5737
1
THE COURT:
2
MR. WAKEFIELD:
3
THE COURT:
4
Sure. No objection.
1518 is admitted.
(Ex. No. 1518 admitted)
5 6
DIRECT EXAMINATION
7 8
BY MS. KOEHLER: Q.
9 10
Good morning, sir.
Can you state your name for the
record, and give us your business address? A.
11
Mark Chapa, and I'm not sure what you mean by business address.
12
Q.
Just the address of where you work.
13
A.
I work at various different stations across the city,
14 15 16
eight different ones. THE COURT:
Who is your employer, sir?
employer?
17
THE WITNESS:
18
THE COURT:
19
THE WITNESS:
20 21 22 23 24 25
Who is your
Seattle Fire Department. Do you know what their address is? It's, I guess, 300 Third Avenue.
I
don't know the exact address. THE COURT: address.
It's the Seattle Fire Department
We've got it.
MS. KOEHLER: technicality. THE WITNESS:
Okay.
Thank you, your Honor. We always get an address. Okay.
KEVIN MOLL, CSR
(206) 477-1584
It's just a
5738
1
BY MS. KOEHLER:
2
Q.
So can you tell us what your job title is?
3
A.
Firefighter/paramedic.
4
Q.
And I'm going to just go a little bit through your
5
history, and then I'm going to have a few questions for
6
you.
7
A.
Okay.
8
Q.
Sir, can you tell us your educational employment
9 10
history, so we can have a snapshot of your background? A.
Sure.
I have a high school degree, a bachelor's degree
11
in neurosciences from the University of Houston.
12
been an EMT for 18 years now, and a paramedic now for
13
almost eight years.
14
Q.
15 16
I've
Can you just, for our purposes, explain to us the difference between a medic and an EMT?
A.
So you have an EMT basic, so that every firefighter in
17
the Seattle Fire Department is an EMT basic.
18
trained in basic first-aid, CPR.
19
They are
The next level above that is EMT/paramedic.
We're
20
trained to give medicines, start IVs, recognize
21
arrhythmias or cardiac problems, read EKGs, and that
22
kind of what separates us from the EMT basic.
23
Q.
All right.
And we heard from Lieutenant Fisk before,
24
and he explained that all EMTs are trained for King
25
County at Harborview; is that correct? KEVIN MOLL, CSR
(206) 477-1584
5739
1
A.
Correct.
2
Q.
Okay.
3
Well, we're here to talk about September 24,
2015.
4
At the time that you responded to this call, had you
5
responded to an MCI before?
6
A.
No.
7
Q.
At this time we've already gone through background on
8
MCIs, but were you aware that this was going to become
9
an MCI as you were travelling?
10
A.
Yes.
We were first dispatched to a single motor
11
vehicle accident which, en route, we believed was just
12
going to involve two vehicles, which we go to quite
13
frequently, but en route it got upgraded to an MCI
14
response.
15
Q.
And who were you travelling with?
16
A.
My partner was driving.
17 18
His name is Paramedic Carl
Gordon. Q.
And can you just tell us the roles that you have when
19
one of you is driving, one of you is not driving, and
20
how does that affect your response in a situation?
21
A.
So we kind of separate.
We switch off throughout the
22
day, or midway through the day, through roles.
23
morning Carl started off driving, and they're usually
24
designated as the skills person, so they'll start the
25
IVs, place an airway, if needed. KEVIN MOLL, CSR
That
They're kind of the
(206) 477-1584
5740
1
facilitator of the treatment, and I'm sitting in the
2
officer's seat, on the passenger seat of the ambulance,
3
and I'm kind of the one that initiates the treatment
4
plan and makes communications with the doctor and the
5
hospitals.
6
Q.
When you arrived at the scene, just take us through
7
what you did initially, before you started actually
8
giving any hands on -- hands on with any patient.
9
A.
We approached the incident from the north, on Aurora,
10
and, coming onto the bridge, I realized that I wanted
11
to keep civilian traffic from blocking the north end of
12
the bridge, so I requested from our dispatch to notify
13
the police department to block access to protect our
14
egress, or our potential transportation corridor, so
15
that we could get patients off the bridge.
16
As we pulled up adjacent to the incident, I first
17
noticed several patients laying on the roadway, and
18
then got out of the vehicle and kind of assessed the
19
scene in front of me.
20
Q.
So am I correct that you were the first medic on scene?
21
A.
