Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - Al
Page 1
IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
~ ~ -
MIRANDA BYRNE,
Plaintiff,
vs Case No.
22 CV 4106
MOUNT CARMEL HEALTH
SYSTEM,
Defendant.
10 - - -
11 DEPOSITION OF MIRANDA BYRNE
12 - - -
13
June 21, 2023
14 10:43 a.m.
BAKER HOSTETLER
15 200 Civic Center Drive
Suite 1200
16 Columbus, OH 43215
17
18 - - -
19 Reported by: Tracy J. Schell
20 - - -
21
22 EXHIBIT
23 A
24
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
O0G550 - A2
rn
Page 2
APPEARANCES
ON BEHALF OF THE PLAINTIFF:
Michael W. DeWitt
DeWITT LAW, LLC
4200 Regent Street
Suite 200
Columbus, OH 43219
mdewitt@dewittlawco.com
614.398.2886
ON BEHALF OF THE DEFENDANT:
Samuel E. Endicott
BAKER HOSTETLER
200 Civic Center Drive
Suite 1200
10 Columbus, OH 43215
sendicott@bakerlaw.com
11 614.228.1541
12
13
14
15
16
17
18
19
20
21
22
23
24
Veritext Legal Solutions
www. veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AB
Page 3
Wednesday Morning Session
June 21, 2023
10:43 a.m.
STIPULATIONS
It is stipulated by and between counsel for
the respective parties herein that this deposition of
MIRANDA BYRNE, the Plaintiff herein, called by the
Defendant under the statute, may be taken at this time
10 and reduced to writing in stenotypy by the Notary,
11 whose notes may thereafter be transcribed out of the
12 presence of the witness; and that proof of the official
13 character and qualifications of the Notary is waived.
14
15
16
17
18
19
20
21
22
23
24
vo veer fe ee oe a
Veritext Legal Solutions :
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
OG550 - A4
oa
Page 4
INDEX
WITNESS PAGE
MIRANDA BYRNE
BY MR. ENDICOTT:
- - -
EXHIBIT DESCRIPTION PAGE
Exhibit Resume of Byrne 17
Exhibit Offer Email, 10-12-14 17
Exhibit Position Description, Staff 20
10 RN
11 Exhibit Leaves of Absence Policy 22
12 Exhibit Attendance Policy 23
13 Exhibit Corrective Action Policy 23
14 Exhibit The Hartford Claims Status 24
15 Exhibit Time Detail 28
16 Exhibit Corrective Action 28
17 Exhibit 10 Corrective Action 29
18 Exhibit 11 Letter to Byrne from The 30
Hartford, 1-23-19
19
Exhibit 12 Memo to Byrne from Howard, 32
20 Employment Status, 1-28-19
21 Exhibit 13 Refiled Complaint 36
22 Exhibit 14 Interrogatories 40
23 Exhibit 15 Nationwide Children's 49
Hospital Records
24
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - A5
Page 5
EXHIBIT DESCRIPTION PAGE
Exhibit 16 Genesis HealthCare System 52
Records
Exhibit 17 Cleveland Clinic Records 56
Exhibit 18 Plaintiff's Responses to 57
Defendant Mount Carmel Health
System's First Set of
Requests for Production of
Documents
Exhibit 19 Matrix Termination Summaries 61
Exhibit 20 Columbus Psychological & 62
Counseling Services Records
10 Exhibit 21 Alfa Counseling Records 63
11 Exhibit 22 Handwritten Notes of Richard 70
Minter, M.D.
12
13
14
15
16
17
18
19
20
21
22
23
24
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - B6
Page 6
PROC INGS
MIRANDA BYRNE
'
being by me first duly sworn, as hereinafter certified,
testifies and says as follows:
EXAMINATION
BY MR. ENDICOTT:
Q Good morning. Can you please state your full
10 name and spell it for the record?
11 A Miranda, middle name Renee, Byrne.
12 M-I-R-A-N-D-A. Last name is B-Y-R-N-E.
13 Q We met briefly off the record. My name is
14 Sam Endicott. I'm counsel for the defendant in this
15 case, Mount Carmel Health System.
