2. OPENING STATEMENT

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2. OPENING STATEMENT63

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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NASSAU: PART 15-------------------------------------xINDEX NO.Plaintiff,- against -Plaintiff's OpeningDefendants' --------xMineola, New YorkSeptember 4,B E F 0 R E:HON. STEPHEN A. BUCARIA,Supreme Court Justice and a Jury.AP P EAR AN C E S:SULLIVAN, PAPAIN, BLOCK,MC GRATH & CANNAVO, P. C.Attorneys for PlaintiffBY:DAVID J. DEAN, ESQ.FUREY & FUREY, P. C.Attorneys for DefendantsBY:JAMES M. FUREY, JR., ESQ.Thomas BasileOfficial Court Reporter·Tr ;Submitted by David J. Dean, Esq. Sullivan Papain Block McGrath & Cannavo P.C. New York, NY65

1234MR. DEAN:2Thank you, Your Honor.May itplease the Court.Jurors, thank you for coming back.All of5you are here and on time and we appreciate that.6It is so necessary for you to participate in7this incredibly important trial.89cPlaintiff's OpeningEverything the Judge told you is true, andit will be in your hands that the fate of the10family lies at the end of this case.11you know, we really shouldn't even be here.12This tragedy could have been so easily avoided.13You will see, and I promise you that you will14see, that on each and every occasion over the 1815months that the employees of thetreated16But, on17each one of those occasions, Maria Murphy had a18brain tumor, and on each one of those occasions19over 18 months, they didn't diagnose it.20each one of those occasions her brain tumor was21easily diagnosable.22show you that.23And onI promise you that I willYou may say, easily diagnosable?Yes,24easily diagnosable, her brain tumor, and how do25I know this?They have even admitted it.66Theretb

Plaintiff's Opening1(c32are examinations before trial in this case, and3I promise you, you will see us soon enough refer4to those examinations in which they have5admitted, and we know this is what our experts6are going to say, that7have easily been diagnosed.8removal.9it was so easy to diagnose her brain tumor.brain tumor couldShe died from itsWe'll get into that in a minute.By an invasive test?10How?11open?12they had to do, and all good medical practice13demanded that they do, was to have an MRI of her14brain.15endured -- endure; it's nothing to endure, it's16nothing harmful17it's a brain or whether it's a back or whether18it's a knee or part of a body.19non-invasive.20and certainly in this case would have diagnosed21her brain tumor.22it.23And they blew the diagnosis.24I promise you I will show you this in just a25minute -- she came in with a condition thatNo.By harming her?No.ButBy cutting herIn no way.AllAnd all of us have known people or havean MRI of some sort.WhetherMRis areMRis don't hurt.MRis are easyThere isn't any question aboutAnd that's what she had, a brain tumor.67She came in -- andtb

Plaintiff's Opening142showed that had they diagnosed it, it could, it3would have been resolvable and they didn't do4it.5Wait till you hear what they did do.I promise you that I will show you that6because of the negligence of the employees of7the defendant medical group, because of the8negligence of9practitioner, because of the negligence of1011the family, the neurologist,year old wife who was his soulmate.1213lost a 36Andlost a mother whoadored her children, and14andlost a beloved daughter, and it15didn't have to be.16promise you that I will show you that.17It didn't have to be and Iin July ofcame into the18medical group complaining of dizziness,19complaining of vertigo, complaining of loss of20balance and complaining of numbness in her arms21and legs, in her hands and legs.22serious business.23you will see, that doctors have to deal with and24say why is this?25balance?Now, this isThis is something that, asWhy is there a loss ofAnd by the way, I'm just not making68tb

1(52this up, it's in the records and you will see3the records.4things are blowups of the records.5have already been introduced into evidence and6we'll deal with that when the first witness is7called.8She comes in saying, I'm dizzy, I have lost my9balance, I have numbness in my hands andThe records and those big whiteThe recordsBut you will see that in the records.10numbness in my legs.11obviously.12think maybe because there's this loss of13balancing maybe it's her ears, let's clean out14her ears, a:nd they do that and have her looked15at and they know it's not her ears.16(Plaintiff's OpeningSomething is wrong,So initially, what they do is theyNow, let me make this very clear.We're17not saying that just because someone has a loss18of balance that means automatically they have a19brain tumor.20saying that a brain tumor can be one of the21reasons for dizziness and vertigo -- that, s a22fancy word for that -- and loss of balance, and23we're saying if you have these signs you've got24to look for it.25Wait until you hear what they did.We're not saying that.We'reYou've got to do something.69But whentb

