19 		TANYA CROSSMAN
	20 	after having been duly sworn to tell the truth, the whole
	21 	truth, and nothing but the truth, testified as follows:
	22 		DIRECT EXAMINATION
	23 			THE COURT: Go ahead.
	24 	BY MR. CORGAN:
	25 	Q	Would you state your name, please.


220
	1	A	Tanya Crossman.
	2	Q	Miss Crossman, are you employed?
	3	A	Yes.
	4	Q	Would you tell us what your employment is?
	5	A	I work at Jane Phillips Hospital emergency room.
	6	Q	And do you have any specific duties or
	7	responsibilities there as. an employee in the emergency
	8	room?
	9	A	I'm a unit secretary.
	10	Q	And as unit secretary, what are your
	11	responsibilities?
	12	A	I do everything but hands-on treatment of the
	13	patients.
	14	Q	Can you kind of give me some examples of what you
	15	mean when you say "everything but hands-on treatment"?
	16	A	I take care of the patients when they first come in.
	17	I'm the first one to see them. Family, I check them in,
	18	make the charts. I order all the lab, the X-rays.
	19	0	What is involved in checking -- you say you check
	20	families in?
	21	A	Well, I deal with the family. I usually get my
	22	information from a family member, not the patient.
	23	Q	And for obvious reasons, right?
	24	A	Yeah.
	25	Q	How long have you been employed there?


DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


221
	1	A	Ten years.
	2	Q	What kind of training or experience do you have for 
	3	your job?
	4	A	I had to go to school for it.
	5	Q	And where did you go?
	6	A	Tri County Tech.
	7	Q	And as a result of that, did you receive a diploma or
	8	certification or --
	9	A	Yes.
	10	Q	-- something?
	11	A	Yes.
	12	Q	And what did you receive?
	13	A	I was certified.
	14	Q	And what are you certified as?
	15	A	A medical secretary.
	16	Q	And is there anything more specific than that?
	17	A	No.
	18	Q	In your certification as a medical secretary, did you
	19	have any particularized training in regard to emergency
	20	 room and those type things?
	21	A	As far as the emergency room goes, no.
	22	Q	And during the time that you've been employed at the
	23	Jane Phillips Hospital as a medical secretary, have you
	24	spent all that time in the emergency room?
	25	A	Eight years of it.
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


222
	1	Q	Where did you spend the other two?	
	2	A	On the third floor on the cancer floor.
	3	Q	So was that the first two years?
	4	A	Uh-huh.
	5	Q	The first two years, you were on the cancer floor;
	6	and the last eight have been in the emergency room.
	7	A	Yes.
	8 	Q	And I guess from what you told us that you were
	9	employed in the emergency room as a medical secretary on
	10	June the 11th of 1990.
	11	A	Yes.
	12	Q	And did you have occasion to work that day?
	13	A	Yes, I did.
	14	Q	Pardon me?
	15	A	Yes, I did.
	16	Q	What were your hours of duty on that day?
	17	A	I worked 3:00 to 11:00 at the time.
	18	Q	Would that be a.m. or p.m.
	19	A	P.M.
	20 	Q	3:00 p.m. to 11:00 p.m.?
	21 	A	Uh-huh.
	22	Q	Okay. Did you as a result of that have occasion to
	23	have contact in regard to the case that's before the Court
	24	and the jury today?
	25	A	Yes, I did.
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


223
	1	Q	Tell us how you became involved in this case.
	2	A	I was the first one at the door to meet Mr. Allen
	3	when he came in.
	4	Q	Can you tell us about what time he arrived?
	5	A	It was sometime after 10:00.
	6	Q	When he -- where did he come in?
	7	A	He came through the emergency room doors.
	8	Q	And what did you see or observe as he came through
	9	those doors?
	10	A	I saw a man approaching my desk covered in blood, and
	11	he had his face in a towel.
	12	Q	After you saw this man, what did you do?
	13	A	I went to him, asked him if his wife was in the back.
	14	And he said, yes, that was his wife.
	15	Q	Did you ask anything else of him at that time?
	16	A	No. He did ask me if she was talking.
	17	Q	Now, tell me, please, ma'am, his exact words to you.
	18	A	He said is she talking. -
	19	Q	And what did you say?
	20	A	I said I couldn't answer that.
	21	Q	Now, when he said that to you, did you have any
	22	problem understanding what he was saying to you?
	23	A	No, I didn't.
	24 	Q	After you made your response to him, what did you do
	25	then?
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