16 Over the course of today's deposition, I'm
17 going to be asking you questions about your employment
18 at Mount Carmel as well as the allegations in your
19 lawsuit.
20 Does that make sense?
21 A Yes.
22 Q Do you understand that the testimony you're
23 going to give today is under oath?
24 A Yes.
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - Al
Page 7
Q. Do you understand that the failure to answer
truthfully may subject you to the penalty of perjury?
A. Yes.
Q. Have you had your deposition taken before?
A No.
Q I'm going to go over a few ground rules. And
the goal of these ground rules is to get a clean
transcript, because as you probably noticed, our court
reporter is taking down everything that we say
10 verbatim. And to help us get a clean transcript, I'm
11 going to do my best to wait until you've answered the
12 question before I ask you another question. And in
13 turn, I'd ask that you wait for me to finish my
14 question before you start responding.
15 Does that make sense?
16 A Yes.
17 Q Another, you know, technique to get a clean
18 transcript is to have us not talk over each other. So
19 I would appreciate it, to the best you can, not to
20 interrupt if I'm asking a question.
21 Does that make sense?
22 A Yes.
23 Q And if you need to take a break today, that's
24 totally fine, if you could just answer whatever
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - A8
Page 8
question I've asked before we take the breaks.
Make sense?
A Yes.
Q And we have to have verbal answers, so yes,
no. Yeah or uh-huhs aren't going to work. So to the
extent you can, if you can do yes or no, please.
A Yes.
Q Thank you.
If I ask you a question, I'm going to assume
10 that you understood the question; is that fair?
121 A Yes
12 Q And if you don't understand the question,
13 will you just ask me to repeat it or rephrase it?
14 A Yes
15 Q You understand that your former employer is
16 Mount Carmel Health System, right?
17 A Yes.
18 Q And if one of us refers to it as Mount
19 Carmel, we're talking about Mount Carmel Health System.
20 Okay?
21 A Yes.
22 Q Is there any reason that you cannot testify
23 truthfully today?
24 A No.
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin Count ty Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV0041 06
0G550 - AQ
Page 9
Q Are you under the influence of alcohol or
medication?
A No.
Q Have you ever filed a lawsuit before this one
before?
A No.
Q Have you ever filed a charge of
discrimination with the Ohio Civil Rights Commission or
other government agency?
10 A No.
11 Q Have you ever had any criminal charges or
12 arrests other than traffic tickets?
13 A No.
14 Q Have you ever provided testimony of any kind
15 before?
16 A No.
17 Q Did you do anything to prepare for today's
18 deposition?
19 A Just meeting with Mike.
20 Q Perfect. And I don't want to hear anything
21 that Mike and you have ever talked about.
22 But I am curious, did you review any
23 documents during your prep session?
24 A Just what I gave him, but it's been a while
Veritext Legai Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 10
ago.
Q Okay. Do you remember what any of those
documents looked like or were titled?
A I don't remember. I think it was mostly
emails that I had.
Q Okay. Any other kind of documents?
A I don't believe so.
Q Okay. Did you look at any discovery
responses?
10 A I went over like what I filled out for Mike.
11 Q Okay. Did you look at the lawsuit itself?
12 A I don't believe so.
13 Q Okay. And ballpark, how long did your
14 meeting last?
15 A Honestly, I don't know. It was over like a
16 few phone calls really.
17 Q Sure. Other than Mike or anybody in his
18 office, did you talk to anybody else about your
19 deposition today?
20 A No.
21 Q What's your current residential address?
22 A It is 111 Brenden Loop, it's B-R-E-N-D-E-N,
23 and that is in Delaware, Ohio. It's 43015.
24 Q Are you -- strike that.
Veritext Legal Solutions
www.verifext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
vn
Page 11
How long have you lived there?
About a year and a half.
And are you currently married?
Yes.
Do you have any children?
Yes.
How many?
Two.
