Direct Exam Transcript of Mark Chapa Seattle Fire Department

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THE COURT:

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MR. WAKEFIELD:

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THE COURT:

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Sure.

No objection.

1518 is admitted.

(Ex. No. 1518 admitted)

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DIRECT EXAMINATION

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BY MS. KOEHLER: Q.

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Good morning, sir.

Can you state your name for the

record, and give us your business address?

A.

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Mark Chapa, and I'm not sure what you mean by business address.

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Q.

Just the address of where you work.

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A.

I work at various different stations across the city,

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eight different ones.

THE COURT:

Who is your employer, sir?

employer?

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THE WITNESS:

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THE COURT:

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THE WITNESS:

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Who is your

Seattle Fire Department.

Do you know what their address is?

It's, I guess, 300 Third Avenue.

I

don't know the exact address.

THE COURT: address.

It's the Seattle Fire Department

We've got it.

MS. KOEHLER: technicality.

THE WITNESS:

Okay.

Thank you, your Honor.

We always get an address.

Okay.

KEVIN MOLL, CSR

(206) 477-1584

It's just a

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BY MS. KOEHLER:

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Q.

So can you tell us what your job title is?

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A.

Firefighter/paramedic.

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Q.

And I'm going to just go a little bit through your

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history, and then I'm going to have a few questions for

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you.

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A.

Okay.

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Q.

Sir, can you tell us your educational employment

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history, so we can have a snapshot of your background?

A.

Sure.

I have a high school degree, a bachelor's degree

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in neurosciences from the University of Houston.

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been an EMT for 18 years now, and a paramedic now for

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almost eight years.

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Q.

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I've

Can you just, for our purposes, explain to us the difference between a medic and an EMT?

A.

So you have an EMT basic, so that every firefighter in

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the Seattle Fire Department is an EMT basic.

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trained in basic first-aid, CPR.

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They are

The next level above that is EMT/paramedic.

We're

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trained to give medicines, start IVs, recognize

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arrhythmias or cardiac problems, read EKGs, and that

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kind of what separates us from the EMT basic.

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Q.

All right.

And we heard from Lieutenant Fisk before,

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and he explained that all EMTs are trained for King

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County at Harborview; is that correct?

KEVIN MOLL, CSR

(206) 477-1584

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A.

Correct.

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Q.

Okay.

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Well, we're here to talk about September 24,

2015.

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At the time that you responded to this call, had you

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responded to an MCI before?

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A.

No.

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Q.

At this time we've already gone through background on

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MCIs, but were you aware that this was going to become

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an MCI as you were travelling?

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A.

Yes.

We were first dispatched to a single motor

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vehicle accident which, en route, we believed was just

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going to involve two vehicles, which we go to quite

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frequently, but en route it got upgraded to an MCI

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response.

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Q.

And who were you travelling with?

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A.

My partner was driving.

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His name is Paramedic Carl

Gordon.

Q.

And can you just tell us the roles that you have when

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one of you is driving, one of you is not driving, and

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how does that affect your response in a situation?

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A.

So we kind of separate.

We switch off throughout the

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day, or midway through the day, through roles.

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morning Carl started off driving, and they're usually

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designated as the skills person, so they'll start the

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IVs, place an airway, if needed.

KEVIN MOLL, CSR

That

They're kind of the

(206) 477-1584

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facilitator of the treatment, and I'm sitting in the

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officer's seat, on the passenger seat of the ambulance,

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and I'm kind of the one that initiates the treatment

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plan and makes communications with the doctor and the

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hospitals.

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Q.

When you arrived at the scene, just take us through

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what you did initially, before you started actually

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giving any hands on -- hands on with any patient.

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A.

We approached the incident from the north, on Aurora,

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and, coming onto the bridge, I realized that I wanted

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to keep civilian traffic from blocking the north end of

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the bridge, so I requested from our dispatch to notify

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the police department to block access to protect our

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egress, or our potential transportation corridor, so

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that we could get patients off the bridge.

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As we pulled up adjacent to the incident, I first

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noticed several patients laying on the roadway, and

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then got out of the vehicle and kind of assessed the

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scene in front of me.

