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AFFIDAVIT
_________

STATE OF FLORIDA )
COUNTY OF PINELLAS )

BEFORE ME the undersigned authority personally appeared CARLA
SAUER IYER, R.N., who being first duly sworn, deposes and says:

1. My name is Carla Sauer Iyer. I am over the age of eighteen and make
this statement of my own personal knowledge.

2. I am a registered nurse in the State of Florida, having been licensed
continuously in Florida from 1997 to the present. Prior to that I was a
Licensed Practical Nurse for about four years.

3. I was employed at Palm Garden of Largo Convalescent Center in
Largo, Florida from April 1995 to July 1996, while Terri Schiavo
was a patient there.

4. It was clear to me at Palm Gardens that all decisions regarding Terri
Schiavo were made by Michael Schiavo, with no allowance made for
any discussion, debate or normal professional judgment. My initial
training there consisted solely of the instruction "Do what Michael
Schiavo tells you or you will be terminated." This struck me as
extremely odd.

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5. I was very disturbed by the decision making protocol, as no allowance
whatsoever was made for professional responsibility. The atmosphere
throughout the facility was dominated by Mr. Schiavo's intimidation.
Everyone there, with the exception of several people who seemed to be
close to Michael, was intimidated by him. Michael Schiavo always
had an overbearing attitude, yelling numerous times such things as
"This is my order and you're going to follow it." He is very large and
uses menacing body language, such as standing too close to you,
getting right in your face and practically shouting.

6. To the best of my recollection, rehabilitation had been ordered for
Terri, but I never saw any being done or had any reason at all to
believe that there was ever any rehab of Terri done at Palm Gardens
while I was there. I became concerned because Michael wanted
nothing done for Terri at all, no antibiotics, no tests, no range of
motion therapy, no stimulation, no nothing. Michael said again and
again that Terri should NOT get any rehab, that there should be no
range of motion whatsoever, or anything else. I and a CNA named
Roxy would give Terri range of motion anyway. One time I put a
wash cloth in Terri's hand to keep her fingers from curling together,

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and Michael saw it and made me take it out, saying that was therapy.

7. Terri's medical condition was systematically distorted and
misrepresented by Michael. When I worked with her, she was alert
and oriented. Terri spoke on a regular basis while in my presence,
saying such things as "mommy," and "help me." "Help me" was, in
fact, one of her most frequent utterances. I heard her say it hundreds
of times. Terri would try to say the word "pain" when she was in
discomfort, but it came out more like "pay." She didn't say the "n"
sound very well. During her menses she would indicate her discomfort
by saying "pay" and moving her arms toward her lower abdominal
area. Other ways that she would indicate that she was in pain included
pursing her lips, grimacing, thrashing in bed, curling her toes or
moving her legs around. She would let you know when she had a
bowel movement by flipping up the covers and pulling on her diaper
and scooted in bed on her bottom.

8. When I came into her room and said "Hi, Terri", she would always
recognize my voice and her name, and would turn her head all the way
toward me, saying "Haaaiiiii" sort of, as she did. I recognized this as a
"hi", which is very close to what it sounded like, the whole sound

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being only a second or two long. When I told her humrous stories
about my life or something I read in the paper, Terri would chuckle,
sometimes more a giggle or laugh. She would move her whole body,
upper and lower. Her legs would sometimes be off the bed, and need
to be repositioned. I made numerous entries into the nursing notes in
her chart, stating verbatim what she said and her various behaviors, but
by my next on-duty shift, the notes would be deleted from her chart.
Every time I made a positive entry about any responsiveness of Terri's,
someone would remove it after my shift ended. Michael always
demanded to see her chart as soon as he arrived, and would take it in
her room with him. I documented Terri's rehab potential well,
writing whole pages about Terri's responsiveness, but they would
always be deleted by the next time I saw her chart. The reason I wrote
so much was that everybody else seemed to be afraid to make positive
entries for fear of their jobs, but I felt very strongly that a nurses job
was to accurately record everything we see and hear that bears on a
patients condition and their family. I upheld the Nurses Practice Act,
and if it cost me my job, I was willing to accept that.

