Preview
FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018
NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
X
THERESA ROBINSON and DEREK ROBINSON,
Plaintiffs,
Index No.
- against - 717964/201
NORTHWELL HEALTH, INC., LONG ISLAND JEWISH
MEDICAL CENTER, DEEPAK NANDA, MD, PC,
DEEPAK NANDA, MD and EMMANUEL M. PAFOS, MD,
Defendant s.
•X
via Zoom Videoconference
January 6, 2021
10:03 a.m.
DEPOSITION of LONG ISLAND JEWISH MEDICAL
CENTER, Defendant, by JENNIFER WOLLAND, taken by
Plaintiff, pursuant to Article 31 of the Civil
Practice Law and Rules of Testimony, and Order, held
at the above-noted time and place, before Donna C.
Gilmore, a Stenotype Reporter and Notary Public
within and for the State of New York.
Q ORIGINAL
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NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021
2
1
2 APPEARANCES:
3
4 THE PAGLINAWAN LAW FIRM, PC
Attorneys for Plaintiff
5 118-21 Queens Boulevard, Suite 501
Forest Hills, New York 11375
6
BY: JAMES S. PAGLINAWAN, ESQ.
7
8
AARONSON, RAPPAPORT, FEINSTEIN & DEUTSCH, LLP
9 Attorneys for Defendants
NORTHWELL HEALTH, INC. and LONG ISLAND
10 JEWISH MEDICAL CENTER
600 Third Avenue
11 New York, New York 10016
12 BY: YANIQUE BURKE, ESQ.
13
14 RUBIN, PATERNITI, GONZALEZ & KAUFMAN , LLP
Attorneys for Defendants
15 DEEPAK NANDA, MD, PC and DEEPAK NANDA, MD
555 Fifth Avenue, 6th Floor
16 New York, New York 10017
17 BY: STEVEN KRAUS, ESQ.
18
19 GALVANO & XANTHAKIS, PC
Attorneys for Defendant
20 EMMANUEL M. PAFOS, MD
358 St. Marks Place, Suite 202
21 Staten Island, New York 10301
22 BY: ANTHONY XANTHAKIS, ESQ.
23
24
25
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NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021
1
2 PROCEEDINGS
3 THE REPORTER: The attorneys
4 participating in this deposition
5 acknowledge that I am not physically
6 present in the deposition room and that I
7 will be reporting this deposition
8 remotely.
9 They further acknowledge that, in lieu
10 of an oath administered in person, I will
11 administer the oath remotely, pursuant to
12 Executive Order Number 202.7 issued by
13 Governor Cuomo on March 19, 2020.
14 The parties and their counsel consent
15 to this arrangement and waive any
16 objections to this manner of reporting.
17 Please indicate your agreement by stating
18 your name and your agreement on the
19 record.
20 MR. PAGLINAWAN: I stipulate and I
21 agree with everything.
22 MR. XANTHAKIS: I agree as well.
23 MR. KRAUS: I so stipulate.
24 MS. BURKE: I agree.
25
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1
2 STIPULATIONS
3
4 IT IS HEREBY STIPULATED, by and between the
5 attorneys for the respective parties hereto, that:
6 All rights provided by the CPLR, and Part 221
7 of the Uniform Rules for the Conduct of Depositions,
8 including the right to object to any question, except
9 as to form, or to move to strike any testimony at this
10 examination is reserved; and in addition, the failure
11 to object to any question or to move to strike any
12 testimony at this examination shall not be a bar or
13 waiver to make such motion at, and is reserved to,
14 the trial of this action.
15 This deposition may be sworn to by the witness
16 being examined before a Notary Public other than the
17 Notary Public before whom this examination was begun,
18 but the failure to do so or to return the original
19 of this deposition to counsel, shall not be deemed a
20 waiver of the rights provided by Rule 3116 of the
21 CPLR, and shall be controlled thereby. The filing
22 of the original of this deposition is waived.
23 IT IS FURTHER STIPULATED, that a copy of this
24 examination shall be furnished to the attorney for
25 the witness being examined without charge.
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NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021
5
1
2 THE REPORTER: Mr. Kraus, are you
3 ordering a copy of this transcript and
4 paying for it?
5 MR. KRAUS: Yes, just a regular
6 transcript and e-mail to me as well.
7 please.
8 MR. XANTHAKIS: And same for me, but
9 just, fine for me, I don't need a hard
10 copy.
