“What I'm going to do now is ask we get our video started, if it's all right, Your Honor, and I would like you to, Michael, to get where you can see the screen and tell the jury, if you will, what's going on in this video.”

“Okay.You want me to use his, too, or –“

“.No, I think you best come down here. If you can see it from right over there, that will be fine. Can you see it from there? Maybe you can come over here with me. Is that fine, Your Honor?”

20 THE COURT: Certainly.

21 MR. WOODWORTH: With the Court's permission, while we're getting this started, early on, if I may, let me just orient us. We originally told the jury we would bring Terry in in lieu of this film. Your Honor, we think that this will take care of that. This is a film that was made relatively recently at Sabal Palms which is designed to compress the average day for Terry into a twenty minute video so that you all, so the jury can have an opportunity to see what the day was like. And if we can start the video now. Mike, if you will, just as we go along, tell the jury what's happening here. Do you remember when we went over to Sabal Palms? Tell the jury what's going on now.”

“.Right here, basically, you can see she's dressed, she's already had her shower and everything. We would get her dressed, put her shoes and socks on. I'm trying out her hands there. You have to keep the inside of the hands, since she's contracted, you have to keep them dry because infection can set in, and I usually do a little bit of range of motion with her.”

“And while you're doing that, do you talk to her?”

“Yes, I am talking to her right now telling her it's okay.”

“She doesn't like that very much?”

“No, she doesn't. She does feel pain”.

“Does she like that kind of treatment very much?”

“No, she does not. Here I'm trying to bend her leg.”

“Now, I notice under her legs when you did that the skin is very loose; is that true?”

“Yes, it is. Now we're about to transfer her to her wheelchair.”

“Michael, at this time now does she weigh more than she did when she went to see Dr. Igel?”

“No,she doesn't weigh more. What I was just doing with the pad there, it's a jay cushion, and you have to keep it pushed down, you have to move that gel in there around so it fits nicely around her bottom end. We'll sit her up on the edge of the bed and my mother-in-law takes the feet and I'll take the top end and we transfer her into her chair and slide her down, and usually we're pretty careful about the aligning of her body and her hips. Now we'll go about and put the different fixtures on the chair and strap her in”.

“I notice, Michael, you're holding her head back. why are you doing that?”

“Because she'll fall forward, and if she falls fast she gets excited. It's -- I was told by a doctor she was getting the feeling she's falling. This is the cross bar that goes across her chest to keep her from falling forward. This is the tray that goes in front of her arms that holds her instead of her arms contracting in, to hold them out, and we'll also place pillows. You'll see. Now, we'll put the leg braces on.”

“Why do you put the leg braces on for?”

“To help her to keep her knees more bent to help stretch the top muscles of her legs and so it doesn't shorten her legs and the legs won't become stiff and straight out. And we strap her feet in to help because she has foot drop right now and that helps bend the foot down pulling those muscles and putting the foot down. Here I'm brushing her teeth.”

“Do you take her to the dentist from time-to-time?”

“Yes, we do.”

“How often do you do that?”

“We try to do it twice a year. As a matter of fact, she has an appointment Monday. We try to keep her teeth as clean as possible. It's very hard for us to get into the back of her mouth. She clamps down and bites down on the toothbrush. I've had problems before using the suction catheter and she bit the suction catheter there.”

“What are you doing now?”

“I'm putting on makeup. I put on her makeup everyday and I'm finishing up her lipstick. This is the speech pathologist who comes in and works with Terry.”

“This is the speech pathologist you say?”

“Yes, it's the speech pathologist.”

“What does he do for her?”

“He comes in and massages her lips and uses different flavors to try to help her swallow. You'll notice he's moving her lips and it helps massage the side of the mouth so the mouth doesn't tighten up.”

“You hoping he can get her to the point where she swallows?”

“Yes.You see here rubbing the bottom of her throat, that's, I don't know what the word is, gets them to swallow when you rub the bottom of their throat. She just swallowed that time. Sometimes they use ice on her face, too. It's a stimulation.”

“What is that, Mike?”

“That's a -- that is basically used to stimulate her tongue and the back of her tongue to help with her gag reflex. And like I said, sometimes they use different flavors.

“What are you getting ready to do here?”

“We're getting ready to put what's called a tilt table. The lady is helping me and what we'll do is just slide her over to this table.”

“And then after you get her on the table, what happens then?”

“We will slowly stand her to a standing position.”

“Why do you do that?”

“This is very good for like, she has drop legs, and it's good for stretching the Achilles tendon and good for the skin and good for contractors and good for circulation, and it's good for somebody in Terry's condition that lies down all the time. It's good for when -- it's good for replacing the organs in your system back to where they're supposed to be. Now while they're doing this, they usually monitor the blood pressure. Now we're just going to transfer her back into the bed. This is where I'm getting her ready to start her feeding. What that bottle is is her food. It's basically all nutrition. It is all nutritious food.

That wire I'm playing with right there will connect to her catheter or her Peg tube as they call it.”

