Good Medicine - Residency II
Copyright© 2025 by Michael Loucks
Chapter 24: A Deposition
May 23, 1990, McKinley, Ohio
"Last day to play doctor," I said to Mary.
She laughed, "I think I'd remember if we had played doctor!"
"And you know what I meant, Miss Anderson!"
"And you knew I'd take it the way I did, Doctor Mike!"
"Truth," I admitted with a grin. "Next time you're here, YOU will be the doctor AND the teacher."
"As much as I want it, do you know how crazy that sounds?"
"Trust me," I replied, "been there; done that. Get a chart, if there is one."
She went to the triage station and returned with a chart.
"Twenty-two-year-old male with an arm lac. Notes say he claims a kitchen accident, but the triage nurse doesn't believe him."
"OK. Bring him in."
Mary brought the patient in, and we escorted him to Exam 2.
"Mr. Schroeder, I'm Mary, and this is Doctor Mike. What brings you to us today?"
"A cut on my arm," he replied.
"May I examine it, please?" Mary asked.
"Sure."
Mary washed her hands, put on gloves, and got a bottle of saline to make it easier to remove the gauze Mr. Schroeder had wrapped around his arm. She did so, and from the location and angle of the laceration, it was immediately obvious to me it was not accidental.
"How did this happen?" Mary asked.
"I was slicing a melon and put the knife on the counter and dragged my arm across the sharp edge."
There was simply no possible way that was true. He had either cut himself intentionally or someone had cut him.
"I'm going to perform a basic exam, and then we'll suture your arm," Mary said.
She retrieved gauze and re-wrapped the arm, then performed her exam, calling out the vitals.
"About ten sutures, I believe," Mary suggested.
"I concur," I replied. "You may proceed."
"Mr. Schroeder, have you ever had a bad reaction to an anesthetic?" Mary asked.
"I've never had any."
"Have you had cavities filled?"
"Sure."
"Any trouble with that?"
"No."
"OK. Hang tight, and a nurse will bring you to the suture room."
"Thanks, Doc," he said.
"I won't be a doctor until tomorrow afternoon," Mary replied. "This is my last day of training."
"You're a student?"
"Yes. Doctor Mike is training me. I graduate from medical school tomorrow."
Mary and I left the room.
"Suture room?" I asked.
"We'll move him to Exam 6," she said. "But I wanted to talk to you about a psych consult because there is no way his story is true."
"I agree. What's your gut say?"
"If I had to put money on it? Self-inflicted."
"OK. Make the call, then ask Ellie to have a nurse move him to Exam 6."
Mary called for the psych consult, then asked for a nurse to move the patient, which she did. We went into Exam 6, where Mary got a suture tray, and once again washed her hands and put on fresh gloves. With assistance from Becky, Mary injected the lidocaine, then began suturing. Ellie came to let me know that Doctor Bishop was waiting for me, so I left Mary to suture and went to speak to Maureen Bishop.
"Dale Schroeder. Healthy twenty-two-year-old male with normal vitals presented with a five-inch laceration on his forearm. He claims it was an accident, but his story doesn't add up. Mary and I both suspect it's self-inflicted. She's suturing now. May I suggest you don't identify your service and simply appear to be checking on Mary's work and engage the patient?"
"Are you aware we've been told not to listen to anything you say beyond patient vitals?"
"No, I wasn't," I sighed. "Do what you want."
"I didn't say I wasn't going to listen; I said we've been told not to listen."
"Sorry; previous experience colored my response."
"Between you and me, and never to be repeated — that doctor in Cincinnati should have lost his license."
I nodded, "Got it."
"Let me play this as your supervisor, please."
"Sounds good."
The two of us went into Exam 6.
"Hi, Mr. Schroeder. I'm Doctor Bishop, and I'm senior to Doctor Mike and Mary, and I'm just checking how things are going. How did you hurt your arm?"
"I was cutting a melon, put the knife on the counter, and put my arm down on the sharp edge."