11 Thank you.
12 (Curriculum vitae was preraarked as
13 Plaintiff's Exhibit 1, and Fetal Heart
14 Monitor strips with notes and annotations.
15 for identification, as of this date.)
16 J E N N IFER WOLLAND,
17 called on behalf of Long Island Jewish Medical
18 Center, Defendant, having first been duly sworn
19 by the Notary Public, was examined and
20 testified as follows:
21 EXAMINATION BY
22 MR. PAGLINAWAN:
23 Q Please state your name for the record.
24 A Jennifer Wolland.
25 Q Please state your address for the record.
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NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021
1 Jennifer Wolland
2 MS. BURKE: Business address.
3 A 270-05 76th Avenue, New Hyde Park, New
4 York .
5 Q Good morning, Ms. Wolland.
6 A Good morning.
7 Q My name is James S. Paglinawan, and I work
8 for the Paglinawan Firm, PC, which is the law firm
9 that represents the plaintiffs in this case, namely
10 Theresa Robinson and Derek Robinson. I am deposing
11 you this morning as a witness from Long Island
12 Jewish Medical Center and Northwell Health, Inc.
13 I'll go over some very basic questions,
14 I'm going to go over some very basic rules with you
15 today.
16 First, if for some reason you’re not able
17 to hear me or you cannot understand my question, let
18 me know right away so I can rephrase the question in
19 such a way that you're going to be able to
20 understand me as well as you're going to be able to
21 hear me. There are times when the Internet
22 connection may not be as good as it should be, and,
23 but I don't have a way of knowing whether or not
24 you're able to see me in the screen or able to hear
25 me at all unless you indicate.
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7
1 Jennifer Wolland
2 If you have to take a break during the
3 deposition, I'm assuming that you might have to do
4 it every now and then because I can see you're
5 wearing a mask, right, you might need to take a
6 breather every now and then, not a problem. Let me
7 know. It's generally okay, unless there's a
8 question that's pending. That means that I've asked
9 you a question and you haven't answered it yet. If
10 you have to take a break and there is a pending
11 question, I will ask that you answer the question
12 and then we take a break.
13 Also, I will have to ask you to wait until
14 I'm finished asking the question before you start to
15 answer, even though sometimes, probably more like
16 frequently, you'd be able to anticipate what my
17 question is. And also, Ms. Gilmore, as you can see
18 in your screen, is transcribing what I'm saying,
19 even though you can't see her hands, that's what
20 she's doing there, so that in order for her to be
21 able to transcribe your responses you will have to
22 provide your responses using spoken words, rather
23 than using inaudible gestures only, so that she can
24 hear your answer so that she can transcribe your
25 answer.
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NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021
8
1 Jennifer Wolland
2 Are you clear with respect to the rules of
3 the deposition?
4 A Yes, I understand.
5 Q Okay. Your counsel provided to me a copy
6 of your c .V., which we marked as Plaintiff's Exhibit
7 No. 1 today. And you do have a copy in front of you
8 there, I' m hoping?
9 A Yes .
10 Q And I want you to tell me what this
11 document is .
12 A This document shows my education and my
13 work experience.
14 Q So is it your resume or c.v.?
15 A My resume, correct.
16 Q And when was the last time you updated
17 this c.V. that's in front of us?
18 A Last year, I believe.
19 Q So would you say that as of today this
20 c.v. is up to date?
21 A Yes .
22 Q Your c.v. states that your name is
23 Jennifer Wolland; however, in the medical records
24 from Long Island Jewish Medical Center it says that
25 your name is Jennifer Stanga, S-T-A-N-G-A?
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1 Jennifer Wolland
2 A Yes, that's my birth name. I got married
3 and changed my name in 2018.
4 Q And so in 2016 you were still using the
5 last name , I don’t know how to pronounce that.
6 Stan--
7 A Stanga.
8 Q Stanga ?
9 A Yes .
10 Q In April of 2016 who were you employed by?
11 A Northwell.
12 Q And specifically which hospital?
13 A Long Island Jewish Medical Center.
14 Q So let's go over some of the things that
15 you wrote down here. At the outset, are you
16 licensed to practice as a registered professional
17 nurse in New York?
18 A Yes .
19 Q And when did you obtain that license?
20 A In February 2011.
21 Q Other than New York, are you licensed to
22 practice anywhere else, in other states or
23 j urisdictions ?