And what are the ages?
10 A Five and six.
11 Q What do you do for social relaxation after
12 leaving Mount Carmel?
13 A Just hang out with my family --
14 Q Okay. Have you taken any --
15 -- pretty much.
16 Sorry. Have you taken any vacations?
17 Yeah.
18 Okay.
19 A Occasionally.
20 Q Where was the most memorable place you've
21 been since leaving Mount Carmel for vacation?
22 A Probably just Florida seems to be our go-to.
23 Q Have you had any significant personal issues
24 in the last eight years? And what I mean by that is,
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 12
have there been any prolonged illnesses of a family or
a friend?
A In the last eight years? I don't believe so.
Q How about criminal problems in the last eight
years for a family or close friend?
A No.
Q And the same question, in the last eight
years, any civil problems for a friend or a close
family member?
10 A No.
11 Q And then the same question, in the last eight
12 years, any financial problems for a friend or a family
13 member?
14 A No.
15 Q And in the last eight years, have you had a
16 death of a close friend or a family member?
17 A No.
18 Q Is there -- strike that.
19 Have you served in any branch of the
20 military?
21 A No.
22 Q Did you graduate high school?
23 I did.
24 And when did you graduate high school and
o
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 13
where?
A 2009. I graduated from Worthington
Kilbourne.
Q And after high school, did you receive any
other degrees?
A Yes.
Q And take me through your educational history,
or what was the next degree?
A I received my associate's degree from Ohio
10 University in 2014.
121 Q Okay.
12 A And then continued on to finish my bachelor's
13 degree in 2017.
14 Q And where did you obtain your bachelor's
15 degree?
16 A Ohio University.
17 Q Okay.
18 A And then I am currently working on my doctor
19 of nursing practice at the University of Cincinnati.
20 Q And what date did you enroll in that program?
21 A I believe it was August of 2019.
22 And do you have an estimated graduation date?
23 This coming December.
24 And is that a full-time program, an online
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 14
program?
A It is all online, part time.
Q So do you physically go into a classroom at
all?
A No. We do have clinicals that I have to be
at, but those are at the sites, wherever they are, so
not actually at the school.
Q So, for example, in the first couple years of
the program, how much time were you devoting to being a
10 student a week?
11 A I'd say maybe 20 hours a week.
12 Q And has that been kind of the consistent
13 amount throughout the course of the program?
14 A Yeah.
15 Q And the 24 [sic] hours a week, that would
16 include both the clinical time and the online
17 classroom?
18 A Correct. Yes.
19 Q So when you were doing the clinical portion
20 of your training, are you at a specific hospital or a
21 care site?
22 A Yes, So it depends. As the student, I'm
23 responsible to set them up myself, so they could be
24 mostly like outpatient clinic.
Veritext Legal Solutions
www. veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 15
Q Okay. And would you go and shadow a doctor
or a nurse?
A Yeah. Uh-huh.
Q Is that a yes?
Yes.
And how many hours a week are the clinics?
A Usually about 14 hours a week.
Q And then the remaining six or so hours are
for the online instruction?
10 A Yeah. Yes.
11 Q And have you been continuously in the
12 doctorate program since August 2019 to the present?
13 A Yes. I did take a semester off last winter.
14 Q And so what would that have been, 2022?
15 A Yes.
16 Q And what are the semester ranges, if you
17 remember?
18 A It was from August through January.
19 Q Now you're back in the program and on pace
20 for graduation?
21 A Yes.
22 Q Do you hold any other degrees?
23 No.
24 And have you had any other significant
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 16
trainings or courses that we haven't talked about?
AB No.
Q Other than a driver's license, what licenses
do you hold?
A My nursing license.
Q Is that an RN license --
Yes.
-- through the State of Ohio?
A Yes.
10 Q After graduating from Ohio University, what
11 was the first job you had?
12 A I'm sorry, the first job I had?
13 Q Uh-huh.
14 It was with Mount Carmel.
15 Okay. And what was your job title?
16 A Staff RN.
17 Q And do you remember ballpark when you began
18 that position?
