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10 ul 13 rey 16 17 18 19 u 2 23 24 FILED 2021 MAY 24 02:54 PM KING COUNTY SUPERIOR COURT CLERK E-FILED CASE #: 21-1-03456-2 KNT SUPERIOR COURT OF WASHINGTON FOR KING COUNTY. ‘THE STATE OF WASHINGTON, ) Plaintiff, v ) No. 21-1-003456e2 KN ) SOPHIE HARTMAN, ) INFORMATION ) Defendant.) ) ) I, Daniel T. Satterberg, Prosecuting Alomey for King County in the name and by the authority of the State of Washington, do accuse SOPHIE HARTMAN of the following crime[s]: Assault Of A Child In The Second Degree, Attempted Assault of a Child in the Second Degree - Domestic Violence, committed a follows: Count 1 Assault Of A Child In The Second Degree ‘That the defendant SOPIIE ITARTMAN in King County, Washington, between May 24, 2018 and March 17, 2021 . being 18 years of age or older, did intentionally assault C.H. (DOB: 6/27/2014) , a child under the age of 13, and thereby recklessly inflict substantial bodily harm upon C.H. (DOB: 6/21/2014) Contrary te RCW 9A.36.021(1)(a) and 9A.36.130(1)(), and against the peace aud dignity of the State of Washington. And fiurther do accuse the defendant, Sophie Hartman, at said time of committing the above crime against a family or household member, a crime of domestic violence as defined under RCW 10.99.020. Count 2 Attempted Assault of a Child in the Second Degree - Domestic Violence hat the defendant SOPHIE HARTMAN in King County, Washington, hetween May 74, 2018 and March 17, 2021 . being 18 years of age or older. did intentionally assault C.H. (DOB: 6/27/2014), a child under the age of 13, and thereby recklessly inflict substantial bodily harm. upon C.IL (DOD: 6/27/2014); attempt as used in the above charge means that the defendant org, Prosecuting Attomey INFORMATION - 1 1206477 206) 205.9875 61005675, 10 ul 12 13 4 16 7 18 19 20 2 22 committed an act which was a substantial step towards the commission of the above described crime with the intent to commit that crime; Comtrary to RCW 9A.28,020 and 9.36.021(1\@) and 9.36.130(1}(@), and against the peace and dignity of the State of Washington. And further do accuse the defendant, Sophie Hartman, at said time of committing the above crime against a family or household member as defined in RCW 26.50.010(6), which is a crime of domestic violence as defined in KCW 10.99.020. DANIEL T. SATTERBERG Prosecuting Attorney eee Celia A Lee, WSBA #41700 Senior Deputy Prosecuting Attorney Daniel T. Satterberg, Prosecuting Attomey (CRIMINAL PIVISION Male Mezionl sie Center INFORMATION - 2 4-H Avenue Noh, Suite 24 Kent, WA DS052-4125| (206) 477-3757 FAX G06) 205-7475 10 ul 13 rey 16 17 18 19 u 2 23 24 CAUSE NO. 21-1-03456-2 KNT PROSECUTING ATTORNEY CASE SUMMARY AND REQUEST FOR BAIL ANDIOR CONDITIONS OF RELEASE ‘The State incorporates by reference the Certification for Determination of Probable Cause prepared by Officer Adele O'Rourke of the Renton Police Department for case number 21 1786. Pursuant to Celt 2.2(6)(2)(ii) and (ii), the State requests bail sot in the amount of ‘$100,000.00 based upon the likelihood that the defendant will commit a violent offense and the likelihood that the defendant will interfere with the administration of justice. According to the certification for determination of probable cause, tho defendant has. subjected her 6-year-old child, (H_, to medically unnecessary surgical interventions and restraints, In July of 2017, C.H. underwent surgical placement of a gastrostomy lube, a tube that provides direct aovess to the stomach to provide food, liquid, and medication when a child is unable fo eat by mouth. In December of 20018, CH. underwent surgical placement of a cecostomy tube, a tube that is surgically placed into the intestine so that liquids ean be used to flush the bowels Ihe defendant has also attempted to substantially escalate U.H.’s medicalization by requesting increasingly invasive and unnecessary medical procedures, including total parenteral nutrition (TPN), a method of feeding that bypasses the gastrointestinal tract and provides fluids directly into a vein. The defendant has also sought the surgical placement of a hormonal implant intended to suppress the early onset of puberty in G-year-old C.II. Placement of this device is invasive and requires anesthesia. Prosecuting Attorney Case ‘Summary and Request for Bail and/or Conditions of Release - 1 Dar Sanna, Poses Ate Maleng Reelonl susteeCemer f01 4 Avenue Non, Suite 2A enn WA SRD 35, 10 ul 13 rey 16 17 18 19 u 2 23 24 Since 2016 C.H. has endured more than 474 medical appointments with various medical primary care providers and spectahsts. C.H. has heen seen hy care providers throughout Western Washi iglou and specialists in North Carolin After C.H. was removed from the defendant’s exclusive care in March of this year, C.H. was admitted to Seattle Children’s Hospital for observation during a 16-day admission. During, her admission, beginning on March 17, 2021, C.H. met her calorie and hydration needs by mouth, Similarly, during this time C.H. experienced voluntary bowel movements and her cecostomy tube Was determined to be medically unnecessary. She was able to run and walk without the use of orthotics; she demonstrated no need for a wheelchair. The importance and significance of this 16-day admission, during which care providers were able to objectively observe C,H, cannot be overstated. Since her discharge on April 2, 2021, C.H. has met her hydration and caloric needs by mouth and her e+tube has not been used at al In addition to surgical interventions, the defendant has required C.H. wear leg braces orthotics, and use a Wheelchair since at least 2016. According to C.H."s medical records, at an orthopedic consultation on June 20, 2019, the defendant was told that C.II. did not need braces, orthotics or a wheelchair. Nonetheless, just four days later, the defendant continued to restr CH in leg braces and utilized a wheelchair when she met with a specialist in a different department. Moreover, fundraisers were carried out around this time and the defendant used fundraiser fimnds to purchase a wheelchair accessible vehicle ‘The defendant's behaviors already recited in this case summary and certification for dotermination of probable cause support the State’s concem for the safety and well-being of C.HL However, ather acts hy the defendant give the State farther concern for the escalation af Prosecuting Attorney Case ‘Summary and Request for Bail and/or Conditions of Release - 2 Dar Sanna, Poses Ate Maleng Reelonl susteeCemer f01 4 Avenue Non, Suite 2A enn WA SRD 35, 16 7 18 19 20 al 22 2B m4 behaviors directed at C.H. These behaviors give the State concem that the defendant will interfere with the administration of justice According to medical records, the defendant has sought palliative eare for C.H. And, as recently as the fall of 2020, the defendant represented to a paraeducator at C.H.’s elementary school that CH. conld “leave us anytime.” In addition, a gudicrally authorized search of the defendant's iPhone and iPad revealed internet searches including “songs about kids facing, sickness,” “songs for sick kids,” “best song for cancer patients,” and “funeral songs.” Ihe State requests that the court order the defendant have no contact with C.H. or any other minors unless professionally supervised. C.H. is currently placed with her maternal grandmother and maternal aunt, In addition, the State requests that this court order that the defendant comply with the conditions ordered by Judge Robertson in 21-7-00194-1 KNT (In Re Dependency of C.IL). Signed and dated by me this 24th day of May, 2021. ee Celia A. Lee, WSBA #41700 Senior Deputy Prosecuting Attorney Prosecuting Attorney Case Dani 1. Satererg,DeovingAtrey ‘Summary and Request for Bail eemacomes and/or Conditions of Release - 3 401 4th Avenue Nom, Suite 24. (206) 477-3757 FAX (206) 208-7475 