3.Alia Goodheart — Direct (Part 1)
600 linesMS. BUCKINGHAM: The Commonwealth would call Alia Goodheart.
THE COURT: All right. Good morning, doctor.
ALIA GOODHEART: Good morning.
THE COURT: Hi. I'm gonna ask you when you sit down, if you speak loudly so the jury can hear you, and speak into that microphone. Okay?
ALIA GOODHEART: Okay. Thank you.
THE COURT: All right. Thank you.
THE COURT: Counsel.
MS. BUCKINGHAM: Thank you. Good morning.
ALIA GOODHEART: Good morning.
MS. BUCKINGHAM: Could you please tell the jury your first and last name?
ALIA GOODHEART: My first name is Alia, last name is Goodheart.
MS. BUCKINGHAM: Can you spell your first name for the record?
ALIA GOODHEART: A-L-I-A.
MS. BUCKINGHAM: And your last name, please.
ALIA GOODHEART: G-O-O-D-H-E-A-R-T.
MS. BUCKINGHAM: And what do you do for work?
ALIA GOODHEART: I'm a psychiatrist.
MS. BUCKINGHAM: And can you tell us a little bit about your educational background to be a psychiatrist?
ALIA GOODHEART: I got my medical degree from the State University of New York in Brooklyn, the Health Sciences Center, and I came to Boston to do my four-year residency at the Harvard Longwood Psychiatry Residency Program. I also trained for an additional three years at the Boston Psychoanalytic Institute, and got my advanced training in advanced training pro— Well, I attended the advanced training program, and yeah.
MS. BUCKINGHAM: Are you licensed here in Massachusetts to practice as a psychiatrist?
ALIA GOODHEART: I am.
MS. BUCKINGHAM: Are you licensed in any other states?
MS. BUCKINGHAM: Okay. So you said that you're a medical doctor with a specialization in psychiatry, correct?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: Can you tell us a little bit about your work history in that field?
ALIA GOODHEART: Yes. I've worked in several different settings. When I first started out, I was working at Beth Israel in integrated care, which means essentially that you work with primary care physicians, and if they have patients that they have questions about, they can consult you. And if there's a need, you can continue to manage the patient's psychopharm medications. And if it's simple, they can continue to do it, but you're available to do... for them to consult with and to discuss cases. After that, I went to Emerson Hospital, where I worked on the inpatient psychiatric unit for a total of nine years. I left for one year to be the medical director at another freestanding hospital. After that, I worked at the women's prison in Framingham for a year and a half. And after that, an outpatient clinic at—affiliated with Tufts. I had a private practice for two years, and then I've been working at McLean for the last five years.
MS. BUCKINGHAM: Okay. And what is McLean Hospital?
ALIA GOODHEART: It's a freestanding psychiatric hospital that is part of the Mass General Brigham system.
MS. BUCKINGHAM: What kind of services does that facility offer to patients?
ALIA GOODHEART: They have, you know, lots of services, including inpatient, outpatient, substance abuse, trauma-focused. There are lots of specializations, eating disorder programs. They have residential programs. They have partial programs. So there's a really broad breadth of-
MS. BUCKINGHAM: And what is your role at McLean?
ALIA GOODHEART: I work on one of the inpatient psychiatric units.
MS. BUCKINGHAM: And tell us a little bit about what an inpatient psychiatric unit is.
ALIA GOODHEART: Patients who come to our unit are referred to us by the emergency department, because it's been determined that they need inpatient level of care. You can come voluntarily, or you can be sent involuntarily. And once you arrive, we work with the patient until, you know, they're... for a certain period of time, which isn't predetermined. It is flexible, so it depends on what's going on. And when you're on an inpatient unit, it's not just that you're seeing the psychiatrist, you're working as a team. So there are nurses, there are mental health workers, there are social workers. And the way it works at McLean is that every day you have a meeting where people discuss what's been going on, and you share any information that you have, and you know, that kind of guides treatment. It's—if I'm on the unit while I see the patient, I'm not there twenty-four, twenty-four/seven. But the mental health staff and the nursing staff are there, and they contribute to the assessment of the patient.
MS. BUCKINGHAM: So in that team approach, when you're... have mental health workers, nurses, social workers that work with you, there's fair to say some combination of that team present all the time?
ALIA GOODHEART: Yes. There are three shifts, and each shift has mental health workers and nurses.
MS. BUCKINGHAM: And in that team approach, sometimes particular members of those—that team may have direct contact with the patient, correct?
ALIA GOODHEART: Absolutely. Each shift, each patient is assigned a mental health worker and a nurse. They're offered a check-in, which is basically time to sit and talk about how they're doing and what's going on and if they're upset or distressed. And so, you know, there is documentation of that, and that happens on a regular basis.
MS. BUCKINGHAM: And even when members of the particular treatment team don't have direct contact with a patient, they're still there and observing what's going on, right?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And are they trained to do that?
ALIA GOODHEART: Absolutely.
MS. BUCKINGHAM: And so even if they don't have a conversation with somebody that's documented, they're still observing to be able to report back if there's any concerns that they observe during any given shift. Is that fair to say?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. Now, you mentioned that the inpatient unit at McLean, that most they come from the ER departments of the surrounding hospitals?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: So you can't just walk in.
ALIA GOODHEART: Not, not at McLean.
MS. BUCKINGHAM: For the inpatient for... in any—
ALIA GOODHEART: Right. Correct.
MS. BUCKINGHAM: Okay. And so oftentimes when a patient comes from the emergency department or is referred over there, how do they get there?
ALIA GOODHEART: They have to be sent on a Section 12, most of the time. Well, then it doesn't make sense. So they're usually sent on a Section 12, especially if they're gonna be sent in an ambulance. And then when they arrive at McLean, they are seen at the CEC, which is the Clinical Evaluation Center.