For a very short time, maybe 30 seconds, 40 seconds,
22 23
and then the second medic unit arrived. Q.
What is the significance of if you're the first unit to
24
arrive, then what is the significance in terms of your
25
vehicle placement? KEVIN MOLL, CSR
(206) 477-1584
5741
1
A.
I would -- well, some of the things we look for is not
2
to block access for the heavy rescue trucks that come
3
in, and when we placed the -- when Carl pulled up, I
4
think he wanted to just get close to the scene and
5
leave access for the trucks.
6
Q.
Without having -- well, would you mind showing us where
7
your vehicle is?
8
microphone, so you could just tell us where the vehicle
9
is, and maybe just show us where you -- what you did
10 11
I'm going to give you a pointer and a
initially. A.
So I was the officer in medic 16.
This is medic 16,
12
right here.
13
room for somebody to get about by if they needed to,
14
but, also, since we had the initial patients that I
15
encountered were kind of in this area, wanted us to
16
kind of protect them by placing a vehicle between them
17
and any potential traffic that was going to come up
18
behind us.
19
Q.
All right.
So Carl parked here so we could leave some
Thank you very much.
Before you get up,
20
could you just show us on Exhibit Number 2, which is
21
the MCI diagram, can you just show us the significance
22
of the transportation corridors, because I know that
23
you worked a lot in that area?
24
how those work for us?
25
A.
Sure.
Could you just explain
I worked in the north transportation corridor. KEVIN MOLL, CSR
(206) 477-1584
5742
1
So I'm just kind of shuttling patients from the
2
treatment area to the ambulances that were --
3
eventually they ended up staging closer, but here
4
they're still quite a ways away.
5
Q.
Thank you, sir.
Now, shortly after, like you said, 30
6
seconds after you got there, was it -- who then became
7
the medical coordinator?
8
A.
9
Initially I was the medical group supervisor, and then medic 18 arrived.
We discussed the next course of
10
action, what needed to happen.
11
Paramedic Pat Kyles about the need to get a better
12
count of our patients, and to do that he needed to
13
enter the bus.
14
I had a discussion with
And then as he was relaying the updated patient
15
count, that's when I was relieved by my superior
16
medical safety officer, Lieutenant Fisk.
17
Q.
And then what role did you then take on?
18
A.
I was assigned as an aide to the transportation leader,
19
which is a Lieutenant Aman.
20
Q.
What specifically were you aiding?
21
A.
Kind of a facilitator, moving patients from the
22 23
treatment area into the ambulances for transport. Q.
So in facilitating the movement from -- and that would
24
be the patients in the red or yellow zones into
25
ambulances; am I correct? KEVIN MOLL, CSR
(206) 477-1584
5743
1
A.
I'm sorry, could you repeat?
2
Q.
I'm sorry.
3
That would be the patients that were in the
red or yellow zones?
4
A.
Correct.
5
Q.
How did you facilitate?
6 7
What was your -- how did your
job function, facilitating that? A.
Kind of prioritizing as the patients were coming out of
8
the treatment area to the transportation area, which
9
one would go first and next, and so forth.
10
Q.
And then in determining which patient would be number
11
one, number two, and number three, and you're out in
12
the field like this, how did you make those decisions,
13
just procedurally first, before we go on to specifics?
14
A.
We kind of triage patients, we kind of use a sick/not
15
sick model.
16
are they conscious, are they unconscious, their
17
respirations, are they breathing, not breathing, are
18
they breathing fast or slow, their pulse rate, fast,
19
slow, threading, their skin color, like are they pale,
20
sweaty?
21
To determine a sick patient, we look at
It only takes 10, 15 seconds.
The initial patients that are coming out of the
22
treatment area are all what we would categorize as red,
23
sick patients that needed immediate care or transport.
24
But we had various levels of red, some worse than
25
others. KEVIN MOLL, CSR
(206) 477-1584
5744
1
Q.
Let's start with the worse than others.
That's pretty
2
much what we're going to talk about during your
3
testimony today.
4
time that you got there, how long did it take for
5
ambulances to arrive so that you could begin to
6
transport patients off of the bridge?
And I would like to ask you, from the
7
A.
I can't remember the exact time.
8
Q.
Am I correct that you couldn't transport patients until
9
the ambulances arrived?
10
A.
Correct.
11
Q.
So tell us, if you would be so kind, as to the first
12
patient that was brought to you, I guess, would be
13
priority number one.
