STATE OF FLORIDA )
COUNTY OF PINELLAS )
BEFORE ME the undersigned authority personally appeared CARLA SAUER IYER, R.N., who being first duly sworn, deposes and says:
My name is Carla Sauer Iyer. I am over the age of eighteen and make this statement of my own personal knowledge.
I am a registered nurse in the State of Florida, having been licensed continuously in Florida from 1997 to the present. Prior to that I was a Licensed Practical Nurse for about four years.
I was employed at Palm Garden of Largo Convalescent Center in Largo, Florida from April of 1995 to July 1996, while Terri Schiavo was a patient there.
It was clear to me at Palm Gardens that all decisions regarding Terri Schiavo were made by Michael Schiavo, with no allowance made for any discussion, debate or normal professional judgment. My initial training there consisted solely of the instruction “Do what Michael Schiavo tells you or you will be terminated.” This struck me as extremely odd.
I was very disturbed by the decision making protocol, as no allowance whatsoever was made for professional responsibility. The atmosphere throughout the facility was dominated by Mr. Schiavo’s intimidation. Everyone there, with the exception of several people who seemed to be close to Michael, was intimidated by him. Michael Schiavo always had an overbearing attitude, yelling numerous times such things as “This is my order and you’re going to follow it.” He is very large and uses menacing body language, such as standing too close to you, getting right in your face and practically shouting.
To the best of my recollection, rehabilitation had been ordered for Terri, but I never saw any being done or had any reason at all to believe that there was ever any rehab of Terri done at Palm Gardens while I was there. I became concerned because nothing was being done for Terri at all, no antibiotics, no tests, no range of motion therapy, no stimulation, no nothing. Michael said again and again that Terri should NOT get any rehab, that there should be no range of motion whatsoever, or anything else. I and a CNA named Roxy would give Terri range of motion anyway. One time I put a wash cloth in Terri’s hand to keep her fingers from curling together, and Michael saw it and made me take it out, saying that was therapy.
Terri’s medical condition was systematically distorted and misrepresented. When I worked with her, she was alert and oriented. Terri spoke on a regular basis while in my presence, saying such things as “mommy,” and “help me.” “Help me” was, in fact, one of her most frequent utterances. I heard her say it hundreds of times. Terri would try to say the word “pain” when she was in discomfort, but it came out more like “pay.” She didn’t say the “n” sound very well. During her menses she would indicate her discomfort by saying “pay” and moving her arms toward her lower abdominal area. Other ways that she would indicate that she was in pain included pursing her lips, grimacing, thrashing in bed, curling her toes or moving her legs around. She would let you know when she had a bowel movement by flipping up the covers and pulling on her diaper.
When I came into her room and said “Hi, Terri”, she would always recognize my voice and her name, and would turn her head all the way toward me, saying “Haaaiiiii” sort of, as she did. I recognized this as a “hi”, which is very close to what it sounded like, the whole sound being only a second or two long. When I told her humorous stories about my life or something I read in the paper, Terri would chuckle, sometimes more a giggle or laugh. She would move her whole body, upper and lower. Her legs would sometimes be off the bed, and need to be repositioned. I made numerous entries into the nursing notes in her chart, stating verbatim what she said and her various behaviors, but by my next on-duty shift, the notes would be deleted from her chart. Every time I made a positive entry about any responsiveness of Terri’s, someone would remove it after my shift ended. Michael always demanded to see her chart as soon as he arrived, and would take it in her room with him. I documented Terri’s rehab potential well, writing whole pages about Terri’s responsiveness, but they would always be deleted by the next time I saw her chart. The reason I wrote so much was that everybody else seemed to be afraid to make positive entries for fear of their jobs, but I felt very strongly that a nurses job was to accurately record everything we see and hear that bears on a patients condition and their family. I upheld the Nurses Practice Act, and if it cost me my job, I was willing to accept that.
Throughout my time at Palm Gardens, Michael Schiavo was focused on Terri’s death. Michael would say “When is she going to die?,” “Has she died yet?” and “When is that bitch gonna die?” These statements were common knowledge at Palm Gardens, as he would make them casually in passing, without regard even for who he was talking to, as long as it was a staff member. Other statements which I recall him making include “Can’t you do anything to accelerate her death - won’t she ever die?” When she wouldn’t die, Michael would be furious. Michael was also adamant that the family should not be given information. He made numerous statements such as “Make sure the parents aren’t contacted.” I recorded Michael’s statements word for word in Terri’s chart, but these entries were also deleted after the end of my shift. Standing orders were that the family wasn’t to be contacted, in fact, there was a large sign in the front of her chart that said under no circumstances was her family to be called, call Michael immediately, but I would call them, anyway, because I thought they should know about their daughter.
