SUMMARY OF TESTIMONY BY DR.

MATTHEW BRAMS

(This Summary focuses on Dr. Shirley Pigott’s medical disability)

1. Dr. Brams has been Dr. Pigott’s treating physician for 9 years; her original diagnosis is
bipolar disorder and attention deficit hyperactivity disorder; Dr. Pigott did very well on
her medications with no indications that these two illnesses were getting worse.
2. In 2007, Dr. Pigott suffered several traumatic stresses; her husband for many years
developed Alzheimer’s, committing suicide in January, 2008; her activism toward the
TMB became very tense and stressful, with the TMB raising issues about her medical
license.
3. These stresses caused Dr. Pigott to suffer from Post Traumatic Stress Disorder; her
underlying bipolar disorder and her attention deficit hyperactivity disorder further
interfered with her ability to process external stimuli.
4. P.T.S.D. results in a hyper-vigilant state; one may develop a phobia, ie, one may
perceive fear even when there is no reason to be fearful. In a situation where one could
rationally be fearful, the P.T.S.D. will result in the fear being heightened by many
magnitudes.
5. In the hyper-vigilant state, the response to relatively minor stimuli will be exaggerated.
In Dr. Pigott's case her vital signs in the emergency room reached as high as BP 160/106
and Pulse 134, a condition known as adrenergic storm, as explained by her cardiologist.
Considering her near collision with the 18-wheeler shortly after Officer Terronez
shattered her car window, her fear of harm may have been completely rational;
6. To an outside observer, one suffering from P.T.S.D. can appear irrational, even crazy. It
is incumbent upon law enforcement officers to possess skills which enable them to calm
a person with such a disability. However, the person with P.T.S.D. is reacting to the
extreme anxiety of a full-blown panic attack. Dr. Pigott, being in fear for her life, did not
possess a mens rea, a necessary component of a crime in every state. The jury was not
instructed that a criminal act must have two components - an actus reus (leaving the
scene when she was being detained) and a mens rea, or guilty mind. Her intent was not
to "flee arrest"; she was fleeing for her life.
7. Considering her obvious paralysis on the witness stand in response to what she
perceived to be prosecutorial abuse, she was unable, because of her disability, to
explain these facts to the jury.

Dr. Brams did not have access to the following:

The Deloitt Report (Exhibit X) acknowledges that DPS officers sometimes lack
professionalism, as appears to have been the case on September 29, 2007.

Had Dr. Pigott been a black male in Wharton County, with the same diagnoses, not
having the advantage of being under skilled psychiatric care for years,not on stabilizing
medications, the outcome could have been tragically different.

It is a fact that Officer Terronez has been the sole witness to several single vehicle
accidents resulting in fatalities. In 1997, he (or his backup) shot in the back and killed a
young unarmed man who was said to have been "fleeing arrest". It may be that Dr.
Pigott was actually perceptive that she truly was in a position where her life really was in
danger. If so, she acted appropriately.