“That's the tube that goes into her stomach?”

“Into her stomach.”

“How long does that feeding take place? How long does it take to accomplish that?”

“They start her 6:00 in the morning and complete the runs until 8:00 the next morning. Now what I'm doing here is changing the dressing around the stoma. The stoma is very, very important, the most important part of her medical treatment is right now due to the fact that the acids from her stomach could come up through that hole, and if that happens, it's very, very irritating and it's very, very hard to clear up. Acid from your stomach can burn a hole in the rug. What we do is we apply some, what we call Bactroban, it helps soothe the area and keeps the bugs down, also. And if that tube were to come out accidentally and nobody knew it, they would have to take Terry to the hospital and have it opened up again because it will close within five minutes that stoma.”

“What's the problem over here?”

“Terry had a persistent sore on top of her toe, and the hand you see is Dr. Brown the podiatrist coming in and treating it. And what you'll see is see the blackened area keeps coming back and they don't know why so she'll scrape it and see what's going on.”

“Did she have problems with a toe on her other foot? I think we heard some other testimony from Dr. Mulroy about a toe that had to be amputated?”

“On her left foot. The small toe developed an ulceration, what we believe were the potis boots we were using for her and turned to osteomyelitis and her toe had to be removed. The bone had to be taken out. This is the physical therapist that's coming in now. When he gets set up, I'll explain to you what he's doing. The people you see now are assistants.”

“Does she express discomfort when some of these things are happening to her?”

“Yes.Yes, she does.”

“How does she do that?”

“She'll moan and groan.”

“What are these therapists trying to do for her?”

“At the moment they're setting her up so they can use ultrasound on the back of her heel cord and calves.”

“What is that supposed to do?”

“Ultrasound helps to relax the muscles to be better stretched. You'll see when he does it, he'll start stretching the heel cord or the Achilles tendons.”

“Is that a lamb's wool protector over that side rail?”

“Yes, it is. Now, this is the other leg they're doing.”

“And I see is she all healed up on -- from the amputation on that foot?”

“Yes, she's all healed, yes. Now what he's going to start to do is going to stretch that muscle out here.”

“In one fashion or another, Mike, are all of the joints of her body limbered up in some fashion with these various kinds of things that you all are doing for her?”

“It's preventing them from getting any worse, yes. And what he's doing right there is pretty uncomfortable. He's working more with her. We take her out for walks. usually take her out to the pond and sit and feed the ducks. And now the cooler weather is coming and they have a baseball field next to her and little leaguers play ball. I like to get her outside for fresh air.

  February 4, 1992- According to Michael Schiavo's book Terri the Truth, page 53, On February 4, 1992, Glenn Woodworth asked Mary Schindler and Michael Schiavo to come to his office in St. Petersburg. What he told them was, "that after completing all the steps necessary to prepare for the filing of the complaint, he'd decided that he couldn't go ahead with it."
   In a follow-up letter to the February 4 meeting, Woodworth told them that Gary D. Fox,an attorney from a Miami law firm "had expressed a willingness to associate in the handling of this lawsuit on certain conditions, namely that [the Schindlers] we were prepared to present direct testimony of Theresa's eating disorder, and direct testimony that, had it been reported to her physicians, in all likelihood, she would have changed her eating habits. Obviously, such testimony is required in order to establish a connection between the failure of the physicians to inquire of such matters and her low potassium levels., If, indeed, such testimony is not available, the defense will surely prevail because they will be able to take the position that their failure to properly manage Theresa did not make any difference in the outcome."
Attorney Woodworth told them that “this kind of testimony is impossible to obtain from any source.” and added, "The obvious result, therefore, is that, despite our hopes and our preparations, I do not believe that the venture is sufficiently promising to proceed."
   Woodworth's meeting with Michael Schiavo and Mary Schindler and his letter indicating that he wouldn't file the case proved to be premature. Gary Fox changed his mind.

   The preparation that Gary and Glenn did for the trial was extensive and instructive. They ran a mock trial in front of a focus group of people selected to mirror the Clearwater jury pool, and we lost. They changed their arguments, tried it with another focus group mock jury, and lost again.
   It turned out, Gary explained, that the jurors weren’t buying the argument that this was all Dr. Igel’s fault; that if only he had recognized the disease and Terri had been treated for it, she would never have collapsed. The mock jurors told my lawyers that much of this was Terri’s own fault, and that unless we admitted that, they wouldn’t find the doctor even partially responsible. …
   Glenn and Gary worked out a new strategy, and spent the money, somewhere in the neighborhood of $25,000, to hold another mock trial in front of a third focus group. This time, the verdict went our way. [TTT p61-62]

May 1992 -Michael moves out of the Schindlers’ house, at 273 Hermosita Drive, St. Pete Beach, Florida. (Michael states he lived with the Schinders at this address for "A year.")

June 1992: Michael Schiavo starts working at Freedom Square Nursing Pavilion.[ Michael Schiavo, July 27, 1992 malpractice deposition [case no. 92-939CI-15]

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