Deposition of Norah K. Randles, M.D. (PDF)

NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 1 ·1· · · · · · · · · ·CAUSE NO. DC-19-18636 ·2· ·CICILY JOHN AND TONY JOHN,· ) IN THE DISTRICT COURT OF · · ·INDIVIDUALLY AND AS PARENTS ) ·3· ·AND NEXT FRIEN...

NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 1 ·1· · · · · · · · · ·CAUSE NO. DC-19-18636 ·2· ·CICILY JOHN AND TONY JOHN,· ) IN THE DISTRICT COURT OF · · ·INDIVIDUALLY AND AS PARENTS ) ·3· ·AND NEXT FRIENDS OF S.T., A ) · · ·MINOR,· · · · · · · · · · · ) ·4· · · · · · · · · · · · · · · ·) · · · · · · ·Plaintiffs,· · · · ·) ·5· · · · · · · · · · · · · · · ·) · · ·VS.· · · · · · · · · · · · ·) DALLAS COUNTY, TEXAS ·6· · · · · · · · · · · · · · · ·) · · ·TOUCHSTONE MEDICAL IMAGING, ) ·7· ·LLC; TOUCHSTONE MEDICAL· · ·) · · ·IMAGING, LLC D/B/A· · · · · ) ·8· ·TOUCHSTONE IMAGING· · · · · ) · · ·RICHARDSON; TOUCHSTONE· · · ) ·9· ·IMAGING OF MESQUITE, LP· · ·) · · ·D/B/A TOUCHSTONE IMAGING· · ) 10· ·RICHARDSON; BTDI JV, LLP· · ) · · ·D/B/A TOUCHSTONE IMAGING· · ) 11· ·RICHARDSON; RICHARDSON· · · ) · · ·PEDIATRIC ASSOCIATES;· · · ·) 12· ·GREGORY C. DOWNING, M.D.;· ·) · · ·GDX, P.A.; AND NORAH K.· · ·) 13· ·RANDLES, M.D.,· · · · · · · ) · · · · · · · · · · · · · · · · ·) 14· · · · · ·Defendants.· · · · ·) 191ST JUDICIAL DISTRICT 15· ********************************************************* 16· · · · · · ·ORAL AND VIDEOTAPED DEPOSITION OF 17· · · · · · · · · ·NORAH K. RANDLES, M.D. 18· · · · · · · · · · · ·March 18, 2021 19· · · · · · · · · · · · · Volume 1 20· · · · · · · · · · (Reported Remotely) 21· ********************************************************* 22· · · ORAL AND VIDEOTAPED DEPOSITION OF NORAH K. RANDLES, 23· M.D., produced as a deponent at the instance of the 24· PLAINTIFFS, CICILY JOHN AND TONY JOHN, INDIVIDUALLY AND 25· AS PARENTS AND NEXT FRIENDS OF S.T., A MINOR, and duly 800.211.DEPO (3376) EsquireSolutions.com  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 2 ·1· sworn, was taken in the above-styled and -numbered cause ·2· on the 18th day of March, 2021, from 10:04 a.m. to ·3· 1:49 p.m., before Tonie Thompson, Certified Shorthand ·4· Reporter in and for the State of Texas, Registered ·5· Professional Reporter, Certified Realtime Reporter, ·6· reported by machine shorthand, at the offices of Kershaw ·7· Anderson, PLLC, located at 12400 Coit Road, Suite 570, ·8· Dallas, Texas 75251, pursuant to the Texas Rules of Civil ·9· Procedure, the First Emergency Order Regarding the 10· COVID-19 State of Disaster, and the provisions stated on 11· the record or attached hereto. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 800.211.DEPO (3376) EsquireSolutions.com  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 3 ·1· · · · · · · · · ·A P P E A R A N C E S ·2· · · · ·(All parties present via videoconference.) ·3· ·ATTORNEY FOR PLAINTIFFS, CICILY JOHN AND TONY JOHN, · · ·INDIVIDUALLY AND AS PARENTS AND NEXT FRIENDS OF S.T., A ·4· ·MINOR: · · · · Mr. Russell T. Button ·5· · · Ms. Ashley Washington · · · · THE BUTTON LAW FIRM, PLLC ·6· · · 4315 West Lovers Lane, Suite A · · · · Dallas, Texas 75209 ·7· · · Phone:· (214)699-4409 · · · · Fax:· Not available ·8· · · E-mail:· [email protected] · · · · · · · · ·[email protected] ·9 · · ·ATTORNEY FOR DEFENDANTS TOUCHSTONE MEDICAL IMAGING, 10· ·LLC; TOUCHSTONE IMAGING OF MESQUITE, LP; AND BTDI JV, · · ·LLP, D/B/A TOUCHSTONE IMAGING RICHARDSON: 11· · · Ms. Amanda F. Hobbs · · · · Ms. Cathy F. Bailey (from 10:11 a.m. to 1:49 p.m.) 12· · · STEED DUNNILL REYNOLDS BAILEY STEPHENSON LLP · · · · 1717 Main Street, Suite 2950 13· · · Dallas, Texas 75201 · · · · Phone:· (469)698-4200 14· · · Fax:· (469)698-4201 · · · · E-mail:· [email protected] 15· · · · · · · ·[email protected] 16· ·ATTORNEY FOR DEFENDANTS GREGORY C. DOWNING, M.D., AND · · ·GDX, P.A.: 17· · · Mr. Jeffrey W. Ryan · · · · CHAMBLEE RYAN, P.C. 18· · · Trinity Towers · · · · 2777 North Stemmons Freeway, Suite 1257 19· · · Dallas, Texas 75207 · · · · Phone:· (214)905-2003 20· · · Fax:· (214)905-1213 · · · · E-mail:· [email protected] 21 22· · · · · · · · · · · · · ·* * * 23· · · · · · · · · · · · · ·* * * 24· · · · · · · · · · · · · ·* * * 25· · · · · · · ·(Continued on the next page.) 800.211.DEPO (3376) EsquireSolutions.com  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 4 ·1· · · · · · · · · ·A P P E A R A N C E S · · · · · · · · · · · · · (continued) ·2 · · ·ATTORNEY FOR DEFENDANTS NORAH K. RANDLES, M.D., AND ·3· ·RICHARDSON PEDIATRIC ASSOCIATES: · · · · Mr. Peter H. Anderson ·4· · · KERSHAW ANDERSON, PLLC · · · · 12400 Coit Road, Suite 570 ·5· · · Dallas, Texas 75251 · · · · Phone:· (214)347-4993 ·6· · · Fax:· (214)615-7361 · · · · E-mail:· [email protected] ·7 · · ·ALSO PRESENT: ·8· · · Ms. Sanam Arefi, Videographer ·9· · · Ms. Cicily John, Plaintiff 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 800.211.DEPO (3376) EsquireSolutions.com  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 5 ·1· · · · · · · · · · · · · ·INDEX ·2· Appearances· · · · · · · · · · · · · · · · · · · · 3 - 4 ·3· Index and Exhibits· · · · · · · · · · · · · · · · ·5 - 6 ·4· Requested Documents/Information· · · · · · · · · · · · 6 ·5· · · · · · · · · · ·EXAMINATION INDEX ·6· NORAH K. RANDLES, M.D. · · · · BY MR. BUTTON· · · · · · · · · · · · · · · · · · · 9 ·7 · · ·Changes and Signature· · · · · · · · · · · · · · · ·124 ·8 · · ·Reporter's Certification· · · · · · · · · · · · · · 126 ·9 · · ·Further Certification· · · · · · · · · · · · · · · ·129 10 · · · · · · · · · · · · ·EXHIBIT INDEX 11 · · ·NUMBER· · DESCRIPTION· · · · · · PAGE REFERENCED|MARKED 12· ·Exhibit 1 Medical note· · · · · · · · · · · · · ·62|123 · · · · · · · ·(RANDLES & RPA - 064-068) 13 · · ·Exhibit 2 Preparticipation Physical· · · · · · · 65|123 14· · · · · · ·Evaluation - Medical History · · · · · · · ·(RANDLES & RPA - 015) 15 · · ·Exhibit 3 Medical note· · · · · · · · · · · · · ·85|123 16· · · · · · ·(RANDLES & RPA - 056-059) 17· ·Exhibit 4 Call note· · · · · · · · · · · · · · ·112|123 · · · · · · · ·(RANDLES & RPA - 018) 18 · · ·Exhibit 5 Medical note· · · · · · · · · · · · · 114|123 19· · · · · · ·(RANDLES & RPA - 068-070) 20· ·Exhibit 6 Letter from Philip Wilson, M.D.,· · · 116|123 · · · · · · · ·dated 2/18/2019 21· · · · · · ·(RANDLES & RPA - 0142-0147) 22· ·Exhibit 7 Medical note· · · · · · · · · · · · · 117|123 · · · · · · · ·(RANDLES & RPA - 070-073) 23 · · ·Exhibit 8 Letter from Norah Randles, M.D.,· · · 119|123 24· · · · · · ·dated 12/3/2019 · · · · · · · ·(RANDLES & RPA - 011) 25· · · · · · · ·(Continued on the next page.) 800.211.DEPO (3376) EsquireSolutions.com  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 6 ·1· (All exhibits that were sent electronically to the court · · reporter will be marked and attached to the transcript.) ·2 · · · · · · · · · · · · · · ·* * * ·3 · · · · · · · · REQUESTED DOCUMENTS/INFORMATION ·4 · · ·NUMBER· · DESCRIPTION· · · · · · · · · · · · · · · PAGE ·5· ·Request 1 Current curriculum vitae of· · · · · · · · 13 · · · · · · · ·Norah K. Randles, M.D. ·6 · · ·Request 2 Form filled out and provided to· · · · · · 81 ·7· · · · · · ·the imaging center ·8· · · · · · · · · · · · · ·* * * ·9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 800.211.DEPO (3376) EsquireSolutions.com  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 7 ·1· · · · · · · · · ·P R O C E E D I N G S ·2· · · · · · · ·THE VIDEOGRAPHER:· Good morning.· We are ·3· now on the record.· Today's date is March 18th, 2021. ·4· The current time is 10:04 a.m.· This begins the ·5· videotaped deposition of Norah K. Randles, M.D., taken in ·6· the matter of Cicily John and Tony John, individually and ·7· as parents and next friends of S.T. v. Touchstone Medical ·8· Imaging, LLC, and others.· This case is being heard in ·9· the District County [sic] of Dallas County, Texas. 10· · · · · · · ·I am your remote videographer.· The court 11· reporter is Tonie Thompson. 12· · · · · · · ·Counsel, will you please introduce 13· yourselves, and the witness will be sworn. 14· · · · · · · ·MR. BUTTON:· Russell Button and Ashley 15· Washington on behalf of plaintiffs. 16· · · · · · · ·MR. ANDERSON:· Peter Anderson.· I represent 17· Dr. Randles and her group. 18· · · · · · · ·MR. RYAN:· Jeff Ryan for Dr. Downing. 19· · · · · · · ·MS. HOBBS:· Amanda Hobbs, and I represent 20· Touchstone Imaging of Mesquite, LP, improperly named as 21· Touchstone Imaging of Mesquite, LP, d/b/a Touchstone 22· Imaging Richardson -- and that's just the first one -- 23· BTDI JV, LLP, d/b/a Touchstone Imaging Richardson, and 24· Touchstone Medical Imaging, LLC, improperly named twice 25· and incorrectly named once as Touchstone Medical Imaging, 800.211.DEPO (3376) EsquireSolutions.com  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 8 ·1· LLC, d/b/a Touchstone Imaging Richardson.· I'm done now. ·2· · · · · · · ·THE REPORTER:· Thank you.· Please stand by ·3· for court reporter's introduction. ·4· · · · · · · ·The oral and videotaped deposition of ·5· Norah K. Randles, M.D., is being conducted remotely in ·6· accordance with the First Emergency Order Regarding the ·7· COVID-19 State of Disaster, paragraphs 2(b) and (c). ·8· · · · · · · ·The deponent is located at the offices of ·9· Kershaw Anderson, PLLC, located at 12400 Coit Road, 10· Suite 570, Dallas, Texas 75251. 11· · · · · · · ·My name is Tonie Thompson, Certified 12· Shorthand Reporter Number 8348.· I am administering the 13· oath and reporting the deposition remotely by 14· stenographic means from my home residence/office within 15· the state of Texas. 16· · · · · · · ·The deponent has been identified to me 17· through notice of deposition. 