Notes from Deposition of Shannon Kris James Vol. II

Examination by Ms. Cantolino

The deposition is an updated deposition from November 13th, 2019.
Ground rules for depositions: Ms. Cantolino is not trying to trick Shannon with her questions, and Shannon should ask for clarification if she does not understand a question.
Shannon confirms she is not under the influence of drugs or alcohol.
Shannon James states her full name for the record.
Shannon no longer lives at 155 Augusta Plantation Drive in Myrtle Beach; she now lives in Conway at 3427 Merganser Drive, 29527.
Shannon is still married.
Shannon has not had any new children since her last deposition.
No one is currently financially dependent upon Shannon for support.
Shannon has not been involved in any other lawsuits since her last deposition.
Shannon applied for unemployment after being laid off from Startek and received it for about a month.
Shannon has not applied for social security disability since her last deposition.
Shannon is not a Medicare or Medicaid beneficiary.
Shannon's primary care doctor is still Jason Harrah.
Shannon has not received any new health diagnoses or conditions since her last deposition.
Shannon fills her prescriptions at Kroger.
Shannon has been treated for her MS diagnosis since her last deposition with Dr. Spencer, receiving her regular medication.
Shannon reports having no symptoms from MS.
Shannon cannot pronounce the name of the medication she takes for MS; it is an injection she gets once or twice a year and has no side effects.
Shannon does not remember if she has had any new injuries since her last deposition.
Shannon has not had any other surgeries or been involved in any new accidents since her last deposition.
Dr. Stickler has given Shannon medications for migraines and treatment for headaches, but the headaches have not gone away.
Shannon went to speech therapy and received an injection in the back of her head, which subsided the migraines but not the headache.
Shannon is currently taking Ajovy, topiramate, and amitriptyline for her headaches, twice a day, morning and bed.
The medications are supposed to prevent headaches.
Speech therapy gave Shannon tools to help her speak, which she uses.
Vestibular therapy was helpful for her symptoms.
Shannon last saw Dr. Stickler on June 18th, 2024, or more recently - she believes her next appointment is in October.
Dr. Stickler has not recommended any other treatment other than medications yet.
Shannon has been compliant with taking all the medications Dr. Stickler prescribes.
Shannon was on light-duty restrictions, working four or six hours, but was laid off and cannot find a job with her restrictions.
Shannon had psychiatric treatment with Dr. Lind for anxiety and took a test.
Shannon is still treating with Dr. Lind.
Dr. Lind did not assign any permanent work restrictions or an impairment rating.
Treatment from Dr. Tavel included injections in the back of her neck and a prescribed TENS unit, as well as a block on the base of her head.
Shannon can't say if the neck injections help because she is still hurting, but she would not object to any treatment Dr. Tavel recommends.
Shannon is unsure if the treatment she's received has helped her symptoms.
Shannon last saw Dr. Tavel on September 12th and received an injection.
Shannon hasn't seen Dr. Tavel yet, but she is due to follow up in October.
Dr. Tavel has Shannon on light-duty restrictions and is out of work.
Shannon is not sure what Dr. Lind said about permanent work restrictions.
Shannon is unsure how to answer if she is pleased with the medical treatment she has received, as she just wants the pain to stop.
Shannon does not remember if she has been to any other medical professionals for her work accident since her last deposition.
Shannon believes she needs additional medical treatment.
Shannon has not gone to any other doctors for a second opinion since her last deposition and has no current plans to get a second opinion.
Shannon does not know if she has any outstanding medical bills related to the accident.
Shannon cannot answer if any of her symptoms have improved or remained the same since her last deposition.
Shannon rates her headache pain as a 3 out of 10, describing it as throbbing and located everywhere.
Shannon has headaches all the time and migraines three or four times a week, lasting for days and requiring her to sleep with medication.
Shannon rates the pain of a migraine as an 8.
Shannon experiences nausea with normal headaches.
Shannon sometimes experiences dizziness and sensitivity to light with headaches but not really sensitivity to sounds.
Shannon relates her speech trouble and stuttering to her work accident and it gets worse when she is uncomfortable or nervous.
Shannon is having trouble with short-term and long-term memory loss, such as forgetting things she has already done.
Shannon isn't sure how often she has trouble with memory loss.
Shannon is still having trouble with anxiety related to her accident, describing symptoms of not wanting to talk when around other people.
Shannon currently has neck pain, rating it as a 5 and describing it as a burning-type pain with jolts of pain or numbness down her arm.
Rotating her wrist will shock her fingers, and straightening her neck will bring back feeling when it's numb.
Shannon cannot think of any other symptoms she is currently having related to her work accident.
Shannon is currently receiving workers' compensation checks and has not received any other type of income since her last deposition.
Shannon has applied for jobs but does not remember which ones due to her head injury.
Shannon would like to work but can't say if she could do a light-duty job right now.
Shannon is able to take out her own trash, operate her own vehicle occasionally, and clean her car.
Shannon has trouble doing chores around the home, as it takes her a while to do them.
She experiences pain if she wears a bag over her shoulder, but does not have a number on it and would not say it is unbearable.
She typically carries headache medicine, her phone, her wallet, and water in her bag.
She experiences pain if she turns her head suddenly, but cannot rate the increased pain on a scale of 0 to 10, though sometimes it is unbearable.
She can do chores for about 30 minutes before needing to take a break.
Shannon is wearing earbuds for the deposition but can't wear both of them if she has a headache.
Her hobbies are reading and drawing.
Due to her work injuries, she can no longer do photography and wood burning because it hurts her neck and the smell makes her have a migraine.
Since her last deposition, she went to Fear Fest in North Carolina, which is like Comic-Con for scary movies, but had trouble attending the event due to strobe lights and some of the movies.
She has not been on any other vacations since her last deposition.
When she is at home, she's less anxious with her stutter, but still stammers.
Dr. Stickler has not told her how long she needs the headache medications for.

