3.Latiesha Dukes — Cross/Redirect/Recross (Part 2)

MR. REDDINGTON: Thank you, Your Honor.

MR. REDDINGTON: Morning.

MR. REDDINGTON: So can you tell me, is it four times that you yourself actually met with Lindsay or more?

MR. REDDINGTON: I'm sorry. Was it four times that you actually met with Lindsay or more? And that would include telehealth.

MR. REDDINGTON: Four times. Okay. You met with her on the 2nd of December, right?

MR. REDDINGTON: And you met with her on the 12th of December. Is that right?

MR. REDDINGTON: You met with her on the 19th of December, right?

MR. REDDINGTON: And is it the 27th as well? Was there another one? Do you remember when that was?

MR. REDDINGTON: By phone.

MR. REDDINGTON: And would that be the 27th?

MR. REDDINGTON: Okay. So what I'm gonna do is give you the documents that the district attorney is questioning you from just so that you may actually have in front of you, okay?

MR. REDDINGTON: Then you can slide up and just—

MR. REDDINGTON: And if I get confused or something, just let me know that I'm on a—you're on a different page than me. Couple of background questions. When you met with Lindsay, for example, on the 2nd of December, you were at least able to look at the records of Nurse Paul as well as Nurse Jollotta, right?

MR. REDDINGTON: Oh. I mean, you guys work in the same place though, right?

MR. REDDINGTON: Okay. So when a woman is in postpartum and comes to South Shore Health for help, when you're trying to help them, you can't see the medical records from what the other people like Nurse Paul and Nurse Jollotta have written down?

MR. REDDINGTON: You can?

MR. REDDINGTON: Okay. So you did look at the records?

MR. REDDINGTON: Okay. On just—on the 2nd of December, and you can look along with it if you wish, looking under what would be referred to as behavioral health intake. Your pages are numbered, mine are not. So if you can find that one page, behavioral health intake on December 2nd. And the jurors will have this as an exhibit, but just going through the pages. Do you have it?

MR. REDDINGTON: Okay. Now, one of the things that you would be interested in when you're interacting with a patient that comes to your facility for help is how honest they are, right?

MR. REDDINGTON: Especially in psychiatry. You wanna make sure that the person is not lying to you or hiding something. You want them to be honest, right?

MR. REDDINGTON: And for example, Lindsay disclosed to you and to the others that back in 2012 while she was in nursing school, she actually had Prozac because she was very nervous actually about public speaking, but she was on Prozac, right?

MR. REDDINGTON: Sure. I think it's right under behavioral health history, first paragraph.

MR. REDDINGTON: Okay. And she also told you that she had been prescribed Ativan, for example, by a psychiatrist, Jennifer Tufts, right?

MR. REDDINGTON: Second paragraph.

MR. REDDINGTON: Okay. Do you see where it says, "Prior to attending the Sosua program," sent in the second paragraph?

MR. REDDINGTON: "Patient was prescribed Ativan by psychiatrist Jennifer Tufts"?

MR. REDDINGTON: Well, I must be misreading something. I apologize. Let me approach you.

MR. REDDINGTON: This is what I have here. History of current functioning, right? History and current, okay.

MR. REDDINGTON: And then behavioral health history, paragraph one, right, references the Prozac, right?

MR. REDDINGTON: Okay.

MR. REDDINGTON: No, I was saying the second paragraph, prior to attending Sosua program, she disclosed to you that she was prescribed Ativan, right?

MR. REDDINGTON: Second paragraph right here.

MR. REDDINGTON: Yeah. Prior to attending Sosua program, patient was prescribed Ativan, right?

MR. REDDINGTON: Okay. And that was by Dr. Tufts, right?

MR. REDDINGTON: So she told you that she was prescribed a benzodiazepine by her treating psychiatrist, and further on into your interaction with her, she told you that she was very concerned about taking medication, right?

MR. REDDINGTON: And she was really concerned about becoming addicted to medications such as a benzo like Ativan, right?

MR. REDDINGTON: All right. In the very last paragraph, it says, "When no longer taking Ativan," you see that one?

