UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA 2 COLUMBIA DIVISION 3 4 5 Plaintiff 6 Vs CASE NO. 3:93-1881-19 7 NATIONAL RAILROAD PASSENGER 8 CORPORATION and CSX TRANSPORTATION, INC., 9 Defendants. 10 COPY 11 DEPOSITION OF: COOPUL, M. D. 12 DATE: September 9, 1994 13 TIME: 4:10 P.M. 14 LOCATION: Office of 15 Frank E. Forsthoefel, M.D. 1333 Plaintiff Street 16 Columbia, SC 17 TAKEN BY: Counsel for the Defendant 18 REPORTED BY: JANET L. ANDERSON, Court Reporter 19 20 Computer-Aided Transcript By: 21 A. WILLIAM ROBERTS, JR., & ASSOCIATES 22 Charleston, SC Columbia, SC Charlotte, NC 23 (803) 722-8414 (803) 731-5224 (704) 573-3919 24 25 A. WILLIAM ROBERTS, JR., & ASSOCIATES 2 APPEARANCES OF COUNSEL: 2 ATTORNEYS FOR THE PLAINTIFF Plaintiff: 3 STEPHEN H. COOK 4 Attorney at Law 1412 Barnwell Street 5 Columbia, SC 2 92 0 1 (803) 254-0658 6 ATTORNEYS FOR THE DEFENDANT 7 NATIONAL RAILROAD PASSENGER CORPORATION and CSX TRANSPORTATION, 8 INC.: 9 McNAIR & SANFORD, P.A. BY: LESLIE S. ROGERS 10 1301 Gervais Street P.O. Box 11390 11 Columbia, SC 29211 (803) 799-9800 12 13 14 15 (INDEX AT REAR OF TRANSCRIPT) 16 17 18 19 20 21 22 23 24 25 A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 3 1 STIPULATION 2 It is stipulated by and between 3 Counsel that this deposition is being taken in 4 accordance with the Federal Rules of Civil 5 Procedure; that all objections as to Notice of this 6 deposition are hereby waived; that all objections 7 except as to form are reserved until the time of a trial; and that the witness waives reading and 9 signing of this deposition. 10 11 (Two-page medical report was marked as 12 Defendant's Exhibit Number I for identification.) 13 FRANK E. FORSTHOEFEL, 14 M.D., being first duly sworn, testified as follows: 15 DIRECT EXAMINATION 16 BY MS. ROGERS: 17 Q. Dr. Forsthoefel -- is that the right 18 way to pronounce it? 19 A. Absolutely. 20 Q. My name is Leslie Rogers; and, as you 21 probably know, I represent the Defendants Amtrak and 22 CSX in this litigation. 23 A. Yes, I do. 24 Q. I'm going to ask you questions. if I 25 don't make sense or I don't understand -- A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 4 1 A. Sure. I understand. 2 Q. --please let me know. 3 A. Sure. 4 Q. Let's start, if you would, by you 5 stating your full name. 6 A. Frank Eugene Forsthoefel. 7 Q. And what is the business address here? 8 A. 1333 Plaintiff Street. 9 Q. And I understand you are a 10 psychiatrist; is that correct? 11 A. Yes; that's correct. 12 Q. When and where did you receive your 13 undergraduate degree? 14 A. My undergraduate from Marquette 15 University in Milwaukee, Wisconsin; medical degree, 16 Marquette University, Milwaukee; internship, Jackson 17 Memorial Hospital, Miami; residency, Lafayette 18 Clinic in Detroit, Naval Hospital, Philadelphia; and 19 I was chief of psychiatry at Parris Island. I'm 20 board certified in psychiatry, 1972; private 21 practice here for 23 years. 22 Q. When you say here, you mean in 23 Columbia? 24 A. Yes. 25 Q. Have you ever taught at any school in A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 5 1 South Carolina? 2 A. At one time I was on the associate 3 psychiatric staff for the medical school, but I am 4 no longer active with that. 5 Q. Have you ever written any articles or 6 papers? 7 A. No. 8 Q. Have you ever taught specifically 9 anything on the topic of post-traumatic stress 10 disorder? 11 A. No. I've not taught anything. 12 Q. Have you ever attended any seminars in 13 the area of post-traumatic stress disorder? 14 A. No, I have not. 15 Q. Have you ever testified in a 16 deposition before today? 17 A. Many, many times. 18 Q. What were the circumstances? 19 A. I get a number of referrals from 20 attorneys who have clients who have work-related 21 accidents, or car accidents. So I'm very, very 22 familiar with the area. 23 Q. Do you normally testify on behalf of 24 the plaintiff? 25 A. Yes. A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 6 1 Q. Do you normally testify in court? 2 A. No. 3 Q. How many times have you appeared in 4 court? 5 A. Over 23 years, probably ten, 15 times. 6 Q. Have you appeared in both state and 7 federal court? 8 A. Uh-huh. 9 Q. Have you been qualified as an expert 10 in psychiatry during those trials? 11 A. Definitely. 12 Q. Have you been qualified as an expert, 13 specifically in the area of post-traumatic stress 14 disorder? 15 A. I don't think there is anybody -- I 16 don't think there is any such designation, as such. 17 Q. What is your normal fee for 18 testifying? 19 A. Regular hourly fee, like $125 for an 20 hour. 21 Q. In this case what is your agreement 22 with the plaintiff or the plaintiff'B attorneys 23 regarding your payment for your services? 24 A. This hasn't even been talked about. I 25 assume that the plaintiff's attorney would pay for A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 7 1 this. 2 Q. Do you have a retention letter where 3 you were retained by the plaintiff or the attorney? 4 A. I don't know. It could be here in the 5 records somewhere. I don't keep track of all of 6 that. 7 Q. Do you have your file in front of you? 8 A. I do. 9 Q. Would you mind looking just to see if 10 you can recall how you might have been retained in 11 this matter? 12 A. Well, the original referral came from 13 Dr. Margolit, so Dr. Margolit asked me to see the 14 patient. And then when I learned about legal 15 things -- because he does see a lot of 16 accident-related injuries. And once I learned that 17 it was an accident, my procedure is that before I 18 see anybody from a physician in an accident-related 19 case, they must have an attorney and the attorney 20 must pay the fees for my services. 21 Q. Okay. So would it be fair to assume 22 that you had a similar arrangement in this case? 23 A. Yes. That's my usual procedure. 