation 95:13
cetera 186:1
chain 59:21
chair 41:9 65:7
65:19 103:14
chance 190:18
Chang 70:13
92:2
change 22:23
92:15 107:7
154:9 179:17
179:21 192:24
193:5 194:13
195:2 207:2,12
208:4
changed 22:22
49:10 107:8
159:22 178:3
192:15 198:23
207:21
changes 21:13
71:3 84:9
188:17 193:3
characteristic
83:25
charade 199:18
charge 15:22
125:5
charged 114:19
114:22
charges 226:7
chart 33:8,23
50:10 156:16
158:1 159:23
162:17,20
176:8,11,12,15
176:20 185:9
185:14 186:3

189:15 191:6
206:3
charting 156:8
157:21 205:25
charts 184:21
Chavez 5:7
65:24,24 66:20
75:23 76:21
77:7 79:11
89:3
check 21:19
49:14 88:15
93:13 94:16
104:14 108:1,4
108:11 125:25
153:10 163:12
213:2
checked 108:12
110:3,5 115:5
125:5 144:2
147:4,15,17,20
149:24 151:8
154:23 165:4,6
199:1,16 200:5
206:9,12
chest 28:18
Chih 4:17
204:14 205:2
Children's 51:8
chloride 193:14
choose 149:7
Christmas
43:17 124:5,6
124:14
chronologically
59:23
chronology 98:8
123:18 195:20
chunk 140:2
churlish 127:19
cinnamon 140:2
cited 184:10
claim 149:21
clar- 75:17
clarify 73:14
clean 28:7,8
76:6,13
clear 61:7 87:21

223:25
clearly 59:23
click 192:21,22
clicks 214:3
clinic 145:12
clinical 53:6
70:14 92:3
clinically 84:8
close 47:25
54:23 60:7
162:17,20
184:16 188:17
203:24
Closed 184:13
closer 54:23
178:4 198:20
closing 146:8,9
146:9 203:22
CN- 61:9
cocaine 58:15,20
58:23
code 107:20
108:13 212:2
coding 160:1
coincidental
121:9,17,23
colleagues 219:2
220:10,12
222:22
college 13:4 16:8
Collegial 54:21
colloquy 69:11
124:10 167:2
211:21
column 117:23
118:9 186:11
195:22 196:2,6
196:8 209:11
212:21 214:18
215:3 216:12
216:17
columns 214:15
215:17
coma 84:17,21
141:16
combat 99:7
combination
33:7 149:13

combined 73:18
come 8:4 14:11
14:13 15:3,6
26:11 39:17
46:13 62:12
64:16 66:6
75:16 87:9
88:16 104:20
127:24 155:5
161:25 164:18
169:5 220:7
222:2 223:10
223:17 224:2
225:9
comes 39:19
comfortable
97:3 156:3
coming 107:15
commence 8:8
48:14
commenced
167:22
commencing
2:21
commenting
66:7
commission
226:14
committee 65:6
65:23,25 69:25
70:1,13 75:19
75:22,24 76:18
76:19,24 77:12
77:13 87:9,17
89:5 91:6,7,9
91:21,23 92:2
92:8,16,18
100:17,20
101:4,8,11
102:4,11,18,22
103:3,8,9,15
103:24 104:2
104:17,20,22
104:25 105:2,6
105:14,24
106:3,11
114:17 125:25
126:22 128:5

Imagine Reporting 619.888.0297

223:24
common 13:9
16:25 18:17
53:3 130:21
142:2,5 155:16
communicated
39:1,2,5
communicates
161:10
communication
224:14,23
225:3,21
communicatio...
225:13
community
102:7
complete 116:1
completed 40:9
115:25
completely
73:19 97:6
228:13
completeness
183:21
completion
40:11
complexities
199:14
complicated
61:20,21
complications
203:10
comply 110:11
111:9
complying
21:10
compulsion 96:7
computer 158:2
159:7,9,17
160:15 161:10
161:13,17
183:3 194:23
195:5,8 233:7
conceive 154:21
concentrate
81:20
concentrated
33:10

 Page 239
concentration
22:6 112:13
138:22 139:8
155:7 157:22
182:1
concern 75:5
211:4
concerned 39:6
189:10
concerning 9:23
108:25 204:25
230:17
concluded 8:24
231:9
conditioning
168:24
conditions
101:18 131:23
conduct 39:15
75:8 92:23
93:1,6 226:9
226:21,24
227:3,7,10,14
227:15,19,22
conducted 66:18
230:1
conducting
230:7
conference
164:20,23
confronted
88:21 89:23
confused 87:16
96:23 156:22
confusing 151:3
confusion
177:11 224:1
connection
216:18 228:19
connections
69:21
conscientious
73:22
consciousness
85:21 220:3
consecutive 72:3
consent 90:15
166:15,16

167:6,14
consequences
15:13 72:17
considered
141:4 190:5
consistency
112:17
constant 18:11
138:20,23,24
153:22
constitute 199:8
constitutes
227:7,10
constriction
84:14 85:2
consuming
24:14
consumption
33:24
contact 165:25
contained 232:6
container
181:19 197:25
210:23,24
211:11
context 9:5 54:2
continue 11:18
46:8 96:6,11
96:14 102:20
121:20
continued 13:3
14:5 36:1 79:3
83:2,13,21
97:14 98:23
104:23 110:23
190:25
continuing
104:13
continuous
197:1
Continuously
197:8
control 82:15
229:10
controlled 17:20
18:12 19:13
46:1 49:9 55:8
57:1,6 99:2,19

100:3 205:21
210:21 211:4
226:20 227:18
227:21,25
228:10 229:10
229:16 230:2,8
conversation
19:1 129:1,21
134:3 136:15
139:17 140:12
conversations
40:24 43:6
conversion
157:24 182:14
convert 178:16
conviction 15:21
16:13,17,20
convictions
15:18
copd 131:19
142:6
copy 92:19
143:3 174:25
183:18,21
205:9,10 231:5
Cordial 54:19
corner 184:6
correct 11:4
40:6 73:10
74:23 95:9,12
98:14 116:24
117:2,5,10
121:19,25
123:5,7 126:10
126:14 169:2
176:22 177:2
179:8 187:3
191:1 193:7
196:13 232:7
corrected 232:6
corrections
232:4
correctly 130:11
corruption
226:15
cough 142:2,5,8
coughed 142:9
counsel 5:12,14

175:3,10
183:18,24
205:6,6 208:3
225:13 230:16
233:10
counseling
46:22
count 163:10
213:24
counting 163:14
counts 16:17
County 1:2 2:2
93:24
couple 14:24
25:10 29:3
34:9 42:8 44:9
48:5,23 53:5
69:18 72:25
90:13 100:14
103:18 108:5,9
114:8,11
172:16 184:24
220:18 221:20
224:16,17
course 17:19
22:5 24:3,6,15
49:5 58:8 59:5
66:14 68:15
72:24 89:24
109:4 129:18
137:18 167:5
169:18,18
198:18 205:14
227:24
court 1:1 2:1 5:6
40:19 228:5
cover 6:11 49:23
50:3 63:4,5
123:13 161:20
179:18
covered 63:2
90:5
covering 142:20
crack 26:23
218:5
craving 25:4
82:21
crazy 74:14

Imagine Reporting 619.888.0297

143:18,20
creating 227:6
Creighton 7:17
7:21,25 8:1,12
criminal 15:18
16:13
criminals
125:12
criteria 71:20
80:10,13,24
82:6,9 84:4,6
critical 53:6
197:5 218:5
CRNA 60:12,18
61:4,10 62:24
63:6
CRNAs 61:14
63:3
crook 172:21
CRR 1:22
233:20
cryptic 214:22
CSR 1:22 233:4
233:20
CU-PO-CTL
1:6 2:6
cup 93:15
CURES 229:13
curiosity 75:1
current 233:3
cust- 144:7
custom 144:9
customarily
144:7 189:24
190:3
cut 76:14 82:14
94:14 139:18
139:21,23
140:3 142:25
143:22 144:15
144:20 146:9
174:7,8 180:13
cutting 139:18
140:1 174:8
D
D 4:1
daily 31:20 36:4

 Page 240
40:24 42:2,21
68:20
Dalo 1:4,4 2:4,4
3:21,22 4:12
4:15 5:3 130:6
130:17 131:23
132:8 144:3
147:4 148:1,21
154:1 165:25
166:7,10,17
212:17
Dalo's 160:22
164:7 165:3
175:12
Dan 5:20 142:15
142:17,24
dangerous
180:18 226:20
DANIEL 3:10
dark 218:15
data 107:21
108:13 189:10
189:13,15
193:5 206:10
date 5:8 6:9
66:16 95:16,18
97:18 101:2
103:7 120:3,3
120:6,8 125:20
129:25 134:14
135:21 195:24
196:9 211:14
213:15
Dated 233:14
dates 97:20
98:14 117:22
124:3
datewise 47:24
DAVID 3:9
Davidson 3:21
5:4
DAVIS 3:16
day 5:8 25:13
30:17 32:25
34:9,12,12
37:2,19,20
41:17 47:8
48:15 50:14

60:9 63:4
67:21 69:9,12
69:15,15 70:5
81:1,1,5,10,13
81:15,18,21
88:8,18,18
90:4 93:14
94:17 106:20
114:2,6,14
115:20 116:20
117:1 122:24
123:4,23
124:19 127:17
127:18 128:10
139:24 140:4
144:8 146:24
149:7 163:5,7
163:11,18
164:15 172:9
172:12,13
210:5,6 222:1
224:15 232:8
233:14
days 13:14 19:6
42:23,24 72:3
115:18 116:6,7
160:22 183:10
De 1:22 2:24
233:3,19
dead 141:15
deal 62:15 82:17
110:7
dealing 95:7
199:14
dealings 40:23
dean 64:10
death 81:23
deceit 227:22
December 95:20
124:2,16
decide 149:7
decided 45:11
146:24
decipher 204:24
decisive 64:1
declaration 4:17
204:13 205:2
declare 232:1

decreased 72:6
deep 144:17
defendant 3:14
9:11,13,19
Defendants 1:10
2:10 3:8
Defense 205:6
define 84:22
defined 83:18
deflect 74:15
degree 6:22,24
7:8,11,13
17:15 18:8
19:9,17
delay 193:2
deliberately
214:22
Demand 213:24
denied 66:14,14
66:14 76:5,5,5
76:5 89:24,24
89:24
deny 66:23 67:1
depart- 220:18
department
7:19 8:21
38:15 41:9
65:7,19 70:2,3
90:18,21,22
91:1 203:6
departments
103:21
depend 60:11
depended 42:5
dependence
20:20
dependent
189:18
depending
42:18 62:13
108:6 116:7
164:23 168:4
depends 187:16
deponent 5:23
deposition 1:16
2:20 5:2,12 9:3
230:17 231:3,9
233:5,6,9,11

depressant
56:25 57:1
depressed 66:10
80:25 86:14
depression 67:4
99:7 104:14
depressive
80:14,25
deprivation
85:23
desaturate
170:15
describe 15:9
28:12,13 52:10
65:3 109:22
181:19
described 22:19
207:16
describing
203:8
designed 200:3
desire 82:14,21
desired 83:20
despite 40:23
83:2,13
destroy 32:22
destroyed 32:19
32:20
details 21:9
91:15
detect 71:3
develop 20:17
69:20
developed 84:11
developing
84:16
Dexmededoza...
57:11
dexmedetomi...
57:7,12,15,18
57:20 58:1
Dexmedetomi...
57:13
diagnosis 71:6,8
71:14 80:7,11
80:17 82:3
diagnostic 71:20
82:5 84:4

Imagine Reporting 619.888.0297

dial 139:6,9
156:14,15
Diarrhea 86:24
died 44:11
Diego 1:2,17 2:2
2:23 3:5,17 5:6
7:19 8:5,21
46:10 64:10
69:20 93:24
115:9 233:15
dieting 81:7
difference 33:22
112:16 209:15
differences
212:3
different 31:1
39:16 42:11,12
50:11 110:2,4
110:7 112:21
141:9 161:18
177:4 189:19
201:21,21
206:3
differently
38:15
difficult 130:8
130:24 167:22
182:11
digital 185:16
dilation 84:14
86:22
Dilaudid 55:13
56:5,5,10,18
57:2 58:1
106:23,24
213:5
dilute 22:3
diluted 22:6
32:15,17 33:4
diluting 32:6
33:3
diminished 81:4
81:20 83:21
dink 189:2
direct 11:14
180:2,8
directed 87:9
direction 233:8

 Page 241
directly 44:15
105:10 110:14
225:5
director 70:14
77:9 92:3
105:21,22
106:9,13
directs 105:13
disability
225:24 226:4
disappeared
89:12
Disc 5:2
discectomy
131:18 138:12
discipline 97:23
disclose 68:3
91:4 92:12
disclosed 90:15
90:20 91:5
disclosure 68:12
discomfort
35:21
disconnected
181:10
discovered 71:5
discovery 74:3
discrepancy
38:16 90:23
DiscrepancyD...
215:19
DiscrepancyR...
216:2
discuss 12:14,23
84:6 86:5 87:7
118:5 120:2
175:21 197:16
229:6
discussed 19:2
91:10,12 93:7
104:8 121:18
136:18 174:21
197:18
discussion 12:17
104:7 182:10
231:4
disease 171:3
dishonesty

226:15
disorder 71:9
80:8,20 82:3,6
82:10
dispensary
210:4
DispenseAmo...
215:12
dispensed 107:4
213:23 215:13
dispenser
107:12,13
dispensing 49:9
displayed
136:17
disposal 210:16
212:14
disposed 109:16
111:19 200:11
207:3 210:20
dissolved 101:25
distinct 140:25
Distractibility
72:13
distribution
229:10
diversion 15:20
15:20 16:16
27:22 101:24
102:5 105:17
105:18
divert 101:18
111:15 180:24
182:18 201:20
diverted 27:20
30:22 67:1
diverting 66:13
88:7 97:20
divide 177:24
178:16,25
divided 178:25
division 1:2 2:2
52:6 61:11
doctor 51:4
175:5 200:21
doctors 18:4,15
95:7 96:19,20
102:12

doctors' 91:5
document
117:20 118:2,4
118:19 128:18
128:18 175:15
175:16 204:19
209:7 210:2
214:21,25
227:2
documentation
112:22 205:21
doing 23:24
25:20 27:5
29:11,11 43:25
46:13,25 71:2
74:10,11 78:21
97:13 102:8
108:7 125:21
126:1 127:25
159:24 161:10
162:17 167:24
170:23 189:2,8
201:22
door 37:21
217:10,13
218:4,7,9
dosage 29:1
dosages 108:21
177:12
dose 138:14,24
153:18,18,19
155:24 156:2
158:8,12
177:25 178:4,6
188:2 193:18
doses 37:19
108:18 153:17
193:7
dosing 193:16
double 60:20
Dr 4:11 5:2,19
5:21,21 41:13
41:14,24 43:1
44:2,3,17 54:9
54:11 65:20,24
66:21 70:4
73:9 75:21
77:10 79:15

87:13 88:4
89:6 91:2,3,20
117:20 125:15
126:17 219:25
220:23 224:5,9
224:25
drank 46:9,10
46:16 48:2,6
draped 169:9
draw 27:1
drawback 169:3
drawer 215:8,10
215:10,11
DrawerSubDr...
215:4
drew 155:6
165:9,13
drill 64:6
drink 13:3,4,9
13:13 14:5
47:7,14 48:3
drinking 13:21
46:5 47:13
drive 2:22 3:17
223:2,7,9,10
223:12
driver 9:25 10:9
driving 15:16,22
16:10,14,21
drop 188:18
drove 17:2
223:19
drowsiness
84:17 85:5
drowsy 85:7,8
85:10
Drs 229:4
drug 25:4,6,8
39:8 50:11
58:20 59:9
67:5 68:1,3
76:6,7,12,15
77:20 78:1,3
78:11 93:10,10
93:13 94:2,11
94:13 95:1
109:1,10
111:16 112:22

