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FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
EXHIBIT BB
FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
Page 1
1
2 SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
3 -------------------------------------------X
MINEL JOHNSON and ANSEL JOHNSON,
4
PLAINTIFFS,
5
-against- Index No.:
6 523101/2016
7
BERNARD RIMPEL, UMESH MISHRA, JOSEPH DERGAN,
. 8 SARINA CRANAGE, STACEY MARTINDALE, AMER
HOMSI, DAVID SCHANER, and THE BROOKLYN
9 HOSPITAL CENTER,
10 DEFENDANTS.
___________________________________________x
11
12 DATE: May 25, 2021
13 TIME: 12:04 p.m.
14
15
16 VIDEOCONFERENCE EXAMINATION BEFORE
17 TRIAL of a Defendant, DAVID SCHANER, taken
18 by the respective parties, pursuant to a
19 Court order, held via Zoom, before Nicole
20 Veltri, RPR, CRR, a Notary Public of the
21 State of New York.
22
23
24
25
Diamond Reporting
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FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
Page 2
2 A P P E A R A N C E S:
3
GURFEIN DOUGLAS LLP
4 Attorneys for the Plaintiffs
11 Park Place, Suite 1100
5 New York, New York 10007
BY: PRESTON DOUGLAS, ESQ.
6
7
ELLENBERG & PARTNERS LLP
8 Attorneys for the Defendant
BERNARD RIMPEL
9 494 Eighth Avenue, 7th Floor
New York, New York 10001
10 BY: NIKKI ALIEVA, ESQ.
File #: MLMIC30856225
11
12
KERLEY, WALSH, MATERA & CINQUEMANI, P.C.
13 Attorneys for the Defendants
SARINA CRANAGE AND DAVID SCHANER
14 2174 Jackson Avenue
Seaford, New York 11783
15 BY: ROBERT LAPPING, ESQ.
File #: 15230
17
DOPF, P.C.
18 Attorneys for the Defendants
UMESH MISHRA, JOSEPH DERGAN, STACEY
19 MARTINDALE, AMER HOMSI, AND THE
BROOKLYN HOSPITAL CENTER
20 440 Ninth Avenue, 16th Floor
New York, New York 10001
21 BY: DENISE SAPANARA, ESQ.
File #: 133-73
22
23
ALSO PRESENT:
24 KENNETH LO
RICHARD GURFEIN
25 * * *
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FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
Page 3
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2 221. UNIFORM RULES FOR THE
CONDUCT OF DEPOSITIONS
3 221.1 Objections at Depositions
(a) Objections in general. No
4 objections shall be made at a deposition
except those which, pursuant to subdivision
5 (b), (c) or (d) of Rule 3115 of the Civil
Practice Law and Rules, would be waived if
6 not interposed, and except in compliance
with subdivision (e) of such rule. All
7 objections made at a deposition shall be
noted by the officer before whom the
8 deposition is taken, and the answer shall be
given and the deposition shall proceed
9 subject to the objections and to the right
of a person to apply for appropriate relief
10 pursuant to Article 31 of the CPLR.
(b) Speaking objections restricted.
11 Every objection raised during a deposition
shall be stated succinctly and framed so as
12 not to suggest an answer to the deponent
and, at the request of the questioning
13 attorney, shall include a clear statement as
to any defect in form or other basis of
14 error or irregularity. Except to the extent
permitted by CPLR Rule 3115 or by this rule,
15 during the course of the examination persons
in attendance shall not make statements or
16 comments that interfere with the
questioning.
17 221.2 Refusal to answer when objection is
made A deponent shall answer all questions
18 at a deposition, except (i) to pr'eserve a
privilege or right of confidentiality, (ii)
19 to enforce a limitation set forth in an
order of the court, or (iii) when the
20 question is plainly improper and would, if
answered, cause significant prejudice to any
21 person. An attorney shall not direct a
deponent not to answer except as provided in
22 CPLR Rule 3115 or this subdivision. Any
refusal to answer or direction not to answer
23 shall be accompanied by a succinct and clear
statement of the basis therefor. If the
24 deponent does not answer a question, the
examining party shall have the right to
25 complete the remainder of the deposition.
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FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
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2 221. UNIFORM RULES FOR THE
CONDUCT OF DEPOSITIONS
3
221.3 Communication with the deponent
4 An attorney shall not interrupt the
deposition for the purpose of communicating
5 with the deponent unless all parties consent
or the communication is made for the purpose
6 of determining whether the question should
not be answered on the grounds set forth in
7 section 221.2 of these rules and, in such
event, the reason for the communication
8 shall be stated for the record succinctly
and clearly.