18· · · · · · · ·Please raise your right hand, Dr. Randles. 19· · · · · · · ·THE DEPONENT:· (Deponent complies.) 20· · · · · · · ·(Deponent sworn in.) 21· · · · · · · ·THE REPORTER:· Thank you.· Please lower 22· your hand. 23· · · · · · · ·THE DEPONENT:· (Deponent complies.) 24· · · · · · · ·THE REPORTER:· Counsel, please proceed. 25· · · · · · · ·MR. BUTTON:· Thank you, ma'am. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 9 ·1· · · · · · · · · NORAH K. RANDLES, M.D., ·2· having been first duly sworn, testified as follows: ·3· · · · · · · · · · · · EXAMINATION ·4· BY MR. BUTTON: ·5· · · Q.· ·Good morning, Dr. Randles.· How are you doing? ·6· · · A.· ·Fine.· Thank you.· Good morning. ·7· · · Q.· ·Good morning.· I'm Russell, and I'll be asking ·8· you the questions today.· Okay? ·9· · · A.· ·Okay. 10· · · Q.· ·The awesome court reporter here went through a 11· fantastic list of instructions and a bunch of stuff that 12· I'm not going to repeat.· I'll just bounce around a 13· little bit, if that's okay with you? 14· · · A.· ·Sure. 15· · · Q.· ·So one of the things is, because this is via 16· Zoom, there will be times that somebody's going to talk 17· over somebody or there's going to be an objection when 18· you're giving an answer.· What I tend to do is just wait 19· until everybody is done, and then I'll ask you to repeat 20· your answer if you -- if it was talked over.· Okay? 21· · · A.· ·Uh-huh.· Okay. 22· · · Q.· ·And you're going to have to give verbal answers 23· today. 24· · · A.· ·Okay. 25· · · Q.· ·And you're doing fine.· You're doing fine.· I'll 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 10 ·1· prompt you if you don't; just don't take offense to me if ·2· I prompt you for that.· It's not your fault.· It's just ·3· part of what we've got to have for this record.· Okay? ·4· · · A.· ·Okay. ·5· · · Q.· ·And, again, because we're on Zoom, there's going ·6· to be a little bit of a lag.· So if you'll let me get my ·7· whole question out, pause a little bit, you'll have all ·8· the time you need to answer your question, and I'll try ·9· to do the same for you.· All right? 10· · · A.· ·Okay, sir.· Thank you. 11· · · Q.· ·If you need a break, just let me know.· I just 12· ask that you answer the last question that I just asked 13· on the table, or if we're almost done with a particular 14· set, finish, and then go ahead and take a break.· Okay? 15· · · A.· ·Okay. 16· · · Q.· ·Real quick, do you have a cell phone in front of 17· you or anything? 18· · · A.· ·I do not. 19· · · Q.· ·And you don't have any e-mail or message 20· applications up on your computer? 21· · · A.· ·No, sir. 22· · · Q.· ·Do you have any documents with you today? 23· · · A.· ·I do not. 24· · · Q.· ·Okay.· And you understand that you're here for 25· your deposition and you're under oath, correct? 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 11 ·1· · · A.· ·I do, yes. ·2· · · Q.· ·All right.· Can you please state your full name ·3· for the record. ·4· · · A.· ·Norah Kathleen Randles. ·5· · · Q.· ·All right.· And, Dr. Randles, you work for ·6· Richardson Pediatric Associates as a pediatrician, ·7· correct? ·8· · · A.· ·Yes, sir. ·9· · · Q.· ·And do you have any ownership interest in 10· Richardson Pediatric Association? 11· · · A.· ·I am part owner in Richardson Pediatric 12· Associates, yes. 13· · · Q.· ·Okay.· What's your part ownership -- what's the 14· ownership interest? 15· · · A.· ·I have one partner.· It's just herself. 16· Dr. Sarah Troendle and myself are the owners of 17· Richardson Pediatric Associates. 18· · · Q.· ·Gotcha.· And is it a 50/50 partnership? 19· · · A.· ·Yes, sir. 20· · · Q.· ·And there's no other owners or part owners or 21· entities that own Richardson Pediatric Associates? 22· · · A.· ·No, sir. 23· · · Q.· ·Where is Richardson Pediatric located? 24· · · A.· ·1112 North Floyd Road, Suite 6A and Suite 7, 25· Richardson, Texas 75080. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 12 ·1· · · Q.· ·Any other locations other than that one? ·2· · · A.· ·No, sir. ·3· · · Q.· ·When did you first start working as a ·4· pediatrician with Richardson Pediatric? ·5· · · A.· ·July 2006. ·6· · · Q.· ·And is that when Richardson Pediatric was first ·7· established? ·8· · · A.· ·The practice itself has been present since ·9· early -- late '70s.· Dr. Steven Crow is the founder of 10· the practice.· I joined him in 2006 and then have been 11· present since. 12· · · · · · · ·(Ms. Bailey joined the deposition.) 13· · · · · · · ·(Comments made off the written record.) 14· · · Q.· ·(BY MR. BUTTON) So, Dr. Randles, when you first 15· came into Richardson Pediatric, did you come in as 16· ownership or did you come in as just a pediatrician as 17· part of the group? 18· · · A.· ·I came in as a pediatrician.· I was not an 19· owner.· I was an employee. 20· · · Q.· ·And when did you become a part owner of 21· Richardson Pediatric? 22· · · A.· ·My former boss passed away, and Dr. Troendle and 23· I purchased the practice at that time in, I think, 2013. 24· It's been about eight years. 25· · · Q.· ·Okay.· And Richardson Pediatric only sees 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 13 ·1· children, correct? ·2· · · A.· ·Yes, sir. ·3· · · Q.· ·Okay.· Up to what age? ·4· · · A.· ·Typically, age 18 or graduating high school. ·5· · · Q.· ·How many pediatricians work for Richardson ·6· Pediatric at this time? ·7· · · A.· ·Four. ·8· · · Q.· ·Who would be the other two pediatricians? ·9· · · A.· ·Dr. Abbie Smith and Dr. Natalie Pounds. 10· · · Q.· ·Was it a similar number of pediatricians working 11· at Richardson Pediatric in November of 2017? 12· · · A.· ·Yes, sir. 13· · · Q.· ·The same four? 14· · · A.· ·Yes, sir. 15· · · Q.· ·Do you keep a current CV? 16· · · A.· ·Yes, I guess.· It's been a while since I've had 17· to need one, so I could find one if I needed to. 18· · · Q.· ·Sure.· Well, it would just -- if you could find 19· your most recent one or get a current one, provide it to 20· your counsel -- 21· · · A.· ·Okay. 22· · · Q.· ·-- it'll prevent the need to go through all 23· those questions about background in depth.· So if you can 24· get that for us.· Is that fair? 25· · · A.· ·Sure. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 14 ·1· · · Q.· ·Where did you go to medical school, though? ·2· · · A.· ·University of Oklahoma in Oklahoma City. ·3· · · Q.· ·And you completed your pediatric residency, I ·4· believe, at Children's Medical Center in Dallas.· Is that ·5· correct? ·6· · · A.· ·Yes, sir. ·7· · · Q.· ·And then after completing your residency, did ·8· you do any fellowships? ·9· · · A.· ·I did not. 10· · · Q.· ·What's your experience in pediatric orthopedics? 11· · · A.· ·I'm a general pediatrician, so I have a broad 12· view of pediatric orthopedics, but not specialized. 13· · · Q.· ·So anything beyond your rotations as a part of 14· either med school or residency with orthopedics? 15· · · A.· ·No, sir. 16· · · Q.· ·I want to go to your -- kind of how Richardson 17· Pediatric and you as pediatricians operate.· Okay? 18· · · A.· ·Uh-huh.· Okay. 19· · · Q.· ·When a patient first sees Richardson Pediatric 20· to start the initial pediatrician-patient relationship, 21· is the patient assigned to one particular pediatrician as 22· a primary pediatrician? 23· · · A.· ·In the chart, it may say there is a PCP.· When a 24· family calls to schedule appointments, they are given the 25· option to schedule with whichever provider they choose. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 15 ·1· · · Q.· ·Okay.· So the policy at Richardson Pediatric is, ·2· when a patient calls in to schedule an appointment, they ·3· can either pick one or they can go to the first ·4· available.· Would that be fair? ·5· · · A.· ·Basically, yes. ·6· · · Q.· ·There's not one designated pediatrician that's ·7· assigned to a patient? ·8· · · A.· ·No.· Like I said, in the chart, it says PCP with ·9· a name.· That typically is the first provider who may 10· have seen them at the office.· But when they call, 11· they're offered appointments with the provider of their 12· choice or who -- which providers may be there that day to 13· see them. 14· · · Q.· ·Okay.· And so in Sandra's relationship with 15· Richardson Pediatric, you -- you were the listed primary 16· physician because you were the first one to see her when 17· she first started with Richardson Pediatric, correct? 18· · · A.· ·I believe so, yes. 19· · · Q.· ·And then when Sandra would schedule other 20· visits, would she always see you or would she see other 21· pediatricians as well? 22· · · A.· ·I believe she's seen mostly me, but I do believe 23· she has seen the other pediatricians in the practice 24· also. 25· · · Q.· ·And so collectively as a unit, you, with the 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 16 ·1· other three pediatricians at Richardson Pediatric, were ·2· responsible for Sandra's care as her pediatrician, right? ·3· · · A.· ·Yes. ·4· · · Q.· ·Do all of the pediatricians, nurses, and other ·5· staff members use the same medical records and charting ·6· system throughout Richardson Pediatric? ·7· · · A.· ·Yes, sir. ·8· · · Q.· ·And what's the name of that charting system? ·9· · · A.· ·It's Epic. 10· · · Q.· ·And how long have y'all had Epic? 11· · · A.· ·Oh, gosh.· Maybe about 10 years. 12· · · Q.· ·At least the time that you've been seeing 13· Sandra.· Would that be fair? 14· · · A.· ·For part of it, yes.· I think some of it was 15· on -- when we were paper charting, and some of it was 16· electronic. 17· · · Q.· ·Okay.· So if we see an electronic record in 18· Sandra's file, it would be through Epic? 19· · · A.· ·Yes, sir. 20· · · Q.· ·When you're doing your notes, are you dictating 21· those? 