224
	1	A	Well, he asked me if she was still alive; and I told
	2	him that he'd have to wait and talk to the doctor.
	3		And I took him back in what we've got, as we
	4	call it, grieving room where we take our families in a
	5	situation like that and asked him the initial questions I
	6	needed to ask to make a chart.
	7	Q	What type questions did you need to ask as far as
	8	preparing your chart?
	9	A	Her name, date of birth.
	10	Q	Did you go through that list with Mr. Allen?
	11	A	Yes, I did.
	12	Q	And was he able to respond to those questions?
	13	A	Yes, he was.
	14	Q	Was able to give you the name?
	15	A	Yes.
	16	Q	Able to give you the date of birth?
	17	A	Yes.
	18	Q	What other type information did you request?
	19	A	I asked if there was any family that we could contact
	20	for him so he wouldn't have to be alone. And he said, no,
	21	that they all lived out of state.
	22	Q	How long would you say that it took you to complete
	23	this information for your chart?
	24	A	Just a few minutes.
	25	Q	During that time, did he appear to be responsive to
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT



225

	1	your questioning?
	2	A	Yes, he did.
	3	Q	After you had completed the information for the
	4	chart, what did you do then?
	5	A	I went out front, made my chart, and then went back
	6	in to check on him.
	7	Q	Now, when you went back to check on him, what, if
	8	any, observations did you make?
	9	A	He was just sitting there.
	10	Q	Did you talk to him at that time?
	11	A	No, not really.
	12	Q	What did you do then?
	13	A	I went back out to my desk. We were real busy, and I
	14	had other things to do.
	15	Q	Did you have occasion to observe his emotional state
	16	that night?
	17	A	Yeah, as he came through the door and then when I was
	18	back asking the questions that I needed answered.
	19	Q	What observations did you make as you came through
	20	the door?
	21	A	He seemed to be weeping into this towel that he had
	22	in his hands; but when he looked at me and answered
	23	questions, he was straight-faced. I saw no tears.
	24	Q	And that would be the observation that you made later
	25	in the grieving room as you got the information?
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


226
	1	A	Yes.
	2	Q	What, if any, other observations did you make?
	3	A	Just that he was covered in blood.
	4	Q	What do you mean by that?
	5	A	He looked like he had been splattered. It was -- I
	6	don't know -- from his face all the way down to his tennis
	7	shoes.
	8	Q	Do you recall what type clothing he had on?
	9	A	He had on a T-shirt that had the name of a church on
	10	the front of it, a pair of shorts, and some tennis shoes.
	11	Q	Other than the clothing, was there blood on any other
	12	portions of his body?
	13	A	He had it on his face and hands.
	14	Q	Do you recall if he had any type of eye wear on?
	15	A	I believe he was wearing glasses.
	16	Q	And do you know or recall if you made observations
	17	about the glasses?
	18	A	No.
	19	Q	Did you have any further contact with Mr. Allen that
	20	evening?
	21	A	Later when the doctor went back into the room to tell
	22	him that his wife did not make it, I went with him.
	23		And he was -- he asked the doctor when the
	24	doctor came into the room if she had made it. And the
	25	doctor said, no, I'm sorry. And the preacher was in the
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


227
	1	room with him at the time.
	2	Q	Do you know who that preacher was?
	3	A	Just from his church.
	4	Q	You didn't know the man?
	5	A	No.
	6	Q	Did you know Mr. Allen at that time?
	7	A	No. I'd never seen him before.
	8	Q	How did you, how did you come to know then the person
	9	you were talking to that evening as Mr. Allen?
	10	A	Because he'd identified himself (sic), and he signed
	11	permission for treatment for his wife.
	12	Q	Do you recall how that was signed?
	13	A	No.
	14	Q	Okay. Apparently, you had no problem feeling that
	15	that was the lady's husband.
	16	A	Right.
	17	Q	Now, when the doctor -- did you say that the doctor
	18	asked you to accompany him when the doctor went into the
	19	grieving room to give Mr. Allen the news?
	20	A	He didn't ask me. It's just that everybody else was
	21	tied up, so I went back with him.
	22	Q	Who was the doctor?
	23	A	Dr. Abatso.
	24	Q	And what, if any, observations did you make about Mr.
	25	Allen when he was given this news by the doctor?
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


