See also: Julie Glade Criminal Trial

JULIE GLADE
HOSPITAL TECHNICIAN
DEPOSITION


Page 3

Julie Lynn Glade,

being produced, sown as hereinafter certified and examined on behalf of the Defendant, testified as follows:

Examination by Mr. Correll

6 Q. Will you state your full name, please?
7 A. Julie Lynn Glade.
8 Q. Is it all right if I call you Ms. Glade?
9 A. That's fine.
10 Q. Ms. Glade, where do you reside?
11 A. 2305 Rownd Street in Cedar Falls.
12 Q. And where are you employed?
13 A. Sartori Hospital.
14 Q. How long have you been employed there?
15 A. Going on 17 years.
16 Q. And in what capacity are you employed
17 there?
18 I am a medical technologist.
19 Q. How many of your 17 years there have you
20 been working as a medical technologist?
21 A. All of them.
22 Q. Would you indicate where you graduated
23 from high school, please?
24 A. Clarion.
25 Q. Iowa?

Page 4
1 A. Clarion, Iowa; Clarion high School.
2 Q. And what has your education been --
3 formal education since high school?
4 A. After high school, I went to UNI for
5 four years, and -- actually four and a half years.
6 I took my internship for medical technology at
7 Schoitz Hospital when it was Schoitz, for a year.
8 Q. And what was your major at UNI?
9 A. UNI? Biology. I have a biology major.
10 Q. And did you work at Schoitz, or did you
11 come to work immediately after college at Sartori?
12 A. I went immediately after my internship
13 at Schoitz to Sartori.
14 Q. And in conjunction with your work there,
15 am I correct that a substantial portion of that
16 involves overseeing or doing the actual testing of
17 various samples in the Sartori lab?
18 A. Uh-huh, that's right.
19 Q. Is the Sartori lab at this time owned by
20 Sartori, or is it owned by a pathology group?
21 A. Well, the lab itself is not owned by a
22 pathology group. It's owned now by Covenant Health
23 Systems.
24 Q. Was there a period of time where the lab
25 was owned or run by a group of pathologists?

Page 5
1 A. No, it's never been owned by a group of
2 pathologists. We are supervised by them, and I
3 assume that that's contracted out to a group
4 of pathologists.
5 Q. But you are a direct employee of
6 Sartori?
7 A. Yes.
8 Q. And have been these past 17 years?
9 A. Right, un-huh.
10 Q. Now I'm probably going to talk to you
11 about half hour, 45 minutes typed of period of
12 time. It I ask you a question that you don't
13 understand or is worded poorly or if I speak too
14 fast, stop me.
15 A. Okay.
16 Q. If you think I'm in any way -- I don't
17 certainly think I will be, but if you think I'm
18 mistreating you in any way or argumentative, let me
19 know that, too, because I don't want to do that.
20 A. Okay.
21 Q. Let me see, It is my understanding that
22 your involvement in this case is that you tested
23 some blood that was withdrawn from Mr. Rokes on or
24 about October 4 of 1996.
25 A. Uh-huh.

Page 6

1 Q. Did you come to work at like six in the
2 morning?
3 A. Uh-huh, at six.
4 Q. Did you see Mr. Rokes at any time at the
5 hospital?
6 A. No.
7 Q. Did you know Mr. Rokes?
8 A. No.
9 Q. And you and I have never met, is that
10 correct?
11 A. Huh-uh.
12 Q. With regard to the deposition that we're
13 taking, have you ever had your deposition taken
14 before?
15 A. No.
16 Q. Can you tell me what, if anything, you
17 did to get ready to prepare for the deposition?
18 A. I probably looked at the methodology
19 that the instrument uses to come to its results,
20 and I got the little strip printers. That's about
21 it.
22 Q. So I understand, when you say "looked at
23 the methodology for the machine" -- and I
24 understand that's some kind of a DuPont, some kind
25 of a --

