Examination 2 - direct and cross of Paramedic Emergency Medical Technician expert in product liabilty case against ford

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JOHN SLOOP, called as a witness herein, having been first duly sworn, was examined and testified as follows:

DIRECT EXAMINATION

BY MR. BLOCK:

Q. Mr. Sloop, good morning.

A. Good morning.

Q. Mr. Sloop, could you tell the jury your full name, please, and if you would try to keep your voice up.

A. Okay. My name is John Sloop.

Q. What is your business address, your business address?

A. For work?

Q. Work.

A. For work it's 1234 East Sibley Boulevard in Dolton, Illinois.

Q. What is your full-time employment?

A. I work for Daley's Ambulance Service.

Q. What do you do for them?

A. I'm an operations manager.

Q. And do you also have additional part-time employment?

A. Yes, I do.

Q. What is that?

A. I work for the Crete Fire Department.

Q. And how long have you been with the Crete Fire Department?

A. Since April of ′88.

Q. What do you do for them?

A. I'm a firefighter paramedic.

Q. So depending on what shift you are working or whatever you might be fighting fires one day and being a paramedic the next?

A. Correct.

Q. What is your paramedic training?

A. My paramedic training consists of six months of emergency medical technician course at St. James Hospital, and then another year at Ingall's Hospital in the paramedic program.

Q. Do you also work for other departments as a paramedic?

A. No.

Q. Directing your attention to May 2nd of 1995, did you have occasion to receive a call to go to the intersection of Crete and Exchange in Crete?

A. Yes.

Q. And would it be you received a call from a dispatcher to go there?

A. Yes.

Q. I'm going to put these in front of you. Would the Crete Fire Department report and your report be helpful in giving testimony today?

A. Yes, it would.

Q. Showing you Exhibit No. 7, is that the report of the Crete Fire Department?

A. Yes, it is.

Q. And what does that show regarding the time that the call was received?

A. It shows that at 0837 hours.

Q. And what was the nature of the call?

A. It was for a traffic accident.

Q. One or two?

A. It was initially one.

Q. Can you describe what the report says.

A. The report says the first involved a Ford Explorer that hit a utility pole. The second involved a school bus with children that hit the low wires from the first accident.

Q. My question is this. Were both accidents called in at 8:37?

A. Yes.

Q. After that accident was called in, did you go to the scene?

A. Yes, I did.

Q. What time did you arrive at the scene?

A. I arrived at 0840 hours.

Q. So you were there three minutes later?

A. Correct.

Q. And when you arrived at the scene, what if anything did you observe regarding traffic on the road or vehicles being backed up?

A. I observed a Ford Explorer that was - had crashed into a utility pole, and that the wires subsequently from that telephone pole were laying on top of a school bus.

Q. That was already there at 8:40?

A. Correct.

Q. Now, as far as the traffic on the roadway, how was it?

A. Traffic was backed up behind the school bus going westbound, and eastbound traffic was stopped at the intersection going eastbound because they couldn't go through because of the wires.

Q. Were there a lot of people there already?

A. There was a ton of people.

Q. Were you the first trained medical personnel there?

A. Yes, I was.

Q. Upon arriving, what did you do?

A. First I assessed the scene to make sure that there was no additional damage other than the bus and the car. I started to initially assess the patient in the Explorer to find out his extent of injuries and then to go to the bus and assess what type of injuries I had on the bus and then report back on the radio.

Q. For medical reasons with respect to the driver of the Explorer, did you inquire whether he had a seat belt?

A. In my comments to bystanders I did ask if anybody noted that he had a seat belt on.

Q. Did somebody respond that he did?

A. Yes, they did.

Q. Did you know either the driver of the Explorer or any of the people that were around?

A. No, I did not.

Q. When you first went to the driver of the Explorer, what was his condition?

A. He was unresponsive.

Q. And he was unconscious as well, I assume?

A. Yes.

Q. You transported him to the hospital?

A. Yes.

Q. Was he also unconscious for the entire time you transported him?

A. Yes.

Q. When you first got there, what did you do regarding the patient?

A. Well, like I said, I went to assess his injuries, to call for additional help right away due to the fact that there was a school bus involved, and started to stabilize him, applying a neck collar in place, and then waiting for additional help to get him out of the vehicle and onto a backboard and into the back of the ambulance.

Q. By the way, everybody on the school bus was okay, were they not?

A. Correct.

Q. When the fire department or the paramedics go to a scene like this, are there general procedures regarding cutting the battery cable?

A. At some point, yes, there are.

Q. In this case I take it you have no idea who would have done that?

A. I have no idea.

Q. After you assessed the patient, what did you do with him?

A. We placed him on a long backboard, moved him up onto the stretcher, moved him to the back of the ambulance and started to reassess additional external or internal injuries and treat as such.