24 Q. Okay. What is your general procedure, 25 when you get a patient, for evaluating that patient? A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 8 1 A. Well, the standard evaluation -- and 2 it's standard practice among all psychiatrists, that 3 in an hour we are trained to get a history and to 4 come up with an impression with recommendations, and 5 we ought to be able to do that in an hour. So that 6 would be my standard approach to a new patient 7 referral. 8 Q. Do you use any particular guidelines 9 for your evaluation? 10 A. No. Other than my training 11 background, which is standard, has remained 12 standard. 13 Q. Are you familiar with the Diagnostic 14 and Statistical Manual of Mental Disorders? 15 A. Oh, definitely. That's our handbook. 16 Q. So is that a resource or treatise 17 that you rely on in diagnosing-- 18 A. It certainly is a guideline. 19 Q. How many cases have you dealt with in 20 your experience regarding PTSD, or post-traumatic 21 stress disorder? 22 A. over 23 years, I would say, probably 23 200 to 300. 24 Q. Do you consider yourself a specialist, 25 to have special knowledge in the area of A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 9 1 post-traumatic stress disorder? 2 A. As a generalist -- and that's how I 3 see myself. As a generalist, with considerable 4 experience with post-traumatic stress disorder, I 5 would say because of my experience, and what I'm 6 able to effect in terms of improvement, and 7 improvement in symptoms and improvement in 8 functioning, I would say I would qualify as an 9 expert, given my training and board certification 10 and teaching background. 11 Q. Did you state earlier, I believe, that 12 you get several referrals or numerous referrals from 13 Dr. Margolit? 14 A. Yes. I frequently get referrals from 15 Dr. Margolit. 16 Q. Do you know Dr. Margolit? 17 A. Yes, I do know him. 18 Q. As a colleague or as an acquaintance? 19 A. We've had lunch from time to time. 20 Q. Do you know whether he normally 21 represents plaintiffs as well? 22 MR. COOK: Objection to the term 23 represents. Do you mean treats? 24 MS. ROGERS: Excuse me. Yes. 25 Q. Do you know whether he normally works A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 10 I on behalf of -- you said he treats, I believe, a lot 2 of accidents? 3 A. Yes, he does. 4 Q. Does he normally work on behalf of the 5 plaintiff, or does he normally treat plaintiffs? 6 A. Yes. To my knowledge, he treats many 7 plaintiffs. 8 Q. Are you familiar with Dr. Chesno? 9 A. Definitely. 10 Q. Again, do you know him as a colleague 11 or as friend? 12 A. Both. Both. 13 Q. Are you aware of the treatment of Ms. 14 Plaintiff in this matter by Dr. Chesno? 15 A. Yes, I have been. 16 Q. Prior to your treatment of Ms. Plaintiff, 17 did you review any noteb or speak with Dr. Chesno? 18 A. Yes, I did. 19 Q. Which one? 20 A. Dr. Frank CheBno. 21 Q. Right. 22 A. I did talk with him. 23 Q. You spoke with him. 24 A. Beforehand. So I knew the background 25 of her before she came to see me. A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS I Q. Did you review his notes, or did he 2 provide you any notes or analysis of his treatment? 3 A. Yes, he did. 4 Q. That was before you saw her? 5 A. Yes. 6 Q. What about Dr. Margolit? Did you 7 speak with him? 8 A. I don't recall. Sometimes we talk 9 before I see a person, sometimes we don't talk. I 10 don't recall that. 11 Q. Did you review Dr. Margolit's medical 12 records? 13 A. Yes, I did. 14 Q. Who provided you with these medical 15 records of Dr. Chesno and Dr. Margolit? Was that 16 the plaintiff, the plaintiff's attorneys, or the 17 doctors? Do you recall? 18 A. No, I don't recall any of that. 19 Q. Prior to treating Ms. Plaintiff, did you 20 speak with the plaintiff's attorney, Ms. Plaintiff's 21 attorney? 22 A. I don't recall that either. I talked 23 to somebody in Richmond, because I think that is 24 where the referral -- the legal side of the 25 referral, I think, came from Richmond, or maybe A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 12 1 that's where the train company is. I talked to 2 somebody in Richmond. 3 Q. Do you know whether you talked to any 4 lawyer in Columbia? 5 A. I don't recall that. 6 Q. Do you recall when was the first time 7 you spoke with Francis Hajek or Cliff Coon was? Not 8 Cliff Coon, I'm sorry. 9 MR. COOK: Steve Cook. 10 BY MS. ROGERS: 11 Q. Steve Cook. 12 A. No, I don't. I don't know the exact 13 date of that. 14 Q. But you have had conversations with 15 either Francis Hajek or somebody at Cook and Coon, 16 one of the attorneys there? 17 A. It's just been relative to 18 appointments only, or scheduling. It hasn't been 19 any discussion of the matter, BO to speak. 20 Q. Are you aware of the nature of what 21 this lawsuit about? 22 A. Yes. 23 Q. What's your understanding about the 24 allegation in this suit? 25 A. Well, I'm sure she has a claim for A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 13 1 mental injury, you know. That's my understanding of 2 it. She has a claim for -- because of her mental 3 illness because of the injury, she has claim. 4 Q. And that arises out of what incident? 5 A. The Amtrak accident. 6 Q. You lived in South Carolina during the 7 time of the accident; correct? 8 A. Definitely. 9 Q. Did you learn about the accident at 10 that time or see about it on television? 11 A. Oh, absolutely. I remember that. 12 Q. Have you treated any other patients 13 who were involved in the accidents? 14 A. Not in that accident, no. 15 Q. Have you treated any other patients 16 that were involved in train accidents? 17 A. No. 18 Q. Have you treated any people that were 19 involved in airplane crashes? 20 A. No. 21 Q. When was the first time that you saw 22 Ms. Plaintiff? 23 A. That would be on July 5th of 1994. 24 How many times have you seen Ms. 25 Plaintiff? A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 14 1 A. Let me check. I think it's three 2 times, the last time being August the 24th. 3 Q. And the first time was July 5th. When 4 was the second time? Do you know the date? 5 A. Right. The second date would be July 6 the 19th. July 5th, July 19th and August the 24th. 7 Q. Dr. Forsthoefel, do you have any notes 8 or other reports that you made? The only report 9 that I have is a report dated July llth of 1994, and 10 I'm wondering if you have any other reports that 11 were made after that during your other two visits 12 with Ms. Plaintiff. 