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
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