Dr. Siva Arunasalam - The Patient Safety League4patientsafety.org/documents/Arunasalam, Siva...

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 1 VICTORVILLE, CALIFORNIA; THURSDAY, OCTOBER 6, 2005 A. M. SESSION DEPARTMENT V-10 HON. STANFORD E. REICHERT, JUDGE APPEARANCES: DESERT VALLEY HOSPITAL WAS REPRESENTED BY ITS COUNSEL, DEBORAH S. TROPP AND MICHAEL J. SARRAO, ATTORNEYS AT LAW; TINA BUCHANAN AND LISA CROUCH WERE REPRESENTED BY THEIR COUNSEL, VINCENT P. NOLAN, ATTORNEY AT LAW. (FRED BERZAK, OFFICIAL REPORTER, CSR NO. 5815.) -O0O- SIVA ARUNASALAM, CALLED AS A WITNESS BY THE PLAINTIFF AND CROSS-DEFENDANT, HAVING BEEN FIRST DULY SWORN, WAS EXAMINED AND TESTIFIED AS FOLLOWS: THE COURT ATTENDANT: PLEASE STATE AND SPELL YOUR NAME FOR THE RECORD. THE WITNESS: SIVA ARUNASALAM, S-I-V- A, A-R-U-N- A-S-A -L-A -M. THE COURT: THANK YOU. GO AHEAD , PLEASE, MISS TROPP. MISS TROPP: THANK YOU, YOUR HONOR. DIRECT EXAMINATION BY MS. TROPP. Q DOCTOR, I'LL CALL YOU DOCTOR SIVA. IS THAT ALL

Transcript of Dr. Siva Arunasalam - The Patient Safety League4patientsafety.org/documents/Arunasalam, Siva...

Page 1: Dr. Siva Arunasalam - The Patient Safety League4patientsafety.org/documents/Arunasalam, Siva 2005-10-06... · 2018-03-08 · siva arunasalam, called as a witness by the plaintiff

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VICTORVILLE, CALIFORNIA; THURSDAY, OCTOBER 6, 2005

A.M. SESSION

DEPARTMENT V-10 HON. STANFORD E. REICHERT, JUDGE

APPEARANCES:

DESERT VALLEY HOSPITAL WAS REPRESENTED

BY ITS COUNSEL, DEBORAH S. TROPP AND

MICHAEL J. SARRAO, ATTORNEYS AT LAW;

TINA BUCHANAN AND LISA CROUCH WERE

REPRESENTED BY THEIR COUNSEL,

VINCENT P. NOLAN, ATTORNEY AT LAW.

(FRED BERZAK, OFFICIAL REPORTER, CSR NO. 5815.)

-O0O-

SIVA ARUNASALAM,

CALLED AS A WITNESS BY THE PLAINTIFF AND CROSS-DEFENDANT,

HAVING BEEN FIRST DULY SWORN, WAS EXAMINED AND TESTIFIED AS

FOLLOWS:

THE COURT ATTENDANT: PLEASE STATE AND SPELL YOUR

NAME FOR THE RECORD.

THE WITNESS: SIVA ARUNASALAM, S-I-V-A,

A-R-U-N-A-S-A-L-A-M.

THE COURT: THANK YOU.

GO AHEAD, PLEASE, MISS TROPP.

MISS TROPP: THANK YOU, YOUR HONOR.

DIRECT EXAMINATION

BY MS. TROPP.

Q DOCTOR, I'LL CALL YOU DOCTOR SIVA. IS THAT ALL

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RIGHT?

A PLEASE DO.

Q IS THAT WHAT YOU'RE CALLED?

A YES.

Q DOCTOR SIVA, ARE YOU AFFILIATED WITH THE HEART

INSTITUTE OF THE HIGH DESERT?

A YES.

Q WHAT IS YOUR AFFILIATION WITH THAT ORGANIZATION?

A I'M THE FOUNDER AND THE DIRECTOR OF THE HEART

INSTITUTE.

Q WHERE'S THE HEART INSTITUTE LOCATED?

A IN VICTORVILLE.

Q HOW LONG HAS THE HEART INSTITUTE OF THE HIGH DESERT

BEEN IN EXISTENCE?

A FOR ABOUT 10 YEARS.

Q DID YOU START THAT 10 YEARS AGO?

A THAT'S CORRECT.

Q SIR, WHAT TYPE OF PHYSICIAN ARE YOU?

A I'M A CARDIOLOGIST.

Q ARE YOU BOARD CERTIFIED?

A YES.

Q IN WHAT FIELDS?

A INTERNAL MEDICINE, CARDIOLOGY, AND INTERVENTIONAL

CARDIOLOGY.

Q WHAT'S THE DIFFERENCE BETWEEN CARDIOLOGY AND

INTERVENTIONAL CARDIOLOGY?

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A IN CARDIOLOGY YOU GO THROUGH INITIALLY ONE YEAR OF

INTERNSHIP AND TWO YEARS OF INTERNAL MEDICINE TRAINING. YOU

HAVE TO BE CERTIFIED IN INTERNAL MEDICINE. THEN YOU GO

THROUGH THREE YEARS OF CARDIOLOGY FELLOWSHIP. AFTER YOU DO

THAT, YOU HAVE TO DO ONE ADDITIONAL YEAR OF INTERVENTIONAL

CARDIOLOGY.

Q THE TYPE OF INTERVENTION THAT YOUR ARE SPEAKING OF

WOULD BE PROCEDURES SUCH AS WHAT?

A ANYTHING AND EVERYTHING TO DO WITH CATHETER-BASED

INTERVENTION, ANYTHING FROM THE CAROTIDS TO THE CORONARY

ARTERIES TO THE LEG, TO THE RENALS. ANYWHERE THE BLOOD FLOWS

WE'RE ABLE TO GO IN WITH CATHETERS AND INTERVENE.

Q HOW LONG HAVE YOU BEEN PRACTICING CARDIOLOGY?

A FOR 10 YEARS.

Q CAN YOU TELL US WHERE YOU WENT TO MEDICAL SCHOOL,

SIR.

A EMORY UNIVERSITY IN ATLANTA.

Q WHERE DID YOU DO YOUR INTERNSHIP AND RESIDENCY?

A HARBOR-UCLA IN TORRANCE.

Q DID YOU DID A FELLOWSHIP?

A YES.

Q WHAT WAS YOUR FELLOWSHIP IN?

A I DID A CRITICAL CARE FELLOWSHIP AT CEDARS-SINAI IN

LOS ANGELES. THEN I FOLLOWED IT WITH A THREE-YEAR FELLOWSHIP

IN CARDIOLOGY ALSO AT CEDARS-SINAI.

Q TAKING A BRIEF LOOK HERE AT YOUR CV, YOU GOT OUT OF

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COLLEGE IN 1980?

A THAT'S CORRECT.

Q AND STUDIED MEDICINE FROM 1980 TO 1994?

A THAT IS CORRECT.

Q 14 YEARS?

A YES.

Q YOU KNOW DOCTOR PREM REDDY?

A YES.

Q WHEN DID YOU FIRST MEET HIM?

A PROBABLY ABOUT 10 YEARS AGO.

Q WHEN YOU CAME TO THE AREA?

A ABOUT SIX MONTHS OR SO AFTER I CAME TO THE AREA.

Q YOU DID NOT KNOW HIM BEFORE THAT?

A NO.

Q WHEN YOU CAME TO THE AREA AND MET DOCTOR REDDY, WHAT

WAS HE DOING HERE?

A AT THAT TIME HE ALREADY HAD BUILT HIS HOSPITAL. HE

WAS PRACTICING CARDIOLOGY.

Q DO YOU HAVE A PROFESSIONAL RELATIONSHIP WITH DOCTOR

REDDY?

A YES.

Q DO YOU HAVE A SOCIAL RELATIONSHIP WITH HIM?

A NO.

Q DO YOU KNOW DOCTOR PANCH JEYAKUMAR?

A YES.

Q DID DOCTOR PANCH JEYAKUMAR EVER WORK FOR YOU, SIR?

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A YES.

Q CAN YOU TELL US WHEN.

A APPROXIMATELY FIVE YEARS AGO WHEN DESERT VALLEY WAS

SOLD TO PHYCOR AT THAT TIME AND HE LEFT THERE AS MEDICAL

DIRECTOR AND JOINED ME FULL-TIME AS A PULMONOLOGIST.

Q HE WORKED AS A PULMONOLOGIST AT THE HEART INSTITUTE?

A YES.

Q HAD YOU KNOWN DOCTOR JEYAKUMAR BEFORE THAT?

A YES.

Q IN WHAT CAPACITY?

A AS THE MEDICAL DIRECTOR OF DESERT VALLEY HOSPITAL.

Q SIR, DO YOU HAVE PRIVILEGES AT DESERT VALLEY

HOSPITAL?

A YES.