MS. BUCKINGHAM: If I could just stop you for one second.
ALIA GOODHEART: Yeah.
MS. BUCKINGHAM: Can you tell us what a Section 12 is?
ALIA GOODHEART: A Section 12 is basically a doctor or social worker or psychologist states that you are being referred to a hospital for admission because you have a mental health condition.
MS. BUCKINGHAM: And the Section 12 could be something that the patient voluntarily elects to do, right?
ALIA GOODHEART: That's a Section 10. The Section 12 is—it means that you have to go there. If you go there and they evaluate that you're fine and you decide you don't want to be at the hospital, you can choose to leave, and they'll have to let you go.
MS. BUCKINGHAM: So when you say that a person comes transported from an ER on a Section 12, they also can come transported on a 10 as well, a voluntary?
ALIA GOODHEART: A Section 12 is required for transportation because in the time between when they leave the hospital and they're supposed to get to you, you wanna make sure that something could happen, and then they could leave. So you wanna make sure that the physician sees them at that end, and then somebody sees them at the other end to ensure that something hasn't changed. So it's evaluation.
MS. BUCKINGHAM: Okay. And at the emergency department, there is a particular type of evaluation that's done before somebody is sent over to McLean, correct?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: From the Mass General, what is that usually referred to?
ALIA GOODHEART: It's called the acute psychiatric consultation. AP- yes, no. So the service is acute psychiatric services, and it's an evaluation. So it's a complete evaluation by either a nurse practitioner or a psychiatrist, and they go over things like, "Why are you coming now? What is your history? Have you ever had problems before? What's your family history?" They document how you're presenting. They inquire about symptoms, and that's how they find out what medications you're on. And then they, based on that, they decide whether you need, you know... There could be several options. They can recommend inpatient treatment. They can recommend partial hospital program. But the patient doesn't have to do either. If they're not, you know, unsafe, they can choose to leave. But most of the time people take the recommendation, and they've presented because they are seeking help.
MS. BUCKINGHAM: And unless the patient is deemed unsafe in that involuntary realm, it's their choice.
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: Now, you mentioned that when they come to McLean, that they first come through and have a CEC. What is that?
ALIA GOODHEART: It's a Clinical Evaluation Center.
MS. BUCKINGHAM: What happens at that stage at McLean?
ALIA GOODHEART: They're seen by— a psychiatrist, and there's a nurse as well. They review the history that was obtained at the emergency department, and they inquire about any... They actually do another evaluation, just like at the APS, basically reviewing all the history but also asking their own questions, and if they have any concerns, they document them there.
MS. BUCKINGHAM: And you said this evaluation is done by a psychiatrist?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And when a person comes into McLean, can they come at any hour of the day or night?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And when they first make it to the clinic of, clinical evaluation center, it's always... They're always seen by a psychiatrist?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Now once they do this evaluation, gather all the information, do they also do kind of a physical exam to make sure that there's no medical issues to address?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And after all the information is gathered, what is done at the evaluation center?
ALIA GOODHEART: So they basically enter the order. May I have some water, please?
ALIA GOODHEART: No worries.
ALIA GOODHEART: Can you repeat the question?
MS. BUCKINGHAM: Sure. When a patient is evaluated or seen in the clinical evaluation center, what happens after the evaluation's done?
ALIA GOODHEART: So, they determine the level of checks that the patient should be on once they get to the unit, 'cause there are several units there, at least four inpatient units. They decide what medications the patient is gonna be able to get, thank you, until they are seen by a psychiatrist on the unit.
MS. BUCKINGHAM: And when you say level of check, what does that mean?
ALIA GOODHEART: Everybody who is on the unit, there's a mental health worker assigned the task of ensuring that all the patients who are supposed to be on the unit are present, and that they're safe. And the lowest level is 15-minute checks. If there's concern about somebody, it goes up to five-minute checks. And if they're extremely unsafe, it goes to a one-to-one.
MS. BUCKINGHAM: And what does one-to-one mean?
ALIA GOODHEART: There would be a staff person with the patient at all times.
MS. BUCKINGHAM: And again, this determination of which unit to be on and what level of security or what level of check is done by the psychiatrist that performs that first evaluation, correct?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: Now, when a person who comes through the CEC then gets sent to the unit, do they walk to the unit on their own or how do they get to the unit?
ALIA GOODHEART: They're escorted to the unit.
MS. BUCKINGHAM: And you said there's four inpatient psych units. Is that—
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: Now when the person arrives at the unit, what happens?
ALIA GOODHEART: They're seen by a nurse and a mental health worker. Their belongings are... They go through the belongings to ensure that there's nothing unsafe. There's certain things that are not allowed on a psych unit. The nurse reviews their history and takes some vital signs, sees if they need any medication, and then they show them to their room and the unit.
MS. BUCKINGHAM: And again, people come through the CEC at all hours of the day and night, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: So this whole process is pretty seamless and could happen at any point.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Now you mentioned previously that the length of stay or how long a person is on the unit or inpatient varies, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Is there any sort of minimum that's required when a person comes in for an inpatient stay at McLean?
MS. BUCKINGHAM: And if they are voluntarily there, can they leave at any time?
ALIA GOODHEART: As long as the psychiatrist and the team assesses them and determines that they don't pose an imminent risk to themselves or anybody else.
MS. BUCKINGHAM: Now what if they're there on a Section 12? Is there a time limit or a minimum amount of time they have to be there?
MR. REDDINGTON: Well, no, she wasn't there on Section 12. She was on a voluntary...
MS. BUCKINGHAM: We haven't gotten there yet. I'm just asking background questions about the facility.
THE COURT: I'll allow some background questions but let's kinda move it along.
