The horrific nightmare I have endured will be brought to light through deposing of all parties who have shamelessly denied their responsibilities. I will be disclosing the names and positions of all parties involved.
All depositions from the defendants are taken by the law firm Mirch and Mirch, San Diego, CA.
My name is MARGIE SHEPHERD, PLAINTIFF, I AM THE VICTIM. The following is my opinion. All charges against the recovery room nurse, surgeon, and a well-known bank have been filed in the Los Angeles courts. All documents, declarations, witnesses’ statements, billing etc. is in the possession of my legal counsel.
The first defendant my legal counsel will depose is Kita Stovall, RN.
The following will clearly outline the negligence that started this horrific nightmare. I have lived with for four and half years.
August 31, 2005: I was ready for surgery, but, I was scared !
On the morning of September 3, 2005:
Where am I? Who am I? I am disoriented. Does anybody know me? I’m yelling and pounding on what seems to be a table next to me because I couldn’t open my eyes to see where I was. My head hurt, my neck hurt, my breasts hurt and I hurt all over ! I was in such pain. I had been bandaged from the top of my head all the way to my waist. The openings from where the drainage tubes had been placed at the base of my skull, I could feel the openings. There was drainage running down my pajamas. The back of my pajamas was soaked. I was lying in a bed of fecal incontinence. I was in excruciation pain. I could not open my eyes. I finally found the telephone and started pushing buttons. And then someone came on, and I yelled, “Help where am I? What is going on?” A few minutes later the hotel management arrives. From the voices I could tell one was a man and one was a woman. I heard the concern in their voices. I was asked “where is your nurse?” I said, “I don’t know. I hired through the doctor’s office a per diem nurse to take care of me.” They wanted me to describe her, but I couldn’t. I explained I had memory of only one nurse, the surgeon’s nurse, Kita Stovall, RN who took care of me in his overnight recovery facility. I gave a description of her based off of what I remembered and that was of course before I was administered a heavy drug called Demerol. To be exact I was give eight 12.5 mg of Demerol in a period of less than five hours. It was discovered additional Demerol was given during the night. However, dosages were not logged. This happened in the surgeon’s overnight recovery facility. The only nurse I remember was Kita Stovall, RN. She administered the injections through my IV. My memory STOPPED.
Management had left, and the phone rings. This individual identified herself as Kita Stovall, RN, the nurse from the surgeon’s office and said that SHE was supposed to be TAKING CARE OF ME! “I didn’t hire you!” When I met the coordinator at the surgeons’ office, she specifically stated it would be an outside per diem nurse. Kita Stovall, RN had placed herself in the position to be my nurse at the hotel. She had continued to administer Demerol or a substance strong enough to keep me drugged. Management stopped her from returning to my room.
Seven and half hours of reconstructive surgery, under full blown anesthetic, eight injections of 12.5 mg of Demerol within a five-hour period with additional Demerol given in the middle of the night, dosages not charted which was discovered later, seventeen hours after surgery I am discharged, I am in my pajamas, bandaged from the top of my head all the way to my waist with drainage tubes draining down the back of my neck. I had endured not only the facial surgery, but breast surgery on both breasts as will as lip enhancement. I am then taken into a bank in Beverly Hill, this happened five hours after being discharged on September 1, 2005, I HAVE NO MEMORY OF THIS ! I was taken from the doctors overnight recovery facility by the nurse Kita Stovall. The nurse had instructed the driver to take us to the bank ! My question is, would you remember writing a $19,000.00 check and supposedly signing it to pay a nurse under the guise of receiving payment for nursing services in advance especially when you were initially advised by the surgeon that you would only be in town three to five days? Kita Stovall was a part time nurse and making $30.00 per hour. When at that particular time you don’t know who you are, you don’t know what you’re doing, and you don’t know where you are going next. From there I was then taken back to the hotel and medicated heavily again. Still no memory of what I had gone through from the time the Demerol was being administered to me at the doctor’s recovery facility. All these details were reconstructed much later. I was not WELL nor did I have MEMORY !