Q PRIVILEGES TO DO INTERVENTIONAL CARDIOLOGY IN THEIR

CATH LAB?

A YES.

Q WHEN DID YOU FIRST ACQUIRE PRIVILEGES AT DESERT

VALLEY HOSPITAL?

A TEN YEARS AGO.

Q HAVE THEY EVER BEEN SUSPENDED OR REVOKED?

A NO.

Q HAVE THEY BEEN IN EXISTENCE CONSISTENTLY SINCE THEN?

A YES.

Q WHEN DOCTOR JEYAKUMAR CAME AND WORKED FOR YOU, DID

YOU HIRE SOMEBODY ELSE AT HIS RECOMMENDATION?

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A YES.

Q WHO WAS THAT?

A LISA CROUCH.

Q DID DOCTOR JEYAKUMAR BRING YOU LISA CROUCH AS A

PROSPECTIVE EMPLOYEE?

A AFTER HE CAME AND JOINED ME, ABOUT A MONTH LATER I

NEEDED AN RN, AND HE RECOMMENDED HER AS AN EMPLOYEE; SO I SAID

YES.

Q HOW LONG DID DOCTOR JEYAKUMAR WORK FOR YOU?

A ABOUT 12 MONTHS.

Q DO YOU KNOW WHY HE LEFT AFTER 12 MONTHS?

A PERSONAL REASONS.

Q HOW LONG DID MISS CROUCH WORK FOR YOU?

A ABOUT 10 MONTHS.

Q AFTER DOCTOR JEYAKUMAR LEFT, DID MISS CROUCH LEAVE

YOUR EMPLOYMENT AS WELL?

A THAT'S CORRECT.

Q HAVE YOU EVER BEEN EMPLOYED BY DESERT VALLEY MEDICAL

GROUP?

A NO.

Q YOU DON'T HAVE AN OFFICE IN ANY OF THE DESERT VALLEY

MEDICAL GROUP BUILDINGS?

A I SEE SOME OF THEIR PATIENTS IN THE CARDIOLOGY

DEPARTMENT, BUT I DO NOT HAVE AN OFFICE THERE. MY OFFICE IS

IN THE HEART INSTITUTE.

Q YOU HAVE NEVER HELD CLINICAL HOURS THERE ON A

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REGULAR BASIS?

A OFF AND ON I HAVE DONE SO OVER THE LAST 10 YEARS.

WHENEVER THEY HAVE NEEDED HELP I HAVE PROVIDED THEM HELP.

Q WHEN HAVE YOU BEEN ASKED TO HELP OUT AT DESERT

VALLEY?

A SIX SEPARATE OCCASIONS.

Q OVER WHAT YEARS AND FOR HOW LONG?

A IN 1995 THEY ASKED ME TO HELP BECAUSE ONE OF THEIR

CARDIOLOGISTS LEFT. THEY WERE SHORTHANDED, AND I HELPED THEM

FOR ABOUT SIX MONTHS. THEN I THINK IN 1998 FOR ABOUT SIX

MONTHS AGAIN. THEN IN 2000 AND 2001. I'M NOT VERY FAMILIAR

WITH THE DATES.

ABOUT FOUR OR FIVE TIMES THE CARDIOLOGISTS WERE IN

TRANSITION OR LEAVING THE AREA SO THEY NEEDED HELP, AND I WAS

ABLE TO PROVIDE THEM WITH HELP.

Q WHEN YOU WERE CALLED TO HELP, WHO WAS IT THAT

TYPICALLY CALLED YOU?

A DOCTOR JEYAKUMAR.

Q WHEN YOU HELPED OUT IF THERE WAS A SHORTAGE OF

CARDIOLOGISTS, WHAT DID YOU DO FOR THE GROUP OR THE HOSPITAL?

A ESSENTIALLY CONSULTATIONS IN THE HOSPITAL, EMERGENCY

ROOM COVERAGE FOR CARDIOLOGY AND ALSO IN THE CLINIC.

Q WHEN IS THE LAST TIME THAT YOU FILLED IN, SO TO

SPEAK, AT DESERT VALLEY MEDICAL GROUP AND HOSPITAL AS A

CARDIOLOGIST?

A I'M FILLING IN RIGHT NOW.

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Q BUT YOU HAVE NEVER BEEN EMPLOYED BY THE GROUP?

A I HAVE NOT BEEN EMPLOYED BY THE GROUP. I HAVE A

CONTRACT WITH THEM IN TERMS OF PROVIDING SERVICES, BUT I'M NOT

UNDER THEIR EMPLOYMENT.

Q DID YOU KNOW LISA CROUCH WHEN SHE WAS THE DIRECTOR

OF THE EMERGENCY ROOM AT DESERT VALLEY HOSPITAL?

A YES.

Q DID YOU EVER HAVE AN ISSUE WITH MISS CROUCH WHEN SHE

WAS THE DIRECTOR OF THE EMERGENCY ROOM REGARDING A PATIENT?

A A RUN-IN YOU MEAN?

Q SO TO SPEAK.

A YES.

Q COULD YOU TELL US ABOUT THAT.

A THIS WAS LIKE ON A WEDNESDAY. I GOT A CALL FROM THE

EMERGENCY ROOM AT DESERT VALLEY HOSPITAL, AND WAS WAS LISA ON

THE OTHER LINE STATING THAT A PATIENT OF MINE FROM BARSTOW WAS

SENT BY ME BY PRIVATE CAR, AND THE PATIENT ARRIVED ALMOST IN

DIRE STRAITS IN THE EMERGENCY ROOM. SHE STATED THE PATIENT'S

NAME. I SAID, "THIS DOESN'T SOUND LIKE MY PATIENT. THIS

DOESN'T SOUND LIKE SOMETHING THAT I WOULD DO." AND I SAID,

"LET ME CHECK ON THIS."

I CALLED HER BACK ABOUT 10 MINUTES LATER BECAUSE THE

PATIENT WAS NOT IN MY COMPUTER, AND I SAID, "THIS PATIENT DOES

NOT BELONG TO ME. WHAT IS THE SITUATION WITH THE PATIENT?"

SHE TOLD ME THE PATIENT'S HEMOGLOBIN WAS SIX, WHICH

MEANS THE PATIENT WAS BLEEDING INTERNALLY, AND THE PATIENT WAS

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HYPOTENSIVE. THAT MEANS THEIR BLOOD PRESSURE WAS VERY LOW.

SHE WAS IN THE EMERGENCY ROOM IN FRONT OF ALL THE

PEOPLE IN THE EMERGENCY ROOM ESSENTIALLY BERATING ME FOR THE

CARE I WAS GIVING THE PATIENT. "HOW DARE YOU SEND THIS

PATIENT TO THE EMERGENCY ROOM WHEN THE PATIENT WAS CRITICALLY

ILL?"

I STOPPED HER RIGHT THERE, AND I SAID, "THIS IS NOT

MY PATIENT. YOU HAVE DONE GRANDSTANDING HERE. YOU KNOW THAT

THERE IS ANOTHER DOCTOR SIVA IN THE HIGH DESERT THAT BELONGS

TO DESERT VALLEY. ASK THE PATIENT WHETHER THE PATIENT BELONGS

TO THAT PHYSICIAN OR ME."

AND SHE CAME BACK AND SAID, "YES, THE PATIENT

BELONGS TO THE OTHER PHYSICIAN."

SO I SAID, "BEFORE YOU JUMP TO CONCLUSIONS AND

ACCUSE ME AND RUIN MY REPUTATION, YOU HAVE GOT TO CHECK YOUR

FACTS." AND I HUNG UP ON HER, AND I WROTE A MEMO TO DOCTOR

JEYAKUMAR AT THAT TIME TELLING HIM THAT ANOTHER PHYSICIAN WAS

USING MY NAME SIVA JUST LIKE I HAVE BEEN USING HERE FOR THE

LAST 10 YEARS, AND THAT'S CAUSING A LOT OF CONFLICT IN TERMS

OF PATIENT CARE ISSUES. PATIENTS ARE GETTING CONFUSED, AND

THESE KIND OF ISSUES IS RUINING MY REPUTATION AND WILL NOT BE

TOLERATED. IT WENT UNHEEDED.

Q DID YOU TELL DOCTOR JEYAKUMAR IN THE LETTER THAT YOU

WROTE HIM THE ISSUE THAT YOU HAD WITH MISS CROUCH ON THE

PHONE?

A YES.

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Q DID DOCTOR JEYAKUMAR EVER CALL YOU BACK AND DISCUSS

THIS WITH YOU?

A NO.

Q YOU KNOW DOCTOR AHMED?

A YES.

Q YOU KNOW DOCTOR RAZA?

A YES.

Q IN WHAT CAPACITY DO YOU KNOW THOSE GENTLEMEN?

A AS CARDIOLOGISTS IN THE HIGH DESERT.

Q HAVE YOU WORKED WITH DOCTOR AHMED BEFORE?

A YES.

