Trial Day 20

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This court is now in session. Please be seated.

Good morning, Your Honor. May I proceed?

Yes, please.

Your Honor, before the court today, we have the matter of Commonwealth versus Lindsay Clancy. Ms. Clancy is present. She is represented by attorney Kevin Reddington. The Commonwealth is represented by Assistant District Attorney Jennifer Sprague and Assistant District Attorney Shannon Buckingham.

All right. Well, good morning, everyone. Good morning, Counsel.

Good morning, your Honor.

Morning Ms. Clancy.

Morning, Your Honor.

All right. Well, I guess as we always seem to start every morning, if I could see everybody over at the sidebar, please. All right. All set for the-

[inaudible 01:29:37].

Yeah. I'll sit for the jury.

[inaudible 01:29:39]. All rise. Jurors entering. Here ye, here ye, here ye. All persons having anything to do before the Honorable William Sullivan, Justice of the Superior Court, now sitting in Plymouth, within and for the Commonwealth. Draw near, give your attendance and you shall be heard. God save the Commonwealth of Massachusetts. This court is now in session. Please be seated.

Good morning, Your Honor. May I proceed?

Yes, please.

Before the court today, we have the continuation of the jury trial in the matter of Commonwealth versus Lindsay Clancy. Ms. Clancy is present. She is represented by attorney, Kevin Reddington. The Commonwealth is represented by Assistant District Attorney Jennifer Sprague and Assistant District Attorney Shannon Buckingham.

Good morning, everyone.

Good morning.

All right. It's nice to see everyone. So what I'm going to do is I'm going to ask you the questions again, make sure everybody's able to follow those instructions, then go a little bit in regards to what our schedule is today, and then we'll talk maybe about where we go after today. All right. So first off, let me get to those questions. Has any member of the jury read, seen, heard, or overheard anything from any source about any aspect of this case which would affect your ability to be a fair and impartial juror?

No.

All right. Next question. Is there any other serious matter or concern bearing on your service as a juror in this case that anybody needs to bring to my attention?

Mm-mm.

Again, thank you so much for following those instructions. Now, what we're going to do today is we're going to return to the witness who was on the stand. Commonwealth is still conducting direct examination. After that, the defense will be given the opportunity to do their cross-examination. And I believe after that, the commonwealth has one last witness. Okay? And so, that's the anticipated lineup that we have today. And going beyond that, I'm not going to speculate too much because I've been wrong just about every time I gave you an estimate of the symbol of the schedule. But just so you understand, it's anticipated that these would be the last two witnesses. All right? And then I'll talk to the lawyers. We'll kind of see where we go from there. And then I will, today, before you leave, I'll explain exactly what the next step is going to be. Okay? And so with that, return, if we can have the witness back on the stand and the Commonwealth.

Good morning. Do you solemnly swear that the testimony you give [inaudible 01:33:10] shall be the truth, the whole truth, and nothing but the truth, so help you God?

I do.

Thank you, sir. You may be seated.

Step please.

Good morning, Doctor.

Good morning, Your Honor.

All right, [inaudible 01:33:26].

Thank you, Your Honor. Do you need a moment?

I do.

So, Doctor, could you tell us what is peri-traumatic... Sorry, let me start over. Can you tell us what peri-traumatic disassociation is and whether it factored into your evaluation in this case?

Yes. That's the kind of thing that you experience when you're going through a very frightening or traumatic set of situation or circumstances or whatever. And it's the sort of thing that you can experience in the sense that you feel that things are unreal or that it's not you. It's like you're watching yourself go through actions and so on. And it's the sort of thing that if you talk about it, it sounds like it could be psychotic, but it's more likely to be a recognized aspect of going through a traumatic situation or set of circumstances that many people going through something like that would experience.

And when you say going through something like that, are you talking about when the defendant was strangling her children?

That would be one example because that was very traumatic for her.

And did the defendant show signs of peri-traumatic disassociation in the records or in your conversation with her?

She did. She talked about feeling like it wasn't her, like she was watching herself, like she was going through what she called no thinking, no decision making, only responding to the voice and taking action.

And when she said that there was no decision making involved, did you see anything in the records or in her detailing of what happened that was inconsistent with that claim that there was no decision making?

Yeah, this is difficult, but important to say that there are just many ongoing decisions that have to be made to accomplish a killing like this in 18 to 20 minutes. For example, why the basement? Who among the children goes first? What do you say to the kids to keep them from panicking? There are other examples, but...

Yeah, hold on.

And so what types of decisions, without getting to what she might have said or thought, what are some types of decisions that had to be made to effectuate the strangulation of the children?

Well, I tried to give some examples a minute ago and I don't want to go too-

I object to the editorial.

All right, hold on. Just answer the question. All right? Don't comment on the rulings of the court. Just answer the question, please. Okay?

If I could rephrase.

Yeah. Yeah.

Doctor, the choice of where to strangle the children, does that have to be a choice of where that happens?

Yes.

The decision of how to strangle them, is that a decision that needs to be made?

Yes.

What to use to strangle the children, is that a decision that has to be made?

[inaudible 01:37:25]. I'm sorry, I have to object.

Overruled. I'll allow that.

What to use to strangle the children, is that a decision that has to be made?

Yes, it is.

The order in which to strangle the children, is that a decision that has to be made?

That's another example of the decision, yes.

Okay.

Decisions.

And the way in which to kill herself, were those decisions that had to be made?

Yes, they were.

Now, you said that this peritraumatic disassociation seems like it would be a sign of psychosis, but isn't. Why isn't it?

It's actually something that is much more commonly experienced in that kind of set of circumstances than psychotic symptoms.

And yesterday when you went through the two options that you considered, that this was psychosis with command hallucinations or suicide with altruistic filicide, is your testimony that it's either/or, or it's one or the other?

It's my testimony that those were the two possibilities that seemed to have some evidence. But at the end of talking to her, testing, reviewing all the information, doing the collateral interviews, everything I did as a part of this evaluation, the evidence much more strongly, in my opinion, supported the second explanation, which was the serious suicide attempt accompanied by killing the children out of love.

... accompanied by killing the children out of love.

Now, you interviewed the defendant on two days, the first day and the third day, correct?

Yes, that's correct.

And were there any differences in her demeanor or her way of answering questions between the first day and the third day?

Yes. Actually, I interviewed her and worked with her on testing for three days. And during the first and the second day, she was quite attuned to the question. Her recollection was good, even considering that we were more than three years away from some of the events in question. She had, I thought a very good memory for dates and medications and dosages and times and other relevant details. And she continued to have to be attentive and responsive, good attention, concentration, that sort of thing on the second day. On the third day, when we were talking about mental state at the time of the offense and the circumstances of what was going on with the alleged offense, she appeared to me much more cautious and guarded.

