Chapter 41

Extending his hand to introduce himself, Grant stood up to meet the nurse and hospital lawyer as they entered the conference room. Then he introduced me as part of the legal team.

I don’t know what I’d expected, but I was surprised the nurse facing deposition appeared to be in her thirties. Like me, she wore a dark blazer over a fitted blouse with dark slacks. Her blonde hair hung above her shoulders in an angled bob. Under the fluorescent lighting of the conference room, a tiny diamond above her pierced right nostril flashed when she turned her head, and a quarter-sized tattoo of the sun on her wrist was visible beneath the cuff of her blouse..

I also sport a tiny diamond in my nose, and a tiny red heart is tattooed at the nape of my neck. This is going to be harder than I thought.

I’d guess the hospital lawyer to be in his sixties, with a shock of thick, silver hair. The absence of telltale clipper marks as it formed around the shape of his head bespoke of a meticulous, and expensive scissor cut.  He wore a navy blue jacket, which he carefully removed before taking his seat at the table, revealing a pale blue dress shirt with French cuffs. His formal attire was at odds with Grant’ business casual look: a sport coat over an open neck dress shirt, no tie, and khakis. I got the sense something was being communicated between the two of them, but I couldn’t quite grasp the message.

After introductions, Grant explained that the deposition is a discovery process performed under oath, and would be videotaped.

“Before we begin, would anyone like a glass of water?”

“Yes, please.” Grant poured a glass of water for Melissa, the other nurse, from a pitcher of ice water and set of glasses conveniently placed on the table.

“Okay, let’s begin,” Grant started. “Melissa, how long have you been a Registered Nurse?”

“Seven years.”

“And, have you been employed at Sand Bluff Hospital for all of that time?

“No. Only for five years.”

“Have you worked all of those five years on their pediatric unit?”

“No. Only the past three years.”

“Were pediatrics part of your nursing school curriculum?”


“What pediatric education or training have you received since nursing school?”

“I’ve taken a few pediatric continuing education courses.”

“Describe these pediatric continuing education courses, please.”

“I’ve completed a course in common pediatric diagnoses, and an overview of pediatric assessment.”

“Were these courses provided to you by your employer, Sand Bluff Hospital?”

“No. I took these courses on my own, as part of the continuing education required by the state of California to renew my license.”

“Has Sand Bluff Hospital provided you or other nurses in your unit with pediatric specific education?”

“Yes. All nurses assigned to the pediatric unit must complete age-specific competencies, and have current PALS certification.”

“And what is PALS certification?”

“Pediatric Advance Life Support.”

“Does this certification make you competent in the care of pediatric patients?”

“Objection!” This from the hospital lawyer.

“Okay,” says Grant, “Let me rephrase the question. What is the significance of PALS certification for nurses?”

“PALS certification signifies a nurse is competent in the necessary skills to assist in a pediatric code under the supervision of a physician.”

“But not specific to a particular diagnosis?”

“No. PALS certification is not specific to diagnosis. PALS certification outlines responses to specific patient conditions.”

“Like respiratory failure or cardiac arrest?”


“PALS certification and, what did you say, age-specific competencies are provided to you by Sand Bluff Hospital, at their cost?”


“So further pediatric nursing education regarding specific diagnoses is something, for the most part, you have taken on your own initiative, at your own expense?”


“With no other education provided by Sand Bluff Hospital other than what you’ve just described?”


“Melissa, have you reviewed the medical chart of the deceased patient from the night of the event”?

“I went to medical records and reviewed them once.”

Grant gives a sharp look to the other lawyer. I know what he’s thinking. This nurse isn’t the target of the suit, so no one’s taken time to prepare her for this deposition. That energy’s been reserved for damage control for the hospital. They’re the “deep pocket.”

“Melissa, tell us about that night, leading up to the event.”