24 A No .
25 Q Regarding your education, as of today are
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1 Jennifer Wolland
2 you still working on your master's of science in
3 nursing?
4 A Yes, I'm currently enrolled in that
5 program.
6 Q And how many more credits do you need to
7 finish that program?
8 A Four more semesters now.
9 Q And that, and you're working on that.
10 you're actually attending Stony Brook University,
11 that's what your resume says; is that correct?
12 A Yes .
13 Q And in 2007 you obtained your associates
14 in science degree from Nassau Community College,
15 correct ?
16 A Yes .
17 Q And then you went on to work on your
18 Bachelor of Science in Nursing at Molloy College,
19 right ?
20 A Yes .
21 Q And you graduated there in 2010, correct?
22 A Yes .
23 Q The degree that you obtained from Nassau
24 Community College, it says here associates in
25 science, was it related to any field of science?
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1 Jennifer Wolland
2 A It was just a prerequisite for the nursing
3 program that I went on to complete at Molloy
4 College.
5 Q It wasn't what can be called as AAS in
6 Nursing? It wasn't that kind of a degree, right?
7 A No .
8 Q So the degree that you obtained at Nassau
9 Community College, was it just a general associates
10 in science degree and not related to nursing?
11 A Correct.
12 Q So it says here on your resume that you
13 began working at Northwell Health, Long Island
14 Jewish Medical Center --
15 A Yes .
16 Q -- in May of 2011, correct?
17 A Yes .
18 Q So the resume, that should say Long Island
19 Jewish Medical Center or --
20 A Yes .
21 Q -- at that time was it Long Jewish Medical
22 Center?
23 A I'm sorry, yes. There is a typo. It
24 should say Long Island Jewish Medical Center.
25 Q Okay. And your first job there, at Long
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12
1 Jennifer Wolland
2 Island Jewish Medical Center, was a staff nurse,
3 correct ?
4 A Correct.
5 Q Did you begin working there in labor and
6 delivery initially?
7 A The whole time I’ve been at Long Island
8 Jewish Medical Center I’ve worked in the obstetrical
9 department. When I first started I was on the
10 antepartum/postpartum unit for eight months, and
11 then transferred to labor and delivery.
12 Q So you transferred to L&D, was it sometime
13 in the later part of 2011?
14 A Yes, correct.
15 Q And so underneath the part where it says
16 you began working at Long Island Jewish Medical
17 Center in May of 2011 up until now, it says in there
18 staff nurse and then it has some, what looks like
19 responsibilities and duties as a staff nurse; is
20 that correct?
21 A Yes ,
22 Q So let's go over not all of them, but some
23 of them.
24 Okay. It says here, "initiates inductions
25 of labor according to hospital protocol."
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NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021
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1 Jennifer Wolland
2 When you say hospital protocol, what are
3 you referring to?
4 A Policies and guidelines provided by the
5 hospital.
6 Q And which specific guidelines are those?
7 A We have specific to obstetrics, many in
8 which for any type of induction or labor or
9 lactation , depending on the current situation.
10 MR. PAGLINAWAN: Donna, do you have
11 the whole thing?
12 (The requested portion of the record
13 was read by the reporter.)
14 Q That sounds correct?
15 A It wasn't lactation, it was medication.
16 Q In 2016 was there a protocol in effect
17 where you were working at Long Island Jewish Medical
18 Center related to administration of Pitocin drip or
19 oxytocin drip to a woman in labor?
20 A Yes .
21 Q Do you remember what that was called.
22 precisely that specific protocol?
23 A Administration of oxytocin to the laboring
24 patient.
25 Q And that was something that was in
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14
1 Jennifer Wolland
2 writing, correct?
3 A Correct.
4 Q And in 2016, you being a staff nurse at
5 Long Island Jewish Medical Center, were you allowed
6 to administer Pitocin drip to women pursuant to a
7 doctor' s order?
8 A I'm sorry. Can you repeat the last part
9 of that question?
10 Q Sure .
11 MR. PAGLINAWAN: Donna?
12 {The requested portion of the record
13 was read by the reporter.)
14 A Yes .
15 Q And in 2016, you being a staff nurse at
16 Long Island Jewish Medical Center, were you allowed
17 to titrate, in other words increase or decrease, the
18 dosage of Pitocin or oxytocin drip?
19 A Yes, according to the doctor's order.
20 Q What is Pitocin drip?
21 A Pitocin is an IV medication that increases
22 the strength of contractions for a woman in labor.