And can you give us some examples of that?

She more frequently said, "I don't remember, I don't recall," that sort of thing during the third day than the second or the first. For one example, I asked her about wearing a smartwatch, which she had carried a phone, carried a smartwatch as well, and one of the things I asked her is what wrist she wore it on. This was on the third day and she said, "I don't remember."

And did you also ask her about her statement at Brigham and Women's when she woke up and said she was horrified?

I did. Now that statement was not a statement so much as it was a written. She woke up in having regained consciousness that evening, she was intubated so she couldn't speak, but they asked her questions and she wrote down the answer and they asked her, "How are you feeling?" Or "What's your mood?" And what she wrote was "Horrified."

And when you asked her about that on that third day of interviewing, what was her response?

She said, "I don't remember writing that and I don't remember why I would've been horrified."

And did you also ask her about the statement she made at Brigham and Women's, either verbally or on writing it down about how she said that one of the reasons she killed the children was because she thought they would suffer?

Where are you? Are you in my report there?

Referring to the records at Brigham and Women's where she told...

I'm going to object, Your Honor. She's going to lead him with the records.

She can refer to where she's looking to direct his attention, if he reviewed those.

You reviewed the Brigham and Women's records, correct?

I did, yes.

And the portion where it says that she told a treatment provider that she had to kill the kids to kill herself because the kids would suffer. Do you recall that statement?

Yes, I do recall that statement.

And when you asked her about it on the third day of interviewing her, did she recall that statement?

Yes. That statement in Brigham and Women's to the attending psychiatrist was made in the context of her thinking about what happened. Let me see if I can find it here. Yeah, she was asked about what the voice had said on that afternoon and her response was, it had said, "You have to kill yourself so you can kill the kids." It also said, "The kids will suffer without you." And when I asked her about that, whether the voice had said that, she said, "No, the voice only said, this is your last chance. You have to kill the kids so you can kill yourself."

So I'm going to move to strike as not responsive.

No, overruled. I'll allow it.

So the two differences where at Brigham, she's saying the voice said, "You have to kill yourself so you can kill the children," and that the children would suffer without her versus after that when she says the voice only said, "You have to kill the kids so you can kill yourself," is the fact that she's giving two different statements significant in your evaluation?

As I talked about in my testimony yesterday, when there is inconsistency, that's something that alerts me to the possibility of inaccuracy and two statements that are mutually exclusive or inconsistent suggest to me that there is a problem. One of them at least is not accurate.

Doctor, did you find any significance in your evaluation to the fact that she was able to complete a phone call with her husband during this timeframe of killing the children and herself?

Yes. That was very unusual in my experience to have a crucial time interrupted by something like a phone call, because one of the considerations there is that you then not only can document the time that it happened and that helps be more precise about the time, but you also have whoever is on the other end of the phone, and this was her husband. When he called her at 5:33, she didn't pick up, but she called back immediately at 5:34. And when I talked to him during the collateral interview, one of the things he said is that she sounded on the short call distracted and like she was in the middle of something, but it wasn't anything that struck him as that unusual. He said when she's home with three kids, she's always in the middle of something. So that was one of the reasons that it was important. And then another reason, as I mentioned a minute ago, is it helps to establish a timeframe. We know when her husband left the house, which was 5:15, we know when he came home, which was around six o'clock, and this is not quite in the middle of it, but close to that. And so it was unusual and valuable and important in trying to establish those kinds of things.

And when reviewing the records and talking to the defendant, did you notice any statements or behaviors that seemed to focus in on herself, such as, for example, being future oriented?

Well, one of the things I noticed from the records at Brigham and Women's is that several days after she came in, there were comments from staff and in the notes about how she was a little bit more future oriented and thinking about what it would be like in the future, her life and that sort of thing. So that's one of the considerations that was in response to kind of thinking about herself and being oriented toward herself.

And is there any significance to that state of mind or those thoughts in your evaluation of her?

Well, I don't think that she was in any way over this or thinking only about herself. It's something that I noticed when I evaluated her in April is that she is still grieving. She's still in mourning for those kids and she used language like, "I have lost everything and I don't want to be here." So I would not think of Lindsay Clancy as someone who is really self-centered or oriented only to herself. She is grieving her children.

And you mentioned yesterday the emphasis she had on control of though and control of her life. How did that come into play in your evaluation in terms of what was done here?

One of the considerations is why she got to the point where she decided to take her own life. And she's an individual who for most of her life has been disciplined and liked to control things, liked to work hard, liked to accomplish things, and one of the things that was striking about what happened with her between October and January is that she seemed to be doing her best talking to the doctors, talking to the therapists, working on trying to get things accomplished in terms of lessening the anxiety and getting the right medications. And it wasn't working and she couldn't help make it work. She could not control that through hard work and discipline and so on. And that had to be very frustrating and I think got her to the point where it was very difficult for her to actually think about not being hopeless and going on with her life and so on.

Now Doctor, did you form an opinion to a reasonable degree of psychological certainty as to whether or not the defendant was suffering from a mental disease or defect at the time she killed her children?

I did, yes.

And what is that opinion?

That opinion is yes, she was. She was experiencing bipolar II disorder, depressive symptoms, and there were other things that were exacerbating that, making it worse. One is the sleep problems and probably the continued adverse reactions to medication and so on. But yes, in my opinion, she did have a mental disease or defect on January 24th.

And Doctor, to a reasonable degree of psychological certainty, did you form an opinion as to whether or not the defendant appreciated the criminality or wrongfulness of her conduct when she killed her children?

I did, yes. And at the end of my report, I was very careful about how I phrased this. And so...

Objection [inaudible 01:50:53].

Sustained. If you could just answer the question regarding your opinion.

So yes, you formed an opinion?

I did, yes.

And what is that opinion?

That opinion is that she retained an awareness of the illegality of killing others, including killing her children. Her moral awareness of the wrongfulness of this killing was influenced by her strong desire to die and if she were dead, not to leave her children behind. Some of this perception was realistic. For example, "My children will suffer without me," because they would have suffered, I think. And some of it was distorted. For example, "Nobody else can care for my children." But her awareness of the illegality and moral wrongfulness of such killing is best appraised by understanding these acts as a serious suicide attempt combined with altruistic filicide, killing her children out of love, rather than as a response to command hallucinations.

And did you form an opinion to a reasonable degree of psychological certainty as to whether Ms. Clancy was able to conform her conduct to the requirements of the law when she killed her children?

Yes.

And what is that opinion?