9
10
11 IT IS FURTHER STIPULATED AND AGREED
that the transcript may be signed before any
12 Notary Public with the same force and effect
as if signed before a clerk or a Judge of
13 the court.
14
IT IS FURTHER STIPULATED AND AGREED
15 that the examination before trial may be
utilized for all purposes as provided by the
16 CPLR.
17
IT IS FURTHER STIPULATED AND AGREED
18 that all rights provided to all parties by
the CPLR cannot be deemed waived and the
19 appropriate sections of the CPLR shall be
controlling with respect hereto.
20
21 IT IS FURTHER STIPULATED AND AGREED by
and between the attorneys for the respective
22 parties hereto that a copy of this
examination shall be furnished, without
23 charge, to the attorneys representing the
witness testifying herein.
24
25
Diamond Reporting
800.727.6396 A Veritext Company www.veritext.com
FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
Page 5
1 D. SCHANER
2 D A V I D S C H A N E R, called as a
3 witness, having been first duly sworn by a
4 Notary Public of the State of New York, was
5 examined and testified as follows:
6 EXAMINATION BY
7 MR. DOUGLAS:
8 Q. Please state your name for the
9 record.
10 A. David Schaner.
11 Q. What is your address?
12 A. My home address is 77 Hudson
13 Street, H-U-D-S-O-N, Apartment 3303, Jersey
14 City, New Jersey, 07302.
15 MR. DOUGLAS: Good morning,
16 Doctor. Is it Schaner?
17 THE WITNESS: Schaner, yup,
18 correct.
19 MR. DOUGLAS: Shamer (phonetic)?
20 THE WITNESS: Schaner with an N.
21 MR. DOUGLAS: Okay. Let me just
22 get a baseline here, if you will.
23 Q. On May 2nd overnight into the 3rd,
24 did you participate in the care of a patient
25 named Minel Johnson.
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NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
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1 D. SCHANER
2 A. In 2014.
3 Q. Yes, sir.
4 A. Yes.
5 Q. And when did you first see Minel
6 Johnson professionally?
7 A. I took care of her in a prior
8 month when she had her gallbladder removed.
9 I can't remember exactly. It was two months
10 prior, two or three months prior.
11 Q. Were there any unusual events in
12 that prior admission?
13 A. No.
14 Q. Then we'll skip it.
15 A. Okay.
16 Q. On the overnight of May 2nd to
17 May 3rd, 2014, were you there when she
18 arrested?
19 A. I was called -- there was a code
20 blue that was called, and I arrived within a
21 minute of the code blue being called.
22 Q. Is code blue what the code in that
23 hospital is for a cardiac pulmonary arrest?
24 A. Correct.
25 Q. So you were there during the
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NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
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1 D. SCHANER
2 arrest; is that correct?
3 A. Yes. Not -- after the code was
4 called. I arrived within a minute.
5 Q. Okay.
6 When you arrived, who else was
7 there? .
8 A. Sarina Cranage was there. Homsi,
9 the residents, surgical residents. Nurse
10 Michelle was there, and that's all I can
11 recall. There have been -- there were
may
12 other people, but I can't recall.
13 Q. One of the papers that I gave you,
14 and I've numbered it number four in a
15 circle, was the cardiopulmonary
16 resuscitation sheet.
17 A. Uh-huh.
18 Q. Mr. Lapping I'm sure has because I
19 sent it to him three times.
20 MR. LAPPING: The one number four
21 is Dr. Shaner's progress note, but I'll
22 get him the CPR sheet.
23 MR. DOUGLAS: Pencil number four.
24 They had to be renumbered because they
25 were used for a prior section.
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FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
Page 8
1 D. SCHANER
2 MR. LAPPING: Well, we have the
3 CPR sheet in front of us.
4 MR. DOUGLAS: Okay.
5 Q. I see that Cranage is there?
6 A. Correct.
7 Q. Someone named Joseph Dergan was
8 there. Who is that?
9 A. He was -- I believe he was the
10 medical -- senior medical resident on-call,
11 and he was the code -- he was the code
12 leader.
13 Q. He was the code leader?
14 A. Correct.
15 Q. Do you know where Joseph Dergan is
16 these days?
17 A. No.
18 Q. Someone named Lee Scott (phonetic)
19 was there. Do you know that person?
20 A. No.
21 Q. And then there's someone named
22 Arnanos (phonetic) who was there; do you
23 know that person?
24 A. No.
25 Q. Was someone taking notes at this
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1 D. SCHANER
2 resuscitation?
