Free Objection - District Court of Arizona - Arizona

Case 2:O3—cv—O1892—ROS Document 245-2 Filed O1/11/2007 Page1 0f3

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1 injury to be using the arm in_a spontaneous way.
2 Q. BY MR. TREON: So if Teresa August were_in the
3 ·presence of the officers prior to being handcuffed and
4 seized by them using her arm in a spontaneous way and
5 demonstrating and manifesting no suggestion of prior
6 injury to ner elbow, would you conclude-to a reasonable
7 degree of medical certainty that there had been no force
8. placed on that arm.even approximating what appears in
9 Figure l?
10 MS. HOLSMAN: Form, foundation.
ll A. Correct.
12 Q. BY MR. TREON: And would that then therefore
° 13 suggest to you that any possible force-applied by her
14 17—year—old grandson Sam Hickey 15 to 20 minutes earlier
15 did not play any causal role in the dislocation injury
16 that occurred later after being grabhed_by the officers?
17 MS. HGLSMAN: Form, foundation.
18 A. ‘Gorrect.
19- MR. TREQN: I don't have any more
20 questions. Thank you very-much.
21
22 FURTHER EXAMINATION
23 BY MS. HOLSMAN:
) 24 Q. I just have a couple fo1low—up questions. You
25 stated that the officers caused Teresa August's injury,
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I 110
1 correct?
N i 2 A. Once again that*a my Completely nonlegal opinion
3` based on what I have been provided with. And like I said,
4 I don't have any reason to think otherwise.
5 “Q. And do you agree that you have not been provided
6 all of the information that has been_developed through the
7 course of this oaee, including transcripts of officers,
8 the police report, the fire-department report at the
9 scene, pioturee,_additiona1 transcripts taken at the
10 aoene?
it MR. TREON: Object to form, foundation.
12 ·A. Obviously you would be in a better position to
) 13 judge what I haven't Seen.
14 Q. BY MS. HOLSMAN: But we can conclude that you
15 have not seen everything developed during the discovery
16 ‘prooeee of this oaee and that you have come to your
11 oonelueion based on the limited information that
18 plaintiff'e counsel has provided to you?
19 MR. TREON: Form, foundation.
20 A. Correct.
21 Q. BY MS. HOLSMAN: And when we look at the
22 August Blot letter written to you by Mr. Troon that‘s
23* Exhibit No. 1, he asks-you particular questions about
” p 24 whether or not —- he asks you questions about loading, he
` 25- asks you questions about the-length of time between Sam
Case 2:03-cv—Qj;_§g2-_§{l§};§,MAQ0,§urggegyjggggg.2 Filed O1/11/2OpgO_2.)P%gje)§éDE*)]§4

Case 2:03-cv-01892-ROS

Document 245-2

Filed 01/11/2007

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Case 2:03-cv-01892-ROS

Document 245-2

Filed 01/11/2007

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Case 2:03-cv-01892-ROS

Document 245-2

Filed 01/11/2007

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