That her capacity to conform a conduct to the requirements of the law is again best understood by considering the seriousness of her suicide attempt and her strong desire not to leave her children. She demonstrated such self-control throughout the day on January 24th, and her actions between 5:15 and 6:00 PM that afternoon were influenced by her depression and her hopelessness about her life and the desire to end the pain she had experienced since October. Although this depression and hopelessness influenced her decisions, she retained control over whether, when, and how she carried it out and the inclusion of her children.

And Doctor, did you form an opinion to a reasonable degree of psychological certainty as to whether or not the defendant was criminally responsible when she killed her children?

Yes.

And what is that opinion?

My opinion, my clinical opinion, since I'm not the decision maker here, but my clinical opinion is that she was criminally responsible on January 24th.

Thank you. Your Honor, I'd move to submit the PowerPoint for identification.

I'm sorry?

I'd move to submit the PowerPoint for identification.

For identification. Okay. Thank you. That may be done.

[inaudible 01:53:43].

Attorney Reddington.

Thank you. Sorry. Doctor, I'd just like to ask you about one of the things you just said to this jury that apparently stood out in your mind, and that would be the dichotomy of the difference between two statements that Lindsay made, one being, I believe, in the hospital, and you felt that there was a subsequent statement that was made by her that contradicted that or was different from that, and that would be after three days of you and Mack testing her. Is that right? Can you just say, is it right or wrong?

Mr. Reddington, it's not quite right.

Okay. Why don't we do it this way?

Yeah.

You just told this jury that Lindsay made a statement to you at the conclusion of the three days that you and Mack were questioning her and testing her and interviewing her. Is that fair? Yes or no?

What I would say is...

Yes or no?

No.

Did you tell this jury in addition that Lindsay made a different statement when she was in the hospital? Yes or no?

What I said to the jury is...

I'm asking you, sir, did you make that statement to this jury?

What I intended to say...

No, not what you intended. Can you answer my question? Yes or no?

No.

Now, is Dr. Heilbrun aware of the concept of post-intensive care syndrome?

Post-intensive care syndrome?

Yeah, PICS. It's called PICS.

No, I have not heard of post-intensive care syndrome.

Is Dr. Heilbrun aware of when a person is coming out of major surgery and has been subject to anesthesia, that it is known that they have delusions, hallucinations, make statements that don't make sense. Are you aware of that, sir?

Yes, I'm aware of that.

And is that from your personal experience, professional experience, because you didn't know what PICS was when I asked you, right?

Yes. It's not from my personal experience or my professional experience.

You received a notification to evaluate Lindsay Clancy on this criminal case from the district attorney's office, right?

Yes.

And do you recall when you received that notification?

It would've been sometime before January of 2025, because that's when I started reviewing the documents that they provided.

Okay. So January of '25, January of '26, and then in the spring of '26, you go to the Tewksbury Hospital with Mack and you interview Lindsay, right?

Correct.

So how many months is it from the time that you were appointed or requested or asked to help the DA's office to the time you saw Lindsay? How much time passed?

Probably about 18 months.

About a year and a half. And how much time passed from that point going backwards to January of '23?

I'm not sure what the question is.

Okay. January of '23, you add a year, that's January of '24, right?

Yeah.

One year.

Yeah.

January '24, you add a year up to January '25, that's two years, right?

Yes.

January of '25 up to when you and Mack finally go out to Tewksbury to interview this young lady is how many months?

Well, it would be about three years.

Okay. And are you telling this jury that it's good, using the term loosely, medical practice to interview a young lady like this three years after the event for purposes of helping the DA in your opinion?

Do you mean in the context of a forensic mental health assessment, sir?

That's the only reason you're here, right?

Yes, it is.

Okay. So can you answer my question?

The answer to your question is the sooner that I'm able to evaluate somebody after their involvement in the alleged offense, the more closely I can come to using that current state information as something that is relevant to their mental state at the time of the offense.

Okay. So in other words, yes, it is better to see them sooner rather than later, to coin a phrase, right?

Yes, it is.

Okay. And have in mind January of '25 that you were retained by... And again, normally this isn't an issue, who cares, but how much money did you make out of this case, as they want to ask my doctor? How much money did you make out of this case?

That depends when I'm finished, but I mentioned earlier that I had spent 180 hours before coming to Plymouth.

How much money did you make on the case, Doctor? Simple.

Well, it's not that simple, but I'm being paid at $300 an hour.

Okay. So how much money did you make on the case?

Well, $300 an hour times 180.

What's your last billing?

I've been billing monthly, sir.

Okay. You must know what the total billing is up to this point, don't you?

I actually have not added it up.

How about you just give us your best estimate, Doctor?

Well, let's see. Probably up to this point, it's been about $54,000.

$54,000. And it will be more, right? When we get finished with you today, right, it'll be more.

Yes.

Okay. So you received from me by certified mail, a video interview of Lindsay by my guy, Dr. Resnick, right?

Correct.

You received the notes from Dr. Margaret Spinelli, right?

Yes.

You received the notes from my doctor, Paul Zeizel, right?

Yes.

You received the report that was prepared and submitted by Dr. Phillip Resnick, right?

Yes.

You received the report prepared and submitted by Dr. Margaret Spinelli, right?

Yes.

And you received the report prepared by Dr. Zeizel, right?

Yes.

And then I said, "If you have any questions, give me a call, drop me a line, whatever," but we never talked until today, right?

That's correct.

All right. Now, you have a curriculum vitae that talks about that you are a clinical psychologist, correct? As you've told us yesterday, right?

Yes.

Have you ever treated a woman in postpartum psychosis?

When I was a staff psychologist at the forensic service at Florida State Hospital.

When was that, please?

That was back in 1982.

82?

Yes. I had a therapy group, which comprised women who had killed their children. They were severely mentally ill, and at that time, it was important to recognize the severity of their mental illness, and so I worked with them in a group at that time.

Okay. And this is 44 years ago?

Yes.

All right. And where was it?

It was at the Florida State Hospital in Chattahoochee, forensic unit, forensic service.

How many of these people did you have a chance to interview in group or whatever you did?

There were four or five in the group.

Four or five, okay. Well, you are also a forensic psychology expert working for Park Dietz & Associates, right?

I have an affiliation with Park Dietz & Associates, yes.

But that's basically, that's the letterhead that you have on all your stuff, right? Park Dietz & Associates, Inc. Is that right?

Yes.

Okay. You know Mack, do you?

Do I know Dr. Mack?

Yeah, Dr. Mack, yeah. The guy that was here testifying for the last two days, Friday and Monday, you know him?

Yes, I do know him, yes.