ALIA GOODHEART: So Section 12 entails that, that the team and the psychiatrist has three days to evaluate the patient to determine whether they pose a danger to themselves or others. And if at the end of that time they do determine that the person poses a risk, then they have to apply for commitment, which would mean going in front of a judge who would decide if the patient should remain hospitalized or be discharged.
MS. BUCKINGHAM: And if at the end of the three days you deem them to be safe, are they allowed to leave?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And is there something in the field of psychiatry or in your training and experience in your time at McLean about being discharged against medical advice?
MR. REDDINGTON: She wasn't discharged AMA.
THE COURT: I will allow the... Set the, really the terms and where we are, so you can go into that.
MR. REDDINGTON: AMA is not applicable in this case.
MS. BUCKINGHAM: If we can approach—
THE COURT: Yeah, you know, I don't think you heard me.
MR. REDDINGTON: I did hear you.
THE COURT: All right. Well, then I'm gonna allow that question. There, your rights are saved.
MR. REDDINGTON: My objection.
THE COURT: Yeah, it... I've noted it. Go ahead, counsel.
MS. BUCKINGHAM: Thank you.
ALIA GOODHEART: I think we tend not to do against medical advice because if we are concerned about somebody's safety, we would not discharge them.
MS. BUCKINGHAM: So you have another procedure available to you if you were concerned for somebody's safety?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that's the procedure you described about seeking an order for further commitment?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: Okay. Thank you. Now when a person comes and goes through that process and is placed on their unit and settled in, what is the plan after that? How often do they see providers?
ALIA GOODHEART: They're assessed by a psychiatrist every single day that they're there. They have nurses who are checking in with them, mental health workers. They're offered group programming and medical monitoring, vital signs. Yeah.
MS. BUCKINGHAM: What types of group programming are offered to people while they're inpatient at McLean?
ALIA GOODHEART: We offer skills groups, which are things like... They're meant to teach patients skills so that they can tolerate the stress, they can kind of observe their thoughts. It's meant to shore up their skills. Then there are some groups which are more just relaxed, I guess, such as going for fresh air walks or going to the recreation center, just, you know, drawing or coloring and, yeah.
MS. BUCKINGHAM: And are there other things offered to patients once they're on a unit to assist them in their care, like counseling?
ALIA GOODHEART: Yeah. Those are the check-ins and they, when they meet with the psychiatrist or, and the social worker, they're, the counseling happens in those sessions as well, and also by the nurses and the mental health staff.
MS. BUCKINGHAM: Okay. Now does this procedure or does how this, how it operates for any given patient, does it change if there's a holiday or a weekend?
ALIA GOODHEART: I think they're still seen, they're still seen by a psychiatrist.
MR. REDDINGTON: She's thinking if she knows. I have no objection. I'm gonna object to the way she's answering that.
THE COURT: All right. She's... Why don't you rephrase the question?
MS. BUCKINGHAM: I will, thank you. As far as your experience at McLean Hospital, is there, does the schedule change when there's a weekend or a holiday?
ALIA GOODHEART: The group schedule might change, but the staffing schedule doesn't change.
MS. BUCKINGHAM: So the availability and the mental health worker that sees the patient, the social worker that checks in, and the psychiatrist and nurse, the team all stays the same even on a weekend or a holiday?
ALIA GOODHEART: Other than the social worker.
MS. BUCKINGHAM: Okay. And when I say stay the same, it could be different individuals—
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: ... but it's somebody from that group, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. So...
MS. BUCKINGHAM: As far as your role as a psychiatrist, how do you get assigned patients when they are admitted to McLean inpatient?
ALIA GOODHEART: It's random. There are beds that are open, and I carry a certain number of patients and other psychiatrists have a certain number of patients, and whoever has an opening gets the admission.
MS. BUCKINGHAM: Do you have to be there when the patient is admitted to have the patient assigned to you?
MS. BUCKINGHAM: And so do you rely on other psychiatrists to perform those tasks before you meet a patient?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: I'm gonna draw your attention to a particular patient by the name of Lindsay Clancy that arrived at McLean in the early morning hours of January 1st of 2023. Do you recall that patient?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Have you had the ability to review the records related to that patient prior to coming in today?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And do you know where she came from?
ALIA GOODHEART: The emergency department at MGH.
MS. BUCKINGHAM: Okay. And did she come voluntarily or did she come on some sort of section?
ALIA GOODHEART: Again, for transportation it's always a section, but then she signed in voluntarily, which is the section 10.
MS. BUCKINGHAM: Okay. So to your knowledge, she was brought in the early morning hours via ambulance?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And did she go through that process of the clinical evaluation center in the early morning hours, approximately 4:00 AM on the 1st?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And who saw her there?
ALIA GOODHEART: I think the psychiatrist's name was Dr. Outlaw.
MS. BUCKINGHAM: Okay. And you're familiar with Dr. Jasmine Outlaw?
ALIA GOODHEART: I've never met her.
MS. BUCKINGHAM: Okay. But she is a psychiatrist on staff?
ALIA GOODHEART: Correct.
ALIA GOODHEART: I don't know what on staff, what you mean by on staff.
MS. BUCKINGHAM: Well, she works at McLean.
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And so, you were able to review the information she gathered in that first evaluation?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And in reviewing that information, did you identify that the patient was identified as medically stable, right? Meaning she didn't have any acute medical issues that you had to worry about.
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And she was screened on the suicide screening?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: What was the chief complaint of the patient when she arrived at McLean?
ALIA GOODHEART: She was unhap... She was finding it hard to sleep if she didn't take medications.
MS. BUCKINGHAM: Okay. And do you recall reviewing in the records that it was noted that she reported that she felt numb?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that she was having some issues managing medication?
ALIA GOODHEART: I don't know what you mean by that.