23 We can titrate as needed to get the contractions
24 closer together.
25 Q And in administering Pitocin drip to a
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15
1 Jennifer Wolland
2 woman in labor at Long Island Jewish Medical Center,
3 were there any specific side effects that you were
4 required to look for?
5 MS. BURKE: Over my objection, you can
6 answer.
7 A Tachysystole, and we also look for changes
8 in the fetal heart rate.
9 Q So you did use the term fetal heart rate.
10 Was it part of your responsibility as a staff nurse
11 at Long Island Jewish Medical Center in 2016 to
12 monitor the fetal heart rate?
13 A Yes .
14 Q And would you agree with me that there are
15 certain fetal heart rate rhythms, or fetal heart
16 rhythms that would require you to notify a doctor?
17 MS. BURKE: Over objection, you can
18 answer.
19 A Yes .
20 Q And what are those rhythms that you can
21 think of that you were required to notify the doctor
22 about?
23 A Category 2 fetal heart rate tracings.
24 Q Okay. And what would be included in a
25 Category 2 fetal heart tracing?
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16
1 Jennifer Wolland
2 A Decelerations.
3 Q Would that include late and early
4 decelerations or just late decelerations?
5 A Any type of deceleration.
6 Q I'm going to challenge your memory quite a
7 bit, and if you don't remember it's perfectly fine.
8 In 2016 how many rooms did the L&D unit at
9 Long Island Jewish Medical Center have?
10 MS. BURKE: Over objection, you can
11 answer.
12 Do you remember?
13 A Labor rooms?
14 Q Yes.
15 A Fourteen.
16 Q And in 2016 was there only one unit for
17 the L&D or there's more than one?
18 A Just one unit.
19 Q And in that particular unit was there a
20 nurse's station somewhere?
21 A Yes.
22 Q Okay. And I'm also concerned about what
23 it looked like in 2016, because it might have
24 changed, it's been four years. Okay?
25 In 2016 where was the nurse's station
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17
1 Jennifer Wolland
2 located in relation to the labor rooms, the labor
3 unit?
4 A On the unit.
5 Q Would
Preview
FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS X THERESA ROBINSON and DEREK ROBINSON, Plaintiffs, Index No. - against - 717964/201 NORTHWELL HEALTH, INC., LONG ISLAND JEWISH MEDICAL CENTER, DEEPAK NANDA, MD, PC, DEEPAK NANDA, MD and EMMANUEL M. PAFOS, MD, Defendant s. •X via Zoom Videoconference January 6, 2021 10:03 a.m. DEPOSITION of LONG ISLAND JEWISH MEDICAL CENTER, Defendant, by JENNIFER WOLLAND, taken by Plaintiff, pursuant to Article 31 of the Civil Practice Law and Rules of Testimony, and Order, held at the above-noted time and place, before Donna C. Gilmore, a Stenotype Reporter and Notary Public within and for the State of New York. Q ORIGINAL Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 2 1 2 APPEARANCES: 3 4 THE PAGLINAWAN LAW FIRM, PC Attorneys for Plaintiff 5 118-21 Queens Boulevard, Suite 501 Forest Hills, New York 11375 6 BY: JAMES S. PAGLINAWAN, ESQ. 7 8 AARONSON, RAPPAPORT, FEINSTEIN & DEUTSCH, LLP 9 Attorneys for Defendants NORTHWELL HEALTH, INC. and LONG ISLAND 10 JEWISH MEDICAL CENTER 600 Third Avenue 11 New York, New York 10016 12 BY: YANIQUE BURKE, ESQ. 13 14 RUBIN, PATERNITI, GONZALEZ & KAUFMAN , LLP Attorneys for Defendants 15 DEEPAK NANDA, MD, PC and DEEPAK NANDA, MD 555 Fifth Avenue, 6th Floor 16 New York, New York 10017 17 BY: STEVEN KRAUS, ESQ. 18 19 GALVANO & XANTHAKIS, PC Attorneys for Defendant 20 EMMANUEL M. PAFOS, MD 358 St. Marks Place, Suite 202 21 Staten Island, New York 10301 22 BY: ANTHONY XANTHAKIS, ESQ. 23 24 25 Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 1 2 PROCEEDINGS 3 THE REPORTER: The attorneys 4 participating in this deposition 5 acknowledge that I am not physically 6 present in the deposition room and that I 7 will be reporting this deposition 8 remotely. 9 They further acknowledge that, in lieu 10 of an oath administered in person, I will 11 administer the oath remotely, pursuant to 12 Executive Order Number 202.7 issued by 13 Governor Cuomo on March 19, 2020. 14 The parties and their counsel consent 15 to this arrangement and waive any 16 objections to this manner of reporting. 17 Please indicate your agreement by stating 18 your name and your agreement on the 19 record. 20 MR. PAGLINAWAN: I stipulate and I 21 agree with everything. 