again the security guard said by the yes the receptionist what happened old lady got caught in the doors and she fell the security guard went over to mrs sadness and she stated to the security guard after she had fallen off she was still in the and what happened in this case as a sadness was trying to walk through the doors after they've opened it closed on her while she was still in the in the doorway and that's what is indicated in the medical records because that's what she told the doctor  i mean repeat that this is the defendant's mouth at the defendant's facility the defendant's doctor employing the whoever the doctor was that day that took the history that indicated that she and when he was questioned in his deposition about that statement he said i don't remember the details other than she said she was injured by the door that's on page three fifty eight of the record ok she didn't say that she by the door he didn't even remember her saying that she felt so there is no statement through mr don't we even if his his recollection his recounting as we're admissible under some with what is in the record the statement that is or statement taken that she made during the into the emergency room as to what happened there are two the weight of the door caught her and pushed her forward off her feet the weight of the door right that's all it doesn't say that sliding door squeeze through other words in you describe the scene earlier as before the trial or from a nurse or a doctor or anyone else who could we count what happened during this accident as the plane and could not put forth any evidence to support the elements of his degeneration a lady was ninety she was doing pretty well for nine but she had a lot of health issues and he testified that she couldn't remember from on certain days what she had done earlier in the day so there were or your honor let's just say all of that comes then there's absolutely no evidence that the plaintiff doesn't walk before the court about notice to silver cross hospital about any reasonably records showing that there's been work on the story well your honor i i believe that counsel really lost over what that evidence actually it's there are mr nelson is the director of building services for the hospital and he's the one testified about the maintenance on the doors he supervised meetings all of the buildings and that includes inspecting these doors on a weekly basis his personnel does that and what mr nelson said is that the doors are inspected every week and if they're wrecked if any of his personality or finds a problem with them they the alleged accident and then the time period after so these are the work orders that mr pyles was referring to if not one of those work orders had any sort of repair having to do with the doors closing but there had never been a complaint about that to mr nelson or  mr nelson explained that that was a problem that would prevent the doors open not that they were closed on people so there was no notice to the hospital gave any details but but that work that were ordered does not evidence and notice to the hospital prior to the accident that there was any problem with the doors and there's no evidence at all that the doors were in and reasonably dangerous condition the hospital has you know the plaintiff has to prove that the hospital knew or reasonably should have known about it unmusical a dangerous condition some short term memory problems answer it was when her sister died in two thousand and nine it was november i believe so the short term memory issue that is something that occur over a year took place so we'll talk about short term memory issues about what she remembered what happened the incident the short term memory issues something that was going on after this incident took place what in the security guard actually testified to at the record see three fifty eight this is a page ten of the of where we dealey is deposition line five on page ten and what did she say to you and what did you say to her answer i don't remember the details other than she claimed she was injured by the door that's all i remember question how was she injured by the door answer she claimed the door slammed on her as she was exeter so that's the testimony of the he looked at as the east side doors and he didn't look at the doors now his testimony was that well i didn't see anything wrong with them when i love them but in the deposition testimony this if you're a guard does is very specific and he looked at where the doors were as the allegation the silver cross had no knowledge of what happened we're disregarding the testimony of kimberly deadlock who is the defendant's nurse she indicate in the record and her deposition so simple she she would recall people would be walking to the door and sometimes they were started to cause of or they got through and that was a statement that she heard making that somebody made to the receptionist and again this is not really classic music because we're not talking about whether or not the actual fact took place we're talking about no this did the defendant had noticed that these there was problems with these storms and if you look at the testimony  she goes through in any case not only were there complaints about the door she saw the gun was team work done she saw the doors being worked on multiple occasions she heard complaints of the receptionist that the doors were not working so there is and this is all before the incident you and i just want to say i find it incredible that the council persona across has indicated the silver crosses of medical records are so inherently inconsistent well that's not what they're saying you see if there's nobody to testify is the one that makes that one period i think i disagree they are still the process of medical records and i'm looking at the record this is the even our physician documentation so this is the doctor it's taken a history that indicates mechanical fall and doctor's office and then there's a description of why she was there get her coonan level checked that patients think she is walking through the door and the way to the door harmed her one door is a conventional door i don't see how a slider door pushes you forward but i do can see why how a conventional board closing in on your rear end can push  difference without distinction one of the two sets of water that door slammed on her and her fall and i think that it's pretty clear that you know somebody walking through those doors that were top of the automatic doors in the lobby because the security guard is a description and he talks about where the doors were where they were located because he looked at her after his second this talked about we're not speculating where this happened and we're not also speculating on what happened and that's why  testify either missed or didn't look at that we've just seen she did write that opinion however in this case we know what happened she was there she was walking out the automatic doors of the library where the reception was one of the the at the west side of the building the fact the matter is this you know this lady had a right to go to her doctor's office without a sudden one of many door slamming or that you know the judge or the traffic court indicated she said that she had seen people that were complaining about these gorgeous that they were close enough people and she had heard people that were staff just hearing her that somebody was complaining about the condition to the you know to the doors to an employee of the defendant that's a need would give the defendant notice that the doors were malfunctioning and that they were more in fashion in the same way testimony from the security guard that they were working ok on that day but that the repairs had been done earlier i would suggest you that that's not notice that there was a mouth wash and that it's fire of fact should sort out just as  all the testimony from everybody else and saying that there was that there was complaints about the door it's not about the dog it was one isolated incident in one page of the electronic medical records of the famous medical records that indicates a dog the testimony diagnosis for example you talk about a situation where they can't i think a lot of times the mechanics of what happens to a patient is very important in making a diagnosis of what happened to the patient for example in this case we had some   i'm wondering if one look at the records that they are can you determine which is the statement closest in time to the incident because we've got this dog out there somewhere and we're hearing from him why i have no idea scrivener's there is a possibility of some short term memory loss as possibility why i don't think the short term memory i don't want to go there i'm just saying those are possibilities so we're talking what's closest in