13 A. Right. I do. You've got a copy of 14 the originals. 15 Q. Right. 16 A. Can you read my writing? 17 Q. Yes. Would you mind, please? 18 A. (Reading.) On the 19th of July: More 19 energy, less depression, sleeping better, remains 20 fearful and nervous and excitable. Okay. 2 1 August the 24th, again: More energy 22 and less depressed, but continued post-traumatic 23 stress symptoms. Still so fearful she has her 24 grandson staying with her. 25 Q. Is this a copy for me? A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 15 1 A. No. 2 Q. That's your original? 3 A. Right. 4 Q. Do you have any other notes or records 5 in your file? 6 A. I may have made some medication notes. 7 Let's see if I've got that. on 7/19 -- these are 8 medication sheets, okay -- less post-traumatic 9 stress disorder, less agitated, less depressed; 10 8/23, less post-traumatic stress disorder, remains 11 fearful, excitable; nightmares in -- oh, fearful and 12 excitable in malls, driving, bridges; still remains 13 depressed. 14 Q. On the left-hand side there, I see 15 that you have noted some medications that you have 16 prescribed for the patient? 17 A. Right. The Ativan is for her 18 excitability, nervousness, startled reflex, fears of 19 driving. 20 Q. Is that similar to Xanax? 21 A. It's in the same family. 22 Q. Okay. 23 A. Zoloft is for her depression, negative 24 feelings. Okay. Ambien is for insomnia, and 25 Tranxene -- the Ativan wasn't working as well, or A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 16 1 whatever, so I changed it to Tranxene. So that's 2 for the general excitability that we see in 3 post-traumatic stress disorder. 4 Q. Is Tranxene similar to like a mild 5 form of Valium? 6 A. Uh-huh. 7 Q. As a tranquilizer? 8 A. Yes. 9 Q. Did Ms. Plaintiff report to you during 10 these visits that you just made reference, on July 11 19th at August 24th, whether these medications were 12 helping her at all? 13 A. Yes. She is some better. She is some 14 better. 15 Q. Were you aware, when you prescribed 16 prescriptions or medications for Ms. Plaintiff, of her 17 previous medication history? 18 A. Probably. 19 Q. Do you know specifically whether you 20 reviewed the medications that were prescribed to her 21 by Dr. Margolit? 22 A. Oh, definitely. 23 Q. Do you know whether Dr. Margolit gave 24 her any similar prescriptions? 25 A. I'm sure he did, because he does that A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 17 1 kind of thing. 2 Q. But Dr. Margolit is not a psychiatrist 3 or psychologist; correct? 4 A. No, but he's capable of prescribing 5 those kinds of medications. 6 Q. Normally when you have a patient, do 7 you use only medication or do you use a combination 8 of medication and therapy in your treatment? 9 A. Both. Yeah, both. A patient 10 frequently benefits from education about what -- 11 they don't really understand post-traumatic stress 12 disorder. That makes it worse. You know, so there 13 is a lot of education that goes with it, and that 14 helps them work with the medication better. 15 Q. In your treatment of Ms. Plaintiff, did 16 you ever speak with her son, a Dr. Plaintiff who was a 17 psychologist? 18 A. No, I have not. 19 Q. Are you aware that she was allegedly 20 treated by her son who is a psychologist? 21 A. Well, I think she got counseling in 22 some kind of general way. I don't know whether we 23 can say she was treated by him. But she was -- you 24 know, he was giving out certainly helpful advice. 25 Q. Do you use any certain guidelines in A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 18 1 evaluating a patient with PTSD to determine if they 2 have it, or would you use the DSM, for example? 3 A. Yeah. Religiously we use the 4 guidelines, which are acceptable guidelines, 5 important guidelines. 6 Q. And do those guidelines lay out 7 certain characteristics or qualities that could be 8 exhibited in a person who may have, or be, suffering 9 from post-traumatic stress disorder? 10 A. Right. The guidelines are really 11 symptoms, you know, a collections of symptoms. And 12 so I think there are about 25 symptoms for 13 post-traumatic stress disorder; and, yeah, they are 14 very good, very useful guidelines. 15 Q. Does the patient usually exhibit all 16 of the symptoms of post-traumatic stresb disorder, 17 or any of the disorders that are in the handbook, or 18 is that just a laundry list of some of the things? 19 A. Could you say that over again? 20 Q. Sure. Specifically on post-traumatic 21 stress disorder, the DSM lists numerous @ptoms 22 that can be exhibited by a person that has 23 post-traumatic stress disorder; is that correct? 24 A. Right. 25 Q. And do your patients, or do patients, A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 19 1 from your experience, usually have all those 2 symptoms, or is that just a laundry list and they 3 would have some of the different symptoms? 4 A. Well, people with post-traumatic 5 stress, I think the requirements are that you 6 probably have to have about 14 or 15 out of about 7 25. So to make the diagnosis you have to have about 8 14 of them. So it's more than a laundry list. It's 9 the requirements to make the diagnosis. You have to 10 have enough to make enough of the 25, at least 14 or 11 15, to make the diagnosis. 12 Q. In your experience, do patients 13 usually, or do they ever, have all -- say, there are 14 25 things listed. Do they exhibit all 25? 15 A. That would be rare. 16 Q. About what is common, from your 17 experience, as to the number of symptoms exhibited 18 by someone with-- 19 A. I'd say 15 to 20. 20 Q. Did you do any testing at all on Ms. 21 Plaintiff? 