All right. And he works with Park Dietz as well, right?

I think he has the same kind of affiliation I do, which is we both have jobs and do things elsewhere, but we occasionally do cases in affiliation with Park Dietz & Associates.

Right. And continuing on, and if you have it you can certainly take a look at it, make sure I don't misrepresent anything on your vitae as you refer to it. You also were involved with Giant Food Corporation, you do fitness for duty assessments. What is that?

What are fitness for duty assessments?

Yeah, what's Giant Food Corporation?

Oh, that's something that I did many years ago. Basically, a company or an organization might refer someone who is having difficulty at work, having symptoms, making threats, that sort of thing, and they would ask for an evaluation from a psychiatrist or a psychologist, and I did that for a while for Giant Food Corporation.

And you also did it for US Airways, apparently, evaluations and consultation, right?

Yes.

You also did it for the Texas Education Commission. You put in your resume, the Forensic Clinical Site Visitor, Sam Houston State Hospital or University, right?

Yes.

You were a grant reviewer for the Office of Victims of Crime for the United States Department of Justice. That's the feds, that's the US Attorney's Office, right?

Yes.

Okay. You also worked, and you did violence risk assessment consultant as a consultant to the New Jersey Department of Mental Health Services, right?

Yes.

You also consulted as a research consultant with the community education centers in New Jersey, right?

Yes.

Research advisory board, the center for the analysis of... Actually the FBI, you worked for the FBI?

I consulted with the FBI, yes.

And in consulting with the FBI, you also consult with the Bureau of Prisons, right? BOP?

Yes.

When you're consulting for... Well, okay. Site visit of juvenile justice and psychology, you were involved with that, right?

Yes.

And a consultant forensic psychology service for the Walter Reed Medical Center, correct?

Yes.

When you work on the consulting with the Bureau of Prisons, basically what you're doing is you're evaluating, as you told us a couple of times, people that are wrongfully convicted and they're in jail for decades, and you would evaluate them for the Bureau of Prisons to see if they're okay to release to society, right?

That does not sound like a typical question that I would evaluate for the Bureau of Prisons.

All right. Well, what would you evaluate for the Bureau of Prisons?

Well, for example...

Hold on. Just so we know, Bureau of Prisons is federal as opposed to the Department of Correction, which is state, right?

Yes, that's right.

So go ahead. Tell me what you do for the Bureau of Prisons.

Well, one of the things that I might do is conduct a meeting or a workshop on a topic such as violence risk assessment or something like that. So I have done that, deliver a workshop or provide an organizational meeting, provide information, and so on, on a number of occasions.

And do you evaluate people to see if they're able to be reintegrated into society?

I do that as well, yes.

Okay. You also are involved with sexual violence risk, is that correct?

Yes, it is.

You also are involved with specialized police response and collaboration with behavioral health systems in Pennsylvania, right?

Correct.

Sexual violence risk, again, for purposes of the Department of Correction, you've focused on that, right?

Yes.

Principles of forensic assessments that you would be assessing juveniles for purposes of juvenile assessment and risk assessment, right?

Yes.

You also are involved with violence risk and sexual violence risk, correct?

Yes, correct.

Juvenile assessments, risk assessments, and principles of forensic assessment for the American Academy of Forensic Psychology, is that right?

Yes, that's right.

And also a focus on juvenile assessment and risk assessment of juveniles, right?

Yes, correct.

Violence towards others, psychiatrically hospitalized populations, that would be what? Patient on patient assaults or something like that when somebody's at a mental institution?

Yeah, patients against patients, patients against staff, that sort of thing.

They can be pretty violent places, can't they?

They can be sometimes, yes.

Sexual violence risk, you're involved with New Orleans, Louisiana, sexual violence risk assessment, right?

Correct.

Obtaining and using mental health experts in criminal litigation for the administrative office of the United States courts, right?

Yes.

What does that mean? What did you do with that when you were dealing with obtaining and using mental health experts in criminal litigation?

Well, I have had the occasion to provide workshops to prosecutors, to defense attorneys, to judges and so on, and depending on some of the questions that arise, such as what's the most effective way to obtain and present a forensic psychologist or forensic psychiatrist expert, I might do a half day or a full day workshop on that.

Okay. So my question, sir, I know you get in there, but where did you lecture or give a lecture to criminal defense attorneys?

I've given a number of those lectures over the years. I can't recall them all offhand.

Okay. But my question, sir, was that you were working on behalf of the administrative office of the United States courts, federal courts, right?

Yes, that's right.

Did I ask you that question?

Yeah.

Okay. You also worked for the forensic mental health assessment for the Ohio Forensic Psychiatric Center, that's inmates, right?

Yes.

You also participate and have written about, to kill or not kill, that is the question, for Drexel University where you were a professor, correct?

Yes.

All right. Assessing risk of violence towards others in psychiatrically hospitalized populations. You focused on that, right?

Yes, that's right.

You had a chance there to give a total of, let's see, 131 lectures or workshops presented in the area of violence, risk assessment, sexual offenses and forensic mental health and ethics, right?

Yes, that's right.

Is that right?

Yes.

Aggression, forensic psychological assessment, risk assessment, treatment of mentally disordered offenders and juveniles. That's another focus, correct?

Yes, it is.

You've had a number of publications that you put in your CV. Basically, you're talking about justice involved youths, correct?

‍ Yes. That's one of the things I talk about.

Appraising Jackson based unrestorability to competence to stand trial, deals with the standard of competence to stand trial, correct?

Yes, it is.

Public perception on policies to address prenatal substance use recommendations regarding maternal criminal prosecutions. What is that? Prosecute a woman that's pregnant who's involved with drug use?

Yeah, that sounds like something that would have been a dissertation where I served on the committee and was a co-author of some kind, but the individual who wrote the dissertation would have been the first author there.

All right. And life sentence for juveniles, sequential model for juvenile...

... "Sentence for juveniles, sequential model for juvenile justice, justice involving men, forced medication and competency to stand trial." These are interests or focuses of yours, sir?

Yes.

"Urine drug screens as a baseline for predictors of graduation from drug court."

Yes.

What does that mean, that you were involved with drug court?

Yes. I've been involved in writing about and consulting to drug courts over the years. Yes.

And disputed paraphilia diagnoses and legal decision making is one of your other focuses, right?

That was one of my graduate students and I was a supervising and second author.

Paraphilias would be in the... I mean, that's basically if you have some kind of weird sexual things that you do, right?

Something like that, yes.

Yeah. Continuing on, a lot of juvenile focus on your resume, correct, sir?

Yes. There's a fair amount of juvenile work that I've done over the years.