Page 7
1 A. DuPont ACA.
2 Q. Yes. Thank you.
3 A. Uh-huh.
4 Q. Was it literature regarding that machine
5 that you referred to regarding methodology?
6 A. Right, uh-huh.
7 Q. And is there a written protocol that
8 Sartori has developed for purposes of analyzing
9 blood for the purposes of determining alcohol
10 content?
11 A. There's nothing -- we don't analyze
12 these any differently than any other specimen,
13 except that we follow the chain of custody.
14 Q. Okay. so there is no special protocol
15 that has been developed by your department for that
16 analysis?
17 A. Just for legal alcohols. Other than
18 following chain of custody, filling out the extra
19 paperwork for that, there really isn't. we run
20 controls along with the specimen, just like we do
21 with a regular medical kind of specimen.
22 Q. Would it be accurate to say that over
23 all the Sartori lab, 99.9 percent of its work is
24 not blood legal, but it is analysis for purposes of
25 treatment of --

Page 8
1 A. Right, uh-huh.
2 Q. -- patients? One of the things that I'm
3 going to ask you, and I need to do, too, is
4 sometimes you can anticipate what I'm going to ask,
5 and then you answer before I'm done with my
6 question, and it makes it have for the reporter
7 when we both talk at the same time. So I don't
8 mean to be petty or anything, but if you could wait
9 until I'm done.
10 A. Okay.
11 Q. Even thought I know some of these
12 questions, halfway through them you're going to
13 know what the question is and what your answer is,
14 it just helps her out.
15 A. Okay.
16 Q. Over the course of the time that you've been
17 working at the hospital, have you kept track of on
18 how many occasions you have analyzed blood for the
19 purposes of blood-alcohol content?
20 A. No.
21 Q. Would it be over a hundred, would you
22 think?|
23 A. No.
24 Q. and is that because usually breath is
25 involved, or is it just because you're not working,

Page 9
1 or do you have any sense as to why that would be?
2 A. We just don't do that many. I do
3 maybe -- well, it's hard to say. I'll go months
4 and not have any, and then I'll maybe have one -- I
5 I work every other weekend, and usually they fall on
6 the weekend, but we just don't have that many.
7 Q. Maybe half a dozen a year?
8 A. Probably. No more that that, probably.
9 Q. With regard to when you say you made
10 reference to the methodology, did you read the
11 literature or the pamphlet that came with the
12 machine?
13 A. Uh-huh.
14 Q. And how long a procedure or how long a
15 manual is that?
16 A. It's a big manual, but there's
17 many chemistries that we run it on. Alcohol is just
18 one. I just reviewed the methodology. I know it's
19 different from what the DCI uses.
20 Q. And they use gas chromatography?
21 A. High pressure liquid chromatography is
22 what it is, HPLC, and I'm not familiar with that.
23 We don't use anything like that at Sartori, so I'm
24 not real familiar with that method.
25 Q. And do you know that because Mr. Wadding

Page 10
1 told you that?
2 A. No.
3 You know that independently from another
4 source?
5 A. Uh-huh.
6 Q. Would you generally agree that that
7 machine is -- I guess the GC machine, which I'll
8 call it --
9 A. Okay.
10 Q. -- is the s called gold card or
11 Cadillac of the machines available t test
12 blood-alcohol?
13 A. No, I'm not aware of that.
14 Q. With regard to your specific machine, is
15 that the enzymatic assay analysis approach?
16 A. Uh-huh.
17 Q. And it's my understanding from doing
18 some reading, that that is an approach where there
19 is a centrifuge spin of the specimen, and that
20 separates certain items from the sample so that a
21 sample can be run. Am I correct in that?
22 A. Uh-huh.
23 Q. And what what happens is with that spin,
24 it spins out the components that would interfere
25 with the analysis.

Page 11
1 A. It spins out the red blood cells.
2 Q. And after the spin, only the serum is
3 left for the purposes of the analysis, it that
4 correct?
5 A. Uh-huh. Right.
6 Q. Now, what is your understanding, if you
7 have any, as to whether or not the analysis of
8 serum produces a higher or lower or any way
9 affected result, as opposed to analyzing whole
10 blood?
11 A. I'm not aware of any difference.
12 Q. In you calculations, which I guess
13 they're making copies of now, did you make any type
14 of adjustment for that?
15 A. No.
16. Q. Do you have any opinion as to whether or
17 not an adjustment needs to be made with you're only
18 analyzing serum as opposed to whole blood?
19 A. I'm not aware of any difference between
20 the two.
21 Q. And have you ever heard that analysis of
22 serum will produce a higher blood-alcohol content
23 than the analysis of the whole blood form the
24 same --
25 A. No, I'm not aware of any difference.

