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CASE: DOYLE V.

MOUNT VERNON MEDICAL CENTER SUMMARY OF THE DEPOSTION OF: ALAN MERCER PAGE/LINE 1:16-24 2: 11-17 2: 19-27 4:2-9 5: 7-19 5:20 6:05 6: 12-26 7: 7-15 8: 1-12 8-9: 20-5 9: 18-21 10:6-17 11 11: 19-24 14: 1-25 TOPIC Appearances Location Background Experience Requirements Exhibit 1 Exhibit 2 Typical Day IVP Dangers Form/Manual Form/Manual Violation Exhibit 3 Duty Breached Duty SUMMARY Bradford, Miller, Hutchinson Reeves, Allyn, Cain Mercer employed at Mt. Veron Med. Center Glessner Ave., Mt. Veron Mercer attended Concord County Community College. Earned his associates degree I applied science in radiologic technology Witness stated he had over 320 hrs of experiencein the radiology department at Mount Vernon Medical Center. Employees at MVMC are required to sign appropraite forms before procedure. Copy of Procedural forms with Plaintiff's sigature. Copy of Policy and Procedural Manual. Witness remembers Mr. Doyle as the patient who "came close to dying." Witness deals with many patients on a daily basis. (30-40 patients) Intravenous pyelogram can be a dangerous procedure. Mr. Doyle was scheduled for one. Mr. Doyle was never explained the dangers involved in the procedure. Dr. Abigail Rooseevelt was supposed to explain the dangers. Witness never got the chance to explain form to Mr. Doyle. Manual states that radiologist is REQUIRED to explain dangers of procedure. Witness states that everytime he worked with Dr. Roosevelt, she has violated the procedural manual for patients. Copy of patients chart of allergies. Mr. Doyle answered "YES" for allergies. Nurse had a duty to check the patients chart to make sure for any complications Dr. Roosevelt was negligent in checking chart also. Antidote was supposed to be available near by during procedure just in case something were to happen. Dr. Roosevelt was aware of this according to witness. Also, with the antidote not available nearby, Mr. Doyle could have gone into shock. Dr. Roosevelt according to the witness was AWARE of the antidote not being precent during procedure, but went ahead with it annyway. Witness stated that Dr. Roosevelt continued with the procedure. When witness came into the room, there was a crash-cart there and Mr. Doyle suffered cardiac arrest. If procedures go wrong, the standard procedure is to fill out incident report but Dr. Roosevelt informed witness not to worry about the report. Mr. Doyle suffered injuries during procedure to an allergic reaction, a reaction that could have easily been tteated with an antidote that the witness had to obtain during procedure.

15: 1-7 16: 6-18

Cause Cause

17: 3-17

Damages