Doctor Bishop stepped closer and looked over Mary's shoulder.
"OK. I'll come back and check on you once Mary is done suturing. Doctor Mike, can I see you in the corridor?"
I nodded and we stepped out, leaving Mary and Becky with the patient.
"I may be a psychiatrist," Maureen said, "but I doubled in the ER and Internal Medicine Fourth Year, and I'm positive that wasn't accidental. If you'll sign the chart, I'll take him. I might not convince him to stay, but I also might put him on a hold."
"Thanks, Maureen. I do apologize for my attitude when you first came down."
"It's OK. I have this. Thanks."
I waited for Mary to come out, and as there were no charts in the rack, we went to the lounge.
"That Psych Resident seems competent," Mary observed.
"A fifteen-year difference in age from the Chief, and an attitude closer to ours makes all the difference in the world."
"Ours?"
"Name one thing on which we disagree?" I countered.
"I can't think of anything major, or even minor, in that regard. I'm pretty much in tune with you the same way your work wife is!"
I chuckled, "Doctor Saunders does find that amusing! And you know, there are no bigamy rules for work wives!"
"A harem? Listen to who's full of themselves!"
"Sorry, that's a privilege for the legal wife alone!"
Mary laughed, then rolled her eyes.
"I know the rules as well as you do, and I agree with them completely! Not to mention you are the last person on this planet who would cheat, Nurse Ellie's attempts to the contrary notwithstanding!"
"She has toned it down a bit."
"Mike?" Becky said, coming into the lounge. "EMS three minutes out with an MVA. Paramedics say it's a bad one, and Ghost asked for you."
"Come along," I said to Becky.
The three of us put on gowns, gloves, and goggles, and made our way to the ambulance bay. About a minute later, Bobby's rig turned into the driveway and a few seconds later came to a stop in front of us. Bobby jumped out and gave the bullet as he moved towards the back of the squad.
"Twenty-nine-year-old male; head on MVA; probable flail chest; compound fractures both lower legs; severe head trauma; BP 70/30; tachy at 120; PO₂ 92% on ten litres; unit of plasma in; backboard and neck brace."
"Trauma 1," Ghost declared, and we began moving. "Mike, head, neck, and neuro eval; Mary, assist Mike; John, EKG and monitors; Becky ABG and type and crossmatch; Leslie, Foley!"
Two doctors, two Fourth Years, a Third Year, and a nurse just didn't seem enough for me.
"Ellie, we need another nurse!" I called out as we moved into Trauma 1.
Ellie came herself, and I asked her to switch the oxygen.
"Mary, Babinski!" I directed.
She moved to the patient's feet while I assessed the patient's C-spine. I carefully assessed his neck while Ghost called out the bad news about the injuries.
"Muffled heart sounds and a punctured lung. Pericardiocentesis and chest tube! That has to be first or he won't live long enough for the C-spine to matter."
"Indifferent Babinski!" Mary called out, indicating serious neural compromise.
"Mary, with me!" I called out. "Becky, syringe with cardiac needle and alligator clip with lead, then thoracotomy tray!"
"V-fib!" John, a Third Year, called out.
"Paddles!" Ghost called out. "Charge to 250!"
"Let me resolve the fluid tamponade," I said. "We might lose him otherwise!"
"Do it!" Ghost ordered.
I worked as quickly as I could and aspirated the fluid in the pericardium.
"Blood in the pericardium!" I called out.
"Out of time!" Ghost declared. "Clear!"
Three shocks, two doses of epi, and one of atropine didn't help, as the patient's injuries were too significant to get him back.
"Time of death, 07:13," Ghost announced.
"Just too many things wrong at once," I observed. "McKnight will find at least three things that were fatal."
"I wouldn't doubt it," Ghost agreed. "Becky, death kit, please. John, you assist."
They both acknowledged him and Mary, Ghost, and I left the trauma room and were immediately approached by Deputy Kenseth.
"Didn't make it?" he asked.