22 MR. XANTHAKIS: I agree as well. 23 MR. KRAUS: I so stipulate. 24 MS. BURKE: I agree. 25 Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 1 2 STIPULATIONS 3 4 IT IS HEREBY STIPULATED, by and between the 5 attorneys for the respective parties hereto, that: 6 All rights provided by the CPLR, and Part 221 7 of the Uniform Rules for the Conduct of Depositions, 8 including the right to object to any question, except 9 as to form, or to move to strike any testimony at this 10 examination is reserved; and in addition, the failure 11 to object to any question or to move to strike any 12 testimony at this examination shall not be a bar or 13 waiver to make such motion at, and is reserved to, 14 the trial of this action. 15 This deposition may be sworn to by the witness 16 being examined before a Notary Public other than the 17 Notary Public before whom this examination was begun, 18 but the failure to do so or to return the original 19 of this deposition to counsel, shall not be deemed a 20 waiver of the rights provided by Rule 3116 of the 21 CPLR, and shall be controlled thereby. The filing 22 of the original of this deposition is waived. 23 IT IS FURTHER STIPULATED, that a copy of this 24 examination shall be furnished to the attorney for 25 the witness being examined without charge. Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 5 1 2 THE REPORTER: Mr. Kraus, are you 3 ordering a copy of this transcript and 4 paying for it? 5 MR. KRAUS: Yes, just a regular 6 transcript and e-mail to me as well. 7 please. 8 MR. XANTHAKIS: And same for me, but 9 just, fine for me, I don't need a hard 10 copy. 11 Thank you. 12 (Curriculum vitae was preraarked as 13 Plaintiff's Exhibit 1, and Fetal Heart 14 Monitor strips with notes and annotations. 15 for identification, as of this date.) 16 J E N N IFER WOLLAND, 17 called on behalf of Long Island Jewish Medical 18 Center, Defendant, having first been duly sworn 19 by the Notary Public, was examined and 20 testified as follows: 21 EXAMINATION BY 22 MR. PAGLINAWAN: 23 Q Please state your name for the record. 24 A Jennifer Wolland. 25 Q Please state your address for the record. Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 1 Jennifer Wolland 2 MS. BURKE: Business address. 3 A 270-05 76th Avenue, New Hyde Park, New 4 York . 5 Q Good morning, Ms. Wolland. 6 A Good morning. 7 Q My name is James S. Paglinawan, and I work 8 for the Paglinawan Firm, PC, which is the law firm 9 that represents the plaintiffs in this case, namely 10 Theresa Robinson and Derek Robinson. I am deposing 11 you this morning as a witness from Long Island 12 Jewish Medical Center and Northwell Health, Inc. 13 I'll go over some very basic questions, 14 I'm going to go over some very basic rules with you 15 today. 16 First, if for some reason you’re not able 17 to hear me or you cannot understand my question, let 18 me know right away so I can rephrase the question in 19 such a way that you're going to be able to 20 understand me as well as you're going to be able to 21 hear me. There are times when the Internet 22 connection may not be as good as it should be, and, 23 but I don't have a way of knowing whether or not 24 you're able to see me in the screen or able to hear 25 me at all unless you indicate. Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 7 1 Jennifer Wolland 2 If you have to take a break during the 3 deposition, I'm assuming that you might have to do 4 it every now and then because I can see you're 5 wearing a mask, right, you might need to take a 6 breather every now and then, not a problem. Let me 7 know. It's generally okay, unless there's a 8 question that's pending. That means that I've asked 9 you a question and you haven't answered it yet. If 10 you have to take a break and there is a pending 11 question, I will ask that you answer the question 12 and then we take a break. 13 Also, I will have to ask you to wait until 14 I'm finished asking the question before you start to 15 answer, even though sometimes, probably more like 16 frequently, you'd be able to anticipate what my 17 question is. And also, Ms. Gilmore, as you can see 18 in your screen, is transcribing what I'm saying, 19 even though you can't see her hands, that's what 20 she's doing there, so that in order for her to be 21 able to transcribe your responses you will have to 22 provide your responses using spoken words, rather 23 than using inaudible gestures only, so that she can 24 hear your answer so that she can transcribe your 25 answer. Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 8 1 Jennifer Wolland 2 Are you clear with respect to the rules of 3 the deposition? 4 A Yes, I understand. 5 Q Okay. Your counsel provided to me a copy 6 of your c .V., which we marked as Plaintiff's Exhibit 7 No. 1 today. And you do have a copy in front of you 8 there, I' m hoping? 9 A Yes . 10 Q And I want you to tell me what this 11 document is . 12 A This document shows my education and my 13 work experience. 14 Q So is it your resume or c.v.? 15 A My resume, correct. 16 Q And when was the last time you updated 17 this c.V. that's in front of us? 18 A Last year, I believe. 19 Q So would you say that as of today this 20 c.v. is up to date? 21 A Yes . 22 Q Your c.v. states that your name is 23 Jennifer Wolland; however, in the medical records 24 from Long Island Jewish Medical Center it says that 25 your name is Jennifer Stanga, S-T-A-N-G-A? Enright Court Reporting 631) 589-778 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 9 1 Jennifer Wolland 2 A Yes, that's my birth name. I got married 3 and changed my name in 2018. 4 Q And so in 2016 you were still using the 5 last name , I don’t know how to pronounce that. 6 Stan-- 7 A Stanga. 8 Q Stanga ? 9 A Yes . 10 Q In April of 2016 who were you employed by? 11 A Northwell. 12 Q And specifically which hospital? 13 A Long Island Jewish Medical Center. 14 Q So let's go over some of the things that 15 you wrote down here. At the outset, are you 16 licensed to practice as a registered professional 17 nurse in New York? 18 A Yes . 19 Q And when did you obtain that license? 20 A In February 2011. 21 Q Other than New York, are you licensed to 22 practice anywhere else, in other states or 23 j urisdictions ? 24 A No . 25 Q Regarding your education, as of today are Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 10 1 Jennifer Wolland 2 you still working on your master's of science in 3 nursing? 4 A Yes, I'm currently enrolled in that 5 program. 6 Q And how many more credits do you need to 7 finish that program? 8 A Four more semesters now. 9 Q And that, and you're working on that. 10 you're actually attending Stony Brook University, 11 that's what your resume says; is that correct? 12 A Yes . 13 Q And in 2007 you obtained your associates 14 in science degree from Nassau Community College, 15 correct ? 16 A Yes . 17 Q And then you went on to work on your 18 Bachelor of Science in Nursing at Molloy College, 19 right ? 20 A Yes . 21 Q And you graduated there in 2010, correct? 22 A Yes . 23 Q The degree that you obtained from Nassau 24 Community College, it says here associates in 25 science, was it related to any field of science? Enright Court Reporting (631) 589-7788 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 11 1 Jennifer Wolland 2 A It was just a prerequisite for the nursing 3 program that I went on to complete at Molloy 4 College. 5 Q It wasn't what can be called as AAS in 6 Nursing? It wasn't that kind of a degree, right? 7 A No . 8 Q So the degree that you obtained at Nassau 9 Community College, was it just a general associates 10 in science degree and not related to nursing? 11 A Correct. 12 Q So it says here on your resume that you 13 began working at Northwell Health, Long Island 14 Jewish Medical Center -- 15 A Yes . 16 Q -- in May of 2011, correct? 17 A Yes . 18 Q So the resume, that should say Long Island 19 Jewish Medical Center or -- 20 A Yes . 21 Q -- at that time was it Long Jewish Medical 22 Center? 23 A I'm sorry, yes. There is a typo. It 24 should say Long Island Jewish Medical Center. 25 Q Okay. And your first job there, at Long Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 12 1 Jennifer Wolland 2 Island Jewish Medical Center, was a staff nurse, 3 correct ? 4 A Correct. 5 Q Did you begin working there in labor and 6 delivery initially? 7 A The whole time I’ve been at Long Island 8 Jewish Medical Center I’ve worked in the obstetrical 9 department. When I first started I was on the 10 antepartum/postpartum unit for eight months, and 11 then transferred to labor and delivery. 12 Q So you transferred to L&D, was it sometime 13 in the later part of 2011? 14 A Yes, correct. 