Any time Terri would be sick, like with a UTI or fluid buildup in her lungs, colds, pneumonia, Michael would be visibly excited, thrilled even, hoping that she would die. He would call me, as I was the nurse supervisor on the floor, and ask for every little detail about her temperature, blood pressure, etc., and would call back frequently asking if she was dead yet. He would blurt out “I’m going to be rich!,” and would talk about all the things he would buy when Terri died, which included a new car, a new boat, and going to Europe, among other things.
When Michael visited Terri, he always came alone and always had the door closed and locked while he was with Terri. He would typically be there about twenty minutes or so.
When he left Terri would would be trembling, crying hysterically, and would be very pale and have cold sweats. It looked to me like Terri was having a hypoglycemic reaction, so I’d check her blood sugar. The glucometer reading would be so low it was
below the range where it would register an actual number reading. I would put dextrose in Terri’s mouth to counteract it. This happened about five times on my shift as I recall.
Normally Terri’s blood sugar levels were very stable due to the uniformity of her diet through tube feeding. It is my belief that Michael injected Terri with Regular insulin, which is very fast acting.
The longer I was employed at Palm Gardens the more concerned I became about patient care, both relating to Terri Schiavo, for the reasons I’ve said, and other patients, too. There was an LPN named Carolyn Adams, known as “Andy” Adams who was a
particular concern. An unusual number of patients seemed to die on her shift, but she was completely unconcerned, making statements such as “They are old - let them die.” I couldn’t believe her attitude or the fact that it didn’t seem to attract any attention. She made many comments about Terri being a waste of money, that she should die. She said
it was costing Michael a lot of money to keep her alive, and that he complained about it constantly (I heard him complain about it all the time, too.) Both Michael and Adams said that she would be worth more to him if she were dead. I ultimately called the police relative to this situation, and was terminated the next day. Other reasons were cited, but I
was convinced it was because of my “rocking the boat.”
Ms. Adams was one of the people who did not seem to be intimidated by Michael. In fact, they seemed to be very close, and Adams would do whatever Michael told her.
Michael sometimes called Adams at night and spoke at length. I was not able to hear the content of these phone calls, but I knew it was him talking to her because she would tell
me afterward and relay orders from him.
While at Palm Gardens, I became fearful for my personal safety. This was due to Michael’s constant intimidation, including his menacing body language, vocal tone and mannerisms.
I have contacted the Schindler family because I just couldn’t stand by and let Terri die without the truth being known.
FURTHER AFFIANT SAYETH NAUGHT.
CARLA SAUER IYER, R.N.
The foregoing instrument was acknowledged before me this _____ day of September, 2003, by CARLA SAUER IYER, R.N., who produced her Florida driver’s license as identification, and who did / did not take an oath.
My commission expires:
STATE OF FLORIDA
COUNTY OF PINELLAS
BEFORE ME the undersigned authority personally appeared HEIDI LAW who being first duly sworn deposes and says:
My name is Heidi Law, I am over the age of 18 years, and make this statement on personal information.
I worked as a Certified Nursing Assistant at the Palm Gardens nursing home from March, 1997 to mid-summer of 1997. While I was employed at Palm Gardens, occasionally I took care of Theresa Schiavo. Generally, I worked the 3 p.m. to 11 p.m. shift, but occasionally also would work a double shift, until 7 a.m. the following morning.
At Palm Gardens, most of the patient care was provided by the CNAs, so I was in a good position to judge Terri’s condition and observe her reactions. Terri was noticeable, because she was the youngest patient at Palm Gardens.
I know that Terri did not receive routine physical therapy or any other kind of therapy. I was personally aware of orders for rehabilitation that were not being carried out. Even though they were ordered, Michael would stop them. Michael ordered that Terri receive no rehabilitation or range of motion therapy. I and Olga would give Terri range of motion anyway, but we knew we were endangering our jobs by doing so. We usually did this behind closed doors, we were so fearful of being caught. Our hearts would race and we were always looking out for Michael, because we knew that, not only would Michael take his anger out on us, but he would take it out more on Terri. We spoke of this many times.
Terri had very definite likes and dislikes. Olga and I used to call Terri “Fancy Pants,” because she was so particular about certain things. She just adored her baths, and was so happy afterward when she was all clean, smelling sweet from the lotion her mother provided, and wearing the soft nightgowns her mother laundered for her. Terri definitely did not like the taste of the teeth-cleaning swabs or the mouthwash we used. She liked to have her hair combed. She did not like being tucked in, and especially hated it if her legs were tightly tucked. You would always tell when Terri had a bowel movement, as she seem agitated and would sort of “scoot” to get away from it.
Every day, Terri was gotten up after lunch and sat in a chair all afternoon. When Terri was in bed, she very much preferred to lie on her right side and look out the window. We always said that she was watching for her mother. It was very obvious that her mother was her favorite person in the whole world.
I worked side-by-side with another CNA named Olga and could tell that she and Terri were especially close. Olga took a definite personal interest in Terri, and Terri responded to her. I could tell that Terri was very satisfied and happy with Olga’s attentions to her.