"Involuntary medication, trial competence, clinical dilemmas, substance abusing, adjudicated adolescence." And your resume basically is a number of pages, correct? Would you agree with me it's almost 70 pages, right?

Yes, I would agree with you.

Okay. Flipping through and jumping ahead, sir, you wrote book chapters, correct?

Yes, that's correct.

You dealt with forensic mental health assessments, principles and standards of care, right?

That's right.

Violence risk assessment, right?

Correct.

Juvenile violence risk assessment, right?

Yes, that's correct.

Managing hindsight bias and unstructured judgments, implications for legal decision making is an article, chapter or whatever that you wrote, right?

Yes, it is.

Again, "Juvenile delinquency, juvenile delinquency, juvenile delinquency, juvenile delinquency." A lot of focus on juveniles, right?

Yes. There's a fair amount of focus on juveniles over the years, yes.

A number of reviews that you have published, presentations that you've presented, a lot of them dealing, again, with juveniles and dealing with assessments of prisoners to have them released into society, things of that nature, right?

Yes.

Life sentence juveniles, for example, is one of the things you focus on, right?

Yes. Again, there's been a fair amount of juvenile work and-

"Handling difficult cross-examination, integrating perspectives, combining substance with style and learning." What does that mean? Handling difficult cross-examination?

Well, one of the things that people as forensic psychologists need to do is convey what they have done in a way that is effective. And so there are things that you-

To who? To a jury?

To a jury, to a judge, to an attorney, various kinds of-

Well, when you're dealing with an attorney, sir, you're presenting information to the attorney. You're not dealing with difficult cross-examination, are you?

Could you repeat the question, please?

Sure. You wrote about handling difficult cross-examination, integrating perspectives, combining substance with style.

Yes.

25 words or less, what is that basically telling people? How to what? Withstand cross-examination?

It's how most effectively to convey the results of the evaluation that you have done.

And then again, just hundreds of articles on topics that the jurors can look at because your resume is in evidence. Finishing it off on that end, "Sexual abuse behavior, juvenile forensic mental health, violence risk assessment of juveniles, behavioral measure of sexual offense behavior, influencing third-party informant observations dealing with juveniles. Should the courts coerce offenders into substance abuse treatment." Is there one article, one that you wrote about a woman who is pregnant, who is undergoing postpartum depression and God forbid, psychosis?

No.

But you did write an article 49 years ago. You published an article on psychosis in 1977 with your dad while you were in college apparently, right? Right?

Yeah. I was his research assistant at that time when I was in college, yes.

Okay. And this is before you went to graduate school and you used the diagnostic framework that no longer exists, didn't you, back then?

It was a long time ago.

Right. And actually it was three years before the DSM was even written. DSM 1 back in the Stone Age.

It was a while ago.

That's the only article you ever wrote dealing with that issue. Is that correct, sir?

Dealing with what issue, sir?

Postpartum psychosis.

Ah, yes.

Does ah mean yes? Thank you. So you make arrangements with the district attorney's office to get all this discovery that I sent you, that the DA sent you, police reports that you went through with the jury and you read it, right?

Yes, that's right.

And you must have talked to the DAs before you saw Lindsay, right?

Yes.

Okay. How many times?

I don't remember how many times.

Well, you billed them for it, I'll bet, right?

Anytime I spend on a case like this, I record and it gets billed.

Of course. So you do have records, but who cares at this point? I mean, you're here testifying based on your opinion at the request of the prosecutors, right?

I'm here based on... Yes. At this point, I've completed the evaluation and don't remember things like how many times I talked to the DAs as part of it.

Okay. But basically in your conversations with these two prosecutors, sir, did you talk to the state police at all, detectives?

I reviewed a massive amount of reports, some by the state police, some by other individuals. So I reviewed records for many, many hours.

And when you got involved with this case three years later, or two and a half years later, you'd agree with me that it was quite publicized, right?

Yes, I would agree with that.

You've heard of confirmation bias, I'm sure, right?

I have indeed.

Yes. And however many times you talked to the DAs and reviewed the information, would you agree with me, sir, that before you met with Lindsay in Tewksbury, you pretty much had an idea that this woman was a beast, killed her three kids, didn't you?

I would not agree with you at all.

So you had an open mind when you went in there to Tewksbury to see and speak to for three days, Lindsay Clancy?

I did my best to have an open mind, yes.

You told us yesterday you had some difficult decisions to make, correct?

Yes, that's correct.

Right. So when did you first meet Avram?

When did I first meet him?

Yeah.

That probably would have been late 2025, early 2026.

Okay. Around the same time that you first got involved with the case?

No, it would have been considerably after I first got involved with the case.

Where did you meet

Where did I meet him?

That's what I said. Where'd you meet him?

Virtually.

Oh, virtually.

Yes.

Okay. So it's like a Zoom thing or FaceTime or something.

Yeah. Exactly.

Did you ever meet him in person before you went to Tewksbury?

No, I didn't.

So did you guys have a plan to meet up somewhere before you went to evaluate Lindsay?

In the lobby of the hospital.

Okay. Did you stay somewhere the night before?

I did, yes.

Where'd you stay?

I don't remember.

Were you with Mack that night?

No.

No? Did you stay in a private house?

No.

Did you stay in a hotel?

Yes, I did.

Wasn't a van down by the river for sure, right?

I don't remember the name of the hotel, but it was a hotel in Tewksbury.

Tewksbury. So you're in a hotel, you meet with Avram Mack in the parking lot, and then you go into Tewksbury Hospital to meet with this young lady, right?

Correct.

And the two of you, day number one, you spend how many hours, the two of you, questioning her?

Four and a half.

And day number two, you don't bring Mack with you, you're by yourself and you administer the psychological testing, correct?

Correct.

And how long was that, sir?

Three hours.

And day number three, how long did you speak to Lindsay in the hospital?

Three hours.

So what was your total period of time over a three-day period that this young woman was dealing with you and Avram Mack?

10 and a half hours.

So for 10 and a half hours, this young lady is in a room in a wheelchair being questioned by you and Avram Mack while she's on medication, right?

Yes, that's correct.

And she was still answering your questions, trying to be cooperative and being affable and friendly, you put in your report, right?

Yes, that's right.

Did at any time she express to you that she was tired or wanted to take a break?

We offered her in the beginning-

My question, sir, was-

Objection, if he could answer-

Oh, he's going to answer my-

Hold on, hold on. Ask a specific question, Doctor, if you'd listen to that question, okay?

My question, sir, was at any time did you or Avram Mack offer to her to take a break?

Yes.

Did she accept that offer?

Once she did and once she did not.

And basically indicated that she wanted to get through this interview and get it over with, right?