3 A. No, not at the exact time of the
4 resuscitation as far as I remember.
5 Q. Ordinarily in most places that
6 I've experienced, there.'s someone who is
7 charged with noting the events during the
8 arrest. Is that your experience?
9 MR. LAPPING: Preston, I'm going
10 to object to the form only of your
11 question. Would you clean it up just a
12 little bit and you'll get an answer.
13 Q. In your experience when there's an
14 arrest, ordinarily is someone assigned to
15 taking notes?
16 A. Yes.
17 Q. Am I correct that no one took
18 notes during this arrest?
19 MS. SAPANARA: Objection.
20 Q. She's not your lawyer. She's
21 objecting for someone else.
22 MR. LAPPING: Doctor, you may
23 answer the question if you can.
24 A. I don't remember.
25 Q. Are you familiar with the
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FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
Page 10
1 D. SCHANER
2 cardiopulmonary resuscitation flow sheet
3 that was used at Brooklyn Hospital at this
4 time?
5 A. I've seen it before.
6 Q. Is this flow sheet complete?
7 A. No.
8 MS. SAPANARA: Objection.
9 Q. What's missing?
10 MS. SAPANARA: Objection.
11 Q. He's not saying anything, so you
12 can talk.
13 MR. LAPPING: He's looking at the
14 sheet.
15 Q. That's a good idea. Thank you.
16 A. Well, the type of events, the
17 pulse present onset, the intubated by, the
18 hyperventilation.
19 MR. LAPPING: Doctor, slow down
20 and enunciate a little better, please.
21 A. The type of event -- there's a box
22 at the top of the sheet that has a series
23 of, I guess, questions and wrote answers.
24 That box was completely unfilled; so that
25 box has in it information regarding the type
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FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016
NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023
Page 11
1 D. SCHANER
2 of the event, whether anyone witnessed
3 whether the patient was conscious at the
4 onset, whether there was pulse present at
5 the onset, whether an AED was applied,
6 whether ventilation at onset, intubated by,
7 the ETT size, the type of ventilation, the
8 ETT placement confirmed by.
9 Q. Are you done?
10 A. No.
11 Q. There's more?
12 A. There's more.
13 Q. Okay.
14 A. Resuscitation ended time, the
15 status of the resuscitation,
Preview
FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 EXHIBIT BB FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 1 1 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS 3 -------------------------------------------X MINEL JOHNSON and ANSEL JOHNSON, 4 PLAINTIFFS, 5 -against- Index No.: 6 523101/2016 7 BERNARD RIMPEL, UMESH MISHRA, JOSEPH DERGAN, . 8 SARINA CRANAGE, STACEY MARTINDALE, AMER HOMSI, DAVID SCHANER, and THE BROOKLYN 9 HOSPITAL CENTER, 10 DEFENDANTS. ___________________________________________x 11 12 DATE: May 25, 2021 13 TIME: 12:04 p.m. 14 15 16 VIDEOCONFERENCE EXAMINATION BEFORE 17 TRIAL of a Defendant, DAVID SCHANER, taken 18 by the respective parties, pursuant to a 19 Court order, held via Zoom, before Nicole 20 Veltri, RPR, CRR, a Notary Public of the 21 State of New York. 22 23 24 25 Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 2 2 A P P E A R A N C E S: 3 GURFEIN DOUGLAS LLP 4 Attorneys for the Plaintiffs 11 Park Place, Suite 1100 5 New York, New York 10007 BY: PRESTON DOUGLAS, ESQ. 6 7 ELLENBERG & PARTNERS LLP 8 Attorneys for the Defendant BERNARD RIMPEL 9 494 Eighth Avenue, 7th Floor New York, New York 10001 10 BY: NIKKI ALIEVA, ESQ. File #: MLMIC30856225 11 12 KERLEY, WALSH, MATERA & CINQUEMANI, P.C. 13 Attorneys for the Defendants SARINA CRANAGE AND DAVID SCHANER 14 2174 Jackson Avenue Seaford, New York 11783 15 BY: ROBERT LAPPING, ESQ. File #: 15230 17 DOPF, P.C. 18 Attorneys for the Defendants UMESH MISHRA, JOSEPH DERGAN, STACEY 19 MARTINDALE, AMER HOMSI, AND THE BROOKLYN HOSPITAL CENTER 20 440 Ninth Avenue, 16th Floor New York, New York 10001 21 BY: DENISE SAPANARA, ESQ. File #: 133-73 22 23 ALSO PRESENT: 24 KENNETH LO RICHARD GURFEIN 25 * * * Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 3 1 2 221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS 3 221.1 Objections at Depositions (a) Objections in general. No 4 objections shall be made at a deposition except those which, pursuant to subdivision 5 (b), (c) or (d) of Rule 3115 of the Civil Practice Law and Rules, would be waived if 6 not interposed, and except in compliance with subdivision (e) of such rule. All 7 objections made at a deposition shall be noted by the officer before whom the 8 deposition is taken, and the answer shall be given and the deposition shall proceed 9 subject to the objections and to the right of a person to apply for appropriate relief 10 pursuant to Article 31 of the CPLR. (b) Speaking objections restricted. 