Direct (full words) Flashcards
Please introduce yourself to the court.
Hello, my name is Dr. Anna Phylaxis. I specialize in food allergies
Can you tell us a little about your education?
I graduated from UT Austin with a degree in biology. I then obtained my medical degree from Johns Hopkins University
And can you explain some of your professional background?
I completed my residency at the Mayo Clinic. I then began working at Massachusetts General Hospital. I’ve been there for twenty years and am the Attending Allergist and Immunologist. I am also board certified in Allergy and Immunology.
Have you dealt with any cases where an individual was exposed to an allergen through a restaurant?
Yes. Thirty cases. In those cases I analyzed both the allergic reactions and allergen management by the restaurants.
How did you go about your analysis?
I examined the three things within Herb’s Haven that could have contributed to allergen contamination in Hazel’s food.
What are those?
(Hold up one finger as you say each of these) Lack of adequate training on allergens, improper allergen isolation, and poor communication.
What did you determine about the Defendant’s (point to Herb) training?
(Write on whiteboard “1. Training = Entirely Inadequate” as you say the following) It was entirely inadequate.
Why?
There were training materials in the kitchen on allergens, but they were not regularly reviewed. This led to staff not knowing how important it was to identify allergens like peanuts and isolate them so that they did not get into Hazel’s food.
What about the Defendant’s actual allergen isolation?
(Write “2. Allergen Isolation = Completely Insufficient” as you say the following) As you can probably guess, it was also completely insufficient.
How so?
Allergy-containing ingredients were not marked as such and stored separately. In this case powder containing nuts was transferred from a container labeled as having nuts into a container that was not labeled. The nut allergen was then taken from the unlabeled container and put in Hazel’s food.
What about the Defendant’s communication practices?
(Write “3. Communication = Did Not Communicate Peanut Allergy to All Staff” as you say the following) They did not communicate allergy concerns to everyone involved in the food preparation process.
Can you explain that?
Yes. Hazel’s mother specifically instructed Herb’s Haven to not include peanuts in Hazel’s food because she was allergic to them. Despite this, individuals like Chef Sage (point to Basil Sage), who was in charge of the kitchen, did not make sure all staff preparing the food were aware of the dangerous allergy. This resulted in peanuts being put in Hazel’s food.
