1 1 IN THE CIRCUIT COURT FOR CECIL COUNTY, MARYLAND 2 ----------------------------------x 3 JANE DOE, : 4 Plaintiff, : 5 v. : Case No.: 6 THE UNION HOSPITAL, INC., : 07-C-11-000000 7 et al., : 8 Defendants. : 9 ----------------------------------x 10 11 Deposition of MARGARET SMITH, RN, BSN 12 Elkton, Maryland 13 Tuesday, January 28, 2014 14 8:03 a.m. 15 16 17 18 19 20 Job No.: 11111 21 Pages: 1 - 41 22 Transcribed by: Annie Adams 2 1 Deposition of MARGARET SMITH, RN, BSN, held at 2 the offices of: 3 4 5 THE UNION HOSPITAL 6 100 Main Street 7 Baltimore, Maryland 99999 8 (555) 555-1212 9 10 11 12 13 Pursuant to agreement, before Benjamin Barnes, 14 Notary Public in and for the State of Maryland. 15 16 17 18 19 20 21 22 3 1 A P P E A R A N C E S 2 3 ON BEHALF OF THE PLAINTIFF, JANE DOE: 4 SUSAN B. ANTHONY, ESQUIRE 5 ANTHONY & ANTHONY 6 1000 Main Street 7 Suite 500 8 Baltimore, Maryland 22222 9 (410) 555-1212 10 11 ON BEHALF OF THE DEFENDANT, THE UNION HOSPITAL, 12 INC.: 13 KATHY I. WATSON, ESQUIRE 14 WATSON & WATSON 15 1000 1st Street, NW 16 Suite 800 17 Washington, DC 20036 18 (202) 555-1212 19 20 21 22 4 1 C O N T E N T S 2 EXAMINATION OF MARGARET SMITH, RN, BSN PAGE 3 By Ms. Anthony 6 4 By Ms. Flower 37 5 6 7 E X H I B I T S 8 (Retained by counsel) 9 SMITH DEPOSITION EXHIBIT PAGE 10 Exhibit 1 Ms. Smith's Curriculum Vitae 7 11 Exhibit 2 Recall Notice 22 12 Exhibit 3 Recall return communication 24 13 Exhibit 4 Manage OR Bookings document 25 14 Exhibit 5 Pick List 27 15 Exhibit 6 Pick List 29 16 17 18 19 20 21 22 5 1 P R O C E E D I N G S 2 Whereupon, 3 MARGARET SMITH, RN, BSN, 4 being first duly sworn or affirmed to testify to the 5 truth, the whole truth, and nothing but the truth, was 6 examined and testified as follows: 7 EXAMINATION BY COUNSEL FOR THE PLAINTIFF 8 BY MS. ANTHONY: 9 Q Good morning, Ms. Smith. 10 A Good morning. 11 Q My name is Susan Anthony. I represent the 12 Plaintiff, Jane Doe, in the lawsuit that was brought 13 against The Union Hospital and Dr. Frankenstein. Do 14 you understand that? 15 A Yes. 16 Q I'll be asking you a series of questions 17 this morning. If at any time you don't understand my 18 question, tell me that and I will rephrase so that you 19 and I understand each other. Do you understand that? 20 A Yes. 21 Q If an answer to a question is yes or no, 22 it's best to say yes or no rather than um-hum, huh-uh, 6 1 uh-huh, because that gets a bit garbled in the written 2 transcript. Do you understand that? 3 A Yes. 4 MS. FLOWER: Thank you. I don't have any 5 more questions. 6 MS. ANTHONY: You have the right to read and 7 sign this transcript, but whether it's going to get 8 done in time for you to do that will be up to 9 Ms. Watson. 10 MS. WATSON: I assume you're ordering it 11 expedited? 12 MS. ANTHONY: Well, I am. But I ordered it 13 expedited as close to trial as I can to save myself a 14 couple bucks. 15 MS. WATSON: We will waive. 16 THE REPORTER: We are off the record at 17 8:44 a.m. 18 (Off the record at 8:44 a.m.) 19 20 21 22 7 1 CERTIFICATE OF NOTARY PUBLIC 2 I, Benjamin Barnes, Notary Public in and for the 3 State of Maryland, do hereby certify that on January 4 28, 2014, the witness MARGARET SMITH, RN, BSN was 5 sworn before me at the aforementioned location, and 6 that I am neither counsel for, related to, nor 7 employed by any of the parties to this case and have 8 no interest, financial or otherwise, in its outcome. 9 IN WITNESS WHEREOF, I have hereunto set my hand 10 this 29th day of January, 2014. 11 12 13 14 15 _____________________________ 16 NOTARY PUBLIC IN AND FOR THE 17 STATE OF MARYLAND 18 19 20 21 22 8 1 CERTIFICATE OF TRANSCRIBER 2 I, Annie Adams, do hereby certify that 3 the foregoing transcript is a true and correct record 4 of the recorded proceedings; that said proceedings were 5 transcribed to the best of my ability from the audio 6 recording and supporting information; and that I am 7 neither counsel for, related to, nor employed by any 8 of the parties to this case and have no interest, 9 financial or otherwise, in its outcome. 10 11 12 13 14 _____________________________ 15 ANNIE ADAMS 16 January 29, 2014 17 18 19 20 21 22