Q WHAT IS YOUR IMPRESSION OF DOCTOR AHMED AS A

CARDIOLOGIST?

A IF I HAVE NOTHING GOOD TO SAY ABOUT SOMEBODY, I'D

RATHER NOT SAY. BUT IF YOU INSIST, I WILL.

Q DID YOU KNOW DOCTOR AHMED WHEN HE WAS WORKING AT

DESERT VALLEY HOSPITAL?

A YES.

Q HAVE YOU WORKED WITH HIM DIRECTLY?

A YES, I HAVE.

Q I DO WANT TO HEAR WHAT YOU HAVE TO SAY.

A DOCTOR AHMED IS LAZY, AND BECAUSE OF HIS LAZINESS,

HE'S DANGEROUS TO PATIENTS. THAT HAS BEEN BROUGHT UP ON MANY

ISSUES. AND I HAVE HAD PATIENT CARE ISSUE AFTER PATIENT CARE

ISSUE. AND IT COMES THROUGH NOT RESPONDING TO CALLS WHEN

PATIENTS ARE IN DIRE STRAITS, AND, THEREFORE, PATIENTS HAVE

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BAD OUTCOMES BECAUSE OF THOSE ISSUES.

Q THERE'S SOME EVIDENCE IN THIS CASE THAT DOCTOR AHMED

DID NOT RESPOND TO PAGES FOR PATIENTS IN THE ER AT LATE HOURS.

DO YOU HAVE ANY PERSONAL EXPERIENCE WITH HIM IN THAT REGARD?

A ABSOLUTELY.

Q WHAT IS THAT EXPERIENCE?

A THIS WAS ON A SATURDAY ABOUT SIX MONTHS AGO.

PATIENT WAS CAPTAIN OF THE POLICE DEPARTMENT IN BARSTOW. IT

WAS HIS PATIENT. PATIENT CAME IN ACUTE M.I. HE COULD NOT BE

REACHED, REFUSED TO COME TO EMERGENCY ROOM, AND PATIENT

ARRESTED ON TWO SEPARATE OCCASIONS.

Q CARDIAC ARREST?

A YES.

I HAPPENED TO BE BY THE EMERGENCY ROOM. THE

PHYSICIANS IN THE EMERGENCY ROOM REQUESTED WHETHER I CAN DO

SOMETHING ABOUT IT OR NOT. AND I HAD TO TAKE THE PATIENT TO

THE CATH LAB AND PERFORM AN INTERVENTION.

Q DID YOU FILL IN AT DESERT VALLEY HOSPITAL AFTER

DOCTOR AHMED LEFT AS A CARDIOLOGIST?

A I DID NOT FILL IN AFTER DOCTOR AHMED LEFT AS

CARDIOLOGIST. I FILLED IN AFTER DOCTOR RAZA LEFT AS

CARDIOLOGIST.

Q DO YOU HAVE PERSONAL EXPERIENCING IN WORKING WITH

DOCTOR RAZA?

A YES.

Q WHAT'S YOUR EXPERIENCE WITH WORKING WITH DOCTOR

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RAZA?

A SIMILAR TYPE OF EXPERIENCE THAT I HAVE WORKED WITH

DOCTOR AHMED.

Q DOCTOR RAZA TESTIFIED IN THIS COURT THAT HE BELIEVES

THAT DOCTOR REDDY'S CARDIOLOGY SKILLS ARE LACKING, THEY'RE

OLD. DO YOU KNOW DOCTOR REDDY AS A PRACTICING CARDIOLOGIST?

A YES, I DO.

Q BEFORE I ASK YOU ABOUT DOCTOR REDDY'S SKILLS, TELL

ME ABOUT DOCTOR RAZA'S CARDIOLOGY SKILLS.

A AS A CARDIOLOGIST, WE'RE LIKE SURGEONS. WE ALL HAVE

TREMENDOUS AMOUNT OF EGO. I HAVE LOTS OF EGO. I TAKE PRIDE

IN WHAT I DO. IF YOU DON'T HAVE THAT KIND OF PRIDE IN THE

WORK THAT YOU DO, THEN YOU'RE NOT VERY GOOD BECAUSE YOU HAVE

TO TAKE PRIDE. I PRIDE MYSELF IN WHAT I KNOW. IF I DO NOT

KNOW SOMETHING, I'LL ALWAYS SEEK HELP. I'LL GIVE YOU AN

EXAMPLE.

PATIENT OF MINE WITH SEVERE HEART FAILURE COMES TO

ME AND NEEDS HELP. HE HAS GONE TO SEVERAL OTHER

CARDIOLOGISTS. WE PUT HIM ON A THERAPY OF TREATMENT CALLED

NATRECOR INFUSION. IT'S A DRUG THAT HAS BEEN APPROVED BY THE

FDA FOR THE LAST THREE YEARS. SO WE HAVE IMPLEMENTED A

PROGRAM OF PATIENTS WHO ARE IN SEVERE HEART FAILURE WHO HAVE

TAKEN ALL OTHER THERAPY. THEY'RE NOT A CANDIDATE FOR

TRANSPLANT BECAUSE THEY'RE OVER 80 YEARS OLD. THEN WE PUT

THEM ON THIS THERAPY TO HELP THEIR QUALITY OF LIFE.

THIS PATIENT BEFORE SUBMITTING TO THE THERAPY WANTED

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TO GET A SECOND OPINION; SO HE GOES TO DOCTOR RAZA. HE TELLS

THIS PATIENT THAT I'M EXPERIMENTING ON HIM. THE PATIENT COMES

BACK AND TELLS ME, "YOU ARE TRYING TO EXPERIMENT ON ME."

AND I LOOKED AT HIM AND SAID, "SIR, HERE'S THE PDR.

HERE'S THE DRUG THAT I'M GOING TO USE ON YOU. IF THE PDR HAS

IT, THE FDA HAS APPROVED THIS DRUG."

Q PDR MEANING PHYSICIANS' DESK REFERENCE?

A THAT'S CORRECT.

Q A LARGE BOOK WITH LOTS OF DRUGS IN IT?

A THAT'S CORRECT.

THAT DRUG IS IN THE PDR, WHICH MEANS IT'S ALREADY

BEEN AVAILABLE FOR AT LEAST 12 MONTHS IF NOT LONGER BEFORE IT

MAKES IT INTO THE BOOK. THIS DRUG HAS BEEN APPROVED FOR THREE

YEARS FOR THAT PURPOSE.

I SENT THE DRUG REP TO DOCTOR RAZA'S OFFICE TO

EDUCATE HIM AND ESSENTIALLY TOLD HIM THAT AT TIMES IT'S BETTER

TO KEEP ONE'S MOUTH SHUT AND LET PEOPLE WONDER IF YOU'RE A

FOOL RATHER THAN TO OPEN IT AND REMOVE ALL DOUBTS. THIS IS

WHAT I SAID. IT WAS RELATED TO HIM IN SO MANY WORDS. SO

BEFORE HE STARTS POINTING FINGERS AT OTHER PEOPLE'S CLINICAL

SKILLS, HE NEEDS TO OWN UP ON HIS OWN SKILLS.

I HAVE NO LOVE LOST WITH DOCTOR RAZA. HE'S ACCUSED

ME OF STEALING PATIENTS, AND I HAVE TOLD HIM MANY TIMES

"PATIENTS LEAVE YOU TO COME AND SEE ME BECAUSE YOU DON'T

PROVIDE THE RIGHT CARE. YOU HAVE TO BE AVAILABLE FOR PATIENTS

WHEN THEY NEED YOU, NOT WHEN IT'S CONVENIENT FOR YOU."

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SO WE HAVE NEVER SEEN EYE TO EYE.

Q WHAT DO YOU KNOW OF DOCTOR REDDY'S CARDIOLOGY

SKILLS?

A I HAVE OBSERVED HIS CLINICAL SKILLS IN TERMS OF

TAKING CARE OF PATIENTS. I HAVE DISCUSSED CASES WITH HIM.

OTHER THAN MYSELF, WHICH I PRIDE MYSELF -- I'M NOT POMPOUS. I

PRIDE MYSELF IN TERMS OF MY CLINICAL SKILLS, WHICH HAVE GROWN

WELL IN THIS COMMUNITY. I THINK DOCTOR REDDY'S THE ONLY OTHER

CARDIOLOGIST I'LL TRUST IN THIS COMMUNITY. I HAVE NO DOUBTS

IF I'M SICK OR IF ONE OF MY FAMILY MEMBERS IS SICK, I'LL

READILY SEND MY PATIENTS TO HIM.

Q HAS YOUR RELATIONSHIP WITH DOCTOR REDDY ALWAYS BEEN

SMOOTH?

A ABSOLUTELY NOT.

Q CALL ME CRAZY, BUT I'M THINKING YOUR EGOS HAVE

CLASHED BEFORE.

A MANY TIMES.

Q OVER WHAT TYPES OF THINGS?