19 A I do. It was October of 2014.
20 Q October 2014, a staff RN.
21 And was that at Mount Carmel St. Ann's
22 Hospital?
23 A Correct
24
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 17
(Deposition Exhibit 1 marked.)
I'm going to mark this as Exhibit 1.
Have you seen the document we've marked as
Exhibit 1 before?
A Yes.
Q And can you identify it for the record?
A It is my resume.
Q Is it accurate to the best of your knowledge?
10 A It is except for my graduation date has
il changed But other than that...
12 Okay. The employment history is accurate as
13 well?
14 Yes.
15 Other than Mount Carmel, have you threatened
16 litigation against any other employer you've had since
17 graduating from Ohio University?
18 A No.
19
20 (Deposition Exhibit 2 marked.)
21
22 I've marked this as Exhibit 2.
23 Can you please identify Exhibit 2 for the
24 record?
Veritext Legal Solutions
www .veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 18
A It looks like my offer letter [sic] from
Mount Carmel St. Ann's.
Q And as of October 12, 2014, your last name
was Thompson; is that right?
A Yes.
Q Is that your maiden name?
Yes.
And then your married name is Byrne?
Yes.
10 And when did you become married?
11 A It was October of 2015.
12 Q It looks like according to this document,
13 your first date of employment was October 20, 2014.
14 Does that sound about right, when you
15 started?
16 Yes.
17 And your rate of pay here is $24.33 per hour.
18 Do you see that?
13 A Yes.
20 Q And does that comport to what your pay was
21 when you started at Mount Carmel?
22 A Yes.
23 Q You were hired in the full-time staff RN
24 residency program position in Mount Carmel's Mother
a
Veritext Legal Solutions
www.veritext.com 888-391-3376
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106
0G550 - AL
Page 19
Infant Unit at Mount Carmel St. Ann's, correct?
A Yes.
Q Were you automatically placed into Mount
Carmel's residency program?
A Yes.
Q And that was because you had less than one
year of clinical experience, correct?
A. Yes.
Q What did your obligations under the residency
10 program entail, if you remember?
11 A I believe it was just a residency meeting
12 once a month. I believe it was like four
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - Al Page 1 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO ~ ~ - MIRANDA BYRNE, Plaintiff, vs Case No. 22 CV 4106 MOUNT CARMEL HEALTH SYSTEM, Defendant. 10 - - - 11 DEPOSITION OF MIRANDA BYRNE 12 - - - 13 June 21, 2023 14 10:43 a.m. BAKER HOSTETLER 15 200 Civic Center Drive Suite 1200 16 Columbus, OH 43215 17 18 - - - 19 Reported by: Tracy J. Schell 20 - - - 21 22 EXHIBIT 23 A 24 Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 O0G550 - A2 rn Page 2 APPEARANCES ON BEHALF OF THE PLAINTIFF: Michael W. DeWitt DeWITT LAW, LLC 4200 Regent Street Suite 200 Columbus, OH 43219 mdewitt@dewittlawco.com 614.398.2886 ON BEHALF OF THE DEFENDANT: Samuel E. Endicott BAKER HOSTETLER 200 Civic Center Drive Suite 1200 10 Columbus, OH 43215 sendicott@bakerlaw.com 11 614.228.1541 12 13 14 15 16 17 18 19 20 21 22 23 24 Veritext Legal Solutions www. veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AB Page 3 Wednesday Morning Session June 21, 2023 10:43 a.m. STIPULATIONS It is stipulated by and between counsel for the respective parties herein that this deposition of MIRANDA BYRNE, the Plaintiff herein, called by the Defendant under the statute, may be taken at this time 10 and reduced to writing in stenotypy by the Notary, 11 whose notes may thereafter be transcribed out of the 12 presence of the witness; and that proof of the official 13 character and qualifications of the Notary is waived. 