MS. BUCKINGHAM: Well, that she had some complaints about side effects or symptoms of medication.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Now, when the psychiatrist in the clinical evaluation center gathered the information, fair to say that it's primarily based on what's reported to the doctor by the patient?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: At McLean, do you have access to a patient's full psychiatric history or all of their records from other places?
ALIA GOODHEART: It depends where the patient is coming from. I think that Dr. Outlaw did take an excerpt of the APS evaluation that was done at MGH, so I assume that she had access to that.
THE COURT: I'm sorry. Assumptions, like...
ALIA GOODHEART: I mean, she would have had—
MS. BUCKINGHAM: I can ask it a different way.
THE COURT: She doesn't know, she doesn't know.
ALIA GOODHEART: Yeah.
THE COURT: Right.
MS. BUCKINGHAM: As far as the full record of this particular patient that you were assigned to and responsible for, you reviewed all of the notes and information gathered by Dr. Outlaw on that first interaction with the patient, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And you indicated a little while ago in your testimony that McLean is affiliated with the Brigham—
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: ... Hospital and Mass General. So is it fair to say that those records from Mass General are available to you at McLean?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And again, you indicated that that APS evaluation is something that's done at the emergency room, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And is it common that that information come along with the patient?
MR. REDDINGTON: Objection.
ALIA GOODHEART: ... don't know.
THE COURT: No. Good. Just if you could answer that. You don't know?
ALIA GOODHEART: I don't know.
THE COURT: Okay. All right. Next question.
MS. BUCKINGHAM: In this instance, when you reviewed the records, were you aware or did you see that there was some note to the APS evaluation from the Mass General ER?
ALIA GOODHEART: I saw the excerpt of the APS evaluation in Dr. Outlaw's note.
MS. BUCKINGHAM: Okay. And that excerpt from the APS evaluation was conducted by somebody by the name of Dr. Hogan, correct?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And did you review a portion of the record indicating that the patient said to Dr. Hogan or reported thoughts of wishing to be dead, but no plan?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that there was no violent or homicidal ideation, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that that was observed at Mass General to have no evidence of psychosis, mania, obsessions, or current anxiety symptoms?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: So that's information that you knew before you've met with the patient?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And as far as what's reported when the patient comes to McLean, and in this instance when Lindsay Clancy came, are you aware she reported, during that clinical evaluation center evaluation, that at the beginning of December she had started Seroquel and Remeron and started to have intrusive and suicidal thoughts?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: That she attributed that to medication?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. And so what was the plan, the first plan that came out of that clinical evaluation center evaluation of Ms. Clancy?
ALIA GOODHEART: She was continued on the medication she was admitted on. You know, the plan, they do the checks, they decide what medical monitoring you need, but she basically was admitted—
MS. BUCKINGHAM: Okay.
ALIA GOODHEART: ... and the medications were the same.
MS. BUCKINGHAM: And what was the security level or how long were the checks assigned to her after this evaluation?
ALIA GOODHEART: Fifteen minutes.
MS. BUCKINGHAM: And was she considered to be a high risk upon coming into the inpatient unit, or was she minimal risk?
ALIA GOODHEART: Low. Minimal, yeah.
MS. BUCKINGHAM: And were you aware of what's called the provisional diagnosis that was assigned to this patient when she arrived?
ALIA GOODHEART: I don't recall what the provisional diagnosis was, but I do know that they do assign a diagnosis. I don't recall it. I must have seen it in their records, but I think there are like five different diagnoses.
MS. BUCKINGHAM: Just referring to what's already been marked as Exhibit seventy-nine. I'm gonna draw your attention to page twenty-four.
ALIA GOODHEART: Thank you. Right. Okay. I think I remember. Yes.
MS. BUCKINGHAM: Okay. Does that refresh your memory as to the provisional diagnosis?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what was it?
ALIA GOODHEART: Major depressive disorder, severe, without, without psychotic features.
MS. BUCKINGHAM: Now, what does the provisional diagnosis mean to you— ... when you're assigned a patient?
ALIA GOODHEART: That this is the assessment of the psychiatrist who saw her at that time.
MS. BUCKINGHAM: Do you have to stick with that diagnosis, or are you free to change that based on your experiences with the patient?
ALIA GOODHEART: The diagnosis I give the patient is dependent on what my interactions are and the observations of the team.
MS. BUCKINGHAM: Okay. Now, for this particular patient, Ms. Clancy, on January 1st, when she got situated onto the unit after that first evaluation by Dr. Outlaw, are you aware that she was then seen later in that day on January 1st?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And were you the doctor who saw her, or was there somebody else?
ALIA GOODHEART: It was a different psychiatrist.
MS. BUCKINGHAM: Okay. And who was the psychiatrist that saw her on January 1st?
ALIA GOODHEART: It was Dr. Madva.
MS. BUCKINGHAM: And that would be Dr. Elizabeth Madva?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: Again, is she a psychiatrist as well?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And so this occurred while you were not in the hospital, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And were you able to review the notes, the admission notes of Dr. Madva regarding her interactions with this patient on January 1st at approximately twelve forty-seven PM?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And again, as far as these interactions go with the patient and the psychiatrist, it's more of a conversation, right?
ALIA GOODHEART: I'm sorry. Could you repeat the question?
MS. BUCKINGHAM: Yeah. It's a conversation when you meet with a patient.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: You ask them how they're feeling. Oh, get information that you think is necessary. Is that fair to say?
ALIA GOODHEART: It's a conversation and also you get the information.
MS. BUCKINGHAM: Okay. And so do you rely on things that were reported before?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. But you also ask follow-up questions, right?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And as far as your review of Dr. Madva's interaction with Ms. Clancy on January 1st, is it clear to you that she did that?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: She reviewed her history with her and spoke with her about how she was feeling?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: At the time she spoke with Dr. Madva, you're aware she said that she denied feeling depressed and denied any passive death wishes or suicidal thoughts, but reports feeling numb?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: She reports she can't feel any emotion other than mild anxiety at now being in a hospital setting.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. After Ms. Clancy was seen by Dr. Madva, were you aware of what the plan was regarding her medication?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what was the plan?
