her death it's the fact that she had an allergic reaction to the drug defer mean and there's evidence showing that she went in and took something out of her personal belongings put something in her mouth from there is there any evidence that the officer had any knowledge whatsoever at that she might have this allergic reaction which is a different question than the heroin issue you matthews had this training every single year these motueka let's talk about the nd point you were making matthews knowledge you talked about training you talked about a warning that she had used heroin be could be made what's the record show with regard to matthew's knowledge that the plaintiff was frazier had taken heroin right d about what's the issue of where in her case she had several preexisting conditions including the recently surgery she had a mild stroke he had some prior seeders but most importantly  knowledge with regard to frazier and heroin was during the entirety of his shift or was it just after she starts kicking the door and the rd time he goes back she references stomach problems as a result of withdraw its our contention that he knew from the beginning that he knew you know her booking started it's complaint that's the paragraph where you talk about the deliberate indifference claim including the death but also including that pain and suffering war or personal injury that she may have suffered short of that is there a certain time frame that you're arguing that sergeant matthews was responsible for that i'm sorry go completely understand your question your honor in the rd amended complaint you made reference to the fact that it was the deaths but it was also the injuries that ms frazier suffered up until the death i'm focusing on the latter part is there are certain time frame that you're saying sergeant for sergeant matthews was responsible for in terms of ms frazier the deliberate indifference towards mr frazier non emergency mail for the medical nurse that was about the com proffer evidence that sergeant matthews was aware of a substantial risk of injury serious injury and consciously disregarded that risk i fail to see that any evidence supporting either of those criteria no she was obviously in some distress during the four hour period between two hundred and thirty and six thirty in the morning  however every time the surgeon matthews respond that she refused to say what was wrong with her and that testimony is corroborated by two other correctional officers officers ar christians now when she finally did say what was wrong with their that she was suffering from withdrawal he acted appropriately he notified by email the medical staff and then he faced the priest notif in an ambulance get him call doctoring right now well as an adult if he had done those things it's reasonable to assume that the medical staff would have found exactly what nurse which was withdrawal medication no negligence even gross negligence is insufficient to establish great liability for under a deliberate indifference thinker under the circumstances of this difficult to see how he consciously disregard a risk that he had no knowledge of that's that's all i have if the court has any questions i urge the court hours are the most important and finally it didn't matter what it's miss braziers said to mr matthews the video evidence was clear whether weather well it was clear that she was saying and something to him but it doesn't matter what she said or what she did not say what he saw for five and a half hours that night was a woman in medical distress an act of withdrawal and he