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause That Adele O'Rourke 17870is a Detective with the Renton Police Department and is familiar with the investigation conducted in Renton Police Department 21-1786, There is probable cause to believe that Hartman, Sophie, 7/3/1989 committed the crime(a) of: Assault Of Child In The Second Degree (Substantial Bodily Harm) In Renton; and ‘Assauft OF A Child in The Second Degree (Patter or Practice). in Renton, and ‘Assault OFA Ghd in The Second Degree (Pattern or Practice) in Renton, and Assault OFA Child in The Second Degree (Substantial Bodlly Harm) in Renton County of King, in the State of Washington, This belief is predicated on the following facts and circumstances: CAUSE NO. 21-1786 CERTIFICATION FOR THE DETERMINATION OF PROBABLE CAUSE That A. O'Rourke is a Detective with the Renton Police Department and has reviewed the investigation conducted in Renton Police Department Case Number #27-1706; There is Probable Cause to believe that Sophie Hartman (DOB 07/03/1989) committed the crime(s) of Assault of a Child 2nd Degree. KCW YA.36.130(a) and (b) and Attempted Assault of a Child 2nd Degree. RCW 9A.36.13U(a and (b} and 9A.28.020. This beliof ic predicated on the following facts and circumstances: (On February 18, 2021, | was assigned to investigate a Department of Children Youth and Familes (DCYF) Referral, Intake 10 453644 1. The referral Was noted for the adaress of 620 S, 27th Ct, within the city lms of Renton, county of King, Washington. Based upon my own investigation | learned the following: The above intake had been crested in regards to an official latter sent to DCF by Seattle Childran's Hospital in Seattle, WA. [reviewed the fetter, which had been submited by the Safe Child and Adolescent Network (SCAN), and signed by ‘medical director Dr. Rebecca Wiester and co-signed by numerous physicians who had been handling the care of a child identified as CH. (0OB 06/27/2014). The contents of tre [eter ave pasted here with C,H. namie redacted. 2716/2021 Re CH DOR: 6/27/2014 To whom this may concer, CH isa 6 yard female followed hy Seattle Children's Hospital (SCH), Dirke Chilrren's Hospital and Health Center department of neurology, previously, by Mary Bridge Children’s Hospital and well child care with Or. Paik Consultation was requested of the Safe Child and Adolescent Network (SCAN) in early 2079 by a group of C.H.'s SCH specialists and providers at Seattle Children's Hospital because of concer regarding a pattem of parental requests for Increasingly invasive procedures based upon undocumented signs and symptoms reported by the parent. Review of the available records at Seattle Children’s Hospital, records within Care Everywhere, Mary Bridge Hospital ‘and Duke Cinidren’s Hospital. indicate that C.H. has the folowing clagnoses based upon objective fnaings: 1, Static encephalopathy. There is reported (by the adoptive parent) prenatal substance exposure and prenatal trauma. C.H/S MRI Was previously read as abnormal Consistent with prenatal insult mn utero and possible staphyioma (congenital ‘eye abnormaiity). However, C.H.'s brain MRI was normal on 10/28/2020, 2 Abnormal EEG, The record shows several EEGS done for reported spells oF seizures described by C.H.S parent. The first 2 were normal and the third showed an abnormality in the sleep phase that could indicate a “seizure risk” but no seizures were noted clinically or in the EEG. The inpatient EEG done in 10/2020 also did not show seizure-lke activity. The last EEG was done as an outpatient at homie for 24 hours in 1/2021. While no “spells” have been documented on any medica! visits or hospitalizations, the mother reported 4 spells during the home EEG. No EEG changes were recorded during the reported spells and the overall reading was similar to past readings, 3. Possible developmental delay. Evaluations of CH, have beer consistent nr the idicetion of mild gross sutor delay and recent neurapsycholagical testing at Duke decumented neurocognitive concems or deficits. The cause for this was Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 1 of 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause ‘not uetennined. During mutiple medical evaluations sire has been described as “appropriate for age, independently ‘mobile and active, and appropriately interactive. 4. Delayed gastric emptying, small intestine decreased motilty and constipation. This has been demonstrated radiologically and treated with medical and surgical mterventions. The cause of these problems is not known at this time: 5, Genetic mutations of unknown significance. intialy, one of the mutations was thought to be associated with a ‘disorder known as alternating hemiplegia of chidhood (AHC). Ithas since been found to nat be associated with AHC. 6. Behavioral concems. Ihese are varied and descnbed aitferenty by diferent evaluators in dlerent environments There are no noted independent evaluations of her bchavior when she te saparated from her mother. There was reportedly one “episode” witnessed by Dr. Brei of the Neurodevelopmental department. it was unclear to Dr. Brel it this wwas indcod a behavioral ovent. Dr. Boi had, howovor, racommendd in the past (as had the tcam at Duko) bohavioral ‘evaluation and treatment for C.H.. This has not been obtained at ths point. The following Is a lst of problems, symptoms, behaviors, and alagnoses which have not been adequately objectively documented: 1. Oysphagia or aiticulty swallowing. Because of multiple and varied reports from C.H.s mother of choking and cificuty eating, CH, had 3 swallow studies. On 7/2016 it wes ret -On 10/2016 it demonstrated mild difcuity with thin fluids but na fluid aspiration into airway. At that time, cantinutian of ronal feeding by anvutl was recormivended afory wis tre use: of ticketed Muth --On 12/2016 the study was again normal Insertion of a G-tube was not recommended although C.H.'s mother continued to discuss this with many providers (at SCH and UW primary care) C.H’s mother then changed C.H.'s care to Mary Bridge Hospital. There, C.H.'s mother reported in 3/2017: ~ "failed" swallow study (in spite of normal study on 12/2076). - chronic vomiting (never documented or noted in any visit, - multiple ED visits needing intravenous fluids for dehydration (very few documented ED visits and all visits note well- hydrated, non-vomniting, well-appearing child and fluids given once on advice from GI team not seeing C.H. who was by lab resufts and clinical exam not dehydrated.) ~ that G-lube was needed because U.H. had vomiting ana decreased drinking with her “spells" and the mother wanted the G tube tobe abie 10 give Nuids. C.Hs mother reported to the Mary Bridge GI doctor that the SCH GI doctor had said C.H. ‘may need to go on TPN (total parenteral nutntion, nutrition through a central line into her vein)’ which was untrue. C.H/s mother’s continued reporting of spelis, discomfort and seizures to other providers outside of Seattle Children's ‘Hospital resulted in the replacement of the G-tube with a G-J tube (more invasive) elsewhere which had been recommended against at SCH. The spells as C.H.'s mother describes and records them, have never beer: documented,” 2 Clinical diagnosis af alternating hemiplegia of childhaod (AC). CAL fay beet foltoneed arn weed by ant expert iv this usecase at Duke Chiherr> Hospital ail Healt: Certer, Thee Cinieal diagnosis is hased upon the reports given only by C H's mather of mufiple, numerous and varied “spells” of alysis, pain, abnormal movements, altered mental status, inabiliy to talk, staring, developmental regression and Fafeaiorl symptoms These spall have heen reporter in Ings kept hy © Hs ranfer and recorded invdens occasion. The logs mote multiple and prolonged spells in each day. itis net clear from the documentation what the video-recorded episodes represent to any professionals who have viewed the videos. Some