14 15 16 17 18 19 20 21 22 23 24 vo veer fe ee oe a Veritext Legal Solutions : www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 OG550 - A4 oa Page 4 INDEX WITNESS PAGE MIRANDA BYRNE BY MR. ENDICOTT: - - - EXHIBIT DESCRIPTION PAGE Exhibit Resume of Byrne 17 Exhibit Offer Email, 10-12-14 17 Exhibit Position Description, Staff 20 10 RN 11 Exhibit Leaves of Absence Policy 22 12 Exhibit Attendance Policy 23 13 Exhibit Corrective Action Policy 23 14 Exhibit The Hartford Claims Status 24 15 Exhibit Time Detail 28 16 Exhibit Corrective Action 28 17 Exhibit 10 Corrective Action 29 18 Exhibit 11 Letter to Byrne from The 30 Hartford, 1-23-19 19 Exhibit 12 Memo to Byrne from Howard, 32 20 Employment Status, 1-28-19 21 Exhibit 13 Refiled Complaint 36 22 Exhibit 14 Interrogatories 40 23 Exhibit 15 Nationwide Children's 49 Hospital Records 24 Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - A5 Page 5 EXHIBIT DESCRIPTION PAGE Exhibit 16 Genesis HealthCare System 52 Records Exhibit 17 Cleveland Clinic Records 56 Exhibit 18 Plaintiff's Responses to 57 Defendant Mount Carmel Health System's First Set of Requests for Production of Documents Exhibit 19 Matrix Termination Summaries 61 Exhibit 20 Columbus Psychological & 62 Counseling Services Records 10 Exhibit 21 Alfa Counseling Records 63 11 Exhibit 22 Handwritten Notes of Richard 70 Minter, M.D. 12 13 14 15 16 17 18 19 20 21 22 23 24 Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - B6 Page 6 PROC INGS MIRANDA BYRNE ' being by me first duly sworn, as hereinafter certified, testifies and says as follows: EXAMINATION BY MR. ENDICOTT: Q Good morning. Can you please state your full 10 name and spell it for the record? 11 A Miranda, middle name Renee, Byrne. 12 M-I-R-A-N-D-A. Last name is B-Y-R-N-E. 13 Q We met briefly off the record. My name is 14 Sam Endicott. I'm counsel for the defendant in this 15 case, Mount Carmel Health System. 16 Over the course of today's deposition, I'm 17 going to be asking you questions about your employment 18 at Mount Carmel as well as the allegations in your 19 lawsuit. 20 Does that make sense? 21 A Yes. 22 Q Do you understand that the testimony you're 23 going to give today is under oath? 24 A Yes. Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - Al Page 7 Q. Do you understand that the failure to answer truthfully may subject you to the penalty of perjury? A. Yes. Q. Have you had your deposition taken before? A No. Q I'm going to go over a few ground rules. And the goal of these ground rules is to get a clean transcript, because as you probably noticed, our court reporter is taking down everything that we say 10 verbatim. And to help us get a clean transcript, I'm 11 going to do my best to wait until you've answered the 12 question before I ask you another question. And in 13 turn, I'd ask that you wait for me to finish my 14 question before you start responding. 15 Does that make sense? 16 A Yes. 17 Q Another, you know, technique to get a clean 18 transcript is to have us not talk over each other. So 19 I would appreciate it, to the best you can, not to 20 interrupt if I'm asking a question. 21 Does that make sense? 22 A Yes. 23 Q And if you need to take a break today, that's 24 totally fine, if you could just answer whatever Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - A8 Page 8 question I've asked before we take the breaks. Make sense? A Yes. Q And we have to have verbal answers, so yes, no. Yeah or uh-huhs aren't going to work. So to the extent you can, if you can do yes or no, please. A Yes. Q Thank you. If I ask you a question, I'm going to assume 10 that you understood the question; is that fair? 121 A Yes 12 Q And if you don't understand the question, 13 will you just ask me to repeat it or rephrase it? 14 A Yes 15 Q You understand that your former employer is 16 Mount Carmel Health System, right? 17 A Yes. 18 Q And if one of us refers to it as Mount 19 Carmel, we're talking about Mount Carmel Health System. 20 Okay? 21 A Yes. 22 Q Is there any reason that you cannot testify 23 truthfully today? 24 A No. Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin Count ty Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV0041 06 0G550 - AQ Page 9 Q Are you under the influence of alcohol or medication? A No. Q Have you ever filed a lawsuit before this one before? A No. Q Have you ever filed a charge of discrimination with the Ohio Civil Rights Commission or other government agency? 10 A No. 11 Q Have you ever had any criminal charges or 12 arrests other than traffic tickets? 