Karen Koehler

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Perpetuating* radiologists' depositions

Get up at 6:00 am.   Have to drive back downtown before heading south.  Need a plan "B" in case doctors don't have access to the radiology films.  Get ready, feed and quickly walk Nala.  Write note to let the girls know she's been fed.  Wash bowl of raspberries.  Get in car 6:30.  Eat bowl of raspberries on the way.  Get to office by 7:10, run in undo alarm.  Grab computer discs, run out redo alarm.  Back in car 7:15.

Drive down viaduct. Not going to be able to drive this way much longer.  One lane is blocked off.  The viaduct is doomed.  It is going to viaduct heaven.  Supposedly being replaced by a tunnel.  Which is too bad because it is absolutely stunning driving on this  rare sunny morning with the ocean on the right and the city on the left.

Get onto freeway.  Traffic is flowing nicely.  Ding.  Fuel light comes on drat.  Keep driving, ignore fuel light. Looking for the closest gas station to a freeway exit.  Oh there's one.  Oh, too late to get over.  Next exit there's one.  Nope.  Oh there's one.  Oh, too late to get over.  Want to find the perfect station until see the car is claiming there is less than 5 miles left.  Probably a fudge factor in there.  But can't chance finding out.  Take next exit.

Gas station has a nice store attached.  Grab two packets of sugarfree gum.   For counterbalance grab a very necessary donut.  Oily and sugary - yum.  Get back in car and onto the freeway.  Drive.  Consume sugar/nonsugar.  Listen to oldies on ipod.

Ding.  What's that.  Not the fuel light.  Warning light says "Maximum speed".  Oops.  Have previously increased the preset manufacturer's default setting.  So basically, am speeding.  Ding.

Arrive at the hospital at 10:00.  My dear paralegal Anne has set the first deposition for 10:30.  This was so I didn't have to get up too early.  Which did anyway because needed to pick up plan "B".  Which now realize is dumb dumb dumb.  Because forgot to bring the computer's DVD drive that is still sitting on my desk.

Pull up to the emergency entrance.  Wrong.  Drive around in a circle.  Or two.  End up in a parking garage.  Pull out phone.  Refers to a map of the hospital campus.  Click on it.  Microscopic.  Can't read it.  Pull out computer.  Dial up, find map.   Am bad at reading maps.  Get out of car with computer bag and plan "B" discs but no disc drive.  Not sure where to go.  Walk a little way and realize have parked right by where need to be.  Am a map wizard queen.  Arrive with ten minutes to spare.

Videographer and court reporter are already set up.  Have to change the set up though.  This isn't the type of deposition where the camera focuses on the head of the doctor and never moves.  (note:  never do a perpetuation deposition of a talking head - this is a guaranteed bore).

Anne has arranged with the doctor's office for this deposition to be in the hospital medical library.  All the films are stored in the secure hospital server.  The hospital computer is already hooked up to a projector and a screen.  Don't need plan "B" after all hurray.

Nic Scarpelli comes in the room.  First of the four defense attorneys.  What a gaggle.

I explain the set up and he doesn't argue with it.  We actually rub along pretty well most of the time.  Unless he's upset with me.  Hard to believe that could ever be possible.  Am such an angel.

The doctor will start off on camera for background questions.  Then will move over to the computer.  We'll have to turn off the lights since it's too bright.  The videographer will then focus the camera on the screen and zoom onto the projected images.

The doctor is right on time.  I explain the protocol and you can see the shoulders relax.  He doesn't have to leave the familiar world of radiological films.   After a few preliminaries we get right to the films.  He walks over to the computer.  And brings the images alive for the jury.

After he's finished, a second radiologist comes in.  We don't take a break, repeat the process and finish at 12:40 pm.   The defense lawyers bolt out of there.  Where did they go so fast.

Get back in car.  Donut has worn off.  Equally unwholesome Burger King is handily right at the freeway entrance.  Veggie Burger and fries to go.  Get on freeway almost without incident. Have taken off top part of bun with goopy mayo and lettuce.  This creates a bit of instability in sandwich. Drop piece of tomato on white shirt which now has a pink speckle.

Doesn't take the full three and a half hours to get back.  Ding!

* A perpetuation deposition is testimony under oath preserved in this case by digital recording and played at the time of trial.  Doctors are commonly perpetuated to avoid trial scheduling nightmares.