"No," Ghost said. "Next of kin?"
"Scott Turner and Laurie Chapel are on their way to the address on his license."
"Do you have a name for the chart?"
"Max Lucas," Deputy Kenseth said. "I'm going to radio Scott and see where they are."
He stepped away, and I sent Mary back into the room to write the patient's name on the chart. I overheard the conversation Deputy Kenseth had with Deputy Turner, and they were already on their way to the hospital.
"Looks like we'll have to talk to the next of kin," I said to Ghost.
"I'll handle it," Ghost said. "I see several charts in the rack, which means Varma, Lincoln, and Lewis are swamped."
Mary returned, and I asked her to get a chart.
"Is Doctor Casper doing the notification?" Mary asked.
"Yes."
"You do realize on June 1st, I'm going to insist you teach me how to do those procedures."
"I do, and I wouldn't have it any other way!"
May 24, 1990, McKinley, Ohio
"I think I know those girls," I said to Kellie after lunch with Antonne and his study group.
"The two cute twins in the waiting room?" she asked. "They can't be a day over fifteen!"
I chuckled, "If they are who I think they are, they're seventeen and likely just finishing their Junior year of High School."
"How do you know that?"
"They see Doctor Forsberg as their OB/GYN, and came in for their annual exams when I was on my OB/GYN Preceptorship. Walk with me."
Kellie rolled her eyes and followed me to the beautiful twin girls.
"Hi, Mary; Hi, Martha," I said.
"Oooh!" Mary exclaimed. "It's the cute medical student!"
"I graduated about a year ago," I said.
"Well, you can examine me now!" Martha exclaimed.
Kellie rolled her eyes again.
"My wife would object," I said with a smile. "What brings you two here today?"
"My mom accidentally slammed her hand in the car door when she was picking us up from school after finals today," Mary said. "I drove her straight here from school."
"Saint Augustine, right?"
"How did you know?" Martha asked.
"An educated guess! And I'm sorry to cut this short, but I need to head to McKinley Medical School. My star student is graduating today."
"I'm sure there's a lot you could teach me!" Martha exclaimed.
"Have a good afternoon, girls. I hope your mom is OK."
"Thanks!" they both exclaimed.
Kellie and I walked back into the ER.
"Those two are dangerous!" Kellie said quietly.
"No kidding," I chuckled. "I figured that out when they were thirteen and said I was 'cuuuuute'."
"Mike?" Nate called out.
I walked over to the Clerk's desk.
"I'm just about to sign out for graduation."
"Mr. Crowe is on line 3 for you."
"Thanks."
I picked up the phone and pressed the blinking button.
"Mike Loucks," I said.
"Hi, Mike. Can you sit for a deposition on the Ken Webber suit tomorrow morning?"
"If you clear it with Doctor Wernher and Doctor Roth, yes."
"I'll take care of that. 9:00am in my conference room."
"I'll be there."
"Thanks."
After I hung up, I signed out and left the hospital to head to the medical school so I could see Mary graduate. I was happy to see Loretta, so I sat down next to her.
"How are the legs?"
"My therapist is the spawn of Satan," she growled.
"You said that on Sunday," I chuckled. "And the Sunday before that. And the Sunday before that."
"That doesn't make it any less true!"
"You seem to be getting around OK with the forearm crutches. When are you going to talk to Dutch Wernher?"
"I figure around August 1st. I need about twelve more weeks of therapy before my therapist will sign off. What do you think Wernher will say?"
"I don't know. He's tough, but fair. Make your case. You know all of us will support you, but if any of us were to go to Wernher, it would do more harm than good because he knows we're all partisans. That said, he will ask me."
"Because you're frenemies?" Loretta asked.
"That is what both of us want everyone to think, because it's in each of our best interests."
"Mike Loucks, schemer?"
"I have my agenda, Doctor Wernher has his. Where there is overlap, we coöperate; where there is disagreement, we each politely listen to each other. I am positive he prioritizes patient care, though he obviously has what Rachel's grandfather calls 'P&L responsibility'. I do not envy that for one second!"