9. Throughout my time at Palm Gardens, Michael Schiavo was focused

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on Terri's death. Michael would say "When is she going to die?,"
"Has she died yet?" and "When is that bitch gonna die?" These
statements were common knowledge at Palm Gardens, as he would
make them casually in passing, without regard even for who he was
talking to, as long as it was a staff member. Other statements which I
recall him making include "Can't anything be done to accelerate her
death - won't she ever die?" When she wouldn't die, Michael would
be furious. Michael was also adamant that the family should not be
given information. He made numerous statements such as "Make sure
the parents aren't contacted." I recorded Michael's statements word
for word in Terri's chart, but these entries were also deleted after the
end of my shift. Standing orders were that the family wasn't to be
contacted, in fact, there was a large sign in the front of her chart that
said under no circumstances was her family to be called, call Michael
immediately, but I would call them, anyway, because I thought they
should know about their daughter.

10. Any time Terri would be sick, like with a UTI or fluid buildup in her
lungs, colds, or pneumonia, Michael would be visibly excited, thrilled
even, hoping that she would die. He would say something like,

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"Hallelujah! You've made my day!" He would call me, as I was the
nurse supervisor on the floor, and ask for every little detail about her
temperature, blood pressure, etc., and would call back frequently
asking if she was dead yet. He would blurt out "I'm going to be rich!"
and would talk about all the things he would buy when Terri died,
which included a new car, a new boat, and going to Europe, among
other things.

11. When Michael visited Terri, he always came alone and always had the
door closed and locked while he was with Terri. He would typically
be there about twenty minutes or so. When he left Terri would be
trembling, crying hysterically, and would be very pale and have cold
sweats. It looked to me like Terri was having a hypoglycemic reaction,
so I'd check her blood sugar. The glucometer reading would be so low
it was below the range where it would register an actual number
reading. I would put dextrose in Terri's mouth to counteract it. This
happened about five times on my shift, as I recall. Normally Terri's
blood sugar levels were very stable due to the uniformity of her diet
through tube feeding. It is medically possible that Michael injected
Terri with Regular insulin, which is very fast acting, but I don't have

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any way of knowing for sure.

12. The longer I was employed at Palm Gardens the more concerned I
became about patient care, both relating to Terri Schiavo, for the
reasons I've said, and other patients, too. There was an LPN named
Carolyn Adams, known as "Andy" Adams who was a particular
concern. An unusual number of patients seemed to die on her shift,
but she was completely unconcerned, making statements such as
"They are old - let them die." I couldn't believe her attitude or the fact
that it didn't seem to attract any attention. She made many comments
about Terri being a waste of money, that she should die. She said it
was costing Michael a lot of money to keep her alive, and that he
complained about it constantly (I heard him complain about it all the
time, too.) Both Michael and Adams said that she would be worth
more to him if she were dead. I ultimately called the police relative to
this situation, and was terminated the next day. Other reasons were
cited, but I was convinced it was because of my "rocking the boat."

13. Ms. Adams was one of the people who did not seem to be intimidated
by Michael. In fact, they seemed to be very close, and Adams would
do whatever Michael told her. Michael sometimes called Adams at

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night and spoke at length. I was not able to hear the content of these
phone calls, but I knew it was him talking to her because she would
tell me afterward and relay orders from him.

14. I have contacted the Schindler family because I just couldn't stand by
and let Terri die without the truth being known.

FURTHER AFFIANT SAYETH NAUGHT.

<signed>
CARLA SAUER IYER, R.N.

The foregoing instrument was acknowledged before me this 29 day of August,
2003, by CARLA SAUER IYER, R.N., who produced her Florida's driver's license
as identification, and who did take an oath.

<signed Patricia J. Anderson>
Notary Public

My commission expires
<Notary seal of Patricia J. Anderson>