MR. REDDINGTON: Okay. She then explained that, you know, she had issues with the sleep, and she started having heart palpitations, and she went to the ER for anxiety. Is that right?

MR. REDDINGTON: And at that time, she told you that she felt that she had an addiction to Ativan. That's why she couldn't sleep, right?

MR. REDDINGTON: And she was stressing about that, was really concerned about that, right?

MR. REDDINGTON: She then said that she had weight loss, right?

MR. REDDINGTON: No appetite, right?

MR. REDDINGTON: Panic attacks, right?

MR. REDDINGTON: Couldn't sleep, right?

MR. REDDINGTON: Next page, December 2nd, office visit, the same visit. First paragraph, she was prescribed Remeron and Seroquel in the past four days, right?

MR. REDDINGTON: Okay. So the next page. Do you have time?

MR. REDDINGTON: Okay. All right. Let's look at this one then. Is this... Would you agree that this is a record from South Shore Health, and it talks about continuing your appointment December 2nd?

MR. REDDINGTON: Okay. If you can find that.

MR. REDDINGTON: Okay.

MR. REDDINGTON: That's fine. That's no problem. That's not your fault. So are you with me on that, that she was prescribed Remeron and Seroquel?

MR. REDDINGTON: Okay. And that was within the last four days. Is that right?

MR. REDDINGTON: So when you saw her on December 2nd, after telling you about the Ativan, and telling you about her weight loss, and her anxiety, and everything else, she told you that she had been prescribed Remeron and Seroquel. And I understand you don't do the drugs, so you don't really have-

MR. REDDINGTON: ... very difficult to get the brand names, and the other names, and it... But we have a chat for that. So she started Remeron and Seroquel, and then she told you that since starting the medication, she's had thoughts that she no longer wants to be here, meaning, I guess, what, on the earth?

MR. REDDINGTON: Going to kill herself?

MR. REDDINGTON: Okay. And then she indicates further that this week, she was seeing you, feels like she's gonna die. That's what the DA read to you, right?

MR. REDDINGTON: But then it goes on and says, "But she doesn't care if she dies," basically. She feels like she's gonna die, but she doesn't care. She said that, right?

MR. REDDINGTON: She then talked about how the Remeron and Seroquel were not helping her sleep. Yesterday she took Ativan, she told you, right?

MR. REDDINGTON: Due to intrusive SI, suicidal ideation, thoughts, right?

MR. REDDINGTON: Do you... Did she indicate what the intrusive suicidal ideation thoughts were yesterday, which would be December 1st? Did she tell you what that meant? Did you ask her what she meant by that?

MR. REDDINGTON: Okay. And you then told her that she could go to the ER, and that you then sent her local crisis contact information. Is that right?

MR. REDDINGTON: And then talks about onset. Says three months after the baby was born, she had unmanageable anxiety. Correct?

MR. REDDINGTON: And what did she tell you the anxiety was about?

MR. REDDINGTON: Yep. It's under onset.

MR. REDDINGTON: Under onset, she indicated three months after the baby was born she had unmanageable anxiety, is what—

MR. REDDINGTON: ... the district attorney asked you. And then it continued on with a sentence. What was her anxiety about?

MR. REDDINGTON: And what did she... What does that mean, that she was having unmanageable anxiety? Do you know, what does unmanageable mean?

MR. REDDINGTON: And at that time, the children were four, three, and six months, right?

MR. REDDINGTON: Under social, the notes indicate that she reported she talks about her anxiety all the time with her mom, husband, and mother-in-law. Correct?

MR. REDDINGTON: And one of the questions the DA asked you is about her support, family supports or collateral contacts, and you indicated the mother-in-law. She also had her mother and father as family support as well, right?

MR. REDDINGTON: And you knew that her mother and father had actually lived in Connecticut, but moved up or came up and stayed with her for at least a week, if not longer, during December, right? If you know.

MR. REDDINGTON: And I know it's difficult, if it's not in the notes, for you to remember. I'm just asking, do you remember at all that she said that her mother and father came up and stayed with her to help out?