228
	1	A	Well, when he asked if she was still alive, he was
	2	pretty straight-faced. There was no tears.
	3		And he did starting weeping or sobbing into, you
	4	know -- he had his pastor and started sobbing. But I
	5	never saw tears.
	6	Q	You didn't see tears at that time?
	7	A	No.
	8	Q	Now, after that, did you have any further contact
	9	with Mr. Allen?
	10	A	No, I didn't.
	11			MR. CORGAN: I believe that's all.
	12	-----------------------------------------------------
	13			CROSS-EXAMINATION
	14	BY MR. CARLSON:
	15	Q	Miss Crossman, we do know, and from your experience
	16	at the emergency room as a unit secretary and dealing with
	17	people, we do know that certain people will sob and cry
	18	and, yet, not show tears; isn't that true?
	19	A	It's possible.
	20	Q	You've seen that happen; isn't that true?
	21	A	Yes.
	22	Q	Now, you've seen that happen even when people are
	23	genuinely emotionally upset; isn't that true?
	24	A	Yes.
	25	Q	Now, you stated that when the doctor walked in the
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


229
	1	room to tell him that his wife had not survived --
	2	A	Uh-huh.
	3	Q -- and after he was told that and he turned to his
	4	pastor and his pastor and him hugged each other, didn't
	5	they?
	6	A	Yes.
	7	Q	And he began to cry at that point, didn't he?
	8	A	He was sobbing.
	9	Q	Now, at one point, Steve wanted to know is Sandra
	10	alive, didn't he ?
	11	A	He asked if she was talking.
	12	Q	But from your experience, it's not unusual for
	13	someone in an emergency room to say and to ask is my
	14	child, my wife, my husband, are they conscious. You've
	15	seen that happen.
	16	A	They've asked if she's conscious, but this is the
	17	first time I've ever had somebody ask me if she was
	18	still -- if she was talking.
	19	Q	Would you agree with me by the same token that it
	20	wouldn't be unusual for someone to say is she talking?
	21			MR. CORGAN: Your Honor, I think it's been
	22	asked and answered and calls for speculation on the part
	23	of the witness.
	24 			MR. CARLSON: It'll be clear in a minute,
	25	Your Honor. Bear with me.
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT



230

	1			THE COURT: You can repeat it. I think she
	2	answered it, but go ahead.
	3	A	I've never had anyone ask me that before.
	4	Q (By Mr. Carlson) Well, I understand that; but, in
	5	your opinion, it would not be unusual for someone to ask
	6	that is she talking.
	7			MR. COROAN: Again, Your Honor, I think
	8	she's answered that.
	9			THE COURT: You may answer.
	10	A	I don't know how else to answer it.
	11	Q (By Mr. Carlson) I'm sorry?
	12	A	I wouldn't know how else to answer that.
	13	Q	Let me ask you, ma'am, did you testify at a
	14	preliminary hearing in this particular matter?
	15	A	Yes.
	16	Q	And let me hand you a copy of your testimony at the
	17	preliminary hearing which was held back on March the 25th
	18	 and 26th. -
	19		And I want to direct your attention to page 228
	20	of your preliminary hearing testimony and ask you to read
	21	at page (sic) 18, 19, and 20 for me please.
	22		Or let me do it this way. I will read the
	24		QUESTION: By the same token, it wouldn't
	25	be unusual for you or somebody to say is
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


231
	1		she talking, would it?
	2	And your answer was:
	3		No, I guess not.
	4	A	Correct.
	5	Q	And do you recall giving that testimony back in March
	6	at preliminary hearing in this matter?
	7	A	Yes, I do.
	8	Q	And you agree with that, no, it's not -- wouldn't be
	9	unusual.
	10	A (The witness shook her head from side to side).
	11	Q	Don't you?
	12	A	Yeah.
	13	Q	Okay. Thank you, ma'am. And, as a matter of fact,
	14	that is another way of expressing, from your background,
	15	is she conscious.
	16	A	It could be.
	17	Q	Now, there's nothing about the fact that Steve could
	18	give general information in regard to Sandra with regard
	19	to her birth date, with regard to personal information,
	20	there's nothing about that, that you thought was unusual
	21	or strange, did you, Miss Crossman?
	22	A	Not at the time, no.
	23	Q	You've seen people go into a number of different
	24	ways. You've seen people show shock there at the
	25	emergency room, haven't you, Miss Crossman?
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