Yes.

You weren't her buddy going there to talk to her those three days, were you?

No.

She knew that you were there on behalf of the district attorney's office to testify against her in a trial and say to a jury that she knew and was able to conform to the law that she killed her three kids. Isn't that right?

No, that's not right.

So your diagnosis is depressive bipolar II, right?

Bipolar II disorder, right.

Okay. And that's a serious mental disease, isn't it?

Yes, it is.

You would agree with me, sir, that Lindsay is a, in your opinion, testified she's a very hardworking and highly self-disciplined individual, right?

Yes, I would agree with that.

You testified to that yesterday, right?

Yes, that's right.

Right. That's funny?

No, it's not funny. It's just that you asked me whether I agree with something that I testified to yesterday.

So what does that mean?

It means that I testified to it yesterday and that means I do believe it, yes.

Okay. So we established that. In your opinion, granted through those three days that you had interactions with Lindsay, is it your opinion that she is a controlling individual, sir?

It depends what you mean by controlling.

Well, let me ask you, for example, would you agree that if a young mother prepares lists for a babysitter, for example, to chop up the carrots and dice them up small and how to prepare the spinach and how to prepare the chicken McNuggets and then leaves them in a note and puts them on the kitchen table, is that controlling in your opinion of that individual?

That is something that is working hard and being disciplined and exerting a certain amount of control, yes.

That's not something that you would use against her in this opinion you have for this jury, is it?

What I do is do my best to describe what she does, what she thinks, what she feels at certain times, what symptoms she has and so on. And if that's a part of that overall picture, then it's not that I'm using it in favor of her or against her. It's just part of the overall picture, which I'm trying to present.

And, I mean, it's not a bad thing to chop up the carrots and tell somebody, "This is how I like my child to be fed," right? There's nothing wrong with that, right?

Not that I know.

And you would agree, sir, that she was a good student. You told us about she got all A's, she was hard driving and actually drove herself pretty good to try to succeed in college and in nursing school, right?

I would.

And did you interview any of her coworkers or did you review any of her five-star reviews from Mass General Hospital or flagship hospitals?

I reviewed every record that was provided to me.

And that would be by them, right?

It was records that were provided to me by individuals who were a part of the investigation, and a lot of that were interviews with people who had known her before or were currently friends with her, things like that.

Okay. So things like that. I'm asking you, sir, about with her seven-year career as a nurse, labor and delivery nurse at a very, very well established hospital, did you talk to any of the nurses that she worked with or did you review any of the records of her work reviews, anything like that?

No.

Would you agree with me, sir, that she also, by all accounts, is and was an incredible mother taking care of her kids?

I would describe her as a very good mother, yes.

And in fact, sir, in the past six weeks or five weeks, there hasn't been one person that's had one thing bad to say about her other than these two, isn't that right?

Objection.

Sustained.

Did anybody, to your knowledge, come into this court in front of this jury and say that Lindsay Clancy was a bad wife?

I don't know.

How about bad mother?

Again, I don't know.

So in your readings about her as a mother, you were able to see that she would sing to her daughter when she put her to bed? That's in the reports. You read the reports, right?

You might have to ask me that question again.

You know Rascal Flatts?

I'm sorry?

Rascal Flatts, you ever heard of them?

No.

Okay. So if I suggest to you, sir, that Lindsay would sing to her daughter every night, is that important to you in your evaluation?

Yes.

You didn't know that though, apparently, right?

I knew that she was very good with her kids, paid a lot of attention to them, spent a lot of time with them, and really enjoyed it.

Even right up to within hours of their killing, she was making snowmen with them, right?

Yes. She was playing with the two older children out in the backyard.

And then bringing her life experience, which you testified yesterday that she never had any abuse in her life, was raised by loving mother and father, good student, hard worker, great mother, good friend, wonderful wife. She then randomly decides to kill her children by strangling them. That's the facts we're dealing with, yes, sir, right?

No, not right.

So one of the things you testified to yesterday is that, and you went like this and said that this is difficult, but then you were able to power through and tell the jury that Lindsay didn't like to leave her kids alone. She got anxious about that. Remember telling that to this jury?

I do.

And this is one of the things that you kind of hang your hat on that you felt was important in your evaluation, right?

It was an important part of my evaluation that she did not like to leave her kids and it made her anxious, yes.

That's not a bad thing, is it? For a mother not to want to leave her children and be anxious when they're out of her home, right?

Well, it depends. It could be difficult and so on, depending on how anxious and even disabling it was if she just couldn't leave her kids. But on the other hand, if it just reflected that she was close to them and wanted to be with them and wasn't a problem or disabling, then it's not a problem.

Did you know, sir, that Pat's mother and father would come over to the house and babysit for the kids when Lindsay and her husband would go out to dinner or go out to a movie or go out with their friends? Did you know that, sir?

Yes.

Did you know that the children were actually in Learning Sprouts School? Did you know that?

Yes.

They had to leave the house to go to school, didn't they?

Yes.

She wasn't anxious when they would go to school, was she?

It made her a little anxious to drop her kids off. She didn't like to be separated from them.

Well, that's because the kids many times on occasion would cry, like little kids do when you drop them off somewhere, right?

I don't know if she was anxious only when they cried.

You knew that in addition to the date nights, in addition to socializing with friends, in addition to the children leaving to go to the Little Sprouts School, you knew that there were a number of occasions that Lindsay alone or Lindsay with her husband would leave the kids and go out and do any number of things, shopping, socializing, go to Boston, things like that. Did you ask third-party contacts about that?

I asked Patrick about that, and one of the things he said is that it was difficult for her to leave the kids, and he used as an example, date night for their fifth anniversary. It was hard for her to leave.

Was that in '22?

Was date night for their fifth anniversary in '22?

You just mentioned i to the jury. Was that in 2022, their fifth anniversary? Their anniversary is in December, right?

I don't know what year it was in, Mr. Reddington. What

Was the problem? What did he say? Third-party collateral? What did he tell you?

What he said in response to that question is that on date night for their fifth anniversary, she was anxious about leaving the kids.

Right. Did they ultimately go out that night?

They did.

Do you know where they went?

I don't.

Did she have fun? Did she appear to be enjoying herself away from the kids?

That was not part of the question I asked him.

I mean, there's nothing wrong with a woman being concerned about her babies when she's not at home, right? There's nothing wrong with that.

I wasn't presenting it as something that is wrong.

I'll back off. I'm sorry. I thought you did. I thought yesterday you were telling this jury that because Lindsay didn't like to leave her kids at home, that was a factor that Dr. Heilbrun considered in his opinion, but that's fine. You agree that there's nothing wrong with a woman being concerned about her children leaving them out of the house, right?