Imagine Reporting 619.888.0297

123:21 136:7
138:22 148:10
166:24 167:1
181:21 182:17
188:21,21,21
188:21 189:3
192:17,21
197:19,20
206:12 213:18
215:13 226:23
227:13
drugs 22:20
50:4,8 57:3,25
58:3,5,7,13
65:1 66:13
67:1 68:18
97:17 99:5,19
106:23 107:3
107:12,17
108:2,23
109:14,20
110:7,10 117:6
123:11,14
125:5 165:5
181:1 206:3,7
213:16 226:20
drunk 16:5 48:5
DSM 126:3
DSM-5 71:14,19
80:11,24 82:9
due 84:14
duly 6:3 233:4
duties 37:17
226:16
dwindling 96:9
97:12
dysphoria 84:10
dysphoric 86:13
E
E 4:1,8
e-mail 225:25
E-p-i-c 159:12
earlier 100:5
128:10 135:14
150:3 158:8
172:10 183:23
184:15 191:14

 Page 242
early 13:1 21:15
21:18 29:7
95:23 137:19
140:10,13,14
154:21 155:8
earned 6:22,24
7:8,13
easier 156:5
182:17 183:23
201:16
easiest 182:15
easily 54:17
168:5
easy 40:21 168:6
230:14
echocardiogra...
119:20
ecstasy 58:16,17
ED 4:12
edit 159:14,17
160:22
edited 183:22
194:24 195:1,2
196:3,8 203:19
editing 195:9
education 52:20
52:22
EEG 140:25
effect 44:7 83:20
83:21 158:15
207:16 221:6
229:11
effects 82:19
83:4 149:18
egiredale@ire...
3:6
eight 37:4 60:21
106:20 114:2,6
114:13 115:21
116:20 122:23
123:2 124:19
163:18 214:8
eighth 11:9
either 16:18
26:12 27:11,12
32:1 83:25
88:18 93:11
99:3 102:20

104:22 107:20
110:15,15
117:6 133:19
138:21 141:15
156:19 164:24
174:3 198:19
206:12 215:12
225:16
El 10:15
elbow 172:21
electroenceph...
140:24
em 69:17 73:19
143:14
embarrass
12:17
embarrassing
149:1
embarrassment
12:19
emerge 35:12
emergence
62:19 197:10
emergencies
63:22
emergency
122:8 145:10
174:12 221:12
221:13,18,22
emergent 122:9
emoji 133:9
empathogen
58:17
employment
7:14 8:17
104:23 225:22
empty 32:13,16
152:21 213:9
214:5
Encinitas 10:14
10:14
Encounter
184:12
EndCount
215:18
endeavor 11:24
ended 36:13
44:22,25 66:15

183:9
energy 72:2
81:15
engaged 68:7
Engy 146:11,14
146:15,15,17
146:18,20
enhance 102:11
enjoy 35:15
ensure 101:12
entactogen
58:18
enter 161:16
188:25 193:5
entered 161:13
205:24
entire 64:23
77:13 179:10
entirely 169:7
186:15
entirety 168:10
entries 109:1
120:3 121:18
121:24 163:1
175:21 183:3
188:13 189:24
190:3 191:22
192:14,16
204:25
entry 120:25
121:4,12,21
153:24 160:11
160:12 174:2
187:12,17,19
187:22,24
188:10,14
191:15 196:20
203:12,14,23
Epic 159:12,14
184:18 185:16
195:5,8,11
205:24 208:7
episode 57:8
71:21 80:12,15
80:25
episodes 71:24
equal 148:11
156:21 158:7

178:2 182:4,15
182:18,21
197:21 198:23
199:10 206:5
equaled 197:23
198:2 199:15
equaling 156:13
equals 150:20
158:9
equate 178:17
equation 149:24
equivalent
177:25
ER 139:19
error 156:8
157:21,22
158:11 222:10
escalated 106:19
114:5
especially 63:4
142:3,6 155:19
180:18
ESQ 3:4,10,15
3:16
essentially 44:8
44:13 61:16
66:17 101:11
105:16 180:21
established
189:23
estimate 22:18
30:1,2 37:3
39:23 56:6,16
58:25 112:21
174:14,17
201:18
et 5:3 186:1
EUGENE 3:4
euphoria 28:20
28:23 84:10
evaluate 101:14
evaluation
66:16 104:20
229:17
evaluations
104:16
eve 124:6,12,14
evening 134:8

Imagine Reporting 619.888.0297

event 16:19
64:12 77:12
106:15 120:12
122:8 160:2
172:13 181:5
189:14 196:3
211:3,8
events 59:21
73:21 195:17
195:24 197:6
eventually 25:7
25:14 34:11
everybody 91:8
128:8 139:25
evidence 145:3
ex 189:10
exacerbated
83:4,15
exact 11:7 17:25
43:9 47:24
48:24 49:7
66:6 101:1
110:12 149:9
159:21 165:16
165:16 174:18
189:7
exactly 46:21
101:7 123:17
134:11 136:18
148:4 151:22
160:18 229:24
examination 4:5
6:5 222:3
example 123:1
192:11
excess 21:4
excessive 46:5
72:16 81:17
excessively 48:3
exclusively
24:16,17
173:19
excuse 8:13 67:3
164:21
excuses 74:15
Executed 232:8
Executive 105:2
exercise 97:15

 Page 243
153:25 157:6
177:3,22
186:24 187:1
188:2 193:6
200:8,22
218:19
facto 189:11
factor 156:21
179:2 182:14
218:21 222:12
facts 87:24
156:24 157:3,5
157:7 227:2
fail 76:15
failed 94:2
failure 82:24
131:7 227:9
fair 17:14 18:15
30:3,13 39:24
40:4,12 56:13
60:14 75:2
90:25 95:23
98:17 123:6
127:4,5 144:22
147:1 151:25
157:12 160:9
177:5 217:19
217:23,23
fairly 52:13
140:14,14
168:6 222:5
fairness 16:12
97:22 99:1
128:2 132:24
157:13
fall 29:7
false 109:1
F
179:9,10,12,14
F 3:4
200:1,3,25
face 133:10
227:6
facilities 51:6
falsely 227:2
facility 51:5
falsification
52:1
200:18
fact 18:6 25:4
falsified 124:24
68:20 91:11
154:3 180:1,5
126:15 127:1,6 falsify 108:22
131:2 138:9
110:25 150:4
147:13 149:22
166:17 179:18

exhibit 4:10,11
4:12,13,15,16
4:17 117:18
120:4 124:24
128:17,20,25
162:21 175:16
175:19,23
183:12,14,16
183:16,21
184:1,3 185:22
202:18,20
204:10,15
205:7
existence 101:21
expect 116:4
expected 116:3
experience
71:23 72:10
155:20 190:15
explain 21:8,11
32:8
explained 158:7
expressed 74:25
75:5
ExtendedCost
215:18
extension 171:2
extent 40:3
91:14,16 128:2
extubate 174:20
extubation
62:19 174:17
217:3
Eye 107:23,24
eyeballs 71:2
119:10

179:21 202:6
202:10
falsifying 31:14
38:4 68:25
117:9 123:13
128:4
falsity 161:21
familiar 10:21
17:22 71:15
82:5 229:25
family 10:8
25:18 103:18
far 58:9 194:19
201:8 202:5,9
202:11 206:6
Farrugia 3:10
5:20,20 127:15
230:25 231:8
farrugiad@dj...
3:12
Fatigue 81:15
Fax 3:6,12,18
fear 133:23
fearless 11:3
February 196:9
203:16,21
federal 40:19
226:19 228:2,5
feel 24:24 28:18
35:14,15 73:13
91:7 162:13
feeling 25:2
28:20,20,23
46:7 72:5
86:14
Feelings 81:17
feet 221:9
fell 89:11
fellow 74:18
142:18
felony 228:6
felt 53:19 72:2
73:10 75:7
77:24 91:17
128:6 218:24
femoral 173:6,8
173:9,14,17
218:23

fentanyl 19:23
20:1,7,13,16
20:25,25 21:10
22:7 23:4,10
23:15,19 24:4
24:7,20 26:3
26:10 27:3
28:10,22,25
30:5,17,20,22
31:6 32:5,9
33:4,10,13,17
34:3 36:5 37:6
38:2,7 40:1
45:17 47:12
48:21 49:2
50:1 53:24
55:5,8 56:9
79:3,25 86:8
89:11,16 98:13
100:9,12 101:5
106:16,22,24
106:25 111:4,5
112:13,17
114:13 136:1,3
149:8,16
155:13,16,19
156:1,4 163:17
170:22 171:6
172:5,6,18
173:21,22,25
179:14,22
185:25 186:5,7
186:22 187:1
187:21 188:3
213:4 214:3
215:8 222:15
222:15
Fever 87:3
few-month 86:3
fiber 132:1,3,4
133:22
fiberoptic
170:24 171:1
171:12,16
fifth 11:5
figure 177:4
figured 88:12
file 129:16

Imagine Reporting 619.888.0297

203:23,24
fill 183:5,6
196:21
filled 182:4
final 146:5
152:23
finally 83:24
229:6
find 23:24 89:14
findable 168:5
fine 72:25 88:17
230:21,25
231:1
finger 139:18,21
140:3,3 142:12
143:1 181:6
191:20 220:7
224:21
fingerprint
107:21,22,25
198:1
finish 145:24
finished 46:6
97:3 180:21
182:3
fire 66:17
fired 90:1
225:25
first 6:3 19:6,25
20:2,24 21:13
23:10 24:19
25:14,22 26:2
27:2,11 28:22
28:25 29:8,15
30:12,15 34:7
35:24 41:14,17
48:15 49:2
74:5,6,7,16,25
84:24 100:25
102:1 120:3,25
121:9,17,24
127:16 130:12
132:16,17
135:23 146:16
165:25 170:21
172:9,17
187:22 204:13
205:2 209:7

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221:2 222:25
Fischbach
126:17 224:5
fitness 222:3
five 13:14 30:15
30:19 50:22
57:19 94:18
95:15,19,20
106:20 114:1,6
114:13 116:7
116:19 117:1
122:23 123:1
124:19 160:22
163:18 170:13
213:4 223:1
five-minute
50:17 117:12
161:24 202:13
five-year 94:22
95:13
flat 141:2,3,3
Flight 72:10
floor 2:23 3:4
89:12 219:1
220:6 221:2,8
focus 73:23
103:22
follow 11:24
183:23
followed 28:14
84:10 170:22
following 83:25
84:16 88:8
100:25 104:20
224:15
follows 6:3
215:17
Ford 66:16
67:10,23,25
71:6,12 80:3
80:21 87:11
90:1,4,7,14
91:4 102:1
foregoing 232:3
233:5,11
forged 89:10,11
89:18
forgive 64:5,12

113:16 123:17
198:5 204:7
forgiving 156:5
form 21:20
45:19 77:22,23
140:25 183:22
formal 16:20
45:3 76:1
104:1 119:21
formalized
101:22
formally 105:10
format 118:3
formed 102:7
105:18,19,19
former 126:16
forms 13:18,20
forth 84:4
forthcoming
175:7
fossa 27:15
foul 200:20
found 47:2
128:7 132:22
152:24
foundation
207:12 217:12
four 23:7 30:15
36:16 52:24
57:8 60:17
67:24 69:5
72:3 90:6
117:1 147:17
147:20 151:8
151:19 198:5
198:10 200:5
four-page
128:18
fourth 3:4 11:2
67:21 69:13,15
121:4,18,24
143:24 144:13
147:15 210:7
frame 46:6
fraud 128:6
227:21 228:11
fraudulent
227:6

free 73:13
162:13
frequencies
43:10
frequency 15:2
15:5 25:17
29:16 78:12
96:12 230:4
frequent 42:10
64:18
frequently
42:17,21,24
54:25 192:20
Friday 79:5
115:21 130:6
130:17 134:6
135:10 164:16
friendly 43:11
132:22
friends 53:17
front 25:24
77:15 89:19
111:19 145:19
206:13 207:24
Frost 229:4
fulfill 82:25
full 6:7 119:14
214:5
fully 124:18
226:12
fun 47:3
functions 43:16
226:16
furnishing
227:17
further 233:10
fusion 131:18
192:24
future 32:19
G
G 3:4
gain 81:8,8
225:12
game 89:25
Gene 5:16
general 14:1
18:1,4 34:18

42:25 52:5
61:6 66:6
91:11 104:7
108:2 119:14
171:19,22
192:10
generally 21:20
24:15 28:3
34:23 35:10
40:16 43:4
51:16 61:10
66:19 104:9
107:20 108:5
159:21
generated
185:14 187:12
187:13 208:15
gentleman
75:23
Gerard 1:7 2:7
3:8
getting 62:14,17
104:6 119:16
142:5 171:13
gibberish
212:12
gig's 220:9
Gina 1:22 2:23
5:6 233:3,19
give 9:18 22:16
22:18 61:2
67:3 85:18
98:10 128:22
138:13,13
139:11 156:2
174:19 180:12
183:11,15,18
204:10,24
218:19
given 9:3 21:6,7
22:1,5 33:17
50:13 71:6,9
82:2 83:7
123:4 138:23
152:4 157:22
157:23 160:7
161:19 182:16
186:20,21

Imagine Reporting 619.888.0297

197:23 198:22
199:3 213:8,9
213:9,11,13
225:14 229:7
giving 17:12
138:15 174:25
177:19,22
207:17
glass 26:12
Glassmoyer
106:5,6 224:1
224:11,18
228:23
Glenn 1:7,16 2:7
2:20 3:14 4:3
5:2 6:2,8
184:13 196:13
232:1,12
glide 134:1
go 5:12 9:21
15:19 29:20
32:25 34:25
35:4,6 36:8
37:17 45:11
47:10 49:19,24
49:25 53:7
55:2 59:23
64:5,15 78:11
87:7 89:25
93:15 96:3,14
97:1,5 102:15
104:16,19
107:19 114:9
116:6 128:10
135:2 138:20
143:5,24
144:10,13
153:15 159:14
160:2,4 162:23
172:2 184:5,25
188:16 189:2
190:20,23
193:8 194:11
196:15 200:17
200:21 210:8
215:1,25
216:22 218:20
219:15,18

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221:11,13,18
221:21 224:22
225:23 226:1
230:10,22
go-between
101:19
god 38:13 93:12
97:20 103:12
143:17 149:1
218:23 220:15
225:1
goes 25:16 33:1
153:18,19,20
153:21 168:3,4
192:9 195:13
205:9
going 19:7 43:25
50:16 62:25
63:11,19 64:8
64:14 66:8,11
66:16 74:9,9
76:3 80:13
104:21 107:15
122:5 125:10
133:19 138:6
142:5 149:2,25
153:15 155:1,2
157:13,17
160:2 166:21
169:10 178:21
181:4 184:20
189:18 199:17
200:11 204:23
209:7 217:5,7
217:21 218:16
223:7,9
good 8:23 24:25
29:21 43:20,24
46:7 54:18
61:23 74:24
85:24 87:20
120:1 132:20
149:10,15
167:25 169:11
170:6 171:15
210:10 214:11
gosh 53:8
Gotcha 96:23

69:13,16
124:12
hand 10:6,9
128:11,11
180:11
Handing 203:4
handle 129:15
hands 39:21
128:15
handwritten
206:2
hanging 181:9
hangover 15:11
happen 27:23
34:11 208:4
happened 34:8
44:10 50:1
89:8 105:23
127:23 167:20
170:4 179:5
202:2,3 218:13
220:8 223:25
224:8 225:20
happening
171:5 193:4
221:15 225:20
happens 161:18
happy 29:10
hard 13:22,25
28:13,19 47:2
60:7
harm 200:19,20
harmed 11:10
hassle 217:14,17
Hay 1:7,16 2:7
2:20 3:14 4:3
4:11 5:2,3,19
H
6:2,8 73:9
H 3:15 4:8
117:20 184:13
habit 208:12
196:13 205:4
habituation
211:24 219:25
20:17
232:1,12
half 25:22,23
hazardous 83:11
36:23,25 94:14 HC 209:12
101:2 116:6,6 HC_OR-4 210:6
116:16
he'll 133:20
halfway 29:13
head 28:17
Halloween 69:9
41:18,21 44:13
gotten 102:21
147:6 154:14
government
229:22
grab 49:20
grabbed 21:22
gradually 28:25
graduate 62:3,3
94:20
graduated 6:15
14:4 101:1
102:19
gram 137:1,3,6
137:6,8 177:15
gram's 137:7
graph 50:10
graphs 185:9
great 82:17
208:16 209:2
grew 6:13
groin 173:15,16
grounds 226:17
group 91:5
93:21
groups 102:7
105:19
guarantee
188:19
guess 217:12
224:17
guesstimate
189:21
guilt 81:18
guilty 228:5,14
guise 201:15
guy 220:22

48:17 58:24
65:24 71:16,22
76:24 94:4
103:20 110:8
113:7 125:9
147:10,12
151:24 156:20
175:1 197:15
218:17 223:24
224:24
headache 15:9
15:10
health 105:11,15
105:20 106:3
106:10 114:23
200:23 211:3
229:9
heard 66:23
67:1,3,7
225:19 229:18
229:19
heart 119:3,4,7
131:7 185:10
hearts 119:11
heavier 139:12
heaviest 37:5
heavily 46:9,10
Hegeler 3:15,15
5:18,18 29:18
29:20,22 50:23
59:3,6 72:20
72:22 73:1
127:14,18
129:5,8,12,18
133:2 138:3,7
151:13 158:24
159:3 162:1,4
170:16 174:23
175:1 177:9
183:17 189:23
202:21 204:1,8
204:16 207:11
217:12,22
219:9,12
230:18,22
231:1,6
held 92:25
hell 142:21

Imagine Reporting 619.888.0297

hello 166:5
help 7:25 57:10
61:17,17,17
127:12 174:23
190:7
helped 127:13
221:9
helping 114:19
204:23
hereto 205:7
232:5
heroin 20:10
58:6 136:4
222:16
hey 78:11
112:12 214:10
hide 128:8
173:20
high 6:15 17:15
18:8 72:17
116:4
higher 18:16
19:8,18
highest 18:2
Hillcrest 51:5,6
51:16,25 60:3
209:14 210:8
himself/herself
233:9
history 12:14,23
hit 155:2 159:25
189:2,2,16,16
192:19
Hmm-um 64:6
hold 39:21
128:15
holding 233:3
home 25:15 26:3
28:3 32:1 34:8
34:9 45:11
46:13,14 47:10
47:21 48:2,3,4
49:25 82:25
85:8,9 88:24
204:3,5,6
218:20 221:22
223:4,19
224:13 230:11

 Page 246
honest 30:10
230:15
honestly 164:11
208:8 209:16
honesty 68:12
hope 130:6,17
hopefully 63:17
71:3 168:10
hospital 32:2
34:6 36:5
37:11 42:5,11
42:22 51:7,7
51:16 58:3
65:5 90:16,20
100:24 101:20
102:6 105:19
105:24 107:23
116:23 117:7
125:5 127:24
128:4 163:21
168:10 184:25
185:5 222:1,19
223:1,19
224:15 225:4
225:15,16,22
230:2
hospital's
102:13
hour 2:21 50:17
134:20 135:5
136:11 156:15
157:25 176:5
176:18,25
177:20 178:1,7
178:11,17,18
178:21 195:20
hours 104:5
115:21,21
116:5 121:5
134:4 196:7
house 87:19
88:4,19 89:4
89:23
Hsu 4:17 204:14
205:2
Huff 106:7
human 11:6
187:12,14,15

187:17 188:10
humans 56:4
humiliate 12:17
hundred 17:7
141:17,19
hundreds 17:5
40:4 56:11,13
56:16 59:1
hung 14:14 15:6
15:8 171:12
hurt 10:6,6,9
hypersomnia
81:10
hypomanic
71:21,23 80:12

impaired 84:11
96:19 101:15
102:9 227:14
impairment
84:18 85:13
101:14
important 12:18
61:18 62:5,7
62:22 83:6
92:22,25
imposition
97:23
impossible 17:7
214:23,23
impression
200:14
I
improper 156:2
ID 118:7 130:20 inaccurate
184:7 211:22
89:21 180:5
idea 18:1 118:11 inadvertent
125:7 155:5
12:20
167:24 208:23 inadvertently
209:13 212:13
139:23
212:15 214:18 inappropriate
214:20 215:6
81:18
215:20 216:5
incident 74:6
216:10,18,20
75:14,15
218:13,16
225:15
ideal 149:20
incidents 15:16
ideas 72:10
16:14 74:2
ideation 81:24
incision 61:19
82:1
62:10,12,13
IDENTIFICA... include 34:19
4:9
82:10 86:13
identified
included 76:20
205:16
88:3
identify 107:25 includes 80:25
II 71:9,14 80:8
including 79:11
80:17,20
106:22 185:10
III 126:3
185:24 228:23
iliac 173:12
inclusive 1:9 2:9
illegal 109:7
increase 25:16
immediate 64:1 increased 29:1
immediately
72:2 83:19
136:14 159:20
192:6
165:17 171:8
indecisiveness
197:2,6,8
81:21
217:7
independent

52:13
India 85:25
99:23
Indian 220:21
indicated 56:20
indicating 27:12
indirect 39:7
individual 213:3
induce 170:10
induced 170:19
170:20 171:6
induction 61:19
62:8,9,11
120:15 137:21
138:14,14
144:1,4,5
155:18 165:17
169:13 170:2
170:21 172:8
173:22,25
186:20 188:19
196:24 197:5
inference 73:11
189:14
influence 10:10
15:3 16:10,21
17:2 37:23
38:1 39:25
58:22 64:22
69:3 85:19
117:4 123:2,8
166:24 227:12
information
31:17 196:17
201:1 204:24
229:7
informed
162:10 166:15
166:16 167:14
infrequent
29:12
infrequently
30:9
infusion 138:16
138:18 148:5
153:18,19
156:6,16
159:24 160:7

Imagine Reporting 619.888.0297

161:5,6,10
176:13,15
187:6 188:24
188:24,24,25
189:3 190:25
192:22
infusions 138:17
inguinal 173:14
initial 142:4
181:21
initialed 232:5
initially 12:25
43:23 115:15
initiated 102:4
inject 27:8,9,17
27:22 34:5
35:8 37:6
64:15 153:14
163:21 172:14
injected 27:10
28:9 55:8,12
55:13,25 56:5
57:4 150:12
152:15 172:5
172:10 174:5
180:14 182:3
188:2 216:24
218:21
injecting 30:17
114:1
injection 27:24
35:11 172:9,13
186:7,23,24
187:2,21
injections 37:1
injects 153:20
injured 10:2
injury 10:4
143:3
ink 232:5
innocent 89:17
inpatient 115:16
inquire 12:21
insert 26:23
inside 35:6
108:16 217:8
218:1
insofar 189:9

 Page 247
Insomnia 81:10
87:5
inspected
112:12 145:11
inspecting
136:16
instance 53:22
111:3 112:16
161:4 186:4
196:23 210:20
instantaneous
28:10 189:1,17
institutional
107:3
intend 25:18
intended 82:12
117:6 166:17
166:20
intensive 115:11
115:23
intent 227:6
interaction
42:25
interactions
40:24
interest 75:1
81:4 183:20
interested
233:11
interests 102:13
intern 132:16
internal 7:18
103:18
internship 7:17
7:18,21 8:11
8:15 14:5,10
14:13 52:24
interpersonal
83:3
interrupt 29:22
129:5
intersection
10:14
interview 157:8
166:15
interviewed
41:15 157:6
intoxicated

14:11,14,19
intoxication
16:7 83:20
84:5
intraoperative
119:20
intravenous
166:12 194:8
intravenously
24:10,15
introduce 5:14
intubate 133:19
intubated
138:17 188:22
intubating
170:6
intubation
62:11 132:4
169:21 170:24
171:1,12,17
inventory 11:3
11:19
involve 16:3
80:14 122:5
involved 10:16
15:15 16:9,20
17:11 19:20
31:11 32:5
50:5 53:23
55:4 60:24
68:9,12 71:20
72:5 74:3
100:11 107:11
122:3 123:10
123:20 163:4
163:10 171:14
201:25 207:17
involvement
72:16
involves 11:5
17:15,19 121:8
involving 119:2
138:11 226:15
Iredale 3:3,4 4:6
5:16,16 6:6
29:21,23 50:15
50:19 51:3
55:20 59:3,5

176:18,25
177:20,23
178:7,8,11,14
178:18
kilograms 139:5
139:10 193:16
kind 10:19
13:23 33:6
44:11,15,19,20
48:1 50:10
53:6 59:20
65:5 73:14,17
74:8 75:10
96:16 100:22
101:14,18
103:21 108:6
119:8,19 141:2
145:9,13
149:14 153:20
155:2 158:7
171:4 175:3,10
192:11 214:24
kinda 145:24
kinds 118:25
119:6
kit 213:1,2,6,7
213:21 215:13
K
knew 19:7,11
K 56:1
29:11 38:15
Kai 228:25
43:23,24 46:8
Karen 1:4 2:4
65:8 70:5,7,11
3:21 132:1,8
90:17,18,22,22
132:10 166:4,5
90:24 91:2,9
keep 22:1 35:3
132:8 149:25
78:21 97:3
167:5 171:21
108:12 111:8
184:17 225:19
143:19 170:16 knife 140:1
keeping 208:21
143:18,19,20
kept 88:13 90:21 know 11:2 15:21
Kerri 229:2
16:15,15,17
ketamine 55:12
17:8,25 18:22
55:25 57:2
20:11,11 21:3
J
58:1
25:15,15 26:13
jacked-up 140:3 key 21:19 49:16
27:12 28:24
January 99:22
kilogram 135:5
29:9,10,13
113:1 124:18
136:10 139:9
30:11 31:11
124:20 125:21
156:15,16
32:23 34:7,8
163:2,7 175:12
157:25 176:4
36:7 38:17
59:10 69:14
72:20,21,24
73:8 117:11,19
120:20 124:11
127:16,19,21
128:21 129:7
129:11,15,19
133:3 138:2,6
138:8 151:14
159:4 161:23
162:2,9 167:4
171:9 174:24
175:2,20
177:13 183:15
183:18,19
184:2 189:23
189:25 190:2
202:12,19,22
204:4,9,17
207:14,15
212:4 217:17
217:19,23,24
219:11,17,24
230:10,13,21
isolated 48:1
issue 104:11
144:19 200:23
issued 12:9
233:3
issues 95:8
104:13 114:20
203:11
item 212:22,24
213:3
items 185:24
213:10
IV 130:8,20
131:2 167:21
167:22,23,25
168:11,13,18
170:21

208:14,22
Jerry 41:11
70:12
job 34:6 40:7
41:6,7 43:13
43:21 44:3
45:1 52:3 54:3
join 102:21,23
102:23 127:15
Jolla 2:22 3:17
51:7,8 65:5
Jr 1:8 2:8 3:8
Judge 106:7
judgment 84:11
July 8:13 29:18
29:19,19 30:4
30:8 51:14
67:16,17,21
69:13 80:3
100:24,25,25
103:7 122:18
124:12
June 8:10,13,14
8:16,24 12:9
36:13 44:23
122:18 205:7

Imagine Reporting 619.888.0297

 Page 248
39:17 41:22,23
44:10,11,12,14
44:19,20 46:11
47:24 48:6
51:18 52:21
53:3 54:7,9,14
56:1,7,10 60:7
61:15 64:13
69:19 70:5,8
70:21 72:14
74:13 75:12
77:8 78:14,14
84:22 87:2
89:1 90:19,23
92:12,17,20
93:5 94:23
95:18 101:23
102:3,13,14
103:19 104:12
106:12,13
114:11 118:1,8
118:10,13,19
123:22,22
124:3 125:4,8
126:3,25
129:13 133:6,9
133:14 134:12
136:16,17
137:22 144:6
145:22 146:23
147:14 148:3,4
149:11,13
150:10 151:22
152:10,14,17
152:20,23
156:3,11,20,22
157:5 159:2,18
160:1 161:15
165:17,22
166:11 167:10
174:2,3 176:23
178:8 179:11
180:19 183:5
183:10 184:9
184:11,18,23
185:14 187:20
190:19 191:15
195:7,12 198:1

large 22:3 213:3
larger 82:11
168:8 170:7,12
largest 37:1,5,7
lasted 8:11
14:23
late 51:12 95:22
95:24
law 3:9,9 228:3
228:3
laws 226:10
232:2
lawsuit 9:14,18
12:18
lawsuits 10:17
lawyer 64:9
225:6,7,17
leading 89:20
learned 225:18
learning 171:15
190:15
leave 61:24
62:12 70:16
171:23 172:15
219:19 225:24
226:1 230:23
leaving 222:19
223:7
lecture 19:1,3
led 75:7 85:24
Lee 142:15,17
142:24
left 21:25 32:9
33:7 50:7
130:14 131:10
134:22 149:25
152:1,4 155:1
L
155:3 172:2,7
La 2:22 3:17
194:11 209:2
51:7,8 65:5
214:8 216:9,17
labor 52:6 61:11
217:4 222:23
lacks 217:12
left-hand 140:16
Lacrimation
185:23 186:10
86:20
212:21
laid 31:1 207:12 leftover 34:2
Lamictal 99:3
leg 119:16
99:11
legal 15:13
language 16:16
104:18
199:9 201:6,8
201:9,19 202:2
202:5,9,11
203:12 204:18
207:6 208:19
208:21 209:15
209:16,25
211:16,20
212:12 213:17
213:24 214:16
215:22,24
216:6 217:1,11
217:13,15,18
218:10,11,12
218:25 219:18
220:8 222:4
223:25 224:16
224:23 225:18
229:12,13,18
229:19,21
230:3,13
knowing 125:10
knowledge
18:16,18 49:15
83:13 90:15
91:18 142:24
156:8 180:3,9
181:10
knowledgeable
70:2,3
known 51:21
54:11 56:1
132:10 159:11
knows 146:23
149:12
knuckle 47:4

legally 52:12
legs 10:7
length 117:21
Leon 70:13 92:2
lesions 119:3
lesser 96:12
let's 12:23 14:21
21:24 22:25
24:1 32:9 33:7
34:13 36:10
49:24 63:18
74:5 87:20
91:1 96:3
104:13 107:1
108:20 112:12
135:2 137:7
150:7 151:7
158:6,12
161:23 162:23
177:14 189:25
190:20 193:8
199:10,15
201:5 214:7
215:9 216:22
218:4,5 230:22
letter 106:7
letters 228:20
Levels 131:17
Lexapro 99:3,7
license 12:8,12
226:17 233:3
lido- 180:14
lidocaine 180:15
180:16 186:1
221:5
lie 31:12 67:7
lied 39:12,13
66:10
life 11:24 13:1
25:19 40:18
91:8
light 73:24
102:4
liked 40:12 41:3
133:1,4,6
likewise 113:14
line 66:7 141:2,3
141:4 166:12

Imagine Reporting 619.888.0297

167:24 168:2,3
169:9,20 170:5
171:13,16,17
189:6 210:8
lines 115:22
liquor 13:22,25
list 11:10 50:11
103:10 117:22
117:22 185:24
192:20
listing 50:11
lists 117:23
liter 47:8
literature 17:23
18:7 20:9
little 14:8 28:13
36:19 44:6
62:14 74:12
95:15 96:23
132:24 144:8,8
152:2 155:21
156:5 170:6
218:17,20
living 25:20
88:19
Lmk 133:12
located 5:5 8:1
173:11 210:9
location 209:18
211:10
locations 60:5
213:1
lock 49:20
217:13 218:4,6
218:9
lockbox 49:17
49:19,25
lockboxes 49:13
locked 22:22
217:10,18
218:3,12
log 109:24 112:1
118:7 182:19
206:10
log-in 4:10
logged 194:22
long 21:3 23:6
24:21 28:22