13 A No. 14 Q Have you ever provided testimony of any kind 15 before? 16 A No. 17 Q Did you do anything to prepare for today's 18 deposition? 19 A Just meeting with Mike. 20 Q Perfect. And I don't want to hear anything 21 that Mike and you have ever talked about. 22 But I am curious, did you review any 23 documents during your prep session? 24 A Just what I gave him, but it's been a while Veritext Legai Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 10 ago. Q Okay. Do you remember what any of those documents looked like or were titled? A I don't remember. I think it was mostly emails that I had. Q Okay. Any other kind of documents? A I don't believe so. Q Okay. Did you look at any discovery responses? 10 A I went over like what I filled out for Mike. 11 Q Okay. Did you look at the lawsuit itself? 12 A I don't believe so. 13 Q Okay. And ballpark, how long did your 14 meeting last? 15 A Honestly, I don't know. It was over like a 16 few phone calls really. 17 Q Sure. Other than Mike or anybody in his 18 office, did you talk to anybody else about your 19 deposition today? 20 A No. 21 Q What's your current residential address? 22 A It is 111 Brenden Loop, it's B-R-E-N-D-E-N, 23 and that is in Delaware, Ohio. It's 43015. 24 Q Are you -- strike that. Veritext Legal Solutions www.verifext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL vn Page 11 How long have you lived there? About a year and a half. And are you currently married? Yes. Do you have any children? Yes. How many? Two. And what are the ages? 10 A Five and six. 11 Q What do you do for social relaxation after 12 leaving Mount Carmel? 13 A Just hang out with my family -- 14 Q Okay. Have you taken any -- 15 -- pretty much. 16 Sorry. Have you taken any vacations? 17 Yeah. 18 Okay. 19 A Occasionally. 20 Q Where was the most memorable place you've 21 been since leaving Mount Carmel for vacation? 22 A Probably just Florida seems to be our go-to. 23 Q Have you had any significant personal issues 24 in the last eight years? And what I mean by that is, Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 12 have there been any prolonged illnesses of a family or a friend? A In the last eight years? I don't believe so. Q How about criminal problems in the last eight years for a family or close friend? A No. Q And the same question, in the last eight years, any civil problems for a friend or a close family member? 10 A No. 11 Q And then the same question, in the last eight 12 years, any financial problems for a friend or a family 13 member? 14 A No. 15 Q And in the last eight years, have you had a 16 death of a close friend or a family member? 17 A No. 18 Q Is there -- strike that. 19 Have you served in any branch of the 20 military? 21 A No. 22 Q Did you graduate high school? 23 I did. 24 And when did you graduate high school and o Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 13 where? A 2009. I graduated from Worthington Kilbourne. Q And after high school, did you receive any other degrees? A Yes. Q And take me through your educational history, or what was the next degree? A I received my associate's degree from Ohio 10 University in 2014. 121 Q Okay. 12 A And then continued on to finish my bachelor's 13 degree in 2017. 14 Q And where did you obtain your bachelor's 15 degree? 16 A Ohio University. 17 Q Okay. 18 A And then I am currently working on my doctor 19 of nursing practice at the University of Cincinnati. 20 Q And what date did you enroll in that program? 21 A I believe it was August of 2019. 22 And do you have an estimated graduation date? 23 This coming December. 24 And is that a full-time program, an online Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 14 program? A It is all online, part time. Q So do you physically go into a classroom at all? A No. We do have clinicals that I have to be at, but those are at the sites, wherever they are, so not actually at the school. Q So, for example, in the first couple years of the program, how much time were you devoting to being a 10 student a week? 11 A I'd say maybe 20 hours a week. 12 Q And has that been kind of the consistent 13 amount throughout the course of the program? 