22· · · A.· ·No, sir. 23· · · Q.· ·You type them out? 24· · · A.· ·I do. 25· · · Q.· ·Do you enter them into the computer while the 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 17 ·1· patient's in the room with you? ·2· · · A.· ·I do.· I typically type while I'm obtaining the ·3· history. ·4· · · Q.· ·And so there wouldn't be any handwritten notes ·5· in the medical record as you're meeting with a patient ·6· and then kept that in a file, correct? ·7· · · A.· ·Not typically, no. ·8· · · Q.· ·Are the records all kept electronically at ·9· Richardson Pediatric? 10· · · A.· ·Yes, sir. 11· · · Q.· ·And so if a patient was seen by a different 12· physician, a different pediatrician other than you, would 13· the -- would that physician use the same chart and go 14· through the same medical conditions, diagnoses, 15· recommendations, everything the same? 16· · · A.· ·I mean, it's all one chart in the system, if 17· that's what you're asking, yes. 18· · · Q.· ·Okay.· So, for example, one -- one pediatrician 19· at Richardson Pediatric wouldn't use random written notes 20· or notes kept separately than any other pediatrician, 21· correct? 22· · · A.· ·Oh, no, sir.· No, sir. 23· · · Q.· ·And so the -- the notes that we see are 24· standardized (indiscernible) pediatrician -- 25· · · · · · · ·(Clarification made by the reporter.) 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 18 ·1· · · Q.· ·(BY MR. BUTTON) So regardless of which ·2· pediatrician sees a patient, the notes or the charts at ·3· Richardson Pediatric are all standardized.· They're all ·4· the same? ·5· · · A.· ·The chart is standardized, yes.· We have the ·6· ability to document within the chart, and that is ·7· individualized, yes. ·8· · · Q.· ·Is there a written policy and procedure on what ·9· gets put in individually within the chart? 10· · · A.· ·No, sir. 11· · · · · · · ·(Internet difficulties.) 12· · · · · · · ·(Comments made off the written record.) 13· · · · · · · ·THE REPORTER:· Back on the written record. 14· · · Q.· ·(BY MR. BUTTON) Before we get going any further, 15· Dr. Randles, we've been provided 191 documents as a part 16· of your medical chart.· To the best of your 17· understanding, is that the full record chart that 18· Richardson Pediatric has for our client Sandra Tony? 19· · · A.· ·Yes, sir. 20· · · Q.· ·There's not any other notes or additional 21· documents that would be in the record or that you would 22· have that aren't in that production? 23· · · A.· ·No, sir. 24· · · Q.· ·So everything that you've either written, 25· dictated by somebody else, or somebody else has written 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 19 ·1· and documented at Richardson Pediatric is included in ·2· that 191 pages, correct? ·3· · · A.· ·Yes, sir. ·4· · · Q.· ·Dr. Randles, you've been Sandra's pediatrician ·5· since she moved here to Texas in 2010, correct? ·6· · · A.· ·Yes, sir. ·7· · · Q.· ·And you actually were the pediatrician for all ·8· of her siblings, correct? ·9· · · A.· ·Yes, sir. 10· · · Q.· ·And the purpose of a primary care physician or a 11· pediatrician is to have one primary doctor in charge of 12· the overall care of a patient, correct? 13· · · A.· ·Yes, sir. 14· · · Q.· ·Because a -- if you refer out, a cardiologist is 15· not going to know what the ortho is doing and what the 16· radiologist reviewed, correct? 17· · · A.· ·They would know what was pertinent to why the 18· person was presenting to a specialist, but generally 19· they're not going to take care of the whole being. 20· · · Q.· ·Right.· So the pediatrician is the doctor that's 21· in charge of the whole being of the patient, including 22· what's happening with specialists and being the 23· centralized coordinator of care, correct? 24· · · A.· ·That's the goal, yes. 25· · · Q.· ·And the PCP, the pediatrician, is the keeper of 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 20 ·1· all that information, right? ·2· · · A.· ·If we receive the records from the specialist, ·3· we keep them, yes. ·4· · · Q.· ·And if you referred out to a specialist, you ·5· would get those records, correct? ·6· · · A.· ·Yes. ·7· · · Q.· ·Do you agree that a part of your job as the ·8· primary care pediatrician physician is to keep track of ·9· the patient's treatment needs? 10· · · A.· ·When a patient presents to me with needs, I try 11· to take care of them and take care of those needs as best 12· as possible, yes. 13· · · Q.· ·And if those needs are ongoing, it's going to be 14· something that you, the pediatrician, is monitoring and 15· making sure is carried out, correct? 16· · · A.· ·If the need is ongoing and they're seeing a 17· specialist, you would assume that the specialist is 18· taking care of that need.· So your role is in the 19· background; you're not actively taking care of that need. 20· · · Q.· ·Gotcha.· I'll ask you a little bit of a 21· different question.· Okay? 22· · · A.· ·Uh-huh.· Okay. 23· · · Q.· ·So if you diagnose a patient and it's not going 24· to a specialist, but it's your diagnosis for your 25· treatment, are you monitoring and making sure that any 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 21 ·1· future treatment needs are followed up and monitored on ·2· for that patient? ·3· · · A.· ·So typically if you are working on an active ·4· diagnosis with a patient and you give them a treatment ·5· plan, the assumption is, if they reach back out to you, ·6· that the plan is or is not going well, further decisions ·7· would be made based on that.· If they don't reach back ·8· out to you, then the assumption is that things are going ·9· well. 10· · · Q.· ·Okay.· So part of your job, then, would be to 11· develop and document the follow-up plans for a patient's 12· care needs, correct? 13· · · A.· ·Yes. 14· · · Q.· ·And Sandra sought treatment from you for 15· everything from common colds to yearly physical exams for 16· school, right? 17· · · A.· ·Yes, sir. 18· · · Q.· ·As far as a doctor-patient relationship, was it 19· a good relationship? 20· · · A.· ·A very good one, yes, I felt like. 21· · · Q.· ·Was she a good patient as far as hearing what 22· you had to say, following up on what you asked her to do, 23· and doing her best to carry out your recommendations as 24· best you can recall? 25· · · A.· ·Yes, sir. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 22 ·1· · · Q.· ·The -- when I refer to the "Tony family," you ·2· understand that I'm referring to her parents as well as ·3· Sandra, correct? ·4· · · A.· ·Yes, sir. ·5· · · Q.· ·Sandra Tony and her family, they could have ·6· picked anyone to be their primary care physician of their ·7· children and their family, right? ·8· · · A.· ·Yes. ·9· · · Q.· ·But they chose Richardson Pediatric because -- 10· and you? 11· · · A.· ·Yes, sir. 12· · · Q.· ·And you would agree that when patients come to 13· you, as their doctor, they expect that you're going to 14· take care of them, right? 15· · · A.· ·I would hope so, yes. 16· · · Q.· ·And do you believe that patients should trust 17· their doctors? 18· · · A.· ·Absolutely. 19· · · Q.· ·And do you believe that your patients should 20· trust your medical opinions as their doctor? 21· · · A.· ·Yes. 22· · · Q.· ·And you understand that patients rely on your 23· medical opinions and diagnoses, correct? 24· · · A.· ·I do, as I rely on their history and their 25· openness and honesty about how things are going and, you 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 23 ·1· know, what they're there for, what they're presenting for ·2· also.· It's definitely a give-and-take relationship. ·3· · · Q.· ·Sure.· And I'll get to the second part of that ·4· in just a second, trust me.· I'm not going to leave you ·5· hanging -- ·6· · · A.· ·Uh-huh. ·7· · · Q.· ·-- okay?· You ready to go? ·8· · · A.· ·Yeah.· Sorry.· Yes. ·9· · · Q.· ·Do you understand that your patients rely on 10· your medical opinions and diagnoses, correct? 11· · · A.· ·Yes, sir. 12· · · Q.· ·And do you believe that Sandra Tony and her 13· parents trusted you as Sandra's doctor? 14· · · A.· ·I would hope so, yes. 15· · · Q.· ·And you believe that Sandra Tony and her parents 16· relied on your medical opinions and diagnoses when it 17· came to Sandra's care, correct? 18· · · A.· ·Yes, sir. 19· · · Q.· ·When a patient -- or when you want a patient to 20· come back to you, to see you for a follow-up appointment, 21· you would put that in the medical records, correct? 22· · · A.· ·Most of the time, yes.· There is an assumption 23· with certain care that if things are not getting better, 24· that the family will call back and reach out. 25· · · Q.· ·Where is the assumption written down in any 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 24 ·1· policies and procedures at Richardson Pediatric that that ·2· is an assumption? ·3· · · · · · · ·MR. ANDERSON:· Objection; form. ·4· · · · · · · ·Go ahead. ·5· · · · · · · ·Can you hear me, Court Reporter?· Okay. ·6· · · · · · · ·THE REPORTER:· Yes.· Thank you. ·7· · · · · · · ·MR. ANDERSON:· Thank you. ·8· · · · · · · ·(Comments made off the written record.) ·9· · · A.· ·Like I said, we don't have written policies and 10· procedures in our office according to -- to dictate how a 11· relationship is enacted between a patient and a provider. 12· · · Q.· ·(BY MR. BUTTON) Is the assumption that you've 13· mentioned -- do you believe that patients have a right to 14· be informed that that is a unwritten policy at Richardson 15· Pediatric Associates? 16· · · A.· ·I guess I don't understand your question. 17· · · Q.· ·Sure.· You've mentioned a couple of times now 18· that there's an assumption that if you give a treatment 19· plan, there is no designated follow-up for a patient to 20· come back.