A MANY THINGS. PATIENT CARE, ISSUES IN TERMS OF

SOMETIMES MY PATIENTS ARE NOT CALLED WHEN THEY COME TO THE

EMERGENCY ROOM. THOSE KINDS OF ISSUES THAT I CLASHED WITH

HIM.

IN TERMS OF ISSUES WITH DOCTOR RAZA, I HAVE CLASHED

WITH HIM. IN TERMS OF DOCTOR AHMED, I HAVE CLASHED WITH HIM.

AND IN TERMS OF HIS MEDICAL DIRECTOR WHO WAS HERE TESTIFYING,

I HAVE CLASHED WITH HIM MANY, MANY TIMES.

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Q DOCTOR THACKER?

A THAT'S CORRECT.

Q WE ACTUALLY SAW A THREE-PAGE LETTER THAT DOCTOR

THACKER WROTE TO YOU CRITICIZING YOUR CARE OF A PATIENT.

A THAT'S BECAUSE I WROTE TO THEM IN A NASTY MANNER OF

THE CARE THAT WAS DELIVERED TO ONE OF MY PATIENTS AT DESERT

VALLEY HOSPITAL.

Q DOCTOR THACKER, AS THE MEDICAL DIRECTOR, HAS THE

RIGHT TO REVOKE THE PRIVILIGES OF DOCTORS AT DESERT VALLEY

HOSPITAL?

A THAT IS CORRECT.

Q WERE YOUR PRIVILEGES EVER REVOKED BECAUSE OF THAT

LETTER OR ANY INVESTIGATION?

A NO.

Q NOW, YOU HAVE CLASHED WITH DOCTOR REDDY BEFORE.

HAVE YOU ARGUED WITH HIM?

A NO.

Q JUST MEDICAL JUDGMENT CLASHING?

A YES, YOU CAN CALL IT THAT. I HAVE NEVER HAD AN

ARGUMENT WITH HIM. I NEVER HAD WORDS WITH HIM. THROUGH THIRD

PARTIES I HAVE EXPRESSED MY OPINIONS.

Q SIR, ARE YOU IN THE PROCESS OF ATTEMPTING TO BUILD A

HOSPITAL IN THE AREA?

A NOT ATTEMPTING. I'M GOING TO BUILD A HOSPITAL IN

THE AREA.

Q WHERE?

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A IT'S GOING TO BE IN APPLE VALLEY AT THE CORNER OF

APPLE VALLEY AND BEAR VALLEY ROAD WHERE THE LOWE'S IS BEING

BUILT RIGHT NOW. IT'S NEXT DOOR TO IT.

Q WHY ARE YOU BUILDING A HOSPITAL?

A THERE'S A TREMENDOUS SHORTAGE OF BEDS. THERE'S

APPROXIMATELY A 400 BED SHORTAGE AT THIS POINT. WHENEVER I

NEED TO GET CERTAIN THINGS DONE, PATIENTS ARE NOT ABLE TO GET

THOSE SERVICES BECAUSE THERE'S A SHORTAGE OF BEDS. THAT'S THE

REASON WHY.

Q YOU HAVE HAD PRIVILEGES BEFORE AT SAINT MARY'S

HOSPITAL?

A THAT'S CORRECT.

Q HAVE YOU HAD ISSUES WITH SAINT MARY'S HOSPITAL AS A

RESULT OF YOUR BUILDING A HOSPITAL?

A THIS GOES BACK THREE YEARS AGO WHEN I WENT TO SAINT

MARY'S AND SAID, "LET'S DO A JOINT PROJECT." SAINT MARY'S

HIRED ME AND BROUGHT ME TO THE HIGH DESERT. SISTER DIANE

ASKED ME TO COME UP HERE. I'M VERY PARTIAL TO SAINT MARY'S.

WITHOUT THEM I WOULDN'T BE HERE, AND WITHOUT THEM I WOULDN'T

BE AS SUCCESSFUL AS I AM TODAY; SO I OWE A LOT TO THEM.

THREE YEARS AGO I WENT TO THEM AND SAID, "THERE'S A

SHORTAGE OF A LOT OF SERVICES THAT WE NEED IN THE AREA THAT WE

DON'T HAVE. LET'S DO A JOINT PROJECT. I HAVE THE FUNDING.

THE BANKERS IN THE COMMUNITY WILL BE ABLE TO FUND THIS. THEY

HAVE ALREADY PROMISED ME THE FUNDING. ALL I NEED IS A BIG

BROTHER TO KIND OF HELP ME ALONG."

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THEY SAID THEY WOULD, AND BEHIND MY BACK THEY WENT

AND TOLD ALL THE FINANCIAL SUPPORTERS NOT TO SUPPORT ME. WHEN

THAT HAPPENED, I WENT BACK TO THEM AND SAID, "YOU DON'T NEED

TO SUPPORT ME. I'LL DO IT ON MY OWN."

WHEN THAT HAPPENED, THE PREVIOUS CEO THREATENED ME.

HE ESSENTIALLY THREATENED TO REVOKE MY PRIVILEGES IN THE

HOSPITAL. AND IT SO HAPPENS THAT WE'LL TAKE LEGAL ACTION

AGAINST THEM.

Q DOES DOCTOR REDDY KNOW YOU'RE BUILDING A HOSPITAL?

A YES.

Q HAS DOCTOR REDDY HAD CONVERSATIONS WITH YOU ABOUT

THE FACT YOU'RE GOING TO BE A DIRECT COMPETITOR WITH HIM?

A HE SAID, "I CANNOT BE HYPOCRITICAL. SINCE I BUILT A

HOSPITAL, IF SOMEBODY ELSE WANTS TO BUILD A HOSPITAL, I CAN'T

STAND IN THEIR WAY."

Q HAS HE EVER TOLD YOU THAT HE WILL REVOKE YOUR

PRIVILEGES FOR BUILDING A HOSPITAL?

A AS A MATTER OF FACT, HE'S MADE ME THE MEDICAL

DIRECTOR AND THE DIRECTOR OF HIS CATH LAB.

Q DOCTOR SIVA, DO YOU RECALL MEETING WITH ME THE OTHER

NIGHT AND GOING OVER THIS PARTICULAR CHART, SIR?

A BRIEFLY, YES.

Q WE HAVE BEEN REFERRING TO THAT PATIENT IN THIS

COURTROOM AS PATIENT B. IT IS A KAISER PATIENT THAT CAME IN

WITH CHEST PAIN; IS THAT RIGHT?

A THAT IS CORRECT.

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Q HAVE YOU REVIEWED THAT CHART?

A YES.

Q WHAT IS THE DIAGNOSIS WRITTEN ON THE CHART BY DOCTOR

REDDY ON THE FACE SHEET?

A SYNCOPE, BRADYCARDIA, HYPOTENSION.

Q THERE'S A PAGE THERE, SIR, THAT SAYS "DIAGNOSTIC

IMPRESSION"?

A YES.

Q WHAT IS WRITTEN THERE?

A "STATUS POSTCARDIAC ARREST, SUDDEN DEATH."

Q ARE YOU FAMILIAR WITH THAT DIAGNOSIS?

A YES.

Q WHAT IS THAT DIAGNOSIS?

A WHEN A PATIENT'S HEART RATE STOPS, THE PATIENT DOES

NOT HAVE ANY BLOOD PRESSURE AND IS NOT RELATED TO LUNG

PROBLEMS OR SEPSIS, AND IT PRIMARILY HAS TO DO WITH CARDIAC

ARRYTHMIA, AND THE PATIENT'S BLOOD PRESSURE DROPS. YOU CAN

CALL IT SUDDEN CARDIAC DEATH.

Q IS THERE ANYTHING IN THAT CHART THAT LED YOU TO

BELIEVE THAT DOCTOR REDDY'S WRITTEN DIAGNOSIS COULD BE

JUSTIFIED?

A YOU CAN CALL IT ANYTHING YOU WANT. LOOKING THROUGH

THE CHART, THERE WERE SEVERAL THINGS HAPPENING TO THE PATIENT.

PATIENT HAD CHEST PAIN; THEREFORE, YOU CAN CALL CHEST PAIN

ACUTE CORONARY SYNDROME. YOU CAN CALL IT UNSTABLE ANGINA.

YOU CAN CALL IT HEART ATTACK. YOU CAN CALL IT WHATEVER I

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WANT. YOU CAN CALL IT PULMONARY EMBOLISM. ALL THIS FITS THE

DIAGNOSIS OF CHEST PAIN. AND WHEN A PATIENT'S HEART RATE

STOPS, WHICH IS SYNCOPE, YOU CAN CALL IT BRADYCARDIA.

VENTRICULAR FIBRILLATION. YOU CALL IT WHATEVER YOU WANT. THE

WORKUP IS STILL GOING TO BE THE SAME NO MATTER WHAT THE

DIAGNOSIS IS.

