"One of the main symptoms is a reliving of the original traumatic experience through either flashbacks, or in nightmares. Beyond that, there's insomnia, of course, and a sense of disconnect with life. Then depression, memory and cognition issues, abusive and self-destructive behavior. A huge range of personal and societal problems, actually."
"Doctor, you referred to abusive and self-destructive behavior. Could this include alcohol abuse?"
"Yes, of course."
"And memory issues? Do you mean blackouts?"
"Yes. Blackouts are not uncommon, especially if coupled with excessive drinking or drug use or both."
"I see." Washburn acted as though he were hearing all of this for the very first time in his life. Now he moved a step closer to his witness. "Doctor, is there a physical component to PTSD? Or is it simply what a layman might just call a mental problem?"
As Washburn intended, this question kept Overton from becoming lulled in her relatively straightforward recounting. This hearing hadn't been his idea, but since he was in it, he was dry-running her to play to the jury's sensibilities when and if she testified at trial. She sat up stiffly, her expression defiant. "Absolutely not! In the first place, a mental problem is a real problem. It's as real as a broken leg. Secondly, with PTSD there is measurable altered brain-wave activity, decreased volume of the hippocampus and abnormal activation of the amygdala, both of the latter having have to do with memory. The thyroid's affected, as is production of epinephrine and cortisol. I could go on, but suffice it to say that there are many, many physical and neurological changes and reactions associated with PTSD."
"I see, Doctor. Thank you," Washburn said. "Now, have you had an opportunity to interview and examine my client, Evan Scholler, with regard to PTSD?"
"I have."
"What were your findings?"
"I found that Mr. Scholler clearly suffers from the disorder. His memory, particularly, seems to be compromised, and this symptom has been aggravated by a traumatic brain injury he suffered in Iraq in August of two thousand three. He suffers from frequent migraine headaches. Beyond that, he has reported the experience of blackouts and episodes of rage, shame, guilt, and depression. Sleeping has been a consistent problem. Finally, he has spoken to me about a tendency to abuse alcohol and other painkilling drugs, such as Vicodin. All of these symptoms are not only consistent with PTSD, they are diagnostic of it."
"And what about the physical changes you've described-to the amygdala and hippocampus and so forth? Did you test Mr. Scholler for these?"
"Yes, I did."
"What were your findings?"
"I found decreased cortisol with increased epinephrine and norepinephrine levels. Together, these hormone levels impact the body's fear response and the startle reflex, both of which I found to be in the abnormal range with Mr. Scholler."
"And your conclusions as a medical professional? Does Mr. Scholler suffer from PTSD?"
Dr. Overton looked over at the defense table where Evan sat. "Yes. Unremitting and severe PTSD. Without a doubt, in my professional opinion."
"Without a doubt. Thank you, Doctor." Washburn inclined his head in a courteous bow. Facing Mills, he turned his palm up. "Your witness, Counsel."
"DR. OVERTON," the assistant district attorney began, "you've testified that blackouts were not uncommon among people with PTSD. Were you saying that PTSD causes blackouts?"
"Not exactly. I believe I said that blackouts were common, especially when drugs or alcohol were part of the picture."
"Oh, so PTSD does not in itself cause these blackouts, is that true?"
"Well, in a sense you can say that-"
"Doctor, I'm sorry. It's a yes or no question. Does PTSD cause blackouts?"
Overton frowned, glanced over at Washburn. "They are commonly associated with PTSD, yes."
"Again, Doctor, not my question. Does PTSD cause blackouts?"
Washburn cleared his throat and spoke from his table. "Objection. Badgering."
Tollson didn't take two seconds to make up his mind. "Overruled." He leaned over to speak to the witness. "Please answer the question, Doctor."
Mills jumped right in. "Would you like me to repeat it?"
Tollson transferred his scowl down to her. "Can the sarcasm, Counselor. Doctor, answer the question, does PTSD cause blackouts?"
"Yes, there are some reports of that."
"Some? How many of these reports are you personally familiar with?"
"I'm not sure. To the best of my recollection, a few."
"A few. All right. And do any of these few reports with which you're familiar speak to the duration of any of these rare PTSD blackouts?"
From behind her, Everett Washburn rumbled forth again. "Objection. Assumes facts not in evidence. The doctor's awareness of only a few reports on blackouts doesn't mean that the blackouts themselves are rare."
"Sustained."
But Mills came right back at Overton. "Doctor," she said, "do any of these few reports with which you're familiar speak to the duration of any of these PTSD blackouts?"
"Yes, they do."