of the spells noted by C.il’3 mother have reportedly included not breathing for 90 seconds, hours and days of paralysis and dystonia, days of ‘minimal fluid intake and decreased urine output. However. C.H. was not brought for medical care emergently despite recommendations from medical professionals. CH. has been seen multiple umes in primary and specialty care in at least 4 medical systems and has been hospitalized for observation ‘and management several tmes in addition to being nosp\taized tor procedures and surgeries. “There is one documented episode of “unusual behavior’ By witnessed by C.H.’s mother and Dr. Brel Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 2 0f 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause during hospitalization in 10/2079. (Per Dr. Brei’s note: I reviewed with mother that the episode | observed in the hospital certainly was unuswal and atypical for what | have seen from C.H. previously. | did not note any clear-cut indicators of antecedent causes to these ‘behaviors. She was at that fime disruptive and could he aggressive. The occurrence of the behavior | observed in the ‘hospital and which mother describes as similar to what she observes at home, though at home it can be more severe, (3 dificult to ascertain, Whule there ts 2 behavioral component to these, itis not clear what is driven by behavior versus neurologic versus psychiatric contribution, While there was a period of time where she seemed less responsive and “vague,” as the episode progressed. she continued to have disruptive behaviors. but there was a Sense / had that she was more aware and more purposeful in her bohaviors late in the episode | obscrvcd.") Aside from this one poorly defined episode, ne athor events or spells as consistently described by C.H.'s mother as being frequent and protonged or naving various characteristics of dystonia, paralysis, apnea, pain or screamung have been documented. The following Is alist of problems, symptoms, behaviors and diagnoses for which there has been an evaluation and documented findings for the positive or negative: 1. Precocious puberty (early pubertal development) This has been fully evaluated over time by pediatric endocrinology at Seattle Children's Hospital and she is found to not have findings consistent wilh precocious puberty. Reconmerctation was for follow up arid enoritoring ly. Tire following ise fst uf prubletis, synplon, Delraviors aid diaytuses for wich there i> nu docunented ubjective evidence 1. Excessive vomiting or dehydration 2 Ohrone cartes 97 3. Hematemesis (vomiting blood) 4 Seizures 5. Prolonged paralysis (92 days straight) 6. Prolonged apnea (not breathing) (90 seconds) 7. Low blood oxygenation 8, Prolonged lack of urine output (30-40 hours} 9. Speech or language pathology 1. Recurrent ankie sprains 11. Need for any orthotics, wheelchairs, gait trainers, leg braces 12, Terminal ness The SCAN team was first consulted in early 2079 regarding concerns related to the chronic pattem of parental requests for madical interventions that seemed to be escalating and based upon undocumented signs and symptoms. The concern, however, was also rooted in the fact that the requested interventions were not onty inappropriate, but dangerous for C.H, and the insinuation of C.H.’s mother by making these requests was that C.H. was terminal. One request was based upur the mother’s report tal regular ubitionall care for C.H, caused su tiany spells that, for fier ‘quality of life! she should have a central line placed into her chest and be fed only total parenteral nutrition. This was for child whe van easily eat must of fret (oud by mouth ard has always beer uesciibed ay active asd able, Antler concerning development was C.H's mother contacting the palliative care team for a child who does not have a documented terminal ilness nar documented debiltating chronic disease. ‘Another area of concer is regarding imposed equipment restricting C.H.' activities and development. At some point, C.H’s mother obtained bilateral orthotics for her legs and a wheelchair. Its unclear who, if anyone, recommended these or why. There were also requests for a type of stroller with restraints and, | believe, a gait trainer. Dazed upon C.H’s mother’s report that she will sprain her ankles, that she has chronic and prolonged paralysis, some of this ‘equipment was approved. C.H. is and has been always described by every professional objective observer as an active cchid who can waik. run. get up off the tloor, cimb onto the table and pertorm normal childhood actwities. C.H.5 “orthopedic consuitation at SCH in 6/20/2019 (she arrived in a wheelchair) demonstrated that she had a normal ‘examinabon and U:H.’s mother Was fold tat she needed absolutely no braces/ormoucs/wheelchars/etc, U.H.'S mother was also told that what C.H, actually needed was normal activity and play to be able to develop appropriate muscle swrength and physical development. C.H, was Seen in SCH neurojogy on 6/24/2019 and she came with leg braces and Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 3 0f 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause Jina wheelchair. This is highly conceming, aot only for evelopment imitation, but also for creating illness behavior and creating the image, and, most worrsama, the identity of disabilty. There is alsa concern for limitation of C-H.'s appropriate developmental activities and education. C.H.'s mather has described not being able to trust anyone with C.l1's special care, Consequently, C.ll. does not go to school and, 1 worry, spends a significant amount of tine in ines care. ! fear that this pattern of experience and limitation can contribute to developmental delays and cognitive impairment and impact her long-term developmental potential This situation is a case of medical child abuse. Medical child abuse is described az "A child receiving unnecessary and ‘harmful or potentially harmful medical care at the instigation of a caretaker." Its not necessary to know the possible ‘motivation of a caregiver, only the outcome of the behavior. It is my concern that this pattom has resulted in unnecessary medical testing, medication, procedures, surgeries and deowity of tus child. The risk to CM. from this, situation is profound, ‘Medical procedures and treatments can always dangerous and in soma cases even simple procedures can be lethal. A child raised in environment where illness or ilness betravior is reinforced and where there are no opposing rewards for boreal cluld betravior acid yrowt, will be al very high risk of pour outcome anid inpaived independence and competence as an adult Neglect is also a part of this situation. The neglect described hy C.H.'s mather in reporting dire symptoms and situations and not bringing her for care and avoiding medical recommendations for things such as Behavioral treatment or ‘eliminating orthotics and wheelchairs. There have heen 7 muttidisciplinary team meetings since 2019 regarding this situation. There has been collaboration between medical centers to try to improve communication and care management so that misunderstandings or ‘incomplete information do noé result in inappropriate or unnecessary care. \Whule the risk to C.H. has decreased with improved medical team collaboration. the chronically unreliable reports trom C.H.'s mother have not changed, nor have the requosts for unnecessary or inappropriate caro. In addition, as C.H.'s care gets Jess tragmented, more cohesive and based upon objective hriaings (and not her mother’s reports), the more unhappy C.H.'s mother is becoming. This will very likely result in sabotage of care plans and a change of caregivers and ‘once gain create an opportunity for fragmented care and medical risk for C.H. This report has been wniten with collaboration and endorsement of the following medical providers involved in C.H.'s Or. Lusine Ambartsumyan Dr. Timothy Brei Nancy Chase, RN Dr. Mark Waimsright | recommend the following: 1. Immediate cessation of fragmented care by changing providers and care directed by mother. 