[Music] all right the criminal district court of Lavery County is now in session the Honorable Lana Meyers reside [Music] please be seated good evening and welcome to the final round of the state high school mock trial competition I'll now call the case the state of tekzilla' versus Avery Jackson and before we get started please make sure that your cell phone is either in the opposition or on silent we don't want any disruptions during the trial and so with that all right if you would please introduce yourselves representing the state of Texas please introduce yourselves good evening your honor your state of take some excuse me the prosecution along with co-counsel Darby Daniel and Nina return we are witnesses introduce themselves yes good evening your honor my name is Gabriella Newkirk and I will be portraying the role of Dana Scully good evening your honor my name is Enoch Gardner and I'll be portraying the role of Arizona Robbins okay good you think your honor my name is Kaden Cameron and I portraying the role of Lady Parrish thank you the defense would please introduce yourselves and your witnesses good evening your honor members of the jury my name is Grace Rochester and today I will be conducting the direct examination of Addison Montgomery the cross-examination of Dana Scully as well as delivering the closing argument good evening your honor members of the jury my name is Jane Adama and today I will be conducting the direct examination of Avery Johnson and the cross-examination of Arizona logixx good evening your honor members of the jury my name is Charlie stock and today we'll be conducting the direct examination of nurse Alex Karev the cross-examination of Layne Parish as well as delivering today's opening statement and our witnesses your honor yes good evening your honor members of the jury my name is Mike Rutherford and today I'll be portraying Avery Jackson good evening your honor members of the jury my name is Kathleen McNeil and today I will be portraying Alex Karev good evening your honor members of the jury my name is Ryan Guerin and today I will be portraying dr. Addison Montgomery thank you in a few kids remain standing have all the witnesses stand please and I'll swear all of you in at once please raise your right hand do you and each of you promise that the testimony you are about to give will faithfully and truthfully conform to the facts and rules of the Texas high school mock trial competition thank you please be seated is the state ready to present your opening statement yes but first your honor the party should have some housekeeping matters to attend to maybe a visa yes first may we move about the world for opening and closing statements you men and maybe move about the welfare cross and direct examination you men and what is your preference on approaching witnesses as to approach the witness make your out for doing so and without we're ready to proceed thank you your honor the defense also has some pretrial matters to attend to go ahead we ask for the same courtesies as prosecution has been given yes and your honor defense has prepared a binder full of stipulation case statements and the rules of competition if your honor with so life sure thank you Your Honor the defense has also created a binder full of all the exhibits if you would like that now or we can give you a courtesy copy as they are entered individually you can just give me a courtesy copy when they're introduced yes your honor and with that the defense is present and ready to proceed thank you you may proceed with your opening statement I'm trying to get this microphone on him that I'll be ready to proceed may it please the court opposing counsel members of the jury god knows what would happen to the patients here this was a statement made by the defendant Avery Jackson now we're all used to hearing about doctors playing God taking patient's lives into their own hands but on April 1st 2017 Avery Jackson tried to play God that night he hacked into Texoma General Hospital's online medical records system he shut down the system the hospital relied on demanding he received $150,000 and if they didn't pay he threatened to delete the records permanently you'll hear that Avery Jackson did this knowing it would put patients in danger and he was right the day of the hack Mulder Scully a 75 year old man simply got a cut on his left hand his daughter Dana Scully took him to the hospital where she thought he'd been well care be well cared for a simple cut they went to the hospital thinking this would be a simple fix that he'd be right back to working in the garden where he got his injury in the first place which should have been a simple fix turned into a nightmare for Mulder Scully and he's an entire family his nurse Alex Karev began the patient's treatment when he input his medical history the next day Avery Jackson had hacked the system and all medical records were locked Mulder Scully's hand was causing him pain so doctor Arizona Robbins prescribed to eliminate him and medication but because the PMT system was down they didn't know Mulder Scully's allergies and a medication he was allergic to was administered this caused an allergic reaction but because the PMT system was down even trained medical professionals could this reaction without the PMT this allergic reaction led to anaphylactic shock cardiac arrest and finally his death today you'll hear that ain't the PMT system had been up this would have been a simple fix nurse Alex Karev would have opened his knee pad to find Mulder Scully's allergies and even if the drug that the patient was allergic to still would have been administered hospital staff could have input his allergic reaction symptoms into the PMT recognized the reaction and treated it you'll hear today that if the PMT system had been up Mulder Scully would still be alive the hack of the PMT system began months ago when Avery Jackson was still an employee at Texoma General Hospital the hospital implemented the PMT system intending to help the patients but instead Avery Jackson exploited it Avery Jackson while he was an employee fought to get rid of the no pay ransom policy the hospital adopted while he was still working at T gh he made sure the hospital was willing to pay the ransom a hacker asked for and when he was fired he hacked the system and asked for that very ransom ask yourselves what's a life worth to Avery Jackson a life was worth $150,000 and the chance to prove he was right he turned a warning into a threat and a threat into an action hacking the hospital shutting down its system and leaving the patients helpless until he received his ransom we as a prosecution carried the burden of proof in today's case proof beyond a reasonable doubt we must prove to each and every one of you that Avery Jackson's hack is the proximate cause of molars Foley's death we gladly accept this burden and believe that their witness testimony and evidence you all will see that the hospital was in chaos due to Avery Jackson's actions we're here told Avery Jackson accountable for the life he took in the future he took away Mulder Scully will never be able to grow old with his wife he'll never be able to see his grandkids walk across the stage at graduation Avery Jackson took that future away from him and he's not above the consequences at the end of today's trial find a verdict of justice for Mulder Scully's family fine Avery Jackson guilty thank you is the defense ready to proceed with your opening statement yes your honor may it please the court your honor opposing counsel members of the jury my client is a happy but he's not a killer he did not cause the death of Mulder's stole opposing counsel told you Mulder Scully Scully's injuries should have been a simple fix they're right it should but it wasn't because of the actions of the Texoma General Hospital if it wasn't for the mistakes that the hospital made Mulder Scully would still be alive today and now to shift the blame from their own mistakes they have accused my client every Jackson's a hacker member peterey he hacked the hospital but he's no killer my name is Charlie stock and I along with my co-counsel grace Rochester and Jada Naha represent the defendant Avery Jackson who you will hear from today and he will tell you that he was an employee at the Texoma General Hospital and he worked in their computer and Technology Group it was there he learned of the PMT the paperless medical technology a massive and expensive digital system that allowed doctors and nurses in the hospital could view attack patient records now you will hear today that prior to the systems implementation every Jackson was able to discover some serious security flaws so to address his concerns he went to his boss Lane Parrish but instead of being praised he was ignored not to be deterred in understanding the seriousness of the flaws he found inside the PMT system he wrote to the chairman of the board of directors but again he was ignored this time being fired Avery Jackson knew he had to fix the system but no one would listen to him he knew he had discovered was too important to be ignored so to force the hospital to confront the dangers of their system he decided to expose the very vulnerabilities of which he had repeatedly warned the hospital he hacked into the system and locked access to patient records however at that time my client was very well aware of section 4.2 of the hospital's policies and procedures because of that he knew in cases of emergency involving patient records the hospital board was authorized to protect patient safety they were supposed to put patients lives over money but they didn't and as a result one of their patients Mulder Scully is dead now the prosecution has the burden of proof in today's case it's their job to prove to you all of the elements of today's case beyond a reasonable doubt now beyond a reasonable doubt is the highest burden in our legal system it's a higher burden than the rest needed to take your children from you members of the jury the law says you have to be more certain than that to convict my client and they have to prove to you beyond a reasonable doubt two elements in particular the first that Avery Jackson consciously disregarded a substantial and unjustifiable risk of patient safety and the second that Mulder Scully's death would not have occurred but for Avery Jackson's actions and they will not be able to meet that burden the evidence will simply not allow it because you will hear that the dismissal of my clients war to fix the system was just the beginning of the hospital's incompetence and Alex Karev Mulder Scully's nurse whom we would call will tell you about the hospital's incompetence she will tell you that she and Mulder studies doctor doctor Arizona Robbins were warned that Mulder Scully was allergic to a specific type of drug but they gave him that drug anyway and it killed him you will hear that motor Scully's doctor would have prescribed that deadly medication even with access to the medical records now you will also hear from renowned medical expert Addison Montgomery today who will tell you that dr. Robbins should have been able to save Mulder Scully but failed not because of the PMT but because she forgot how to do her job she forgot how to be a doctor the Texoma General Hospital is entrusted to treat and care for their patients and members the jury they violated that their mistakes their actions were sufficient to cause the death regardless of my clients actions and because my clients actions were insufficient to cause to death you will not be able to find him criminally responsible so at the end of trial today my co-counsel grace Rochester will come before you and ask you to return a verdict of not guilty don't allow the prosecution distract you from the mistakes the hospital made don't allow them to shift the hospital's blame on to Avery Jackson he's a hacker members the jury but he's not killer thank you car your first witness the prosecution calls Dana Scully to the stand good evening can you turn to the jury and introduce yourself I'm Dana Scully and I don't have any allergies just just so everyone knows kids on the court a little bit about yourself well I live in Texas omma City with my spouse and two children at the age of 16 I quit my one and only job to pursue veganism full-time let's talk about the reason here that you're here today can you tell the jury a little bit about your father yeah my dad and I were really close and he was always fairly healthy but when I introduced him to veganism he took a turn for the better you know veganism gets a really bad rep but in my dad's case it really was beneficial can you tell us a little bit more about him yeah he