22 A. Dr. Chesno had already done the 23 testing and so that was available to me. 24 Q. Do you recall what kind of testing Dr. 25 Chesno did? A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 20 1 A. Well, he did standard testing and came 2 up with an impression. 3 Q. When you say standard tebting, if you 4 could tell me what the standard testing would be. 5 A. Sure. (Reviewing file.) I thought 6 that he had tested her. But what he sent me was 7 just the treatment summary of his work. I'm a 8 little surprised that there isn't any testing. Wait 9 a second. I guess the referral -- I guess Dr. 10 Chesno's work with her was so short-lived, I guess, 11 8/16 to 8/29. Let's see. 8/22 was the last time 12 that he saw her. So I guess it was on such short 13 notice that he didn't really have her 14 psychologically tested. I thought he had. All I 15 have from Dr. Chesno is the treatment summary of his 16 work. 17 Q. Are there any tests that can be done, 18 with a post-traumatic stress person, to find out, 19 you know-- 20 A. Sure. 21 Q. --if they've got like Gestalt or 22 Rorschach or any kind of test like that that you can 23 do to determine how severe, or the reliability of 24 the PTSD @ptoms? 25 A. Right. There would be such tebts for A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 21 1 that. 2 Q. What would those tests be, for 3 example? 4 A. Let me review my thoughts. Well, I 5 think a test such as sentence-completion test or 6 draw-a-person test, would indicate problems with 7 concentration; startle, like the coordination 8 problems. Certainly the quality of the draw-figure 9 test, fear responses, figure drawings that would 10 depict fear. Rorschach testing, that would indicate 11 fear in the person. In other words, you'd be 12 looking, I think, for fear responses as lot, 13 cognitive problems a lot, levels of anxiety and 14 depression. 15 The Minnesota Multi-phasic Inventory, 16 MMPI, you'd be looking for affect, anxious affect; 17 anger, somatic aspects of anxiety. So you could 18 pick that up in a lot of ways. Supporting evidence 19 could be picked up by psychological testing. 20 Q. And those tests could help you or 21 assist you in determining the severity of the PTSD? 22 A. That testing would not help me at all, 23 because I know that by just talking and looking and 24 listening. That would not be helpful to me. 25 Q. To you, you mean to you in your A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 22 1 diagnosis? 2 A. No, would not be helpful. 3 Q. Do you usually do those kind of testb? 4 A. No, I do not. 5 Q. Do not? 6 A. Huh-uh. 7 Q. I'm going to show you what's been 8 marked as Defendant's Exhibit Number 1, which is 9 labeled July Ilth, 1994, and it is regarding Ms. 10 Plaintiff. It appears to be your analysis of your 11 first appointment with Ms. Plaintiff. I'd like to show 12 it to you and see if you recognize that. 13 A. Sure. Sure. That's my report. 14 Q. Thank you. 15 And you made this report after your 16 first visit with Ms. Plaintiff? 17 A. Right. My standard practice is that 18 within 24 hours I write that up, handwritten, and 19 then it's typed up. 20 Q. Is this report based on your meeting 21 with Ms. Plaintiff alone, or is it based on your 22 meeting with Ms. Plaintiff and a combination of the 23 information you got from Dr. Chesno and Dr. Margolit 24 regarding Ms. Plaintiff? 25 A. It would be just my information I A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 23 1 picked up in the interview situation. 2 Q. Tell me generally what you do in a 3 first consultation with a client. What kind of 4 information do you try to get to help in your-- 5 A. Well, right. The interview is 6 organized, you know, the first part -- Yeah, right. 7 The interview goes along these lines. Like the 8 first part will be like, you know, what is bothering 9 you, how are you feeling, how have you been feeling, 10 I understand you are not feeling well. You know, 11 what's going on with your feelings. And that's a 12 whole big area. okay. And that's kind of what this 13 is. Since I knew that she had been in Amtrak, you 14 see, so I'm headed down the trail with all these 15 complaints, because I know, you know, what this 16 disorder is like and so I'm all ready to ask, do you 17 feel -- for instance, are you irritable, do you have 18 problems with irritability, or stress intolerance, 19 or do you have nightmares. I just know all that 20 stuff so I just go through that real fast. 21 And then I go into the history. The 22 second part of the interview is going through the 23 history of the trauma, because the trauma has caused 24 all of these feelings and emotional problems and 25 mental problems. So I go into the incident itself A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 24 1 as the cau5dl factor, the triggering factor. And I 2 also ask, have you had any preceding mental illness, 3 have you ever been in earlier accidents, which is 4 always helpful to know, because some people have 5 been in many accidents. 6 You ask about drug, alcohol abuse, and 7 you ask just a lot of standard -- their marriages or 8 their living situations, and their ability to 9 function before and after the episode of illness, 10 whether it's traumatic post-traumatic stress 11 disorder or whether it's some other mental disorder. 12 You ask the level of function before and after, and 13 you go into the past history. 14 And then you get into a mental status 15 examination, where you can pull together their -- 16 the way they present themselves, the way -- some 17 people are nervous and depressed, excitable, easily 18 startled. They're logical, coherent, whether they 19 have any perceptual disorder, organic symptoms. 20 Then you come up with a clinical impression and 21 treatment recommendations. So that's just a 22 standard. 23 Q. So that's kind of standard? This is a 24 standard report of what is typical that you do in 25 the first-- A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 25 1 A. In one hour, yes. 2 Q. And the mental status examination 3 portion, that is basically your impression of the 4 client? 5 A. No. The mental status examination 6 supports -- see, the whole sequence is building up 7 towards a diagnosis. So the mental status 8 examination is really the last part. It's all 9 organized in such a way that you come up with a 10 clinical impression. And the mental status 11 examination is supposed to support what she's 12 telling you, or what the patient is telling you, and 13 the history that they gave you. It's a very 14 supportive piece, you see. 15 Q. And basically is it your tebtimony 16 that the way you get this information, you have 17 certain questions that you ask, that you go through 18 and ask the client about their complaints, their 19 history, in order to gain this information and 20 prepare this report? 21 A. Exactly. 22 Q. And in asking those questions, under 23 the chief complaint section, Ms. Plaintiff responded by 24 telling you that she had nightmares and visual 25 flashbacks; is that correct? A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 26 1 A. Uh-huh. 2 Q. Is that a common symptom of 3 post-traumatic stress disorder? 4 A. Very, very, very common. 5 Q. Typically, how long do the nightmares 6 and visual flashbacks continue after that traumatic 7 event? 8 A. Variable. As you know, people in 9 Vietnam are still having flashbacks and trauma, so 10 variable. 11 Q. What is that-- 12 A. Excuse me. 13 (Interruption) 14 BY MS. ROGERS: 15 Q. I think when we dropped off, we were 16 talking about the nightmares and the flashbackb. 17 A. Right. 18 Q. And I waB asking you how common that 19 is for that to continue on a regular basis. 20 A. Variable. Variable. 21 Q. What does that vary on? The 22 individual or the severity of the trauma? Or all of 23 the above? 24 A. I'd say both, yes. 25 Q. Typically, how frequently does the A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 27 1 normal, or the usual, PTSD patient, how frequently 2 do they have these nightmares and flashbacks? Is 3 this an everyday occurrence? Weekly? Monthly? 4 A. Generally if the trauma is severe, you 5 know, it would be daily for anywhere from a week to 6 a couple of weeks, and then maybe like every other 7 day, you know. So, I mean, generally the nightmares 8 start going away within a month or so. Start going 9 away. They may continue periodically for many, many 10 months, periodically. 11 Q. Over the years, generally, as the 12 traumatic event becomes more remote, do the symptoms 13 of PTSD become less frequent? 14 A. Yes. That's generally the trend. 15 Q. So nightmares, flashbacks, things of 16 that nature would become less frequent as the event 17 became more remote? 18 A. Definitely. 19 Q. Did you counsel Ms. Plaintiff about any 20 thought-blocking techniques? 21 A. I don't do that. I mean, I'm not a 22 behaviorist, although I believe in it. But she 23 knows and I knew that she would have intrusive 24 thoughts about the accident; and so in my work with 25 her, I did tell her to keep busy, stay busy and get A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 28 1 her mind on other things. And so to that extent I 2 encouraged that. 3 Q. How long would the intrusive thoughts 4 about the accident in your -- normally how long 5 would those continue? 6 A. In a very serious accident, I would 7 say they disappear more slowly than the nightmares, 8 and generally they will persist as a major problem 9 for -- again, a major accident, major thought 10 intrusion -- I'd say a couple of months, that then 11 they would start to go away. They kind of follow 12 the nightmares. I think as the brain settles down 13 more, then the intrusive thoughts start being less 14 of a problem. 15 Q. Just generally speaking from your 16 experience, one who is involved in an accident like 17 Ms. Plaintiff, a serious train or car accident in which 18 people were killed, how long does it take that 19 individual to start getting rid of some of these, or 20 getting better from some of these post-traumatic 21 stress symptoms? 22 A. It depends on how quickly they are 23 treated. If you go untreated -- and, see, she was 24 untreated for a long time, in terms of the 25 medication side of it. Medication is really A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 29 1 important in terms of treatment. So she Wa5 2 untreated. 3 Dr. Margolit may have given her 4 something here and there, but I don't think she had 5 any aggressive treatment until I came along. And BO 6 that means that her recovery is -- her recovery has 7 been compromised by the fact that she didn't get 8 early treatment, early intervention; and I think 9 that's one of the reasons she's not as well as she 10 could have been. 11 Q. When you say treatment, you mean, 12 what, seeing a psychiatrist? 13 A. Medication. Appropriate, aggressive 14 use of medication is so important in this disorder, 15 otherwise you've got chronic -- I've got lots of, I 16 can't say lots. But I've treated -- I don't have 17 lots of chronic post-traumatic stress disorder 18 currently, but I've had lots of post-stress over the 19 years, and a lot of them become -- they're no longer 20 acute, they are chronic, because they have not been 21 appropriately treated. 22 Q. Is seeing a psychologist, in your 23 opinion, without medication, would that be 24 appropriate treatment? 25 A. I think that would be not standard A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 30 1 treatment. 2 Q. What is the difference basically 3 between your treatment of Ms. Plaintiff and what like a 4 psychologist, Dr. Chesno, or some psychologist could 5 do? 6 A. The big thing is the biological 7 intervention that a psychiatrist can give, you see. 8 I mean, people are depressed, angry, anxious, 9 fearful. That needs to be treated with medicine. 10 Q. So one of the main differences would 11 be you, you are an MD, meaning you can prescribe 12 medication whereas a psychologist cannot? 13 A. Right. Right. 14 Q. You note again in your report, in the 15 chief complaint section, that Ms. Plaintiff had 16 startled reflex. Explain to me what that is. 17 A. Easily startled when somebody 18 approaches her from the side or back. 19 Q. Is that a typical symptom? 