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RECORDS ⌃
Complaint Affidavits Redacted
Defense Expert Deposition 2
■ SUMMARY
■ DIGEST
Medical Record Redacted
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■ TIMELINE
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Date ⇅ Facility ⇅ Category ⇅ Summary Bates# ⇅ Page Links
07/27/201200:39 Emergency
Department		 Emergency
Department		 Providers: Attending Physician, MD; Consulting Physician II, MD Emergency Department:
  • HISTORY: Patient is a 38-year-old woman presenting with abdominal pain, chronic for months, worsening today.
  • PHYSICAL EXAM: BP 150/84, pulse ox 99%. Awake and in pain. Abdomen mildly diffusely tender.
  • IMPRESSION: Acute abdominal pain; suspect small bowel obstruction.
 Bates 000001–
Bates 000003		 1–3
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07/27/201201:37 Regional
Endoscopy Ctr.		 Pathology Providers: Submitting Physician, MD; Pathologist, MD Pathology:
  • DIAGNOSIS: DUODENUM, SECOND PART — Small bowel mucosa with no significant histopathology.
  • No histologic evidence of celiac sprue or infectious microorganisms.
  • GASTRIC, ANTRUM — Mild chronic inactive gastritis.
 Bates 000030
Bates 000717		 30717
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08/14/201209:15 University
Hospital		 Surgery
Follow-up		 Providers: General Surgery, MD Post-Operative:
  • Patient presents for 3-week follow-up after bowel resection. Wound healing well. No signs of infection.
  • Diet advanced to regular. Activity as tolerated.
 Bates 000042 42
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09/22/201214:30 Gastro-
enterology		 GI
Consultation		 Providers: Gastroenterologist, MD Consultation:
  • Patient referred for post-surgical GI evaluation. Reports intermittent cramping and loose stools since discharge.
  • Plan: colonoscopy in 6 weeks, nutritional counseling, low-residue diet.
 Bates 000058 58
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10/15/201211:00 Radiology
Associates		 Imaging /
Radiology		 Providers: Radiologist, MD CT Abdomen/Pelvis W Contrast:
  • Post-operative changes consistent with prior small bowel resection. No evidence of abscess or anastomotic leak.
  • Small amount of residual free fluid in pelvis — likely post-surgical. No acute finding.
 Bates 000071–
Bates 000073		 71–73
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11/03/201208:45 Primary Care
Associates		 Primary
Care		 Providers: Primary Care Physician, MD Follow-up Visit:
  • Patient doing well overall. BP 128/76, weight stabilizing. Incision fully healed.
  • Continued monitoring of bowel function. Labs ordered: CMP, CBC.
 Bates 000088 88
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Deposition Digest Table
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Page ⇅ Topics Covered Summary
1
Deposition OpeningObjections Reserved
 Counsel opens deposition, formalities waived. Stipulation accepted by both parties.
2
Oath/IDMedical Credentials
 Deponent confirms identity and board certification in general surgery.
3
MedEd/TrainingPractice History
 Describes residency training. Has practiced general surgery since 1989.
4
LicensurePatient ID
 Confirms licensure, affiliations, and recognizes patient chart as Exhibit No. 1.
6
On-call/ERInitial Eval Time
 Witness was on-call general surgeon; first evaluated patient at approx 4:00–4:30 a.m. after finishing an operation.
7
Clinical FindingsSBO Diagnosis
 Patient had severe abdominal pain, distention, tachycardia, WBC 17; CT interpreted as small-bowel obstruction.
8
Metabolic AcidosisLab Results
 Blood gas and lactate: metabolic acidosis, lactate ~3.5, pH 7.16, bicarb ~15.
15
Operative DecisionStandard of Care
 Team deferred resection; serosal discoloration can be reversible with restored blood flow and resuscitation.
17
ICU CourseReturn to OR
 Patient required ventilator and vasopressors in ICU; returned to OR next morning with necrotic proximal jejunum.
18
Bowel ResectionSurgical Findings
 Surgeons resected one large necrotic segment plus two smaller pieces; attempted to obtain viable margins.
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↵
↷

B
I
U

CREDENTIALS & BACKGROUND

Counsel commenced the deposition under the state's Civil Practice Act, waived formalities, and reserved objections until trial or first judicial use 1. The physician identified as a medical doctor who graduated from medical school and completed a general surgery residency at a charity hospital system with a year at a teaching clinic 2. He has practiced general surgery in Georgia since that time, performing breast, thyroid, abdominal, and soft-tissue procedures as well as vascular access work 3. He confirmed licensure in Georgia, current hospital affiliations, and recognized the patient's chart as Plaintiff's Exhibit No. 1 4.

INITIAL EVALUATION

He testified he was on emergency-room call in the early morning hours, finished an operation, and first evaluated the patient at approximately 4:00–4:30 a.m. as the on-call general surgeon 6. On arrival she had severe crampy abdominal pain, marked tenderness and distention, tachycardia, a WBC count around 17, and a CT scan interpreted as small-bowel obstruction with free fluid 7. The team obtained blood gas and lactate studies; results showed metabolic acidosis with lactate near 3.5, pH 7.16, and bicarbonate near 15 8.

OPERATIVE DECISION & FINDINGS

The team deferred bowel resection initially because serosal discoloration can be reversible and mucosal injury may recover with restored blood flow 15. In the ICU, the patient required ventilatory support and vasopressors and was returned to the OR the following morning, at which time portions of bowel had not recovered and the proximal jejunum appeared necrotic 17. Surgeons resected one large necrotic segment plus two smaller pieces to obtain viable margins 18.

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PLEADINGS
Complaint Affidavit Redacted
RECORDS
Medical Records Redacted
Deposition Redacted
MASTER TIMELINE

Review the deduplicated MASTER timeline and the pleadings and the medical records. Tell me if the timeline contains all of the data points from the medical record that are relevant to the allegations of negligence.

Short answer: I cannot confirm the MASTER timeline is complete — a file clearly identified as such was not provided. Not available — Page NaN
Specific data points the MASTER timeline would need to include:
  • 12/30/2023 — Presentation to regional ED with right-sided deficits and abnormal speech; CT Angiogram performed. Complaint101987151 — Page 5
  • 12/30/2023 — CT Angiogram findings of soft tissue mass not correctly interpreted or urgently communicated. Complaint101987151 — Page 7
  • 1/01/2024 — Discharge home after the 12/30/2023 admission without further workup. Complaint101987151 — Page 5
  • 1/17/2024 — Presentation to ED with generalized weakness and syncope; second CT Angiogram performed. Complaint101987151 — Page 5

Are there any contradictions between the defense expert deposition and the medical records regarding the timing of the initial surgical evaluation?

Yes — there is a notable inconsistency on the timing of first evaluation:
  • Defense expert testified initial evaluation occurred at approximately 4:00–4:30 a.m. Defense Expert Dep. — Page 6
  • The nursing notes document the surgical consult as called at 2:48 a.m. and the surgeon arrived at 3:22 a.m. Medical Records — Page 14
  • The operative note records the pre-op evaluation time as 3:15 a.m. — 45 minutes earlier than the deponent's testimony. Medical Records — Page 31
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