No, I don't believe I said that.

Okay.

One of the things that I-

No, no, no. Nevermind one of the things.

Objection. He can finish.

Okay.

The answer was you did not say that?

Judge, I'm getting a little confused here between-

Well, listen, no. My question is not that confusing.

Okay.

Are you done saying that you did not say what Mr. Reddington said?

Yes, I'm done saying that.

All right. That's good. Next question.

One of the other issues is that also factored into when Tufts prescribed her the SSRI, she didn't want to take it because she was afraid of the breast milk being contaminated by this drug, right?

Yes.

And then ultimately when she stopped breastfeeding, at that point, she was able to take the SSRI, correct?

Yes, that's correct.

And then Tufts increased it to 50, right?

I don't recall offhand what the-

Okay. Well, you agree that Tufts increased the SSRI, right?

I do.

You agree that before the end of September of 2022, this young woman was living her life with her husband and her kids, summer of '22, happy, had a great time? Do you agree with that, sir?

I do.

And when she saw Tufts from September and up until the killing of these children and the state of her condition that you told the jury was confusing, remember using that word yesterday? It was confusing with these number of diagnoses that she dealt with?

Yes, I did use that word.

And the confusing with the number of drugs that was one drug on top of another drug and stop this drug, start that drug, that was confusing, wasn't it, sir?

Yes, it was.

And it was confusing and upsetting to her and her husband to the point where they went to these doctors and said to them, "You're turning her into a zombie," right?

Yes, that's right.

But prior to seeing Tufts and the other healthcare providers, she was a happy woman, wasn't she?

She was, in many respects, happy, pleased with her life. So she wasn't happy in an unqualified way, but she was, yes, she was very happy with certain aspects of her life.

So as September turns into October, middle of October or thereabouts, how was she doing at that point between her depression, anxiety, drugs prescribed? How was she doing?

She was anxious about going back to work, but she hadn't started taking the drugs that were prescribed.

Okay, wait, wait, wait, No, no, no.

Let him finish. Go ahead. Go ahead, Doctor.

Yes. In September, she was anxious about returning to work. She had not yet started taking the medications that Dr. Tufts had prescribed though.

How about a text that she had sent to her mother on October 20th, sir? I know you indicated in your report that you had a chance to review all of the computer searches, text messages, Apple... All that stuff, right?

Yes, that's right.

All right. Read that text, please. October 20th. This is a text that she sent to her mother. Read it.

Would you like me to read it out loud? I'd

Yeah, I'd like you to read it out loud.

All right. "Mom, will you please come up and stay with me for a bit? I'm really sick. Something is wrong. I had horrible insomnia all night, and I just don't know how I'm going to get through the day. I started taking the medicine my doctor prescribed for anxiety, and I think it's made things worse. It's just really scary and I don't want to be alone."

Did her mother come up the next day and stay with her?

Oh, I don't know. I'd have to go back and look at the records.

I'm sure. You know, sir, that she actually climbed into the bed with her mother to sleep with her mother when her mother was staying with her during this period of time?

No, I didn't know that.

In the middle of November, sir, she texted her mother-in-law, which would be Pat's mother, Sue. This would be Sue Clancy, who was also a labor and delivery nurse, right?

Yes, that's correct.

She texted Sue while she was at work as a nurse, right?

Yes.

And Sue was in the emergency room and actually realized that Lindsay was at the hospital and stated that she felt unwell. Is that right?

Yes.

Did Sue see her in the hospital, if you know?

I think she met with her in the emergency room.

Okay. And then her mother-in-law was trying to help her out and referred her to another person that was a friend of a friend, so to speak, right? To help her out?

The nurse practitioner, is that who you're talking about?

Yep. Yes. Yeah.

Yes, that's right.

And she was able to meet with that individual, Paul, until she left, I think, like a week later. She went on to another job, right?

I think that's right, yes.

And that's when she saw Nurse Gelada, was that correct?

To my memory, that's correct, yes.

And then would you agree with me, sir, that at this timeframe in November, she was having real difficulty with sleep disruption, yes?

Yes, I would.

You had concerns all along about this starting in mid-October about the impact of the medications on her insomnia, correct?

Yes. Insomnia was one of the first problems that she experienced when she started taking the medication in October.

She expressed the fact that she believed that the medications were obviously having an adverse effect on her. They were damaging her brain, right?

She did express that view, yes.

And then she still, however, had a positive outlook and was, "Hoping that things would turn around in her life and that she could get back to being herself," is a quote, right?

Yes, that's right.

But instead, and I quote your words yesterday, "It got worse."

Yes.

"Late in November, she's still having a lot of trouble sleeping. She thought that she was close to," and I quote, "The end of her rope." Bad analogy, but nevertheless, that's what she said, right?

Yes, it is.

"She was feeling off, disconnected, sort of like a zombie," your words, testifying here yesterday, sir, correct?

Correct.

"She was reporting at this point, panic symptoms, concerns about the benzodiazepines," correct?

Yes.

"Indicated that she was disoriented and forgetful," correct?

Correct.

You told us that she stated that she was disconnected from her body, isn't that correct?

That's how she described feeling, yes.

"Could not relate to people, felt that she was in a disassociative state," isn't that right?

Yes, that is right.

"Though that the medication was resulting in this type of development in her life," correct? She felt the medications were contributing to this?

Yes, that's correct.

And in December, and I quote you, "It's not getting better." It got from worse, it got better, well, actually, not better, it got worse again, didn't it, in December?

December was probably the worst month for her as she described it.

And in December, sir, you recall that she indicated, and I quote in your testimony, "Horrible, intrusive thoughts." She had thoughts about harming herself potentially as she continued to experience these thoughts later into December, correct?

Yes, that's right.

These thoughts, did anyone, anyone say to her, "Are these thoughts, are these coming from outside your head? Are they coming from inside your head? Are they male voices? Are they female..." Anybody ask anything about thoughts, what they were, according to the medical records, not according to your guess?

That's a standard kind of question when you're being-

Objection.

My question, sir, is you read the medical records-

No, overruled.

Can you answer that question based on Dr. Heilbrun's review of the medical records of what this young lady went through in that hell that she was living?

Is your question, did someone ask her about hallucinations or thoughts?

Yeah, if I come to you for help and I say, "I've got intrusive thoughts about killing myself. And God forbid, I'm thinking about killing my kids. I've got these thoughts in my head." Would you ask me, "Are they voices? Thoughts? Whatever. Does anybody ask that question?

Yes. That's a standard question that psychiatrists ask at the beginning of each appointment. It's a standard mental status question.