· It's just assumed that if there's a problem, 21· that the patient will schedule an appointment and come 22· back in, correct? 23· · · A.· ·It is typically verbalized in an appointment at 24· the end, "If" -- as you're walking out, "If things aren't 25· better, let me know."· That is typically how I end most 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 25 ·1· of my appointments, whether it's a sick visit or a well ·2· visit.· Is that always written in the chart?· No.· Is it ·3· often written in the chart?· Yes. ·4· · · Q.· ·So when we're looking at the chart from ·5· Richardson Pediatric, there are going to be times when ·6· not everything is charted, correct? ·7· · · A.· ·Every single word that is spoken is likely not ·8· charted.· Pertinent positives and pertinent negatives, ·9· things that are valid to the complaint and to the reason 10· for the visit are charted, yes. 11· · · Q.· ·And that would be dictated by what you 12· understood to be important or to be valid, correct? 13· · · A.· ·It's dictated by what the conversation -- what 14· is happening in the conversation during the visit. 15· · · Q.· ·But you, the pediatrician at Richardson 16· Pediatric listening to the patient, are the one that 17· makes those records, correct? 18· · · A.· ·Yes. 19· · · Q.· ·And so if something was not put in the records, 20· it would have been your choice because you were the one 21· making those records, correct? 22· · · A.· ·I guess, yes. 23· · · Q.· ·Do you recall any time in the past with Sandra 24· where you had requested to see her for a follow-up 25· appointment and she did not comply with that request? 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 26 ·1· · · A.· ·I couldn't recall off the top, sir.· I'm sorry. ·2· · · Q.· ·That's okay.· And if there ever was a time where ·3· Sandra didn't comply with a request to see her back for a ·4· follow-up appointment, you would have noted that in the ·5· medical records, correct? ·6· · · A.· ·Yes. ·7· · · Q.· ·As Sandra's primary care physician pediatrician, ·8· you have asked Sandra in the past to come back in and see ·9· you for follow-up appointments, correct? 10· · · A.· ·It's likely, yes.· I'd have to look through her 11· chart to confirm that fully. 12· · · Q.· ·Sure.· The last time that I saw one was done was 13· back in 2010, 2011.· Is that the best that you could 14· recall? 15· · · A.· ·Again, I'd have to look at the chart, but I 16· won't argue with that. 17· · · Q.· ·Do you recall any time in the past where you had 18· told Sandra she needed to see a specialist for a 19· condition or illness and she didn't do as you told her to 20· do? 21· · · A.· ·I don't believe so. 22· · · Q.· ·If there ever was a time where Sandra didn't do 23· as you told her to do, as far as seeing a specialist for 24· a condition or illness, that would have been noted in the 25· medical records, correct? 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 27 ·1· · · A.· ·Yes. ·2· · · Q.· ·When you made a specific recommendation to ·3· Sandra, whether it be follow-up appointments or seeing a ·4· specialist, she followed through, correct? ·5· · · A.· ·I believe so, yes. ·6· · · Q.· ·And not only that, but she also came in ·7· regularly for preventative care in the form of her annual ·8· well-child visit from the years 2014 to 2018 for her ·9· physical exams, correct? 10· · · A.· ·I believe so, yes. 11· · · Q.· ·Now, you keep track of Sandra's treatment needs 12· to make sure things are not overlooked and to know if 13· there's something else that needs to be followed up on, 14· correct? 15· · · A.· ·Could you clarify what you mean by that? 16· · · Q.· ·Sure.· What part of that was -- did you not 17· understand so I can clean it up for you?· No problem. 18· · · A.· ·I guess keeping track of her treatment needs -- 19· I mean, I guess I just don't understand what you're 20· asking. 21· · · Q.· ·As Sandra's pediatrician, were you keeping track 22· of -- when you noted something down that was an illness 23· or a condition or a need or a complaint, would you keep 24· track of those things and make sure that it's not being 25· overlooked when she would come back in or to make sure 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 28 ·1· that stuff was being done that you asked her to do? ·2· · · A.· ·I mean, during a visit, you make recommendations ·3· and, again, you hope that the families follow through ·4· with the recommendations.· They are allowed, as humans, ·5· to decide what they follow through with or not. I ·6· receive reports from specialists if they have seen ·7· specialists that were recommended.· So keeping track of ·8· their treatment in that way would be how that is ·9· performed. 10· · · Q.· ·So it's fair to say, then, that at Richardson 11· Pediatric, as far as you're concerned as the 12· pediatrician, you did not keep track of Sandra's 13· treatment needs to make sure that things aren't 14· overlooked.· What you did is, once you made a 15· recommendation, you either got the records back from 16· specialists or a referral or you just saw the patient 17· next time they made a complaint, correct? 18· · · A.· ·I don't think it's fair to say that I did not 19· keep track of her treatment needs.· I made a 20· recommendation, and they never returned with further 21· complaints that things were not improving; therefore, the 22· recommendation was successful, so the treatment was 23· successful. 24· · · Q.· ·Right, and we'll get to the specifics here, 25· trust me. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 29 ·1· · · A.· ·Uh-huh. ·2· · · Q.· ·And I understand that you're saying that they ·3· didn't come back in and make any other complaints.· Okay? ·4· · · A.· ·Uh-huh.· Yes, sir. ·5· · · Q.· ·But is it fair to say that you did not keep ·6· track of a complaint that Sandra made to make sure that ·7· on subsequent visits, things were not being overlooked, ·8· there wasn't something else that Sandra needed to be ·9· followed up on, correct? 10· · · · · · · ·MR. ANDERSON:· And I'll object; form. 11· · · · · · · ·Go ahead. 12· · · A.· ·I don't think it's fair to say that.· I think 13· it's fair to say that she presented with certain 14· conditions or complaints, those complaints were addressed 15· appropriately, and at future visits, the complaints were 16· not rebrought up, so therefore they did not need to be 17· readdressed. 18· · · Q.· ·(BY MR. BUTTON) Do patients fill out any 19· paperwork upon arriving at Richardson Pediatric for their 20· appointments? 21· · · A.· ·There's various paperwork at all the different 22· stages through the visits depending on the type of visit 23· they present for, yes. 24· · · Q.· ·Okay.· So what is that different sets of 25· documents called?· Walk us through them. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 30 ·1· · · A.· ·I mean, the front desk, they have a -- and it's ·2· not every visit.· They'll just update, like, parent ·3· information forms, HIPAA forms, privacy forms, consents ·4· potentially for certain treatments or testing.· There's ·5· school forms, sometimes day care forms.· So there are ·6· various forms that are filled out depending on the ·7· patient's needs and what our office needs to update. ·8· · · Q.· ·And all of those would be part of the patient's ·9· medical record, correct? 10· · · A.· ·Yes. 11· · · Q.· ·So any form that Sandra or her parents filled 12· out at any appointments coming in at the front office 13· would have been included in the 191 pages we were 14· provided, correct? 15· · · A.· ·I believe, like, HIPAA -- yes, I believe so. 16· Yes. 17· · · Q.· ·What information regarding the reason the 18· patient is coming to see you is provided to you before 19· you see the patient? 20· · · A.· ·When they're brought back by my medical 21· assistant, they usually obtain a brief chief complaint, 22· which is typically the primary reason a patient is there, 23· and that is in the chart, and then I go into the room and 24· obtain my own history. 25· · · Q.· ·And what information would you be provided -- 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 31 ·1· you said "brief."· Give me an example. ·2· · · A.· ·They're not medically trained personnel, so we ·3· ask them not to get too in-depth with exactly what's ·4· going on.· They just say, "What are you here to see the ·5· doctor for today?"· And it's sore throat, vomiting, ·6· fever, runny nose, whatever they're primarily there for. ·7· It's typically a bullet point presentation. ·8· · · Q.· ·And is that written down, or is that plugged ·9· into a system? 10· · · A.· ·I believe it's in the medical record system 11· under "Chief Complaint," yeah. 12· · · Q.· ·So when we see "Chief Complaint" in your medical 13· records, is -- is that then what the medical assistant 14· put in or is that what you put in? 15· · · A.· ·I would have to look at how it's printed out, 16· but it's -- there is a chief complaint put in by the MA, 17· the medical assistant, and then under the "History" is 18· where I put my history, which is often based on what the 19· chief complaint was. 20· · · Q.· ·Do you review the patient's chart or records 21· before you see them in an exam room? 22· · · A.· ·Yes. 23· · · Q.· ·Do Richardson Pediatric's medical charts or 24· records have a problem -- problem list for quick 25· reference to see what kind of significant medical issues 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 32 ·1· that the patient has experienced in the past? ·2· · · A.· ·There is a problem list.· It is generally ·3· long-term problems.· They have to be put in there.