Page 12
1 Q. With regard to the machine that you
2 have, how long has that machine been there,
3 approximately?
4 A. Five years.
5. And is that machine calibrated from time
6 to time?
7 A. Uh-huh.
8 Q. Do you ever calibrate that machine?
9 A. I don't very often. I can if I need to,
10 but it's not part of the routine.
11. Q. It's my understanding that Mr. Hill does
12 it. Does she calibrate it sometimes?
13 A. Uh-huh.
14 Q. And there's a chemist by the name of
15 Mr. Hauser?
16 A. Maury.
17 Q. Maury. Excuse me. Anybody else
18 calibrate the machine?
19 A. Us three are probably the main ones that
20 do it. Those two, and then I will on occasion if I
21 need to.
22 Q. Say in 1996 calendar year, that 12
23 months, how many times would you have calibrated
24 the machine yourself?
25 A. Maybe less than half a dozen times. I'd

Page 13
1 say maybe four or five times.
2 Q. And is there a record that is maintained
3 as to when the machine is calibrated?
4 A. Uh-huh.
5 Q. And who has that record?
6 A. It in the lab, right in the chemistry
7 department. But there are certain protocols that
8 we follow when we need to calibrate. If the
9 controls are shifting or they're out, we'll
10 calibrate. Every -- I don't know if it's six
11 months for alcohol. Every test has its own
12 schedule for being calibrated.
13 Q. And would, to the best of your
14 knowledge, the calibration that's called for in the
15 manual be approximately every six months for
16 blood-alcohol?
17 A. I think it is. I'm not exactly sure
18 about that, but --
19 Q. And would it be every six months unless
20 your checks or values say it should be sooner?
21 A. Right, uh-huh. We run two controls a
22 day, and we also are surveyed by the College of
23 American Pathology. We do three surveys a year, so
24 we have to keep up on that, also.
25 Q. With regard to doing the values -- is

Page 14
1 that what you call the, the values of --
2 A. The results or --
3 Q. Yes.
4 A. Uh-huh.
5 Q. are those printed out on the little
6 papers that you brought in?
7 A. Uh-huh.
8 MR. CORRELL: Maybe this would be a good
9 time, Kasey, if you and I and Ms. Glade have
10 those.
11 (A conversation was held off the record.)
12 Q. I'll just ask you a few questions while
13 we're waiting to get that copy. With this machine,
14 how many checks -- I'm going to call them checks,
15 but how many values does this machine produce o
16 its accuracy can be checked? Two or three?
17 A. I' not sure what you mean.
18 Q. Well, there are ways to run tests to
19 determine if the machine is operating correctly, --
20 A. Uh-huh.
21 Q. -- and what do you use to refer to those
22 tests?
23 A. We use two controls that we run a day,
24 what these are right here.
25 Q. And for those controls, does that

Page 15
1 machine have the capacity to run three controls?
2 A. Yeah, you can run as many controls as
3 you want.
4 Q. And on this machine, is there a high
5 control and a low control?
6 A. Uh-huh.
7 Q. And how do those controls works, if you
8 know?
9 A. I'm not sure I understand how they
10 work. They jut -- they run just like a patient.
11 You load them on just like a patient. The
12 methodology is the same as a patient.
13 Q. When we use this first one here --
14 A. Okay. This top one.
15 Q. And that is marked at 7:27. That must
16 have been the time in the morning that your ran it?
17 A. Uh-huh.
18 Q. Is that Level 2 control? Is that why
19 it says?
20 A. Level 2 control. We ran what's called
21 a Level 2 and a Level 3 control. There is a Level 1
22 control that's even lower, but these are the two
23 that we run. This one, because the legal limit is
24 at a hundred, that this range is 86 to 129, so that
25 100 falls in the middle of that range. And the