and my mom were big on gardening they love their flowers that's actually what sent him to the hospital in the first place how did you first find out about your father's injury on April 1st I went over to my parents house to check up on them and check up on my dad and make sure that there was no dairy in the house when I got there he had this big gash on his hand and blood I at the sight of blood I I just I can't handle blood well so I took him to Texoma General Hospital what happened when you arrived at the hospital a nurse had my father admitted and came into the room to get him situated can you tell us what happened after your father was admitted to tech so my General Hospital yes the nurse did it Haskell my father a bunch of questions including any allergies he had so my father mentioned that he was allergic to penicillin is penicillin your father's only allergy no my father was a bit out of it he had just been rushed to the hospital with his big gash and so it slipped his mind that he was also allergic to naproxen so I made sure to let him know how did the nurse record your father's information the nurse put everything into a me pad and then put a bright red wristband answerest would you recognize the photo of the source pand if i were to show it to you yes I would your honor our permission to approach the way these four things a bit one you may counsel your honor would you like your copy I have one thank you basically what have I just handed to you this is the photo photo of the bright red wristband they put on my dad's wrist it Texoma General Hospital is this a fair and accurate representation yes it is how many apparent changes been made no your honor at this time we offer exhibit one it's evidence any objection no Jackson all right the exhibit is admitted miss Coley can you show this photo to the jury and read it aloud for the court sure Your Honor may i reposition myself so that you may it says allergy in big bold letters anywhere on this wristband or your father's allergies mentioned no to your knowledge was there anywhere besides the knee pad that your nurse recorded your father's allergies no not to my knowledge Thank You mrs. Scully miss Scully what happened when nurse Kraft finished recording your father's information well she left the room and dr. Arizona Robbins came in to further examine my dad's hand how did the doctor proceed the doctor first ordered some hydrocodone and a painkiller and then a scan a CT scan after that the doctor doctor recommended that my father's stay overnight for observation after the doctor recommended that he stay overnight did you stay with your father I stayed with him for a little while but I had to get home I have a family to get to and I had to update my blog on veganism a healthy chickpea what time did you return the next morning on April 2nd I returned around 9 a.m. now in the morning of April 2nd how did your father appear to you he wasn't doing good at he had a lavender aura that morning did any of the nurses or doctors check on your father not while I was there actually all the doctors and nurses that I saw seemed to be running around all frazzled how long did you stay with your father that morning I stayed with him for a while but I had to leave I had a protest for endangered tadpoles for some reason they keep turning into frogs what time did you return to the hospital later that day I returned with my two children around 5:45 I remember because my daughter was tugging at my sleeve asking what time we'd get to go see grandpa upon arriving at the hospital that evening what did you see the body language of everyone that I saw at the hospital was off the energy of the hospital was it was suffocating miss Hawaii do you need to take a moment no no I'm ok I I told my life coach I would stay strong ok please continue he got inside and upstairs to my father's room and I was astonished to find out that my dad had been killed my dad from a cut on his hand I I was furious and confused I should have had more time with him we should have had more time with him and that was stolen from me mr. Cooley I know this must be difficult for you to talk about but can you explain what happened to your father he was administered Bokke tracts ofin which is a derivative of naproxen one of my father's allergies did you learn anything else about your father's death I learned that Avery Jackson hacked the hospital while my father was there how did you respond to your father's death in the months following I was heartbroken I I still AM it was so hard on my family my mother shortly after died of a broken heart I'm sure your honor we've passed the witness cross-examination miss Scully I I'm very sorry for your loss but I do have to ask you a couple questions if that's all right okay now you took your father to Texoma General Hospital on April 1st correct that's correct as you stated nurse Kraft took you back from the intake process right yes and this is where his allergies were made knows with medical stuff correct yes that's correct and your father mentioned penicillin yes but he never mentioned aprox it right no it slipped his mind he didn't write so you had to remind them didn't you I did and you also had to remind them that this allergy had almost killed him once before isn't that right if I recall he's the one who mentioned that but yes so that's a yes that did you almost kill him once before that's a yes and they gave your father a red allergy correct they did your honor my sheep exhibit what you men as you stand on direct examination this is that wristband right yes it is and no one on the first band does it's a penicillin no it doesn't and no one on this wristband does it say naproxen no it just says allergy isn't that correct that's right and mrs. Foley because of the severity of this allergy you decided to write your number on the whiteboard isn't that correct I did and you told them to call that any questions or concerns yes Your Honor may I approach the witness was all has the previously more enticing City to no other record if like I'm tendering to opposing counsel this is the whiteboard in your father's room correct yes it is and it doesn't look changed or altered in any way no it doesn't it's a clear and accurate representation of that whiteboard isn't it yes it is your honor at this time the sense moves to enter exhibit two in evidence any objection no objections your honor the exhibit is submitted fully this is your phone number and the bottom corner correct yes it is and it's written in red pen it is and the rest of the board is written in blue correct yes that's correct and as you previously stated you told the hospital staff to call you if they had any questions or concerns right I did but mrs. : you never received a phone call did you no I didn't and on April 2nd when you got there on 545 that was when you were informed that your father had passed away isn't that correct yes that's correct but dr. Robbins shifted the blame and said that it was the medication that nurse Karev administered isn't that correct yes that's what he said and so you screamed at nurse Karev didn't you I did in a heated moment I didn't know what was up or what was down so I I did I don't yell you were mad at her for what she did or didn't do isn't that right I was and mrs. Cole you blamed the hospital for your father's death don't you initially I did blame the hospital but now after gathering more information right initially you sued the hospital actually didn't you yes I did and you blamed dr. Robbins and nurse Karev isn't that right that's right you were mad at dr. Robbins a nurse Rev for what they did or didn't do isn't that right yes before I had all the information I thought it was their fault but miss Kolling you settled with them prior today's trial isn't that correct that's correct and so mystically now you're shifting the blame to Edwin Jackson isn't that correct yes because with more information I understand that it's Avery Jackson who killed my father but Miss Scully the mistakes that were made by dr. Robbins nurse Kraft aren't raised are they the mistakes that were made wouldn't have been made if the PMT system had been redirecting back to my question those mistakes aren't erased are they no of course not never the question I passed the witness redirect examination yes your honor no mrs. Cooley why did you file a lawsuit against the hospital I filed a lawsuit against the hospital because initially it did seem like their fault naturally anyone would think that and during this investigation this internal investigation in this lawsuit I received more information and understood that it was a pre Jackson's fault that my father died now to your knowledge did the nurse record your father's information anywhere except the PMT not to my knowledge no your honor we passed three cross-examination nobuseri honor and they step down your honor at this time we call your Arizona Robbins good afternoon dr. Robbins can you introduce yourself to the jury howdy I'm Arizona Robbins and I'm currently employed at tekzilla General Hospital I knew that I wanted to go into the medical field after I witnessed my brother and get trampled by a cow actually it was a herd of cows but either way dr. Robbins what's your educational background well I graduated from text-only University with the bachelor in science and biology then went on to Harvard Medical School and started my residency here in text-only universe text-only General Hospital how long have you worked at techsan General Hospital I've heard that takes all in general hospital for around 10 years now and really throughout all these years there have been so many changes what changes have you referring to well the change that stands out the biggest is the PMT system and what was on this PMT system well this is where we stored all the patient information instead of having it on paper and with the PMT in place did you have to write down any information absolutely not the PMT had all of the information with the PMT in place were you obligated to memorize patient information absolutely not this isn't where the p.m. this is what the PMT was for and it was very important was there ever a time when this PMT system was not working yes ma'am when the defendant a rejection hacked into the system and shut it down unfortunately well it was shut down patient Mulder Scully sadly passed away bless his heart dr. Robbins was Mulder's Foley a patient of yours yes ma'am what point did you see him during his treatment well after nurse Karev went through the intake process I answered the room and prescribed 10 milligrams of hydrocodone and a CT scan dr. Robbins would you recognize a picture of his medical chart if I were to show it to you I would Your Honor permission no personal witness with what has been previously marked as a trivet 3 you may take a moment to look it over if you need but once you're finished will you explain to the jury what this exhibit is yes this is Mulder Scully's medical chart this is a fair and accurate representation I would believe so yes have any apparent changes been made not that I can see no your honor at this time we offer exhibit three into evidence any objection no objections your honor the exhibit is admitted dr. Robbins can you hold up this exhibit and show it to the jury briefly explain what was on Mulder Scully's medical chart yes ma'am so as you'll see there's contact information at the top each chart with family members there was the treatment log encounter notes medications and there was a very important spot where you could input patient symptoms and get a suggested diagnosis this is very important Thank You dr. Robbins you can set that exhibit down so before you entered this exhibit you mentioned that you ordered a CT scan what were the results of this CT scan well I showed no structural damage but I did keep the patient overnight just for further observation and the next day did you find this condition the same it was most like mostly the same but I did prescribe medication because he was in pain and there was still swelling and what medications did you prescribe well I prescribe vocal tracks venom penicillin but before this would administered the nurse Alex Karev actually pointed out an allergy wristband and with the PMT down how did you get Mulder's collects allergies well we couldn't look in the PMT system for his allergy so we asked the patient and verbally confirmed his allergies therefore administering the medication he was not allergic to and what medications did you end up prescribing after knowing his allergies yes ma'am this was boko tract opinon your birth Romantics did the patient's condition improve with the two medications well not really about 4 to 5 