Plaintiff's Opening1(2someone comes in and makes these complaints they3have to treat it seriously.4On theday ofofwent5towho thought that she may have this6problem with her ears causing the dizziness and7(6referred her to a doctor to be sure8it wasn't her ears and it wasn't.9also said she should have x-rays of a word10you're going to be hearing about throughout this11trial, cervical.12neck.13all it means is the neck area.14the world cervical spine and that's the portion15of the spine that's where your neck is.16Cervical.17the 22nd of August and those x-rays were18negative.19problems with the spine.20of the spine were on properly, they weren't21moved, they weren't tilted.22space between them.23you will see with regard to those x-rays shows24that her spine is okay.25Cervical is a fancy word forC-e-r-v-i-c-a-1, if you hear that word,You will hearSo they had x-rays taken on I thinkThe spine was fine.She calls,There were noIt was -- the piecesThere was a properEverything, I promise you,calledon the70tb

Plaintiff's Opening1(2third of September of that year and says, I'm a3little less dizzy but my right arm is numb.And, instead of saying see a neurologist,45instead of pursuing it, says, well, you should6have physical therapy.7You got something with dizziness, you got8something with numbness, this is a neurological9problem that neurologists have to deal with andWe say that's wrong.10evaluate and say what is wrong, what could be11wrong?Three months pass and on the fourth of12(713December ofgoes tois a neurologist.14.We don't know how she15got there because no one knows whether it was16idea and, again, both of these people17are employees, they're all employees of the18medical group, this HIP group.19they're sued, because of the negligence of the20employees is attributable to the group itself.21The Judge will tell you that at the end of this22case.23but I assure you that this is what you will see.So we don't have to deal with that now,, the neurologist, evaluates2425That's whyandsays that for the only time71tb

1clPlaintiff's Opening82in the 16 or more times that he sees Maria over313 months does he think, well, maybe she has a4brain tumor.5don't know why, because she does have a brain6tumor and as he has admitted, that brain tumor7could have been diagnosed had it been done, the8MRI of the brain.9be a number of reasons forBut he then discounts that.IBut he says, well, there maydizziness.10Why do I know this is what he says?Because I11asked him.12he says, well, dizziness could be caused and13loss of balance, all those problems could be14caused by problems with the inner ear.15there weren't any, so that's discarded.16could be caused by vascular, that is, blood17problems.18discarded.19is, an accident of some kind.20any, so that's discarded.21but that's discarded.22effect, but that's discarded.23stroke, but she didn't have a stroke so there24are only two things left:25she had, or something called a postural strain.Because I took his examination andButItBut there were not any, so that'sIt could be caused by trauma, thatBut there wasn'tIt could be toxins,It could be a drug sideIt could be aA brain tumor which72tb

Plaintiff's Opening1(\c2That is some kind of strain from the posture3that you're in.4neurologist, says, the reason for your problems,5Maria, the reason for your dizziness and your6loss of balance and your numbness is the way you7are holding the telephone.8He says you have -- you're using a telephone at9work and the way you are holding that telephoneAndtheThat's what he said.10has caused your problems.11a woman who has a brain tumor?12her in traction.13the door putting weights on the other side and14that's how he treats a woman with a brain tumor.So how does he treatReady?He putsHe hangs her by her neck overNow, they're going to say, well, we didn't15(916know she had a brain tumor and we say, but you17should have because you have to explore this.18If there are two choices, one is a brain tumor19that can and did kill her and the other is20holding a phone at your ear, how about deciding21and doing what you have to do to be sure it's22not a brain tumor?23say,24and says your common sense, is no.25too much to ask because -- and I promise youIs that too much to ask we, and the answer, say our expertsThat is not73tb