WE OFTEN ADMIT PATIENTS WITH CHEST PAINS, BUT WE

WORK UP THE PATIENT IN A WISE MANNER. IT DOES NOT MATTER WHAT

THE DIAGNOSIS IS. WHAT MATTERS IS WHETHER THE PATIENT WAS

APPROPRIATELY TREATED. THE PATIENT NEEDED TO BE ADMITTED AND

NEEDED TO HAVE CARDIAC WORKUP.

Q DO YOU TAKE ISSUE WITH DOCTOR REDDY'S DIAGNOSIS?

A NO.

Q WE HAVE HEARD SOME TESTIMONY TO THE EFFECT OF THAT

WOULD JUST BE A TERRIBLE DIAGNOSIS TO GIVE A PATIENT BECAUSE

IT WOULD AFFECT THEIR LIFE IN TERMS OF LIFE INSURANCE AND

THEIR DRIVER'S LICENSE. WHAT ARE YOUR THOUGHTS ON IF A

PATIENT HAD SYNCOPE HOW IT WILL AFFECT THAT?

A IF A PATIENT COMES IN WITH SYNCOPE, I'LL NOT ALLOW

HIM TO DRIVE. HIS DRIVER'S LICENSE HAS TO BE REVOKED UNTIL WE

CAN DETERMINE WHAT IT IS.

IF A PATIENT HAS CHEST PAIN AND VENTRICULAR

FIBRILLATION OR BRADYCARDIA, SLOW HEART RATE, THE PATIENT HAS

TO BE WORKED UP. THIS IS GOING TO AFFECT PATIENT'S LIFE

INSURANCE. MITRAL VALVE PROLAPSE, WHICH IS MOST BENIGN OF

CARDIAC CONDITIONS, IS A DIAGNOSIS THAT NO INSURANCE COMPANY

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WILL INSURE THE PATIENT.

Q THIS PATIENT WAS ADMITTED INITIALLY TO TELEMETRY AND

MY UNDERSTANDING WAS TRANSFERRED LATER TO ICU. BASED ON THE

WORK UP THAT YOU SEE IN THE ER AND THE FINDINGS IN THE ER, WAS

ADMITTING THIS PATIENT TO TELEMETRY WITHIN THE STANDARD OF

CARE OF CARDIOLOGY?

A ABSOLUTELY.

Q WE HAVE HEARD THAT THERE'S NO WAY THIS PATIENT

SHOULD HAVE GONE TO TELEMETRY. THIS PATIENT HAD TO GO TO ICU.

WE HAVE HEARD THAT FROM NURSES. LET ME HAVE YOUR THOUGHTS ON

THAT.

A IT'S MY CALL. IT'S MY CLINICAL JUDGMENT. I'M THE

ONE WHO'S MAKING THE DECISION WHETHER THE PATIENT GETS

ADMITTED OR NOT. I'M THE ONE WHO WILL DECIDE WHAT PROCEDURE

NEEDS TO BE DONE. I'M THE ONE ASSESSING THE PATIENT. SO

WHERE I PUT THE PATIENT IS MY CALL AND NOBODY ELSE'S BUSINESS.

Q WAS DOCTOR REDDY WRONG TO ADMIT THIS PATIENT, IN

YOUR OPINION, TO TELEMETRY?

A ABSOLUTELY NOT.

Q COULD THIS PATIENT ON THE DAY OF THE ER VISIT HAVE

TRAVELED BY AMBULANCE DOWN THE HILL TO KAISER HOSPITAL? WAS

HE ABLE TO DO THAT?

A NO.

Q WHY NOT?

A ANY PATIENT WHO COMES IN WITH CHEST PAIN ON TOP OF

THAT HAS SYNCOPE, I WON'T PUT MY REPUTATION ON THE LINE JUST

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BECAUSE SOME INSURANCE COMPANY WANTS ME TO TRANSFER THE

PATIENT. I'M THE PHYSICIAN WHO'S TRANSFERRING THE PATIENT. I

ULTIMATELY AM RESPONSIBLE FOR THE PATIENT.

WHAT IS THE DOWNSIDE OF KEEPING THE PATIENT FOR 24

TO 48 HOURS IN THE HOSPITAL MAKING SURE NO ADVERSE EVENT

DOESN'T TAKE PLACE? I DON'T SEE ANY DOWNSIDE TO THAT. I SEE

A LOT OF DOWNSIDE TO TRANSFERRING THE PATIENT TO A FACILITY

WHICH IS FONTANA WHICH DOES NOT PROVIDE ALL THE SERVICES THAT

THAT PATIENT MAY END UP REQUIRING ANYWAY.

Q WHAT ABOUT THE FACT THAT THE EMERGENCY ROOM

PHYSICIAN DOCTOR WAS READY TO DISCHARGE THE PATIENT AND THEN

DOCTOR REDDY INTERVENED?

A I WOULD NOT HAVE DISCHARGED THE PATIENT.

THE NUMBER ONE ADMITTING DIAGNOSIS IN THIS COUNTRY

FROM THE EMERGENCY ROOM IS CHEST PAIN. 24 PERCENT OF ALL

ADMISSIONS FROM THE EMERGENCY ROOM TO THE HOSPITAL IS FOR A

DIAGNOSIS OF CHEST PAIN. 12 PERCENT OF ALL ER PHYSICIAN

MALPRACTICE CLAIMS ARE FOR THE MISDIAGNOSIS OF CHEST PAIN.

I DON'T WANT TO TAKE THE RISK OF TRANSFERRING THE

PATIENT OR DISCHARGING THE PATIENT WITHOUT KNOWING ANYTHING

ABOUT THE PATIENT BEFORE HIS PRESENTATION TO THE EMERGENCY

ROOM. IF IT IS MY PATIENT, I KNOW THIS PATIENT. I HAVE TAKEN

CARE OF THIS PATIENT. I HAVE DEFINED THIS PATIENT'S ANATOMY.

THEN I WOULD SAY WHETHER TO ADMIT THE PATIENT OR NOT. IF I DO

NOT KNOW THE PATIENT, I RATHER ERR ON THE SIDE OF CAUTION.

Q BETWEEN 2001 AND 2003, YOU HAD PRIVILEGES AT DESERT

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VALLEY HOSPITAL?

A YES.

Q DID YOU HAVE INTERACTIONS WITH DOCTOR REDDY?

A VERY LITTLE.

Q DURING THE TIME THAT YOU FILLED IN AS A CARDIOLOGIST

WORKING UP PATIENTS IN THE CLINIC, DID DOCTOR REDDY EVER ASK

YOU TO PERFORM WHAT YOU BELIEVED TO BE MEDICALLY UNNECESSARY

TESTS ON PATIENTS?

A NEVER.

Q WHAT ABOUT CARDIOLOGY CONSULTS ON PATIENTS THAT

APPARENTLY ENDED UP NOT NEEDING IT AT ALL?

A NEVER.

Q HAS HE EVER INFLUENCED YOUR DECISION ON HOW TO TREAT

ANY PATIENTS THAT YOU HAVE LAID YOUR HANDS ON?

A ABSOLUTELY NOT.

Q YOU HAVE KNOWN DOCTOR REDDY TO SPEAK ABOUT INSURANCE

OR REIMBURSEMENT?

A YES.

Q DO YOU SEE A PROBLEM WITH THAT?

A NO. I NEED TO BE EDUCATED ON WHAT I CAN AND CAN'T

DO, WHAT THE INSURANCE WILL PAY AND WILL NOT PAY.

WE HAVE TO UNDERSTAND THE ECONOMICS OF THIS

PROFESSION. TO PROVIDE THE BEST CARE FOR THE PATIENTS, WE

HAVE TO UNDERSTAND HOW THE SYSTEM WORKS. IF THE PATIENT'S A

MANAGED CARE PATIENT, WE NEED TO KNOW HOW TO USE THE SYSTEM SO

THE PATIENT BENEFITS. IF I DO NOT AND I DO A PROCEDURE

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WITHOUT GETTING AUTHORIZATION ON A PATIENT, THE PATIENT WILL

END UP WITH THE BILL.

Q I WANT TO TALK TO YOU ABOUT SEEING A PATIENT IN THE

ER, DECIDING TO ADMIT THE PATIENT, AND AT THE TIME OF

ADMISSION ORDERING A STRESS TEST AND AN ANGIOGRAM. FIRST OF

ALL, HAVE YOU EVER SEEN THAT DONE?

A A LOT.

Q WHY?

A FOR SCHEDULING PURPOSES. THE CATH LAB NEEDS TO KNOW

THAT THERE'S A PROCEDURE COMING UP BECAUSE NURSES ARE ON CALL

AND ARE GOING TO COME IN. THE CATH LAB ALWAYS GETS FILLED UP;

SO IF YOU DO NOT SCHEDULE A CASE AND SOMEBODY ELSE TAKES THE

SLOT, THEN THERE ARE TWO, THREE DAYS THAT MAY GO BY BEFORE A

PATIENT CAN BE SCHEDULED FOR A PROCEDURE.