15 Q And so underneath the part where it says 16 you began working at Long Island Jewish Medical 17 Center in May of 2011 up until now, it says in there 18 staff nurse and then it has some, what looks like 19 responsibilities and duties as a staff nurse; is 20 that correct? 21 A Yes , 22 Q So let's go over not all of them, but some 23 of them. 24 Okay. It says here, "initiates inductions 25 of labor according to hospital protocol." Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 13 1 Jennifer Wolland 2 When you say hospital protocol, what are 3 you referring to? 4 A Policies and guidelines provided by the 5 hospital. 6 Q And which specific guidelines are those? 7 A We have specific to obstetrics, many in 8 which for any type of induction or labor or 9 lactation , depending on the current situation. 10 MR. PAGLINAWAN: Donna, do you have 11 the whole thing? 12 (The requested portion of the record 13 was read by the reporter.) 14 Q That sounds correct? 15 A It wasn't lactation, it was medication. 16 Q In 2016 was there a protocol in effect 17 where you were working at Long Island Jewish Medical 18 Center related to administration of Pitocin drip or 19 oxytocin drip to a woman in labor? 20 A Yes . 21 Q Do you remember what that was called. 22 precisely that specific protocol? 23 A Administration of oxytocin to the laboring 24 patient. 25 Q And that was something that was in Enright Court Reporting 631) 589-7788 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 14 1 Jennifer Wolland 2 writing, correct? 3 A Correct. 4 Q And in 2016, you being a staff nurse at 5 Long Island Jewish Medical Center, were you allowed 6 to administer Pitocin drip to women pursuant to a 7 doctor' s order? 8 A I'm sorry. Can you repeat the last part 9 of that question? 10 Q Sure . 11 MR. PAGLINAWAN: Donna? 12 {The requested portion of the record 13 was read by the reporter.) 14 A Yes . 15 Q And in 2016, you being a staff nurse at 16 Long Island Jewish Medical Center, were you allowed 17 to titrate, in other words increase or decrease, the 18 dosage of Pitocin or oxytocin drip? 19 A Yes, according to the doctor's order. 20 Q What is Pitocin drip? 21 A Pitocin is an IV medication that increases 22 the strength of contractions for a woman in labor. 23 We can titrate as needed to get the contractions 24 closer together. 25 Q And in administering Pitocin drip to a Enright Court Reporting (631) 589-7788 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 15 1 Jennifer Wolland 2 woman in labor at Long Island Jewish Medical Center, 3 were there any specific side effects that you were 4 required to look for? 5 MS. BURKE: Over my objection, you can 6 answer. 7 A Tachysystole, and we also look for changes 8 in the fetal heart rate. 9 Q So you did use the term fetal heart rate. 10 Was it part of your responsibility as a staff nurse 11 at Long Island Jewish Medical Center in 2016 to 12 monitor the fetal heart rate? 13 A Yes . 14 Q And would you agree with me that there are 15 certain fetal heart rate rhythms, or fetal heart 16 rhythms that would require you to notify a doctor? 17 MS. BURKE: Over objection, you can 18 answer. 19 A Yes . 20 Q And what are those rhythms that you can 21 think of that you were required to notify the doctor 22 about? 23 A Category 2 fetal heart rate tracings. 24 Q Okay. And what would be included in a 25 Category 2 fetal heart tracing? Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 16 1 Jennifer Wolland 2 A Decelerations. 3 Q Would that include late and early 4 decelerations or just late decelerations? 5 A Any type of deceleration. 6 Q I'm going to challenge your memory quite a 7 bit, and if you don't remember it's perfectly fine. 8 In 2016 how many rooms did the L&D unit at 9 Long Island Jewish Medical Center have? 10 MS. BURKE: Over objection, you can 11 answer. 12 Do you remember? 13 A Labor rooms? 14 Q Yes. 15 A Fourteen. 16 Q And in 2016 was there only one unit for 17 the L&D or there's more than one? 18 A Just one unit. 19 Q And in that particular unit was there a 20 nurse's station somewhere? 21 A Yes. 22 Q Okay. And I'm also concerned about what 23 it looked like in 2016, because it might have 24 changed, it's been four years. Okay? 25 In 2016 where was the nurse's station Enright Court Reporting 631) 589-77 FILED: QUEENS COUNTY CLERK 06/16/2021 01:34 AM INDEX NO. 717964/2018 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 06/16/2021 17 1 Jennifer Wolland 2 located in relation to the labor rooms, the labor 3 unit? 4 A On the unit. 5 Q Would