ALIA GOODHEART: Ms. Clancy complained, one of the... There were several symptoms. One of the things that she did complain about was the numbness, and Dr. Madva did, you know, hear that and hear her concern, and that she had been sensitive to many different medications, so she—
MS. BUCKINGHAM: Well, let me ask a... If I can ask a question.
THE COURT: Finish the answer. Will you finish with your answer?
ALIA GOODHEART: So she determined that it was possible that the numbness the patient was complaining of was a side effect of the medication she was on. And the plan was to taper that medication and observe the patient to see whether the numbness went away, and also if any other symptoms became evident.
MS. BUCKINGHAM: So the medications, you were aware of the medications that Ms. Clancy came into McLean on, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what medications were those?
ALIA GOODHEART: Seroquel at 100 milligrams a day. Valium, two milligrams. I don't remember the frequency. I think it was per day.
MR. REDDINGTON: Objection.
ALIA GOODHEART: And-
THE COURT: Again, we're gonna let her finish.
MR. REDDINGTON: Yeah, I'm just saying I have no problem if she looks at the record.
ALIA GOODHEART: So Seroquel, Valium, and Benadryl.
MS. BUCKINGHAM: Do you remember or do you recall Remeron being one of the drugs that were described or reported by Ms. Clancy?
MS. BUCKINGHAM: When she came in, that she reported taking Remeron?
ALIA GOODHEART: In the past, yes.
MS. BUCKINGHAM: Okay. And again, in that report from the patient about past history, do you recall her indicating that one of the providers had suspected a bipolar disorder?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: In your interactions with Ms. Clancy and your review of the interactions she had with other psychiatrists, did she appear to agree with that diagnosis? If you know.
ALIA GOODHEART: Did who appear to agree?
MS. BUCKINGHAM: Ms. Clancy.
THE COURT: Rephrase that question, please.
ALIA GOODHEART: Ms. Clancy?
MS. BUCKINGHAM: Yes.
ALIA GOODHEART: Did she... She disagreed with the diagnosis.
MS. BUCKINGHAM: Okay. The fact that she came in and she was on 100 milligrams of Seroquel or more, would that have been something that was significant to you in considering a bipolar diagnosis?
ALIA GOODHEART: Seroquel is used for several purposes. It is not just used for bipolar illness.
MS. BUCKINGHAM: Okay. And Ms. Clancy also reported, coming to McLean, issues with insomnia, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Is Seroquel sometime used in low doses to address insomnia?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Now, as far as the plan from January 1st, you indicated that Dr. Madva recommended reducing the Seroquel and then monitoring symptoms, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. Were you aware that Ms. Clancy saw Dr. Madva again on January 2nd?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And again, that was prior to your first point of contact with her.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: As far as what you know from reviewing the record, you're aware that Ms. Clancy reported that she slept well on lesser dose of Seroquel.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Did she report any delusions, hallucinations or suicidal or homicidal ideation?
MS. BUCKINGHAM: Okay. And as far as after the check-in with Dr. Madva on the 2nd, was the plan to continue to decrease the Seroquel?
ALIA GOODHEART: Dr. Madva was gonna continue her on 75 milligrams, and then the next day she would have gone down to 50 milligrams.
MS. BUCKINGHAM: And on these first few days that Lindsay Clancy was at McLean Hospital from January 1st until you actually saw her on January 3rd, you're aware that in addition to seeing Dr. Outlaw at the intake and Dr. Madva on two occasions, on the 1st and the 2nd, that there were also notes in the record for you to review from nurses who interacted with her on January 1st at 5:20 AM, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: From nurse, January 1st at 6:28 AM.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: A nurse interacting with her on January 1st at 10:34 AM.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that she actually participated in a group activity with a social worker at 12:03 PM on the 1st.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that a nurse interacted with her and note—made notes on two, at 2:07 PM on the 1st.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that she saw a mental health worker at 9:33 PM on the 1st?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And in relation to January 2nd, she, a nurse made note of interaction with her on 9:46 on the 2nd, right?
ALIA GOODHEART: I remember there were interactions. I don't remember the exact time.
MS. BUCKINGHAM: Okay. But fair to say on the 2nd she interacted with nurses and most, and Dr. Madva-
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: ... based on your review. Now, going to January 3rd, that was the first face-to-face contact you had with the patient, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Prior to meeting with her, had you reviewed all of these notes and all of the information up to that date?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And did you go through again, a report of history with her?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Were you able to make an assessment of her mental status during that interaction with her?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what were your observations of her mental status?
ALIA GOODHEART: I can't ... I mean, I can remember certain elements, but I don't remember ... I mean she was dressed in, you know, she was appropriately dressed. Her speech was of normal rate and volume. Behaviorally she was polite and cooperative. Her mood, I don't remember exactly. It's a quote, so I don't remember exactly what she's quoted her mood as being. Can you ... You can ... it would be in the medical record.
MS. BUCKINGHAM: Yeah. One moment.
MS. BUCKINGHAM: I'm just gonna approach if that's okay.
THE COURT: You may, yeah. And just so the records are Exhibit 79?
MS. BUCKINGHAM: Yes.
THE COURT: All right, so those records, you'll have those with you. Okay.
MS. BUCKINGHAM: So I have pulled six- pages 61 through 66. So if that's your note, if you can just take a look at that and let me know when—
MS. BUCKINGHAM: Does that refresh your memory as to what your observations are, were of her mood?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: What was her mood?
ALIA GOODHEART: Anxious.