· It is ·4· not automatically populated from each specific visit with ·5· each specific diagnosis. ·6· · · Q.· ·What would qualify as a long-term problem? ·7· · · A.· ·Like a syndrome, a Down syndrome, Turner's ·8· syndrome, a chronic -- chronic illness, type 1 diabetes, ·9· seizures, things such as that. 10· · · Q.· ·Is Osgood-Schlatters or growing pains, would 11· that be a long-term problem? 12· · · A.· ·I would say that would generally not be put in 13· the problem list. 14· · · Q.· ·So is anything that's put in the problem list at 15· Richardson Pediatric records, is that then followed up on 16· or at least checked in on at each subsequent visit? 17· · · A.· ·I would say that the providers will generally 18· review some visits to see what the primary diagnoses 19· were.· Whether the problem list is evaluated at each 20· visit is probably dependent on the provider. 21· · · Q.· ·And when you say it's "dependent on the 22· provider," you mean it may vary from you to Dr. Troendle 23· to the other two pediatricians, correct? 24· · · A.· ·Yes. 25· · · Q.· ·So within Richardson Pediatric, if a patient 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 33 ·1· sees one pediatrician versus another, as far as the prep ·2· work that goes into seeing the patient on that visit, ·3· there may be varying levels of what's looked at in the ·4· prior records of the chart, correct? ·5· · · A.· ·I think, as individuals, we all have our own ·6· individual way of reviewing the chart before the visit. ·7· · · Q.· ·To the extent that records are incomplete, that ·8· would be dangerous for a patient's safety, correct? ·9· · · · · · · ·MR. ANDERSON:· Objection; form. 10· · · · · · · ·MS. HOBBS:· Form. 11· · · · · · · ·THE DEPONENT:· Do I answer when there's 12· an -- 13· · · · · · · ·MR. ANDERSON:· Yeah. 14· · · · · · · ·THE DEPONENT:· I'm sorry.· I'm a little 15· confused.· Okay. 16· · · · · · · ·MR. ANDERSON:· Only if I say -- if I ever 17· say "objection," "attorney-client privilege" or 18· something -- 19· · · · · · · ·THE DEPONENT:· Okay. 20· · · · · · · ·MR. ANDERSON:· -- don't answer. 21· · · · · · · ·THE DEPONENT:· All right. 22· · · · · · · ·MR. ANDERSON:· I'll make it clear you don't 23· need to answer it. 24· · · · · · · ·THE DEPONENT:· Okay. 25· · · · · · · ·MR. ANDERSON:· But if I just say 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 34 ·1· "objection, form" or somebody else does, then you can ·2· still answer if you understand the question. ·3· · · · · · · ·THE DEPONENT:· Okay. ·4· · · · · · · ·MR. ANDERSON:· Does that make sense? ·5· · · · · · · ·THE DEPONENT:· Yeah. ·6· · · · · · · ·Can I ask you to clarify that question or ·7· repeat the question? ·8· · · · · · · ·MR. BUTTON:· Sure.· Can you hear me okay? ·9· · · · · · · ·THE DEPONENT:· Yeah. 10· · · Q.· ·(BY MR. BUTTON) To the extent the records are 11· incomplete, that would be dangerous for patient safety, 12· correct? 13· · · · · · · ·MR. ANDERSON:· And I'll object; form. 14· · · A.· ·And are you implying that my reports are 15· incomplete, or are you saying if records are incomplete? 16· · · Q.· ·(BY MR. BUTTON) If records are incomplete, that 17· would be dangerous for patient safety, correct? 18· · · · · · · ·MR. ANDERSON:· Objection; form. 19· · · · · · · ·MS. HOBBS:· Form. 20· · · A.· ·If records are incomplete, it is possible that 21· that could pose an issue for the patient, yes. 22· · · Q.· ·(BY MR. BUTTON) Incomplete records are one cause 23· of patients and their conditions being untreated or 24· falling through the cracks, correct? 25· · · A.· ·It's possible, yes. 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 35 ·1· · · · · · · ·MS. HOBBS:· Form. ·2· · · Q.· ·(BY MR. BUTTON) Other than waiting for a patient ·3· to make a follow-up appointment on their own, did you do ·4· anything else to make sure that things are not overlooked ·5· or if there's something else that needed to be followed ·6· up on with regard to Sandra Tony? ·7· · · A.· ·No, sir. ·8· · · · · · · ·MR. ANDERSON:· Objection; form. ·9· · · A.· ·I did not do follow-up, because there was no 10· follow-up from the family with me. 11· · · Q.· ·(BY MR. BUTTON) So following a diagnosis 12· relating to knee pain, charting findings relating to 13· musculoskeletal exams should be done and noted in the 14· medical records, correct? 15· · · A.· ·It depends on what type of visit it is involved 16· in. 17· · · Q.· ·If a patient came in for an unrelated condition 18· or chief complaint, a musculoskeletal exam would not be 19· done and noted in the patient's medical records, correct? 20· · · A.· ·If a patient presents for a sick visit with a 21· specific complaint, those are focused visits on the 22· specific complaint.· So they are going to, you know, 23· focus their exam and their diagnosis based on that day's 24· complaint, yes. 25· · · Q.· ·Regardless of what a prior visit would have 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 36 ·1· entailed, correct? ·2· · · A.· ·Yes. ·3· · · Q.· ·In the medical records, wherever it would have ·4· been noted that all was well with Sandra's knee, that ·5· means that there must have been follow-up done regarding ·6· her knee issues, correct? ·7· · · A.· ·I think that means that in the moment, at that ·8· exam, things are well. ·9· · · Q.· ·And that would have been something that would 10· have had to have been discussed in an exam that's done to 11· write that down, correct? 12· · · A.· ·Yes. 13· · · Q.· ·So on dates where Sandra was seen by you or 14· other physicians at Richardson Pediatric following 15· November 21st of 2017 where she first complained of knee 16· pain, every time it was charted that her musculoskeletal 17· exams were normal, that would be a result of a follow-up 18· exam being done and all findings being normal, correct? 19· · · A.· ·That would be a result of that issue not being 20· brought up and discussed or a normal exam. 21· · · Q.· ·So if it was noted that the musculoskeletal exam 22· was normal, that would mean that the patient did not 23· bring up any musculoskeletal issues, correct? 24· · · A.· ·I'm sorry.· I misunderstood.· If it is noted on 25· the physical exam that is it is normal, then it is normal 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 37 ·1· on the physical exam.· I apologize.· I misunderstood your ·2· question. ·3· · · Q.· ·So I'm going to ask it again.· Okay? ·4· · · A.· ·Yeah. ·5· · · Q.· ·So on the dates where Sandra was seen by you or ·6· other pediatricians at Richardson Pediatric following the ·7· November 21st, 2017, date where she first complained of ·8· her knee, every time it was charted that her ·9· musculoskeletal systems -- musculoskeletal exams were 10· normal, that was a result of a follow-up exam being done 11· and all findings being normal, correct? 12· · · A.· ·It is our general practice to chart what we 13· experience and what we evaluate during the exam.· So, 14· yes, I would assume that if it was charted as normal, it 15· was normal. 16· · · Q.· ·Approximately how much time do you spend 17· reviewing a patient's past medical records before you see 18· that patient in person? 19· · · A.· ·Honestly, it depends on how complicated of a 20· patient it is.· If it is a typical child with a 21· relatively benign past history, it can be very brief.· If 22· it is an extremely complicated patient, it's going to 23· take more time. 24· · · Q.· ·Using Sandra Tony as your example, approximately 25· how much time would you spend reviewing her past medical 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 38 ·1· records before you would see her in person? ·2· · · A.· ·Typically, a minute or two -- ·3· · · Q.· ·Not very -- ·4· · · A.· ·-- five minutes. ·5· · · · · · · ·Yeah.· No, it doesn't take long. ·6· · · Q.· ·When one of your patients like Sandra, even ·7· though you were designated as the primary physician, when ·8· she would see a different doctor at Richardson ·9· Pediatric's office that was covering an appointment that 10· maybe you weren't available for, would that physician be 11· expected to record their medical opinion, notes, 12· diagnoses, and everything the same to the electronic 13· system as you are? 14· · · A.· ·I mean, if you're asking if they document in the 15· same system, yes, it's the same exact system, yes. 16· · · Q.· ·And that is in order to ensure that the 17· patient's records are all kept together so that all 18· physicians across Richardson Pediatric can access them 19· when they need to, correct? 20· · · A.· ·Yes, sir. 21· · · Q.· ·And are all physicians at Richardson Pediatric 22· held to the same standard as far as charting the 23· patient's symptoms and complaints? 24· · · A.· ·Yes. 25· · · Q.· ·So both you and Dr. Troendle would follow the 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 39 ·1· same procedure on documenting all of the patient's ·2· complaints in medical records, correct? ·3· · · A.· ·Yes. ·4· · · Q.· ·What amount of time is blocked out for each ·5· patient in your days at work? ·6· · · A.· ·So it varies depending on the type of visit. ·7· Sick visits are scheduled for 10 minutes.· Well visits ·8· are scheduled for 20 minutes.· I think all my patients ·9· can attest that we do not wear a timer, and we spend 10· whatever time we need with them, and so hence we tend to 11· run behind sometimes. 12· · · Q.· ·Approximately how much time would you have spent 13· with Sandra, for an example, of her visit like the knee 14· visit in 2017?· How much time would you have spent with 15· that kind of a patient? 16· · · A.· ·Reviewing the chart and seeing the history that 17· I took, which was pretty extensive, I would say I 18· probably took probably about 20 minutes, would be my 19· guess. 20· · · Q.