IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA
PROBATE DIVISION


IN RE:  THE GUARDIANSHIP OF			
	THERESA MARIE SCHIAVO,
	Incapacitated.
		//

MICHAEL SCHIAVO, as Guardian of the 
Person of THERESA MARIE SCHIAVO,

	Petitioner,		File No. 90-2908GD-003				
vs.

ROBERT SCHINDLER and MARY 
SCHINDLER,

       	Respondents.
       	
	//

AFFIDAVIT

STATE OF FLORIDA
				ss
COUNTY OF PINELLAS

     BEFORE ME the undersigned authority personally appeared HEIDI LAW who being first duly sworn deposes and says:
1.	My name is Heidi Law, I am over the age of 18 years, and make this statement on personal information.
2.	I worked as a Certified Nursing Assistant at the Palm Gardens nursing home from March 1997 to mid-summer of 1997. While I was employed at Palm Gardens, occasionally I took care of Theresa Schiavo. Generally, I worked the 3 p.m. to 11 p.m. shift, but occasionally also would work a double shift, until 7 a.m. the following morning. At Palm Gardens, most of the patient care was provided by the CNAs, so I often served as a caregiver for Terri.
3. I know that as a caregiver for Terri I was instructed by various charge nurses never to talk to Terri’s parents about her medical condition, only to talk to Michael Schiavo about her condition.  
4. I never had access to medical records as a CNA, but as one of Terri’s caregivers, I never saw in Terri’s file, nor did anyone ever tell me about, any written notice from Michael Schiavo that he had no objection to Terri’s caregivers discussing Terri’s medical condition with either Robert or Mary Schindler.  I was never made aware of any such notice in Terri’s file, nor of any court order directing Michael to instruct Terri’s caregivers that they could discuss Terri’s medical condition with her parents.  
5. In fact, I was specifically instructed by various charge nurses not to discuss Terri’s medical condition with her parents, but only with Michael, even though it was clear from Terri’s reactions to visitors that her mother was her favorite person in the whole world. 
6. As a CNA, I wanted every piece of information I could get about my patients in order to give them the best care possible and I was especially fond of Terri.  But I was told by supervisory staff that Michael was Terri's legal guardian, and to do what Michael told you to do or you will lose your job.  
7. To the best of my knowledge, none of Terri’s caregivers at Palm Garden were ever instructed or informed either orally or in writing that Michael Schiavo had no objections to Terri’s caregivers discussing her medical condition with Robert or Mary Schindler.  
	AFFIANT SAYS NOTHING FURTHER.


	______________________________
	Heidi Law

Sworn to and subscribed before me this _____ day of March, 2004.


	
Notary Public, State of Florida 

Printed Name: 	


	 Personally Known
	 Produced 	
        as identification.
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