232
	1	A	Yes.
	2	Q	And a lot of people who are in shock in the emergency
	3	room from your experience are somewhat stoic, are they
	4	not?
	5	A	They can be.
	6	Q	And some people when they're in shock like that would
	7	be somewhat poker-faced. Wouldn't you agree with that?
	8	A	They can be.
	9	Q	How long have you worked there in the emergency room?
	10	A	Eight years.
	11	Q	And has all your time been as a unit secretary?
	12	A	Yes.
	13	Q	Did you have occasion to give us -- be interviewed in
	14	this matter by Mr. Mason?
	15	A	Yes, I did.
	16	Q	And if Mr. Mason were to report in one of his reports
	17	that Steve wanted to go back and see Sandra, would you
	18	agree with that -- Steve asking to go back and see Sandra?
	19	A	When he first came in. I told him he couldn't.
	20	Q	But that was the very first thing he asked, wasn't
	21	it?
	22	A	No.
	23	Q	Well, he asked that right after he asked is she
	24	talking.
	25	A	Yes.
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT



233
	1	Q	He said can I go back and see her.
	2	A	He said can I go back; and I said, no, you need to
	3	come back here with me and sit down.
	4	Q	Thank you, ma'am.
	5			MR. CARLSON: That's all we have.
	6			THE COURT: Any redirect?
	7	---------------------------------------------------
	8			REDIRECT EXAMINATION
	9	BY MR. CORGAN: -
	10	Q	Miss Crossman, you said something on
	11	cross-examination about the fact that Mr. Allen could give
	12	you a name and date of birth and those things that didn't
	13	seem strange to you at the time. Is that what you said?
	14			MR. CARLSON: Objection.
	15	A	Yes.
	16			MR. CARLSON: Leading, Your Honor.
	17			THE COURT: Overruled. Go ahead.
	18	Q (By Mr. Corgan) What did you mean by that?
	19	A	 When I get real busy and there's other things going
	20	on, I try and get my information as fast as possible.
	21		And I really didn't think about it at the
	22	time -- his reactions.
	23		A lot of times when I deal with families in
	24	situations like this, I hardly ever get my information
	25	because they're just -- they're real upset. And they get
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT



234
	1	mad at me for even wanting to come in and ask questions.
	2	Q	Did you find that to be the case in this instance?
	3	A	No.
	4	Q	And how was it different?
	5			MR. CARLSON: Objection. Asked and
	6	answered, Judge.
	7			THE COURT: You may answer.
	8	A	He didn't seem to have any problems.
	9			MR. CORGAN: That's all.
	10	Q (By Mr. Corgan) Thank you, ma'am.
	11	-----------------------------------------------
	12			RECROSS -EXAMINATION
	13	BY MR. CARLSON:
	14	Q	Would you agree with me Mrs. Crossman that different
	15	people will handle that kind of stress, that kind of
	16	emotional trauma in different ways?	
	17	A	Yes.
	18	Q	As a matter of fact, from your experience having
	19	worked out there, there's no way to predict how some
	20	person's going to handle that, is there?
	21	A	That's true.
	22	Q	We all are different, aren't we?
	23	A	Yes.
	24			MR. CARLSON: Thank you.
	25			THE COURT: Thank you, ma'am.
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


235
	1			MR. CORGAN: Your Honor, I believe -- if we
	2	might address the matter, I believe Miss Crossman has some
	3	vacation scheduled and wants to leave the state. Might
	4	she be finally excused?
	5			MR. CARLSON: Your Honor, we don't have any
	6	problem with Mrs. Crossman leaving on her vacation out of
	7	state if she'll just give us a phone number of where she
	8	is.
	9		If we need to bring her back, we'll pay her to
	10	bring her back if that needs to be done.
	11		At this time, I don't see that need; but we
	12	would like, since there's a lot to go in the case, we
	13	would like to let her go ahead and go on her vacation if
	14	she could just be where we can possibly reach her by phone
	15	at some point. Is that possible?
	16			THE COURT: Can you do that?
	17			THE WITNESS: Yeah.
	18			THE COURT: Thank you.
	19			MR. CARLSON: Thank you.
	20			MR. CORGAN: Miss Crossman, if you'll leave
	21	that number with my office, I'll make sure that Mr.
	22	Carlson gets it.
	23			THE WITNESS: Okay.
	24			THE COURT: Next witness.
	25			MR. CORGAN: Your Honor, the State would
DISTRICT COURT OF OKLAHOMA
OFFICIAL TRANSCRIPT


 

lh1998-99, 2000