11 Every objection raised during a deposition shall be stated succinctly and framed so as 12 not to suggest an answer to the deponent and, at the request of the questioning 13 attorney, shall include a clear statement as to any defect in form or other basis of 14 error or irregularity. Except to the extent permitted by CPLR Rule 3115 or by this rule, 15 during the course of the examination persons in attendance shall not make statements or 16 comments that interfere with the questioning. 17 221.2 Refusal to answer when objection is made A deponent shall answer all questions 18 at a deposition, except (i) to pr'eserve a privilege or right of confidentiality, (ii) 19 to enforce a limitation set forth in an order of the court, or (iii) when the 20 question is plainly improper and would, if answered, cause significant prejudice to any 21 person. An attorney shall not direct a deponent not to answer except as provided in 22 CPLR Rule 3115 or this subdivision. Any refusal to answer or direction not to answer 23 shall be accompanied by a succinct and clear statement of the basis therefor. If the 24 deponent does not answer a question, the examining party shall have the right to 25 complete the remainder of the deposition. Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 4 1 2 221. UNIFORM RULES FOR THE CONDUCT OF DEPOSITIONS 3 221.3 Communication with the deponent 4 An attorney shall not interrupt the deposition for the purpose of communicating 5 with the deponent unless all parties consent or the communication is made for the purpose 6 of determining whether the question should not be answered on the grounds set forth in 7 section 221.2 of these rules and, in such event, the reason for the communication 8 shall be stated for the record succinctly and clearly. 9 10 11 IT IS FURTHER STIPULATED AND AGREED that the transcript may be signed before any 12 Notary Public with the same force and effect as if signed before a clerk or a Judge of 13 the court. 14 IT IS FURTHER STIPULATED AND AGREED 15 that the examination before trial may be utilized for all purposes as provided by the 16 CPLR. 17 IT IS FURTHER STIPULATED AND AGREED 18 that all rights provided to all parties by the CPLR cannot be deemed waived and the 19 appropriate sections of the CPLR shall be controlling with respect hereto. 20 21 IT IS FURTHER STIPULATED AND AGREED by and between the attorneys for the respective 22 parties hereto that a copy of this examination shall be furnished, without 23 charge, to the attorneys representing the witness testifying herein. 24 25 Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 5 1 D. SCHANER 2 D A V I D S C H A N E R, called as a 3 witness, having been first duly sworn by a 4 Notary Public of the State of New York, was 5 examined and testified as follows: 6 EXAMINATION BY 7 MR. DOUGLAS: 8 Q. Please state your name for the 9 record. 10 A. David Schaner. 11 Q. What is your address? 12 A. My home address is 77 Hudson 13 Street, H-U-D-S-O-N, Apartment 3303, Jersey 14 City, New Jersey, 07302. 15 MR. DOUGLAS: Good morning, 16 Doctor. Is it Schaner? 17 THE WITNESS: Schaner, yup, 18 correct. 19 MR. DOUGLAS: Shamer (phonetic)? 20 THE WITNESS: Schaner with an N. 21 MR. DOUGLAS: Okay. Let me just 22 get a baseline here, if you will. 23 Q. On May 2nd overnight into the 3rd, 24 did you participate in the care of a patient 25 named Minel Johnson. Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 6 1 D. SCHANER 2 A. In 2014. 3 Q. Yes, sir. 4 A. Yes. 5 Q. And when did you first see Minel 6 Johnson professionally? 7 A. I took care of her in a prior 8 month when she had her gallbladder removed. 9 I can't remember exactly. It was two months 10 prior, two or three months prior. 11 Q. Were there any unusual events in 12 that prior admission? 13 A. No. 14 Q. Then we'll skip it. 15 A. Okay. 16 Q. On the overnight of May 2nd to 17 May 3rd, 2014, were you there when she 18 arrested? 