minutes later Alex Graham called me back into the room and the patient appeared to be having a bad reaction to what I heard dr. Robbins can you clarify what you mean by bad reaction well he had a rash near-space was having trouble breathing and half attention well what do you think was occurring well I had no idea and this couldn't be allergic reaction because we ask the patient what his allergies were and I administered accordingly so if you didn't know what was occurring what did you and nurse crack do well at this time the patient was going into anaphylactic shock and I had to call a code blue and run out of the room very fast to consult another doctor to help my patient well what happened when you were out of the room well sadly the patient unfortunately died bless his heart now dr. Robbins if the PMT system had been up when you were ordering medications would you have seen molar skalise allergies absolutely the PMT system had all the information that I needed and that is what the defendant took away from us if the PMT system had been up could you have treated his allergic reaction yes I could have and dr. Robbins has this PMT system ever gone down before no ma'am this I'd never happened in nurses and doctors are not ready for this and this is what the defendant did to us Your Honor this time it passed the witness cross-examination - yes your honor Mara truth exhibit - three from the witness stand before yes you may dr. Robbins I'd like to ask you a few questions if that's okay with you absolutely now you've been employed at the tgh for some time now correct I have about 10 years you were employed at the TTH before the paperless system was implemented correct yes nine and a half years before no you didn't receive a pamphlet about how to operate that paperless system did you know you didn't receive any training at all on how to operate that paperless system did you know it was quite simple and very effective as long as it was working so that is enough yes you know you know I understand what you're saying and you also believe that this tragedy could have been avoided you the hospital didn't change to that paperless system Duncan I thought the walk we still have the papers yes but the PMT is what we were using and that was taken away redirecting you back to my question you do believe that this tragedy could have been avoided it avoided if the tgh did not transition to that paperless system that's correct you could say that happened that could have happened yes now doctor dr. Robbins you as a doctor it is your job to be familiar with your patients plan of care that's correct yes ma'am Your Honor may I approach the witness of what has been previously entered as Exhibit 2 you may now before I approach you you mentioned on direct examination that you did have to ask mr. Scully to verify his allergies correct at what part in the treatment are you Frankie whatever the records were not available quick yes we did this is mr. scalise plan of care that was on the whiteboard in his room correct that's not correct yes and right next to it and red is Dana Scully's phone number is that right that's true Dana Scalia is actually mr. scalise daughter correct yes ma'am now you could have called Miss Scully and asked her about your patients allergies isn't that right yes ma'am but instead you asked a 75 year old man on pain medication to recall what he was allergic to am I correct in saying that yes we did ask the patient and after asking him you then prescribed Bukit Ruxpin and your brother max that's medication that he said he was not allergic to right you actually know quite a bit about that Fogo medication don't I do you got sent on an all-expense-paid trip to Hawaii to learn about that poco medication right yes man was very nice trip and on that trip you learned about the medical trials right yes and the reactions that were found in patients yes because you learned about that you know of one specific reaction called nerd correct I do and when patients are exhibiting the nerd which is just to clarify nerd is specific to that book on medication correct years and when patients are exhibiting nerd they normally show hypotension correct yes a skin rash yes common common symptoms and trouble breathing like asthma-like symptoms correct yes ma'am now 45 minutes after you had given mr. Scully that boko medication he was actually having hypotension wasn't he yes ma'am he was he was having a skin rash yes ma'am and trouble breathing correct yes ma'am but you didn't recognize this reaction to be nerd did you not at the time because we had clarified with the patient what is allergies so that isn't know you did not recognize that reaction to be nerd no ma'am and you didn't think that reaction was any type of allergic reaction at all at this point did you know as I said because we ask the patient what his allergies were and I administer accordingly right now you also learned on that ship in Hawaii that when someone is having nerd they don't respond to epinephrine or an EpiPen is that correct that's correct now after mr. Scully was exhibiting those same three symptoms you and the tghe medical staff administered an EpiPen is that correct yes to which mr. Scully did not respond very unfortunately no bless his heart and even at this point you still didn't think he was having nerve did you um no because again we'd ask the patient what his allergies were and you didn't think he was having any sort of allergic reaction at this point no no ma'am now you when this when you got those records back specifically into the three you saw that you had given your patient and then a derivative of a medication - is that correct I did and your patient was still alive at this time wasn't he he was and at this point you still didn't think he was having nerd or any type of religion reaction no ma'am now you've left the room when your patient was going into cardiac arrest am I correct in saying that that's correct I actually ran out of the room to have consult a doctor I had to do this very quickly right and when you were out of the room your patient doc correct unfortunately yes you know you're here today blaming the death of your patient on Avery Jackson I'm a correct in saying that yes and I'm putting the blame on the correct place despite you being the one that described that book of medication yes ma'am I did prescribe the medication that I poco medication is a derivative of a medication that your patient was allergic to correct yes and just to clarify for the jury at the point that you had given that medication you knew that you couldn't see his allergies is that correct yes ma'am and giving that boko medication prescribing a new medication despite not being able to have access to those allergies it wasn't an emergency situation was it not at the time you his life was an in dire need of a new heparin medication was it I'm not at the time but he was having some pain and swelling but you still decided to prescribed a new medication despite not how the access to his allergies is that correct and what we did ask the patient as I've said but yes because the PMT system was down and the defendant hacked it we did not have access to our most important resource and both attracts ofin a medication you still may have prescribed even with access to that PMT I'm correct in saying that oh yes ma'am I want to consider this no further questions your honor I pass the witness redirector yes during molars Feliz treatment why did you not think an allergic reaction was occurring well I attended a conference as we talked about and I was informed that fictions that are allergic to vocal tract spin or naproxen I'll have very low risk of serious allergic reactions and the benefits of vocal tracks have been heavily outweigh the risks if the PMT system had been up would you have seen his allergies when ordering medications oh yes ma'am absolutely and if the PMT system had been up could you have treated his allergic reaction yes ma'am no further questions your honor any read cross-examination briefly your honor dr. Albans with the yes sir no even when that system was up you still weren't able to save your patient is that correct yes ma'am no further questions your honor and Haskell is no witness yes should I sit down and hear another prosecution calls Lane Harrison hi mr. Parrish it's nice to see you again could you turn to the jury and tell us a little bit about your job you sure I'm not much for introductions but my name is Lanie parish I'm 42 and I'm currently employed as the chief information officer in the General Hospital you might even hear me refer to a few times as McDreamy what technology have you worked with actually I have an expression for this woman's a lonely visual needs official that's French for one link which is never enough that's why I also speak Java C HTML I think you get the picture mr. parish can you tell us about your education sure well I graduated with a Bachelors of Science in Computer Engineering and then continued to get a master's degree in cyber security at the same time I was started a mock trial Club and I was hoping there be best witness for a real court like this but that was not the case mr. Parrish you said that you were chief information officer of Texoma General Hospital can you tell us about your responsibilities with this position sure as the chief information officer my job besides medical equipment is to be responsible for basically everything that led them to a wall were you involved with the PMT system yes that was my biggest project at Tacoma General Hospital we got the system from tier X solutions to fit the needs of our Hospital what exactly did the PMC system do well it would do a large amount of things first of all it would suggest medications and treatments for patients it would improve nurse doctor communications considerably it would that basically changed the whole dynamics of the hospital now you said you got the system from tier X solutions were there any issues with the system previously unfortunately there was a hacking of another hospital who used the system the merchant hospital even after paying the ransom four million dollars unfortunately lost all of their records after learning about the hacking of the PMT system at merchant hospital did you change your system at all yes I implemented the no pay a ransom policy this would deter hackers from even beginning to try to gain access to our systems they wouldn't gain anything from doing so would you recognize this no pay ransom policy if I were to show it to you absolutely and our permission to approach exhibit five you may poison council now mr. Parrish take a moment to look us over if you need it and when you're ready can you tell me what I've just handed to you yeah sure yeah this is the new appearance policy is this a fair and accurate representation of that policy they appears to be something have there been any apparent changes made no there we offer this exhibit and evidence any objection no objections your honor now mr. Parrish can you summarize this ransomware policy for us sure without using all the legal mumbo-jumbo it basically says we will not pay ransom if the hospital is hacked however we do reserve the right to supersede the policy if we believe the patients are in danger no mr. Parrish did anybody advocate against the PMT system yes Avery Jackson one of the newer employees that I hired did not like the system and he sent an email to the Board of Directors expressing his complaints breaking are very strict chain of command rule that was unfortunate that means Linum goes he was a very talented employee mr. Parrish would you recognize this email chain if I were to show it to you yes I know permission to approach with exhibit seven okay once again take a moment if you need and what if I just handed you this is the email thread which started with Avery Jackson sending an email supporting is this a fair and accurate representation of that email fair yes it appears pieces have been there been any apparent changes made no ma'am don't we offer exhibit seven in evidence any objection no objections your honor the exhibit is submitted can you tell us about the email that Avery Jackson sent sure there's a few lines that really stick out to me first is where is it here it is I have analyzed the Solomon package provided by our outside vendor in a past Jurassic security floss that will put the hospital serious risk of being hacked and then later on it says this other really interesting thing there is could crack into our system and then God knows what would happen to the patients here was there anything else that Avery Jackson the defendant warned about well he told us that the PMT system was vulnerable to