14 A Yeah. 15 Q And the 24 [sic] hours a week, that would 16 include both the clinical time and the online 17 classroom? 18 A Correct. Yes. 19 Q So when you were doing the clinical portion 20 of your training, are you at a specific hospital or a 21 care site? 22 A Yes, So it depends. As the student, I'm 23 responsible to set them up myself, so they could be 24 mostly like outpatient clinic. Veritext Legal Solutions www. veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 15 Q Okay. And would you go and shadow a doctor or a nurse? A Yeah. Uh-huh. Q Is that a yes? Yes. And how many hours a week are the clinics? A Usually about 14 hours a week. Q And then the remaining six or so hours are for the online instruction? 10 A Yeah. Yes. 11 Q And have you been continuously in the 12 doctorate program since August 2019 to the present? 13 A Yes. I did take a semester off last winter. 14 Q And so what would that have been, 2022? 15 A Yes. 16 Q And what are the semester ranges, if you 17 remember? 18 A It was from August through January. 19 Q Now you're back in the program and on pace 20 for graduation? 21 A Yes. 22 Q Do you hold any other degrees? 23 No. 24 And have you had any other significant Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 16 trainings or courses that we haven't talked about? AB No. Q Other than a driver's license, what licenses do you hold? A My nursing license. Q Is that an RN license -- Yes. -- through the State of Ohio? A Yes. 10 Q After graduating from Ohio University, what 11 was the first job you had? 12 A I'm sorry, the first job I had? 13 Q Uh-huh. 14 It was with Mount Carmel. 15 Okay. And what was your job title? 16 A Staff RN. 17 Q And do you remember ballpark when you began 18 that position? 19 A I do. It was October of 2014. 20 Q October 2014, a staff RN. 21 And was that at Mount Carmel St. Ann's 22 Hospital? 23 A Correct 24 Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 17 (Deposition Exhibit 1 marked.) I'm going to mark this as Exhibit 1. Have you seen the document we've marked as Exhibit 1 before? A Yes. Q And can you identify it for the record? A It is my resume. Q Is it accurate to the best of your knowledge? 10 A It is except for my graduation date has il changed But other than that... 12 Okay. The employment history is accurate as 13 well? 14 Yes. 15 Other than Mount Carmel, have you threatened 16 litigation against any other employer you've had since 17 graduating from Ohio University? 18 A No. 19 20 (Deposition Exhibit 2 marked.) 21 22 I've marked this as Exhibit 2. 23 Can you please identify Exhibit 2 for the 24 record? Veritext Legal Solutions www .veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 18 A It looks like my offer letter [sic] from Mount Carmel St. Ann's. Q And as of October 12, 2014, your last name was Thompson; is that right? A Yes. Q Is that your maiden name? Yes. And then your married name is Byrne? Yes. 10 And when did you become married? 11 A It was October of 2015. 12 Q It looks like according to this document, 13 your first date of employment was October 20, 2014. 14 Does that sound about right, when you 15 started? 16 Yes. 17 And your rate of pay here is $24.33 per hour. 18 Do you see that? 13 A Yes. 20 Q And does that comport to what your pay was 21 when you started at Mount Carmel? 22 A Yes. 23 Q You were hired in the full-time staff RN 24 residency program position in Mount Carmel's Mother a Veritext Legal Solutions www.veritext.com 888-391-3376 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 20 11:35 AM-22CV004106 0G550 - AL Page 19 Infant Unit at Mount Carmel St. Ann's, correct? A Yes. Q Were you automatically placed into Mount Carmel's residency program? A Yes. Q And that was because you had less than one year of clinical experience, correct? A. Yes. Q What did your obligations under the residency 10 program entail, if you remember? 11 A I believe it was just a residency meeting 12 once a month. I believe it was like four