20 A. Very standard. Very standard. That 21 comes under the category of neural excitability, 22 because the brain has been jarred; and they have a 23 whole sequence of neural excitable symptoms like 24 agitation, irritability, intrusive thoughts, anger, 25 rages, startled reflex, sensitivity to noise and A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 31 1 light. Those are all neural excitable symptoms. 2 You need to suppress those with tranquilizers. 3 Q. If they are suppressed with 4 tranquilizers, does the startled reflex generally 5 improve with time? 6 A. It will go away. 7 Q. How long does that generally take? 8 A. I think if you have aggressive 9 treatment, we'll say, fresh after an accident, 10 within weeks, within, say, a few day5 to a couple 11 weeks. If you are aggressively giving them 12 medication, you can get rid of a lot of that pretty 13 fast. But if you are going to wait months and 14 months and months, then that's a different problem, 15 you see. 16 Q. Does time alone help at all, just the 17 fact-- 18 A. Nature? 19 Q. Yes. 20 A. Yes, it does. 21 Q. That you're remote from the incident? 22 A. Yes. See, a problem in her situation 23 iB the train runs by her home, reactivates it. 24 That's a technical -- she can hear the train. It's 25 a different train obviously, but it'B the same train A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 32 1 line within hearing distance of her. That activates 2 the nightmares at night. I mean, she still has 3 nightmares because she hears the train going by, the 4 train that she was on. That makes it real 5 difficult. 6 Q. Have you advised her as to how to deal 7 with that? 8 A. I've only worked with her two times 9 since the evaluation. I don't know how to address 10 that. That's a problem. I think sleeping pills are 11 indicated, you know, for a whole. But I think as 12 she gets better in general, and she is better, you 13 know, I think the nightmares -- did I say the 14 nightmares are less? 15 Q. I believe you did. 16 A. Yeah. I think even with the little 17 treatment I've been doing -- let's see what I said. 18 Sleeping better. See, she's better even with the 19 little treatment I've been doing. So I would be 20 optimistic, you know, that she will get better and 21 become functional again. 22 Q. Is that typical for post-traumatic 23 stress disorder to have a triggering event like 24 hearing a train to bring back memories of the event? 25 A. Very typical. A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 33 1 Q. And you gave her sleeping pills to 2 help her at night, to sleep through the train-- 3 A. That's right. 4 Q. And that seems to be having some help? 5 A. Uh-huh. 6 I'm going to have to go shortly. 7 Q. Okay. From your recollection, what is 8 her sleep pattern, or how has her sleep pattern been 9 disturbed by the post-traumatic stress disorder? 10 A. Well, multiple awakenings, trouble 11 going off to sleep, just staying asleep, nightmares. 12 Q. Is that typical? 13 A. Right. 14 Q. Is that typical that this would be 15 continuing at this point in time, meaning three 16 years after the accident? 17 A. Well, she's been untreated, you know, 18 and the train still goes by, you know. So those two 19 factors make -- she's been untreated and the train 20 still goes by, so that makes it difficult for her to 21 get over the nightmares. 22 Q. You also note in here that she has new 23 fears of riding in airplanes and cars. 24 A. She's become phobic about it. 25 Q. Is that something you find as a common A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 34 1 response? 2 A. Very common. 3 Q. In PTSD? 4 A. Right. Very common. 5 Q. How do you treat that? With a 6 medication? 7 A. Well, the primary treatment is drug 8 treatment; and so, hopefully, as her brain quiets 9 down with medication, she'll be less phobic and less 10 fearful in general, less phobic, able to drive 11 herself, able to stay home by herself. 12 Q. Do you know whether she is driving now 13 at this point? 14 A. I think she is driving maybe around 15 her neighborhood. I'm pretty sure she is. 16 Q. Do you know whether she plans to fly 17 when she goes on her cruise? 18 A. I have no idea. 19 Q. You note in your records that she lost 20 weight. Did you have any records that showed you 21 that, or was that-- 22 A. Self-report, self-report. Yeah. 23 Q. And most all these things in your 24 report: The insomnia, the nightmares, the 25 headaches, the fears, those all come from what Ms. A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 35 1 Plaintiff told you? 2 A. Right. Self-report. 3 Q. Did Ms. Plaintiff tell you that she had 4 been in a car accident several years ago? 5 A. She may have. I don't recall that 6 offhand. 7 Q. Would that be a traumatic event that 8 could cause some post-traumatic stress symptoms? 9 A. It could have been. 10 Q. Did you find any other previous 11 history that would predispose Ms. Plaintiff to suffer 12 from post-traumatic stress disorder? 13 A. No, I didn't. 14 Q. What is your medical opinion as to the 15 diagnosis, or your diagnosis of Ms. Plaintiff's 16 condition? 17 A. Right. She has post-traumatic stress 18 disorder. 19 Q. And what information, or what is the 20 basis for that opinion? 21 A. Based upon my evaluation and even 22 treatment. I'm sure about the diagnosis, because 23 she is responding to my treatment of it. 24 Q. And you received that information from 25 talking to Ms. Plaintiff; is that correct? A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 36 1 A. That's right. 2 Q. And, in your medical opinion, what is 3 the cause of Ms. Plaintiff's present condition? 4 A. Right. The Amtrak train accident. 5 Q. In your medical opinion what is Ms. 6 Plaintiff's prognosis? 7 A. I would say good, with proper 8 treatment. 9 Q. And how long do you foresee this 10 treatment would continue? 