MR. REDDINGTON: Okay. She further went on and said that she's uninterested in other topics from friends. What did that mean? She just didn't want to talk to her friends about anything?

MR. REDDINGTON: And that would be her social circle. She just didn't care, right?

MR. REDDINGTON: She said that she felt numb, right?

MR. REDDINGTON: She had a lack of attention, right?

MR. REDDINGTON: Confusion, right?

MR. REDDINGTON: Under mood it says, well, of course, you have disturbed sleep. She's only sleeping two to four hours a night, is what she told you, right?

MR. REDDINGTON: And then it says supports. Mother and father had been staying with her for the past week. Does that refresh your memory that you did get that info, that they were staying with her for the past week?

MR. REDDINGTON: That's fine. I just saw that too, so no problem.

MR. REDDINGTON: You took her history, that she was a nurse, that she had been on leave. And she told you that she lost 10 pounds in the past month, right?

MR. REDDINGTON: Now, can you flip to the next page and make sure we're both on the same page? Under substance use assessment, do you have that?

MR. REDDINGTON: Yep.

MR. REDDINGTON: Okay. So one of the things that you're concerned about is whether or not your patient has a substance abuse problem, like drugs or alcohol or something like that, right?

MR. REDDINGTON: And you've already told us that your opinion was that Lindsay did not have any substance abuse problems, other than her fear about the prescribed Ativan, right?

MR. REDDINGTON: So did you ask her about alcohol?

MR. REDDINGTON: Can you tell me what she said about alcohol?

MR. REDDINGTON: Did she—go ahead.

MR. REDDINGTON: Did she tell you how much, what it is, or her alcohol of choice was?

MR. REDDINGTON: Did she say why she would do that?

MR. REDDINGTON: Okay. And this is back in 2019, right?

MR. REDDINGTON: That would be three years before you actually met with her in December of '22, right?

MR. REDDINGTON: Cannabis?

MR. REDDINGTON: The weed. The devil's lettuce. How about that? Did she confess that she was using marijuana?

MR. REDDINGTON: When?

MR. REDDINGTON: Why?

MR. REDDINGTON: Why did she say that she used it? It's under comments?

MR. REDDINGTON: That's okay.

MR. REDDINGTON: And that was on November 15th of '22, right?

MR. REDDINGTON: Go to the next page, assessment and recommendation. If you have that, make sure we have it.

MR. REDDINGTON: Okay. And I think the district attorney had asked you about the mental status exam, facial expression, and you indicated that her facial expression showed anxiety, right?

MR. REDDINGTON: Fear, right?

MR. REDDINGTON: Do you know what the fear was?

MR. REDDINGTON: Sure, yeah. It's under facial expression.

MR. REDDINGTON: Yes, please. Yeah.

MR. REDDINGTON: Okay, so if I can, I apologize, if you just keep your voice—you're very soft-spoken.

MR. REDDINGTON: Voice up so the jurors can hear you.

MR. REDDINGTON: Thank you. And you said that her facial expression exported to you anxiety, right?

MR. REDDINGTON: Fear of something, right?

MR. REDDINGTON: Apprehension, right?

MR. REDDINGTON: Sadness?

MR. REDDINGTON: Depression?

MR. REDDINGTON: And she expressed that she was having anxiety and numbness, right?

MR. REDDINGTON: And she was crying when she was telling you this, right?

MR. REDDINGTON: And again, indicated that her thoughts were worried about her baby, the new baby she had, the infant, as well as if she's being addicted to Ativan, is what she told you, right?

MR. REDDINGTON: And again, thoughts of wanting to die, but there was no plan.

MR. REDDINGTON: Next page, risk assessment. There's a whole lot of stuff on it, these pages. I'm just trying to cut to the chase here. So you see where it says risk assessment?

MR. REDDINGTON: Okay.

MR. REDDINGTON: Yep.

MR. REDDINGTON: It's under current medic—I'm sorry. It's under risk assessment.

MR. REDDINGTON: Okay.

MR. REDDINGTON: Okay, let me ask you, under risk assessment on December 2nd, when you asked her about that, so at that point did she... Let me see here. Did she again admit to suicidal ideation, right?