Q. Showing you Exhibit 3, which is in front of you, is that the report you prepared?

A. Yes, it is.

Q. It's in your handwriting?

A. Yes, it is.

Q. In the usual course of business?

A. Yes, it is.

Q. It's your duty as a paramedic to prepare that report?

A. Yes, it is.

Q. Can you describe what you noted about the patient when you did assess him?

A. Would you like me to read from my comments?

Q. Sure.

A. Upon arrival found patient in seat of car. Bystander stated patient had seat belt on.

THE COURT: You have to slow down a little bit.

THE WITNESS: I'm sorry. Seat belt on and air bag deployed. Patient unresponsive. Eyes rolled back and eyelids twitching. Immobilized on long backboard and collar. 02. Monitor vitals. IV established. Searched for any external injuries. Starburst noted on windshield. Noted no obvious injuries. Contacted Olympia Fields via cell phone and transported without further incident. ALS trauma bypass to Olympia Fields.

BY MR. BLOCK:

Q. I take it you noted the starburst because of possible medical complications?

A. Yes.

Q. With respect to the eyes rolled back, would you please tell the jury exactly what you mean?

A. His eyes were basically rolled back in the back of his head and his eyelids were twitching.

Q. This twitching in the eyelids, did it continue to the time you got him to the hospital?

A. Yes, to the best of my knowledge, it did.

Q. What is the significance of eyelids twitching to a paramedic?

A. In my training it would have indicated to me that it was possible seizure activity. That's just one of the signs of a seizure.

Q. Did you ever look under the hood of the vehicle at the scene?

A. No, I did not.

Q. I take it your only concern at the scene was attending to the patient?

A. Correct.

Q. Do you have a recollection of an injury across the bridge of his nose?

A. Yes, I do.

Q. You actually did something for that, did you not?

A. I put a four-by-four on it.

Q. What you saw there in your experience as a paramedic, is that something that you see commonly after an air bag deployment?

A. Yes.

Q. In the past as a paramedic you've made visual inspections for seat belt marks, have you not?

A. Yes, I have.

Q. You did that in this case?

A. Yes.

Q. What did you observe, if anything?

A. I didn't note any type of rash or burn mark across his chest from the seat belt.

Q. That's something you commonly see in crashes?

A. Commonly, yes.

Q. You've never spoken with Michael Skowronski about this crash, I take it?

A. No.

Q. You don't know him?

A. No.

Q. Did you ever have occasion to check the scene for anything or that wasn't part of your process?

A. No.

Q. Did you ever depress the brake pedal at the scene?

A. No, I did not.

Q. To your knowledge did anyone in your presence?

A. Not in my presence.

Q. With Dr. Skowronski, the driver of the vehicle, having been unconscious the entire time, is there any way that he could have known whether you or anyone else tested the brake pedal at the scene?

A. No.

Q. Just a few more questions. It's common, is it not, for people in the fire department to take Polaroids for training purposes or that when there is a crash?

A. Yes.

Q. Showing you what's been marked Exhibit No. 2, do those appear to be three Polaroids showing the Explorer that you went to investigate that day?

A. Yes.

Q. And do they - strike that.

An officer testified he had some recollection of the front wheels being off the ground. Do you have any recollection one way or the other in that regard?

A. No, I don't.

Q. Do these photos truly and accurately portray the vehicle as it was at some stage that morning?

A. Yes.

Q. Also, the report of the Crete Fire Department, which is Exhibit 7, that's something they keep in the usual course of their business in terms of the calls they receive?

A. Yes.

MR. BLOCK: That's all I have, your Honor.

CROSS-EXAMINATION

BY MR. KRIVICICH:

Q. Mr. Sloop, aside from the abrasion above the bridge of the nose, did you note any other physical external injuries on Dr. Skowronski?

A. No, I did not.

Q. What was the time that you and your men departed with Dr. Skowronski from the scene of the accident?

A. According to my report we left the scene at 0859 hours.

Q. What was the time that you and your men arrived at the hospital with Dr. Skowronski?

A. We arrived at 0911 hours.

Q. So roughly 12 minutes later?

A. Correct.

Q. Did you make any notation of glass in the left hand of Dr. Skowronski?

A. Not that I remember.

Q. You made a notation of a starburst on the windshield?

A. Yes.

Q. Would I be correct in stating that you do not know how that was made in the course of the accident?

A. Correct.

Q. Did you examine the seat belt itself at any time to see if there was a mark on the seat belt that would indicate it locked up during the accident?

A. No.

Q. That's not part of your job, true?

A. True.

MR. KRIVICICH: Thank you. That's all I have, sir.

MR. MULLEN: Nothing.

MR. BLOCK: Just one question.

REDIRECT EXAMINATION

BY MR. BLOCK:

Q. Do you recall if when you arrived at the hospital at 9:11 you did some things outside before going inside?

A. No.

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