Plaintiff's Opening1(c102that you're going to get medical testimony for3this4doctor.5is better than later to diagnose.6a brain tumor and you know what brain tumors do,7the sooner you find out about it the better off8a patient is going to be.but you know this just as well as anyWhen it comes to brain tumors, soonerIf you've got9Now, if there's something wrong with that10logic, maybe you can tell me it at end of this11case.12diagnose a brain tumor the better off you're13going to be.But doesn't that figure?14MR. FUREY:15MR. DEAN:16THE COURT:18MR. DEAN:20This is argument.That's what the evidence isgoing to be.1719Objection.The sooner youOverruled.I promise you that's what theevidence will be.Remember, as I told you in jury selection,21as I represent to you now, we're not talking22about cancer.23malignancy.24hesitate to use this word because it's so25strange -- benign brain tumor.We're not talking about aWe are talking about -- and IThere is no such74tb

1(c112thing as a benign brain tumor, but you'll hear3the word benign as opposed to malignant.4hear the word benign because it's not cancer.5But she has a brain tumor and that brain tumor6is changing her brain because brain tumors do7this in two ways.8confines of the skull there is brain tissue and9blood and cerebrospinal fluid.You'llIn your brain within theYou'll hear more10of this later.11introduced into your brain like a tumor, that12disrupts things in two grounds.13chemistry of the brain by the way, as well as,14as you can understand, as the tumor gets larger,15portions of the brain are pushed aside and16damaged and that's what happened.17(Plaintiff's OpeningIf something foreign isIt changes theOn the second day of April of18had brain surgery which was unsuccessful.That19brain surgery was performed by competent20doctors.21the skilled and dedicated brain surgeons who did22their best to do the right thing for23never have and never will say they were24responsible.25responsible are the doctors who never diagnosedThere is no claim now or ever againstWho is responsible?WeWho are75tb

Plaintiff's Opening112(\(2her condition for all those months beforehand3while that brain tumor was growing and4displacing certain portions of brain tissue and5disrupting the brain itself.6in the surgery was almost the same thing as what7happens when you take a can of soda and you open8up that top of the can.9spills out and shoots up.But what happenedSometimes the sodaAnd when they opened10her brain, when they opened up her skull, the11brain expanded and bled so that there was12nothing they could do about it.13fault.14They sewed her up and eleven days later she15died.16can imagine for the family, and at one point Jim17and18saw her open her eyes and they felt she was19saying goodbye to them.20at that time she died.21mother.22It wasn't theirAnd they couldn't stop the bleeding.It was not an easy eleven days, as youfather were at her bedside and theyOn the 13th of36 years old.Wife andNever should have been.It was the summer of 1979 when they met.23was 18, just graduated from high school, and24was 17, dark haired, dark eyes, laughing,25vivacious, delight to be with, and they met when76tb

( .13Plaintiff's Opening12they worked in the same store in the same deli3department and they became friends.417.5and she said no.6would approve.7fashioned, old line.8different society and culture, and he kept on9asking her out and she kept on saying no.He 18, sheAnd after awhile, he started to ask her outShe didn't think her parentsThey were a kind of oldShe,, aAnd10then he stopped asking her and not too long11after that she came to him and she said, I'd12like you to meet my family and he said okay.13And he went and met the family and they started14to date and became engaged and two years later,15in May of16after that,17and then thereafter18everything that you would expect her to do, took19care of the kids, she did everything in the home20and she worked.21worked full-time, took care of the kids22full-time.23know how but they can.24for them.25until she went to see the defendant HIP andthey married.Not too longwas born, that'sanddidShe became a travel agent,Moms can do that, you know; I don'tAnd it was a good lifeThe families did things together77tb

1(23(these two doctors.14And then everything changed.We are not saying the defendants caused the4brain tumor, of course not.5to remain undiagnosed.6Each and every one of those visits that7went to the group, whether it was8who she saw maybe a half dozen times, or9cPlaintiff's OpeningBut they allowed itThey can't deny that.,the neurologist who she saw at least 1610times, each and every time she had that brain11tumor, each and every time it was undiagnosed.12Every time.13the way, at one point they did a CAT scan of her14cervical spine and that CAT scan was negative so15you have a negative x-ray because they tried to16figure out why this numbness, why this17dizziness?18neck, cervical spine, and a CAT scan negative,19so it wasn't that.20say, do what they should have?21have done was the MRI because that would have22shown it and it is serious business to a23neurologist, and should be to a family24practitioner like25to them with numbness and dizziness and loss ofThey never, ever did the test.ByYou have a negative x-ray of theWhy didn't they, our expertsWhat they should, when someone comes78tb