MR. REDDINGTON: It was passive?

MR. REDDINGTON: It says to go to ER if she feels unsafe or has a plan, right?

MR. REDDINGTON: And then farther down you have current medications, and she was on quetiapine or Seroquel, right?

MR. REDDINGTON: Fluoxetine or Prozac, right?

MR. REDDINGTON: Lorazepam or Ativan, right?

MR. REDDINGTON: Mirtazapine or Remeron, right?

MR. REDDINGTON: And they were all, that was all active prescriptions that she had on December 2nd, right?

MR. REDDINGTON: Told you that she is seeking counseling for postpartum anxiety, right?

MR. REDDINGTON: Do you have on December 2nd, continuing on with your evaluation, where it says clinical notes? Do you have the clinical notes?

MR. REDDINGTON: What I could do is read what I have rather than stand next to you, and if you trust me that I'm not misrepresenting it. I mean, I'm just reading off of this to make it quicker for you—

MR. REDDINGTON: ... if it refreshes your memory. If it doesn't, I can walk up and show it to you, okay?

MR. REDDINGTON: On that date, your notes say, "Patient requested addiction support services." Do you recall that?

MR. REDDINGTON: And that you indicated that you would be sending patient addiction support resources by MyChart or the message thing, right?

MR. REDDINGTON: You then indicate that based on history reported, patient meets the criteria for postpartum anxiety, right?

MR. REDDINGTON: That she would benefit from OP therapy. What does that mean?

MR. REDDINGTON: Okay. PHP?

MR. REDDINGTON: IOP?

MR. REDDINGTON: And that you then helped her out by bridging the therapy services, right?

MR. REDDINGTON: You then noted again postpartum anxiety on December 2nd, according to your notes, right?

MR. REDDINGTON: Okay.

MR. REDDINGTON: Now, did you know that she had been seeking and receiving therapy? I don't know if that's, it's therapy or counseling or that type of thing. Like, there's a woman that works in your business that provides therapy, right?

MR. REDDINGTON: So did she come to see you for therapy?

MR. REDDINGTON: How many times?

MR. REDDINGTON: So is it fair to say that she was more than willing to accept help from somebody like you?

MR. REDDINGTON: She didn't appear to be avoiding any therapy—

MR. REDDINGTON: ...when recommended, right? If you could, Ms. Dukes, please look at, I think it was December 12th, was the next time perhaps that you saw her.

MR. REDDINGTON: Unless it's, there's another intervening period.

MR. REDDINGTON: Oh, okay. So if you could pull out December 5th.

MR. REDDINGTON: And if I can come up and look at it with you.

MR. REDDINGTON: Thanks.

MR. REDDINGTON: All right. So on December 5th, again, you were meeting with her for therapeutic intervention, right?

MR. REDDINGTON: And on this occasion, she reported she had a difficult weekend, right?

MR. REDDINGTON: Intrusive thoughts of wanting to die, right?

MR. REDDINGTON: That she contacted Aspire Crisis Support, right?

MR. REDDINGTON: She met with an Aspire clinician, right?

MR. REDDINGTON: And what happened when she met with the Aspire clinician?

MR. REDDINGTON: So if she said, in addition to the fact that she's been in counseling and therapy and seeing psychiatrists and on medications for the past three months or whatever the period ultimately would be, and that she wanted to kill herself, didn't wanna be here, couldn't care if she died, they told her because she didn't have a plan that they couldn't help her?

MR. REDDINGTON: Did they, to your knowledge, make any recommendations? Did they suggest, recommended that she attend a day program?

MR. REDDINGTON: All right. And that person from Aspire then said he would send her patient resources, right?

MR. REDDINGTON: But nothing ever happened. He never sent her any. You did, but he never sent her any patient resources, right? If you know.

MR. REDDINGTON: Okay. All right. So she had you at least to talk to and counsel and advise her. You continued on to make your observations. Fair to say that pretty much things stayed the same as far as her appearance, appearing anxious, appearing sad, unable to relate to people, that type of thing?

MR. REDDINGTON: Okay.