Okay. Did any one of those psychiatrists ask Lindsay Clancy that question according to the medical records? Anyone?

Ms. Clancy completed the answer to those questions-

What questions?

... on a number of occasions. If I might.

What questions?

He's answered the question.

No, go ahead.

What questions?

Finish that question and I'll let you have that question.

Okay.

Finish the answer.

Questions such as, "Are you hearing voices? If so, describe those," and so on. And the typical response that she gave as part of a question like that was, "No."

About when someone says, "I've got dark thoughts." Does anybody, professionals, ask, "What are the dark thoughts?" Is that-

If somebody said, "I'm having dark thoughts," then the follow-up question would be, "Tell me more. What are the thoughts? Just give me some descriptions of what you're having, what you're thinking, what it's like," and so on.

So if a patient goes to a doctor and says, "I'm having these intrusive thoughts, I'm having dark thoughts, I'm having thoughts of..." And at this same timeframe in December, she's talking about harming the children, correct?

She said that those thoughts had come to her at times.

At times?

Yes.

And she'd mentioned that to her husband, didn't she?

That's what she said, yes.

Did you talk to her husband about it?

Yes, I did talk to her husband about it.

Tell you that she said that to him?

Yes.

A couple of times she said it to him, right?

A couple of times she said, "I'm having thoughts," and he asked her, "Give me more detail if you could." And she said, "They're just thoughts. It's not a plan," that sort of thing.

You got this girl living in her house with her kids saying she's having dark thoughts, saying she's thinking of harming the children. And Patrick's response, according to your testimony, is just basically just, "Power through it, you'd be okay."?

Objection.

Overruled.

No, that was not his response as he described it. He asked more questions because one of the things that she had been dealing with for some time are thoughts about hurting herself and possibly the kids. And so what he did was try to get more information about the details. He asked questions that a mental health professional would also ask, which is-

Questions that a mental health professional would also ask, which is how often, what are they like, do you have a plan? Things like that. And she pretty consistently said, "No, I don't have a plan. And this is how often it happens, but they're just thoughts."

So let's talk about that because that's apparently the standard reaction if a patient comes to a doctor and says, "I'm having dark thoughts, intrusive thoughts, I'm thinking of hurting myself, I'm thinking of hurting the kid." You say, "Do you have a plan?" That's a question you ask, right?

That's one of the questions that you ask, yes.

If the person says, "Nah, I don't have a plan. I'm just having these thoughts," and you just basically move on, give them more drugs, what do you do?

No, you don't move on. You're aware that the person has reported having those thoughts and you've appraised the risk and the risk has to do with things like how imminent is it? How serious is it? Are there means? Is there a plan? What sort of detail is involved and so on. And so basically what you do at that point is you take it seriously, but you also try to describe how seriously to take it, so.

Okay. Would you agree, sir, that she was complaining through December about these unwelcome and internal thoughts. Is that correct?

Yes.

It's important for your evaluation because when you asked the question, "When you're experiencing these thoughts, were they your own thoughts or were they auditory hallucinations?" And she indicated to you, "They're my own thoughts," is what your testimony was, right? Yesterday?

That's correct.

But she made clear that these were unwelcome and that they were intrusive. Is that correct?

Yes, she did.

So she's answering your questions honestly. She certainly isn't trying to fake that she's hearing all sorts of voices yelling at her and things like that. She's answering honestly, correct?

Yes.

Very cooperative, correct?

Yes, correct.

You then would indicate, sir, that in your evaluation as you went on, that she described an experience on December 15th and she described December 15th as being literally one of the worst days in her life, right?

Yes.

Why was it one of the worst days of her life?

Well, it was one of the worst days because things were getting more intense and difficult and the thoughts that she was experiencing were harder to handle for her.

As a result of that, her husband Pat took her to the hospital, right?

Correct.

And you indicated that it looked like she was having general anxiety symptoms, right? That's your testimony yesterday?

It looked from what the records reflected that anxiety was something that they were focusing on her experiencing.

And then you said in your testimony, "But not so much the postpartum." What does that mean?

It means that in December she would have been seven months away from giving birth to Callan and consequently it was less likely to be postpartum than depression for other reasons or bipolar or major depression or something like that, rather than postpartum depression or postpartum psychosis, something like that.

Because you know that postpartum is not a medical diagnosis. That's just the fact that you had a baby, right?

I do know that, yes.

Okay. And when she went to that hospital, did they provide any help for her or any medication or what happened on December 15th?

She did not stay in the hospital very long. And so no, she didn't remain there long enough to get the kind of help that you would usually get on an inpatient basis.

But the next day or thereabouts, she goes back to see Tufts, right?

Yes.

Okay. So she immediately tries to reach out for help to anybody that would listen to her, right?

She was trying hard to get help.

Now we get to December 20th. December 20th wasn't a very good day either, was it?

Well, that was the day she went to the Rhode Island Hospital that had a postpartum program.

Now you know from looking at the medical records that in fact it was recommended to her, I think by maybe the LICSW young lady, Latiesha Dukes, maybe I'm wrong, they're in the records. Someone told her to get in touch with this Rhode Island hospital, right?

Yes.

They specialized in postpartum care for women that possibly are going through postpartum psychosis or postpartum depression, right?

Yes.

And Pat, her husband took her and dropped her off and then he went skiing with Cora, is that correct?

Correct.

And he dropped her off in that hospital and she was evaluated by a doctor and some people, correct?

Yes.

And you reviewed those medical records, right?

I did.

And when you reviewed the medical records, did you see that she was also involved in group discussions and crayons and coloring and things like that?

Yes, I did.

Yeah. Did that help her out, do you think, coloring?

There's a number of things that they try to do. I think coloring as such would not be helpful.

Okay.

But there's art therapy and there's various other kinds of things that people are involved in.

All right. So various other things that people are involved in. So I assume the people you're referring to would be the employees of the hospital?

Or the patients who are attending the postpartum program.

Okay. So what exactly was the program? What did they do that one day that she was there? She was there for eight hours. What did they do?

She wasn't accepted as part of that program.

I didn't ask you about that. I asked you what did they do?

Well, they evaluated her, is my understanding from reviewing the records.

And then what happened, sir, when they evaluated her?

They evaluated her and they indicated that she was not appropriate for their program.

And you testified yesterday that, and I quote, "They said she did not necessarily fit into their postpartum program. They did offer her three other programs." You remember that, sir?

Yes.

Okay. And then you indicated that, "Patient was offered several options, including inpatient treatment for medication management," right?

Yes.

"A partial hospitalization program focused on general mental health," right?

Yes.

Where was that program?