Plaintiff's Opening1(2balance.3We're not talking about your wrist hurting, not4that that's not bad.5little ache in your back, as I have as I get6older, or anything like that.7about loss of balance and numbness and this, as8you will see, was caused by what was growing9inside her brain, that they never diagnosed and10(This is no fooling around matter.We're not talking about aWe are talkingthey should have diagnosed.Now, how it was diagnosed?11c15They changed12their HIP plan.They didn't have HIP any longer13in January of14doctor because it was another plan and that15doctor says, wait a minute, you've got this16numbness, you've got this loss of balance.17send you to a neurologist and you know what that18neurologist ordered?19brain.20done by somebody else and that's what showed it.21That MRI of the brain that was taken in February22of23diagnosed.24we -- the defense in this case is going to be --25and this is part of our evidence -- the defenseSo they went to anotherRight.I'llAn MRI of herThat's what good medical practice wasshowed that which they should haveIt showed that brain tumor.How do79tb

Plaintiff's Opening1(162in this case is going to be, didn't make any3difference whether we diagnosed it in 1996 or41998.5of recovery from that surgery are going to be6the same.7Show me.8You know what happened?9changes, the evidence of these changes and theSo what?Her chances or lack of chancesThat's what they're going to say.That's not so because she did change.When we see the10changes in the tumor itself, because what11happens is that at either the end of '97 or the12beginning of '98 there are changes showing the13change in the tumor.14which could have been prevented had they15diagnosed it.16down.17Her voice has become hoarse.18was caused by the brain tumor expanding.19her tongue, and there's a medical reason for it,20becomes misshapen.21I22change in that tumor.23have been diagnosed that wasn't.24diagnosed, they would have operated earlier and25had they operated earlier chances for survivalHow the tumor is changed,Her eye starts to jump up andThat's a bad sign.She starts to drool.You will see thatAndThat's the fourth thing thatcan think of just right now, four examples ofThe tumor that shouldHad it been80tb

(((217Plaintiff's Opening1were so much greater.3Experts are going to tell you that.We'll4have expert neurologists, who will say you've5got to give her, given these symptoms of loss of6balance, given these symptoms, you've got to do7right away an MRI of a brain.8that.9stick her, hang her from a door as he did.You have to doYou can't just say, put her in traction,10you know something?As11back visit after visit, you know what12was doing?13hang her more.14some treatment for a brain tumor.15know it was a brain tumor.16have.Andcame back and cameHe was increasing the traction.17MR. FUREY:18MR. DEAN:Increase the weights.SoThat'sHe didn'tWell, you shouldObjection, Your Honor.I'm almost finished,19respectfully, Judge.20THE COURT:21MR. DEAN:Go on.So, you hear a neurosurgeon22saying had it been diagnosed earlier her chances23of survival were so much greater and they should24have diagnosed it earlier.25evidence, you may or may not hear an internistDepending upon the81tb

1say the same things,3certain things.4an economist say something that I don't want you5to find any way offensive.6put a dollar and cents amount not only on the7lost wages, which is easy enough, but also on8the things that a housewife and mom does around9the house.11"--·--should have doneShe didn't do it.You'll hearHe's going to try toIt's imperfect but it's the best wecan do.But the most we can do is to remind you12about the loss have a wife and a mother and the13loss of a mother's care and a mother's guidance.14What does it mean to the children?15terrific a guy as16father as he is, he's not a mother.Because asis, as loving a17THE COURT:Mr. Furey.18MR. FUREY:Thank you, Your Honor.19Afternoon, ladies and gentl.emen, Your20Honor, Mr. Dean.21I represent.(18210(Plaintiff's OpeningandLike you will hold the fate of the23Murphy family in this case, you will also hold24the fate of the doctors in your hands.25talking to you this afternoon about who myI'll be'·82tb