OUR CATH LAB IS OFTEN FILLED; SO I MAY SCHEDULE BOTH

CASES AT THE SAME TIME. WE'LL WAIT FOR THE RESULTS OF THE

TREADMILL TEST BEFORE PROCEEDING WITH THE ANGIOGRAM.

Q YOU HAVE DONE IT THAT WAY?

A ABSOLUTELY.

Q WHAT HAPPENS IF YOU DO THE STRESS TEST AND YOU

DETERMINE THE PATIENT DOES NOT NEED THE ANGIOGRAM?

A YOU CANCEL THE ANGIOGRAM.

Q A PRIOR CARDIOLOGIST CAME IN HERE BEFORE TODAY TO

TESTIFY THAT THE ONLY REASON THEY CAN THINK OF FOR ORDERING

BOTH TESTS AT THE SAME TIME WOULD BE FOR FINANCIAL GAIN.

A THAT CARDIOLOGIST HAS NOT BEEN PRACTICING

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CARDIOLOGY, DOES NOT HAVE A BUSY PRACTICE. I HAVE A VERY BUSY

PRACTICE. I HAVE TO UTILIZE MY TIME THE BEST POSSIBLE WAY. I

NEED TO KNOW WHAT MY OFFICE SCHEDULE IS GOING TO BE LIKE. I

NEED TO PREPARE MYSELF FOR IT. THEREFORE, I WILL SCHEDULE

THOSE CASES, AND THEN MY OFFICE IS AWARE OF WHAT'S HAPPENING.

IT ONLY MAKES SENSE. SINCE PATIENTS ARE NOT KEPT THREE, FOUR

DAYS TO GET PROCEDURE DONE, THEY GET EVERYTHING DONE IN AN

ORDERLY MANNER SO THEY ARE DISCHARGED PROMPTLY. I DON'T SEE

ANY PROBLEMS. I DO THIS ALL THE TIME.

MS. TROPP: THANK YOU, DOCTOR SIVA. THAT'S ALL I

HAVE AT THIS TIME.

THE COURT: THANK YOU.

CROSS-EXAMINATION.

CROSS-EXAMINATION

BY MR. NOLAN:

Q DOCTOR SIVA, THERE'S BEEN TESTIMONY IN THIS CASE

THAT DOCTOR REDDY ORDERED CARDIOLOGISTS TO DO THE STRESS AND

THE ANGIOGRAM -- "DO THEM BOTH AND SEE THE WHAT RESULTS ARE.

DO THEM BOTH."

THE CARDIOLOGIST TESTIFIED THAT THIS WAS DONE FOR

FINANCIAL REASONS. AND YOU SAID THAT THAT CARDIOLOGIST HASN'T

BEEN PRACTICING VERY LONG. IT MAY BE TRUE THAT THAT

CARDIOLOGIST KNOWS DOCTOR REDDY QUITE WELL POSSIBLY?

A YOU ARE ASKING ME FOR AN OPINION THAT I HAVE NO

OPINION ABOUT.

Q WE'LL LEAVE IT AT THAT.

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DID I HEAR YOU SAY THAT YOU TOLD SAINT MARY'S THAT

YOU WOULD TAKE LEGAL ACTION AGAINST THEM?

A YES.

Q DID I ALSO HEAR YOU SAY THAT PREM REDDY IS THE ONLY

CARDIOLOGIST THAT YOU TRUST?

A IN THE HIGH DESERT.

Q HAS ANYONE TOLD YOU THAT YOU AND DOCTOR REDDY ARE A

LOT A LIKE?

A I HAVE NOT HEARD ANYBODY SAY THAT TO ME.

Q I'M THE FIRST?

A YOU MAY BE THE FIRST. ARE YOU SAYING THAT TO ME

NOW?

Q YES, SIR.

A THEN YOU ARE THE FIRST.

Q YOUR PRIVILEGES WERE REVOKED AT SAINT MARY'S, AND

YOU BELIEVE IT'S BECAUSE OF SOME DISPUTE?

A NO, I DON'T BELIEVE. I DON'T BELIEVE ANYTHING. I

DON'T SECOND-GUESS. I DON'T GUESS. IF YOU WANT PROOF, I'LL

SHOW YOU PROOF. IT'S A FACT.

Q I'M JUST ASKING YOU A QUESTION. I THINK YOU JUST

ANSWERED IT.

A THANK YOU.

Q YOU DON'T BELIEVE THAT YOUR PRIVILEGES WERE REVOKED

BECAUSE YOU WERE ORDERING UNNECESSARY PROCEDURES?

A SIR, IF THAT IS THE CASE, WE'LL FIND OUT IN A COURT

OF LAW.

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Q I DON'T HAVE THE TIME TO WAIT FOR THAT, SIR. I'LL

JUST ASK YOU A FEW QUESTIONS TODAY. WHAT YOU DO IN A COURT OF

LAW IS BETWEEN YOU AND WHOEVER.

A THAT IS CORRECT.

Q YOU DON'T BELIEVE YOUR PRIVILEGES WERE REVOKED AT

SAINT MARY'S BECAUSE YOU HAD ENGAGED IN UNSAFE PRACTICES

REGARDING PATIENTS?

A ABSOLUTELY NOT.

Q DOCTOR SIVA, YOU ARE NOT ALLOWED TO ADMIT PATIENTS

AT BARSTOW COMMUNITY HOSPITAL; ISN'T THAT TRUE?

A THAT IS NOT TRUE.

Q YOU ONLY HAVE THE RIGHT TO CONSULT BUT NOT TO ADMIT

AT BARSTOW?

A THAT IS NOT TRUE.

Q YOU DON'T KNOW WHY BARSTOW WOULD BE SAYING THAT THAT

IS TRUE?

A THE SAME THING THAT SAINT MARY'S IS DOING. THEY TOO

HAVE GONE ON AN EXPEDITION TO SUSPEND ME BECAUSE OF MY

BUILDING THE HOSPITAL.

Q EVERYBODY'S AFTER YOU? IS THAT WHAT YOU'RE TELLING

US?

A NO.

Q BARSTOW AND SAINT MARY'S ARE AFTER YOU?

A HOSPITAL ADMINISTRATION, SIR.

Q YOU SOUND A LITTLE LIKE DOCTOR REDDY. ANYBODY EVER

TELL YOU THAT?

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A YOU SOUND LIKE SOMEBODY ELSE. YOU WANT ME TO TELL

YOU WHO YOU SOUND LIKE?

WHY ARE YOU MAKING PERSONAL ATTACKS ON ME, SIR?

THE COURT: HE'S NOT. TAKE IT EASY.

BY MR. NOLAN:

Q YOU TOLD US THAT YOU WERE VERY PARTIAL TO SAINT

MARY'S?

A YES, I WAS.

Q BUT YOU WOULD AGREE THAT IT APPEARS THEY'RE NOT AS

PARTIAL TO YOU?

A NOT THE NEW ADMINISTRATION, NO.

Q I'D LIKE TO SHOW YOU THIS LETTER THAT WAS -- I KNOW

YOU JUST TOLD US A MOMENT AGO THAT THIS WAS WRITTEN IN

RESPONSE TO A NASTY LETTER THAT YOU WROTE TO DESERT VALLEY.

IS THAT A FAIR STATEMENT, SIR?

A THAT IS CORRECT.

Q DO YOU KNOW WHO WROTE THIS LETTER TO YOU?

A I THINK DOCTOR THACKER DID.

Q ARE YOU SURE ABOUT THAT?

A I THINK SO.

Q DOCTOR THACKER SAYS THAT THERE WERE QUALITY OF CARE

CONCERNS ABOUT YOU; RIGHT?

A YES.

Q YOU DISAGREE WITH THAT?

A I ABSOLUTELY DISAGREE WITH THAT, OF COURSE.

Q DOCTOR THACKER SAYS IN THE FIRST PARAGRAPH THAT YOU

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DISCHARGED THE PATIENT VIA A TELEPHONE ORDER. THERE WAS NO

EVIDENCE OF YOU SEEING THE PATIENT ON THE ORDER NOTES. IF

THAT'S TRUE, THAT'S NOT A GOOD THING TO DO, IS IT?

A I HAVE TO LOOK AT THE CHART. ANYBODY CAN SAY

ANYTHING THEY WANT.

Q DO YOU KNOW WHETHER DOCTOR THACKER LOOKED AT THESE

CHARTS BEFORE HE WROTE THIS LETTER TO YOU?

A YOU SHOULD HAVE ASKED HIM THAT QUESTION.

Q I SHOULD HAVE.

WE BLACKED IT ALL OUT, BUT HE REFERENCES SPECIFIC

PATIENTS IN THE LETTER; RIGHT?

A I DO NOT KNOW THESE PATIENTS.