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Q.

So am I correct that you were the first medic on scene?

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A.

For a very short time, maybe 30 seconds, 40 seconds,

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and then the second medic unit arrived.

Q.

What is the significance of if you're the first unit to

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arrive, then what is the significance in terms of your

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vehicle placement?

KEVIN MOLL, CSR

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A.

I would -- well, some of the things we look for is not

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to block access for the heavy rescue trucks that come

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in, and when we placed the -- when Carl pulled up, I

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think he wanted to just get close to the scene and

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leave access for the trucks.

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Q.

Without having -- well, would you mind showing us where

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your vehicle is?

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microphone, so you could just tell us where the vehicle

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is, and maybe just show us where you -- what you did

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I'm going to give you a pointer and a

initially.

A.

So I was the officer in medic 16.

This is medic 16,

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right here.

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room for somebody to get about by if they needed to,

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but, also, since we had the initial patients that I

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encountered were kind of in this area, wanted us to

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kind of protect them by placing a vehicle between them

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and any potential traffic that was going to come up

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behind us.

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Q.

All right.

So Carl parked here so we could leave some

Thank you very much.

Before you get up,

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could you just show us on Exhibit Number 2, which is

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the MCI diagram, can you just show us the significance

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of the transportation corridors, because I know that

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you worked a lot in that area?

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how those work for us?

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A.

Sure.

Could you just explain

I worked in the north transportation corridor.

KEVIN MOLL, CSR

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So I'm just kind of shuttling patients from the

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treatment area to the ambulances that were --

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eventually they ended up staging closer, but here

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they're still quite a ways away.

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Q.

Thank you, sir.

Now, shortly after, like you said, 30

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seconds after you got there, was it -- who then became

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the medical coordinator?

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A.

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Initially I was the medical group supervisor, and then medic 18 arrived.

We discussed the next course of

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action, what needed to happen.

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Paramedic Pat Kyles about the need to get a better

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count of our patients, and to do that he needed to

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enter the bus.

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I had a discussion with

And then as he was relaying the updated patient

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count, that's when I was relieved by my superior

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medical safety officer, Lieutenant Fisk.

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Q.

And then what role did you then take on?

18

A.

I was assigned as an aide to the transportation leader,

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which is a Lieutenant Aman.

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Q.

What specifically were you aiding?

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A.

Kind of a facilitator, moving patients from the

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treatment area into the ambulances for transport.

Q.

So in facilitating the movement from -- and that would

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be the patients in the red or yellow zones into

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ambulances; am I correct?

KEVIN MOLL, CSR

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A.

I'm sorry, could you repeat?

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Q.

I'm sorry.

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That would be the patients that were in the

red or yellow zones?

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A.

Correct.

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Q.

How did you facilitate?

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What was your -- how did your

job function, facilitating that?

A.

Kind of prioritizing as the patients were coming out of

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the treatment area to the transportation area, which

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one would go first and next, and so forth.

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Q.

And then in determining which patient would be number

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one, number two, and number three, and you're out in

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the field like this, how did you make those decisions,

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just procedurally first, before we go on to specifics?

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A.

We kind of triage patients, we kind of use a sick/not

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sick model.

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are they conscious, are they unconscious, their

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respirations, are they breathing, not breathing, are

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they breathing fast or slow, their pulse rate, fast,

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slow, threading, their skin color, like are they pale,

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sweaty?

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To determine a sick patient, we look at

It only takes 10, 15 seconds.

The initial patients that are coming out of the

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treatment area are all what we would categorize as red,

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sick patients that needed immediate care or transport.

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But we had various levels of red, some worse than

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others.

KEVIN MOLL, CSR

(206) 477-1584

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Q.

Let's start with the worse than others.

That's pretty

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much what we're going to talk about during your

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testimony today.

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time that you got there, how long did it take for

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ambulances to arrive so that you could begin to

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transport patients off of the bridge?

And I would like to ask you, from the

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A.

I can't remember the exact time.

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Q.

Am I correct that you couldn't transport patients until

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the ambulances arrived?

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A.

Correct.

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Q.

So tell us, if you would be so kind, as to the first

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patient that was brought to you, I guess, would be

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priority number one.