11 A. I don't know. The fact that she's 12 getting some better -- and I don't think she's very 13 far from being a lot better. I can't say she's a 14 lot better. She certainly is some better. And I 15 think with continued treatment she can get a lot 16 better, you know, and not need treatment. Now, that 17 might mean two months, it might mean six months. I 18 would think that by the end of six months it would 19 be finished. 20 Q. When you say treatment, do you mean, 21 again, continuing with therapy and medication; is 22 that right? 2 3 A. Yeah. That's right. 24 Q. Do you know from your history of Ms. 25 Plaintiff when she began to experience the PTSD A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 37 1 symptoms? 2 A. Almost immediately after the accident, 3 with the nightmares and agitation and depression. 4 She saw dead bodies. That made quite an impact on 5 her. 6 Q. How have her symptoms changed over the 7 last three years? 8 A. Not much. I don't think they have 9 changed much. 10 Q. You noted in your report that there 11 wasn't any thought disorder present. 12 A. Right. 13 Q. Can you tell me what that means? 14 A. It means like schizophrenia, illogical 15 or incoherent. 16 Q. I think you noted, though, that there 17 was a perceptual disorder, and what would that mean? 18 A. Fears, projections. I don't know 19 whether I would call her paranoid or not. I don't 20 know whether I would say that. But fears and 21 projections. 22 Q. How did you determine she had that? 2 3 A. I asked her. 24 Q. Talking with her? 25 A. Uh-huh. A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 38 1 You asked her? Okay. 2 Has Ms. Plaintiff been following your 3 treatment plan? 4 A. Very carefully. 5 Q. So she's been taking her medication? 6 A. Yes. 7 Q. And she's continued to see you? 8 A. Yes. 9 Q. Does she have another appointment to 10 see you? 11 A. Yes, she does. 12 Q. Has she kept all her appointments with 13 you? 14 A. Yes, she has. 15 Q. Do you feel Ms. Plaintiff will continue 16 to improve over time? 17 A. Yes, definitely. The prognosis is 18 very good for her because she's been a healthy 19 person to begin with, see, and the people who get 20 mostly all better, or all better, are people who 21 have been healthy to begin with. So we have good 22 reason to be optimistic. 23 Q. Let me review my notes quickly. 24 How would you rate, or characterize, 25 the severity of this stressor, or the train A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 39 1 accident, this traumatic event, in terms of your 2 analysis, you know, of post-traumatic stress 3 disorder? How does this rank or rate in severity? 4 A. I would say moderately severe. I 5 would not say extremely severe. I would not say 6 severe. I would say moderately severe. It's more 7 than moderate. 8 Q. Would you characterize this as a 9 predominantly acute event? 10 A. It's acute. It's moving into chronic. 11 I'm still optimistic that with aggressive treatment 12 we can get it mostly to go away; but, again, it's 13 been untreated for awhile. She's moving towards 14 chronic if we don't get on the ball and do 15 something. 16 Q. In your opinion, how would you rate 17 her level of functioning at the time of your 18 evaluation? 19 A. Level of functioning, do I have that 20 written down anywhere? I'm just kind of wondering. 21 I think with her, let's see. 22 (Interruption) 23 (Reviewing files.) I'm sure she can 24 do activities of daily living, even before she came, 25 like cooking, cleaning. I don't think she was that A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 40 1 bad off. But when it cdme to social functioning, 2 like driving, getting groceries, that is where her 3 functioning -- that, I would say, was moderately 4 severe to severe, that kind of functioning. 5 Q. Meaning what? She couldn't drive by 6 herself or get groceries by herself? 7 A. Right. That's right. 8 Q. Do you use the global assessment of 9 function scale? 10 A. I do. 11 Q. Did you make any ratings on that-- 12 A. I didn't do that. 13 I'm going to have to go. 14 Q. Okay. Just one minute. Let me make 15 sure there is nothing else. 16 Can you tell me any resources or 17 treatises that are generally recognized to be used 18 by people like yourself for expertibe on 19 post-traumatic stress disorder? 20 A. The American Psychiatric Association 21 has standard papers on many disorders that we are 22 familiar with, and they do have a standard paper on 23 post-traumatic stress disorder and its treatment. 24 Q. Is there any other treatise or 25 anything that would be relied on by a psychiatrist? A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 41 1 A. As dominant in the field, I would not 2 know that. 3 Q. In your opinion, does Ms. Plaintiff have 4 the cognitive and emotional resources to improve her 5 emotional adjustment for her situation? 6 A. Does she have the cognitive resources 7 to improve. Not without medication. 8 Q. In your opinion, would Ms. Plaintiff be 9 better at this point if she had had treatment 10 immediately following the accident? 11 A. Yes. Yes. 12 I'm going to have to go. 13 Can I ask you a couple more? I'm 14 almost done, I promise. 15 MR. COOK: I'm not going to have any, 16 unless something surprising-- 17 BY MS. ROGERS: 18 Q. Are there any outward manifestations 19 of post-traumatic stress disorder, okay, meaning 20 other than the recorded symptoms to you about 21 nightmares and other things? Are there any outward 22 manifestations we can see like the weight gain, 23 weight loss, anything else like that? 24 A. I would say her startled reflex, as 25 she reports it. Her irritability. Those are A. WILLIAM ROBERTS, JR., & ASSOCIATES FRANK FORSTHOEFEL, M.D. - DIRECT BY MR. ROGERS 42 1 visible things. 2 Q. Do you have any way of telling whether 3 a person is exaggerating any kind of post-traumatic 4 stress disorder symptoms? 5 A. Right. Well, that gets back to the 6 credibility issue, and, you know, I do not get the 7 idea that she's hysterical or exaggerating. I think 8 her credibility in her self-reporting is accurate. 