MS. BUCKINGHAM: Okay. And did you observe signs of anxiety, or did she tell you that she felt anxious?
ALIA GOODHEART: She appeared anxious.
MS. BUCKINGHAM: And her affect, did you observe it to be congruent to her mood?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And you examined her and found her to have linear thinking and appear goal-directed, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. And as far as addressing kind of why she was there and what your recommendations were, ultimately what were you trying to address or accomplish in the treatment plan with Ms. Clancy?
ALIA GOODHEART: That's a very broad question.
MS. BUCKINGHAM: Okay. I can break it down if that's okay.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: So as far as once you had a chance to sit and talk with her, what did she identify to you to be her main concerns that she wanted to address during her stay at McLean?
ALIA GOODHEART: She did not want to be dependent on an anti-psychotic medication, which is what Seroquel class is, even though it's used for insomnia and other indications, depression. She didn't want to be dependent on Seroquel to be able to fall asleep.
MS. BUCKINGHAM: Okay. And so, fair to say she was very concerned about wanting to sleep at night?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And she was very concerned about her symptomology or what she was experiencing by way of symptoms from various medications, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that concept or the phrase numbness, did she use that a few times?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And again, you mentioned Dr. Madva was concerned about the numbness with the medication. In your experience with Seroquel, is that also a common side effect for people to feel numb?
ALIA GOODHEART: It can be one of the side effects that people can have.
MS. BUCKINGHAM: Okay. And as far as the suicidal statements that you were aware of from the prior reports, did you go through that with her about whether she presented to you with suicidal ideation?
ALIA GOODHEART: Can you ask me that again?
MS. BUCKINGHAM: Sure. Did you talk to her about her thoughts of suicide?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And did you talk to her about whether she had any specific plan?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Did she have any plan?
MS. BUCKINGHAM: Had she reported that she had ever had a plan for suicide?
MS. BUCKINGHAM: And did she tell you there were reasons why she thought she wouldn't commit suicide?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what were those reasons?
ALIA GOODHEART: Her children and her family, her mother.
MS. BUCKINGHAM: So after this face-to-face interaction with her and kind of going through her history and having reviewed what you had, the information you had about her, what did you develop as a plan for her while she was at McLean?
ALIA GOODHEART: I continued with the plan to taper her off Seroquel and to monitor whether her symptoms improved, but also to see if she could sleep while she was off of Seroquel.
ALIA GOODHEART: And to really observe symptoms and mood.
MS. BUCKINGHAM: During this first interaction with her, was there any conversation about how long she would stay or what her plan might be after she left McLean?
ALIA GOODHEART: When we met the first time, Lindsay said that her... she had her daughter's birthday coming up on the weekend, and that it had been planned months ahead of that date. And she was hoping that she could be there that weekend so she could be with the kids and family who was gonna come for the birthday party.
MS. BUCKINGHAM: Now, the concept of kind of tapering her off the Seroquel and monitoring her symptoms, did that seem like a realistic goal to you?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And now after having spoken to her and developing this plan, were you also cognizant or thinking about the potential for a bipolar disorder—
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: … diagnosis? And so how did that affect how you approached this plan to taper?
ALIA GOODHEART: Again, we were observing for any symptoms that would indicate that she might have bipolar disorder.
MS. BUCKINGHAM: And where she had reported that she had issues with sleep, was that also something of concern to you if there was the potential for a bipolar disorder?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And reduction of medication. What was the concern for the sleep?
ALIA GOODHEART: I think people's mental health is negatively affected if they cannot sleep, whether it's bipolar disorder or depression. And so sleep is important.
MS. BUCKINGHAM: Okay. And so a person you might be considering for a bipolar diagnosis, would lack of sleep make you watch for symptoms of hypomania?
ALIA GOODHEART: Yes. Sleep is one of… Sleep deprivation can lead to bipolar, a bipolar episode, a hypomanic, manic episode.
MS. BUCKINGHAM: So you wanted to monitor her patterns and her sleep and her mood to see if there was any evidence of that, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: In this first interaction where you identified a plan, did you also make a suggestion about a particular medication that she might consider after the Seroquel had been discontinued?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: What was the alternative medication, if you will?
ALIA GOODHEART: It was Cymbalta, which is an antidepressant.
MS. BUCKINGHAM: And that… Was that something that you intended to prescribe for her while she was there, or was it something that you suggested that she could consider as an outpatient?
ALIA GOODHEART: It was just a consideration. It would depend on how she was doing after she was off of the Seroquel.
MS. BUCKINGHAM: Okay. Now what about the other, the Valium? Was there a plan to address tapering or weaning her off Valium or an alternative to Valium?
ALIA GOODHEART: Yes. I switched her from Valium to Ativan—
MS. BUCKINGHAM: Okay.
ALIA GOODHEART: … because it has a shorter half-life. And, you know, in my experience, it manages anxiety well.
MS. BUCKINGHAM: And were you aware that she had taken Ativan before?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And did she report any concerns about Ativan or benzodiazepines in general?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what was the concern she reported to you?
ALIA GOODHEART: She stated that her husband had concerns about her being on a benzodiazepine.
MS. BUCKINGHAM: During this interaction with her on the January 3rd, did you observe any signs of psychosis?
MS. BUCKINGHAM: And in notes and the interactions with the providers prior to your meeting between January 1st and January 3rd, did anyone ever note any symptoms or concerns for psychosis?
MS. BUCKINGHAM: And you're aware that Ms. Clancy was also still in that, what was considered the postpartum period, right? She had had a child in May of 2022?
ALIA GOODHEART: That's a tricky question to answer 'cause different organizations or agencies assign postpartum a different length of time.
MS. BUCKINGHAM: Okay. And so in your training and experience, in your experience as a person who diagnoses—
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: ... did you consider postpartum as part of what you had to figure out here with this patient?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Or was it really not a consideration?