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A.

The first patient that was brought to the

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transportation area from the treatment area was a young

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female.

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brought to me on a backboard.

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Q.

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She had severe trauma to her face.

That's fine.

She was

Sorry.

When you say, "severe trauma to the

face," what does that mean?

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A.

It appeared that she had a skull fracture.

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Q.

Could you see it?

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A.

Well, I could see that the front of her face was

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deformed.

Q.

When that patient came to you, did you think that that was, indeed, a high red, number one priority type of KEVIN MOLL, CSR

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patient initially?

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A.

She was definitely red, but unstable, very unstable.

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Q.

Once you triage, once you assess, I mean, are you done

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assessing, or do you continue assessing?

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A.

As far as the same patient, or other patients?

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Q.

The same or other patients.

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A.

Both.

So she was brought to me, and the first

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ambulance at that point -- the crew from the first

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ambulance had arrived, but their apparatus, their

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ambulance, was what I deemed too far of a distance to

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transport this patient to the back of the ambulance.

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requested that they bring the ambulance closer.

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Q.

Did they move the ambulance closer?

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A.

Yes, and --

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Q.

And as they were moving the ambulance closer, did they

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-- once they finished doing that, did you authorize

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patient number one to be loaded onto the ambulance?

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A.

No.

I

At that point patient number two had been brought

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out, so I had two patients, one ambulance, and I had to

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make a quick decision, a reassessment of priority, and

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I deemed that the second patient had a better chance at

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making it to the hospital alive.

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Q.

All right.

When you have to make that type of a

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decision, basically, a life and death decision, how do

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you do that?

KEVIN MOLL, CSR

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A.

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THE COURT:

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I'm not understanding you.

What criteria do you use?

How do you

figure it out?

A.

I figure that the first patient wasn't going to survive

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the possible ten-minute ride to the hospital without

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some further treatment, so I thought that patient

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number two, with a little bit of treatment that I did,

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would survive the ride to the hospital.

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BY MS. KOEHLER:

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Q.

All right.

Let's talk about patient number two then,

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and that's who we'll be talking about for the rest of

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your testimony today.

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As best as you can recall, and I know that documents

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were suspended for you, can you tell us how you treated

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patient number two?

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A.

She had a large, open wound, to her lower extremity.

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don't remember which, left or right.

It was bleeding

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freely, so I stopped to bandage it with a tourniquet,

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and that was the extent of the treatment.

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Q.

Do you know, where was the tourniquet applied?

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A.

On her leg, her lower extremity.

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Q.

Did that slow down the bleeding?

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A.

Yes.

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Q.

Was the amount of blood that was being lost

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significant, before you applied the tourniquet?

KEVIN MOLL, CSR

(206) 477-1584

I

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A.

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Well, she had been deemed a red patient, so it was concerning, yes.

Q.

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Once you were able to apply the tourniquet, what else did you do with respect to that patient?

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A.

I told the ambulance crew to get going to the hospital.

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Q.

All right.

What is your -- so what would be your

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involvement from the time that the patient comes to you

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and then you're deciding that's going to be the first

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person to leave the scene, do you actually help carry

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them?

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get into the ambulance once you released the

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tourniquet?

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A.

How does that physically -- how did that person

They're being carried by a combination of firefighters

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and AMR employees.

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most part.

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Q.

I'm mostly facilitator, for the

And the fire department works -- tell us about your

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role as fire department/transportation assistant.

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do you know the AMR people?

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with them?

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A.

How

What's your relationship

AMR's the company that the City of Seattle contracts

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for our ambulance transports for our low level injuries

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and illnesses.

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Q.

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All right.

And do you -- did you take any records, any

documentation, that you kept in this case?

A.

For patient number two?

KEVIN MOLL, CSR

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Q.

Right.

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A.

No.

3

Q.

Did you view at all the documentation for the AMR?

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A.

No.

5

Q.

The only thing I'd like to do for us, for AMR purposes,

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and this would be the next exhibit, is just look at the

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times, since you didn't create this document.

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So am I correct, under Exhibit Number 1518, that the

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call for AMR, at least, was received at 11:18,

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23 seconds?