attacks and more specifically that an attack on the system could one lead to issues with patient treatment and to put the patients in explicit danger now Easter pairs I want to clarify did Avery talks of Jackson warned about what kind of hack could lead to these problems no ma'am he just said that an attack on the system would put the patients in danger okay mr. parish let's talk about the day of the hack April first how did the hack start well I was going through my email and I found to the email from Avery Jackson posing as the homeowners association the email contained information about a snake sighting in my neighborhood and attached to that that email was a picture of a snake and I learned later that if you click on the picture of the snake it wouldn't still malicious software when you first receive this email I mean did it seem suspicious to you no I receive homeowners association emails quite frequently and did you open this thing though of course I did I actually have snakes my own I was scared my coral snake a little Jordan Humphrey escaped from the back gate again no mr. Parrish what happened after you opened this email well a countdown appeared on the screen and message that said that our records had been locked and demanded $150,000 ransom I jumped on my computer to find sure enough that system was accessible so you said the PMT system was hacked then it was made inaccessible what exactly does this mean what means the entirety of the PMT system was locked and encrypted and we could no longer see it the intake process could was slowed down considerably and decreased nurse doctor communication as the nurses would input information on their and the doctors would read it and then prescribe treatments however this was inaccessible I just like to clarify were the medical records available on the PMT system yes they were was this the only place that they were available yes they were okay so after you realize that the PMT system was shut down what did you do well I emailed the board of directors to let them know the situation and then I got my team working on analyzing and attempting to disable the program and gain access to her files again after your team had worked to rate regain these files were you able to unfortunately not the encryption level was far beyond anything I had seen and my team was unable to dissolve the hack so after he realized that you know there was no way for your team to regain these files what did you do well we worked a little longer until the board called us and let us know that we should go ahead and just pay the ransom and was this ransom paid yes $150,000 was wired into the account and a message appeared on my screen that said thanks for the cash dr. high-and-mighty not so high and mighty now kind of hurtful from August dr. Hine mighty was was this phrase familiar to you yes this phrase was used explicitly by Avery Jackson to disparage me unfortunately and it was actually used on the email that he did sense of the board of directors okay so let's take a step back you said the PMT system was hacked yes it was well how long was the system shut down for 18 hours mr. Parrish are you familiar with all aspects of the PMT system yes I am are you familiar with its uses yes I am are you familiar with its implementation into patient care yes I am so with your knowledge can you tell us what were the consequences of the PMT system being down for 18 hours unfortunately like I said the the nurse doc communication was drastically reduced the suggested treatments and diagnoses were no longer available it completely changed how the hospital was operated during those 18 hours was this the only place for those resources on the PMT system this was the only copies of allergies patient information medical records everything can you tell us if you know who was responsible for this hacking yes it was Avery Jackson he was sitting right back there and no it's especially chilling to find out as he was the one who warned us of just how dangerous a hacking can be you know they say doctors are the ones that play God but slavery Jackson objection your honor speculation this witness does not know whether Avery Jackson was intending to play God when he sent this ransom the witness is speculating as to Avery Jackson's mindset at the time any response yes your honor this witness is not speculating about the witness or the defendants mindset he's simply saying that his actions were about to play God taking patient's life into his hand taking these records into his own hands overruled let's go back to this question who was responsible for the hacking that shut the PMT system down it was Avery Johnson who locked all of these medical information records allergies and medication and treatments yes thank your honor without we pass this witness cross-examination yes your honor mr. Parrish you had a meeting on February 21st correct yes sir an Avery Jackson was out that meeting right yes but and in that meeting Avery Jackson was very vocal about the vulnerability of your system right yes and about the patient danger yes but you make sure reassure on your system was perfect right yes and we did contact here at solutions and they assured us that the system was fine I mean you reassured in that patient safety would never be put at risk correct at the time yes that's is what I believe yeah that's what you told him right exactly yes now would like to talk about patient safety you'd say you care about your hospitals patients right absolutely although they're not my patients I'm just the IT guy as everyone else says and the hospital administrators they care about patient safety yes they do are you free to the port of directors yeah yes I believe they did you'd certainly agree with me that patient safety should be far more important than money shouldn't it oh well it is so yes but for you and your hospital ward patient safety wasn't more important than money was it objection your honor does speculation I would ask that opposing counsel would only ask this witness to testify to his beliefs and not that of the hospital as well Your Honor I can rephrase my question all right rephrase for you lay barish who had contact with the hospital board patients safety wasn't more important than money wasn't that is incorrect well I'd like to talk about that you have a no pay policy that you talked about on direct examination yes and it would prevent things like the merchant Hospital hacking where they paid the ransom and the records were still deleted if you could just focus on that question you have that policy right yes I do I believe it's somewhere up here Your Honor may I approach the witness you may and you were talking about an exception to this policy on direct examination right yes if you don't mind I'm gonna read that exception sure the hospital board may supersede this general policy in cases of emergency involving a complete denial of access to all patient records I've read that correctly right yes you did and you informed every Jackson of that exception in your February 21st meeting right yes I did I mean that's the reason why you told him patients wouldn't be because of that language you could just override the no pay policy right well not just that but yes this was a contributing factor as to why the patient records wouldn't be safe but when you got hacked you did it override the no pay policy immediately did you I unfortunately not know well I'd like to talk about the timeline a little bit you were hacked at 11 o'clock at night right yes and then around 8 hours later you sent an email to the board of directors because you couldn't crack the code right yes we're unable to dissolve the hack yes right that's when you realize the malware was impenetrable correct yes it was but at that point well Your Honor may I approach the witness you may I'd like to refer to the email thread that you've entered under direct examination sure I'm gonna read you your board of directors response to your email all right okay your board of directors said regarding the ransom we are we absolutely are not going to pay that ransom amount I don't care what the virus had done I read that correctly right yes now mr. Parrish after you've got that response you still continue to work on unlocking the records right yes we did but you and the board of directors didn't actually pay a ransom until 18 hours were up like you said on direct examination well after hearing how the merchandise bill paid a million bucks and still did your honor that's sustained the objection you and the hospital board like you said on direct examination waited 18 hours before you paid any rent incorrect yes that is correct and that is 10 hours after you emailed them telling you telling them you could have cracked the code correct yes sir and just to be clear water slowly died at the very end of that 18 hour time frame correct unfortunately yes now you'd say this was a crisis situation well records belong right yes I believe the people downstairs refer this as a code blue and you'd say your number one priority was to get those records back right I'm sure at the time yes but instead of actually unlocking the records yourself or partitioning the board to do so you were actually asleep in your office well those record weren't you that's incorrect if you'd like me elaborate I can no mister no mr. Parrish is it using your testimony dude that you did not take a nap well those records were locked I did not take a nap I passed out from sheer exhaustion and I can elaborate on this further if you'd like me to know you were actually asleep during the time of the records room lock yes or no mr. Parrish yes I was and if again if you'd like me to elaborate I can No thank you mr. Parrish oh that's all right I'd like to actually transition a little bit you are being required to testify today aren't you yes I as a part of the settlement agreement between your hospital and the Scully family yes and you're required to testify on the side of the prosecution against Avery Jackson correct yes sir but mr. Parrish you didn't talk about everyone you believe is that fault on direct examination did you I believe Avery Jackson is at fault mr. Parrish you're aware of Alex Karev correct Mulder Scully's nurse yes I am and you know that Muller stoolies nurse you believe that Mulder's Billy's nerves Alex Karev cut corners correct I share at times and with a yes or no mr. Parrish you believe that had Alex Karev not cut those corners Mulder Scully would still be alive today objection our speculation and improper opinion your honor oh excuse me I'm not asking the witness to speculate I'm asking what he believes asks for an improper opinion again your honor this is what the witness believes it goes directly to causation one of the counts in this case your honor may respond you may just because this is what the witness believes doesn't mean it's one not speculative and not improper opinion this is the IT tech eye of Texoma General Hospital he's not well-versed in treatment or patient care specifically and not enough to assign blame of whether Alex Krebs changing his treatment would have affected Mulder Scalia's death if I may respond I'm not asking this witness to say a definitive answer as to what caused his death just what he believes based on the information he does no I'm not asking to speculate I'll sustain the objection thank you mr. Parrish just to reiterate you spent you and the board spent 10 hours after you told them you couldn't crack the code before you paid any ransom yes or no yes we believe that we could still attempt and try to save these patients all we could no further questions your honor redirect your honor yes now Posey Council discussed how the policy was only overridden because you only cared about money well is that why you override this policy no absolutely not we realized after the ten hours that we weren't able to gain access records entirely before there was a chance that we could and we would fight for every chance that we got so opposing counsel also talks about a crisis situation so let's talk about that was the PMT system shut down yes it was and what was taken away when the system was shut down everything all the-- again the patient records the nurse doctor communications and everything and who was responsible for this hacking that shut everything down every Jackson thank your honor process - in cross-examination yes your honor briefly well mr. Parrish you're familiar with an internal investigation correct yes I am Your Honor may I approach the witness was in civitate Germany Your Honor this is outside the scope of my redirect um if I may respond your honor opposing counsel talked about who this witness believes is at fault this is the information I was talking about earlier in which this witness learned about who he actually believes that it is any response I stand by my objection that this is not within the scope of my redirect I did not bring up an investigation and I never laid any foundation for this investigation even occurring if I may respond this witness did talk about who he believes that false this exhibit will go to counter that Your Honor it is overruled let the record reflect I'm tendering it to a postal counsel do you recognize this yes and this is that internal investigation you're familiar with right yes it doesn't appear to be changed or altered in any way it doesn't look like it now and it's a fair and accurate representation of that in that internal investigation yes sir your honor at this time the defense moves that our exhibit aid into evidence reminding opposing counsel of stipulation six which states that this exhibit is a business record and has been on file with the court for the proper amount of time Your Honor I'm quite aware of the stipulation and I have no objections all right the exhibit is admitted now mr. Parrish based on the information that you learned in that internal investigation you believe that had Alex Karev not cut corners Mulder Scully would still be alive today objection honor I'd like to rephrase my objection from earlier of improper opinion and speculation response responding to that the information that he based his opinion off of is now entered into evidence he has ample proof to show that he is not speculating your arm and as to improper opinion under the same grounds overruled the objection yes sir so I'm going to ask you again based on that information you believe that Alex Karev not cut corners Mulder Scully would still be alive that's what I believed yes no further questions your honor I pass the latest here are made my witness step down it may have published two exhibits of the jury yes he may step down and you may publish the exhibits and your honor without we rest it's the defense ready to call your first witness yes your honor at this time the defense calls or even Johnson to the stand Your Honor may I retrieve exhibit 5 or no I ever see you may good evening please introduce yourself to the ladies and gentlemen of the jury good evening I'm Avery Jackson I'm 24 years old and I lived in Texas Emma for my whole life what are you today I've been charged with manslaughter when I worked at Texoma in general hospital or tgh I had some grave concerns about the new paperless medical technology or PMT to do with you well after completing my research I found that this system was not nearly as secure as it should be I raised some constant concerns to my co-workers but no one seemed to be listening to me so I hacked into the system and sent it a ransomware note to prove my point but now I'm being blamed for a patient's death let's start from the beginning when were you hired to start working at the Texas EMA General Hospital well I'd agree I graduated from SMU pony up in 2016 with a degree in computer science I then got my job with the hospital's so-called computer and Technology Group or CTG why do you refer to them as the so-called computer and Technology Group well because you worked under the blind direction of my boss Lane Parrish see we were a small group of computer information specialists within the hospital however after getting accustomed I began to realize that there were some real slackers when it came to cybersecurity what do you mean by this well in January of 2017 parrish proposed implementing the new paperless medical technology I was given the assignment of finding the necessary software package to bring this about everything sounded pretty easy and doable at first at first yes however after completing my research I found that t-rex solutions the software that Parrish wanted to implement was not nearly as secure as it should be and it was just not up to date did you tell your boss your ex-boss about these security flaws that you found yes I told him that this system was notorious for having major security flaws and when we had the CTG meeting in February I let everyone know including Lane that we'd already had two hospital attacks recent with this software one at a hospital in France the other at a merchant hospital in Cascadia and what happened at those hospitals hackers at both of these hospitals threatened to make all patient records public unless they received a million dollars to your knowledge where any patients harmed that either of those hospitals no not at all not a single patient was harmed at either these attacks and based on what happened at these hospitals I didn't think there would be any risk in my hacking what do you well Lane constantly reassured me that if there was ever a cybersecurity attack to even happen the worst possible thing would be that patient records would be made public I never imagined that anyone would die never this not this so when you brought to light those vulnerabilities you found that any improvements come no this is really important to me so I pushed for more cyber security testing or at least that the system be rolled out on a limited basis with more firewalls but LAN parish blew me off saying I was being overly dramatic and unrealistic so mr. Jackson did you just give up no I was not gonna give up that easily so I emailed dr. Virginia Fox the hospital's chair on the board of directors I let her know about all of my concerns and how Lane had been constantly blowing off my warnings I wasn't just gonna sit back and watch us implement the wack system to your knowledge was there deadlines in implementing this new paperless medical technology yes perish promised the Board of Directors he would have the system in place by March there's now the end of February so the time was running out now you mentioned you sent an email to dr. virginia foxx on the board of directors did any improvements come after you set that in them unfortunately it was quite the opposite on March 2nd parish called me into his office and yelled at me for and I quote being an insubordinate opinionated egocentric non team player and then he just fired me he made me pack up all my things and had the hospital security walk me out so mr. Jackson what does all of this have to do with the ransom that you sent I knew that what I found was way too important to be ignored so I decided to take action into my own hands how exactly did you take action into your own hands on April 1st I hacked into packed into parishes tgh email account and sent him a ransom note I set it up so that when he opened the email the only thing in the hospital that was affected was the encryption on the patient records just the patient records nothing else in the hospital was touched at all besides Layne parish did you notify anyone else about the attack you had just the ransom you would have sent yes I also notified the local media and why did you notify the local media well I thought it would make lane parish and the Board of Directors act faster the sooner they paid back the ransom that sooner they would get their records back pretty simple why did you think that the hospital would pay that ransom so quickly because of the hospital's policy where they do not negotiate with hackers Your Honor may I approach the witness with what has been previously entered as exhibit 5 you may mr. Johnson what is this this is that no pay policy well what is at the end of that no pay policy well here it describes that if a the hospital will not negotiate with the hacker in the event of a cyber attack however the hospital may supersede or override this policy if patient records are unavailable now mr. Jackson who wrote that policy in the ability to override that policy Lane did and in the hospital abide by that policy as you expected they would know unlike I completely expected the hospital did not pay the ransom back immediately instead of getting the records back up upfront they waited a whole 19 hours to pay the ransom I never thought that anyone would be affected was there any information concerning the email you sent Lane that you didn't tell him yes regardless of whether or not the ransom had been paid the system was set up so that the records would be returned regardless at 11:59 the next day no matter what mr. Jackson it wasn't about the money then what were your intentions and sending that you know truly I had grave concerns about this new system I knew that what I found was way too important to be ignored and it needed major improvements but no one seemed to be listening to me proving Lane parish wrong and getting the money was all just an added bonus just a cherry on top did you ever imagine you'd be here no I I never imagined that someone would die in the care of the hospital staff sure I am a hacker but I am NOT a killer no further questions your honor and past the witnessed cross-examination yes your honor mr. Jackson as you stated on Direct you worked at Texoma General Hospital correct yes in the CTG and as an employee you analyzed the PMT system yes that's what that was my job what about a year after you were hired you were fired correct yes I was eventually fired and after you were fired you decided to hack the system yes I was I did hack the system the system that held confidential patient information correct yes and as you testified on direct your goal of the team your goal of the hack was to show the hospital that their system was flawed correct yes they I wanted them to make sure that they need to make improvements with this system you also had some other incentives correct some small and proportionate reasons not nearly as big as the one as to change the hospital policy or change the hospital system small $150,000 ransom correct small for the hospital I mean it's really just a small price for them to pro to pay this was $150,000 ransom correct yes that is what I set the ransom at and you even had a plan for this money didn't you yes you were going to put this money into a computer gaming lab correct that's probably what I you would have used the money for so the hospital paid the ransom eventually after 19 hours yes they did you correct I did let's talk about what you did in preparation for your hack you knew you had to know which computer to hack correct yes and you knew that the best computer to hack was the one with the greatest security privileges who was Elaine parish right and you would agree with me that since you were an employee at TGA check you knew lane Parrish was the one with the greatest security privileges well he was a chief information officer so yes you would agree with me that you knew this since you were an employee tgh yes now let's talk about the policies that were in place when you work the tgh okay um you voiced your concerns about these policies didn't you well it was my job to find holes in the system and make sure we were implementing the right system so when I found vulnerabilities I made sure to bring them up in the meetings and to my boss Elaine Parrish right he warned the hospital about these flops correct yes I did you warned lane Parrish and the board of directors that something could happen to the patients in a hack yes I was assuming that this patient information would be made public in something like embarrassment or fraud or identity theft could have all do these poor patients actually react to my question yes or no you Warren Lang Parrish that something could happen to the patients and a half yes and you heard my pair sets by today correct I did you heard him tell the court that if that you warned if the system was hacked patients could be put in danger did you hear that yes the danger of embarrassment never the danger of harm or death let me reduce to my question Blaine Parrish stated simply you warned if patients if the system was hacked patients will be put in danger correct yes now let's talk about this no pay ransom policy at the hospital there's no pay ransom policy you didn't like it did you I had concerns about it just like everything else that Wayne parish did you went to the hospital board who fought against it yes and you made sure the hospital was willing to pay a hacker's ransom I wanted to make sure that they had a crypto currency account set up that so that they could pay the ransom as quickly as possible in the event of a cyber attack but despite your warnings they implemented this policy didn't they yes they did and you were concerned about this because you knew if they had this policy and the system was hacked this could lead to chaos in the hospital correct well hospitals are usually chaotic in general so I wouldn't say that I mean sure there's always chaos in the hospital but