Q I'M NOT ASKING WHETHER YOU KNOW THE PATIENT. I'M

ASKING YOU WHETHER YOU KNOW THAT DOCTOR THACKER REFERENCED

SPECIFIC PATIENTS AND MEDICAL RECORD NUMBERS?

A THAT'S CORRECT.

Q DOWN IN PARAGRAPH THREE, DOCTOR THACKER SAYS THAT ON

A VERY COMPLEX MEDICAL ISSUE, YOU DID NOT EXAMINE THE PATIENT

FOR TWO DAYS.

A THAT IS NOT TRUE.

Q HE'S OUT TO GET YOU TOO, SIR?

A NO. I MAY NOT HAVE EXAMINED MY PATIENT, BUT I HAVE

OTHER ASSOCIATES WHO WORK FOR ME WHO EXAMINE THE PATIENTS. I

DON'T HAVE TO GO AROUND EVERY ONE OF MY PATIENTS, SIR.

Q YOU'RE A PRETTY BUSY GUY, AREN'T YOU?

A I AM.

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Q DOCTOR THACKER SAYS ON THE SECOND PAGE OF THIS

LETTER THAT YOU, DOCTOR SIVA, EMBARKED ON A PATH OF

ACCUSATIONS AGAINST DESERT VALLEY HOSPITAL.

A CERTAIN MEMBERS OF DESERT VALLEY HOSPITAL.

Q WERE THESE ACCUSATIONS?

A THEY WERE DOING THINGS TO MY PATIENT WITHOUT MY

PERMISSION.

Q THEY WERE ENGAGING IN MISCONDUCT?

A CERTAIN CARDIOLOGISTS AT DESERT VALLEY HOSPITAL

WERE.

DO YOU KNOW WHO THE CARDIOLOGISTS WERE AT DESERT

VALLEY HOSPITAL AT THAT TIME, SIR?

Q THERE'S NO QUESTION PENDING RIGHT NOW, DOCTOR SIVA.

A I JUST WANTED TO MAKE SURE YOU KNEW THAT.

Q ALL RIGHT.

DOCTOR THACKER SAYS HE BELIEVES YOU'RE ACTING

RETALIATORY. YOU DID NOT DO THAT, SIR?

A ABSOLUTELY NOT.

Q IN THIS SECOND PARAGRAPH, DOCTOR THACKER POINTS OUT

THERE'S NO MENTION OF YOUR NAME ON THE PATIENT CHART. DO YOU

SEE THAT?

A IF YOU GO DOWN, IT SAYS: "YOUR QUESTIONING OF THE

CLINICAL DECISION MADE BY A BOARD CERTIFIED CARDIOLOGIST

DOCTOR RAZA." THAT IS WHAT I HAD ISSUES ABOUT. WHY DON'T YOU

HIGHLIGHT THAT?

THE COURT: PLEASE ANSWER THE QUESTIONS.

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THE WITNESS: YES.

BY MR. NOLAN:

Q DO YOU WANT TO COME OUT HERE AND DO MY JOB?

A NO.

Q JUST CHECKING.

DOCTOR THACKER SAYS: YOU TOOK IT UPON YOURSELF TO

WRITE IN THE PATIENT CHART TO TRANSFER THE PATIENT TO YOUR

SERVICE. THIS SEEMED, ACCORDING TO DOCTOR THACKER. TO BE A

CONTINUOUS PATTERN ON YOUR BEHALF THAT YOU COME AND WRITE ON

PATIENTS' CHARTS OF OTHER PHYSICIANS, AND THAT YOU ARE

VIOLATING HOSPITAL POLICY.

A THAT IS NOT TRUE. MY PATIENTS' FAMILY MEMBERS WERE

CALLING ME, AND DOCTOR RAZA WAS INTERFERING WITH MY PATIENT

CARE.

Q FROM YOUR EXPERIENCE IN WORKING AT DESERT VALLEY

HOSPITAL, IF YOU ARE SEEING A PATIENT IN THE ER OR ON THE

MED-SURG FLOOR, SAY, FOR AN INTERNAL MEDICINE PROBLEM, AND

ANOTHER DOCTOR, UNBEKNOWNST TO YOU, COMES UP AND STARTS

WRITING ORDERS ON THE CHART FOR THAT PATIENT, WOULD THAT

TROUBLE YOU?

A IT WILL TROUBLE ME IF THE DOCTOR DOES NOT KNOW THE

PATIENT, IF THE FAMILY MEMBERS HAVE NOT REQUESTED THE DOCTOR

TO WRITE ON THE CHART. FAMILY MEMBERS ARE WONDERING WHY THE

PATIENT IS IN THE HOSPITAL, YET ANOTHER DOCTOR BY THE NAME OF

DOCTOR RAZA IS TAKING CARE OF THE PATIENT WHEN THE PATIENT

ACTUALLY SHOULD BE SEEN BY ME BECAUSE THE PATIENT HAS BEEN

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UNDER MY CARE.

Q LET ME COME BACK TO MY QUESTION BECAUSE YOU WENT OFF

ON A BIT OF TANGENT.

A NO, I DID NOT.

Q ALL RIGHT.

WOULD YOU AGREE THAT IT IS WRONG -- I'M NOT TALKING

ABOUT YOU AND I'M NOT TALKING ABOUT DOCTOR RAZA. I'M JUST

ASKING YOU AS A MATTER OF GENERAL PRINCIPAL AS A PHYSICIAN, IS

IT WRONG FOR ANOTHER DOCTOR TO COME UNINVITED AND WRITE ON

ANOTHER PHYSICIAN'S PATIENT'S CHART?

A I HAVE NO OPINION.

Q NO OPINION OF THAT?

A ABSOLUTELY NOT. I'M NOT SPECULATING ON ANYTHING. I

CAN ONLY TALK ABOUT MY PATIENT AND MY CARE, AND THIS

PARTICULAR DOCUMENT, WHICH IS MY PATIENT, FAMILY MEMBERS

CONTACTED ME THAT THE PATIENT IS IN THE HOSPITAL AND WHY ARE

YOU NOT SEEING THE PATIENT? WHY IS DOCTOR RAZA TAKING CARE OF

OUR FATHER OUR OR MOTHER? YOU ARE THE CARDIOLOGIST. WE HAVE

HIRED YOU AS CARDIOLOGIST. WHY IS THAT HAPPENING? ONLY THOSE

SITUATIONS HAVE I RESPONDED, SIR. I'M NOT SPECULATING ON

ANYTHING ELSE.

Q SEE IF YOU CAN GET FOCUSED ON THE QUESTION, DOCTOR

SIVA.

UP AT THE TOP OF THE FINAL PAGE, IT SAYS:

"DOCTOR SIVA, WE HAVE RECEIVED NUMEROUS COMPLAINTS AGAINST

YOUR LACK OF TIMELY RESPONSE TO THE PAGES FROM THE CLINICAL

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STAFF."

I KNOW YOU ACCUSED ANOTHER PHYSICIAN JUST A FEW

MINUTES AGO OF FAILING TO RESPOND TO PAGES. APPARENTLY

SOMEBODY THINKS THAT YOU SUFFER FROM THE SAME DEFICIENCY.

FAIR STATEMENT?

A NO. THE REASON IS SHOW ME THE COMPLAINTS. SHOW ME

THE PATIENTS THAT I HAVE NOT RESPONDED TO. DON'T MAKE AN

ACCUSATION THAT YOU CANNOT SUBSTANTIATE.

Q I'M NOT MAKING ACCUSATIONS, SIR. THIS WAS DESERT

VALLEY HOSPITAL THAT MADE THE ACCUSATION.

A THAT'S WHY I TOLD DOCTOR THACKER TO RESPOND

APPROPRIATELY WITH SPECIFICS NOT JUST GENERALITIES.

Q DOCTOR THACKER GOES ON TO STATE IN THE SECOND LINE

UP THERE FROM THE TOP: "IN ADDITION, WE ALSO RECEIVED SEVERAL

COMPLAINTS ABOUT YOUR INAPPROPRIATE AND RUDE BEHAVIOR WITH OUR

NURSING STAFF AND PHYSICIANS."

A SPECIFICS, PLEASE.

Q I DIDN'T ASK YOU A QUESTION YET.

DOCTOR SIVA, WOULD YOU EVER BE RUDE TO THE NURSING

STAFF?

A ABSOLUTELY NOT.

Q WOULD YOU EVER BE RUDE TO PHYSICIANS?

A YES. I HOLD PHYSICIANS AT A HIGHER LEVEL. THEY ARE

MY EQUAL; THEREFORE, I DEMAND A LOT MORE FROM MY PHYSICIANS.

NURSES ARE SUBORDINATES. THEY ACTUALLY HAVE LITTLE COST IN

TERMS OF HOW TO DEAL WITH PHYSICIANS.