19 A. I was called -- there was a code 20 blue that was called, and I arrived within a 21 minute of the code blue being called. 22 Q. Is code blue what the code in that 23 hospital is for a cardiac pulmonary arrest? 24 A. Correct. 25 Q. So you were there during the DiamondReporting 800.727.6396 AVeritextCompany www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 7 1 D. SCHANER 2 arrest; is that correct? 3 A. Yes. Not -- after the code was 4 called. I arrived within a minute. 5 Q. Okay. 6 When you arrived, who else was 7 there? . 8 A. Sarina Cranage was there. Homsi, 9 the residents, surgical residents. Nurse 10 Michelle was there, and that's all I can 11 recall. There have been -- there were may 12 other people, but I can't recall. 13 Q. One of the papers that I gave you, 14 and I've numbered it number four in a 15 circle, was the cardiopulmonary 16 resuscitation sheet. 17 A. Uh-huh. 18 Q. Mr. Lapping I'm sure has because I 19 sent it to him three times. 20 MR. LAPPING: The one number four 21 is Dr. Shaner's progress note, but I'll 22 get him the CPR sheet. 23 MR. DOUGLAS: Pencil number four. 24 They had to be renumbered because they 25 were used for a prior section. Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 8 1 D. SCHANER 2 MR. LAPPING: Well, we have the 3 CPR sheet in front of us. 4 MR. DOUGLAS: Okay. 5 Q. I see that Cranage is there? 6 A. Correct. 7 Q. Someone named Joseph Dergan was 8 there. Who is that? 9 A. He was -- I believe he was the 10 medical -- senior medical resident on-call, 11 and he was the code -- he was the code 12 leader. 13 Q. He was the code leader? 14 A. Correct. 15 Q. Do you know where Joseph Dergan is 16 these days? 17 A. No. 18 Q. Someone named Lee Scott (phonetic) 19 was there. Do you know that person? 20 A. No. 21 Q. And then there's someone named 22 Arnanos (phonetic) who was there; do you 23 know that person? 24 A. No. 25 Q. Was someone taking notes at this Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 9 1 D. SCHANER 2 resuscitation? 3 A. No, not at the exact time of the 4 resuscitation as far as I remember. 5 Q. Ordinarily in most places that 6 I've experienced, there.'s someone who is 7 charged with noting the events during the 8 arrest. Is that your experience? 9 MR. LAPPING: Preston, I'm going 10 to object to the form only of your 11 question. Would you clean it up just a 12 little bit and you'll get an answer. 13 Q. In your experience when there's an 14 arrest, ordinarily is someone assigned to 15 taking notes? 16 A. Yes. 17 Q. Am I correct that no one took 18 notes during this arrest? 19 MS. SAPANARA: Objection. 20 Q. She's not your lawyer. She's 21 objecting for someone else. 22 MR. LAPPING: Doctor, you may 23 answer the question if you can. 24 A. I don't remember. 25 Q. Are you familiar with the Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 10 1 D. SCHANER 2 cardiopulmonary resuscitation flow sheet 3 that was used at Brooklyn Hospital at this 4 time? 5 A. I've seen it before. 6 Q. Is this flow sheet complete? 7 A. No. 8 MS. SAPANARA: Objection. 9 Q. What's missing? 10 MS. SAPANARA: Objection. 11 Q. He's not saying anything, so you 12 can talk. 13 MR. LAPPING: He's looking at the 14 sheet. 15 Q. That's a good idea. Thank you. 16 A. Well, the type of events, the 17 pulse present onset, the intubated by, the 18 hyperventilation. 19 MR. LAPPING: Doctor, slow down 20 and enunciate a little better, please. 21 A. The type of event -- there's a box 22 at the top of the sheet that has a series 23 of, I guess, questions and wrote answers. 24 That box was completely unfilled; so that 25 box has in it information regarding the type Diamond Reporting 800.727.6396 A Veritext Company www.veritext.com FILED: KINGS COUNTY CLERK 04/24/2023 12:46 PM INDEX NO. 523101/2016 NYSCEF DOC. NO. 190 RECEIVED NYSCEF: 04/24/2023 Page 11 1 D. SCHANER 2 of the event, whether anyone witnessed 3 whether the patient was conscious at the 4 onset, whether there was pulse present at 5 the onset, whether an AED was applied, 6 whether ventilation at onset, intubated by, 7 the ETT size, the type of ventilation, the 8 ETT placement confirmed by. 9 Q. Are you done? 10 A. No. 11 Q. There's more? 12 A. There's more. 13 Q. Okay. 14 A. Resuscitation ended time, the 15 status of the resuscitation,