 Page 249
30:10 35:10
37:13,15 44:21
45:14 48:20
51:21 54:11
67:23 89:13
103:6,13 104:4
116:3,5,9,13
132:10 137:23
140:13 148:24
149:16,19
150:1 171:10
172:14 173:17
174:14 210:17
222:21
longer 48:11
52:21 82:11
94:20,22 95:1
95:3,6,10 97:1
97:2,4 145:16
longest 36:11
look 95:16 97:18
101:10 103:10
121:4,11
131:25 138:4
145:13 158:24
163:1 175:22
176:11 185:6
188:18 198:22
199:10,11,17
200:10 209:8
213:7 215:15
217:1
looked 126:4
220:4,5 230:4
looking 89:13
143:14 158:24
221:4
looks 129:1
137:15 144:17
203:15 212:25
217:4,6
Los 3:11
loss 81:7,15
226:17
lot 56:7,11 61:21
62:16 70:7,7
102:6 155:2,18
166:11 188:16

43:1 44:3,17
206:22 207:4
65:20 66:21
222:6
70:4,12 75:21
lower 184:6
77:10 79:15
216:9
87:13,19 88:4
Luca 1:22 2:24
89:1,6,9 91:2,3
233:3,19
91:20 125:15
lunch 50:20 61:2
224:25
LUNCHEON
manifested
73:4
83:24
lying 39:19
manner 49:9
128:10
168:16 170:20
M
175:6 180:6
M-i-n-o-k-a-d...
188:12 201:21
70:22
margin 170:13
M.D 1:7 2:7
Marie 1:22 2:23
machine 109:24
233:3,19
147:6 161:9
marijuana
165:10 197:22
58:11,12,13
197:25 210:7,9 mark 94:22
210:11 211:12
95:13 128:17
213:12,14
159:23 175:15
214:2,4,7
183:21 204:10
machines
marked 4:9
211:25
117:18 128:20
main 62:4
175:19,22
180:22
183:14,16
maintain 79:25
184:1 202:18
85:20 95:25
204:15
227:9
markedly 81:4
maintained 79:3
83:19,21
maintenance
marks 231:3
35:18
mask 133:23
major 80:14,24
169:9,11
82:25 90:17
match 179:2,4
180:23
214:6
majority 93:25
matches 214:4
123:3
material 167:6
making 104:14
211:15
159:6 187:17
materials 209:2
201:16 221:17 math 177:14
227:1
178:23 198:15
man 43:20
mathematical
management
222:10
98:24
matter 9:21 17:9
Manecke 1:8 2:8
18:3,4 52:5
3:8 5:21 41:11
80:20 104:7
41:13,14,24
126:15 192:10

192:24
McCARTHY
3:16
McDonald
228:25 229:4
mcg 136:10,22
mcg's 154:24,25
156:15,16
177:7 178:6,7
178:18 181:15
181:15
MD 3:14 7:11
7:13 52:23
184:13 205:5
MDs 52:21
mean 13:25
16:15 32:13
38:19 40:13
44:9 56:7 63:2
76:13 77:16
78:2 91:17
110:12,17
119:7 131:16
132:24 137:12
138:13,25
139:3 142:8
146:15,21
154:23 155:18
168:2 174:16
174:18 190:17
192:5 194:21
195:11 201:8
215:21 222:6,7
meaning 86:20
130:22 134:25
146:9,21
158:11
means 11:9
107:12 109:14
120:22 127:1
132:3 137:1
138:19 140:22
140:23 141:24
184:8,11 194:3
194:22 195:2
203:3 209:13
212:24 214:23
216:18 229:14

Imagine Reporting 619.888.0297

mechanism
161:9
MedAltID1
214:15
MedAltID2
214:15
medical 7:1,3,4
7:16 13:6,8,15
13:21 14:4
17:22 18:7
19:4,11 23:19
31:8,14,17
50:9,12 52:24
65:4 66:17
68:25 90:1
97:24 105:2,21
106:9 108:17
109:1 117:9
118:15,17,17
118:20 124:23
125:10,11
126:7 131:23
140:6 150:5
156:24 157:11
159:6 160:23
166:17 173:24
177:3 183:3,22
205:11 206:4
225:10 226:6
227:5,7
medication
21:23 27:1
32:15,17,18,25
150:19,23
155:6 164:10
165:14 216:4
medications
21:14,20 49:14
98:22 99:14
192:20
medicine 7:18
12:8 17:24
74:20 98:24
103:18,19
227:3,12,14
medicines
138:20
meet 41:14 71:1

 Page 250
meeting 66:18
75:16 76:17
77:1 79:10
87:8,10,10,13
87:16,17 88:3
88:23 89:8
93:22 96:21,25
104:4
meetings 93:17
95:7 96:8,15
96:17 104:1,8
114:10,10
115:23
member 100:16
100:19 128:5
members 76:19
76:20 87:8
91:6 103:24
memory 84:18
84:20 85:13
222:25
mention 75:6
mentioned 12:5
76:20 132:1
184:15
mentioning
156:12
mentor 74:22
mess 132:6
133:8
messages 175:11
met 54:16
metaphor
128:13
methods 22:11
24:2
mg 136:24 194:3
microgram
136:22 137:5,6
177:4
micrograms
135:5 137:8
147:19,22,24
157:24 158:20
176:4,18,25
177:17,20,23
178:10,13
186:11,13,17

193:13,19
194:5 218:18
midazolam
55:15,22,23
56:22 57:3
58:2,25 171:6
185:25
middle 114:7
149:11 195:19
214:14
mild 141:12
Millard 6:15
milli- 158:21
milligram
136:24 137:1,8
147:21 177:7
177:17 194:3,5
198:21,23
milligrams
137:7 158:21
158:22 177:15
194:1
milliliter 111:4
111:4
milliliters 27:6
111:6
mimic 102:8
mind 70:10
144:8 174:25
212:24
mindset 43:24
minimal 27:5
171:2
minimum 63:3
minivan 10:8
Minokadeh
70:18 92:5,6,7
Minus 61:1
minute 63:17
156:17,18
177:7,8,24
178:8 191:6
195:22
minutes 35:13
50:16,22 72:25
134:20 145:22
146:7 157:25
170:11,13,14

172:16 174:17
174:19 177:22
178:1,17
221:21 223:1
misleading
73:11
misrepresenta...
227:22
missed 73:17
129:14
mission 101:10
misspoke 204:1
204:7
mistake 159:15
misunderstood
96:22
ml 147:19
151:13,13,17
154:24,25
181:15 197:13
197:13 218:18
mls 147:20
151:15 152:1
152:24 153:3,6
181:15 198:7
Modafinil 59:8
59:18 85:16
97:20 98:16
99:23,23 100:2
modifying 227:5
mole 62:14
mom 45:20
mom's 74:14
moment 36:10
41:12 72:22
107:1
Momentarily
37:15
Monday 79:6
115:20 134:5,6
134:7
monitor 63:10
70:19,23,24,25
92:13 93:5,7,8
99:14 105:5,7
105:9,10 141:7
141:9 185:16
229:22

monitored
92:23 93:22,23
94:21 104:10
104:10 105:8
119:14
monitoring
92:10 94:15,23
101:3 102:9
105:12,12,23
122:3 123:9
140:24 171:22
197:1,8
month 46:11
47:9 51:8
78:15 116:15
116:15 122:12
123:23,25
monthly 95:6
96:15,17
months 23:7
25:10 29:3
30:15,15 36:8
36:16 42:8,16
45:16 46:17
47:7,16,20,21
47:23,25 48:1
48:7,23,25
67:24 69:5,18
76:12 78:4,17
79:22 92:15
96:10 98:15
114:8,11
months' 90:6
mood 80:25
86:13 99:11
moral 11:3
morbidly
131:20
morning 134:4
140:8 154:22
155:8 164:20
morphine 55:14
56:16,17 57:3
58:2 106:24
213:5
mother's 45:25
motor 9:7
mouse 192:23

Imagine Reporting 619.888.0297

moved 9:15
26:13
MRI 131:25
MRN 118:12
multiple 25:12
34:22 53:1
110:22 189:8
201:21
muscle 86:18
171:8
N
N 4:1
name 5:4 6:7
50:12 70:21
75:24 106:14
108:17 146:16
194:24 196:12
206:4 211:18
220:17,21
229:19
named 51:19
233:11
names 103:12
103:20
narcotic 21:20
227:13
narcotics 180:24
201:20 229:22
natural 20:16
nature 10:4 11:7
42:25 54:5
68:3,16 91:11
126:13
nausea 15:10,10
86:16
Nav 223:14
nearing 40:11
nearly 28:10
81:1,10,12,15
81:18,21
Nebraska 6:13
6:20 7:4 8:1
necessarily
15:21 91:13
148:18 159:19
necessary 80:17
82:18 147:9

 Page 251
148:4
neck 26:23
131:25 168:5
171:2
need 6:11 12:14
12:20 21:22
25:6,8,19
29:24 30:14
35:19,21 41:12
44:6,8,12
51:18 55:7
72:6,23 78:11
82:8 83:19
85:15 87:16
100:14 102:17
111:21 122:9
124:22 125:14
128:17 129:23
140:5 161:2
164:14 168:11
175:21 181:1
219:25 221:18
221:20 229:6
230:10 231:5
needed 9:2
61:17 92:13
127:12 179:17
200:21
needle 26:24,25
neither 233:10
nerve 119:15
145:12
nerves 144:16
nervous 27:5
neuro- 171:21
neuromonitor...
171:20
neurophysiolo...
171:21
neurosurgery
119:9
never 18:20 58:5
58:6,22 74:10
77:15 78:2
113:22 158:12
195:10,12
204:21 208:11
new 104:16

110:6 183:15
194:8,12
next-to-last
162:23
nice 40:15,24
night 86:23 88:5
88:6
nine 46:17 47:21
47:23 213:4
214:8
ninth 11:14
nitrous 185:24
Nodler 1:7 2:7
3:8 4:11 5:21
51:19,21 53:13
54:24 129:2,3
130:1 134:17
150:4,17
153:23 156:8
157:20 158:11
158:17 160:6
165:22 176:2
182:7 188:1
190:13 194:18
194:21 197:12
201:3,12
Nods 71:16,22
110:8 113:7
147:10,12
151:24 175:1
197:15
nominated
102:18
noncardiac 43:7
normal 64:6
127:1 169:8,18
normally 33:10
168:9 183:4
North 6:15
notation 194:7
194:18 212:16
216:9
note 183:5 203:7
203:8,25
noted 158:11
232:4
notes 4:16
188:14 203:1

203:19
noticeable 67:4
noticed 220:10
222:22
notification
162:20
November 1:18
2:22 5:8 6:10
29:8 30:7
48:17,18 51:12
69:8 90:10
95:20 123:25
124:2 233:14
November-De...
51:24
number 17:6
30:16 37:1
40:2 43:9
56:11 60:16
77:14 79:10
93:14 103:23
108:18 118:15
118:17,20
120:11 163:14
177:25 184:9
184:11 198:20
198:23 206:4
207:6 213:4
214:4,5 215:8
numbers 17:25
19:12 150:7
179:1 182:18
186:4 197:21
205:25 206:5
207:5 214:18
nurse 23:20 52:4
52:7,11 53:4,7
53:12 61:23
113:15,16
155:20,25
161:14 201:14
201:24 202:5
nurses 220:16
nursing 53:7
203:5
O
o'clock 117:13

135:13 161:24
164:21,25
186:23
oath 12:1,4
132:25 233:5
oaths 233:4
OB-GYN
103:19 119:9
obese 131:20
objection
127:16 138:2
217:20
obligation 91:7
105:5,6
obligations
82:25
observation
161:12
obstructive
149:17
obtain 21:10
26:8 32:5 36:4
82:18 100:12
107:17 108:13
110:10 111:3
165:2 210:12
obtained 30:20
31:2,5 58:3
172:6
obtaining 22:20
31:23 110:7
123:11,14
166:16 227:21
227:25 228:10
obvious 32:14
85:4,8 173:5
obviously 76:14
85:7
occasion 14:11
Occasionally
43:7
occasions 14:14
14:20 17:3,5
45:21 54:4,5
55:13,14 56:6
64:14 201:25
206:21
occupational

Imagine Reporting 619.888.0297

83:6
occur 10:13
63:22 84:23
95:14 208:4
occurred 65:3,4
87:11 91:4
140:9 188:20
196:24 207:1
occurrence
16:25 71:20
80:12
occurs 18:3
120:15 189:14
OCD 107:11
October 80:4
95:20 97:21
98:18 99:17
106:16 114:1
115:1,1,2
116:11 122:15
122:22 123:19
123:20,23
offense 225:17
228:6
offer 45:1
offered 40:7
41:6,7 44:3
181:12
office 3:9 65:5
129:9 139:22
139:25
officer 88:16
official 225:4,5
oh 21:20 27:10
27:12 28:19
30:6 38:24
42:18 48:16
49:25 57:7
59:8 67:16
70:18 74:13
79:7 85:1 88:5
96:17 103:12
112:11,12
119:7 134:23
138:3 142:11
142:21 143:11
143:17 149:1
149:23 155:2,6

 Page 252
169:19 170:18
190:22 193:22
194:10,12
211:2 214:1
218:23 219:14
221:25 225:1
Ok 130:7,19
okay 14:22
17:10 21:17
23:2 25:24
29:17 33:15
39:7 50:18
62:19 64:13
66:7 70:17
74:9 76:2
87:12 88:1,5
88:17 90:3
96:23 104:15
113:18 130:6
130:17 132:19
134:2 144:11
151:6 162:1
188:22 199:22
209:6 221:18
230:20,24
Olympic 3:10
Omaha 6:13,16
7:6 8:2,3 45:11
45:14
once 15:7 35:16
35:23 84:21
93:11,11,11
94:15,16 97:3
104:3 116:17
130:8,24 131:3
149:12 154:25
173:13 183:7
189:2,8,19
193:2,5
once-a-week
93:21
one's 209:16,16
one-year 7:18
ones 58:16 96:18
oneself 11:3
online 93:13
oOo- 6:1,4
open 26:23

139:18 145:13
218:6
opening 136:14
opens 214:3
operated 144:3
operating 63:6
164:22 165:13
167:25 168:24
168:24 214:2
217:4
operation
137:18 138:11
175:13
ophthalmic
119:10
opiate 38:20
45:19 46:8
56:20,25 85:20
88:21 149:18
155:21
opiates 20:13
55:13 58:9
86:4 180:17
opioid 20:7
24:22,22 82:3
82:9,15,18,24
83:2,7,10,13
83:22,25 84:5
84:7,12,17
86:5,11 115:15
126:4 127:2
128:10
opioids 82:10,22
83:4,20 84:1
163:18
opportunity 8:4
233:9
opposed 28:4
109:15 149:8
209:3
opposite 204:5
option 168:13
OR-2 210:6
Orally 45:23
order 73:11
77:23,24 85:25
99:11 101:15
148:3 200:10

