BEFORE ME the undersigned authority personally appeared
CARLA SAUER IYER, R.N., who being first duly sworn, deposes and says:
1. My name is Carla Sauer Iyer. I am over the age of
eighteen and make this statement of my own personal knowledge.
2. 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.
3. 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.
4. 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
5. 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.
6. 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.
7. 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.
8. 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
9. 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
10. 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.
11. 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.
12. 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."
13. 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.
14. 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.
15. 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
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