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A.

That's what it says.

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Q.

And then it says, "at the scene."

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Is that when they

had arrived at the scene, was 11:40?

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A.

This is not a document that I'm familiar with.

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Q.

All right.

Do you know how long it took from the time

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you arrived at the scene until the time that patient

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two was transported to Harborview?

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A.

No.

19

Q.

After patient number two was gone, just tell us

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generally what happened with you and the scene for the

21

rest of the afternoon.

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A.

I kind of repeated the same thing maybe a dozen times.

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I didn't really -- other than those first two patients,

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I didn't really give any treatment to anyone one else.

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I was just kind of matching patients to ambulances that KEVIN MOLL, CSR

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were waiting.

Q.

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Did you encounter any -- well, let's go back to patient number one.

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Did patient number one survive?

MR. GUTHRIE:

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Your Honor, I'm going to object.

This

patient number one is not a plaintiff in this case.

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THE COURT:

Overruled, but, ladies and gentlemen,

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you will be limited to deciding only the plaintiffs

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that are before you in the case.

9

A.

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This is for context.

I learned later that patient one expired on scene.

BY MS. KOEHLER:

Q.

All right.

Now, with respect to the rest of the scene

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that you handled, from your view of it, did you pay --

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I guess I should be more clear.

14

I apologize.

Other than transporting the patients, as you've

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described, did you take care of the rest of the scene,

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or were you just very focused on doing your particular

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part of the job?

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A.

The very end of the incident, I may have walked around

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it, but most of my area was on the north area of the

20

scene.

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so...

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Q.

I never entered the bus or got onto the Duck,

I do have one question, though.

When you arrived, and

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you arrived quite early, you could see into the bus; am

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I right?

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A.

There was a hole in it?

Yes, but I couldn't see details.

KEVIN MOLL, CSR

I just knew that it

(206) 477-1584

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was occupied.

Q.

Okay.

Sir, after this incident was over, did you have

3

any other involvement with any of the patients in this

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case?

5

A.

I -- one more patient was brought to my attention, that

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an engine company had found along the walkway, on the

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west side of the bridge.

8

been triaged as green, but this engine company had some

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concerns about him, so I went and reexamined him and

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I think he had originally

moved him, I believe, into the yellow category.

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MS. KOEHLER:

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Thank you so much, Mr. Chapa.

I

appreciate your time.

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THE COURT:

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Thank you.

Cross-examination from

International?

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MR. WAKEFIELD:

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THE COURT:

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No, your Honor.

Cross-examination from Ride the Ducks

Seattle?

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MR. GUTHRIE:

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THE COURT:

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No, your Honor.

Cross-examination from the State?

right ahead.

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CROSS-EXAMINATION

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BY MR. PUZ:

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Q.

Good morning.

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A.

Good morning.

KEVIN MOLL, CSR

(206) 477-1584

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Q.

Am I correct that you and the other paramedics and

2

firefighters on the scene were able to get all of the

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red patients and yellow patients transported to the

4

hospital within 30 minutes of this accident?

5

A.

Yes.

I believe that was the case.

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MR. PUZ:

7

THE WITNESS:

8

THE COURT:

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Thank you so much for your service, sir.

Thank you.

Anything from the City, Mr. Seder, or

Ms. Lee?

10

MS. LEE:

No, your Honor.

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THE COURT:

Thank you.

Thank you.

Go ahead and pass your

12

question forms to the end of the jury box, ladies and

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gentlemen.

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we'll see if the jury has any questions for you.

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here.

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Come to chambers, Counsel.

THE COURT:

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for being here.

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THE WITNESS:

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THE COURT:

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Stay

(Chambers conference; not reported)

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Mr. Chapa,

Mr. Chapa, back to work for you.

Thanks

That's it?

Yes.

The plaintiffs can call your next

witness.

MS. KOEHLER:

Yes, Your Honor.

The plaintiffs would

call Ms. Vera Duffie.

THE COURT: would.

Hi, Ms. Duffie.

Come forward, if you

Come right up here and please face me and raise KEVIN MOLL, CSR

(206) 477-1584