2 Arhysiean gatekenner ito puerenes every anf medical spjntmants-ae introns 3. Involvement in schoo! or other activities nihere she can be observed and allowed to develop. 4 Whether C.H. needs to be removed from her environment for understanding of what symptoms she does or does nat have should be explored. 5, Feading advancement and removal of G-tube. 6. Appropriate medical management and follow up as described by the Seattle Children’s Hospital team caring for C.H. ‘ins Would include this team’s coordination with the Duke team as they feel maicated with arect communication and without C.H.'s parent as intermediary. Sincerely, Rebecca T. Wiester MD Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 4 of 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause Professor of Pediatrics, University of Washington ‘Medical Director Seattle Children's Hospital Safe Child and Adolescent Network Rehecea wiester@seanechildrens.org Medical Director Harborview Assault and Trauma Center rmester@u.washington.edu Ine aforementioned “parent” in this case has been identitied as Sophie Hartman (DUB U/U3/198Y). | contrmed that Hartman is the primary caretaker for C.H., and the adoptive mother of C.H. and older sibling M.H (DOB 06/26/2009). CH. has been in Hartman's care since infancy. Based on my research, outside of preschool and schoo! teachers, Hartman is the sole carogiver, and has been the sole carogiver and parent since taking custody of C.H. as an infant, As 4 part of this invesugation { requested medical records for C.M. trom Duke Chifaren's Hospital, Seattie Chuaren’s Hospital, Mary Bridge Children's Hospital, Komerstone Kids, and PeaceHealth; Dr. Pavlik is employed through PeaceHealth, | also requested meaical records from the University of Washington Center for Adoption Medicine, | have reviewed C.H.'s medical records from these medical providers and | noted that since C.H.'s placement into Hartman's custody, C.H.'s visits to different medical faciities have been prolific. This begins with C.H.’s visit to the University of Washington Center for Adoption Medicine in September, 2015. University of Washington Center far Adoptian Medicine Duriny hes evaluation at the Cenites on Adoption Meivioe unt Seplennber 16, 2015, Har tran provided pliyoiviarts will the medical history that she had for CH She noted that CH. had in utero drug exposure. Hartman reported that “the ‘orphanage workers said they meren’t sure ff C.H. would make it through the withdrawals, as they had no resources to help her Hartman advised that C.H. was then brought to the United States on June 22. 2015. Hartman reported that C.H. was slow to meet her milestones and had not begun crawling until 12 months old. She reported that one side of CH’ face was lower than the other. and her muscle contral/ motor processing seemed abnormal. Hartman also reported awkward movements of C's limbs and a dent in her forehead which had not seemed to go away, ‘Aiter numerous lab tests, Dr. Julian Kent Davies reported that all of C.H.’s labs were returning as normal, other than “Giardia”. Hartman was advised to give C.H. the prescribed medicine for this. A follow-up appointment for C.H4.'s 15 ‘month old "Well Child” visit was conducted on November Z.2U75. where the assessment made was that CH. was growing wel, and developing healthy relationships. Based on the history provided by Hartman, a referral was made to ‘Kinaering’ and Seatte Charen’ Hospital tor Hartman's concern of developmental delays and possible “asymmetry”. it was specifically noted that at this visit C.H. had normal muscle tone, and her extremities moved equally. Hartman Teported that C.H. 1s “frustrated” by what she cant do but Is able to get to stand. By her next vist on January 4, 2016, the clinical medical assessment for C.H. Was that she was growing wel. It was noted that the previously indicated neurodevelopment issues were making nice progress, and noted that an abnormal MRI had been indicated. ft was bolieved that this abnormal MRI was from C.H.'s in utero drug/alcohol exposure. By C.H.'s next visit on Apri 4, 2076, it Was noted that the MIR! conducted on C.H. had noted “static encephalopathy’, which is usuaily caused by prenatal ‘exposure, Based on further information provided by Hartman, it was believed that C.H. may have “subtle left cerebral palsy" as stre repurted CH. favored ret right side, Hartnnan also repurted CH, fraviny possible “absence seizures lasting 5.10 seconds, up to 30." On May 9, 2016, Hartman called far Dr. Julan Kent Davies requesting 2 prescription for bilateral custom oF norrcustont foot urtits. She advised tat this had bees equested by “Rivnlesing” aid tat slre needed a leer ta reiterate a diagnosis of cerebral palsy to abtain the prescription. The infamation provide by Harman regarding symptoms she wes seeing i CH. at home seenred to escalate inthe summer of 2276, including constant vonnting fmm CH, manth lang medial episodes of absences seizures, 112s chening and snatiowing foods, and choking. Hartman reported that she even had to de the Heimlich maneuver on CH, 5.6 times within a month period. On a follow-up visit on July 12. 2016. Hartman specifically requested that she would like a swallow evaluation and possible Gi referral for C.i1. Despite the reported symptoms, the physical exams for C.ll stated she was alert. with no acute distress. and well-hydrated. Ail other aspacts of her physical exams were also normal. By 18 months of age. Hartman continued seeking medical attention tor C.H. advising that she did not seem to be developing normally. Hartman reported that CH. suffored from numerous issues, including cerebral palsy and seizures, Records for U.H. show that Hartman verbally proviaed C.H.’s history to medical professionals, inaicaing cerebral palsy and seizure disorder. Based on medical records recelved to date, itis not clear if CH. has been disgnosed by 2 medical professional with a selzure disorder. Further, after recelving Dr. Wiester’s lerer I consulted wan her and she advised Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page § of 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause that FC. cerebral pal, would be ofan extremely ny form, This confined fa the Center for Adoption ‘Medicine records stating C.H. had ‘subtle left cerebral palsy". Moreover, in records Hartman has reported neurological, visual, and endocrine symptoms in CH. which have not been objectively documented by medical providers in the Duke Children’s Hospital, Seattle Children’s Hospital. Mary Bridge Children’s Hospital. PeaceHealth, and the Liniversity of Washington Center for Adoption Medicine. According to the SCI/ records, C.ll. had an "abnormal CEG" after previously ‘raving two normal ones, on December 13/14, 2076. No push-button events, clinical, or electrographic serzures were on the record, but there was a note of fecal epileptiform discharges while C.H. was sleeping. However, none of the significant events described by Hartman were recorded. It was stated “he events in question were not captured auning this recording. Clinical correlation is recommended.” In an inpatient evaluation note written on December 15, 2076 for C.H’s medical history, it fs noted: "approximately 8 month history of abnormal spelts with two normal spot EEGs this yoar that prosents to the hospital {or evaluation and management of vomiting for whom we were consulted for continuous EEG In order to evaluate these episodes. The episodes seem to come in two main types. The first type described involves bilateral odd arm ‘movements that with [C.H.] responsive: op affferental for these is dystonia vs stereotypy. [C.H.'s] mom has been advised regarding these movements and given some Information on what