MR. REDDINGTON: Then you have as a chief complaint of present illness, and again, that would... Oh, wait a minute.

MR. REDDINGTON: That's not you. Okay. All right. So you can hold onto that again.

MR. REDDINGTON: Thank you. Next time you saw her would be December 12th. Is that correct?

MR. REDDINGTON: All right. Now, on December 12th, that was a teleconference that she had called in, by an appointment with you?

MR. REDDINGTON: And at that point, this is, she reported that she had a difficult weekend and was in, experiencing intrusive thoughts of wanting to... Do you have it in front of you? I don't wanna take advantage of you.

MR. REDDINGTON: Yep.

MR. REDDINGTON: Okay.

MR. REDDINGTON: Page 28.

MR. REDDINGTON: And just for the record, I think, Your Honor, that she's looking at the actual exhibit. Am I right? That's the exhibit that's in evidence?

MR. REDDINGTON: No, it's not it. Oh, okay. Can it be in evidence? Can I offer that?

MR. REDDINGTON: Okay. Can I offer that?

MR. REDDINGTON: So, do you have December 12th?

MR. REDDINGTON: Again, I could do what I did before.

MR. REDDINGTON: Right. Yeah.

MR. REDDINGTON: It references provider's interventions. That, and that would be, would that be you, provider?

MR. REDDINGTON: Okay. And you're talking about symptom management, and yet again, she's reporting she had a difficult weekend, experienced intrusive thoughts, wanted to die. Didn't have a plan for suicidal plan, but she contacted crisis over the weekend, and that would be, again, Aspire apparently, right?

MR. REDDINGTON: 'Cause there were two times she contacted Aspire, not once.

MR. REDDINGTON: Twice. Both times they told her that there's nothing they could do for her, right?

MR. REDDINGTON: And she told you that she was gonna start a PHP in Norwell on December 20th, right?

MR. REDDINGTON: But in fact, you were able to, knowing people that you may have and pull strings, you were able to try to get her into the Rhode Island Women and Infants program, right?

MR. REDDINGTON: Which is a really pretty good program.

MR. REDDINGTON: And did you know that she did in fact go to Women and Infants on December 20th? She didn't go to the Norwell program, she went to Women and Infants program. And that she was there for the day, and that they basically turned her away.

MR. REDDINGTON: Okay. So if I suggest to you it was the same date that she had told you that she was gonna go to the program in Norwell on December 20th, and then that you and Nicole Harden Francis reviewed various options, one of which was that, which made sense to attend the Women and Infants program, IOP or PHP program, right?

MR. REDDINGTON: And that she, patient, provided you with verbal consent—

MR. REDDINGTON: ...to sign whatever had to be signed and get her into that program, right?

MR. REDDINGTON: So you know that she did, on December 20th, after not getting anywhere with Aspire times two, and after dealing with Jollotta for all those times that she dealt with her... I'm sorry, the other one, Tufts. You were trying to get her into this program, which would be pretty good for a woman that had postpartum problems, right?

MR. REDDINGTON: And you made your referral. You opened the door for her, and she got in there to at least be interviewed, right?

MR. REDDINGTON: And they didn't take her, right?

MR. REDDINGTON: You know why?

MR. REDDINGTON: Would you be surprised if I told you that they indicated that they could not help her out because their diagnosis or secondary diagnosis was that she was overmedicated?

MR. REDDINGTON: Would it surprise you to know that they indicated that they couldn't treat her as a woman with postpartum psychosis, or postpartum depression, or postpartum anxiety, or any of that, because their opinion was that she was suffering from an overmedication?

MR. REDDINGTON: But you don't know.

MR. REDDINGTON: Okay. Did you know that the records from Women and Infants indicate that in fact on that very same day they reached out to Nurse Jollotta and asked her to call them so that they could discuss the medication, and Jollotta never got back to her?

MR. REDDINGTON: I'm sorry?

MR. REDDINGTON: Okay. I think the district attorney had asked you a question about the last time that you saw her or had any activity with her was on December 19th. Is that right?

MR. REDDINGTON: Okay. And I may have misunderstood. Did she ask you, did, like, did you call Lindsay four times and she never got back to you that day, or is that just a list of different things that you did for her?