ALIA GOODHEART: It was.
MS. BUCKINGHAM: Okay. And why was it for you?
ALIA GOODHEART: I mean, she had a child, and the risk of postpartum depression, postpartum psychosis is a serious consideration.
MS. BUCKINGHAM: Okay. Now, after this first meeting with Ms. Clancy on the 3rd, were you able to give her your, in your own opinion, a diagnosis?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what was that?
ALIA GOODHEART: You said after the 3rd?
MS. BUCKINGHAM: Right.
ALIA GOODHEART: Okay. So that would mean one meeting.
MS. BUCKINGHAM: Yes.
ALIA GOODHEART: I gave her a diagnosis of insomnia, second- with a mental health condition because one day of observation wasn't sufficient for me to figure out if she truly, you know, to give a solid diagnosis because it sticks with the patient.
MS. BUCKINGHAM: Right. Fair to say you just didn't have enough information at that point?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: Okay.
MS. BUCKINGHAM: So again, you saw her on January 3rd, and that was approximately 9:00 and 9:15 AM, right? You recall?
ALIA GOODHEART: If that's what it says. Yeah.
MS. BUCKINGHAM: Well, if I ... At the top of your inpatient progress note on page 61 of the exhibit, if I say the date of service reads 1/3/23 at 9:15, would that be where you would note the time you were scheduled to speak with the patient?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. And you're aware that on that same day, on January 3rd, that in addition to meeting with you, that she met with a social worker at 10:07 AM, right?
ALIA GOODHEART: Yes. The social worker and I would have met with her together.
MS. BUCKINGHAM: Okay. But then the social worker would have their own note if there was any interaction that they were noting, and also a nurse as well.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Right? And that on the 3rd, that Ms. Clancy participated in a group at 12:02 PM, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And engaged with a mental health worker at 12:22 PM, right?
ALIA GOODHEART: I do know that she engaged with the mental health worker. The times are—
MS. BUCKINGHAM: Okay.
ALIA GOODHEART: ... not something I recall.
MS. BUCKINGHAM: If I indicate that the records show she—
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: ... did another group at 2:36 PM, would that sound right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: That she then declined a group at 3:50 PM.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And then saw another mental health worker in the evening before presumably she went to bed, nine, 8:52 PM.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. Did you see her on January 4th?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And so again, is this the same protocol? You meet, you talk, you discuss. Did you talk to her about how the previous night's sleep went?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And how was that night's sleep?
ALIA GOODHEART: She reported sleeping well.
MS. BUCKINGHAM: Well?
ALIA GOODHEART: I don't remember the exact words, but she said she slept.
MS. BUCKINGHAM: Okay.
ALIA GOODHEART: Yeah.
MS. BUCKINGHAM: And do you remember having a conversation with her again on that day, January 4th, about going home?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what did she say about that?
ALIA GOODHEART: Originally I think we were thinking we had talked about discharge on Friday. And she was—she stated that she was anxious being in the hospital, and that she wanted to be discharged so she could be home with her family and her children.
MS. BUCKINGHAM: And so did she ask to leave earlier than Friday?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And when she asked to leave earlier than Friday, what was your response to that?
ALIA GOODHEART: Whenever we... I said she could leave, provided she had psychiatric follow-up the next day.
MS. BUCKINGHAM: And why did you do that?
ALIA GOODHEART: I wanted to ensure that, if she wasn't able to sleep that night after discharge, that she could speak with somebody about it so that they could come up with a plan to ensure she could sleep and to monitor how she was doing off the medication.
MS. BUCKINGHAM: And was there a kind of a secondary reason that you had asked that she make sure she make an appointment before discharge?
ALIA GOODHEART: Yes, it was also to assess whether she could think clearly and follow directions and get it together to... We asked her to set up the appointment herself, and she was able to do that. She responded within an hour. She told the nur- the social worker that she had gotten an appointment, and she even—the social worker had asked her for a fax number so that we could discharge the sum- we could send the discharge summary, and she provided the fax number as well.
MS. BUCKINGHAM: And now on this day that you had met her on January 4, or yeah, January 4th, she reported that she slept well. Do you recall what dose of Seroquel she was down to at that point? Had she reached zero?
ALIA GOODHEART: On which day?
MS. BUCKINGHAM: On the 4th, when you saw her.
ALIA GOODHEART: I'd have to walk myself through this. So I know she was on 75 milligrams the night of the 1st, 75 milligrams the night of the 2nd. On the night of the 3rd, we decreased it to 50 milligrams. On the night of the 4th, she would've been on 25 milligrams.
MS. BUCKINGHAM: Okay. And fair to say that on the 4th, your plan was to continue to taper her so that she wouldn't, she would be at zero for Seroquel, take no Seroquel on Thursday night, right?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And that she would be restarted
MS. BUCKINGHAM: on Ativan, and that she'd have the Trazodone available if she needed it?
ALIA GOODHEART: She was already on Ativan during her admission and was taking it at night. She also had Trazodone, which is a— which can... Which is a sleep medication. It has sedating properties, so it can be used for sleep. So yes, she had that. She had the option to take that as well.
MS. BUCKINGHAM: Okay. And so did you have a concern about her leaving on
MS. BUCKINGHAM: Thursday the 5th, without having monitored her at no Seroquel?
ALIA GOODHEART: I did not have any concerns about her safety or her, a risk for anybody else.
MS. BUCKINGHAM: Okay. But as far as from a diagnostic perspective, would you have preferred to have more information about her sleep patterns and her mood?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Okay. Now you said that you didn't have a concern for her safety. So what, in your time that you were with her, that you met with her, and all the information that we reviewed, what were identified as maybe protective factors that made you feel comfortable that she was safe?