The next day, on September 2, Kita Stovall instructed the driver to take us to the surgeon’s office for a follow up appointment. I couldn’t remember for the longest time being there or exactly what I was even doing there. However, she did not go into the office with me. She took me to the door and then disappeared. All I could remember her saying was, “Don’t tell the surgeon ! ” Don’t tell the surgeon ! ” After the doctors’ appointment she met me out by the elevator. My bandage had been removed and my hair was matted down with blood. I was swollen. I was black and blue and I still had some drainage going down the back of my neck, though the tubes had been removed. All I remember from that day was being told, “ Don’t tell the surgeon ! ”
Stovall then instructed the driver to take us to Beverly Hills to Louis Vuitton. She did not want the doctor to know where I was going, she didn’t want ME to know where I was going and once again she refused to let the driver communicate with me. She took me and my credit card into Louis Vuitton and ended up purchasing $5,466.63 of Louis Vuitton products. The nurse took me and bag after bag after bag out of the store. We returned to the vehicle and she takes me back to the hotel. I was sick, I hurt, I didn’t know where I was. Nonetheless back to the hotel we go and I have absolutely no memory of any of this. I was continually medicated, it was validated by those individuals that tried to call the room and there was no answer. However, Kita Stovall did speak to three parties and stated she had just medicated me. I want to stress that when the surgeon removed the bandages my hair was matted with blood. There was drainage going down my neck, I was sick and I had absolutely no business going shopping let alone in Beverly Hills ! Kita Stovall medicated me repeatedly and then would leave. She took her husband, my credit card and used the hotel limo service and went dining in Beverly Hills. Stovall called the surgeon’s office on September 1, the day I was discharge and quit her job.
With the amount of Demerol in my system at the time of discharge and repeated medicating with Demerol and/or a foreign substance strong enough to keep me drugged can cause serious side effects. It falls into the category of overdose. A serious overdose can create respiratory problems, coma, clammy skin, apnea, cardiac arrest and death ! In fact in the Physician Drugs Reference (PDR) it states that if you have serious stomach problems Demerol should not be prescribed for the patient. My digestive disorder involves the stomach, but is much more complex. All I know is she continued to inject the drug. I was sick and she was gone.
Nurses Malpractice
Over the past five years, the number of nurses’ malpractice cases has risen at an alarming rate. Nurses’ malpractice is one of the most serious problems in the medical profession today.
Nurses’ malpractice is simply defined as negligence by a nursing professional, which can result to serious physical and also emotional damages to the patient: and even deaths.
Only two decades later, the New York Court of Appeals recognized a more modern view of nursing practice and rejected the “ordinary negligence” standard.
While courts have in the past held that a nurse could be liable for negligence, but not for malpractice, “ the role of the registered nurse had changed, in the last few decades, from that of a passive, servile employee to that of an assertive, decisive health care provider. Today, the professional nurse monitors complex physiological data, operates sophisticated lifesaving equipment, and coordinates the delivery of myriad of patient services.”
In recognition of the modern scope of nursing practice, the court held that a nurse may be held liable for malpractice.
Facts are coming your way ! Follow the Kita Stovall, RN story. Her first deposition date will be announced, and strong pertinent information will be revealed!
Please “SHARE YOUR COMMENTS WITH ME!”
We all must “Keep On Going !”
Saturday, April 24, 2010
Margie Shepherd's Final Deposition Marks A Turning Point
From Margie Shepherd: On February 2, 2010, I went to Los Angeles for what I thought to be my fifth and final deposition. However, my counsel informs me that it was my SIXTH and FINAL DEPOSITION.
This deposition marked a turning point and now change is in play. My counsel will begin deposing the surgeon and nurse this month.
The other five depositions, as well as the February 2, 2010 deposition, were riddled with pressure statements. The constant rephrasing of questions over and over again trying to confuse me.
In my first deposition, I tried to ask a question of one of the opposing counsels who threatened to cite me.
The tactics that are used clearly show the power play corporate America continues to inflict and condone time and time again. This tactic does not offer solutions, instead, it’s another avenue to continue to break the spirit of the American people. My opinion? Clearly my constitutional right of ‘FREEDOM OF SPEECH” was infringed upon. We the people need to take an active part in the area of REFORM! If we are going to succeed , We must have faith in who we are!