14
A.
The first patient that was brought to the
15
transportation area from the treatment area was a young
16
female.
17
brought to me on a backboard.
18
Q.
19
She had severe trauma to her face.
That's fine.
She was
Sorry.
When you say, "severe trauma to the
face," what does that mean?
20
A.
It appeared that she had a skull fracture.
21
Q.
Could you see it?
22
A.
Well, I could see that the front of her face was
23 24 25
deformed. Q.
When that patient came to you, did you think that that was, indeed, a high red, number one priority type of KEVIN MOLL, CSR
(206) 477-1584
5745
1
patient initially?
2
A.
She was definitely red, but unstable, very unstable.
3
Q.
Once you triage, once you assess, I mean, are you done
4
assessing, or do you continue assessing?
5
A.
As far as the same patient, or other patients?
6
Q.
The same or other patients.
7
A.
Both.
So she was brought to me, and the first
8
ambulance at that point -- the crew from the first
9
ambulance had arrived, but their apparatus, their
10
ambulance, was what I deemed too far of a distance to
11
transport this patient to the back of the ambulance.
12
requested that they bring the ambulance closer.
13
Q.
Did they move the ambulance closer?
14
A.
Yes, and --
15
Q.
And as they were moving the ambulance closer, did they
16
-- once they finished doing that, did you authorize
17
patient number one to be loaded onto the ambulance?
18
A.
No.
I
At that point patient number two had been brought
19
out, so I had two patients, one ambulance, and I had to
20
make a quick decision, a reassessment of priority, and
21
I deemed that the second patient had a better chance at
22
making it to the hospital alive.
23
Q.
All right.
When you have to make that type of a
24
decision, basically, a life and death decision, how do
25
you do that? KEVIN MOLL, CSR
(206) 477-1584
5746
1
A.
2
THE COURT:
3 4
I'm not understanding you. What criteria do you use?
How do you
figure it out? A.
I figure that the first patient wasn't going to survive
5
the possible ten-minute ride to the hospital without
6
some further treatment, so I thought that patient
7
number two, with a little bit of treatment that I did,
8
would survive the ride to the hospital.
9
BY MS. KOEHLER:
10
Q.
All right.
Let's talk about patient number two then,
11
and that's who we'll be talking about for the rest of
12
your testimony today.
13
As best as you can recall, and I know that documents
14
were suspended for you, can you tell us how you treated
15
patient number two?
16
A.
She had a large, open wound, to her lower extremity.
17
don't remember which, left or right.
It was bleeding
18
freely, so I stopped to bandage it with a tourniquet,
19
and that was the extent of the treatment.
20
Q.
Do you know, where was the tourniquet applied?
21
A.
On her leg, her lower extremity.
22
Q.
Did that slow down the bleeding?
23
A.
Yes.
24
Q.
Was the amount of blood that was being lost
25
significant, before you applied the tourniquet? KEVIN MOLL, CSR
(206) 477-1584
I
5747
1
A.
2 3
Well, she had been deemed a red patient, so it was concerning, yes.
Q.
4
Once you were able to apply the tourniquet, what else did you do with respect to that patient?
5
A.
I told the ambulance crew to get going to the hospital.
6
Q.
All right.
What is your -- so what would be your
7
involvement from the time that the patient comes to you
8
and then you're deciding that's going to be the first
9
person to leave the scene, do you actually help carry
10
them?
11
get into the ambulance once you released the
12
tourniquet?
13
A.
How does that physically -- how did that person
They're being carried by a combination of firefighters
14
and AMR employees.
15
most part.
16
Q.
I'm mostly facilitator, for the
And the fire department works -- tell us about your
17
role as fire department/transportation assistant.
18
do you know the AMR people?
19
with them?
20
A.
How
What's your relationship
AMR's the company that the City of Seattle contracts
21
for our ambulance transports for our low level injuries
22
and illnesses.
23
Q.
24 25
All right.
And do you -- did you take any records, any
documentation, that you kept in this case? A.
For patient number two? KEVIN MOLL, CSR
(206) 477-1584
5748
1
Q.
Right.
2
A.
No.
3
Q.
Did you view at all the documentation for the AMR?
4
A.
No.
5
Q.
The only thing I'd like to do for us, for AMR purposes,
6
and this would be the next exhibit, is just look at the
7
times, since you didn't create this document.