MR. REDDINGTON: Okay. So you were calling other contacts, you were talking to Patrick, you would contact her. I mean, she certainly was not avoiding you. That's—

MR. REDDINGTON: All right. You're familiar with, maybe you are, the, what's called the Edinburgh Scale?

MR. REDDINGTON: And did she have the Edinburgh Scale administered to her, to your knowledge?

MR. REDDINGTON: Okay.

MR. REDDINGTON: What is polypharmacy? What does that mean?

MR. REDDINGTON: Yeah. You ever heard of that, polypharmacy, where—

MR. REDDINGTON: Is it something to do with having too much medications thrown at you all at once? If you know.

MR. REDDINGTON: Not sure, okay.

MR. REDDINGTON: Excuse me for one minute.

MR. REDDINGTON: Apologize. I just had something pulled up and it just went back to default on me, so I just had... Need a second. I apologize.

MR. REDDINGTON: Okay, I get it. And how long have you been working in your particular field?

MR. REDDINGTON: Okay. And you have obviously a very impressive background as far as your educational background and your experience. Do you continue to, like, with continuing education?

MR. REDDINGTON: Have you ever been aware, are you aware of the Mass General Hospital Center for Women's Mental Health?

MR. REDDINGTON: Do they offer seminars and programs as well as research articles?

MR. REDDINGTON: Okay. Do you know that Mass General Center for Women's Mental Health, about a year ago issued a fairly major study and various recommendations for people that are dealing with women that have postpartum periods— and how they break up the periods. You familiar with that?

MR. REDDINGTON: So if I suggest to you that in that particular Mass General Hospital article, it goes on about postpartum period, and is it y— do you agree that the postpartum period, 85% of women that are pregnant exper— or after pregnancy experience some type of mood disturbance. Would you agree with that?

MR. REDDINGTON: All right. Would you agree that 10 to 15% of women develop more significant symptoms of depression or anxiety?

MR. REDDINGTON: Okay. And then postpartum psychiatric illness is then divided into three categories. One sounds like something out of the '50s, postpartum blues. Would you agree with that?

MR. REDDINGTON: You've heard that expression before, right?

MR. REDDINGTON: And that's, it can be bothersome, it can be aggravating, it can be intrusive, but it's not threatening the life of the mother or baby or anybody else, right?

MR. REDDINGTON: And it's fairly common, right?

MR. REDDINGTON: Number two would be postpartum depression. Now, that's a different issue, correct?

MR. REDDINGTON: And number three would be postpartum psychosis. Is that right?

MR. REDDINGTON: All right. Now, postpartum depression, prior to morphing, if you will, into postpartum psychosis, consists of a number of symptoms, symptomology, right? For you to diagnose a woman, whether she's pregnant, has the baby, or after having the baby, with postpartum depression, there are certain things that are symptoms that you look for, right?

MR. REDDINGTON: Okay. One of which would be depressed or sad mood, right?

MR. REDDINGTON: Lindsay had that, right?

MR. REDDINGTON: Next would be tearfulness, right?

MR. REDDINGTON: Lindsay had that, right?

MR. REDDINGTON: Next one would be loss of interest in social activities or usual activities or friends. She had that, right?

MR. REDDINGTON: Feelings of guilt. She had that, right?

MR. REDDINGTON: Okay. Feelings of worthlessness. Did she express that she felt worthless?

MR. REDDINGTON: How about fatigue? Did she have that?

MR. REDDINGTON: Were you—

MR. REDDINGTON: I know lack of sleep. Were you aware that, in fact, that she had indicated that she was so wiped out that she couldn't even get out of bed, couldn't put her feet on the ground, and if she did, she felt heavy?

MR. REDDINGTON: Okay. How about, you've mentioned it, you got it, sleep disturbance is another issue, correct?

MR. REDDINGTON: She had that, right?

MR. REDDINGTON: Change in appetite. She had that. Lost 10, 15 pounds, right?

MR. REDDINGTON: Poor concentration. She had that, right? She said she was numb.