stereotypy 1S and the fact that it isnot dangerous or Concerning. The Second type which involves staring spells are more difficult to distinguish from seizures, and in fact can be consistent with seizures, Videu CEEG demonstrated sare midine discharges during sleep last might this is not 3 totally rival EEG and ‘can be consistent with seizures or can be benign. We cannot rule out orin seizure until we capture an event an EEG: Iromever, [CH] is nevivelly stable artd seicuies Ue wut seer lo be: inipaitiny function or teeing yet iter verti. This indicates that though there were some abnormalities in C.H.'s third EEG, it could be consistent with seizures or could be benign. Further. no larger events were recorded and therefore based on the history provided by Hartman, the Clinical correlation of a “seizure disorder" was recommended. No EEG's conducted on C.H. since this time have shown any seizure-lke activity. Further. during a home EEG in January of 021, Hartman reported that C.H. had four spells during the test. However, no CLG changes were recorded during the reported spells and the overall reading wa similar to past EEG readings. According to C.H.’s medical records, examinations continued for CH. extensively at Seattle Children's Hospital throughout 2076. ‘Seattle Uiilaren’'s Hospital are On July 8, 2016, C.H. was admitted to the emergency room for vomiting after Hartman reported that C.H. had thrown up “15-20 times today”. Hartman advised medtca/ providers that C.H. would vomit anytime she bent over or changed positions, noting additional coughing and choking over the past three weeks. Hartman reported that she had used the Heimlich maneuver on C.H. approximately 5-6 times over this time span. According to C.H.'s medical records, medical providers performed an assessment, and the assessment stated that C:H. is ‘normal playful self and has not experienced nausea/recent URI or gastro symptoms.” The records reveal tat C.H, was determined to have no instances of vomiting from her arrival at approximately 1707 hours, to her discharge at approximately 2201 hours, Accundiny tu records form the visit, CH, was givert oral refiydration during fer tine inthe ermergenncy department, anil her urine analysis was negative. | checked via relevant emergency dispatch organizations and found that Hartman did rot call for ant anribulanice Ua tis tive, ened 2 917 calls mere ale un lela! of CH, despite te reported rine! distress she had been facing On July 28, 2016, C.H. received her initial Gastroenterology (Gi) Clinic assessment. According to medical records, Hariman reported that CH had heen strggling with ‘chronic vomiting, dysphagia and refx After this initial vista plan was created for an "Upper Gi" evaluation, and to consult with Occupational Therapy and Physical Therapy. Also ordered were a feeding evaluation and Videofluroscopic Swallow Study (swallow study) ‘According to medical records, on August 4, 2076, C.ll. underwent Clinical Swallowing Lvaluation (CSC) where her {feeding and swallowing skills were observed to be in normal limits, though Hartman advised that this was not typical for CH. After the CSE Hartman began communicating with Dr. Lauren Elizabeth White via email in regard to C.H.'s CSE. In an emai! Ur. Whnte wrote to Hartman and indicated that C.H.’s upper GI results had come in and everything looked ‘normal. Hartman wrote the following in a reply cmail: “After the feeding eval, | was quite discouraged though to be honest. UI course itis great that U.H. shonted how well she VAN do, the problem 15 that even this aftemoon she was doing se poorly eating (shoving food in, not chewing, gagging and choked on a raisin) and our speech therapist saw a completely afferent °C.H.” than even the therapist at children aid today. Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 6 of 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause Qu August 8, 2016 G4. mas once again acted to Seats Chikirn's Emergency Daparent ate Haren reported CH fiad been vomiting. History for CH. was provided by Hartman. According to medical records, Hartman aduised that C.H. had vomited muttiple times, indicating that at this time there was blood in the vomit. Hartman reported that C.H, vomited after eating and about half of the volume of the vomit was bright red hiaad. The day hefore this emergency department visit, Hartman was in email communication with Dr. White, stating the following: °C.11. was throwing up bright red blood tonight. She hadn't eaten for about 4 hours, so it was surprising to me that she was even throwing Lup...She's had looser stoo! the last few days as wel, but then a very large amount of explosive diarrhea yesterday that shot out the back of ner araper. 1 wasitt going to message you but tonight was talking to my trend who is a PA ana she Was just asking about my might and I told her.” Dr. White aoked in a follow-up cmall how much blood C.H. had in her vomit. Hartman wrote back “last night was more blood- more than a teaspoon even- not specks or streaks." ! confirmed that during this time in August 2016 no 917 calls were made on C.H.'s behalf for immediate care via Medic One or amburanece. The records of examination of C.H. on August 8, 2076, note that C.H. is well developed, well nourished, and in no apparent distress. The records note that the patient listed as well appearing with Denign abdominal exam and stable hemoglobin from prior labs, and with no GI bleed. The records do not reveal any vomiting by C.H. in the emergency department. On October 27, 2076, C.H. received a Videofluroscopic Swallow Study (VFSS) where, according to the medical records, the findings were as follows: “mild pha yoyeal dysphagia with interiittert deep penetiation rioted without observed aspiration recommending nectar thick liquids forms straw cup only." According to medical recards, Hartman nated at 3 eater Gia Urat contery (0 Ure tinting of tre VESS tres inpneasivn frons the study mery tret C.H.'s Uyephssiee wey quite severe/signficant. However, it was specifically noted in the report the evaluation shawed C H's issues to be mild. At this time, Hartman said that C.H. had a history of choking with solids including a period duning the summer when she had to give C.H. the "Heimiich’ ten times in one week. However. no 911 emergency calls were made during this time. or ever. In an in-patient evaluation of C.H. on December 13, 2016, it was stated ‘Mom does report that her current SLP had given her the impression that C.H. would be a candidate for a G-tube due to her refusal of liquids.” ‘An additional clinical svraliowing evaluation (CSL) was then conducted on December 14, 2076. According to medical records for C.H. it was discussed that C.H. had excellent clinical tolerance and acceptance of solids and liquids, These records noted there were no clinical signs or symptoms of aspiration. Nonetheless, according to medical records, Hartman continued to reiterate to providers that “She teels as it C.H.’s swallowing abies are extremely vanable and that she is able to ‘perform’ during evaluations but has instances of severe dysphasia at home". I have spoken with Dr. Viiester on tne methodology of USES, accoraing to Ner due to the nature of these assessments in chularen it's extremely unlikely that a child would have different swellowing abilties outside of the assessment setting ‘Mary Bridge Children’s Hospital Care and Related ER Visits Hariman changed C.H.'s care to Mary Bridge Children’s Hospital in early 2077, despite the approximate 136 mile distance from their home in Lynden, WA at this time, On March 13, 2077 CH. had a “Gastric Emptying Study with Reflux’ conducted. The findings were that C.H. was experiencing slow gastric emptying. On March 25, 2017, C.H. was brought io the emergency department at St, Joseph's Medical Cemer in Bellingham, WA according to documentation provided by PeaceHeath, Hartman