220:16
page 4:5,9 78:10
98:10 120:4
135:2,4,4
143:5,6,10,24
144:14 145:19
157:14 162:24
175:25 184:5,6
185:7,18,20
189:9 190:21
191:8,13,23
192:3 193:8,10
195:15,19
196:15 202:23
202:25 204:13
205:2 209:9
212:7,16,19
214:12 215:1
215:15,25
216:3,7,12,15
paged 122:8
pager 63:16
pages 117:21
191:15 205:17
pain 12:20 35:21
203:11
painful 72:17
pair 71:2
paired 74:22
Palmera 115:6,8
115:14 122:23
123:20
P
pants 221:10
P-y-x-i-s 107:9
paper 130:14,15
p.m 73:7 117:13 paragraph
117:14,17
157:16
121:6 134:14
parameters
134:14 146:11
185:9
162:5,8 202:14 parents 45:12
202:17 219:20
45:15 46:4,12
219:23 231:2,9 parents' 47:21
package 110:5
part 12:18 13:25
packet 21:21
18:8 21:15,18
108:1,2,3,4,8
29:15 31:6
108:14,16
47:15,23 68:13
110:3 165:2
71:20 73:19
209:15
75:24 80:11
PACU 217:6
98:3 100:23
201:6
ordered 67:9
147:8
ordering 99:23
ordinary 169:17
205:14
organize 59:22
orientation 19:6
originally
154:23,23
orthopedic
54:12 119:8
145:11
Ouch 144:15
outcome 233:11
outpatient
115:12,19
outright 74:10
outside 54:3
outstanding
184:21
overall 50:14
overdose 84:15
overhead 63:19
overlap 54:14
Override 216:18
OverrideReas...
216:17
oxide 185:24
oxygen 169:9,12
170:10,13

Imagine Reporting 619.888.0297

113:22 121:9
149:24 151:19
190:15 195:11
203:23 213:21
220:14
partially 31:24
participated
10:24 80:6
participating
10:24
particular 13:24
65:10,12 91:15
118:20 126:8
150:6 153:24
191:15 211:9
229:8
particulars
197:19
parties 43:17
205:13
partner 5:4
parts 40:18
61:18 107:23
118:5
party 9:9,10
58:20 175:6
233:11
pass 78:22
107:20 108:13
119:24,24
passed 37:8,13
37:16 76:10
78:1,3 87:25
222:2,22
passing 43:5
Patel 38:24 74:7
74:18
patient 31:16
33:17 37:25
38:2 62:18
105:10 111:1,6
118:20 120:16
120:19,23
125:5 134:25
139:5,7 142:2
149:10,15
153:16,21
156:10 158:23

 Page 253
160:1 167:10
170:14 171:19
181:10 198:22
203:4,10 217:6
patient's 38:4
50:9,12 108:17
118:16 138:17
189:4 200:23
206:4
PatientID
212:11
PatientName
212:10
patients 34:20
37:23 39:25
62:15 64:23
69:2 104:9
114:24 117:3,7
119:15 124:24
pattern 49:5,7
61:6 116:18
127:2 141:1
patterns 141:1
peak 122:25
123:2
peel 145:13
pelvis 173:13
penalty 232:2
people 11:15
17:12 20:16
38:14 40:23
41:3 47:5 54:7
62:1 63:3 65:6
65:14,17 70:6
70:7 74:11
77:15,16 88:22
91:8 102:19,20
104:12 105:18
110:17 112:21
113:3 183:6
210:20 218:10
220:5,18 221:2
221:11,17
224:2
percent 140:21
140:23 141:6
141:12,19
144:9 161:1

169:12 170:10
170:13 190:18
perfect 134:2
161:15 222:8
perform 44:14
period 30:7 36:2
36:11,13 37:2
46:10,15 72:1
78:17 81:1
82:11 86:3
89:13 96:11
110:19 112:24
112:25 113:25
114:3,7 115:13
121:8 122:19
122:21 127:9
142:4 149:19
170:12 182:20
222:8,21 226:5
228:16
periods 36:6
81:25
peripheral
119:16
perjury 232:2
permitted 29:24
29:25 98:7
226:2
persistent 82:14
83:2,14
person 23:20
25:21 27:9
40:15,25 50:6
51:18 60:24
75:22 101:16
104:12 105:12
110:2,3,3,5
126:23 130:12
132:22 141:10
150:18 155:24
188:14 194:22
227:6
person's 40:18
146:16
personal 11:19
18:3 33:24
110:10
personnel

205:13
persons 11:10
77:14 79:11
88:3 105:7
228:21
pertained 22:19
PHARM 204:14
pharmacist
207:17
pharmacy 22:4
22:9 32:6,12
32:18,24 33:4
38:16 50:6
88:6 90:21
110:14 192:18
192:19
PharmD 4:17
204:14 205:3
phenylephrine
186:1 188:6
phone 129:20
175:4,11
224:16,18
photograph
143:10,17
photographs
143:12
phrase 222:5
physical 25:6,8
28:16 75:8
83:14 185:9
physically 83:11
physician 12:12
94:15 101:15
101:20 104:18
226:16
physician's
101:12
physicians
34:17 93:22,23
102:9
physiological
20:17
pick 32:24,24
92:11 139:7,7
139:7 182:19
182:20 189:3,3
192:17,20

210:18 223:17
picked 29:16
30:5 86:4
piece 129:9
pills 58:6
Piyush 38:24
74:7
placate 200:10
place 5:11 32:1
65:10 78:16
111:16 134:3
165:12 193:23
206:21 210:16
211:9 233:7
placed 168:21
169:20 170:5
171:13,14
placements
167:22
places 63:8
plaintiff 9:12
plaintiffs 1:5 2:5
3:2 5:17
Plaintiffs' 205:6
plan 50:19
154:21 170:24
218:19
plate 145:17
plausibility
149:21
players 90:18
91:18
please 5:10,14
5:23 6:7 28:12
32:8 52:10
73:13 98:9
109:22 162:13
170:17
pleasurable
35:15
pleasure 81:4
pled 228:5
plus 46:11 152:2
pocket 35:5
140:1 143:19
150:16 154:20
215:4
pockets 215:9

Imagine Reporting 619.888.0297

point 19:22 25:9
26:12,18 27:21
30:19 31:21
40:6 48:8
53:22 54:1
55:4 62:7
64:25 65:20
66:2 76:13
81:2 82:2
88:12 91:3
92:22 96:16
99:18 100:16
101:21 106:15
106:20 107:7
122:2 124:5,20
125:15 129:20
150:15 152:7
153:24 154:2
155:4 156:7
157:6,20 158:2
161:7 174:11
176:21 178:3
187:10 195:3
197:12,16
207:21 218:11
218:13 220:24
221:4,9,24
224:24 225:9
226:6
police 88:16
policies 229:7,8
policy 205:20
229:10
pop 192:23
populated 189:4
population
69:21
port 153:20
portal 153:15,18
portion 33:20
111:15 216:9
position 169:3
170:6
positioned
171:19
positioning
168:25 170:7
positive 161:1

 Page 254
possession
205:11
possible 11:15
22:15 61:15
62:20 101:14
224:20 230:15
possibly 63:6
89:2 101:15
123:10 225:24
post 189:10
203:7,19,25
post-anesthesia
203:5
postop 183:5
postoperative
120:24
postoperatively
149:19
potential 72:17
149:18
potentially
31:16
pounds 139:10
power 104:23
powerful 24:22
136:7
practice 12:8
46:5 144:10
169:8 171:20
171:23 180:10
211:7 227:3,12
227:14
practitioners
193:6
Pre 4:16
preceding 134:6
precise 22:16
192:9
predisposed
19:9
pregnant 10:7
preoperative
166:2
prepare 26:10
165:7,19
prepared
176:12
prescribe 99:14

99:15
prescribed
98:23 99:6
229:22
prescribing
98:21 99:19
226:23 227:17
prescription
59:9
prescriptions
99:1
presence 113:10
197:20
present 3:21
66:21 77:6
148:21 197:5
199:5
preserve 195:8
205:12
press 17:9 40:3
127:20 206:23
208:3
pressure 185:10
188:17,18
pretty 14:9 29:9
48:5 61:24
76:9 138:16
140:10 141:13
prevent 171:4
print 175:3
Printed 4:13
prior 216:3
privacy 205:12
private 23:25
34:23
probably 15:7
17:6 23:7
25:10 27:6,11
29:7 36:22,23
42:7 47:25
48:6,23 60:22
66:20,20 84:19
92:18 97:10
116:15,25
124:2,15
141:25 146:7
178:4 180:23
184:9,20

190:17 198:20
208:6,7 210:7
211:24 215:21
217:2,5 223:1
probation
228:17
problem 39:8
66:24 67:5
68:1,4 71:4
83:15 126:19
171:4 182:14
problematic
84:9
problems 12:25
38:18 76:4
83:3 125:16
127:25 182:11
182:16
proce- 146:3
procedure 22:5
61:20,21 62:23
108:7 109:19
119:9,9 140:15
148:7,10 150:1
168:1 169:18
189:19 192:15
197:2 203:9
206:2 207:2,12
207:16
procedures
21:11 62:25
64:14 119:13
120:9
proceeded 180:7
process 21:9,9
35:10 50:4
137:14 174:14
produced 205:6
profession 19:5
105:15
professional
23:20 105:11
106:3,10
professionalism
181:1,4
Professionals
105:20
program 10:22

10:25 15:20
16:16 46:20
68:10 93:17
94:19 95:11
96:7 97:4,11
101:22,24
102:5 105:11
105:15,17,20
106:4,10 115:5
115:10,20,25
116:3 208:7
programs
115:12
progressed 34:8
34:10,11
promise 223:10
promptly 11:19
properly 26:5
78:18 79:17
122:14 186:12
193:20
propofol 161:7
170:22 171:7
185:25 187:6
192:3,6
propolol 185:25
propose 50:16
230:16
propriety
111:11
protect 101:15
102:12
protocol 109:19
205:20
provided 183:23
205:10
provider 117:22
providers 52:13
provides 169:11
provision 109:9
psych 106:13
psychiatric 95:3
98:22 101:13
psychiatrist
71:12 93:17
98:19,25 99:13
99:18
psychiatrists

Imagine Reporting 619.888.0297

103:17
psychiatry
103:22 105:21
psychological
25:7 83:15
84:9 95:4
psychologist
93:18
psychomotor
81:12 84:10
public 16:6,7
92:23 101:16
102:12 105:19
114:23 211:3
pulled 189:22
221:10
pulling 166:13
pulse 185:12
pump 138:21,21
139:6,6 156:14
178:6 181:9,25
punishment
101:19
pupillary 84:14
84:14 85:1,2
86:22
pure 70:15
purpose 12:16
88:11 102:10
push 162:2
put 17:6 19:15
28:19 40:2
43:9 50:12
56:11 71:2
108:18 109:15
111:5 130:8,20
131:2 153:11
155:22 168:4,8
197:14 199:23
putting 31:16
145:17 211:4
Pyxis 107:17
109:24 147:6
150:24 155:11
165:10 197:22
210:4,7,9,11
211:12,16
213:12,14

 Page 255
214:2 216:19
Pyxis-type
107:8
Q
Quantity 215:17
quarter 36:24
question 19:15
60:8 61:7
104:10,19
133:18 138:1,9
162:14 190:1
192:10 207:7
207:14 208:3
218:5 220:1
questioned
112:19 113:4
113:22
questioning
66:7 74:11
questions 73:25
75:7,25 76:2
77:20 80:14
82:8 100:15
136:20 230:7
quick 134:1
quickly 170:8,15
quite 59:14
145:14
quote 176:3
quote/unquote
94:20
R
racing 72:11
raised 88:9
ran 86:2 105:20
Randall 3:22
212:17
random 78:9
93:10,13 202:4
randomly 93:14
Randy 1:4 2:4
130:6,17 131:2
139:12 187:2
range 17:7
116:16 178:5
rate 14:7 18:16
138:21,23

139:8 153:22
158:8 160:3
178:21 182:20
189:3,5 191:3
191:24 192:2,6
192:22,24
194:13 198:15
198:16 199:23
rates 17:23 18:2
ratio 20:12
rays 146:5
rdavis@hegel...
3:19
react 63:17
reaction 142:12
reactive 142:7
read 126:5
130:10,11,19
138:25 156:23
157:9,16 159:1
193:20 212:1
232:3
readily 85:4
reading 193:22
200:22
reads 215:17
ready 18:11
44:20 62:2,17
126:12 134:21
134:22,23,25
134:25
Real 10:15
reality 178:4
198:21 199:19
realized 115:18
154:25 155:6
really 35:16
49:11 74:14
76:14 84:20
179:4
reason 48:16
52:16,17 66:12
119:18 137:13
146:24 149:9
171:1 180:22
180:23 213:19
reasons 44:12
168:25 180:25

recall 20:1 26:17
26:21 27:10
28:23 38:23
45:7,8 49:8,10
49:11 67:14
77:23 78:13
88:2,23 90:9
103:11 128:14
135:9,17 140:8
169:23 221:4
222:19,21
224:7 230:9
receive 21:14
received 21:24
80:7
receptacle
110:16 150:13
recess 50:25
73:4 117:15
162:6 202:15
219:21
reckless 15:22
recognize
128:24 227:24
recollection
21:4 23:11
27:4 30:1,18
36:15 48:14,24
98:6 100:21
152:12 157:18
162:16 165:9
169:16 197:24
222:7
recommend
105:1
recommendat...
116:8
recommendat...
104:22 105:4
recommended
104:17
reconstructed
160:12 189:10
record 5:13
31:14 38:4
50:9,13,24
51:1 73:2,6
88:7 108:17

117:14,16
118:15,17,20
138:5 150:5
154:3 158:13
158:19 160:15
161:12 162:5,7
162:15 164:5
166:18 177:3
178:7 179:10
179:17,21
183:22 184:7
184:16 192:11
192:12 195:8
198:4,10
202:14,16
206:2,4 213:12
219:16,20,22
227:5,7 231:2
231:4
recorded 185:17
205:24
recording 5:11
189:14
recordkeeping
159:11 161:2
records 4:15
31:8 68:25
95:17 108:22
108:25 109:2
111:11 117:9
123:13 124:23
128:4 159:6
160:23 173:24
179:4,9,25
180:5 182:10
182:24 183:3
189:9 192:8,8
196:20 200:18
202:7,10 205:4
205:10,13
208:16 227:10
recount 88:2
recover 82:18
recovery 69:21
97:16 148:22
148:25 149:2
216:25
recreational

Imagine Reporting 619.888.0297

83:6
recurrent 81:23
82:24 83:3,10
83:14
redactions
205:12
reduced 83:7
refer 162:21
174:25 184:3
185:18 191:8
195:14 202:23
210:1 211:14
212:6 214:12
214:16
reference
118:16,17
124:5 142:25
144:19 145:21
146:23 194:21
212:13
referral 87:11
referred 47:22
105:23
referring 69:24
96:24 131:22
139:4,9 146:2
175:12 191:6
215:10
refers 118:8
209:25 213:24
214:19 215:6
215:12,20
216:10
reflect 31:9
111:14 157:23
159:17 173:24
182:24 188:15
192:8,8 199:1
reflected 33:23
124:24 143:7
186:12 191:3
194:13
reflecting
112:22 175:17
reflection 187:5
188:5
reflects 176:15
177:3 186:22

 Page 256
reflex 142:8
refresh 98:6
refreshes 59:6
157:17
regained 220:2
regard 39:15
44:5 71:11
228:13
regarding 17:23
19:4 80:11
142:12 156:9
205:21 225:22
226:20
regardless 16:19
Regents 1:8 2:8
3:8 5:21
regime 94:11
97:6
regimen 98:23
regular 60:6
94:23 230:1
regularly 36:25
92:12 163:20
rehab 68:11
124:14 224:19
relapse 116:14
126:25 127:9
127:10
relapsed 124:16
related 18:13
54:6,22 101:13
101:13 182:14
226:15 227:2
227:25 233:11
relating 169:17
relation 132:20
relations 43:11
54:18
relationship
41:13 53:19
54:23,23 124:4
141:4
relaxant 171:8
relaxation 28:14
relieve 84:1
relinquish
120:23
remain 171:10