Page 16
1 other one is a high control.
2 Q. All right. So you can tell me, when it
3 gives this printout, is this a control, or is it
4 Mr. Rokes' sample, or what is there that
5 produces this 98?
6 A. There's ethanol right in the control.
7 It's nothing to do with his sample at all.
8 Q. And so, this one, it printed out at 98?
9 A. Uh-huh.
10 Q. And the range should have been anyplace
11 between 126 and 129?
12 A. No. 86 to 129 is the range in which
13 that control needs to fall. And if it falls
14 outside that range, we can't take the results.
15 Q. And produced a result of 98?
16 A. Right.
17 Q. Okay. Then down here is 214 to 321 is
18 that range that you need, is that correct?
19 A. Uh-huh.
20 Q. And it came in at a result of 243.2?
21 A. Uh-huh.
22 Q. Okay. Now, what would you expect, or do
23 you have any knowledge if, say, it would have been
24 at the high end of the range, how would that affect
25 the number? If, say the printout number is

Page 17
1 towards the high end of the range, would that have
2 any influence or any effect upon the test result
3 when you ultimately do the specimen?
4 A. No, uh-huh. No. The control is run
5 separately than the specimen. It doesn't have
6 anything to do with the -- I mean, we're just
7 making sure our calibration is accurate and the
8 machine is going to be accurate.
9 Q. Okay. In your opinion, does it make
10 any difference, on on this test that you run, whether it's
11 at the high end or the low end of the range?
12 A. No.
13 Q. So in this, it wouldn't make any
14 difference, on the first one, where it says the
15 range is 86 to 129 -- if the printout was 129,
16 would that indicate to you you should get ready to
17 calibrate the machine?
18 A. Probably. If it's getting up to the
19 high end of the scale, if we see those controls
20 drifting up or down, we'll calibrate.
21Q. And isn't it fair to say that always the
22 machine is not static or not constant? I mean, it
23 changes; it goes up and down continually?
24 A. Right.
25 Q. And when would you have last calibrated t

Page 18
1 his machine?
2 A. I don't know. There's no way to tell
3 from this when it was calibrated. We'd have to go
4 back and look at the records. It's all in the
5 record books.
6 Q. But you say twice a day, you test it to
7 see if it is within --
8 A. We run controls with the patient. We
9 run controls only if we have a patient. Some days
10 we go without running any alcohols on the analyzer,
11 and on those days, we don't run controls. We're
12 not required to do that.
13 Q. Can you tell when a control would last
14 have been run in this situation?
15 A. No. We'd have to look that up, also.
16 Q. Can you tell from this whether the
17 machine was drifting higher or lower?
18 A. You can't really tell from just this
19 one -- these one results, but they're right in the
20 middle of the mean, the ranges in which they need
21 to fall. And we can look up which they ran the
22 whole month if you need to know that. After
23 talking to Diana -- Jennerman, it used to be --
24 Hill, she seemed to think that these controls are
25 real stable. Most of the time they run in these

Page 19
1 numbers. I think we're real consistent with that,
2 but I can get those records if you need them.
3 Q. With regard to the specimens that you
4 ran, how many tests did you do? Did you do just
5 one?
6 A. How many tests on --
7 Q. On Mr. Rokes' blood.
8 A. Just one.
9 Q. And can you indicate why, or is that
10 just a protocol that you --
11 A. That's just a protocol for any test. We
12 don't run any of our medical tests in duplicate.
13 We don't need to.
14 Q. When you are getting certified or
15 getting checked for certification, do you run more
16 than one test?
17 A. For CAP or --
18 Q. Yes.
19 A. No. It is stressed by CAP that we run
20 those specimens only once. That's right in the
21 protocol that we don't run those in duplicate.
22 We're supposed to treat them just like we treat all
23 specimens.
24 Q. And so, those never get run more than
25 one time?