I have been advised by my counsel that my testimony at all six depositions were excellent. Preparation is key. You must understand the purpose and format of a deposition. KNOWLEDGE IS POWER!
In my first Blog column I gave my DNA formula for success. As a reminder, my one word working tool is TENACITY, the definition is BELIEF, FAITH, POSSIBILITIES, COMMITMENT, and INTEGRITY. My DNA success formula and belief in the people pulled me through the stress of six depositions.
DO YOU KNOW AND UNDERSTAND THE PURPOSE OF A DEPOSITION? I didn’t ! Upon my legal counsel filing all of my cases, I began to prepare myself thru research what to expect and how to respond. Once I had a clear understanding of what a deposition was, it became abundantly clear - TELL THE TRUTH !
People who don’t understand automatically go to assumption ! Be clear with yourself. Acquire knowledge.
Please review the definition and purpose of a deposition.
DEFINITION AND PURPOSE OF A DEPOSITION !
In law, a deposition is a witness’s out of court testimony that is reduced to writing for later use in court for discovery purposes. In the United States it is taken during an examination before the trial in which litigants gather information for trial.
The chief value of obtaining a deposition by examination before trial, as with any discovery proceeding, is to give all litigant parties in a contested case a fair preview of the evidence. The process provides a “level playing field” of information among the litigants and avoids surprises at trial (traditionally regarded as an unfair tactic). Another benefit of taking a deposition is to preserve a witness’s recollection while it is still fresh, since the trial may still be months or years away. When a witness’s testimony in open court is inconsistent with that given at examination before trial, a party can introduce the deposition to impeach (or contradict) the witness. In the event a witness is unavailable for trial, their deposition may be read or played before the jury and made part of the record in the case, with the same legal force as live testimony. In some states, stenographic, audio, or video records of depositions can be offered into evidence even if the witness is available.
Sometimes, after a number of witnesses have been deposed, the parties will have enough information to reasonably predict the outcome of a prospective trial, and may decide to arrive at a compromise settlement, thus avoiding trial and preventing additional costs of litigation. Accordingly, while most examinations before trial are not videotaped, opposing counsel may use the opportunity to get an impression of the witness’s affect and appearance, because these are telling factors as to how that person will present in front of a jury.
Remember daily you need to work on your INNER STRENGTH, CLARITY, and INTEGRITY.
PLEASE FORWARD YOUR COMMENTS AND QUESTIONS TO MY BLOG.
I am still that little girl from nowhere that believes we the people can and will make the difference!
We all must “Keep on Going!”
This deposition marked a turning point and now change is in play. My counsel will begin deposing the surgeon and nurse this month.
The other five depositions, as well as the February 2, 2010 deposition, were riddled with pressure statements. The constant rephrasing of questions over and over again trying to confuse me.
In my first deposition, I tried to ask a question of one of the opposing counsels who threatened to cite me.
The tactics that are used clearly show the power play corporate America continues to inflict and condone time and time again. This tactic does not offer solutions, instead, it’s another avenue to continue to break the spirit of the American people. My opinion? Clearly my constitutional right of ‘FREEDOM OF SPEECH” was infringed upon. We the people need to take an active part in the area of REFORM! If we are going to succeed , We must have faith in who we are!
I have been advised by my counsel that my testimony at all six depositions were excellent. Preparation is key. You must understand the purpose and format of a deposition. KNOWLEDGE IS POWER!
In my first Blog column I gave my DNA formula for success. As a reminder, my one word working tool is TENACITY, the definition is BELIEF, FAITH, POSSIBILITIES, COMMITMENT, and INTEGRITY. My DNA success formula and belief in the people pulled me through the stress of six depositions.
DO YOU KNOW AND UNDERSTAND THE PURPOSE OF A DEPOSITION? I didn’t ! Upon my legal counsel filing all of my cases, I began to prepare myself thru research what to expect and how to respond. Once I had a clear understanding of what a deposition was, it became abundantly clear - TELL THE TRUTH !
People who don’t understand automatically go to assumption ! Be clear with yourself. Acquire knowledge.
Please review the definition and purpose of a deposition.
DEFINITION AND PURPOSE OF A DEPOSITION !
In law, a deposition is a witness’s out of court testimony that is reduced to writing for later use in court for discovery purposes. In the United States it is taken during an examination before the trial in which litigants gather information for trial.
The chief value of obtaining a deposition by examination before trial, as with any discovery proceeding, is to give all litigant parties in a contested case a fair preview of the evidence. The process provides a “level playing field” of information among the litigants and avoids surprises at trial (traditionally regarded as an unfair tactic). Another benefit of taking a deposition is to preserve a witness’s recollection while it is still fresh, since the trial may still be months or years away. When a witness’s testimony in open court is inconsistent with that given at examination before trial, a party can introduce the deposition to impeach (or contradict) the witness. In the event a witness is unavailable for trial, their deposition may be read or played before the jury and made part of the record in the case, with the same legal force as live testimony. In some states, stenographic, audio, or video records of depositions can be offered into evidence even if the witness is available.
Sometimes, after a number of witnesses have been deposed, the parties will have enough information to reasonably predict the outcome of a prospective trial, and may decide to arrive at a compromise settlement, thus avoiding trial and preventing additional costs of litigation. Accordingly, while most examinations before trial are not videotaped, opposing counsel may use the opportunity to get an impression of the witness’s affect and appearance, because these are telling factors as to how that person will present in front of a jury.
Remember daily you need to work on your INNER STRENGTH, CLARITY, and INTEGRITY.
PLEASE FORWARD YOUR COMMENTS AND QUESTIONS TO MY BLOG.
I am still that little girl from nowhere that believes we the people can and will make the difference!
We all must “Keep on Going!”
Background: Keep On Going!
Today I am preparing for my fifth and final deposition. February 2, 2010 at 10:00 AM in Los Angeles, California will be a day of positive changes. I ask myself, HOW DID MY STORY BEGIN? As I reflect back to August 31, 2005, the start of what would be the most horrific nightmare of my life, I can’t help but reflect on all the tragic events that started from a surgery, and how all parties have shameless denied their responsibilities. A lawsuit has been filed against all parties:
1. The surgeon who allegedly refused to review my medical records before surgery!
2. The recovery room nurse who allegedly took me into a bank while bandaged from head to waist and under heavy sedation, allegedly withdrew $19,000.00 from my account without my consent.
3. Also implicated in the lawsuit is a well-known bank that sold the note to a collection company which harassed me for 4 1/2 years and ruined my credit.
In addition, though not mentioned in the lawsuit, the law enforcement agencies in Los Angeles dropped the ball at every turn.
The next step of this massive lawsuit is the deposition of the nurse, Kita Stovall, taken by me Margie Shepherd, Plaintive, on February 22, 2010 in Los Angeles, California.
I am no stranger to adversity. I have again summoned my strength to rebuild my life and fight back against the unjust actions of corporate America and the medical establishment. Using my DNA formula for success, I claim TENACITY as my working tool.
My inspirational message is both timely and on target in a world that is permeated with despair. My DNA for success formula gives people the much needed tools to develop a roadmap to reclaim hope, grow inner strength, gain great clarity, and restore their dignity when plagued by adversity and challenged by travesty.
In my opinion, the people in general have had their spirit broken and their personal belief in the American Dream destroyed. I know that to be a true statement because I am one of those people. However, unlike so many, for more than four ½ years, I chose to fight. It is my intention to help restore the belief in the American Dream. However, to really restore it, the people need to believe they make the difference.
We need to begin to dig the ditches, to lay the brick, and build the foundation. The foundation will hold not only the promises from the administration, but the accomplishments of the people. I’m a little girl from nowhere, but this is my mission - my inner strength grows daily, my clarity is clear, but most of all, my level of dignity has been restored.
As you follow the Blog and story, you will discover who each of the perpetrators are by name. I will share my thoughts on the lawsuit and the defendants and I INVITE YOU TO SHARE YOUR COMMENTS WITH ME.
We all must “Keep on Going!”
1. The surgeon who allegedly refused to review my medical records before surgery!
2. The recovery room nurse who allegedly took me into a bank while bandaged from head to waist and under heavy sedation, allegedly withdrew $19,000.00 from my account without my consent.