"He's put you under close supervision, right?"
"You know as well as I do the rules are vague and subjective, and are that way for a reason. His actions weren't directed towards me or Mary."
"Are you sure about that?" Loretta asked.
"As sure as I can be. I'm reasonably sure who they were directed towards, and he's simply being consistent. I'm positive you remember what happened when I received preferential treatment."
"Which you deserved!"
"Agreed; you also have to admit that Northrup was pretty lax in his oversight of the ED. I mean, when did we ever see him take a case?"
"I don't believe I ever did," Loretta admitted.
"I'm sure I didn't," I replied.
The conversation had to end because Doctor Warren, the Dean of the medical school, walked up to the lectern to begin the ceremony. It was nearly identical to mine, and Mary gave an excellent valedictory speech, not all that different from mine with regard to a call to service. A few minutes later, her name was called, and she became 'Doctor Mary Anderson'. Thirty minutes later, she came to where I was standing next to Loretta.
"Congratulations, *Doctor* Anderson!" I exclaimed.
"Thanks, Doctor Mike!" she said, then gave me a tight hug. "Thank you for everything."
"You're welcome! And it's just Mike now when you're speaking to me."
"And Loretta for me!" Doctor Gibbs said. "Congratulations, Mary!"
"Thanks, Doctor Gibbs! I mean, Loretta! How are you doing?"
"Better each day, but as I said to Mike, my physical therapist is the spawn of Satan!"
Mary laughed, "I hear doctors make the worst patients."
"Ain't THAT the truth!" Shelly Lindsay declared, having walked over.
Sophia and Robby came up to me, and Sophia and I exchanged a hug.
"Congratulations!" I said.
"Thanks, but I don't relish being away from you and everyone after seven years together."
"It's not something I want, but it's necessary for the next stage in your lives."
"It is," Sophia agreed.
A few minutes later, Erin Jackson walked over, and I congratulated her as well. The scene repeated itself several times with other newly minted doctors before I had to head back to the hospital to complete my shift.
May 25, 1990, McKinley, Ohio
On Friday morning, I worked three hours in the ED before heading to the conference room next to Mr. Crowe's office for my deposition in the wrongful death suit filed by Ken Webber's family.
"Remember, just answer factually and avoid speculation. I guarantee Miss Temple will ask speculative questions, and you cannot refuse to answer. You can, on the other hand, decline to speculate. What she will likely do then is ask hypotheticals, and you will need to formulate some kind of answer. Remember, this is a civil, not criminal, case, so you cannot refuse to answer any even tangentially relevant question, and your ability to use the Fifth Amendment protections is severely limited."
"I'm aware, and yes, I know you have to remind me."
"I was also notified that Arthur Braun will participate in today's deposition."
"Of course he will," I said with resignation. "I appear to be his special project."
"Don't let him rattle you; stay calm, cool, and collected. He has nothing on you."
"Which doesn't mean he won't try to imply I did something wrong! As you said, I'd be the worst witness for them."
Mr. Crowe's secretary ushered in a stenographer and videographer who set up, and then about ten minutes later, Amanda Temple and Arthur Braun arrived.
"Good morning, Doctor," Mr. Braun said. "It's good to see you again."
"Good morning, Mr. Braun."
"This is one of our partners, Amanda Temple, who will conduct the deposition, though I may ask questions of my own."
"Shall we begin?" Mr. Crowe suggested.
"The oath, please," Ms. Temple said to the court reporter.
"I prefer to affirm," I said.
She nodded, then said, "Do you affirm that you will tell the truth, the whole truth, and nothing but the truth?"
"I do," I replied.
"Then let's begin," Ms. Temple said.
As with the other depositions I'd given, it began with my full name, address, birthdate, education, profession, and employer.
AT: You've been a Resident for a year?
ML: Correct.
AT: All that time at Moore Memorial Hospital?
ML: Yes.