221:8
remaining
152:24 198:12
remember 19:1
21:21,22 23:9
26:19 30:11
41:15,23 48:15
49:1,4,12 53:8
65:17 67:16
69:17 75:23
77:6,11 88:11
89:8 93:12
106:14 107:22
136:18 146:22
156:11,12
157:2,10 158:3
158:3 164:6,9
164:12 165:24
174:18 178:2
186:20 187:20
187:23,25
190:8 197:19
208:5,6,8
213:11,16
216:23 217:25
218:3,14,23
219:5,6 220:3
220:4,12,13,15
220:15,17,20
220:21,22,25
221:15,19
222:4 224:16
224:17 225:1
remotely 185:2
185:3
removal 119:2
216:4
removed 150:24
181:20 197:13
197:22 216:4
repeat 42:13
120:17 207:7
repeated 49:5
repetitive
201:22
replace 32:10
replaced 150:12
181:16

replies 143:16
report 67:9
92:14,19
101:17 205:11
205:16 225:10
reportable
225:17
reported 1:22
21:5,6 95:18
202:6,10
225:15,19
reporter 2:24
5:6,22 55:16
55:18 120:17
231:5,7 233:1
233:3
reports 105:13
represent 5:15
representation
103:21
represents
227:2
request 77:22,25
130:5,16
206:16
required 63:7
93:16 97:4
207:2,23
requirement
95:3,6,10
211:9
requirements
95:14
requires 119:18
requisite 113:11
reside 125:12
residence 9:15
132:18,18
residency 7:17
7:20 8:6,8,24
14:16,23 15:1
17:11 19:22
21:16,18,18
22:13,20,24
23:1,3,8 24:3,5
24:6 25:20,22
26:17 29:15,18
30:12 32:21

34:5 35:24
36:2,13,19,23
37:3,23 38:9
38:14,22 39:23
40:10 41:16,17
41:19,25 44:10
44:22,25 46:7
47:12,17 51:5
53:1,11 54:7
54:13,13 76:8
76:11 77:9
79:20 87:18
119:24 132:17
135:24,24
resident 8:20
19:3 41:16
43:9 48:12
60:12,18 61:5
61:10 62:24
63:7 75:20
77:2 79:19
84:22 89:13
166:13 171:14
190:16 202:9
207:19 220:13
residential
115:10,11
residents 61:14
62:1,2 202:3
respect 7:14
79:25 108:21
108:23 124:25
125:22 126:4
153:7 159:6
179:11,14
191:13,14
205:18 214:14
respected 64:10
respond 142:15
respondent
98:12 158:10
response 39:10
130:7,19
131:10 132:5
133:22,23,25
134:13,20
142:21 143:16
145:17,24

Imagine Reporting 619.888.0297

146:4 158:6
217:20
responsibility
61:11 114:19
114:22
rest 62:6 76:8
90:20 153:1
165:5 186:21
197:23
restroom 216:24
217:8
result 15:18
31:23 32:18
67:4
resulted 16:13
resulting 82:24
results 78:2
resume 37:17
50:21 117:12
resumed 48:20
retardation
81:12
return 22:4
32:11,17
122:12 182:7
212:22,24
213:6,7,14,18
returned 21:5,6
32:13,14 49:2
50:13 69:7
122:16 182:9
returning 22:6
32:6,16 33:12
Review 229:17
rhinorrhea
86:20
rid 154:10,14
right 20:12
22:10,25 24:1
34:1,4 38:17
49:25 50:15
51:4 54:20
57:10,17 65:9
68:6 70:9
75:13 76:9
87:20 89:2,7
90:25 92:21
95:25 98:1,15

 Page 257
101:25 114:12
117:11 122:17
123:18 126:16
130:15 134:9
134:11,23
135:3 136:19
138:7 141:18
143:24 144:13
149:3 151:10
151:13 153:23
154:7 158:12
160:8,21
161:15,23
162:10,21
163:12,16
164:14 170:1,8
174:21,24
177:14,23
178:10 179:7,9
179:12,15,19
180:1 181:5
183:8,11
184:12,22
185:6 186:3
190:20 194:3
194:11 195:14
196:2,12
197:12 201:4
202:5,12 204:8
204:22 206:15
208:13 210:14
210:17 211:2,8
213:22 214:10
216:25 217:8
217:19,22
218:24,25
219:19 224:22
229:24,25
230:22 231:1
right-hand
139:18 184:6
194:19
risk 18:23 19:9
19:17 31:16
RMR 1:22
233:20
Robin 65:22
70:12 75:21

77:1,7 79:11
87:19 89:5,9
91:23 103:14
223:23 224:18
role 82:25 92:10
101:8 229:18
room 61:25
62:13,16 63:6
63:10,14 66:3
122:6,6,6
142:16,20
144:2,10
145:10 148:22
148:25 149:2
164:13,22
165:13 167:25
168:24 170:11
171:11,23
174:12 214:2
216:25 217:4
218:10 221:12
221:13,18,22
roommate 25:23
25:25
roommates
88:20
rotation 42:6
43:5
rotations 42:7
roughly 20:9
36:18
rubber 26:14
rule 52:16
run 101:22
running 221:1
runs 29:18
rush 28:14,16
35:14,17
RYAN 3:16
S
S 4:8
S-a-i-d 146:18
s-u-x 133:25
sad 86:14
safe 167:25
safeguarding
114:23

safely 170:8
safety 52:21
92:23 102:12
114:23 170:12
saline 22:8
32:11 33:3
110:20 111:16
111:18 112:17
150:13,14
153:21 154:10
154:12 181:16
181:17 182:5
199:19 200:12
206:21
San 1:2,17 2:2
2:23 3:5,17 5:6
7:19 8:5,21
46:10 64:10
69:20 93:24
115:9 233:15
Sandhu 223:14
sat 75:20 221:10
221:11
satisfied 35:21
save 122:18
saw 42:16 54:24
150:2,2 199:7
220:6,6,6
say-so 112:3
saying 113:20
134:23 136:9
141:18 151:4
157:10 177:6
178:15 199:13
199:21 221:5
says 80:24
117:23 118:7
120:10 130:1,1
130:5 131:19
133:8 134:2
135:3 137:11
137:11 138:25
139:16 141:21
142:11 146:7
146:11,20
150:23 151:2
158:10 176:3
176:22 177:6

178:23 184:12
184:13 186:7
186:15 187:8
191:12 192:3
193:10,13,18
193:24 194:12
194:15,24
195:17 196:3
197:4,9 203:1
203:18,19
204:13 205:3
205:16 209:1,8
209:11,18,23
212:9 214:7,7
214:15 215:3
215:22 216:2
216:12,17
scan 211:24
scare 77:16
scarring 173:2,5
scheduling 70:7
school 6:15 7:1
7:3,16 13:6,8
13:15,21 14:4
52:24 53:8
82:25
science 6:22
189:7
scopes 119:13
screen 189:17
192:21
scrubs 35:5
scrupulosity
87:23
Seaberg 65:22
70:12 75:21
77:1,7 79:11
87:19 89:1
91:23 103:14
223:24 224:9
224:18
seal 169:11
searching 11:3
second 25:23
32:4 38:12,13
73:16 75:14
84:8 87:10
111:13 112:9

Imagine Reporting 619.888.0297

129:6 135:4,20
143:16 146:25
152:10,15
159:21 175:15
175:25 187:24
188:2 214:18
219:10,12
Secondly 93:10
seconds 192:25
secrete 111:15
secretions 142:7
section 202:25
sedated 141:15
sedation 119:13
119:15 141:8
sedative 57:22
see 27:25 41:24
42:2,4,7,9,10
42:15,21,23
43:5 54:2
71:11 96:12
98:7 104:16
112:13 116:2
121:2,12
129:15,25
130:3 135:6
140:11,19
143:6,8 144:14
145:1,19
146:13 151:7
154:12 158:1
159:21 163:8
163:12 169:3
176:2,6 177:1
184:6 185:23
186:8 188:8
192:2,11
193:10,22
194:7,17
195:17,25
196:4,10,18
199:5 203:8
206:17 217:3
seeing 42:20
97:9 98:18
99:18 220:13
220:25
seek 98:24

 Page 258
seeking 46:22
202:6,10
seen 43:13 75:8
95:17 118:1,3
153:3 158:4
191:23 195:10
195:12 204:18
207:3 209:7
221:19
sending 130:12
sensation 28:10
28:16 35:15
sense 28:1 33:13
52:12 148:11
150:22 152:3
156:3 178:9
199:20
sent 129:8
136:13 175:17
176:2
sentenced
228:16
sentencing
106:7 228:19
separate 73:21
85:22 120:9
122:3 147:17
197:14 201:24
September
229:11
series 195:24
serious 133:10
serving 128:5
set 59:20 84:4
158:8
setting 43:14
139:9
settled 144:12
seven 163:18
213:4 223:1
seventh 121:20
severe 84:15
141:16,16
shady 201:7
Shakes 58:24
94:4 125:9
Shannon 65:24
66:20 75:22

76:21 77:7
79:11 89:3
share 53:20
shared 100:2
sharps 150:13
197:24 199:5
210:22,24
Shayne 3:21 5:4
sheet 4:10 50:8
108:16
shift 42:12 64:23
Shiley 107:23
shipped 85:25
shoot 34:14 35:4
116:25 123:11
123:14 146:5
173:7
shooting 116:22
short 140:25
shorter 53:11
shorthand 2:24
233:3,7
shortly 23:3
84:12,16
155:10
shot 153:4
show 59:4 65:10
118:19 157:13
202:20
showing 121:21
shown 117:20
120:4 186:4
shows 120:8
158:19 176:13
176:20 186:5
187:9 191:23
shuttle 63:14
sic 5:7 33:17
70:20 125:24
130:8 145:9
181:13
sick 62:15 74:14
88:8 225:23
226:1
side 130:14,15
131:10 139:18
140:16 153:20
153:21 185:23

194:19
sign 109:24
111:24 150:17
183:7 184:25
233:9
signature 233:8
233:10
signed 112:22
150:11 184:23
significant 81:7
84:8 129:13
141:7
signing 94:18
183:9 227:1
signs 84:16 85:2
189:22
similar 14:9
53:10 64:7
141:9 201:11
201:15
Simple 192:13
192:13
simply 26:22
32:19 33:3,3
Simultaneous
69:11 124:10
167:2 211:21
simultaneously
63:1
single 13:11
37:2,6 93:14
108:8 113:3
213:3
sink 110:17
210:21,22
sir 6:7,14,17,19
6:21,23,25 7:2
8:19 16:2
29:21 74:17
147:5 173:10
194:6 212:5
sit-down 76:1
site 70:19,24,25
92:13 93:8
sits 48:17,17
sitting 13:11
139:25
situated 138:15

situation 38:6
70:2
situations 83:10
six 37:4 48:6
60:21 96:10
163:18
sixth 121:11
size 26:16 170:7
skill 52:20
skilled 64:10
skin 169:5
sleep 72:6 85:23
133:22 149:17
171:1
slight 15:10
28:18,18,20
slow 29:9
slowly 69:22,23
96:9
slurred 84:17
85:11
small 43:5 92:18
smaller 77:14
105:17
smoker 142:6
sneaky 201:20
so-called 109:10
sober 43:25 54:1
69:20 96:5
sobriety 36:6
79:25 96:1
97:14
social 43:14 54:2
54:8 83:3,6
sodium 193:13
solution 111:16
111:18 112:17
153:15
solves 182:16
some- 135:12
somebody 19:9
38:7 64:25
66:19 89:19
94:23 111:19
207:2
someplace 32:2
something's
218:24

Imagine Reporting 619.888.0297

soon 9:15 28:14
85:22 137:19
138:16 145:15
222:24 224:20
sorry 28:19
29:22 64:13
71:18 78:21
85:1 122:17
132:13,18
134:11 141:18
150:25 170:18
190:22 193:22
219:14
sounds 20:12,12
64:6 206:22
space 215:11
spaces 214:5,5
speak 75:4,11
160:14 201:7
207:5 224:24
speaking 58:1
122:15
special 56:1
119:19
specialties 17:24
18:17 126:8
specialty 19:8
specific 19:1
169:16 189:13
222:5
specifically
18:23 49:4
169:23
specifics 91:9
104:6
speculate 29:25
70:10
speculation
29:14 70:15
speech 84:17
85:11
spell 70:20
spent 82:17
166:11
spine 131:17
171:3,5
spoke 66:19
73:16

 Page 259
spoken 75:9
230:3
sponsor 126:16
223:23 224:4
spot 218:22
squirt 111:23
199:7
squirted 150:14
197:24 199:4
squirting 199:10
199:18
stabilize 99:11
stable 171:19
staff 105:2
139:24
stalls 34:22
stamp 175:16
stand 221:24
standard 94:14
138:14 166:14
169:13 180:6
180:10 211:6
standards 93:1
stands 132:4
start 24:24
62:18 69:19
100:23 117:24
118:21 120:14
120:25 121:5
121:12,21
135:8,11
138:15,16,17
150:25 159:25
159:25 160:7,8
169:20
started 23:6
24:19 29:9
48:15 51:22,23
62:1 66:8
69:22 73:9
86:1 96:8,9
97:19 114:4,9
114:11 137:23
140:14 144:11
148:5,6 159:23
160:3,14,17,19
160:19,20,20
161:16 188:23

starts 100:23
173:12
state 1:1 2:1,25
5:15 12:9
101:22 102:8
105:18 228:3
229:22 232:2
233:4
stated 233:7
statement
101:11 134:12
142:12 156:24
158:10
states 205:3
stating 87:24
station 141:8
209:25 213:8
StationName
209:23
status 184:13
225:22
statute 226:19
statutes 227:25
stay 45:11,14
80:2 90:6
103:6 168:10
217:21
stayed 69:5
steal 21:2 26:3,7
98:13 149:7
155:3 166:20
stealing 38:1,7
68:23 100:11
108:23 114:13
117:6,7 128:4
179:18,22
step 11:2,5,9,14
11:18
steps 11:22 12:5
sterile 168:24
stick 168:14
stimulant 59:11
85:19 100:6
stimulating
141:25
stipulated 97:23
98:3
stipulation

230:17,19
stitched 144:2
145:4,8,14
174:15 180:11
181:6 191:20
stitches 142:14
142:16
stitching 144:25
stole 24:4
stolen 20:25
21:7 30:22
stood 218:25
stop 94:11 98:18
117:24 118:21
120:21 121:1,5
121:15,21
196:7
stopped 86:2
88:19 99:17
148:6 168:15
191:10 194:15
stopper 26:14
stored 159:20
story 91:8
straight 44:13
189:6
street 3:4 58:7
58:14
stress 17:16 18:8
126:11
stressful 17:17
strict 211:8
strike 77:12
80:23 106:1
string 209:21
strong 82:21
stronger 20:10
59:16 136:1,4
222:14,16
stuck 142:1
student 19:11
stuff 49:24
115:17 145:13
159:25 160:4
161:17 198:2
subjected 79:8
subjective 72:10
submit 222:3

submitted
228:20
subspecialties
19:18
substance 12:15
12:24 17:23
18:2,17 19:4
19:10,20 46:4
46:22 57:1
66:23 74:4
76:4 83:16
95:8 96:19
100:3 101:13
101:22 114:20
125:16,22
126:9,20
135:14 210:12
226:20 227:18
228:11 229:10
229:16 230:8
substances
17:20 18:12
19:13 46:1
49:10 55:9
99:2,19 126:12
205:22 210:21
211:4 227:21
227:25 230:2
substantial
19:17
substantially
226:15
substitute
111:16
substituted
110:20 206:21
succinylcholine
171:7
suck 27:16,21
sucks 142:22
sued 9:19
sufenta 135:3,4
136:9 137:11
156:4,5 160:17
176:3,24
sufentanil 55:14
56:14 57:2
58:2 135:15,23