Page 20
1 A. No. We're not to do that.
2 Q. For whatever reasons, are there times
3 like when you run a test more than one occasion?
4 A. If, say, this would be over the
5 linearity of the instrument -- it goes up to 300,
6 If it would be over that, we would have to dilute
7 that and run it again. If it's zero, we would have
8 to verify that it's zero. But in this range, we
9 don't have to run that in duplicate.
10 Q. It's my understanding that sometimes
11 tests can be run, and if you might run a test 10
12 times, there might be a number of different results
13 from that test, form that same specimen?
14 A. If you ran this again, chances are it's
15 not going to be 120.3 again. It may vary a little,
16 but it's not going to vary a lot. I can't tell you
17 how much it would be, but it's --
18 Q. Why is it going to vary?
19 A. Well, it's a methodology. You're not
20 going to come up with the exact same number every
21 time. You might get 121, you might get 118. It's
22 not going to vary much more than, I would say,
23 five.
24 Q. Do you know, on that machine, what it
25 says the level of plus or minus should be

Page 21
1 considered?
2 A. How much it can be? No, I don't know
3 what that is. I don't even know if there is such a
4 number.
5 Q. How much of the machine or how much of
6 the literature on that machine pertains to
7 blood-alcohol analysis?
8 A. I'm not sure what you mean.
9 Q. Well, the machine comes with a manual?
10 A. Uh-huh.
11 Q. And does that manual come in different
12 sections for this type of specimen you're
13 analyzing?
14 A. It comes in different sections for the
15 tests that you're running, if you're running an
16 alcohol, CK/MB or glucose.
17 Q. Would it be possible to get a copy of
18 the portion that pertains only to alcohol?
19 A. Uh-huh.
20 Q. About how many pages would that be?
21 A. Four or five, I would say.
22 Q. Are you of the opinion that the closer
23 the machines gets to the range limits, the more
24 likely the machine is going to be to produce a
25 varying result?

Page 22
1 A. Uh-huh. That's why we watch over
2 controls, to make sure they're not out of range.
3 Q. Can you tell me, do you think personally
4 it is necessary to recalibrate the machine before
5 each and every test?
6 A. No, we couldn't do that. We would -- it
7 would -- we wouldn't be able to function by doing
8 that. It would cost too much.
9 Q. How long would it take to recalibrate
10 the machine?
11 A. Oh, at least half an hour to 45
12 minutes. And in stat situations, you can't do
13 that. That would be just totally unfeasible to do
14 that. That's why we run controls.
15 Q. And do you think that's in part because
16 your lab is not to do blood-alcohol analyses
17 primarily? Your lab is almost exclusively to get
18 results so people can be treated?
19 A. Uh-huh. We don't calibrate it for
20 anything else, though, unless -- I mean, we use the
21 same protocol for alcohols as we do for glucose.
22 Q. Was there anything about the container,
23 that you thought was inappropriate or wrong, the
24 way it was sealed?
25 A. No.

Page 23
1 Q. Do you know, at the time you were
2 analyzing that one, where the sample or specimens
3 were that were ultimately analyzed by the BCI?
4 A, Uh-huh.
5 Q. And where were they?
6 A. In the -- in our chemistry refrigerator.
7 Q. Were they in separate vials to the ones
8 you were analyzing?
9 There were two vil sin the kit, and I
10 unsealed -- spun down one and unsealed that one and
11 left the other one intact and left it in the kit.
12 Q. And so, one vial would have gone to you
13 for your analysis?
14 A. Uh-huh.
15 Q. And one, vial would have gone to the
16 state laboratory?
17 A. They -- both vials went with the kits.
18 We always put the vial that we use back in the kit,
19 and then we store that in the refrigerator.
20 Q. Okay. I'm a little confused here. When
21 you get done testing, --
22 A. Uh-huh.
23 Q. -- there's two vials, but you only used
24 one?
25 A. Right.

Page 24
1 Q. And the one that you didn't use remains
2 sealed?
3 A. Uh-huh.
4 Q. And the one, after you're done with the
5 testing, then do you seal it back up?
6 A. I sealed it back up, initialed it so it
7 was marked that it have been used, and the it goes
8 back into the kit. That's just our protocol.
9 Q. So then, when the state lab would have
10 analyzed it, they would have had the same kit that
11 you did?

