Cross Questioning Flashcards

1
Q

Mrs. Waffle, you testified that you have always been extremely cautious about Hazel’s peanut allergy, correct?

A

Yes, I have always been extremely vigilant when it comes to Hazel’s peanut allergy. From the time she was diagnosed as a toddler, I’ve made it my top priority to protect her from any exposure to peanuts.

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2
Q

You mentioned that you’ve been managing Hazel’s allergy for many years and that you’re very familiar with the necessary precautions, including always carrying an EpiPen, correct?

A

Yes, I’ve been managing Hazel’s peanut allergy for over a decade, and I’m very familiar with the strict precautions needed to keep her safe. One of the most critical of those precautions is ensuring that she always has her EpiPen with her. I understand how quickly an allergic reaction can escalate, and having the EpiPen close at hand is vital to managing those emergencies.

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3
Q

In fact, you stated that you’ve always ensured that Hazel had her EpiPen with her at all times, is that right?

A

Yes, I made sure that Hazel never left the house without her EpiPen. I would remind her constantly, and whenever we were going out, I’d double-check to see that she had it in her purse or backpack. It was second nature to us at this point because we knew how dangerous her allergy was.

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4
Q

Yet, on the night of July 12th, you did not have an EpiPen with you, did you?

A

No, unfortunately, I didn’t have it with me that night. I didn’t realize until it was too late that the EpiPen wasn’t with us. It was a tragic oversight, and I’ve been replaying that night in my head ever since, wishing I had double-checked like I usually do.

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5
Q

And isn’t it true that the only EpiPen you had was left in Hazel’s makeup bag at a friend’s house?

A

Yes, that’s correct. The only EpiPen we had at the time was in Hazel’s makeup bag, which she had accidentally left at her friend Presley’s house earlier that day. I didn’t realize it was missing until Hazel started showing signs of an allergic reaction. It was a terrible mistake, I would never intentionally put Hazel at risk like that.

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6
Q

Given the severity of Hazel’s allergy, would you agree that having her EpiPen readily available at all times is essential for her safety?

A

Yes, without a doubt. Hazel’s peanut allergy was so severe that we were always aware of the life-threatening consequences if she were to come into contact with peanuts. Having her EpiPen on hand was a non-negotiable part of managing her condition. It was her lifeline in case of an emergency, and I fully understand how essential it was to always have it readily available.

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7
Q

You also testified that you double-checked the special instructions for Hazel’s order, noting her peanut allergy. But even with this precaution, you didn’t verify the restaurant’s acknowledgment of the allergy with the delivery driver, did you?

A

I did mention the allergy in the special instructions when I placed the order, and I also asked the delivery driver, Pepper Mint, if the restaurant had been notified. However, I didn’t press him for further confirmation after he said it had been noted. In hindsight, I should have taken extra steps to ensure the restaurant was fully aware of the severity of Hazel’s allergy, but at the time, I trusted that they had followed the instructions.

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8
Q

And despite knowing that you didn’t have an EpiPen available, you proceeded to let Hazel eat the meal without verifying the safety of the ingredients beyond the app’s instructions, isn’t that correct?

A

Yes, that’s correct. I trusted that the restaurant had received and followed the instructions I provided through the app. I was aware that we didn’t have the EpiPen with us, but I didn’t think there would be an issue because I had clearly noted Hazel’s peanut allergy in the order. I regret not taking additional precautions that night, and it’s something I’ll always carry with me.

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9
Q

You’ve dealt with Hazel’s peanut allergy for over a decade. Would you say that you’ve experienced similar situations where you had to be extra cautious about what she consumed?

A

Yes, we’ve had to be extremely cautious throughout Hazel’s life. From the moment we learned about her peanut allergy, it became a constant responsibility to check every ingredient in everything she consumed. Whether it was eating out, buying packaged foods, or even attending social gatherings, I’ve always had to ensure that her food was completely free of peanuts. There have been numerous situations where I had to ask waitstaff or chefs multiple times to confirm the absence of allergens, and I’d always carry her EpiPen just in case. It’s a constant process of vigilance, and while we’ve navigated it safely for years, we’ve always known how high the stakes are..

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10
Q

So, with all your experience and knowledge about managing Hazel’s allergy, how do you explain not having her EpiPen available when you knew she was about to eat food that could potentially be dangerous?

A

It was a terrible mistake, and I can’t begin to express how much I regret it. With all the years of managing Hazel’s allergy, I’ve always been diligent about keeping her EpiPen with us. On that night, I was so focused on making sure the food was ordered correctly and noting her allergy in the special instructions that I didn’t realize we didn’t have the EpiPen until it was too late. I wish I had double-checked, as I usually do. But in hindsight, I should have known better. I’ve always been aware of how dangerous even the smallest exposure to peanuts can be, and it’s something I’ll carry with me for the rest of my life.

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11
Q

Mrs. Waffle, would you agree that the best precaution you could have taken to protect Hazel that night was to have her EpiPen with you?

A

Yes, without question. The best precaution I could have taken to protect Hazel that night would have been to ensure that her EpiPen was with us. It’s the one tool we always relied on to keep her safe in case of a severe reaction. If we had had it with us, we could have administered it immediately when she began showing signs of an allergic reaction, and I truly believe it would have made a difference. Not having it was a critical mistake, and I understand now how vital it was for her safety.

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12
Q

Finally, considering all the precautions you usually take, wouldn’t you agree that the lack of an available EpiPen directly contributed to Hazel’s inability to survive the allergic reaction?

A

Yes, I do believe that not having the EpiPen available was a significant factor in Hazel’s inability to survive the allergic reaction. It’s heartbreaking to say, but I know that if we had been able to administer the EpiPen quickly, it could have given her body the chance to fight the reaction and buy us time to get her to the hospital. The EpiPen was always our lifeline, and without it, we were helpless that night. It’s something I’ll always carry with me, and I wish I had done more to ensure we had it, especially given the severity of her allergy.

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