Imagine Reporting 619.888.0297

135:25 136:7
137:13,17
139:6 146:25
147:3,3,14
149:4,7,10,15
150:15 152:6
153:11 154:8
154:18,19,22
155:17,21
156:9,14
158:20 160:14
160:18 161:5
165:5,7,10,12
176:13 179:12
179:18 181:8
181:11,16,20
181:25 182:12
186:1 190:24
191:10 193:11
193:13 194:8,9
198:18,22
199:1,8,18
200:15 216:24
218:17 222:7
222:14
suffer 86:10
suffered 80:19
suffering 80:7
sugar 140:2
suggest 229:16
suggestion
87:25
suicidal 81:23
82:1
Suite 3:10,17
5:5
summoned
63:25
Super 73:1
SUPERIOR 1:1
2:1
superiors 41:4
supervising 63:1
63:8
supervision
52:12,14 60:13
61:15 233:8
supervisors 41:3

 Page 260
supplement
102:7
supply 108:5
211:5
supposed 31:17
137:17 138:11
160:7 164:22
230:1
Supposedly
94:14
suppression
140:17,22,23
141:1,5,6,11
141:19
sure 16:13 17:18
40:21 41:17
42:19 62:18
70:8 73:20
75:3 76:2
79:14 87:14,21
89:1 104:14
112:9 129:12
129:18 144:9
144:10 156:1
156:12 160:10
160:25 169:8
177:14 184:11
195:10,11
207:13 221:17
surgeon 12:12
226:16
surgeries 118:25
119:6 122:3
123:3 155:17
163:5,11 164:3
surgery 60:25
107:15 119:3,4
119:7,10,16,18
123:9 125:6
133:20 144:2
145:12 147:4,9
147:14,24
151:20,23
153:8 155:4,14
156:7 160:22
164:6 165:3
167:7,15
191:25 192:12

198:9 210:5,6
224:20
surgical 108:7
146:9
surprise 208:19
suspected 38:7
suspend 72:24
suspicion 73:15
75:1,4 88:6
suspicions 88:9
89:20 126:2
suspicious 75:4
sutured 169:5
sux 133:25
swear 5:23
sweating 86:22
sweats 86:23
Swell 162:4
switch 169:7
181:22,23
208:9
switched 218:17
sworn 6:3
symptom 75:8
symptoms 15:9
15:11 84:16
85:3 86:10
115:17
syndrome 84:1
84:2
synthetic 20:7
24:22
syringe 24:12
26:23 27:17,17
27:21 28:4
31:24 33:13
35:1,3 111:18
138:21 152:8,9
152:9,10,15,17
152:20,23
153:12,14
181:13,14,24
181:25 182:2,4
197:14
syringes 26:7,8
28:6,6,7 32:14
32:16 152:6
182:3 197:14

24:1 30:24
34:13 36:10
41:12 74:5
80:13 91:1,3
91:16 100:14
107:1 108:20
125:15,18,21
129:23 154:5
164:14 166:7
219:9
talkative 72:8
talked 18:20
39:3 64:11
T
135:14 153:23
T 4:8
158:5 164:15
tab 192:18,19
170:23 172:17
table 168:25
talking 40:18
tad 139:12
80:2 144:14
take 5:11 11:18
160:12 161:4
24:21 26:3
192:7
32:10 33:8,20 talks 71:19
34:2,14 35:11 tally 189:5
41:12 45:9
Tammy 1:7 2:7
46:1 50:16
3:8 4:11 5:21
57:25 63:23
51:19 53:13
72:23 77:20
54:24 129:2,3
78:11 79:8
130:1,15
112:3,12
134:17 150:4
113:14 117:12
153:23 157:20
119:2 128:18
158:11 165:6
139:11 143:12
165:22 166:12
146:21 153:11
174:3,19 176:2
154:8 161:24
179:1 181:12
172:14 175:11
188:1 191:17
178:19,23
194:18,21
184:22 188:14
198:19 199:6
199:11 202:12 tearing 86:20
210:16 211:9
technical 136:20
212:19 219:12 technically
taken 12:1 62:14
56:25 150:20
82:11 84:1
175:6
110:21 145:11 tell 7:14 8:16 9:5
153:22 165:10
12:2,6 19:25
182:2 185:15
20:24 23:9
198:2,3 211:15
38:11,19 39:14
215:23 224:21
41:2 53:22
233:6
61:13 66:5,17
talk 14:21 22:25
67:25 70:25
220:6 221:5
system 79:6
104:1 107:7,8
107:18,22
108:11 110:6
110:11 159:11
159:11 161:3
194:23 229:17
system's 105:24
systemic 149:18
systems 102:6
105:19

Imagine Reporting 619.888.0297

74:5 77:16
78:9 89:7
95:16 101:7
105:15 107:6
107:14 110:9
118:8,24 119:6
124:22 130:13
131:15 132:3
132:12 136:13
138:19 139:2
140:21 165:24
166:16,20,23
167:12 168:19
170:4 176:11
184:7 188:1,12
190:10,19
203:3,14
204:20 205:19
207:9 217:25
218:14
telling 31:11
179:24
tells 20:9
telltale 173:2
ten 20:9 115:21
120:9 215:9
tendency 20:17
Tens 59:2
tenth 2:23 11:18
tequila 14:2,3
term 47:4
100:22 103:3
141:23
term- 104:25
terminate 105:1
terminating
104:24
test 76:6,15
77:20 78:1,11
112:9 119:25
tested 76:12
78:5 113:4
206:17
testified 6:3
testify 233:5
testimony 9:18
90:9 175:7
191:5 232:6

 Page 261
testing 78:3,12
80:16 82:10
78:16 94:11,13
83:19 90:13
95:1 97:6
119:2 148:8
tests 76:7 78:22
167:6,9 180:8
79:7 93:10,10
189:8 193:1,4
93:13 94:2
209:12 212:21
text 129:1,10
think 10:6,8
130:12 134:17
16:7 18:13,20
139:17 145:4
26:18 29:8
146:5 160:9
38:12,14,16
175:11,17
39:1 40:13
176:3 197:4
49:12 51:22
texted 143:2
52:19 53:9
texts 4:11,13
54:6 55:12,21
175:17
57:7 59:18
thank 50:22,23
66:1 69:18
73:22 87:23
70:7 78:10
117:13 128:23
81:20 84:20
175:5,9 183:17
88:25 89:10,20
202:21 216:21
90:5,19,20,21
230:11,12
92:14 93:11,19
Thanks 73:1
95:15 97:18
204:16
98:14 100:21
theft 161:20
101:1,25
therapist 96:12
104:21 106:6
97:9 105:21,25
116:15 119:11
106:2
122:15 123:25
therapy 58:18
124:4 128:9,15
80:7 115:23
129:16 131:7
thereabouts
142:18,25
200:8
150:6,13
thereof 233:12
156:12 157:7
They'd 112:1
157:10 158:4
thing 40:21
158:21 159:20
75:10 97:1
160:3 162:2
104:18 110:13
163:15 165:5
111:13 128:7
166:6,8 174:16
141:25 150:7
192:18 201:25
159:3 162:15
203:13 204:2
163:23 165:4
210:8 211:6,6
189:2 214:24
211:23 213:16
218:25 221:21
221:1,10 225:1
225:23
225:16 229:23
things 11:6
230:10
15:13 44:9
thinking 168:12
53:20 62:4
218:23 222:25
66:11 68:7
third 33:2 76:11
71:3 73:20
123:10 143:10

205:12
Thornton 51:7
51:16 52:1
60:3
thought 97:19
103:12 149:10
154:24,25
168:12 201:7,7
208:12 218:22
thoughts 72:11
81:23
thousand 137:7
137:8 147:21
177:15,17
194:5 206:20
three 13:14
14:25 15:4,25
16:1,3 22:10
24:1 30:19
31:1 36:16,22
53:9 57:8
60:17 88:3,22
92:14 94:13
114:8 116:7
122:3 148:15
160:21 163:4
167:22 170:14
198:12,14
208:10,16
224:2
three-year 15:1
throw 77:15
91:7
throwing 210:21
Thursday 2:21
134:7,13,15
tightness 28:18
till 62:12 217:21
223:21
time 8:11,12
10:7,10 19:25
20:24 23:10
26:13,19 27:2
27:11,23 28:22
29:8 30:7,19
32:21 34:4
35:11,12 36:8
37:7,22 38:1,1

38:21 44:7,8
44:13,18,21
45:5,9,12,17
46:3,6,10,15
47:5,5,14,20
49:1,2,9 54:1
54:13,16 59:25
60:24 63:22,22
65:7,12 66:2
68:6 70:15
71:4,23,23
72:1 73:16,16
74:16,25 76:10
76:14 77:9
78:25 79:20,24
80:21 81:25
82:17 85:19
86:3,3,7,7
87:18 88:12
89:14,18 90:19
93:12 94:15
96:14,14,17
101:4 102:1
103:15 106:19
109:16 110:16
110:19 112:24
113:14,14,25
114:3,5,7,12
118:2,21
120:14,18
121:8 122:2
123:11,14
124:20 127:9
128:3 132:24
132:24 135:8
135:20,20,23
136:14,16,17
137:20 140:8
143:6,13,15
146:25 148:18
149:19 150:1
150:15 152:7
158:9 160:3,7
160:8,15,20
161:19 164:18
165:2,15,16
166:11 168:11
171:23 172:17

Imagine Reporting 619.888.0297

172:24 173:6
174:19 175:16
178:3 181:22
181:23 182:20
183:4,6 187:9
188:15,23
189:14 191:24
192:5 193:2
194:23 206:15
209:7 211:13
211:14,15
216:23 217:2
222:1,8,21,22
222:23 223:21
223:21 224:4
226:5 229:9
233:7
times 5:11 15:4
15:25 16:1
18:21 20:9
25:12 30:16
34:9 42:7,9,11
42:16 43:15
46:16 48:5,6
54:17 56:16
57:8,17 62:21
62:22,25 64:21
85:9 86:10
106:20 114:2,6
114:13 116:18
116:20 117:1
122:24 123:2
124:19 135:18
135:25 136:3
140:11 155:18
161:18 163:18
178:19,23
188:16 193:7
201:18 207:1,4
207:4,10
208:16 222:14
222:15
Timothy 212:17
tiny 137:9
Title 228:8
today 5:6 12:6
183:24 217:22
Today's 5:8

 Page 262
Todd 1:7 2:7 3:8
toilet 111:23
210:24,25
toilets 211:1
told 29:3 44:15
47:16 53:25
65:7,9 73:9
75:11 78:2
79:22 80:23
91:8 100:5,8
123:19 128:10
140:17 142:20
150:10 158:11
169:24 172:18
201:9 208:13
224:8 225:16
225:17
tolerance 20:18
25:16 34:10
83:18
tomidine 57:14
57:15
tomorrow
133:13 134:13
ton 181:4
tongue 57:10
Tony 220:13,19
top 103:20 118:9
129:25 135:4
total 36:18,20
151:12 181:14
193:18
touch 189:16
trachea 142:2
track 108:12
208:21
tracks 50:3
traded 169:10
181:13
trained 229:9
training 52:22
53:3 119:21,21
229:8
Transaction
211:14
transcribed
233:7
transcript 232:3

Transfer 203:1
transferred
185:16
trash 110:15
210:22
travels 173:15
treat 115:2,16
treated 37:23
39:24
treating 37:25
69:2 117:3
treatment 64:23
68:7 90:14
91:12 95:4
115:10,12
123:21 140:6
145:9
trial 9:21
tried 41:1 43:25
61:14 97:15
115:2 166:13
true 11:17 13:8
14:10,16 24:7
64:21 99:9
109:12 112:6
115:3 125:11
157:3 161:22
161:22 163:23
167:13,18
172:25 173:1
175:13 176:9
179:6 205:10
232:6
trust 223:11
truth 12:2,6
39:14 77:17
98:4 233:5
try 34:23 69:20
101:12 146:25
193:6 225:23
trying 101:1
102:7 124:4
166:11 167:23
217:14 224:19
tube 134:1
153:19 170:8
turn 22:8 33:3,8
33:9,10 139:1

139:14 206:16
212:25 213:21
turned 135:5
136:10 137:13
149:3 176:4,24
turning 50:4,5
110:14
twice 15:24
16:24 56:14
78:15
twister 57:11
two 15:4,15,19
16:9,13 26:14
36:19,22,22
42:16 48:1,25
51:17 53:9,9
53:10 55:12,14
62:25 63:3,8
63:17 73:20,20
74:2 81:1
83:18 88:25
93:12 94:16
103:18 104:5
104:11 114:8
115:18 135:18
143:12 149:13
164:3 177:22
179:25 180:2,8
182:3,16
197:14 206:5
212:3 214:14
217:22
twofold 180:22
type 109:25
203:9 212:2
typed 211:25
types 50:11
typewriting
233:7
typical 15:11
60:16 120:12
128:9 170:20
170:20 196:20
typically 108:22
138:11 188:13
191:22,25
U

UCSD 8:9 14:17
20:5 30:20
40:7 47:18
48:9 49:10
51:5,7 60:3
65:4 69:7
93:24,25 98:13
100:11 184:21
205:11,14
208:22 229:9
Uh-hmm 144:18
Uh-huh 141:22
ultimately 52:13
127:9 152:24
ultimatum
89:25
ultrasound
130:9,25 131:5
166:13 168:6
168:25
Um 38:8
Um-hmm 22:17
22:21 31:4
33:19 35:25
40:20 52:25
64:2,6 76:22
78:6 79:13
85:17 97:25
99:8 107:5
109:11 112:5
120:7 121:14
121:22 131:1
133:11,15
134:19 136:21
140:20 142:23
144:21 145:2,6
146:6 151:9
167:16 172:22
175:24 176:1
176:10 181:7
184:4 185:21
186:2 188:7
193:15 195:16
195:21 199:25
203:2 205:1,8
205:15 209:10
209:24 212:8
212:18,20,23

Imagine Reporting 619.888.0297

215:5 216:8,14
216:16 218:2
219:4,7 222:11
222:13,17
unable 167:23
underneath
43:8
understand
10:21 12:1,22
14:24 19:17
26:5 52:16
76:23 77:19
78:18 79:17
80:16 87:24
102:10 122:14
124:14 131:15
137:12 147:8
151:4 153:10
191:5 192:7
199:21 214:23
225:9,14
understanding
22:15 91:2
101:8 120:22
137:16 138:10
140:21 157:21
182:13 204:22
205:20 209:6
210:1 225:12
understood 10:4
60:2 92:22
109:4 131:22
139:2 226:14
unduly 206:23
unit 120:24
200:7 203:5
UnitCost 215:18
units 191:6
200:5
University 1:8
2:8 3:8 6:20
7:4,17,19 8:5
8:20
unlocked 218:12
unopened
213:13
unprofessional
226:21,24

 Page 263
227:3,7,10,15
227:18,22
unused 32:22
109:20 111:15
154:8 213:10
213:13,18
unusual 67:3
120:12,13
127:1
urge 82:21
urinalysis 79:4,8
urologic 119:9
usage 30:5 76:14
use 13:17,21
19:23 20:16
22:10 23:4,12
23:15,19,22,24
24:9,15,24
25:24 26:2,8
27:2,17 28:25
31:6 33:22
34:16,23 36:7
37:5,19 45:17
45:19 47:5
49:24 55:5
56:19 57:17
58:25 63:11
74:4 79:3 82:3
82:10,15,18,21
82:24 83:2,8
83:10,13,16,21
84:7,12,17
85:6 86:8
88:21 89:16
98:13 100:9,12
101:5 106:19
107:4,24 110:6
110:10 111:13
114:9 117:7
133:25 139:6
148:16,18
153:14 155:16
155:19 156:1
161:21 173:20
178:6 198:17
218:17 230:1,8
230:18,18
user 211:22

versus 157:25
vial 26:14 27:22
89:11 147:20
vials 26:20
147:20 213:4
213:13 214:8,9
215:23
vice 178:22
206:13
Vicodin 45:20
45:21,25
video 1:16 2:20
5:10 63:11
Videographer
3:21 5:1,22
50:24 51:1
73:2,6 117:14
117:16 162:5,7
202:14,16
V
219:15,20,22
V-e-n-d 213:22
231:2
VA 51:7
VideoTrack 5:5
valid 233:3
view 62:8 92:22
variation 138:23 Village 2:22
variety 226:10
3:17
various 13:24
violated 226:9
17:24 185:24
227:24
228:21
violation 226:19
vehicle 9:7
228:2,8
vein 27:14,18
visit 41:16
168:4,5 169:4 vital 189:21
172:21 173:8,9 Vitals 4:12
173:12,14,18
vivid 128:13
218:23
143:2
Vend 212:22
vividly 220:20
213:22
vodka 13:24
ventilation
47:8
133:23
voice 170:16
ver- 124:3
voices 220:4
verbal 45:3
volume 213:20
verbally 45:4
vomit 220:6
verified 169:2
vomiting 86:16
verify 214:4
vs 1:6 2:6 5:3
versa 178:22
vulnerability
206:13
126:9
Versed 55:15,19
W
55:21,21 56:22
170:21 213:5
wait 62:11
216:3
UserID 211:19
UserName
211:18
UserType 212:9
uses 85:15,18
usual 72:8
218:22
usually 27:19,19
103:7 104:11
105:20 116:4
138:13 141:24
170:21 189:1
190:4 192:2
193:2 210:25
212:25 213:7
Utilization
229:16