is it your statement in court today that you didn't say if they implemented the policy and there was a hack this hospital we could be put in chaos correct no I did say that so I got to talk about the email chain that's sitting up there is it still up there no ma'am I don't think so I have a copy who needs Your Honor permission to a personal witness with what has been previously admitted is it a seven you men read along silently as I read aloud god knows what would happen to the patients here did I read that correctly I didn't see yes that's what it says this is your statement that you made to the board of directors yes that's what I emailed dr. virginia foxx your honor he passed away yes redirect briefly your honor mr. Tarson do you currently have that 150,000 dollars no I don't the I don't have it anymore was taken from him and what was the worst thing that he thought would happen to the patient's patient records being made public never this not death no further question John and I pass the witness recalls very briefly cross your honor even though the money was taken from you you planned to obtain $150,000 in this hat correct yes past witness right maybe's way to step down yes I'm nine call your next witness Your Honor at this time the defense calls nurse Alex Karev to the stand before I begin Your Honor may I retrieve exhibit one yes you may also Mary require us know how much time the defense has remaining yes you may would you please introduce yourself the ladies and gentlemen of the jury hello my name is Alex Karev what do you do for a living this Karev well I currently work as a nurse at the Gannett sir Flint Memorial Hospital but I previously worked at the tgh or Texoma General Hospital and what did you do at that hospital in which you formerly worked GGH I worked as a nurse in the A&E department it means accident and emergency it was my job to take in patients and accord their information did you have any other duties possible yes I also continued to care for and treat my patients nurse Streb if we could get to the reason why you're here today were you ever tasked with caring for a patient in Mulder Scully yes I was could you tell us about yes mr. Scully came into the hospital on April 1st just a few days after a new paperless system went live he was 75 years old and when I first saw him he had a deep laceration on his left hand and it was very swollen and do you know how he got that laceration I learned during the intake process that while trimming hedges mr. Scully had fallen off of his ladder and onto the blade of his hedge trimmer giving him the cut and other than that cut on his hand was there anything else wrong with Mulder Scully well during intake I took mr. scalese vitals like his blood pressure heart rate and body temperature and I noted that he had a slightly elevated fever but aside from that everything was normal nurse CREB what did you do after you checked Mulder Scully's vitals I asked mr. Scully if he had any allergies that's what I do with all my patients and T informed me that he was allergic to penicillin which is an antibiotic primarily used against bacterial infections what did you do next nurse Karev well I was about to move on with the intake process but mr. Scully's daughter Dana who was with him at the time reminded her father that he also had an allergy to naproxen could you explain what naproxen is well naproxen is an NSAID or a non-steroidal anti-inflammatory drug but it's used to treat pain in and did Mulder Scully mentioned this allergy to naproxen when you initially asked him about his allergies no he forgot to mention his second allergy but that's not really uncommon for someone that was his age did you make a note at that time that Mulder Scully forgot to mention things [Music] opposing counsel asked if he forgot to remember things they've only shown one instance of the witness forgetting one thing one allergy on one occasion response your honor if that's opposing counsels only objection I could rephrase your question and did you make a note at that time that Mulder Scully had forgotten to mention that allergy no I did not nurse Karev did Dana Scully do anything else while you were talking to her dad yes while we were still in mr. scalise room Dana wrote her phone number on the whiteboard in his room in case we needed a call at any later point in time and did you ever call Dana Scully at any point up until her father's death no but we really should have called her nurse Karev after you finished talking with Dana Scully what did you do I placed a read allergy wristband on mr. Scully notifying any and all hospital staff that he had allergies we needed to keep aware of Your Honor may I approach the witness okay is this that allergy wristband you were talking about yes it is now looking at this wristband did you write his specific allergies penicillin and naproxen on this wristband no I did not nurse CREB did you write those allergies anywhere like on the whiteboard no I did not nurse prep was anyone else with you during this intake process yes dr. Robbins was with me and after I finished conducting intake he prescribed ten milligrams of hydrocodone which is a painkiller and a CT scan to check the extent of mr. scalese injuries and what did you and dr. Robbins do after the CT scan well we determined that mr. Scully should stay overnight for observation so at about five o'clock that afternoon I moved mr. Skelly to room on the tenth floor and after staying with him for a little bit I left him at home did you see mr. slowly again yes the next morning when I came back into work and his daughter Dana was with him again and at that time had the cut on his hand heal the cut hadn't healed but the swelling on his hand had gotten a little better so I left and check back in later that day at about 4:00 in the afternoon and how did you look that the swelling had gotten a little worse so i paged dr. Robbins for re-examination and what did dr. Robbins do after re-examining mr. Scully dr. Robbins prescribed penicillin and bogut Ruxpin for the pain and swelling could you explain what bogut rocks to finish bogut rocks ofin is a medication used to treat pain and inflammation but most importantly it's a derivative of naproxen which was one of mr. scalese allergies nurse Crupp did dr. Robbins administer those two medications right then and there no I made sure to remind dr. Robbins that mr. Scully had an allergy Van Daan and that we needed to double-check his allergies and how did dr. Robbins respond well dr. Robbins groaned and then hurriedly asked mr. Scully what he was allergic to and we were informed that he was allergic to penicillin so dr. Robbins changed the penicillin in his prescription to Yarbrough max did Mulder Scully also mentioned that he was allergic to naproxen no he once again forgot to mention that second allergy did you remember that important second allergy nurse correct no unfortunately I did not how about dr. Robbins did dr. Robbins remember naproxen no we both completely forgot about that second allergy nurse CREB did you call Dana Scully's phone number on the whiteboard to confirm allergies before administering medication no we didn't call her but like I said earlier we really should have nurse Karev was in an emergency situation at that time in which you needed to give your patient Medicaid and medication the swelling on mr. Scully's hand had gotten a little bit worse but aside from that his condition was not life-threatening so nurse Craig after you did give this medication what happened I left mr. Scully for about 45 minutes and then went back to check on him and that's when I noticed that something was seriously wrong what was wrong nurse Karev well mr. Scully was having trouble breathing and was suffering from hypotension which is abnormally low blood pressure and do you know why he was experiencing these symptoms at that time I assumed that it was because of the medication that we'd give him mr. Scully and I later learned that I was right so what did you do after seeing your patient experiencing these symptoms well I immediately page dr. Robbins and he raced right down and based on what you saw dr. Robbins do was he able to recognize what was wrong with mr. Scully not really and instead of trying to figure out what was wrong with mr. Scully dr. Robbins and I just got into an argument about patient treatment and what happened after you got into this argument well we realized that mr. Scully was having an allergic reaction to one of the medications that we'd given him the book at Ruxpin with that new knowledge of bogit rocks fen then was dr. Robbins able to treat his patient honestly I don't know if dr. Robbins would have been able to treat his patient because right after finding out that mr. Scully was going into anaphylaxis dr. Robbins ran away wait dr. Robbins ran away while his patient was dying why I have no idea but nevertheless dr. Robbins abandoned myself and his patient while he was going into anaphylactic shock so what did you do nurse crab being left alone with the dying patient well I immediately call the code blue and administered epinephrine hoping that it would cure the anaphylaxis did it cure the anaphylaxis no the epinephrine didn't do anything and mr. Scully flatlined and what did you do after Mulder Scully flatlines nurse Karev I did everything I could to save his life I performed an emergency tracheotomy to try to re-establish an airway and perform CPR to try to restart his but nothing worked in mr. Scalia passed away thank you nurse Karev Your Honor I have no further questions at this time I passed away cross examination after Mulder's Foley's death you were fired right yes I was objection your honor this is irrelevant what happened after Mulder Scully's death object relevance under for a response counsel has use this witness testimony show fault and hospital treatment and is blaming the EMTs her that Mulder swing set is a fault of this witness and a doctor in understanding why this witness was fired and if it had to do with actuality to Mulder's Foley's death or not would be Belden room yes you are after Mulder's filiz death you were fired yes that's correct you believe that you were wrong I do believe that yes I believe that it should have been dr. Robbins who should have been fired well you believe you were used as a scapegoat yes I did everything that I could I did everything correctly and trying to say well nurse correct you blame the PMT system as one of the reasons that Mulder's fully tragically died one of the reasons but this I can be corrected my question designing yes or no you blame the PMT system as one of the reasons that Mulder slowly died yes as one of the reasons so as we heard you're a nurse for Mulder Scully yes I was and earlier you recognized that olive University right yes that was me that reminded dr. Robbins if the wristband approached with what was previously in it you may now this is the allergy wristband that was put on the picture yes it was and as you said on direct examination nowhere does it list his allergies no it does not so the allergies weren't listed on the allergy risk right that's correct but they were listed on the PMT system yes and you would recognize the PMT system the Mulder's Foley's medical record if I were to show it to you yes I would you know permission to approach with what was already been admitted as exhibit three you may take a moment to look this over if you need but as they're familiar with it can you tell us what I've just handed you this is an image of mr. scalese patient chart and this patient chart was available exclusively on the PMT system yes it was how can you pulled that up and show it to the jury and can you show us where Moltres plays description of his injuries was the description of his injuries was right in this area can you show us her Mulder Scully's pain level during intake was um once again it was right in this area chart can you show us where the medications were prescribed during this treatment where that information is located right here and can you show us where Mulder schoolies allergies are located oh right here now this was taken away wasn't it I'm sorry could you repeat the question sure the PMT system was shot down right yes it was and as a result of this hack all of these records were taken away yes we did not have access to the records Moltres police records were taken away yes and well like as you said all of the hospital's records yes so you didn't have access to one single amount of information from that record once again yes now did you hear lane Parrish testify earlier I did so you heard him testify that one of the uses of the PMT system is to input symptoms for a suggested diagnosis yes I did so the PMT system went down mm-hmm yes could no longer input symptoms for a suggested diagnosis that's true but well the dog that a yes yes but that's not necessarily entirely true for the suggested diagnosis okay well correct me if I'm wrong the PMT system was shut down and this benefit from the PMT system was shut down along with that yes but it's also the doctors job to advise not much question this was shut down was a man yes that's true along with the suggested medications that person but Lane parents testified about yes that's also true so the system was shut down and all of these resources were taken away yes thank you honorary passes redirect yes your honor briefly nerf scrap opposing counsel talked a lot about the necessity of the PMT but is it possible for doctors to treat their patients simply by viewing the patient's symptoms absolutely that's their job the PMT was live for barely even two for not even two weeks before they went down it was still the doctors job to diagnose treat and administer medication to their patients a nurse CREB did those records come back online before Mulder Scully died yes they came back on and when they did come back on did dr. Robbins or you ever use that suggested treatment part of the system that opposing counsel talked about no we didn't no further questions your honor I passed awareness recross rauner yes so during Mulder's police treatment you saw patients wristband right yes I did and after seeing this wristband objection your honor no wristband was talked about during my response you may opposing counsel discussed the prescription of boko tracks then in this line of questioning I will show the connection between the prescription and the use of the PMT system that opposing counsel said was not vital if I may respond your honor I talk to no social administration and your objection is overruled yes your honor so after seeing the witnesses or the patient's wristband do you wait to check for allergies right yes we did and we also asked the patient his allergies so after you saw the wristband he has a patient for his allergies because you needed to know before prescribing medication yes so if the PT system tagged it up you would have seen the wristband and gone to check for his allergies on the PMT system yes but that's not the only method we had of chicken that's not my question you would have gone to the PMT system to check for his allergies yes and if the PMT system would would have been off as you testified you would have seen his allergies yes that's correct but the PMT system was shut down by Avery Johnson's house right yes so you couldn't access resources we couldn't access the records but we had access to these allergies thank your honor fastest car your next witness yes your honor at this time the defense calls Addison Montgomery to the stand before I begin Your Honor may inquire how much time defense has for me yes you know that receipt yes you may good you mean please introduce yourself to the jury good evening my name is Addison Montgomery I'm 38 years old I'm a practicing medical doctor and where did you receive your education after a hard decision between many schools I ultimately decided to attend Southern Texoma University or s tu I graduated with degrees in biology biochemistry and a minor in philosophy and what did you do after you graduated from s to you well I was recruited by some of the top medical schools in the world and I decided to attend the amazing Karolinska Institute in Stockholm Sweden I received a fellowship of medical research and then I graduated in 2004 and returned to Texas omen for my residency and where did you complete this residency at Leonard McCoy General Hospital and then I worked briefly at northern Texoma doctors Hospital where I studied immunology diseases allergies drug interactions and treatments to various ailments dr. Montgomery what are you doing now I now work at st. Nicholas Texoma Hospital where I'm the youngest lead medical researcher in the state I've also opened my own practice in the legal field to offer my opinion on various medical issues what medical issues do you research as a high-level medical researcher my expertise is in immunology drug interactions allergies and how to treat them so why are you here today well I was hired to look at everything involved in this case and render my opinion as to mr. scalese cause of death what information did you rely on in your investigation I relied on all of mr. Scully's medical information all given exhibits and statements from both the prosecution and the defense what an expert in your field normally rely on these types of things inclusions they would and was this sufficient facts and data to form conclusion yes and we're positions eight the jury understanding the facts of today's case absolutely so dr. Montgomery what was your conclusion of today's case well after looking at everything I came to the conclusion that the ultimate cause of mr. scalise death was not an inability to access records but rather the hospital's malpractice and reference to treating mr. Scully's allergic reaction where did you begin this investigation I began on April 1st the day mr. Scalli was admitted to the hospital and I reviewed nurse krebs intake report and what did you learn from this intake report well I learned that the hospital was made aware of mr. Scully's allergy to penicillin but more importantly I learned that they were made aware of mr. scalese deadly allergy to naproxen which later caused complications why would this allergy cause complications well dr. Robbins prescribed poke attracts fen which is the ultimate cause of mr. scalise allergic reaction can you explain to the jury a little bit about bucket rocks and of course bucket Ruxpin for boku was created in 2013 and it's a heavy derivative of naproxen and naproxen is an inset or a non-steroidal anti-inflammatory drug so why wasn't prescribing this boko of complication prescribing boku was a risky move because one mr. Skelly was allergic to naproxen which is in boku and to the surprisingly short testing period of the drug what like revealed some negative effects what were these negative effects well the most severe was referred to as nerd and although it wasn't that common it had a very high morbidity rate every doctor should be aware of this risk after prescribing boku what exactly is nerd nerd are in said exacerbated respiratory disease is an allergy to insect causing a patient to go into anaphylaxis with skin rashes asthma-like symptoms and hypotension well dark montgomery did not have a bearing in your investigation oh absolutely after reviewing everything it was painfully clear to me that mr. Skelly was suffering from a textbook case of nerd house 3 a case of nerd nerd is very treatable it's treated just like any other allergic reaction except for that it doesn't respond to epinephrine but epinephrine isn't the only step in treating an allergic reaction next you need to establish an airway or administer an inhaler or any other drug aiding asthma-like symptoms and did the hospital turn it properly no dr. Robbins failed to realize that mr. Skelly was suffering from nerd or any allergic reaction so what did the hospital do to treat mr. Scully well dr. Robbins abandoned mr. Scully in the middle of an allergic reaction and left nurse Karev to deal with the issue without any prior knowledge of nerd and how did nurse craft him with the situation I commend nurse Karev for everything she tried to do how her she just wasn't equipped to handle this situation and it was saddening to see that she was used as a scapegoat for the hospital's mistakes dr. Montgomery are you aware that the records we're done yes however they came up shortly after mr. Scully's allergic reaction began and we're available to all medical staff including dr. Robbins at the time of Biswas Kelly's allergic reaction Your Honor may I approach the witness was been previously in 2007 three you men dr. Montgomery do you know what this is yes it is mr. Scully's medical records and do you see the differential diagnosis button on the bottom I do during your investigation at any time where did you notice that someone pressed that button once they had the records back no I never heard of them using it at all I don't know why a doctor would need to and did they have these records back before mr. Scully died yes and they made no difference at all even after accessing the records seeing naproxen as an allergy remembering that allergy dr. robbin still failed to acknowledge that mr. Scully was suffering from an allergic reaction that could be deadly if not treated properly cross-examination yes your honour may I proceed yes doctor wondering when you investigate various medical issues you use documents to review your cases absolutely and you use evidence to come to your conclusions I do in all the cases that you look through absolutely now dr. Montgomery we're here for the testimony of lane Parrish I was so you heard Lee Parrish testify that one of the goals of the PMT system was to speed up the intake process for patients yes in the hospital use the PMT system in order to do so correct they did but the hospital was shut the PMT system was shut down as a result of Avery Jackson's hacking correct yes they weren't able to access the medical records because of Avery Jackson's happened yes now due to the system being shut down they were unable to achieve this goal of speeding up the intake process correct I suppose that would slow it down a bit now another goal of the PMT system was to improve nurse doctor communications correct yes in the hospital use the PMT system for this communication process correct do you mean like paging nurses and doctors yes in order to speed up the communication between nurses and doctors and recording their information yes that is what they used to work in the hospital we relied on the system for this that and pagers and doctors communicate in a lot of different ways but yes the PMT was one way now because the PMT system was shut down as a result of Avery Jackson's hacking they were unable to achieve this goal of improving their software communications crap that's incorrect but they were unable to achieve the goal that the PMT system required correct no you see Avery Jackson only locked the medical records part Danka had nothing to do with the communication between nurses and doctors what I redirect you to my question the PMT systems goal was to improve nurse doctor communications by putting information in one spot correct yes I suppose and I was unable to be achieved because Avery Jackson hacked the system I guess because you they aren't able to access the records now another goal the PMT system was to reduce medical mistakes correct I suppose in the hospital used the PMT system to reduce medical mistakes what exactly are you referring to liyan parish's testimony when he testified that one of the goals of the PMT system system is to reduce medical mistakes correct in what way in any way by inputting symptoms yes I suppose that was a goal of the PMT and because the PMD system was shut down as a result of Avery Jackson tacking they were unable to achieve this goal correct yes they were unable to check their diagnosis now were you here for the testimony of dr. Arizona Robbins I was and you heard dr. Robbins testify that one of the goals of the PMT system was to input information into the PMT such as allergies yes the intake process in hospital use the PMT to record this information they did but because the system was shut down they were unable to access this information correct yes now another goal of the PMT system was to speed up diagnosis are you referring again to accessing the records or the differential diagnosis crime putting the symptoms in yes I guess again that was a goal of the PMT then because the PMT system was shut down they were unable to speed up yes now dr. Montgomery you're familiar with the drug poco tracks have it correct yes very much and you agree that the benefits of okra tracks have been heavily outweigh the risks in some cases it is viewed that way by many doctors in some cases so in the cases where hospital staff have access to the risks the benefits may outweigh the risks correct No so why do the benefits outweigh the risks the benefits outweigh the risk when a doctor is able to treat an allergic reaction in this case dr. Robbins was clearly unable to recognize and treat an allergic reaction so it was no action your honor out of moment order I ask that opposing counsel let my witness finish her answer before interrupting her response your honor you know I'd spawn the witness was going into testifying about something on my question is was not specific to therefore