3. Also implicated in the lawsuit is a well-known bank that sold the note to a collection company which harassed me for 4 1/2 years and ruined my credit.
In addition, though not mentioned in the lawsuit, the law enforcement agencies in Los Angeles dropped the ball at every turn.
The next step of this massive lawsuit is the deposition of the nurse, Kita Stovall, taken by me Margie Shepherd, Plaintive, on February 22, 2010 in Los Angeles, California.
I am no stranger to adversity. I have again summoned my strength to rebuild my life and fight back against the unjust actions of corporate America and the medical establishment. Using my DNA formula for success, I claim TENACITY as my working tool.
My inspirational message is both timely and on target in a world that is permeated with despair. My DNA for success formula gives people the much needed tools to develop a roadmap to reclaim hope, grow inner strength, gain great clarity, and restore their dignity when plagued by adversity and challenged by travesty.
In my opinion, the people in general have had their spirit broken and their personal belief in the American Dream destroyed. I know that to be a true statement because I am one of those people. However, unlike so many, for more than four ½ years, I chose to fight. It is my intention to help restore the belief in the American Dream. However, to really restore it, the people need to believe they make the difference.
We need to begin to dig the ditches, to lay the brick, and build the foundation. The foundation will hold not only the promises from the administration, but the accomplishments of the people. I’m a little girl from nowhere, but this is my mission - my inner strength grows daily, my clarity is clear, but most of all, my level of dignity has been restored.
As you follow the Blog and story, you will discover who each of the perpetrators are by name. I will share my thoughts on the lawsuit and the defendants and I INVITE YOU TO SHARE YOUR COMMENTS WITH ME.
We all must “Keep on Going!”
Keep On Going
As we continue the journey with you discovering your one word that describes your DNA for success and how to define it, I can’t emphasize enough how the formula can help you to survive a crisis and apply it to every aspect in your life.
Start thinking about your life and anything that may have happened that was a travesty and how could you have handled it differently if you had applied this formula to the situation.
I think everyone has something within them that they can draw from. Their inner core particularly will help them to fight. The one word that describes my DNA for success is TENACITY.
So if a tragedy, stress, and suffering happen to you no matter how big or how small, I want to share with you how to discover your own DNA for success, which is your one word working tool, how you apply your own DNA for success, and the five points which are actually your road map. You must know your inner strength when you hit a crisis. You must rely on and use that strength to overcome challenges. I knew my inner strength was TENACITY. This is what helped me to deal, survive, and come back to the living each time I encountered a crisis. Once you have discovered your own working tool you have to define it. KEEP IT SIMPLE! Five words, as an example, TENACITY is my working tool, however the definition of tenacity for me is BELIEF, FAITH, POSSIBILITIES, COMMITMENT, and INTEGRITY. This is the formula I developed and implemented. As I proceed, you will see how your DNA for success formula can help you survive and restore your life so you can “Keep On Going!” When you define your DNA for success in one word, you will have your working tool and when you define your five points that become your road map. You are now in position to go forward and break through the wall of passion without fear. You will then be working smarter - not harder.
Once I realized how simple the formula was, I took it to another level. I had to search deep inside myself to redevelop my faith that I would live and be a regular human being again. From there I began to think about possibilities. What I could do with my self? How am I going to fight back? How am I going to live? From there, I realized I had to make a commitment not to others but to myself. I had to reestablish a level of integrity that I had lived by all my life.
Archbishop Desmond Tutu spoke at the Clinton Global Initiative. His words left a lasting impression. God created us differently to know our needs for one another.
When I am interviewed, I search within myself and come from a level of integrity that I have always used both in verbal response and actions.
Begin to focus on rebuilding you inner strength, make sure your clarity is clear, and most of all, dignity must be restored and intact! The feeling of self possibilities truly spawns success.
When tragedy, stress, suffering, and hard times happen, don’t stay in the negative zone, instead go to your DNA word and pick one point to restart the positive process.
My goal with this blog and my own story is to motivate my audiences to face challenges head on, encouraging them to follow my DNA for success formula in order to reclaim their sprit and gain control of their lives. I hope to rekindle your fire of desire and determination.
We all must “Keep on Going!”
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