171:20 189:20
waived 233:10
wake 39:20
waking 62:18
walked 148:25
149:1
walking 217:6
wall 220:7
want 23:23 25:2
38:18 40:17
45:5 49:24
59:4 62:20
70:9 73:17
76:2 77:10
85:6,7 91:16
103:6 112:9
116:8 129:12
133:12,14
134:12 138:4
139:5 145:24
161:20 167:9
169:19 171:3,4
173:2,4 183:15
214:2 219:15
219:19 223:9
225:13 230:16
wanted 35:14
49:23 73:14,19
75:3,17 92:12
111:3 115:16
128:7 148:12
149:13 180:22
221:11,21,22
223:6,11 226:1
wash 170:11
wasn't 18:19
29:10 33:9
37:15 46:7
56:9 84:20,23
85:4 115:18
135:4 136:10
137:11 140:13
149:9 176:3,24
187:2 201:22
waste 21:5,9,11
21:14 110:15
151:2 158:9
181:17 197:20

Imagine Reporting 619.888.0297

198:3,4 205:4
205:19,21
206:6,14,17,21
207:3,17
208:15 211:9
211:11 212:14
212:22 213:12
213:17,20
216:19
wasted 89:19
108:19 109:25
110:1 112:2,23
113:12,19
125:6 150:24
150:24 206:12
wasting 109:10
109:14,19
150:18,20
197:19 199:8
206:6 207:23
watch 61:16
63:11 219:13
watching 142:15
water 211:4
waves 140:25
way 16:18 21:11
22:2 28:21
30:24 32:4
33:2,6 37:20
39:7,15 64:1
101:16 107:25
110:7 149:3
155:22 180:12
182:15 192:9
198:16,17
200:21 201:20
201:22 214:22
227:13 233:11
ways 24:14
26:15 31:2
63:18 71:5
110:9,22
179:25 180:2,4
201:21
we'll 117:12
128:18 158:12
161:25 183:20
we're 40:17

 Page 264
66:16 87:21
90:1 138:6
164:21 217:21
we've 12:5 50:15
57:25 90:5,5
121:18 126:7
161:4 164:15
177:14 191:23
wean 122:19
week 13:14 15:7
93:11 94:16
104:3,21 116:7
weekends 47:14
weekly 42:4
96:21,25
weeks 81:1
93:12 94:16
weight 81:7,8,8
139:1,4,7
149:21 176:16
185:10 189:4
193:16
weird 89:11,15
144:8
WEISS 3:9
well-being 65:6
65:23,25 69:25
70:1,13 75:19
75:22,24 76:18
76:23 77:13
87:9,17 88:15
89:5 91:6,6,9
91:21,23 92:2
92:7,16 100:17
100:19 101:8
101:11,12
102:3,11,11,18
102:21 103:2,8
103:9,14,24
104:17,25
105:6,13,24
106:3,11
114:16 126:22
223:24
well-known
127:6
well-taken
217:20

Wellness 125:24
128:5
went 7:1 16:16
40:19 46:4,13
48:2 52:23
54:6 66:3
67:25 69:10
75:19,19 80:21
85:9 91:19
94:15 95:15
96:8 101:25
144:1 145:10
149:3 150:1
162:14 164:23
165:12 174:7
174:11 192:4
217:8 218:1,15
224:13
weren't 62:21
West 3:4,10 5:5
whatnot 42:24
white 47:4
white-knuckle
46:17,19
wide 218:6
wife 10:6 223:9
223:15 224:2
willing 11:12
Windows
192:19
windpipe 142:1
winter 29:7
wish 49:11
146:23 190:18
224:22
wished 162:11
withdraw
125:11
withdrawal
83:24 84:1,2
86:6,11 115:17
115:18
within-entitled
233:6
witness 4:3 9:9
29:19 50:18
55:17,19 59:8
69:12 120:18

159:1 167:3
170:18 174:25
177:10 204:3
206:10,13
207:24 211:22
217:15,18
219:14 230:12
233:5,8,9
witnessed
110:18 150:18
206:11 210:17
210:19
WitnessUserN...
216:13
woke 149:5
219:1,3
word 74:23
113:6 130:21
words 15:23
28:3,19 33:16
35:19 40:9
42:15 44:7,15
61:9 63:5 65:9
66:6 107:15
108:8 158:15
198:25 199:13
199:23 201:4
221:6
work 14:11,14
15:3,6 17:14
47:17 48:20
54:21 58:23
60:19 61:6
69:7,19,22
70:19,24,25
82:25 88:9
90:10 92:13
93:8 97:14
102:20 116:8
116:10,13
135:8 149:14
150:7 164:19
worked 14:19
53:12 54:15
60:2,23 92:11
107:14
working 42:5,6
42:22,22,23

48:8 51:15,23
59:25 60:11,15
61:4,5 85:23
168:15 184:20
199:14
workplace
104:19
workroom
165:11 210:4,5
works 212:2
world 161:15,17
worried 115:17
worst 40:18
worthless
214:25
worthlessness
81:17
wouldn't 23:23
27:19,21,21
32:15 37:19
42:7,15 62:14
76:15 85:6
100:24 169:5
181:3,3 199:7
wrapping 220:7
write 108:17
130:21 139:17
161:19
writes 131:13,25
140:16 177:19
writing 136:9
written 214:22
228:20
wrong 11:19
29:11 43:25
109:5 193:23
200:11
wrongdoing
89:17
wrongs 11:7
wrote 106:6
179:1 225:25
X
X 4:1,8 146:5
Y
Yawning 87:1
yeah 7:15 14:8,8

Imagine Reporting 619.888.0297

15:10 16:15,18
16:18 17:17
18:13 20:19
23:11,23 24:5
24:21 25:16
26:12,24 27:13
28:20 29:22
30:6,6 33:5
34:2 36:6 38:3
39:11 42:18,18
42:18 44:8
47:3 49:7
53:23,25 54:19
55:19 56:10,18
56:24 57:1,7
58:19,21 59:8
59:20,24 60:22
60:22 61:3
62:9 63:2,16
63:24,24 65:21
66:4 67:8
69:12,22 70:5
70:6,24 75:17
78:19 79:16,18
87:22 93:12,19
95:9,24 96:8
97:8 98:2,12
98:20,23
101:19,24
102:6,13 103:6
103:17 105:16
107:13,13
108:10,15
110:4,21,24
111:24,24
112:1,7 115:24
116:12,18
123:22,22
124:2,13,15,20
126:6 128:6
129:18 130:23
132:5,15,17,19
133:7,8 134:7
137:15 139:11
139:13,24
140:7 142:13
143:4,11,11,14
143:14,19

 Page 265
145:10,14,15
147:25 148:2
148:17,20
153:5 154:4,7
154:13 155:9
155:12 157:15
157:19 159:1
161:15 164:2
168:18,18
173:4 177:6,9
177:10 180:17
182:13 183:13
185:4 189:16
191:21 193:25
196:25 200:24
201:5,8 203:13
203:21,24
204:12 207:18
207:20,22,25
209:16,20,22
210:13,22,22
214:24 215:2
215:16,22,24
216:6 220:11
221:25 223:16
224:6,10,12
226:5
year 6:18 7:8,15
7:23 15:4 20:1
20:2 29:7,15
30:12 35:24
36:23,24,24
38:13 55:3
59:23 76:11
80:3 94:3 96:3
96:10 97:21
100:22 101:2,2
103:3 105:25
107:2,2 109:18
109:18 112:8
116:19 125:14
127:22 132:17
years 14:24,25
21:15 36:19,22
52:24 53:1,5,9
53:10,13 80:20
87:24 94:13,18
95:15,19,21

1.0 178:24
1.02 158:19
1/1,000 137:3,6
1/23/17 4:13
130:1
1/27/17 4:14
Z
193:18
Zeigen 225:7
1:28 146:11
zero 141:11,13
1:53 117:14
141:14,17
10 33:7 37:7
150:20
136:3 146:7
zeroed 148:13
152:8,18
148:14
177:23 193:24
218:21 222:12
0
222:14,15
0.01 178:18
10-cc 152:9
198:20
181:13
0.01333 198:21
10-hour 150:2
0.05 176:16
10-minute
177:6 178:15
174:20
191:3 198:15
10:15 2:21 5:9
0.5 177:4 178:13 10:31 196:9
0.6 135:5 136:10 10:32 121:1
176:4,25
184:14 203:20
177:19 178:10 10:44:39 144:24
178:25
10:45 190:25
01 178:4
10:58 194:13
013 178:4
100 1:9 2:9 3:10
02 193:24
144:9 161:1
05 178:3,19,23
169:12 170:10
170:13 186:19
1
186:23 201:19
1 4:10 5:2 27:6
201:25
29:18 30:4
105 3:4
111:4,4,8
11 215:15
117:18 120:4,4
11:06 194:15
130:14 137:7
11:07 191:11
147:21 148:11
11:08 191:11
150:8 158:7,9
11:13 121:21
162:21 177:4
11:14 50:24
177:15,17
11:25 51:2
178:2 182:21
11:53 73:2
194:5 197:21
11340 3:10
198:2,21,23
117 4:10
199:10 205:5
11th 12:9
205:17 209:9
12 11:22 103:25
1- 192:3
12-hour 150:2
1,000 193:13
12-pack 13:9,13
1,000th 137:1
99:6 107:6
208:10
yesterday 129:9
230:19
YOO 3:3

12-step 10:22,25
68:9 93:16
95:10 96:7
97:11,15
12-step-based
68:11
12-step-like
68:9
12:15 50:20
12:56 73:7
125 192:4
128 4:11
13 215:25
130 139:10
1306 217:4
1310 217:4
1315 217:2,5
1327 184:5
1328 185:7
1329 185:20
191:23
1330 196:7
1331 190:21
191:23
1333 191:8,23
192:3,11
1336 193:8
1338 196:15
1347 202:23
135 139:10
14 1:18 2:22
47:25,25 48:7
163:15,16
181:14
140 193:16
14th 5:8
15 77:15 134:20
135:25 150:15
152:1,4 154:9
154:10,12,15
163:11 181:14
197:13 202:2
216:7,12
150 186:5,7,15
186:19,20
187:8 201:19
201:25
1526 121:5

Imagine Reporting 619.888.0297

16 45:16 47:16
79:22
160 192:4
17 57:9
175 4:13
183 4:12
184 4:15
193.33 193:19
1975 6:10
1994 6:18
1998 6:24
1st 8:13 30:8
100:24 103:7
2
2 4:11 21:25
22:1 27:6
32:10,11,11
33:8,11 111:6
128:17,20,25
152:24 172:5
186:17 210:3,5
210:6
2/3/17 184:14
203:19
2:00 117:13
2:03 117:17
20 26:19 151:15
152:5 174:19
197:13 201:18
20-cc 26:20,20
181:24,25
182:2,4
200 56:8
2002 7:9 8:13
2002-2003 7:23
2003 8:14,15,18
20:4 29:7 30:8
132:13,14
2004 12:10 30:4
30:8
2006 8:10,16,18
8:25 36:14
40:6 44:23
132:11
2007 48:18
51:12
2008 51:14 55:3

 Page 266
55:4 59:23
60:8,16 64:25
67:14 69:7,8
80:3,4 87:11
88:4
2009 94:3
2010 94:5
2011 94:7
2012 94:9
2013 9:16,17
95:22,24 96:1
96:6,11 97:7
2014 95:23 96:3
96:4 97:9,11
97:13
2015 97:17
98:18 125:18
2016 57:9 59:19
97:19 98:12
99:22 100:8
106:15,16
107:2 109:18
112:8,25 114:1
120:6 125:14
205:5 229:11
230:6
2017 107:2
109:18 112:8
113:1 125:20
125:24 196:9
203:21 205:5
205:19 230:6
2019 1:18 2:22
5:8 205:7
233:14
202 4:16
204 4:17
20s 58:25
21 117:21
216:15 228:8
22 117:21
205:17
23rd 134:4
175:12
24th 233:14
25 202:2
250 147:24
25th 163:7,13,17

26th 48:17,18
115:2 122:22
123:20 163:2
163:24
27 205:5
27th 113:1
125:20 134:6
135:8,21 143:7
164:1,3,15
175:12 208:14
208:22 216:22
28 205:7
3
3 1:9 2:9 4:12
21:25 32:9
183:14,16
184:3 185:22
212:7 215:23
3:00 161:24
162:5
3:16 162:8
3:26 121:6
30 44:23 67:17
145:21 174:17
30-60 145:18,21
30th 8:10,14,16
8:24 36:13
80:4 95:20
310.575.9566
3:11
310.575.9576
3:12
33 190:17
35 157:16
37-2018-0000...
1:6 2:6
3rd 6:10 67:16
67:18,19 80:3
122:22 124:12
196:9 203:15
203:21
4
4 4:13 131:17
153:5 175:16
175:19,23
183:12 212:16
4:09 202:14

4:16 202:17
4:38 219:20
4:39 219:23
4:55 231:2
4:56 231:9
40s 59:1
45-minute 50:20
4660 2:22 3:17
47 215:24
4th 115:1 122:22
123:19
5
5 4:15 50:1
111:22 112:2
135:25 147:20
152:1,4,9,11
153:6 154:25
179:2 183:21
184:1 198:7
212:19 214:2
218:18
5-cc 26:18
181:14
5-milligram
147:18
5-ml 151:8
5:00 162:3
5:30 162:3
50 54:17 113:2,3
147:19 154:24
181:15,15
190:18 201:18
201:19 215:22
218:19
500 39:24
51020 211:19,25
59 50:16
5th 120:6
6
6 4:6,16 44:24
202:18,20
6:00 134:14
6:10 134:14
6:30 135:12
6:40 164:21,24
164:25
60 139:1,5,9,10

145:21 156:21
177:25 178:1
178:16,17,19
178:24,25
600 5:5
619.233.1525
3:5
619.233.3221
3:6
670 3:17
6973 1:22 233:4
233:20
7
7 4:17 98:10
131:17 204:11
204:15 214:12
7:00 135:12,13
164:20,21,25
217:21
7:10 165:1
7:11 121:13
7:18 121:5
7:20 135:11
164:22
7:30 135:11
700 5:5
8
8 33:8 157:14
8:30 176:21
187:10
8:41 194:8
196:24
8:45 176:21
186:23 187:10
8:58 121:1
800 206:24
207:6
843(b)(3) 228:10
85 140:21,23
141:6,12,14
85% 140:17
858.452.1491
3:18
858.597.9975
3:18
9

Imagine Reporting 619.888.0297

9 215:1
9:00 186:23
9:08 121:15
9:15 190:25
9:17 176:2,23
9:24 121:21
9:44 130:2 145:9
9:51 143:11
145:5
9:51:47 143:7
90064 3:11
92101-6036 3:5
92122 3:17