verbally provided C.H.'s medical history during the admission and slated that C.F. was experiencing disses, reausea, vorniting ark! abdominal pain since the day before. Further, Hartman reported that C.H. had net been consuming liquids and had been recently diagnosed with yastuparesis and cyutical vomit. These were butl ctivical Uisynuses, reaniay thal bared rt the: destriptionts uf wast Was going an at home, it was thought that C.H was dealing with these issures. According to Dr. Wiester, a clinical diagnosis is commonly made after historical information provided by parents with regard to their children. In the notes fromm this. visit, ts indicated that C-H lid nat appear tn he significantly clinically dehydrated and that she had a normal heartrate. This was despite Hartman's statements that C.H. had not unnated in 30 hours and had a decreased appetitelfuid intake. According to medical records for this visit all of C.H.'s chemistry returned as normal. Furthermore, like in previous emergency department visits already listed in this certification for determination of probable cause, accarding to medical record for ths visit medical providers observed no vomiting events by C.F. dunng this vist. On June 6, 2017, C.H was taken to St. Joseph's Medical Center in Bellingham, WA according to documentation provided by Peacehealth. Ihe isted reason for the visit was “dehydrator. indicating all medical history provided by Hartman. Hartman advised that C.H. was presenting with explosive diarrhea, decreased urine output, nausea, vomiting, and a sore throat. Hartman also advised that U.H. 15 waiting to be seen by a gastroenterologist at Wary Bndge Children’s Hospital to have a G tube put m place. According to the medical records for this visit. C.H., was found to have a low-grade temperature and the clinician believed that she IS “dry and has lost some weight”. The clinician noted that Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 7 of 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause CH. dit not need admittance as she had eaten a popsicle and is i good spits, acting nonaly On uly 6, 2017 C.H. was seen at Mary Bridge by Dr. Michael K. Pickens. Within his notes he stated the following: “xtom feels strongly that she need an access point to get her fluids for AHC. Mom also fs rot sure if she will tolerate ‘halls or fluids in these episodes of vomiting and presumed dehydration. Mom feels that during episodes of AHC. she is gagging and not feeling well and not able to eat. Moin feels that having an access point mill help during AIC episodes and would like her to be on a continuous feed overnight to maintain her hydration and support her fltd goals and nutritional outcomes.” This information was provided by Hartman, though during objective observation, C.H. was never seen to have any issues with eating. dnnking. vomiting. or dehyoration. However. Based on this information and discussion of feeding goals with Hartman, it was decided that a C-Tube would be placed in C.H. for “overnight fuidsiteeds to maintain a consistent hydration goal and expectation.” On July 70 13, 2077, C.H. was admitted to MultiCaro, Mary Bridge Tacoma for a G Tubo placement. Within notes lniten by Or. Cody J. Philips on July 10, 2017, #5 noted that Harman advised it had been mentioned auring one of C.H’ prior admissions at Seattle Children’s Hospital that a G-Tube might be helpful. This assertion by Hartman is not supported by the recommendations found within the Seattle Children’s Hospital medical records. ‘According to information provided by the Children’s Hospital of Philadelohia via the internet, the following is 2 basic understanding for how a G-Tube (Gasirostomy Tube) is placed; “Ayasuustumy tube, often called 3 G-lube, isa suryically placed device used to yive direct access to your child's stomach for supplemental feeding, hydration or medication. G-tubes are used fer a vanety of medical conditions, but the smnust common use is for feedings tu eihance your Clifu’s tutitivit, Wen a clad iy urbe (u eat esrwuylt foud by iiautl, a G-tube helps deliver enough calories and nittrients to support their growth." On July 70, 2017. C.H. had a G-tube surgically inserted into her body by a surgeon at Mary Bridge Children’s Hospital According to the procedure transcript. C.H. was placed under general endotracheal anesthesia, The surgeons began by ‘making an upper abdominal incision, using a #15 blade scalpel. "which continued down through skin and subcutaneous tissues using Dovie electrocautery until the fascia was entered. The fascia was carefully entered, Keeping the underlying peritoneum intact, which was then opened sharply using Metzenbaum scissors.” Affer the surgery was completed, C.H. Was transferred to the PACU where her pain was managed by medications ‘Subsequent to surgical insertion of the G- (ube, C.H. had a "Gastrostomy-Jejunastomy tube” or GJ tube inserted as wel. (On March 1/, 2021, C.H. was placed into protective custody by the Vepartment of Unniaren, Youth and Families (OCYF). After C.H. was placed into protective custody by DCYF, she was admitted to Seattle Children’s Hospital for ‘observation of objective mealca/ needs. Seattle Children’s Hospital Dr. Lusine Ambartsumyan acted as one Of C:H.'S ‘medical providers. Dr. Ambertcumyan noted the following in a statement: “At our last clinic visit 1/5/2021, mother reported that a GJ tube was placed at Duke in March for 2020 as a tial because of maternal history that CH was having abdominal pain with oral and gastrostomy feeds that were triggering her paralyuic episodes, (tis critical to note that when C.H. was most recently hospitalized, she tolerated ful oral feeds and ‘met ail of her caloric and hydration needs by mouth. She did not require GJ tube feeds and her GJ tube was converted to G tube on 3/22/2021 with plan of yastostomy closure on an culpatient basis. The hospital course aid fer inet ability to tolerate all feeds via oral route without any evidence of paralytic episodes indicates that the gastro.jejunastamy tube: arid the yerstrusturnry tube mee ut rneically ee baly." Duke University Medical Center Care Rased on the hisinnical information povided hy Hartman in ragarrs ta © Hand the different medical cancers she stated C.H, was facing, C.H, was given a clinical diagnosis of Alternating Hemiplegia of Childhood (AH) by Mary Bridge Children's Hospital on June 30, 2017. Genetic testing had been conducted on C.H. with a finding of @ mutation ‘on the "ATPAT gene”. On July 17, 2017 a letter was crafted by Mary Bridge Children's 1 lospital referring C11, to Duke University Medical Center. to see Dr. Mohamad Mikat at the Duke Insttute for Brain Sciences. In the referral letter. itis stated that C.H.’s clinical presentation is compatible with AH, and the gene mutation found would support the diagnostic impression ot AHC (On March 79, 2018 C.H. began her first consultation with Duke University in regards to her elnical AH diagnosis. according Ur. Mohamad A. Makan, the Chiet, Livision of Hearatnc Neurology ana Uevelopmental Meaicine, Urector of Pediatric Eplepsy Program, at Duke University Medical Center, the AHC diagnosis for C..H. was clinical diagnosis. Dr. ‘Makat states ‘Normally we rely on the reports of the care givers to determine Ifthe above episodes are occuring.” Dr. Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 8 of 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause Makati advised that C.H. does not have the genetic mutation that specifically indicates for AHC. The clinical diaginosis is ‘based upon the reports given only by C.H.'s mother. It should be noted that a variant in C.H's “ATPAI3" had been found but been classified as ‘ikely benign’. This was confirmed around September 2079, Dr. Makati informed, “in about 80% of patients the diagnosis is alsa confirmed hy the presence af a mutation in the gene called ATPIA3. in the ather 70% ‘one has to rely on the presence of the combination of symptoms. This would indicate that C.il's entire diagnosis has ‘been based on information provided by Hartman, with nothing obyectively viewed by medical professionals. In @ separate phone cal with Dr. Makat, he confirmed that the best hospital to evaluate C.H, and to understand what Was going on with her was Seattle Children’s Hospital. Ur. Makati stated that he has only seen CH. on three Separate ‘oceasions, whereas Seattle Children's Hospital secs her regularly. Dr. Makati said he would have no issues deferring to the findings of Seattle Children’s Hospital with regards to the clinical diagnosis of AHC in C.H., as again, everything for this diagnesis was based upon reports provided by Hartman. AAS part of her time at the AH Ciinic at Duke University Medical Genter, on March 19, 2018, C:H. Was also seen by providers for a feeding and swallowing evaluation. According to medical records, it was indicated that during this ‘evaluation that C.H. was engaged in al of her feeding activities and was taking food at a normal rate. The medical records indicate Hartman commented that C.H. was taking smaller bites and eating more slowly compared to how she eats at home. According to the medical records, an assessment of C.H, was conducted. According to the assessment it is noted that there were no signs of aspiration observed with C.H.'s sips of thin liquid: however, based on history provided by Hartinan, there was stil concer for CH.'s “feeding difficulties” 1 wets slated by Dr. Jamie Thowas thet sie was pleased with C.H.'s overall nutntian, Please note that Duke University Health is located in the state of North Cacti In addition to the placement of the G-tube and AHC clinical diagnosis, C.H has been subjected to other unwarranted interventions, including the use of orthotics or orthoses. Moreover, based on Hartman's assertions concerning ‘symptoms observed in C.H. she has been prescnbed potentially harmful medicines and Hartman is seeking further invasive medical treatment. Orthotics Orthoses, generally, are externally applied devices used to modify the structural and functional characteristics of the neuromuscular and skeletal system. On May 16, 2016, Hartman was advised by Kindenng that C.H. would benefit rom “non custom JumpStart Bunny with tim co-poly shell and wrap around elastic’. However. since this ume. medical records for C-H. show that she has repeatedly becn scon by medical providers wearing anide braces, orthotics, gait tramers, and leg braces. Ine provider annotation of CH. Wwearng orthotics of some kina began prior to U.F.'s cinical diagnosis of AHC, which, according to Dr. Wiester's fetter, has not been adequately objectively documented itself, CH. thas also been seen by providers in a wheelchair. The only indication for a prescription of orthotics was noted in the records by Kindering and the University of Washington Center for Adoption Medicine, whore, on May 9, 2076, Hartman called Dr. Julian Kent Davies requesting a prescription for bilateral custom or non-custom foot orthotics. She advised that this had been requested by Kindering and that she needed a letter to retterate a diagnosis of cerebral palsy to ‘obtain the prescription. t should be noted that tis was in the very early stages of C.H.'s care. Acconiny tu the Seattle Children's SCAN tearm, the above equipment, which restricts C.H.'s activilies could be ‘detrimental to her overall development. CH. has been described by professional objective observers (both medical providers aid teacliers) as beiny att active child ww can walk, rari, yet up off Ue lovr, cl ony the lable, asi perform normal childhood activities. Moreover, videos of C.H_ posted an YouTube show that she is able ta. ambuate and even ride a horse without mare assistance than a handler leading the horse. According ta medical records, CH had an arthonedic cansitttatian at Seattie Chilrren’s Hospital an huine 20.2019 whereupon she arrived ina wheelchair. During her examination, Hartman was told that C.H. needed absolutely a braces/orthotics/wheelchairs/etc. According to the records, after the examination. Hartman was told that C.H. actually needed normal activity and play in order to develop appropriate muscle strength and physical development, use of ‘mobilty limiting devices. ike orthotics and wheelchairs, can delay development in children making them dependent on care providers. ‘Aithough Hartman was advised just tour days earlier that CH. needed no braces or orthotics or wheelchairs and that restraining C.H. was detrimental to her development, nonetheless, on June 24, 2079, Hartman brought C.H. in with log races on and in a wneetcharr. ine SUAN team noted that this was highly concerning, not only for developmental imitation, but for creating the image, ‘and, most worrisome, the identity of disabilty. Further, | conducted interviews with C.H.’s primary physical therapist Dr. Bryce Blaser at Komerstone Kids Therapy, woe Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 9 of 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause treated CH, for approximately 3.5 years. While speaking with Dr. Blase7, | advised hii that during a consultation at Seattle Children’s Hospital orthopédics in June 2079, Hartman was told that C.H. needed “absolutely no braces/orthotics/wheelchairs/etc." Hartman was also told at that appointment that C.H. needed normal activity and to play to he able to develop appropriate muscle strength and physical development. lIpon informing Dr. Blaser of this, 1 asked ifhe had been made aware of this recommendation trom Seattle Children’s lospital. Dr. Blaser stated he had not been made aware of this recommendation by Hartman and he was stil treating C.H. during this time in question. Dr. Blaser contrmed that C.H. was stil utiizing orthotics and equipment during the time after the Seattle Children’s Hospital consultation in June of 2079. While Ur. Blaser and | were stil on the phone | thought of an additional question to ask him in regards to part of the letter written by Seattle Children's Hospital (SCH) SCAN team in regards to C.H.'s case. This part of the letter reads as the following: Hs orthopeaic consultation at SCH in 6/20/2019 (She arrived in a wheelchair} demonstrated that she had a normal examination and CH's mother was told that she needed absolutely no braces/orthotics/wheelchairsietc. CH’s mother was also told that what CH actually needed was normal activity and play to be able to develop appropriate muscle strength and physical development. | asked Dr. Blaser if he was willing to be recorded and he said he was in regard to this follow-up statement. Dr, Blaser stated "Yeah, ur I said I dont ever rerernber Sophie [Haitrnan] ever teling re Ural she was advised to take or tu have the orthotics removed for C.H." ar “| didn't see her ail the time so during this time she may have reparted it ta assistant cur but tu ane directly sre reeves state Ut fet ane: Astow What sire was (u reruove Ure untrue." D1. Blaser sel tat if he had been made aware of SCH's orthopedist recommendation, fre would have called the doctor ta follow-p and "talk 0 them directly and ust get another input before { made my decision. / would want to talk to the doctor directly to see their ‘understanding and point of view and go from there." | asked Dr. Blaser if t was concerning to him that he was not made aware of this suggestion from the orthopedist at Seattle Children’s Hospital. He responded to me by saying, ‘Veah, as being her physical therapist. | would be a litle concemed that | didn’t hear that information." | asked Dr. Blaser if he would expect a parent to provide hint nith that information based on the welfare of their child. Ile said, "Yes, yup. That's something I would expect the parent to inform physical therapist of Medication According to the Duke Health, Scattle