I was going to redirect her to my question dr. Montgomery redirecting you to a question the PMT system held patient allergies correct yes it did and in older Scully's case the risk tobacco tracks ofin was his allergy to naproxen correct yes but they would have still prescribed it or dr. Robbins would I still probably prescribed it even with access to these records because they would have known about the allergy to the proxy I'm sorry dr. Robbins would have prescribed Bunco track seven because she would have known about the allergens naproxen as it was on the kimchi system doctors should be aware of adverse risks no matter what the patient tells them their allergies are but don't always know what all their allergies are just to clarify for the court in this case his allergy was to naproxen yes it was now if the system had been up they would have had access to his medical records yes they would have and if the system had been up they would have known about his allergies in a proxy they would have if the system had been up they would have known that it's allergy to naproxen played a risk and his treatment correct they should have known that regardless Your Honor I've passed awareness redirect no redirect necessary guess what it set down yes good night does the defense wrist yes your honor both sides clothes yes your honor all right take a minute before closing argument the prosecution is ready to proceed your honor okay Your Honor may I go moment to gather exhibit you may Your Honor at this time I'd like to reserve one minute for a rebuttal you know Your Honor the defense is ready to proceed with Rosen arguments I proceed your honor you men may it please the court opposing counsel members of the jury god knows what could happen to the patients here on April 1st of 2017 Avery Jackson played God formerly working at Texoma General Hospital Jackson worked with the paperless medical technology or the PMT by working with the system he knew about the benefits but he also knew about the flaws Jackson chose to exploit these flaws and caused the death of a 75 year old man who went into the hospital with a simple cut on his left hand God knows what could happen to the patients here when the PMT system was implemented the benefits were extraordinary it improved nurse doctor communications quickened treatments and diagnosis and improved quality of care Texoma General Hospital it health patient records files information and flouts the information that's crucial to patient care Mulder Scully died after the hospital staff could not access the system the system that Avery Jackson violated why sure see 150,000 dollars to Jackson receiving from the hospital what he claims to be petty cash was worth the life of a man who went into the hospital with a simple cut only needing simple stitches today we brought before you three witnesses to do the case Dana Scully testified about her father's experience and the chaos that ensued at the hospital because when Jackson played God he put the hospital staff into a frenzy Dana went into the hospital with her father after a minor accident would hedge trimmers but she came out grieving with her crying children dr. Robbins testified that when the records were down they were unable to access patient information including allergies information that is vital to care finally Layne Parrish told you that every Jackson had warned him about the risks to the PMT system Jackson worked with the system and he knew how to hack it but most importantly he knew about the risks to the patients when he said god only knows what could happen to the patients here today the defense tried to tell you their story they want you to believe that the hospitals at fault or that dr. Evans did an improper job however records are vital to care and their resources were cut off when Jackson hacked the hospital Avery Jackson played God when he took patient lives into his own hands he played God when he stole the records from the hospital Avery Jackson is already admitted to hacking the system but now he's attempting to avoid the consequences he knew of the risks having warned lane Parrish months prior but he took those risks into his own hands using his thirst for revenge to punish the hospital to punish Dana Scully to punish Mulder Scully to put the entire PMT system on hold until his ransom had been satisfied god only knows what could happen to the patients here today we have proven beyond a reasonable doubt that Avery Jackson caused the death of Mulder Scully at the end of today's trial we ask you to find a verdict of justice Avery Jackson caused chaos to ensue at the hospital and he caused the death of a 75 year old man with one simple cut for the past two years data has been dragged through trials having to relive the worst day of her life but Jackson didn't just records he stole futures because of Avery Jackson's actions the Benton Mulder Scalise garden sits empty he will never be able to pick flowers with his grandchildren Jackson stole those precious moments just to prove that patients could be harmed and he was right how much is a life worth to Avery Jackson it was worth one hundred and fifty thousand dollars find every Jackson guilty Phantasy you may it please the court Your Honor opposing counsel you members of a jury today you've heard about baby Jackson a happen not a killer as my co-counsel Charlie stop told you the beginning of today's trial the burden of proof lies solely with the prosecution they have to prove to you beyond a reasonable doubt that my client committed the offense of manslaughter and in order to do that they have to prove to you two things one mr. Jackson consciously disregarded a substantial risk therefore he acted recklessly and to that mr. Scully's death would not occur but for the actions of mr. Jackson but members of the jury they have failed today you've heard that mr. Jackson took a job at CGH where he was given the responsibility to find the vulnerabilities in the new PMT system and he did that you heard from mr. Parrish and mr. Jackson that he tried over and over to one of these vulnerabilities that he found but members of the jury over and over he was ignored over and over mr. Parrish told him no patients are going to be in danger there's an exception to her no pay policy the board may choose to override this policy if there's complete denial of patient records but it was the hospital board that chose not to follow if they're in this policy you heard from the chairman of the board herself she didn't care what the virus had done she was not going to pay that ransom under any circumstance members of the jury they also have to prove to you that the death would not have occurred but for the actions of mr. Jackson but once again they have failed Dana Scully she told you that she told the nurse knew the medical staff about his deadly allergy to naproxen but the hospital forgot you heard that dr. Robbins was likely to prescribe Boca Traxxas in any way even if he knew about this deadly allergy to naproxen Dana Scully wrote her number on the whiteboard told the hospital call if you have any questions or concerns never receive a phone call dr. Robbins and ministered Boca Johnston and she shifted the flame to nurse Karev but she ordered it to be administered the hospital relied so heavily on this PMT that it enabled their laziness dr. Robbins said himself today that without this PMT he was not prepared he forgot how to be a doctor members of the jury Addison Montgomery came before you and expert in allergic reactions and told you that mr. Scully was having all the signs of an allergic reaction hypertension skin rashes and admah like symptoms but dr. Robbins failed to recognize any symptoms and dr. Robbins planes that if he had this system he would have been able to treat mr. Scully but the truth is never stitchers this system was up before mr. Scully died and dr. Robbins still failed to recognize the symptoms and treat them properly even with the information right in front of him this shift the blame to nurse Krause medication nurse scribe was fired and they found another state go they've shifted the blame to mr. Jackson members of the jury if the hospital had paid the ransom upfront if they called Dana Scully if they had to recognize the symptoms if any action by the hospital have been done differently if they had done the simple fix mr. Scully would be alive today members of the jury when you go back to the jury room to deliberate remember what is on trial today not the fact if mr. Jackson hacked the system but if that had caused the death of mr. Scully the hospital was blamed once before because their actions were sufficient the internal investigation found nurse Karev guilty Lane Parrish said some of the blame is on nurse Karev and Dana Scully blames the hospital and said that those mistakes are not erased I'm sure the jury mr. Jackson's a hacker he's not a killer there's only one reasonable option mr. Shelton is not guilty of a manslaughter a motor Celie thank you rebuttal your honor yes but before I proceed may I inquire to ask how much time is early an issue may may please the court opposing counsel members of the jury competence at the beginning of today's trial mr. stock got up here and attempted to tell you that the hospital is incompetent but what actually happened Avery Jackson shut down the paperless medical technology system he had an intent he had knowledge and he had motive he had knowledge of the risk to the patients and he had the intent to pocket 150,000 dollars even if his intentions were good when you go back to the jury room they're going to hand you a piece of paper and that piece of paper isn't going to say what were every Jackson's and tensions the piece of paper is going to say did Avery Jackson's hat cause the death of Mulder Scully and the answer is yes they reject ins stole the hospital resources find Avery Jackson guilty thank you members of the jury you are retired to deliver any verdicts anywhere no please be seated this has been a great competition but whether we do this part now is we're just celebrate our third place teams before we celebrate our first and second place team we always go back so we're gonna start with that third place team I invited those to be here and we have someone here from from Regent school [Applause] the [Applause] what's your feet closer to the floor [Applause] and now before we before we proceed we're gonna let the judging panel introduce themselves good evening it's always a pleasure to judge especially the final round of the Texas high school mock trial competition my name is Lana Myers I'm a justice on the 5th District Court of Appeals and before that I was a criminal district court judge in Dallas County for about 15 years and have been on the court of appeals since 2009 and have served as a former chair and co-chair the mock trial committee and judge mock trial for many many years beginning in the 80s so I've done it for a long time and I am never disappointed you all are amazing and I just applaud you for all the preparation time everything that you put into this because it shows in your performance today would you all please join me in giving these students a round of applause [Applause] and our very important jury members if you all will please introduce yourself starting on the first row my name's Jim young lawyer arbitrator and mediator professor here in the Dallas area and Northpoint I'm the assistant coach for the mock trial mediation teams at the University of Texas at Dallas I've been doing this for a long time and I continue to be thrilled I'm also a lawyer happy to start it and Geisler and Wow [Applause] my name's Robert Toby I'm with the law firm with Johnson Toby Farooq on the trial lawyer there I am present elected the Dallas bar so I get two following waters big footsteps y'all were fantastic another great year and a terrific final wrap thank you very much [Applause] [Music] and this year are the honor serving as the president's Women Lawyers Association so very time you see all of our female litigants which is commendable in our males as well all of you all did such a fantastic job office but the biggest reason I'm here is I was on the team that first one this 40 years [Applause] [Applause] [Music] [Applause] all right I believe that the jury has reached its verdict will the defendant please rise madam foreperson has the jury reached a verdict the jury has what is the jury's verdict we will now celebrate our second-place winner one-day Academy [Applause] [Applause] [Applause] and now and now we will celebrate I could have everybody's attention we will celebrate our first-place winner our 40th champion of 2019 Bishop Lynch High School [Applause] [Music]