· ·Is a nurse present with you in the exam rooms 21· while you're seeing the patient, or the medical 22· assistant? 23· · · A.· ·Not unless the family requests it. 24· · · Q.· ·Do you recall if on November of 2017, whether 25· there was a nurse or a medical assistant present with you 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 40 ·1· with the Tony family? ·2· · · A.· ·I can't imagine there would have been. ·3· · · Q.· ·It would have been noted in your records if ·4· there was, I'm sure? ·5· · · A.· ·Yeah.· Likely, yes. ·6· · · Q.· ·So typically, unless it's requested by the ·7· patient, it's just you, the doctor, the patient, and then ·8· their guardian or family member, correct? ·9· · · A.· ·Yes, sir. 10· · · Q.· ·When you walk in the door, you know, what's 11· typically the first thing that you do in your standard 12· protocol? 13· · · A.· ·I greet the family.· I always pretty much 14· apologize for running behind, and with a family like the 15· Tonys -- I've known them for a long time -- "How are 16· things going?"· It's, you know, kind of a very casual and 17· friendly relationship.· And, "I need to know what brings 18· you in today.· What's going on, guys?" 19· · · · · · · ·And, you know, I observe the room.· You can 20· often tell how things are going with a pediatric patient 21· before words even flow just based on how they look, how 22· they are presenting themselves, the level of discomfort 23· on their, you know -- their face or within their body. 24· And then we discuss what's going on, and then I typically 25· would perform a physical exam. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 41 ·1· · · Q.· ·So let's start with, what would be the first ·2· thing that you would have done after the greeting with ·3· the Tony family when somebody's coming in, complaining of ·4· physical pain like knee pain?· What would be the first ·5· thing that you would start with? ·6· · · A.· ·I mean, the history would be the first thing, ·7· asking them:· When did it start?· How often is it ·8· happening?· What makes it better or worse?· How has it ·9· changed?· Things like that. 10· · · Q.· ·So the first thing that you would do after 11· greeting the patient and the family is to take a history 12· of the illness or condition that they were coming in 13· complaining of, correct? 14· · · A.· ·Yes, sir. 15· · · Q.· ·And do you take the history down by hand or type 16· it? 17· · · A.· ·I type it as I am discussing it with the family. 18· · · Q.· ·And on the Richardson Pediatric medical records, 19· that information would fall under the heading of "HPI 20· Comments" in the progress notes.· Is that right? 21· · · A.· ·I believe so, yes. 22· · · Q.· ·And then after you get done with the history, 23· you go to a physical exam, correct? 24· · · A.· ·That would be typical, yes. 25· · · Q.· ·And do you examine the patient as a whole or 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 42 ·1· just the area in which they're complaining? ·2· · · A.· ·For sick visits, you can do a focused exam, and ·3· so if someone is coming in with a focused complaint, a ·4· focused exam is appropriate. ·5· · · Q.· ·And if they're coming in with a non-head-cold ·6· complaint, such as knee pain, do you examine the patient ·7· as a whole or do you just jump to the area that they're ·8· complaining of pain? ·9· · · A.· ·Typically, you would -- you would go to the area 10· of where the complaint is. 11· · · Q.· ·So on a sick visit, though, the knee is not 12· going to be examined, correct? 13· · · A.· ·If it's a sick visit that is not a sick visit 14· for a knee complaint, the knee and the orthopedics would 15· probably not be evaluated, no. 16· · · Q.· ·Do you note down what you examine in the 17· records? 18· · · A.· ·So during my physical exams, I'll generally list 19· pertinent positives or pertinent negatives so that I can 20· be able to review it and know kind of what's going on. 21· · · Q.· ·Explain that a little further.· What do you mean 22· by that?· Take the context of a knee pain case like 23· Sandra's.· Explain to us that way. 24· · · A.· ·So if I have a patient complaining of knee pain, 25· I do have a standard approach.· And so my approach would 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 43 ·1· be to have them sit at the table, visualize the knees, ·2· have them kind of -- I would move the legs back and ·3· forth, both right and left.· And then I would have them ·4· lay on the table, bend their knees.· I would manipulate ·5· the knees to see if there's pain, tenderness, or laxity ·6· within the joints.· And then I would document my findings ·7· based on what I feel was pertinent during the exam -- or ·8· what was pertinent during the exam -- or what was ·9· positive, I guess, would be a better way to describe 10· that. 11· · · Q.· ·So when documenting what you do in an exam, 12· you're really just documenting your findings, the 13· positive findings, correct? 14· · · A.· ·That's generally -- yes, yes. 15· · · Q.· ·You are not documenting the different maneuvers 16· and tests you did during the physical exam, correct? 17· · · A.· ·No, because the physical exam is documenting the 18· findings, not the procedures. 19· · · Q.· ·This standard procedure or protocol that you 20· mentioned, is that written down anywhere? 21· · · A.· ·I don't think I mentioned the "standard 22· protocol."· I don't know what you're referring to. 23· · · Q.· ·The standard knee exam, physical exam, when 24· somebody comes in and you start your knee exam, you said 25· that you have a standard protocol or a standard procedure 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 44 ·1· that -- for those.· Is that written down anywhere? ·2· · · A.· ·No.· It's the exam that you have been taught ·3· through training and utilized as your -- as your standard ·4· as how you approach knee pain in a knee exam.· So that's ·5· what I meant by my standard. ·6· · · Q.· ·Would it be fair to say, then, that there's no ·7· way to tell what you did or didn't do in the physical ·8· exams because that process is not written down, correct? ·9· · · · · · · ·MR. ANDERSON:· Objection; form. 10· · · A.· ·I think you can tell what was done based on the 11· findings that are documented. 12· · · Q.· ·(BY MR. BUTTON) So you can look at a record and 13· tell us all the different steps that you took during the 14· exam for each patient that you see even though no exam 15· notes are written, correct? 16· · · · · · · ·MR. ANDERSON:· Object; form. 17· · · A.· ·You can look at a record and see the findings of 18· the exam, which is the purpose of a physical exam. 19· · · Q.· ·(BY MR. BUTTON) However, if another doctor was 20· going to evaluate what physical exam you gave this 21· patient, they could not look at your records and say, "I 22· examined these different tests when physically examining 23· this patient for knee pain," because you don't document 24· down the different physical exams that you do; you only 25· document the results, correct? 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 45 ·1· · · · · · · ·MR. ANDERSON:· Objection; form. ·2· · · A.· ·So they can look at the physical exam and find ·3· the findings, which is the appropriate documentation of a ·4· physical exam.· When you talk to four doctors, you're ·5· going to find four different ways that they approach ·6· different types of physical exams.· People may auscultate ·7· the heart differently.· People may look at the ears ·8· differently.· But the findings are generally telling of ·9· the exam, and that's what's documented. 10· · · Q.· ·(BY MR. BUTTON) Your standard protocol with 11· handling a physical exam in your records is to only chart 12· the results, not the exam being done, correct? 13· · · A.· ·Yes.· During -- in the physical exam, you chart 14· the results of the physical exam, not how the physical 15· exam is done. 16· · · Q.· ·Right.· And you answered my question. 17· · · A.· ·Okay. 18· · · Q.· ·Try to keep it real simple for the court 19· reporter.· Okay? 20· · · A.· ·Uh-huh.· Uh-huh. 21· · · Q.· ·Are you ready to go? 22· · · A.· ·Yes.· Sorry. 23· · · Q.· ·As far as your standard protocol for documenting 24· in your medical records, you only chart the physical exam 25· results, not the steps done in the exam, correct? 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 46 ·1· · · A.· ·Yes. ·2· · · Q.· ·So there's no way for us to tell whether you had ·3· Sandra stand up, sit down, bend, walk, or jump; we can ·4· only see the findings that you discovered upon doing the ·5· physical exam, correct? ·6· · · · · · · ·MR. ANDERSON:· Objection; form. ·7· · · A.· ·Yes, the findings of the physical exam are ·8· documented in the chart. ·9· · · Q.· ·(BY MR. BUTTON) Another doctor coming after you 10· would not be able to know whether you had Sandra stand 11· up, sit down, bend, walk, or jump, correct? 12· · · A.· ·They would ask the parents, I assume, but, 13· again, the way the physical exam was done is not 14· documented; it's the findings. 15· · · Q.· ·So on November 21st of 2017 when you did a 16· history and then a physical exam of Sandra, there was no 17· documentation in the record of the physical exam steps 18· that you had Sandra do -- for example, standing, sitting, 19· bending, jumping, walking -- correct? 20· · · A.· ·Correct. 21· · · Q.· ·After a physical exam, what do you do? 22· · · A.· ·I -- typically I discuss the findings with the 23· family, kind of tell them what I feel might be occurring, 24· and formulate a treatment plan typically with the family. 25· · · Q.· ·What is differential diagnosis? 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 47 ·1· · · A.