The Opening Statement in the Herniated Disc CaseBy Ben Rubinowitz and Evan TorganAlthough at one time, the law recognized a herniated disc for what it was – a significantand debilitating injury, today, with the statutory threshold requirements of Insurance Law § 5102,the plaintiff is faced with a difficult task. The plaintiff must convince a jury of the “seriousness”of this type of injury. Given the time restrictions on voir dire, the first real opportunity to explainthe nature of this type of injury is through a thoughtful and detailed opening statement on theanatomical features of the herniated disc and the debilitating physical limitations resulting fromsuch an injury.The opening statement is a critical juncture in the case. It sets the stage for impressingthe jury of the righteousness of your client’s cause. Start with an introduction that encapsulatesthe entire case in just a few seconds:On September 14th, 2002 Paula Plaintiff knew she had been rear ended. What shedidn’t know at that time was that her spinal column would be permanentlydamaged. What she didn’t know at that time is that she would sustain herniateddiscs. And what she didn’t know and couldn’t possibly have known is that thoseherniated discs would affect not just her spine but her whole body. What Paulanow knows is that one day she will require surgery for those herniated discs.What she now knows is that she will require a life-time of physical therapy forthose spinal injuries. And what she now knows is that her life will never, ever, bethe same. Through no fault of her own, Paula has suffered injuries that havechanged her life, injuries that will remain with her for the rest of her life.The next thing you have to do is introduce your client, as well as the defendants. Towardthat end, you must humanize your client, and to the extent possible, dehumanize the defendants.Let the jury know who your client is and, more importantly, who she was before the incident thatcompromised her health:183

You know by now that I represent Paula Plaintiff. She is the plaintiff--the onebringing the lawsuit. Permit me to tell you a little bit about her, because to firstunderstand how the injuries have affected the woman, you must first understandthe woman.Then tell the jury what she was like before the accident that changed her life; herenjoyment of physical activity, exercise and time spent with her family. Describe her children’sreliance on her, how she strove to achieve success in her vocation through education and hardwork. Explain how her relationships with her husband, her children and her co-workers haveforever changed:Paula worked hard to get where she was in life. Since she was a little girl, shewanted one thing, and one thing only: to become a nurse. And she worked hard toreach that end. While still in high school she worked at a local communityhospital as a candy striper, assisting patients with their needs. She got goodgrades in high school so that she could get into a top nursing program in college.After graduating with a college degree, she received post-graduate degrees innursing and finally became a Registered Nurse. She has taken care of patients forthe last ten years, and enjoys her job.Prior to this incident, she was able to work twelve hour shifts and provide for herhousehold. Although she was proud of her status as a registered nurse, she boreno greater title than that of “mom.” Unfortunately, because of this accident andthe resulting injuries to her spinal column, she is limited in what she can do forher children. She cannot play with them as she once did, do their laundry or evenhelp them with their homework.While it is important to generally describe the injuries to your client in a manner thatpromotes your cause, you must also deal with the weaknesses in your case and portray them in alight most favorable to your client. Common weaknesses such as the failure to wear a seatbelt, alow speed impact, minor damage to the vehicles or a failure to seek immediate medicaltreatment, must be addressed during the plaintiff’s opening in anticipation of the defendant’sopening:284

Paula was helping to transport a stroke patient from one hospital to another at thetime of this incident. She was sitting in the front passenger seat of the ambulettewithout her seatbelt. But because of her concern for her patient in the back seat,she was facing toward the rear, clearly not bracing for an accident. So althoughthe defendants will testify that the impact was low velocity -- and you’ll see thedamage to the vehicles was minor -- Paula was in a very awkward position. Herneck was turned partially to the side and rear. The impact -- which was in thespecific compartment where she was sitting -- caused her neck to twist andcompress from side to side.Because it was a side impact, a seatbelt would not have helped her. That isbecause she was sitting right next to the door and the force of the truck actuallycame into her body. No seatbelt would have prevented her injuries – particularlyher injuries caused by the forces of extension and flexion. Moreover, because ofher concern with her patient in the back seat, Paula was not braced for theaccident. Paula was right at the center of impact and couldn’t possibly have seenit coming. A police officer got to the scene almost immediately and asked ifanyone was hurt. Although Paula was injured, she refused an ambulance andrefused medical treatment at the scene. She told the police officer she was fine –for two reasons. The first was, she thought she was fine, just shaken up. ForPaula, because of the accident and her injury, her adrenaline had kicked in: thebody’s natural fright or flight response. When someone is injured, the bodysecretes epinephrine or adrenaline, which allows a person to carry on until theyare in a position of relative safety. So Paula told the officer she did not need anambulance. Second, and more importantly, there wasn’t a chance Paula the nursewould ever leave that patient behind. She wanted to ensure that her patient safelyarrived at the hospital that could care for her. And she did just that.When she finally went home, despite the fact that she was hurting, she did not goto her doctor, although obviously as a nurse, she had easy access to medicaltreatment. Her next order of business was to take care of her two little girls whohad arrived home from school. She took Advil and carried on with herobligations as a mother. The last thing she wanted to do was worry her children.Unfortunately, things got worse for her overnight. Paula couldn’t sleep. She haddifficulty moving. The pain, which had originally been localized to her neck,started radiating or traveling down her arm into the fingers of her right hand.In any opening statement involving physical injuries it is imperative that you outline theinjuries in great detail. That being said, however, you should never overstate them. To be able toproperly explain your client’s injuries you have to explain the relevant anatomy to the jury:385