9 Q. Do you have a way to judge that? Is 10 there any way a psychiatrist can judge, other than 11 deciding if a person is credible? 12 A. There would be a lie index on the 13 MMPI, but I didn't think that was appropriate. 14 Q. Okay. 15 A. Adios. 16 MS. ROGERS: We can stop it. How 17 about we stop it now, and then just if I look and 18 see if there is any reason to reconvene, we can 19 reconvene. I need to look at this. I don't want to 20 be rushed. We can stop now and then if we need to, 21 we'll reconvene. 22 THE WITNESS: I'd be happy to. My 23 pleasure meeting you. 24 (The deposition was adjourned at 5:10 25 P.M.) A. WILLIAM ROBERTS, JR., & ASSOCIATES 4 3 CERTIFICATE 2 3 I, Janet L. Anderson, certified 4 Court Reporter, and Notary Public for the State of 5 South Carolina at Large, do hereby certify: 6 That the foregoing deposition was 7 taken before me on the date and at the time and 8 location stated on page 1 of this tranbcript; that 9 the deponent was duly sworn to testify to the truth, 10 the whole truth and nothing but the truth; that the 11 testimony of the deponent and all objections made at 12 the time of the examination were recorded 13 stenographically by me and were thereafter 14 transcribed; that the foregoing deposition as typed 15 is a true, accurate and complete record of the 16 testimony of the deponent and of all objections made 17 at the time of the examination. 18 I further certify that I am neither 19 related to nor counsel for any party to the cause 20 pending or interested in the events thereof. 21 22 23 24 25 A. WILLIAM ROBERTS, JR., & ASSOCIATES 44 1 Witness my hand, I have hereunto 2 affixed my official seal this 9th day of September, 3 1994, at Columbia, Richland County, South Carolina. 4 5 6 n 7 et L. Anderson, 8 ary Public, te of South Carolina 9 Large My Commission expires September 8, 1996. 10 11 12 13 14 15 16 17 18 19 2 0 21 22 23 24 25 A. WILLIAM ROBERTS, JR., & ASSOCIATES 45 I N D E X 2 Page 3 Stipulation 3 4 DIRECT EXAMINATION 5 By Ms. Rogers 3 6 Reporter's Certificate 43 7 8 9 10 E X H I B I T S 11 Page Identified 12 DEFENDANT 1 Two-page report 3 13 14 15 16 REOUESTED INFORMATION INDEX 17 18 (No additional information was requested.) 19 20 21 22 23 24 25 A. WILLIAM ROBERTS, JR., & ASSOCIATES P.C. FRANK E. FORSTHOEFEL. M.D. JUL DEFE F-SYCHIATRY 1333 Plaintiff ST.. SUITE 3F' COLUMBIA. SO. CAR. 29201 fi E TCL".O@E 256-2748 July 11, 1994 Page 1 of 2 RE: Plaintiff Source of Referral: Mrs. Plaintiff is a 65 year old ivorce mo@@her o@@ @@hree children, who 4-s referred by Mr. FranciS Hajek, Attorney at Law, for a psychiatric evaluation and treatment. Chief Complaint: Mrs. Plaintiff complains of post traumatic stress symptoms including nightmares and visual flashbacks of the train accident, intrusive thoughts about the accident with failure to block out these thoughts, headaches, fears, increased star@@le reflex with new fears of riding in air- planes and cars, irritability, loss of interest and pleasure, distancing and emotional withdrawal, stress intolerance and depression. She said that she ate poorly and lost some twenty pounds. She said she experienced considerable insomnia, when awakened twice nightly with the passage of the PIITRACK train with associated feelings of helplessness and hope- lessness and ideas and impulses to jump out of her secon-I story home. Present History: Mrs. Plaintiff stated that she had been in good mental health and denied any antecedant psychiatric historn, prior to the tragic stress as described below. @Irs. Plaintiff said that she was one of the survivors of the A@ITRACK train wreck, which occurred in August 1991 near-Columbia, S.C. She sa4-d she witnessed several deaths and renembered vividly a man bleeding to death as he pleaded for help. Since she experienced this tragic event and witnessed the horror of the event, she has experienced an unremitting, untreated psychiatric disorder, which has worsened since February 1994 for unknown reasons and which has altered her life style. She said she rarely drove or stayed alone and could no longer connect very well -xith her children and friends. She admitted that the proximity to the train tracks resurrected twice nightly the teagic events that she experienced on these same tracks three years ago. She stated that her fear, agitation and reduced frustration tolerance secondary to the traumatic stress had caused a first time ulcer now being treated with Tagamet. She denied any drug or alcohol abuse and denied any arte@edant psyciiiatric problems. She had seen herself, prior to the accident, as a happy, well adjisted woman with good, clc>se relationships with her children and friends. 0 1 0 1 5 5 FRANK E. FORSTHOEFEL. M.D. PSYCHIATRY 1333 T^YLOR ST, SUITE 3F COLUMBIA. SO. CAR. 29201 TELEP.ONE 256-2748 July 11, 1994 Page 2 of 2 RE: Plaintiff Past History: Mrs. Plaintiff said that she was one of a number of children born into a happy family with the early death of her father, when she was 13 years of age. She said she had few memories of him. She denied any childhood abuse, fears, worries, bad experiences nor trouble with authorities nor with school. She admitted to dropping out of the 9th grade, which was customary at that time. Mental Status Examination: Mrs. Plaintiff presented herself as an alert!- pleasant, dtst-ressed, nervous woman who spoke and behaved in a fashion appropriate to her age and background. There was no evidence of any thought disorder but evidence of a perceptual disorder with reported flashbacks. There was evidence of reported fears and other post traumatic stress signs. There was no evidence of any suicidal ideation at the time of the interview. Clinical ssion.- Axis I: Post Traumatic Stress Disorder Recommendations: 1. Ativan .5 mg. po qid for stress and fear symptoms and other neuroexciteable symptoms. 2. Zoloft 50 mg. po qd for depression. 3. Ambien 10 mg po hs for insomnia. 4. Regular outpatient vi.sits to which she has agreed. Thank you. Frank E. Forsthoefel,M.D. FEF:aag cc: Mr. Francis Hajek, Esq. File 0 1 of 5 6