· ·A differential diagnosis is kind of a list or a ·2· working list of what you feel is going on with a -- with ·3· a patient based on complaint and physical exam findings. ·4· · · Q.· ·And why is a differential diagnosis important? ·5· · · A.· ·It gives you ideas as to how much further ·6· evaluation is needed and/or what treatment is needed. ·7· · · Q.· ·And is a differential diagnosis, is that list -- ·8· that active list used until you ultimately reach your ·9· final diagnosis? 10· · · A.· ·If you have a firm diagnosis, they're just kind 11· of part of it.· They're not always utilized.· It's -- 12· it's kind of a thought process, so not really. 13· · · Q.· ·So if you have a firm diagnosis, there's not 14· going to be any other possible diagnoses listed in your 15· medical records as a finding, correct? 16· · · A.· ·If you have an absolute 100 percent diagnosis, 17· you don't need to have a prolonged differential list. 18· · · Q.· ·And so that's why when we look at your medical 19· records, for example, for Sandra on November 21st of 20· 2017, where it diagnosed her with Osgood-Schlatters, 21· there's not going to be any other conditions under that 22· as a potential differential diagnosis, correct? 23· · · A.· ·I believe there was also right knee pain as part 24· of my differential diagnosis. 25· · · Q.· ·So you diagnosed Sandra with Osgood-Schlatters 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 48 ·1· and/or right knee pain, correct? ·2· · · A.· ·Yes. ·3· · · Q.· ·And what did you do to follow up on right knee ·4· pain? ·5· · · A.· ·Based on her physical exam and the complaints, ·6· we did an X-ray -- we ordered an X-ray that day. ·7· · · Q.· ·What does a diagnosis of right knee pain mean to ·8· you, as the doctor? ·9· · · A.· ·Right knee pain in an adolescent can be many, 10· many, many things brought on by many things, and it just 11· gives you something to work from.· It gives you an idea 12· if you need to do further evaluations or what treatments 13· you should employ at that time. 14· · · Q.· ·And so did you send Sandra for an X-ray because 15· of your diagnosis of Osgood-Schlatters, or did you send 16· Sandra for an X-ray because of your diagnosis of knee 17· pain? 18· · · A.· ·I sent Sandra for an X-ray because of the right 19· knee pain and the, kind of, extent of her history. I 20· thought it was likely Osgood-Schlatter.· An X-ray would 21· help me not diagnose Osgood-Schlatter, but confirm that 22· there was nothing more sinister occurring. 23· · · Q.· ·And nothing more sinister occurring that you 24· were looking for would be something like OCD, 25· osteochondritis dissecans, correct? 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 49 ·1· · · A.· ·You know, I think just anything other than a ·2· normal knee, that's what I was looking for, and at the ·3· time, that's what I received, was a normal knee. ·4· · · Q.· ·When you received the radiology report back from ·5· the radiologist, it indicated that there were no abnormal ·6· findings; it was a normal right knee, correct? ·7· · · A.· ·Yes, sir. ·8· · · Q.· ·A negative X-ray -- meaning a normal X-ray -- ·9· does not mean that nothing is wrong, correct? 10· · · A.· ·In this situation, the negative X-ray read 11· helped me feel comfortable with the diagnosis of 12· Osgood-Schlatters. 13· · · Q.· ·So after you got the X-ray radiology report that 14· it was a normal knee, you felt confident; you stand by 15· your diagnosis of Osgood-Schlatters, correct? 16· · · A.· ·Yes. 17· · · Q.· ·Why did that make you feel confident that it was 18· Osgood-Schlatters and not something else? 19· · · A.· ·Because she is a teenager with knee pain with 20· activity.· That is a very common thing that we see in our 21· office.· Osgood-Schlatter is a very common cause of that. 22· With no changes in an X-ray, then there wasn't any reason 23· to question that it wasn't Osgood-Schlatters at the time. 24· · · Q.· ·Osgood-Schlatters in pediatrics, in children is 25· similar to growing pains, correct? 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 50 ·1· · · A.· ·I've never used the term "growing pains" to ·2· describe Osgood-Schlatter.· It is more of an overuse ·3· injury that occurs when they're growing, so it's not a ·4· growing pain. ·5· · · Q.· ·What are the key factors and symptoms of an ·6· Osgood-Schlatters diagnosis? ·7· · · A.· ·Typically, they're an adolescent, early ·8· adolescent who complains of pain with activity, comes and ·9· goes.· Sometimes one knee, sometimes both knees.· It's 10· usually an active -- you know, an active adolescent who 11· is busy in sports or -- in sports, and it's just pain. 12· Sometimes there is a mild swelling at their tibial 13· tuberosity, but often it's a subjective diagno- -- or a 14· subjective history from a patient of pain. 15· · · Q.· ·So let me go through that and make sure I got it 16· all down.· Okay? 17· · · A.· ·Okay. 18· · · Q.· ·One of the things that you mentioned was 19· Osgood-Schlatter, a key factor is adolescent age, 20· correct? 21· · · A.· ·Early adolescence. 22· · · Q.· ·What would be that age range? 23· · · A.· ·Like 11 to 15. 24· · · Q.· ·And would it be the same for males and females? 25· · · A.· ·Generally, yes.· I mean, depends on when they 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 51 ·1· are going through their active growth spurt.· It might ·2· last a little longer in boys because they go through ·3· their growth spurt later. ·4· · · Q.· ·Okay.· So what would be the typical age range ·5· for a female? ·6· · · A.· ·11 to 15. ·7· · · Q.· ·And then the other thing you mentioned is knee ·8· pain, correct? ·9· · · A.· ·Uh-huh.· Yes, sir.· Sorry. 10· · · Q.· ·And the next factor that you mentioned was it 11· could be one knee or it could be both knees, correct? 12· · · A.· ·Yes, sir. 13· · · Q.· ·And the next thing that you mentioned is that 14· the pain would come and go -- it would be on and off, 15· correct? 16· · · A.· ·Yes, sir. 17· · · Q.· ·And did you mention any other factors that I 18· didn't write down? 19· · · A.· ·I don't believe so. 20· · · · · · · ·MR. ANDERSON:· Russell, I don't know if you 21· picked up on -- I believe she said "pain with activity," 22· and I don't know if that's something you went back over, 23· but that was part of what I jotted down. 24· · · Q.· ·(BY MR. BUTTON) Dr. Randles, would pain with 25· activity be another factor that you mentioned for 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 52 ·1· Osgood-Schlatters? ·2· · · A.· ·Yes, sir. ·3· · · · · · · ·MR. ANDERSON:· Russell, when you get to a ·4· decent transition point, I wouldn't mind taking a quick ·5· break. ·6· · · · · · · ·MR. BUTTON:· Sure.· I'm almost there. ·7· · · · · · · ·MR. ANDERSON:· Sure.· Thanks. ·8· · · Q.· ·(BY MR. BUTTON) Dr. Randles, would a factor be ·9· that there would be a bump on the front of the knee or 10· just below the kneecap? 11· · · A.· ·That is a physical finding in the textbooks when 12· you read about Osgood-Schlatter.· It is not something you 13· see on every physical exam of a patient with 14· Osgood-Schlatters. 15· · · Q.· ·Would there be a swelling indication for 16· Osgood-Schlatters? 17· · · A.· ·Swelling of the general knee, likely not. 18· · · Q.· ·Would there be any swelling in a patient with 19· Osgood-Schlatters? 20· · · A.· ·I think anything is possible on exams, so it's 21· hard for me to say would there be any or none. 22· · · Q.· ·And would there be a history of the patient 23· wearing a stabilization brace? 24· · · A.· ·I don't know that that has any pertinence in an 25· actual finding of Osgood-Schlatters.· That's something 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 53 ·1· that families will do on their own, not necessarily ·2· something that is causing Osgood-Schlatters, if that ·3· makes sense. ·4· · · Q.· ·So the fact that Sandra had been wearing a ·5· stabilization brace, per your history, since March began, ·6· that would not be a key factor indication in your ·7· Osgood-Schlatters diagnosis, correct? ·8· · · A.· ·Not particularly, no. ·9· · · Q.· ·Is the knee locking a factor in your 10· Osgood-Schlatters diagnosis? 11· · · A.· ·So knee locking is not something you would 12· typically hear for Osgood-Schlatter.· And in general, 13· when patients give history of knee pain in adolescents 14· and in pediatrics, histories vary so much because 15· perceptions from children can vary.· So the way they 16· express it and the way they describe pain is often also 17· variable.· But the locking was out of the ordinary, which 18· led me also to do the X-ray, which I did. 19· · · Q.· ·So are you saying that you did not take Sandra 20· Tony's and her mom's complaint that her knee locked 21· seriously? 22· · · A.· ·Absolutely not, I am not saying that.· I did 23· take it seriously.· I did an X-ray secondary to their 24· complaint of her knee locking. 25· · · Q.· ·And you would concede that the symptom of a knee 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 54 ·1· locking is not consistent with an Osgood-Schlatters ·2· diagnosis, correct? ·3· · · A.· ·I would say it's not something I hear every time ·4· I hear a complaint that is consistent with ·5· Osgood-Schlatter. ·6· · · Q.· ·And so what did you do when you got back the ·7· normal X-ray to rule out any other further problems with ·8· Sandra's knee because of the locking symptom that you ·9· knew about? 10· · · A.· ·With the normal X-ray, I was reassured that her 11· knee was okay, and so we treated it conservatively with 12· ibuprofen and rest. 13· · · Q.· ·So a knee locking, that could be ligament 14· damage, correct? 15· · · A.· ·I would not know how to answer that.· I'm not an 16· orthopedist. 17· · · Q.· ·Correct.