When Olga was talking with Terri, Terri would follow Olga with her eyes. I have no doubt in my mind that Terri understood what Olga was saying to her. I could tell a definite difference between the way Terri responded to Olga and the way she reacted to me, until she got used to my taking care of her. Initially, she “clammed up” with me, the way she would with anyone she did not know or was not familiar or comfortable with. It took about the fourth or fifth time taking care of her alone, without Olga, that Terri became relaxed and cooperative and non-resistant with me.
Terri reacted very well to seeing a picture of her mother, which was in her room. Many times when I came on duty it would be lying face down where she could not see it.
At least three times during any shift where I took care of Terri, I made sure to give Terri a wet washcloth filled with ice chips, to keep her mouth moistened. I personally saw her swallow the ice water and never saw her gag. Olga and I frequently put orange juice or apple juice in her washcloth to give her something nice to taste, which made her happy. On three or four occasions I personally fed Terri small mouthfuls of Jello, which she was able to swallow and enjoyed immensely. I did not do it more often only because I was so afraid of being caught by Michael.
On one occasion Michael Schiavo arrived with his girlfriend, and they entered Terri’s room together. I heard Michael tell his girlfriend that Terri was in a persistent vegetative state and was dying. After they left, Olga told me that Terri was extremely agitated and upset, and wouldn’t react to anyone. When she was upset, which was usually the case after Michael was there, she would withdraw for hours. We were convinced that he was abusing her, and probably saying cruel, terrible things to her because she would be so upset when he left.
In the past, I have taken care of comatose patients, including those in a persistent vegetative state. While it is true that those patients will flinch or make sounds occasionally, they don’t do it as a reaction to someone on a constant basis who is taking care of them, the way I saw Terri do.
I witnessed a priest visiting Terri a couple of times. Terri would become quiet when he prayed with her. She couldn’t bow her head because of her stiff neck, but she would still try. During the prayer, she would keep her eyes closed, opening them afterward. She laughed at jokes he told her. I definitely know that Terri “is in there.”
The Palm Gardens staff, myself included, were just amazed that a “Do Not Resuscitate” order had been put on Terri’s chart, considering her age and her obvious cognitive awareness of her surroundings.
During the time I cared for Terri, she formed words. I have heard her say “mommy” from time to time, and “momma,” and she also said “help me” a number of times. She would frequently make noises like she was trying to talk. Other staff members talked about her verbalizations.
Several times when Michael visited Terri during my shift, he went into her room alone and closed the door. This worried me because I didn’t trust Michael. When he left, Terri was very agitated, was extremely tense with tightened fists and some times had a cold sweat. She was much less responsive than usual and would just stare out the window, her eyes kind of glassy. It would take much more time and effort than usual to work her hands open to clean her palms.
I was told by supervisory staff that Michael was Terri’s legal guardian, and that it didn’t matter what the parents or the doctors or nurses wanted, just do what Michael told you to do or you will lose your job. Michael would override the orders of the doctors and nurses to make sure Terri got no treatment. Among the things that Terri was deprived of by Michael’s orders were any kind of testing, dental care or stimulation. I was ordered by my supervisors to limit my time with Terri. I recall telling my supervisor that Terri seemed abnormally warm to the touch. I was told to pull her covers down, rather than to take her temperature. As far as I know, Terri never left her room. The only stimulation she had was looking out the window and watching things, and the radio, which Michael insisted be left on one particular station. She had a television, and there was a sign below it saying not to change the channel. This was because of Michael’s orders.
As a CNA, I wanted every piece of information I could get about my patients. I never had access to medical records as a CNA, but it was part of my job duties to write my observations down on sheets of paper, which I turned over to the nurse at the nurses station for inclusion in the patients charts. In the case of Terri Schiavo, I felt that my notes were thrown out without even being read. There were trash cans at the nurses stations that we were supposed to empty each shift, and I often saw the notes in them. I made extensive notes and listed all of Terri’s behaviors, but there was never any apparent follow up consistent with her responsiveness.
I discussed this situation with other personnel at Palm Gardens, particularly with Olga, and another CNA, an older black man named Ewan Morris. We all discussed the fact that we could be fired for reporting that Terri was responsive, and especially for giving her treatment. The advice among the staff was “don’t do nothin’, don’t see nothin’ and don’t say nothin’.” It was particularly distressing that we always had to be afraid that if Michael got upset, he would take his anger out on Terri.
I recall an incident when Olga became very upset because Terri started to get a sore spot, because it might lead to a bedsore. Michael was told about it but didn’t seem to care. He didn’t complain about it all, in fact, saying “she doesn’t know the difference.” When Terri would get a UTI or was sick, Michael’s mood would improve.
FURTHER AFFIANT SAYETH NAUGHT.
Heidi Law, Affiant
STATE OF FLORIDA
COUNTY OF PINELLAS
Sworn to and subscribed before me this day of September, 2003, by HEIDI LAW, who produced a Florida Driver’s License as identification.
My Commission expires: