5           Q     Other than Russell White, did you ever

         6    administer morphine to anybody before?

         7           A     No.  I never administered morphine, period.

         8           Q     Did you ever give a sick patient, whoever

         9    it was, other than Mr. White, morphine?

        10           A     I don't know what you're talking about.

        11           Q     Well, the question is fairly simple.  You

        12    obtained a prescription for morphine to give to

        13    Mr. White; is that correct?

        14           A     Yes.

        15           Q     Okay.  My question is, did you ever

        16    dispense morphine to anybody before Mr. White in your

        17    past?

        18           A     My dad.

        19           Q     And he passed away?

        20           A     He had hospice and he was sick and he

        21    passed away, yes.

        22           Q     Okay.  So it's fair to say that you have

        23    observed an elderly patient who took morphine?  You were

        24    able to observe the effects of morphine on an elderly

        25    patient because you had administered it to your own





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         1    father; is that correct?

         2           A     No, my father had it rubbed on.  It was --

         3    with hospice, they come in certain times.  Other times,

         4    you go by what the medicine tells you to do so people do

         5    not end up in pain.

         6                 MR. CAMPBELL:  Ms. Kreiser --

         7                 MR. DAY:  Let me repeat the question.

         8                 MR. CAMPBELL:  Ask the question.

         9                 Please answer the question.

        10    BY MR. DAY:

        11           Q     My question -- let me repeat the question

        12    so you're clear on what I asked you.

        13                 My question was, so in the past with your

        14    own father, you have observed the administration of

        15    morphine to an elderly person and were able to watch the

        16    impact of that medicine on an elderly person; is that

        17    correct?

        18           A     I don't understand what you mean by

        19    "impact."  Yes, I administered it, but it wasn't -- I

        20    don't understand the question.

        21           Q     Okay.  Let me substitute the word "effect,"

        22    okay, for "impact."  You were able to observe the effect

        23    of morphine on your father; is that correct?

        24           A     No, he was in a coma.

        25           Q     Ma'am, the fact your father was in a coma





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         1    doesn't have anything to do with your observation of

         2    that.  My question is, you were able to observe the

         3    effect of the morphine on your elderly father; is that

         4    correct?  Yes --

         5           A     No.

         6           Q     -- or no?

         7           A     No.

         8                 MR. CAMPBELL:  Now, I'm going to object to

         9           that because if he was in a coma, she could not

        10           observe the effect.

        11                 MR. DAY:  Okay.

        12                 MR. CAMPBELL:  And you're asking for her to

        13           speculate.

        14                 MR. DAY:  I'm just asking for an answer,

        15           and she says no.  Okay.