12 A. Uh-huh.
13 Q. One vial having never been used, and

14 your vial which you had used for analysis?
15 A. Uh-huh.
16 Q. As part of your education, are you
17 involved in continuing legal education at the
18 hospital?
19 A. Uh-huh.
20 Q. In virtually all of the continuing legal
21 education you have as it pertains to lab work
22 directed towards the medical as opposed to the
23 legal aspect of your work?
24 A. Uh-huh.
25 Q. Why was the second specimen sent to the

Page 25
1 kit in this case, if you know?
2 A. That's our protocol for all of them.
3 Q. With regard to your device, your
4 enzymatic assay analysis machine, to your
5 knowledge, does that have any limitations or
6 problems with analysis of blood-alcohol?
7 A. Not that I'm aware of.
8 Q. Would you agree that that machine is
9 primarily not based to do that typed of test?
10 A. Say that again.
11 Q. The DuPont machine that you have is not
12 primarily based just to do blood-alcohol analyses,
13 am I --
14 A. No. It' for different assays other
15 than alcohols.
16 Q. And that is what it's primarily designed
17 for, and that is in fact how it's primarily used?
18 A. It's primarily used for medical testing,
19 not legal.
20 Q. And how many times a day is the machine
21 used for medical purposes, ballpark?
22 A. Oh, up to a dozen, probably. It depends
23 on our work load for the day. It's a backup
24 instrument, so if our other one is down, we rely on
25 that. But there are probably four or five main

Page 26
1 tests that we run on that, and we don't even always
2 run all of those every day.
3 Q. And why is it the backup unit to the
4 units?
5 We need to have a backup for some
6 important tests like blood sugars, BUNs, and
7 creatinines. It's just something for a backup so
8 we don't have to send them out in a stat situation.
9 Q. And again, you have recalibrated the
10 machine how many times in the last year -- yourself
11 personally?
12 A. Four or five times, I think.
13 Q. And how many times has Ms. Jennerman
14 done it?
15 A. I don't know.
16 Q. And do you know how many times the other
17 gentleman would have done it?
18 A. No, I don't.
19 Q. Are the ranges here on these controls --
20 are those kept someplace so a person can determine
21 how those ranges were on, say, the previous 10 or
22 20 tests?
23 A. You mean what the results were, or the
24 ranges? I mean, these ranges for control say the
25 same.

Page 28
1 . It's normally because the time is just
2 up. Either the six months is up or whatever time
3 period it needs to be done. And when I say I've
4 calibrated three or four times a year, it's not
5 just alcohols. It could be some of the other
6 testings. The al have to be calibrated in the
7 same way.
8 Q. Would it be fair to say, then, that it
9 is calibrated for alcohol probably twice a year?
10 A. At least.
11 Q. And how many alcohol tests would be done
12 in a year, ballpark; just a range?
13 Q. It's hard to say. 75, maybe -- 75 to a
14 hundred. I'm really just kind of guessing.
15 Q. Okay. And again, why would it be that
16 if you ran the same specimen 10 times, that you
17 would get different results?
18 A. Simply because of the chemical
19 reaction. The end point is read by a photometer, a
20 light source, and it's just not going to be exactly
21 the same. It's kind of hard to explain,
22 Q. I guess most people assume if you test
23 somebody's blood, that you're always going to have
24 O blood or A blood or whatever it is, --
25 A. That's not going to change.

Page 29
1 Q. -- and I guess people like myself are
2 going to assume that you're always going to get the
3 same result every time you run the test.
4 A. You're not going to always get the exact
5 same number, but the difference you get from one
6 run to another is really clinically insignificant.
7 I mean, a physician is not going to care if you
8 report out of 123 sugar or a 125 sugar. It's not
9 clinically significant.
10 Q. And is that in part why it doesn't make
11 economic sense to recalibrate the machine after
12 every test?
13 A. Recalibrating the machine is not going
14 to make all of you runs exactly the same.
15 Q. It would help, though, wouldn't it?
16 A. Recalibrating is just setting one
17 certain end point. Getting it all the same is
18 precision versus accuracy. I mean, you're
19 calibrating to be accurate, and precision is
20 another thing.
21 Q. Does the role of the technician -- does
22 that play any role at all in the test results?
23 A. In these results? No.
24 Q. Are you familiar with gas
25 chromatography?