Childron’s Hospital, Mary Bridge Ohildren’s Hospital and PeaccHealth records, Harman has reported seeing U.H. experiencing seizure like symptoms. Accoraing to Ur. Mark Wamnwngnt, SCAN team physician, children expertencing seizures are prescribed benzodiazepine as a rescue medication. Although no medical provider has documented observing seizure symptoms in C.H. in Duke Health, Seattle Children’s Hospital, Mary Bridge Children’s Hospital or PeaceHealth records. nor have seizures been observed by C.H.'s preschool or kindergarten ‘educators or paraeducators- C.H. has nonetheless been prescribed benzodiazepine based on Hartman's reports. The short-term effects of the medication can be drowsiness and lethargy. Long-term effects of prolonged exposure to benzodiazepine in chiloren is uncertain, but could include memory oss, confusion and dificulty thinking clearly, lethargy and lack of motivation, fatigue, headaches, drowsiness and sleepiness, difficulty sleeping and nausea. Contral Line Dunit ar apprvvaiendt or Agni! 9, 2019 Hest Uiscusseed teat ole fe it woul be fi C.H.'s best interest ty ae a “central line” so that refydration therapy could occur more easily Hartman told providers that she was interested in the possiblity of bypassing C.H.'s gut for her nutntion, and embarking on a program of Total Parenteral Nutrition (TPN) According ta the Mayn Clinic, ‘Parenteral nutrition, nen called total parenteral nutrition, is the medical term for infising {specialized form of food through a vein (intravenously). The goal of the treatment is to correct or prevent malnutrition. People whose digestive systems either can’ absorb or can't tolerate adequate food eaten by mouth use parenteral nutrition. When used outside the hospital, intravenous feeding is called home parenteral nutrition. Using home parenteral nutntion may be necessary for weeks or months, or in some cases for Ife." Further. the placement of a TPN catheter placement procedure is usually done after you've received heavy sedation or anesthesia. The catheter will be Inserted into a large vein leading to the heart. Parenteral nuthtion through this large vein can deliver nutrients quickly ‘and lower the risk of eatheter infection. According to Stanford Health Care, possible complications of this procedure can Include Veryaration and electrolyte imbalances, 1frombosis (100d clots), Hyperglycemia (hgh biooa sugars), Hypoglycemia (low blood sugars), infection, Liver Failure, and Micronutrient deficiencies (vitamin and minerats). na discharge summary from Apri 13, 2019, the following is indicted in reaards to TPN: Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 100f 21 eLODI PROSECUTING ATTORNEY'S OFFICE KingCounty Certification for Determination of Probable Cause “Sophie (moter) repeatedly advocated for her request for port placement and TPN nutnition for [C-H1] given concen that enteral feeding seems to trigger [C. H.'s] episodes and this is interfering with [C.HJs qualty of ite. In consuttation tnith Dr. Lusine Ambartsumyan (outpatient GI provider), Or, Mary Len (GI consult attending), PACT, MCC and Neurology, our care team feels strongly that [CH] is safe for enteral feeding and that any form of IV nutrition is, contraindicated for [C.11}. During this admission she has not demonstrated any nausea, vomiting, diarrhea, or abdominal discomfort." Despite this alscussion, on a clinic visit on September 9, 2019, Hartman once again brought up the idea of a TPN Central Line tor CH. despite previous discussion that it was not recommended. in the assessment wniten for thes cline visit, t states in the medical record: “We do not under any circumstances recommend TPN, especially given that she has normal small intestinal integrity." 1 spoke with RN’ Nancy Chase, who has been the primary resource in getting “continuity of care” for C.H. RIN Nancy Chase has been a part of C.H.'s care team for a number of years, and is extremely familar with her case. RN Nancy Chase stated that if the Seattie Children's Hospital SCAN team did not reach out to the Department of Youth and Child Services, she was going to make 3 referral herself, as she was extremely concemed for the escalation being requested by Hartman in terms of C.H.'s care. When ft came to the request for C.H. to be given a central ine, RN Nancy Chase ‘became even more concerned. She advised that Hartman's ‘driving’ request for the central line was due to CH.'s “quality of lie’, bad spell, lack of breathiny, and vomiting, Humever, une of these things trad beer objectively dacumented ar observed in a hospital setting RN Nancy Chase stated "if you are giving a kid a central ine you can infect or poison a clal” due tu Ure coutinuaus flow uf fjuid. Martian wets advised ayatito a ceria fine fur C.H. de to the myriad of complications involved RN Nancy Chase was concemed that the central ine/TPN cliscussions were continuously brought up by Hartman, despite prior discussions with providers that it was not necessary for C.H. was that ‘twas not recommended under any circumstances Ina statement written by Dr. Ambartsumyan she states “At our clinic vist on 6/3/2019 mother [Hartman] reported new onset diarhea since February 2019. She stated that the diarmhea was secondary to “autonomic dysfunction’ as they ‘occur during these “episode” cycles every 1-2 weeks and last J-7 days. When she would have these periods of diarrhea ‘mother would stop all her oral feeds, gastric feeds, and run Pedialyte via gastrostomy tube at SmL/hr. Her nutntion and ‘hydration were constantly adjusted by the mother depending on these episodes. it was unclear from history if she met her caloric or nutritional goais for the day. Mother had also discussed with me the ubity of total parenteral nutntion (TPN) for CH. We discussed that the constant adjustment of fecds has resulted in weight loss and we would nced to ‘monitor ner feeding and diarmes on an inpatient basis. We recommended agamst stopping her feeds cunng these episodes as it was limiting her nutritional intake. We discussed inpatient observation and possible consideration of GJ eds and that we would not recommend for her to be on TPN, At our 9/9/2019 clinic visit overail om history C.H.S emesis had improved and she was tolerating orel and gastric feeds. However, during the diarchea episodes her foods were being stopped by the mother. We again recommended against stopping the feeds during these diarrhea episodes. The consideration for TPN was brought up by the mother at our clinic on 8/9/2019 and we once again recommended against a central tine and against TPN. Despite this, In a text message to one of C.H.’s occupational therapists sent at the end of January 2021, Hartman stated! "CH's neurologist wil be reaching cut and discussing with Duke this week and wil got back to me on what Duke's recurnrecadations aie alter test resus, SCH Neuro basivally said teatirent eosectiaily looks hike cunt cin tre) ‘environment and feeds (feeds are critical which is unfortunate due to her gut health but we likely need to go hack on continuous Gi feeds).” In a Developmental Disabilities Administration (DA) Assessment via the Washington Department of Social and Health Services, conducted on September 16, 2020, Hartman is listed as the client representative for CH. Within the assessment, /lartman provides information regarding C.11. being able to "Cat at age level ICH] has a G-J tube, eats by mouth and has dysphagia. She receives continuous teeding at night tor 18 hours when having an AHL episode and 12 on a typical day due to concerns about her weight. She wil have Pedialte overnight to give Nuids to keep hydrated. When she has a good day, she can use silverware but her abuity tuctuates, She ikes ringer foods, She may not understand that she 1s Tull, ana Needs supervision around food. She may eat things that are not edible” Rev 07/14 5/19/2021 2:40:43 PM(CT) Ip 67905 Page 11 of 21