The Deposition
by Becca Gladden

Run Report:  The patient is a 45-year-old female who was reportedly hit or run over by a car about 8 minutes prior to our arrival.  Patient is conscious and alert but in obvious distress, lying in parking lot of convenience store.  Patient has an angulated left femur fracture.  She is complaining of severe pain in entire anterior chest.  Patient has multiple lacerations over entire body.  Vital signs at scene:  Pulse 100, respirations 30.  No BP obtained.  PERRLA.  Breath sounds clear but shallow.  Patient is complaining, "I can't breathe" and says, "I'm going to die."  We put patient on 10 liters of O2 per minute by mask.  We chose not to splint the femur due to gross angulation of left leg.  No BP obtained due to patient wearing heavy leather coat and heavy clothing.  Patient transported code 3 to Rampart without further treatment, due to ETA of less than 2 minutes to Rampart E.R.  Patient was immobilized at scene with c-collar and full spine precautions prior to transport.  J. Gage, FF/PM, 03 January 1975.

ADDENDUM #1:  Since filing this report, I have heard that the patient is suing the car manufacturer, stating that she had put the car in park and it slipped out of gear and ran over her in the parking lot when she was getting out of the car.  I have also been told that I may be asked to give a deposition for the lawsuit.  J. Gage, FF/PM, 12 February 1975.

ADDENDUM #2:  Attached please find a copy of my deposition for the records, given on 5 June 1975.  J. Gage, FF/PM, 07 June 1975.

-----

This is Robert Smith and I am investigating an incident which involved a run to a convenience store parking lot to pick up a lady who had been run over by her own automobile.

Q.  Can you tell me your name please?

A.  John Gage.

Q.  How do you spell your last name?

A.  G A G E. 

Q.  What is your home address?

A.  (Address provided). 

Q.  What is your home phone number?

A.  (Phone number provided).

Q.  Do you have another number that you might be reached at if you are not there?

A.  (Phone number provided).

Q.  What is your job?

A.  I'm a firefighter/paramedic.

Q.  How old are you?

A.  26.

Q.  And were you trained as a paramedic at the University?

A.  No, it was at Rampart General Hospital.

Q.  And where are you presently employed?

A.  L.A. County Fire Department, Station 51.

Q.  And you ride in a rescue vehicle and treat people when they are injured, is that correct?

A.  That's correct.

Q.  Could you tell me about this incident when you were called to go to the convenience store to help this lady?

A.  What would you like to know about it?

Q.  What happened when you were originally called and where you went and that sort of thing.

A.  Okay.  We were just a few minutes away when we got called because we had just left Rampart.

Q.  Go ahead.

A.  And there was a slight amount of confusion between us and the dispatcher as to the address, because the witnesses were giving conflicting information.  So it took us about 2 or 3 minutes to get to the scene and when we got to the scene, some bystanders were waving kind of frantically and they showed us where the lady was.  It was a lady who was lying in the parking lot and she was crying and real frantic, and was just repeating a lot that she was going to die.  I just went ahead and did a normal primary and secondary survey like we do on all our patients and tried to assess the amount of her injuries.

Q.  And what injuries did you find?

A.  Oh, I don't remember everything.  She was complaining a lot that her chest hurt and she said that it felt like everything in her chest was broken, and judging from the amount of pain that she had and the amount of her difficulty breathing, we figured that she had at least some fractured ribs.  To tell you the truth, I can't remember all her injuries.  I think, somehow it seems to me she may have had some head injuries, but I really can't remember.     

Q.  Did she say how she was injured?

A.  She didn't say anything specifically.  I got the impression, and I don't remember whether it was from her or from the bystanders, that she was run over by her own car.  But I can't remember exactly who told us that.

Q.  Did you remember seeing a car parked any place that could have run her over?

A.  There were a couple of cars in the parking lot, but I didn't pay a whole lot of attention to them.

Q.  Who were the bystanders that you talked to?

A.  One of them was a clerk from the store and I don't really know who the others were.  They were just witnesses to the accident.

Q.  Do you remember what the clerk in the store said?

A.  No, I really don't.  You know, I was pretty worried about her condition because she was very upset and said she felt like everything was broken, and she kept saying she was going to die, she was going to die.  So most of my attention was focused on taking care of her.

Q.  What did you do to take care of her?

A.  We put a c-collar on her neck and we put her on a full spine board.   That was all we did in the parking lot.  Then we put her in the back of the ambulance and went ahead and treated her from there.

Q.  And where did you take her?

A.  Took her to Rampart General Emergency Room.

Q.  Did you ask her if she had been drinking?

A.  Yeah, when she, the way she was crying and the way she was kind of hysterical, I wasn't really sure if she might have been, if there might have been some alcohol involved, and I asked her if she had been drinking and she said that she had 4 beers.

Q.  Could you smell alcohol on her breath?

A.  I really don't remember.  I think I might have, because that might have been a reason for me asking the question, but I couldn't tell you definitely.  I just don't remember.

Q.  And when you asked her if she had been drinking, how did she answer?  Did she answer you by word or by gesture or what?

A.  As near as I remember, I think she just told me that she had 4 beers.  That's the way I remember it.

Q.  Do you remember her purse being beside her or anything like that?

A.  No, I sure don't.

Q.  Do you remember any cigarettes or anything like that being spilled on the pavement of the store?

A.  No, I don't.

Q.  Do you remember where she was lying on the convenience store lot?

A.  I think she was on the west side of the parking lot, about in the middle of the lot on the west side.

Q.  Did you talk to a witness who may have helped her try to catch the car as it circled?

A.  No, I didn't.     

Q.  There was another witness, a young man.  Did you talk to him?

A.  I think when we were putting her in the ambulance, there were people standing around, and I asked if anybody knew what had happened and, like I said, by the time we left the scene I had the understanding that she had been run over by her own car, but specifically who told me, I really couldn't tell you.

Q.  Have you heard anything about this incident since that time?

A.  Yes, I've heard a little bit about it.

Q.  What did you hear?

A.  I heard that the insurance company was trying not to have to pay the claim because they thought it was like a DUI accident, and I heard that she is suing the car manufacturer because she thinks there was something wrong with the car.   

Q.  Have you heard anything else?  Have you been contacted by any other attorneys or anybody like that?

A.  No, not at this point.

Q.  By any other investigators?

A.  Nobody at all.

Q.  Do you have anything you'd like to add to this statement?

A.  No sir, not that I can think of.

Q.  This is the 5th day of June, 1975.  May I have your permission to shut off the recorder?

A.  Sure.

Q.  Thank you. 

-----
Note:  Based on a real incident which occurred when I was working as a paramedic in 1981.  I just found a copy of the deposition that I gave, and I typed it pretty much verbatim, except I substituted Johnny as the paramedic.

Click above to send Becca feedback

Guest Dispatchers       Stories by Becca