ALIA GOODHEART: She was— there are several things. She was future-oriented. She was genuinely invested in her children. She was a caring mother, just like a caring mother. She had her parents around to help her. She had family and supports. We ensured that she would have outpatient psychiatric care for follow-up. She didn't have a history of suicide. She had no history of psychosis, postpartum psychosis. You know, she had a stable place to live. So-
MS. BUCKINGHAM: The statement that she made to you, that she wouldn't have completed the act of suicide because of her kids or her mom, was that something that you considered?
ALIA GOODHEART: Absolutely.
MS. BUCKINGHAM: And the fact that during the time she, from admission on January 1st to the time she was discharged on January 5th, that she didn't make statements supporting suicidal ideation, was that a factor that you considered?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And at no time during the time she was at McLean did she ever indicate that she had ever reported or had thoughts of harming anyone else, did she?
ALIA GOODHEART: She had never stated that she had any thoughts of harming anybody else.
MS. BUCKINGHAM: And ultimately, at the end of that conversation with her or the hour later, she was able to secure that appointment that you asked her to on her own?
ALIA GOODHEART: Correct.
MS. BUCKINGHAM: And so what, knowing that now the discharge is moved up a day, what was your plan for medication for her upon discharge?
ALIA GOODHEART: She would have continued on the Ativan to help her sleep at night. That was a short-term plan. Once she was feeling better or was able to sleep or her mood came back to baseline, she could taper off of it. She had Trazodone to use as needed, and melatonin.
MS. BUCKINGHAM: And as far as your recommendations for medication, it would be no more Seroquel?
MS. BUCKINGHAM: I guess, let me ask that question a different way.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: You didn't give her a new prescription for a different dosage of Seroquel, did you?
MS. BUCKINGHAM: And did you advise her to take Seroquel when she was home if she felt that she needed it?
ALIA GOODHEART: I would assume she would take what I had prescribed.
MS. BUCKINGHAM: Just to back up one second. As part of this treatment team plan for patients at McLean Hospital, is it fair to say that either you or other members of the team, either a mental health worker or social worker or nurse, sometimes reach out to collaterals in order to try to gather information and assess a patient?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And in this instance, are you aware that somebody reached out to Patrick Clancy to speak with him about his wife and her care?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And were you aware that he reported that she hadn't ever had suicidal thoughts?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that he actually reported to the social worker that she was concerned about dependency?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: But she had told you that her husband was concerned, is that correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And that he felt that she had succumbed to social pressure to take psychiatric medications because her friends were taking them?
ALIA GOODHEART: That's what he told the social worker.
MS. BUCKINGHAM: And you're aware that he had made statements that he was unhappy with the medical care she was receiving at McLean?
ALIA GOODHEART: He said, I don't think—
MS. BUCKINGHAM: Were you aware that he said he was very unhappy with the medical care she received?
ALIA GOODHEART: She received, yes. It, she didn't specify, he didn't specify McLean.
MS. BUCKINGHAM: Okay. Thank you. And as far as you're aware, the patient themselves, Ms. Clancy, she never complained that she wasn't getting seen by staff or doctors, was she?
ALIA GOODHEART: She never complained of that.
MS. BUCKINGHAM: Did she ever file any sort of complaint with the hospital?
MS. BUCKINGHAM: And is there a mechanism for a person to file a complaint if they feel like they're not being treated—
ALIA GOODHEART: Absolutely.
MS. BUCKINGHAM: And is that information posted all over the units?
ALIA GOODHEART: It is posted on the unit, and the forms are available.
MS. BUCKINGHAM: And a person, even if they're not on a one-to-one or directly interacting with a mental health worker or social worker, do they always have the ability to request to speak to somebody?
ALIA GOODHEART: Absolutely.
MS. BUCKINGHAM: And so even when maybe somebody from their team is not there or working, is there somebody always on call, a mental health worker, a social worker, a psychiatrist, a nurse, for a person to speak to if they felt they needed to?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And in addition to your meeting with her on January 4th, and after coming up with that plan for discharge on the 5th, are you aware that she then continued to engage in groups on the 5th, and that she continued to engage with mental health workers and social workers?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And do you recall when she was discharged on the 5th? Was it in the morning or in the evening?
ALIA GOODHEART: Afternoon. Probably around 3:00ish is my recall.
MS. BUCKINGHAM: Okay. And upon discharge, was she provided with information that she could use when she was home? Like resources.
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And do you recall that she had asked about resources to find a new doctor at some point?
ALIA GOODHEART: She, yes.
MS. BUCKINGHAM: And that she ultimately reported to the social worker that she felt comfortable managing at home?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: I may have one moment?
THE COURT: Sure.
MS. BUCKINGHAM: So upon discharge, what did you actually prescribe her?
ALIA GOODHEART: A 14-day supply of Ativan and a 14-day supply of Trazodone.
MS. BUCKINGHAM: Okay. And when you were having conversations with her about her thoughts of suicide or her thoughts of wanting to die, was she expressly asked if she wanted to kill herself?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And what was her answer, if you recall?
ALIA GOODHEART: She denied that.
MS. BUCKINGHAM: She denied that?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And was she specifically asked if she had a plan to kill herself?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And did she... What was her answer to that?
ALIA GOODHEART: She denied it.
MS. BUCKINGHAM: And was she specifically asked if she wanted to harm anyone else?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And did she provide an answer for that?
ALIA GOODHEART: She denied it.
MS. BUCKINGHAM: And those are standard questions you would ask at every interaction with her, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: And prior to discharge, she would also be asked those questions again, correct?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Because if her answers changed at any point, it would've changed your plan, right?
ALIA GOODHEART: Yes.
MS. BUCKINGHAM: Thank you.
MS. BUCKINGHAM: Nothing further. Thank you.