To understand what these herniated discs are you first have to understand theanatomy, so bear with me while I go through it briefly. As I said earlier, Paula hasinjured portions of her spinal column. The spinal column protects the spinal cordwhich is an extension of the brain. Just as the brain is protected by the skull, thespinal cord, which is the nerve center of the body, is protected by the spinalcolumn which consists of bone, known as vertebral bodies. The spinal columnconsists of three areas: the neck or cervical spine; the mid back, which has twelveribs attached to it, known as the thoracic or dorsal spine; and the low back knownas the lumbar spine or lumbosacral spine. Paula suffered a herniated disc at twoplaces, the cervical spine and the lumbar spine, known as the C6-C7 level and theL5-S1 level. The neck has seven cervical vertebral bodies, the thoracic spine hastwelve vertebral bodies and the lumbar spine has five vertebral bodies. Thesevertebral bodies are hard, and are actually bones. Just as the spinal cord needs tobe protected by the vertebral bodies of the spinal column, the vertebral bodies areprotected by the discs. In between each bone or vertebral body is a substanceknown as a disc. And those discs actually act as shock absorbers for the vertebralbodies. The discs are what give us the ability to jump, flex and bend. They act ascushions for the bone, so without those discs we would have bone constantlyrubbing on bone which would cause great pain, bone spurring and arthritis.These discs consist essentially of two major parts. The outer shell known as theannulus fibrosis or more simply as the annulus. The inner portion is known as thenucleus pulposus, or the nucleus. The outer shell, the annulus, is the hard portion.It is not as hard as bone, but much harder than skin or muscle. It is a cartilaginoussubstance like the cartilage in our noses or knees. It is actually known asfibrocartilageThe inner substance or the nucleus is made primarily of water and is soft orgelatinous. It is that portion of the disc that provides the cushioning or shockabsorption qualities.So to visualize a disc it may be a good idea to picture a stale jelly donut. Thecrusty part of the donut is the annulus fibrosis and the jelly on the inside is thenucleus pulposus.Now that you have laid out the general anatomy, tie it in with your client and demonstratethe actual injury itself by going through the medical explanation of a herniated disc:The word herniated is derived from the word hernia, meaning a portion of thebody is displaced to an area where it should not be. A herniated disc takes placewhen the nucleus pulposus breaks through the outer layer known as the annulusfibrosis.486

It is not enough to describe a herniated disc. You have to explain to the jury why it ispainful and physically debilitating:Now let me tell you why this disc herniation is causing Paula tremendous pain.The annulus itself has nerve fibers in it. This is causing Paula localized neck pain,just from the tear in the annulus itself. But what makes matters worse, is that thedisc is herniated posteriorly and laterally, or toward the back and to the side. Theimplications for Paula are devastating. Because the disc is sticking out laterally, itis impinging on or touching a nerve root which emanates from the spinal cordposteriorly to the disc and comes through a hole on the side of the vertebral bodyknown as the neural foramen. Because the disc is herniated at the level of C6-C7,it is causing pain down a specific nerve root or dermatome pattern that goes fromPaula’s neck behind her shoulders down her arm and into her thumb, middle andindex fingers. This injury doesn’t just affect her neck, but her shoulder, arm andfingers as well. She is not just in horrible pain but has limited use of her right armand difficulty with the fine motor coordination needed for using her fingers orgrasping objects.It is a good idea to explain all the things your client can no longer do because of herinjuries. Do not just focus on her inability to work, but be concerned with her inability tofunction outside of work as well:Obviously, based on these injuries, Paula cannot lift patients any

see, that on each and every occasion over the 18 months that the employees of the treated , on each one of those occasions, Maria Murphy had a brain tumor, and on each one of those occasions over 18 months, they didn't diagnose it. And on each one of those