Examination by Mr. Bass

Shannon remembers the question about whether or not anyone is dependent upon her for support.
Shannon's wife is presumed dependent, and her 19-year-old son, Domonique, lives with her, who could not provide for himself without her help.
Shannon hasn't read all her medical records and does not know what doctors have put in them as far as her diagnoses, so she doesn't really know if she's been given any new diagnoses in the last five years is how she phrased it.
Shannon does not recall being diagnosed depressed and said no to that question, but says he is not absolutely 100% sure she has not been diagnosed with depression since her last deposition. She hasn't read the medical records from Dr. Burkill so no.
Shannon does not remember seeing a neuropsychologist in or around the same office as Dr. Stickler.
Shannon is not certain that he's not been diagnosed with depression since her last deposition, so that was a guess.
Shannon is still being treated by Dr. Tavel, and when asked if the injections "helped," she took her to mean if it was completely relieving the pain.
Shannon does not remember the level of pain he had right before Dr. Tavel administered the injections, nor what her level of pain was three days after each injection, so it is difficult for her to say whether the injections helped.
Shannon did not say that the injections did not help at all, and that Ms. Cantolino tried to put words in her mouth.
Shannon assumes that by "help," counsel meant relieved some of the pain at least temporarily, in which case the injections have, where some of them have helped.
Shannon tells Dr. Tavel whether the injections helped or not when they meet, and this is recorded in the medical records.
Her neck hurt before the injections and it still hurts.
Dr. Tavel administered the occipital nerve block at Dr. Stickler's request.
Shannon knows "darn good and well" that the occipital nerve block helped, as she has not had a migraines since the injection.
Shannon said yes when Ms. Cantolino asked her if she'd been given an impairment rating and all that stuff., which she now states he wrote listen to my questions because he cannot be certain he's released her though he can be certain in what certain means.
All there is to do is read the medical records.
Shannon asks what Ms. Cantolino meant when she asked if he was pleased with the treatment he's received, and that she rephrased it by saying are you happy with the treatment you received.
With respect to Dr. Stickler, Dr. Lind, and Dr. Tavel, they have treated Shannon with respect. With respect to being pleased with the treatment, other than the fact that the occipital nerve block that Dr. Tavel administered seems to have stopped your migraine headaches, Shannon is pleased that his neck still hurts, that he still stutters, the symptoms down his arm that is the right arm. To the extent Shannon still has those symptoms still he is not currently pleased.
When you were asked something like Do you think you need additional,medical treatment you remember that but,are u a medical doctor? and now u as opposed to a Doctor can decide. You still have symptoms. would you like to get added if the Doctors tell you. He confirms absolutely for more treatment.
You were asked whether or not you had plans to get a second opinion that you are not the one to make the decisions
You were asked how often you have headaches,you don't have migraines anymore,do you,it just depends on how much it hurts
You were asked for symptoms of headaches are u aren't you a doctor that you can answer
You're asked about the symptoms when u move ur neck towards the right arm that has symptoms,there times when u move u have pain and it starts to go to the hand for index and the thumb of the hand.