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I TAKE EXTRA PRECAUTION. I'M NEVER RUDE TO ANYBODY

UNLESS THERE'S NEGLIGENCE INVOLVED. WHEN MEDICATIONS NEED TO

BE GIVEN TO THE PATIENT AND HAVE NOT BEEN GIVEN, WHEN PATIENTS

NEED CERTAIN THINGS TAKEN CARE OF AND THEY'RE NOT TAKEN CARE

OF, THAT ADVERSELY AFFECTS THE PATIENT CARE, THEN I'LL TAKE

ISSUE, BUT I NEVER TAKE ISSUE ON AN INDIVIDUAL BASIS WITH

NURSE TO NURSE. I ALWAYS GO TO THE SUPERVISOR, AND I VERY

CALMLY AND COLLECTIVELY TELL THEM EXACTLY WHAT NEEDS TO BE

DONE AND I DO NOT WANT THOSE THINGS REPEATED. YOU CAN ASK

LISA. SHE HAS BEEN WITH ME FOR A LONG TIME. SHE KNOWS ME FOR

A VERY LONG TIME. ASK HER HOW MANY TIMES I HAVE YELLED AT ANY

NURSES.

Q I'LL ASK HER LATER, SIR.

A THANK YOU.

Q DOCTOR THACKER SAYS HE'S GOING TO FORWARD ALL THESE

COMPLAINTS HE HAS ABOUT YOU TO COMMITTEES. DO YOU KNOW

WHETHER THAT WAS DONE?

A NO.

Q HE SAYS HE WANTS YOU TO REFRAIN FROM WRITING

TRANSFER ORDERS TO YOURSELF ON THE CHARTS OF OTHERS. DID YOU

TALK TO DOCTOR THACKER ABOUT THAT?

A YES, I DID.

Q AND HE SAYS: IF YOU DO NOT CORRECT THESE

DEFICIENCIES, THEY'RE GOING TO TAKE APPROPRIATE ACTION AGAINST

YOU, INCLUDING SUMMARY SUSPENSION OF YOUR PRIVILEGES.

A NOTHING HAS HAPPENED, HAS IT?

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Q I DON'T KNOW, SIR.

A OKAY.

Q DOCTOR SIVA, I THANK YOU VERY MUCH, SIR.

A THANK YOU.

THE COURT: REDIRECT, MISS TROPP.

REDIRECT EXAMINATION

BY MS. TROPP:

Q DOCTOR SIVA, DID YOU RESOLVE THESE ISSUES WITH

DESERT VALLEY HOSPITAL THAT WERE RAISED IN DOCTOR THACKER'S

LETTER?

A YES, I HAVE.

Q DID YOU RESOLVE THOSE ISSUES WITH DOCTOR THACKER?

A NO.

Q WITH WHOM DID YOU RESOLVE THEM?

A WITH DOCTOR REDDY.

Q DID IT REQUIRE LEGAL INTERVENTION BY ANYBODY?

A NO.

Q DID HE SUE YOU?

A NO.

Q DID YOU SUE HIM?

A NO.

Q DO YOU STILL WORK THERE?

A I'M STILL THE MEDICAL DIRECTOR AND ALSO THE DIRECTOR

OF THE CATH LAB.

Q YOU TALKED ABOUT SPECIFICS. YOU HAVE SPECIFICS,

SIR, OF DOCTOR AHMED NOT RESPONDING TO PAGES?

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A ABSOLUTELY.

Q LIKE THE BARSTOW SHERIFF THAT YOU MENTIONED?

A CORRECT.

Q WE ACTUALLY SHOWED SOME DOCUMENTATION IN THIS COURT

OF PBX -- WHAT'S PBX?

A THAT'S OUR PAGING SYSTEM.

Q WE SAW SOME DOCUMENTATION IN COURT WHERE PBX PAGED

DOCTOR AHMED AND HE DIDN'T RESPOND.

HAVE YOU EVER HAD THAT SITUATION WITH DOCTOR AHMED

AT DESERT VALLEY HOSPITAL WHERE HE HASN'T RESPONDED?

A YES.

Q ACTUAL SPECIFICS?

A YES.

Q DO YOU THINK IT'S IMPORTANT TO HAVE SPECIFICS OF

PATIENTS, SIR, WHEN YOU'RE ACCUSING PATIENTS' PHYSICIANS?

A THAT'S CORRECT.

Q DO YOU THINK IT'S IMPORTANT FOR NURSES TO HAVE

ACTUAL SPECIFICS OF PATIENTS BEFORE THEY'RE ACCUSING

PHYSICIANS?

A ABSOLUTELY.

Q WHY?

A BECAUSE IT'S HEARSAY. ANYBODY CAN ACCUSE ANYBODY OF

ANYTHING AND GET AWAY WITH IT BECAUSE IT'S HEARSAY RUMORS. I

HEARD THIS FROM SOMEBODY ELSE. BUT NOBODY HAS FIRSTHAND

KNOWLEDGE.

IF YOU HAVE ISSUES WITH SOMEBODY, WRITE IT DOWN.

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TELL ME WHERE IT IS. PUT IT IN A CHART AND SAY YOU HAVE

ISSUES, AND THEN WE'LL RESOLVE THE ISSUE. CALL THE PATIENT.

TALK TO THE PATIENT. DID THE PATIENT HAVE ANY COMPLAINTS

CONCERNING MY CARE? BRING THOSE ISSUES TO ME. GIVE ME

SPECIFICS. THEN I'LL DEAL WITH THE SPECIFICS.

WHEN YOU'RE SIMPLY ACCUSING ME ON NUMEROUS OCCASIONS

THAT SOMETHING WAS SAID BY SOMEBODY SOMEWHERE DOWN THE ROAD,

IT'S ALL NONSENSE.

Q YOU'RE PREACHING TO THE CHOIR, DOCTOR.

THANK YOU.

A THANK YOU.

THE COURT: MR. NOLAN?

MR. NOLAN: I WAS GOING TO GOING TO ASK ABOUT THE

CHOIR, BUT I'LL REFRAIN.

I HAVE NO FURTHER QUESTIONS.

THE COURT: THANK YOU, DOCTOR.

(THAT CONCLUDES THE TESTIMONY OF SIVA ARUNASALAM)

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN BERNARDINO

VICTORVILLE DIVISION

DEPARTMENT V-10 HON. STANFORD E. REICHERT, JUDGE

DESERT VALLEY HOSPITAL, INC., ) CASE NO. VCVVS030193)

PLAINTIFF, ))

VS. ))

TINA BUCHANAN AND LISA CROUCH, ))

DEFENDANTS. )___________________________________)TINA BUCHANAN AND LISA CROUCH, )

)CROSS-COMPLAINANTS, )

)VS. )

)DESERT VALLEY HOSPITAL, INC., )ET AL., )

)CROSS-DEFENDANTS. )

)

REPORTER'S TRANSCRIPT OF ORAL PROCEEDINGS

TESTIMONY OF DOCTOR SIVA ARUNASALAM

THURSDAY, OCTOBER 6, 2005

APPEARANCES:

FOR THE PLAINTIFFS DEBORAH S. TROPPAND CROSS-DEFENDANTS: ATTORNEY AT LAW

611 ANTON BOULEVARDSUITE 1050COSTA MESA, CA 92626

-AND-MICHAEL J. SARRAOATTORNEY AT LAW26632 TOWNE CENTER DRIVEFOOTHILL RANCH, CA 92610

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FOR THE DEFENDANTS VINCENT P. NOLANAND CROSS-COMPLAINANTS: ATTORNEY AT LAW

3877 TWELFTH STREETRIVERSIDE, CA 92501

REPORTED BY: FRED BERZAKOFFICIAL REPORTERC.S.R. NO. 5815

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REPORTER'S CERTIFICATE

I, FRED BERZAK, CSR, OFFICIAL REPORTER OF THE

ABOVE-ENTITLED COURT, DO HEREBY CERTIFY:

THAT I AM A CERTIFIED SHORTHAND REPORTER OF THE

STATE OF CALIFORNIA, DULY LICENSED TO PRACTICE; THAT I DID

REPORT IN STENOTYPE ORAL PROCEEDINGS HAD UPON HEARING OF THE

AFOREMENTIONED CAUSE AT THE TIME AND PLACE HEREINBEFORE SET

FORTH; THAT THE FOREGOING PAGES NUMBERED 1 THROUGH 36,

CONSTITUTE TO THE BEST OF MY KNOWLEDGE AND BELIEF A FULL,

TRUE, AND CORRECT COMPUTER-AIDED TRANSCRIPTION FROM MY SAID

SHORTHAND NOTES.

DATED THIS 18TH DAY OF JANUARY, 2012.

______________________________CSR

OFFICIAL REPORTER, CSR NO. 5815

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WITNESS PAGE

SIVA ARUNASALAM

DIRECT EXAMINATION BY MS. TROPP 1CROSS-EXAMINATION BY MR. NOLAN 24REDIRECT EXAMINATION BY MS. TROPP 34