MR. REDDINGTON: She could not focus. Suicidal thoughts.

MR. REDDINGTON: We know she didn't have a plan, but she had suicidal thoughts, right?

MR. REDDINGTON: So under the Mass General Hospital research project for women that are suffering from postpartum issues, she pretty much hit every one of the postpartum depression symptoms, correct?

MR. REDDINGTON: And then it talks about if it increases in severity, significant anxiety symptoms may occur. Not generalized anxiety. Significant anxiety symptoms can occur. Is that right?

MR. REDDINGTON: And one of the ways that you determine that is by the test that it can be administered to a person who is in a postpartum status, and that would be what we talked about, the Edinburgh test, right?

MR. REDDINGTON: And you're aware that she was given the Edinburgh test and had a twenty-three out of thirty, I think it was?

MR. REDDINGTON: Okay. And some women develop panic attacks referred to as hypochondriasis. You'd agree with that, right?

MR. REDDINGTON: Lindsay. She had panic attacks and complained of having panic attacks.

MR. REDDINGTON: Okay. And then you can get into the various diagnoses of which on a postpartum person in that timeframe, obsessive compulsive disorder, OCD, right?

MR. REDDINGTON: Or bipolar I or bipolar II, right?

MR. REDDINGTON: Trust me. I—let's say bipolar I.

MR. REDDINGTON: Okay? So that would be one mental disease, correct?

MR. REDDINGTON: And it's pretty serious stuff, right?

MR. REDDINGTON: And if a person is diagnosed as bipolar, one of the things that you shouldn't, if you know, is prescribe SSRIs such as Prozac or Zoloft, right? If you know.

MR. REDDINGTON: Okay. Would you agree that, with various cases dealing with postpartum depression, all of the symptoms that we talked about, they utilize the Edinburgh Postnatal Depression Scale, which is a ten-item questionnaire that can identify women that have postpartum depression and the severity that they have. And on the scale, a score of 12 or greater, it raises concern and indicates a need for more thorough evaluation, right?

MR. REDDINGTON: Do you know whether she was thoroughly evaluated by anybody other than Tufts and Jollotta?

MR. REDDINGTON: Okay. I mean, you were trying to do the best you could with what you had to work with, right?

MR. REDDINGTON: Okay. Now we get to postpartum psychosis. That's the third category, right? Postpartum psychosis, you'd agree, is the most severe form of postpartum psychiatric illness, is that right?

MR. REDDINGTON: Would you agree that it occurs in averages about two out of a thousand women, right?

MR. REDDINGTON: And its presentation can be very dramatic with onset of symptoms, and that can be within a year according to the CDC, Center for Disease Control, right?

MR. REDDINGTON: Okay. And when it hits you, it just hits you, bang.

MR. REDDINGTON: Quick, right?

MR. REDDINGTON: And when you think about two out of a thousand people, seems like a daunting number, but if I tell you that Fenway Park, when they're full, when they're playing the Yankees, they have 37,700 people. If you take the 37,000 people and you multiply it by two, that would mean as you're sitting there behind first base, 74 women possibly have postpartum psychosis, right?

MR. REDDINGTON: Well, if you agree that it's two out of a thousand according to the studies and the statistics, and if Fenway Park has 37,000 seats, times two would be 74.

MR. REDDINGTON: That's a pretty large number of people, right? 74 people out of that crowd. Okay. It's not that un- horribly unusual. I mean, it's something that perhaps you've dealt with in your practice, right?

MR. REDDINGTON: And when you're dealing with people with postpartum psychosis, do you agree that generally they present with an episode of bipolar illness? If you know.

MR. REDDINGTON: No, they don't? Or no, you don't know?

MR. REDDINGTON: Okay.

MR. REDDINGTON: Bottom line is from your dealing with Lindsay, she appeared to be sincere, right?

MR. REDDINGTON: She appeared to be help—looking for help, right?

MR. REDDINGTON: She appeared to be hurting, right?

MR. REDDINGTON: Turning in every direction she could for help, right?

MR. REDDINGTON: And the last time you saw her was when?

MR. REDDINGTON: Okay. Thank you very much.