· And so that's why it's important that 18· if you get back a normal X-ray and a patient is 19· complaining of pain and a symptom that doesn't fit into 20· your primary diagnosis, that you need to refer them to a 21· specialist such as an ortho, correct? 22· · · A.· ·With a normal X-ray, I was reassured that there 23· was nothing else going on at the time; therefore, I felt 24· conservative treatment was okay at the time. 25· · · Q.· ·But there was something going on at the time. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 55 ·1· She had OCD defect in her knee and the prime factor was ·2· that the knee was locking and you did nothing further, ·3· correct? ·4· · · · · · · ·MR. ANDERSON:· Objection; form. ·5· · · A.· ·I had a normal X-ray, and I tried to treat the ·6· patient conservatively. ·7· · · Q.· ·(BY MR. BUTTON) And so you were reassured that ·8· upon the normal X-ray, that it was OSD, Osgood-Schlatter ·9· diagnosis, correct? 10· · · A.· ·Yes. 11· · · Q.· ·Sitting here today, is there anything that you 12· would do differently to prevent this type of thing from 13· happening again? 14· · · A.· ·I think anything is possible in hindsight.· If 15· the X-ray had been read abnormal, I would absolutely have 16· referred her to orthopedics.· If the parents had called 17· me back and told me she wasn't doing better, I would have 18· absolutely referred her to an orthopedist. 19· · · Q.· ·So, Dr. Randles, sitting here today -- and it's 20· okay if you feel this way -- it is the responsibility, 21· per you, of the radiologist that missed the OCD and yet 22· you're blaming Sandra Tony and her parents for what 23· happened here that -- to prevent this, correct? 24· · · · · · · ·MR. ANDERSON:· Objection; form.· I don't 25· know if she's blaming them.· She's telling you that if 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 56 ·1· they had complained further, that would have caused her ·2· to do something different.· That's not necessarily ·3· blaming them.· So that's my objection. ·4· · · · · · · ·Go ahead, Dr. Randles. ·5· · · · · · · ·MR. BUTTON:· You can answer, Dr. Randles. ·6· · · A.· ·I feel if I had gotten a different X-ray read, ·7· the decision-making would have been differently.· I am ·8· not blaming the parents.· I wish they had called back and ·9· told me that her knee wasn't better, because I would have 10· sent her to orthopedics if I had known. 11· · · Q.· ·(BY MR. BUTTON) So sitting here today, right 12· now, had you been notified that Sandra had continuing 13· knee pain in her right knee at any point beyond that 14· visit, you would have referred her to an ortho, correct? 15· · · A.· ·If I had known that she had continued knee pain, 16· yes, I would have referred her to orthopedics. 17· · · Q.· ·No question about it, right? 18· · · A.· ·No. 19· · · Q.· ·When the X-ray came back negative, you did not 20· follow up with Sandra on how her knee was feeling, 21· correct? 22· · · A.· ·When the X-ray came back negative, my nurse 23· called her, gave her the results.· We said we would treat 24· it conservatively, and that's what was done. 25· · · Q.· ·And you, as her pediatrician that knew about the 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 57 ·1· knee pain, never asked Sandra again at any other prior -- ·2· or subsequent time how her knee was feeling, correct? ·3· · · A.· ·If it's not always brought up, it's not -- no. ·4· · · Q.· ·Simply put, Dr. Randles:· After November 21st ·5· of 2017 and after you got a normal X-ray, you never asked ·6· Sandra Tony or her parents how Sandra's right knee was ·7· doing, correct? ·8· · · A.· ·Did I specifically call her to ask how her knee ·9· was doing?· No. 10· · · Q.· ·And you never asked her how her knee was doing 11· on any subsequent visits where you saw Sandra Tony and 12· her parents, correct? 13· · · A.· ·The subsequent visits were focused exams for 14· sick visit purposes, and if it was not brought up, it was 15· not discussed, no. 16· · · Q.· ·And you never brought up on subsequent visits 17· any questions or follow-up about Sandra's right knee 18· prior complaints, correct? 19· · · A.· ·Correct. 20· · · Q.· ·So would it be fair to say that it is Richardson 21· Pediatric's policy -- or your policy, Dr. Randles -- that 22· if the child patient does not complain, you're not going 23· to ask them how something is doing, correct? 24· · · A.· ·If it is not an ongoing conversation, it's -- 25· it's hard to have a conversation that's not ongoing. 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 58 ·1· · · Q.· ·Let me put this a different way.· Okay? ·2· · · A.· ·Uh-huh.· Okay. ·3· · · Q.· ·Dr. Randles, you rely on the child patient to ·4· take the first steps in bringing up complaints to you ·5· that are going to be ongoing in order to do your ·6· follow-ups, correct? ·7· · · · · · · ·MR. ANDERSON:· Objection; form. ·8· · · · · · · ·MS. HOBBS:· Objection; form. ·9· · · · · · · ·MR. ANDERSON:· Go ahead. 10· · · A.· ·I rely on the patient and the family member that 11· is accompanying the patient. 12· · · Q.· ·(BY MR. BUTTON) It's fair to say that you, as 13· the pediatrician, don't take the initiative to ask the 14· patient about previous concerns that they had -- for 15· example, Sandra's knee pain -- at subsequent visits; you 16· rely on the child patient and the non-doctor parents, 17· correct? 18· · · · · · · ·MR. ANDERSON:· Objection; form. 19· · · A.· ·I just want to clarify that at a sick visit, 20· they are very focused, so we discuss and address what is 21· brought up. 22· · · · · · · ·At well checks -- "How are things 23· going?" -- it is very broad, and if it is brought up, it 24· is discussed. 25· · · Q.· ·(BY MR. BUTTON) So you're going to wait until 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 59 ·1· the well check visit, and at the well check visit, then ·2· you would bring up any complaints and do an overall ·3· system check, correct? ·4· · · A.· ·Yes. ·5· · · Q.· ·Dr. Randles, your sole justification for not ·6· referring Sandra to an ortho is the reliance on the ·7· radiology report, correct? ·8· · · · · · · ·MR. ANDERSON:· Objection; form. ·9· · · A.· ·I guess, could you kind of rephrase or reask 10· that?· I don't -- 11· · · · · · · ·MR. ANDERSON:· I think you're 12· mischaracterizing her previous testimony.· It was -- 13· Russell, it was the X-ray and the lack of her complaint. 14· · · Q.· ·(BY MR. BUTTON) Dr. Randles, the only reason, 15· after November 21st, 2017, that you referred Sandra for 16· an X-ray was because her knee was locking and you had a 17· listing of knee pain, correct? 18· · · A.· ·I referred her for the X-ray because she had -- 19· her complaints were -- I don't want to say more 20· extensive.· They were -- she had complaints.· They seemed 21· a little beyond what I would normally hear for a typical 22· Osgood-Schlatters; therefore, I referred her for the 23· X-ray. 24· · · Q.· ·Sandra, according to you, Dr. Randles, on 25· November 21st, 2017, presented with a list of symptoms 800.211.DEPO (3376) EsquireSolutions.com YVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 60 ·1· that was more than what you would typically hear for an ·2· Osgood-Schlatters diagnosis, correct? ·3· · · A.· ·Yes. ·4· · · Q.· ·And one of those key factors was the knee ·5· locking, correct? ·6· · · A.· ·One of the symptoms was knee locking that she ·7· complained of. ·8· · · Q.· ·And the other symptoms were also more ·9· significant than what you would typically hear for 10· Osgood-Schlatters, correct? 11· · · · · · · ·MR. ANDERSON:· Objection; form. 12· · · A.· ·I would need to look at the note.· She says she 13· had pain with activity.· That is typical, so -- 14· · · Q.· ·(BY MR. BUTTON) And you referred her to an 15· X-ray, correct? 16· · · A.· ·Yes, I ordered an X-ray. 17· · · Q.· ·And when you got that report back, you chose, at 18· that point, to not refer her out to an ortho, correct? 19· · · A.· ·Yes, sir, because the X-ray was read as normal. 20· · · Q.· ·So the decision to not refer Sandra to an ortho 21· for a second opinion or a specialist evaluation was 22· because you got back a normal X-ray after your first 23· visit with her, correct? 24· · · A.· ·Yes, and that I never heard back that they 25· weren't doing better. 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 61 ·1· · · · · · · ·MR. BUTTON:· Peter, we can go ahead and ·2· take a break right now. ·3· · · · · · · ·MR. ANDERSON:· Okay.· Yeah, let's do that. ·4· · · · · · · ·THE REPORTER:· Okay.· If you'll take us off ·5· the record, Ms. Arefi. ·6· · · · · · · ·THE VIDEOGRAPHER:· We are now going off the ·7· record.· The time is now 11:20 a.m. ·8· · · · · · · ·(Break taken at 11:20 a.m.) ·9· · · · · · · ·(Back on the record at 11:36 a.m.) 10· · · · · · · ·THE VIDEOGRAPHER:· We are now back on the 11· record.· The time is 11:36 a.m. 12· · · Q.· ·(BY MR. BUTTON) Ms. Randles, are you ready to 13· get going? 14· · · A.· ·I am.· Thank you. 15· · · Q.· ·Dr. Randles, just before we left, you were -- we 16· had talked about some of these records, and one of them 17· was the -- was well-child physicals.· Do you remember 18· that? 19· · · A.· ·Yes, sir. 20· · · Q.· ·In 2018, July of 2018, you actually did a 21· well-child physical for Sandra.· Do you remember that? 22· · · A.· ·Yes, sir. 23· · · Q.· ·And you did them for some other years in 2014, 24· 2015, up through there, correct? 25· · · A.· ·Yes, sir. 800.211.DEPO (3376) EsquireSolutions.comYVer1f  NORAH K RANDLES, M.D. VOLUME I March 18, 2021 JOHN vs TOUCHSTONE MEDICAL IMAGING 62 ·1· · · Q.· ·And in all of your medical records from ·2· November 21st, 2017, when you first saw Sandra for her ·3· knee pain, it's your