Page 30
1 A. From school 20 years ago.
2 Q. And And what is your understanding as to the
3 reason of having that approach as opposed to the
4 approach of the machine that you have at Sartori?
5 A. I really don't know.
6 Q. Do you know if either of those two
7 machines have any different purpose?
8 A. I don't know. Not that I'm aware of.
9 Q. Do you have any opinion as to which of
10 those two machines are the more accurate --
11 A. I don't know.
12 Q. --for blood alcohol?
13 A. I don't really. I' just really not
14 that familiar with their method.
15 A. In the 17 years that you have been
16 there, would it be 99.9 percent of your time has
17 been spent doing technical work for the medical
18 care of patients, as opposed to the legal
19 blood-alcohol?
20. Uh-huh, I would say that.
21 Q. I'm going to ask you, are you aware that
22 there have been communications or conversations at
23 the hospital regarding the care that Julie Farrell
24 received while she was there?
25 A. I was at work that day.

Page 31
1 Q. And are you aware that there have been
2 questions raised as to whether she got the proper
3 medical care?
4 A. I'm not aware of that.
5 Q. You've never heard that before --
6. A. No.
7 Q. -- I just mentioned it to you?
8 A. No.
9 MR. CORRELL: I think I might be done.
10 I'd like to just take a minute and step out.
11 (The deposition was recessed briefly.)
12 A. Ms. Glade, were you made aware of the
13 discrepancy between your test result and the test
14 result that was obtained by the Bureau of Criminal
15 Investigation.
16 A. Yes.
17 Q. And what was your understanding of their
18 test result being?
19 A. I don't know the exact number, but I
20 know it was lower than ours.
21 Q. Did that surprise you when you learned
22 that?
23 A. Uh-huh.
24 Q. And when did you learn that for the
25 first time?

Page 32
1 A. Not that long ago; maybe a month or so
2 ago. I really don't know.
3 Q. And could you tell me from whom you
4 heard that?
5 A. I believe from Diana Jennerman.
6 Q. Did you and she discuss how that result
7 could be different?
8 A. Yeah, we did a little bit. It's a
9 different time period and different method, I guess
10 is about the only thing== we know what happened in
11 our lab. We don't really know what happened in the
12 other.
13 Q. Would you agree that the vials were
14 appropriately sealed?
15 A. Uh-huh. Yes, they were.
16 Q. Would you agree that the difference
17 could be the different methodology used between
18 your hospital and the BCI?
19 A. Probably. I would like to know which
20 vial they used, that's been opened, and
21 the ethanol in the sample is a volatile substance,
22 it will evaporate, and that's why they needed to
24 have used the one that had not been opened, and I
25 assume they did. I don't know what happened in

Page 33
1 that lab, but --
2 Q. You would assume that a man that's been
3 testing it for 23 years would know?
4 A. I don't know anything about the guy.
5 You know, I don't know who did it. I don't know
6 how it was run there, so --
7 Q. But was it marked appropriately so that
8 anybody knowledgeable would know that?
9 A. I have labeled it with my initial and
10 the date.
11 Q. And with regard to the test results, did
12 you and Diana Jennerman discuss that the test
13 result may well be different because they ran a
14 different kind of test than you did?
15 A. Yes, uh-huh.
16 Q. And is that what you believe is the
17 difference as we sit here today?
18 A. Probably.
19 Q. Meaning that if you would have used
20 their machine, you would have probably got their
21 result, and if they would used you machine,
22 they would have got your result?
23 A. That's had to say. The time period is
24 what I'm concerned about. I mean, ethanol is
25 volatile, and it will evaporate, and we ran ours

Page 34
1 the next day. I'm not sure when they ran theirs.
2 A. It won't evaporate if it's properly
3 sealed, correct?
4 A. No.
5 Q. Am I correct?
6 A. Yes.
7 Q. And in fact, those vials are sealed in a
8 way, and they have an ingredient in them that are
9 designed to prevent that very thing, don't they?
10 A. The one that I didn't open would have
11 been totally sealed.
12 A. And aren't they designed so you can
13 analyze what is in there for even years later if
14 it's properly sealed?
15 A. I don't know about years. I don't know
16 what the time limit is on it, but --
17 Q. Would you agree it would be at least
18 months?
19 A. Uh-huh. Yes.
20 MR. CORRELL: I have no further
21 questions. I appreciate you coming down. Thank
22 you.
23 (The deposition was concluded at 5:05 p.m.,
24 March 26, 1997)

 

updated 01/21/17