AT: Have you had any training besides McKinley Medical School or Moore Memorial Hospital?
ML: I had one clinical rotation as a visiting student at Good Samaritan Hospital in Norwood. I also had a one-day paramedic course so I could ride along with Hayes County Paramedics for a week.
AT: What training did you receive at Good Samaritan?
ML: It was my OB/GYN Clerkship — the required obstetrics and gynecology rotation during Third Year.
AT: Is that typical?
ML: Being a visiting student is common; my advisor actually recommended doing two stints as a visiting student, or a triple with a charity doctors' group. Given my other obligations, that wasn't possible.
AT: You said you're a surgical Resident; why are you assigned to the ER?
ML: I said I was a Resident in trauma surgery; that's a new specialty which combines surgery and emergency medicine, and allows for more efficient treatment of patients, as well as quicker response when surgical procedures are needed in the Emergency Department.
AT: What kind of procedures are those?
ML: Central lines, which are basically large-bore IVs inserted into veins in the neck or chest; pericardiocentesis, which means aspirating excess fluid from the sac around the heart with a needle; thoracotomy, which is, in layman's parlance, a 'chest tube', used to reinflate a lung; and escharotomy, which is using a scalpel to relieve pressure from burned flesh that interferes with circulation or breathing. I'm also qualified to perform all other emergency room procedures, and I'm tasked with assessing patients for surgery and admitting them if necessary.
AT: You say it's a new specialty; how long has it existed?
ML: I'm the first Resident in trauma surgery at Moore Memorial, so it's been active for a year. Similar programs have existed slightly longer at Indiana University Hospital and University of Chicago Hospital.
AT: You're required to be supervised, are you not?
ML: I am. An Attending physician has to sign all discharge or admission orders. For anything except admission to surgery, that would be an Attending in the Emergency Department; for surgery, that would be the Attending surgeon who will perform the surgery or the Chief Surgeon.
AT: As part of your duties, do you teach medical students?
ML: I do. Usually one Fourth Year and one Third Year, but things have varied a bit due to the shootings at the hospital earlier this year.
AT: On the day in question, you were training a Fourth Year named Mary Anderson?
ML: I was.
AT: And you allowed her to perform the examination on Mr. Webber?
ML: Yes, under my direct supervision at all times.
AT: Has she ever performed any procedures without you directly supervising?
ML: Medical students are allowed to suture simple wounds, and my students have all done that. I assess the wound and, if it's within their skill level, allow them to suture; then I check their work when they finish.
AT: The question was, has she ever done anything without your direct supervision?
ML: Before Doctor Wernher became Chief of Emergency Medicine, medical students were allowed to conduct an H&P – history and physical — without direct supervision.
AT: Are all your charts signed by an Attending?
ML: Yes.
AT: You were never allowed to operate independently?
ML: I was lightly supervised by the Attendings, but in every case, an Attending signed my charts. That's a legal requirement.
AT: But sometimes it was after the fact, right?
ML: Before Doctor Wernher arrived, charts were reviewed and signed by Attendings some time after a patient was admitted or discharged.
AT: Would you call the procedures lax?
ML: No. I had all the support and supervision necessary to be successful.
AT: If that's the case, why would Doctor Wernher feel the need to change things?
ML: You'll have to ask him.
AT: Did you discuss the changes with him?
ML: Yes.
AT: Including organizing a strike by the nurses?
ML: I was aware of the nurses' intent to strike, but I did not organize it.
AT: Did you support their wildcat strike?
ML: I felt they had a legitimate grievance.
AT: Because of Doctor Wernher?
ML: He made a pair of ill-considered changes which he quickly rescinded. One of them was about the lounge; the other was about breaks for nurses.
LC: You're wandering far afield here.
AB: We're allowed latitude to discover how the hospital operates generally, and the ER and surgery specifically.
LC: That is true, but we are strictly enforcing the ninety-minute limit for each deposition. Doctor Mike needs to return to his work.
AB: You know we can ask the judge for more time.
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