HCO006844-0001

Form MGI 1 (T)

Page 1 of 5

WITNESS STATEMENT (CJ Act 1967, s.9; MC Act 1980, ss.5A(3) (a) and 5B; MC Rules 1981, r.70)

Statement of: HEATLIE, GRANT JAMES

Age if under 18: OVER 18 (if over 18 insert ’over 18’) Occupation: CARDIOLOGIST

This statement (consisting of page(s) each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully staled anything which I know to be false or do not believe to be true.

Signed: Grant Heatlie Date: 05/06/2006

I am a Consultant Cardiologist, with a special interest in cardiac imaging, at the University Hospital of North Staffordshire NHS Trust, Stoke-on-Trent; I have held this post since 2004.

My academic qualifications are:

1987 BSc Hons (First Class) in Mathematical Physics, Edinburgh University. 1990 PhD Southampton University 1995 MBBS Newcastle University. 1998 MRCP (UK). 2000 British Society of Echocardiography accreditation in transthoracic echocardiography. 2002 British Pacing and Electrophysiology Group certificate of competence examination. 2003 British Society of Echocardiography accreditation in transoesophageal echocardiography.

2004 Level 3 (Facility Director) credentialing of the Society of Cardiovascular Magnetic Resonance.

My previous appointments are:

1995 House Newcastle General Hospital. 1996 House Surgeon Kin gs Mill Hospital, Mansfield.

Signed: Grant Heatlie Signature Witnessed by: 2004(1) HCO006844-0002

Continuation of Statement of: HEATLIE, GRANT JAMES Form MG 11 (T)(CONT) Page 2 of 5

1996-98 Rotation in , Queen Alexandra Hospital, Portsmouth. 1998 Senior House Officer in , Crawley Hospital 1998-99 Specialist Registrar in Cardiology, Bromley Hospital. 1999-2000 Specialist Registrar in Cardiology, Princess Royal Hospital, Haywards Heath. 2000-2005 Specialist Registrar in Cardiology, Queens Medical Centre and City Hospital, Nottingham. 2003-2004 Specialist Registrar in Cardiac Magnetic Resonance, Royal Brompton Hospital, London.

Between 1996 and 1998 1 was employed as a Medical Senior House Officer at Queen Alexandra Hospital, Portsmouth. Between February and August 1997 I was working as part of the team headed by Gavin MILLAR (Consultant) and Darryl MEEKING (Senior Registrar).

Part of my role would be to see new admissions on the medical wards; I would generally be the first or second doctor to see such patients. If a patient was admitted as an emergency the patient would be seen in Accident and Emergency and if appropriate would then be transferred onto a medical ward. It would then be normal for the duty team to take that patient on, though if a consultant had some previous dealings or knowledge of a patient their treatment would be the responsibility of that consultant and his team from the next normal working day.

I have been asked to detail my involvement in the care and treatment of Robert WILSON. I do not recall this patient at all, but from referral to his medical notes (Exhibit Reference BJC/55) I can state that I admitted this patient to ward F1 on 17th January 1997 (17/01/1997), after he was transferred from the Accident and Emergency Department QAH.

On page 147 of those notes, which refer purely to his admission in 1997 where, he was presenting chest/epigastric pain, which had come on suddenly. This was associated with nausea, vomiting and mild SOB (shortness of breath). He had previously been prescribed Spironolactone. He had admitted consuming a bottle of spirit a week. He was being treated for liver disease and an intercurrent chest infection. I fully examined him and prescribed, Signed: Grant Heatlie Signature Witnessed by: 2004(1) HCO006844-0003

Continuation of Statement of: HEATLIE, GRANT JAMES Form MG 11 (T)(CONT) Page 3 of 5

Amoxicillin 500 mgs: This is an antibiotic Vitamin K 10 mgs: This for the production of blood clotting and protein. Frusemide 80mgs: This is a diuretic.

He was seen by me and other doctors whilst he was at QAH until he was discharged home on 5/3/97.

On page 465 of the notes I have completed and signed a Discharge Summary for this patient, which states;

Dr JGB MII.I Department of Medicine Senior Lecturer in Endocrinology Queen Alexandra Hospital Cosham Portsmouth PO6 3LY

Te101705 286000 Fax 01705 286054

Code A ...... -~~-~i~-)~- ...... i Ward F1 Admitted 17/02/97 Discharged 05/03/97 Dictated 12/03/97 Typed 21/03/1997

DIAGNOSIS

Code A

HISTORY Signed: Grant Heatlie Signature Witnessed by: 2004(1) HCO006844-0004

Form MG11 (I")(CONT) Continuation of Statement of: HEATLIE, GRANT JAMES Page 4 of 5

This chap presented with a 11/2 hour history of epigastric pain. This was relieved by vomiting. There was no haematemesis. He has had at least one previous episode 6 months ago. He described one previous episode being jaundiced...... (;ode A

ON EXAMINATION

He was comfortable, had pitting oedema to the thigh and a large sacral pad. He had some bi- basal crackles. His abdomen was tense, but not tender. There were no masses palpable. Bowel sounds were normal.

INVESTIGATIONS

Full blood count was normal with white cell count of 20. U’s & E’s, glucose, cardiac enzymes and blood gasses were all normal. ECG showed a rate of 75 in sinus rhythm with poor R wave p..rog_~-_.e.ssion. Chest x ray showed increased shadowing in the left zone. i Code A

MANAGEMENT

This chap was admitted and was quite difficult to treat because he was very unco-operative. He was given antibiotics for a presumed chest infection. We started him on diuretics. Ultrasound showed a i ...... ~-~-~i-~-~- ...... i i ...... ~-~)-~]-~-~ ...... ,He lost some weight with an increase in Spironolactone. His liver function increased a little with a bilirubin of 48, an alkaline phosphatise of 145. He was given much dietary advice, most of which he would not accept. His abdominal pain settled and he was discharged home. It was explained to him the

risksi ...... I~~-~-~-~ ...... Signed: Grant Heatlie Signature Witnessed by: 2004( 1 ) HCO006844-0005

Continuation of Statement of: HEATLIE, GRANT JAMES Form MGI 1 (T)(CONT) Page 5 of 5

DRUGS ON DISCHARGE

Spironolactone 100 mgs od, Multivitamins line 25 mgs tds, Frusemide 80 mgs od.

FOLLOW UP

We will see this chap in Dr M!LI.ER’s clinic in two months time.

G HEATL1-F. Senior House Officer

Dr AH MOWBRAY 233a Brook Lane Sarisbury Green Southampton Hants SO3 6DQ

Haematemesis is the vomiting of blood.

I did not see him in 1998 when he was readmitted, as I had left the Queen Alexandra Hospital during the first two weeks of February 1998 to go to Crawley Hospital.

Statement taken by DC ...... ~~~~--~ ......

Signed: Grant Heatlie Signature Witnessed by: 2004(1)