MR. REDDINGTON: What was she laughing about? When was it she was laughing with you?

MR. REDDINGTON: So on the 19th, it was on television, or was it in person?

MR. REDDINGTON: Virtual visit.

MR. REDDINGTON: And on the 19th, on the virtual visit, what was the purpose of that visit?

MR. REDDINGTON: Okay.

MR. REDDINGTON: So you would have, I guess, in your notes or a reference to the fact that on the 19th of December, that she was laughing?

MR. REDDINGTON: Able to laugh.

MR. REDDINGTON: Okay. 'Cause I'm looking here on December 19th, telemedicine, Latasha, Latisha, I apologize, Dukes. Perinatal Behavior Health Program, and you talk in that form about the date of the service, December 19th, psychotherapy, PCP, Margaret, that would be the primary care, Margaret Anastasi. Perinatal Behavioral Health Program. You talk with the quote, "If this is telehealth visit, please dot the phrase video visit," whatever. Therapeutic intervention. She's 32 years old, married female, presents for postpartum anxiety, symptom management. Patient continues to have low mood and numbness. Pa- numbness? Was she laughing when she had numbness?

MR. REDDINGTON: December 19th, the last day you saw her, or the last time you had any contact with her.

MR. REDDINGTON: She didn't appear to have what? Laughing or numbness?

MR. REDDINGTON: Well, it says right in the notes, does it not, that patient continues to have low mood and numbness?

MR. REDDINGTON: Okay. I don't want you to say yes unless I just show it to you, so. The patient continues to have low mood and numbness, right?

MR. REDDINGTON: Patient has not had suicidal ideation, does not need... Had, did not need crisis intervention over the weekend. In other words, she didn't kill herself, right?

MR. REDDINGTON: To help with the mood, patient has been spending time with her husband, children, and exercising, right?

MR. REDDINGTON: And exercise is one of the things that you would generally, your people would generally recommend that the mother do, right?

MR. REDDINGTON: That's a good thing to try to do, is to exercise, right?

MR. REDDINGTON: So if the fact that the government has records that show that she would take her kids, or her husband would take her kids, and they would go to a local gym and exercise or swim, that's consistent with what she was advised, right?

MR. REDDINGTON: It doesn't mean that she's just out there having a good time exercising, right?

MR. REDDINGTON: She was told that that's a good thing to do, right?

MR. REDDINGTON: Oh, okay. So when did she go to the gym?

MR. REDDINGTON: Did you ever ask her? Did you ever ask her if you're telling me that, you know, this is showing improvement, is it in the records? Does it indicate that you asked her if she was exercising, and if so, where and when?

MR. REDDINGTON: Okay. And all I did was ask you about patient was spending time with her husband, children, and exercising, and then you said that that's an indication that she's improving.

MR. REDDINGTON: Okay. And then I asked you if she's going to a gym. That's not a bad thing, is it?

MR. REDDINGTON: Okay. And then it says that she received a call, and counsel asked you about this. She received a call from Women and Infants, but missed the call. Do you remember that?

MR. REDDINGTON: Remember the DA asking you that question? You said that she missed a call.

MR. REDDINGTON: She didn't continue to read that the reason she missed the call is that she was at another medical appointment, right?

MR. REDDINGTON: And she called you back, right?

MR. REDDINGTON: Okay. A clinician, that'd be you, provided contact information for Women and Infants. Patient reported that she would contact them today, meaning December 19th, but in fact, she did, and you did with— She— Back it up. She did with your help, and she then went the following day on the 20th, right?

MR. REDDINGTON: Okay. And finally, fair to say that nowhere in here does it say that she was laughing?

MR. REDDINGTON: Okay. Let's do that. You got it?

MR. REDDINGTON: Let me see it, please.

MR. REDDINGTON: Okay. Now, what's a mental status exam?

MR. REDDINGTON: Okay.

MR. REDDINGTON: So with the help from the DA, we have December 19th, the telemedicine form, clinical notes, right?

MR. REDDINGTON: The laughing wouldn't be in that area, would it?

MR. REDDINGTON: Okay.