8
So am I correct, under Exhibit Number 1518, that the
9
call for AMR, at least, was received at 11:18,
10
23 seconds?
11
A.
That's what it says.
12
Q.
And then it says, "at the scene."
13
Is that when they
had arrived at the scene, was 11:40?
14
A.
This is not a document that I'm familiar with.
15
Q.
All right.
Do you know how long it took from the time
16
you arrived at the scene until the time that patient
17
two was transported to Harborview?
18
A.
No.
19
Q.
After patient number two was gone, just tell us
20
generally what happened with you and the scene for the
21
rest of the afternoon.
22
A.
I kind of repeated the same thing maybe a dozen times.
23
I didn't really -- other than those first two patients,
24
I didn't really give any treatment to anyone one else.
25
I was just kind of matching patients to ambulances that KEVIN MOLL, CSR
(206) 477-1584
5749
1 2
were waiting. Q.
3
Did you encounter any -- well, let's go back to patient number one.
4
Did patient number one survive?
MR. GUTHRIE:
5
Your Honor, I'm going to object.
This
patient number one is not a plaintiff in this case.
6
THE COURT:
Overruled, but, ladies and gentlemen,
7
you will be limited to deciding only the plaintiffs
8
that are before you in the case.
9
A.
10 11
This is for context.
I learned later that patient one expired on scene. BY MS. KOEHLER:
Q.
All right.
Now, with respect to the rest of the scene
12
that you handled, from your view of it, did you pay --
13
I guess I should be more clear.
14
I apologize.
Other than transporting the patients, as you've
15
described, did you take care of the rest of the scene,
16
or were you just very focused on doing your particular
17
part of the job?
18
A.
The very end of the incident, I may have walked around
19
it, but most of my area was on the north area of the
20
scene.
21
so...
22
Q.
I never entered the bus or got onto the Duck,
I do have one question, though.
When you arrived, and
23
you arrived quite early, you could see into the bus; am
24
I right?
25
A.
There was a hole in it?
Yes, but I couldn't see details. KEVIN MOLL, CSR
I just knew that it
(206) 477-1584
5750
1 2
was occupied. Q.
Okay.
Sir, after this incident was over, did you have
3
any other involvement with any of the patients in this
4
case?
5
A.
I -- one more patient was brought to my attention, that
6
an engine company had found along the walkway, on the
7
west side of the bridge.
8
been triaged as green, but this engine company had some
9
concerns about him, so I went and reexamined him and
10
I think he had originally
moved him, I believe, into the yellow category.
11
MS. KOEHLER:
12
Thank you so much, Mr. Chapa.
I
appreciate your time.
13
THE COURT:
14
Thank you.
Cross-examination from
International?
15
MR. WAKEFIELD:
16
THE COURT:
17
No, your Honor.
Cross-examination from Ride the Ducks
Seattle?
18
MR. GUTHRIE:
19
THE COURT:
20
No, your Honor. Cross-examination from the State?
right ahead.
21 22
CROSS-EXAMINATION
23
BY MR. PUZ:
24
Q.
Good morning.
25
A.
Good morning. KEVIN MOLL, CSR
(206) 477-1584
Go
5751
1
Q.
Am I correct that you and the other paramedics and
2
firefighters on the scene were able to get all of the
3
red patients and yellow patients transported to the
4
hospital within 30 minutes of this accident?
5
A.
Yes.
I believe that was the case.
6
MR. PUZ:
7
THE WITNESS:
8
THE COURT:
9
Thank you so much for your service, sir. Thank you. Anything from the City, Mr. Seder, or
Ms. Lee?
10
MS. LEE:
No, your Honor.
11
THE COURT:
Thank you.
Thank you.
Go ahead and pass your
12
question forms to the end of the jury box, ladies and
13
gentlemen.
14
we'll see if the jury has any questions for you.
15
here.
16
Come to chambers, Counsel.
THE COURT:
18
for being here.
19
THE WITNESS:
20
THE COURT:
22 23 24 25
Stay
(Chambers conference; not reported)
17
21
Mr. Chapa,
Mr. Chapa, back to work for you.
Thanks
That's it? Yes.
The plaintiffs can call your next
witness. MS. KOEHLER:
Yes, Your Honor.
The plaintiffs would
call Ms. Vera Duffie. THE COURT: would.
Hi, Ms. Duffie.
Come forward, if you
Come right up here and please face me and raise KEVIN MOLL, CSR
(206) 477-1584