posted by admin on Feb 1

1

1 IN THE COURT OF COMMON PLEAS
LORAIN COUNTY, OHIO
2

3 T.L.G., Minor *
by her parent and next
4 friend, D.K.G., * Case No.
Plaintiffs
5 *

6 vs. * Judge B.

7 M.F.S., M.D., *
et al
8 Defendant *

9 * * * * *

10 Telephonic deposition of M.V.

11 J., M.D., taken on behalf of the Plaintiffs,

12 before S.M.W., a Notary Public in and for

13 the State of M., County of W., at East

14 __________ Street, _____ 170, W., M.

15 Zip code, at 3:40 p.m., month 6, year.

16 * * * * *
APPEARANCES:
17
ZEEV GERSHON, Esquire (via telephone)
18 On behalf of Plaintiffs

19 J.W.J., Esquire
On behalf of Defendants,
20 R., D. & Associates

21 Reported By: S.M.W.

2

1 APPEARANCES: (Cont’d)

2
A.C., Esquire (via telephone)
3 On behalf of Defendant,
Dr. P.H.
4
J.K., Esquire (via telephone)
5 On behalf of Defendant,
Dr. M.F.S.
6

7 W.F., Esquire (via telephone)
On behalf of Defendant,
8 C.H.P Hospital

9

10

11

12

13

14

15

16

17

18

19

20

21

3

1 * * * * *

2 M.V.J. M.D.,

3 called as a witness and having been duly sworn,

4 testified as follows:

5 EXAMINATION BY MR. GERSHON:

6 Q Doctor, can you give us your name and

7 address for the record, please?

8 A It’s Dr. M. V. J. –

9 J. And my work address is address

10 B, W., M. zip code.

11 Q Doctor, as you know, my name is Zeev

12 Gershon. I’m one of the attorneys for the plaintiffs

13 in this case. I’m going to be asking you a series of

14 questions. If at any time you do not understand one of

15 my questions, please tell me so, or ask me to rephrase

16 it. If you do answer, though, I’ll assume you

17 understood the question, and I’ll hold you to your

18 answer. Do you understand?

19 A Okay.

20 Q Great. Do you have a copy of your

21 curriculum vitae in front of you?

4

1 A Yes.

2 Q We’ll mark that a Plaintiff’s Exhibit

3 Number 1 at the end of the deposition.

4 Doctor, can you either circle or indicate

5 with a check mark on there any articles that you’ve

6 written, or chapters or abstracts, what have you, that

7 pertain to your opinions in this case?

8 A Okay.

9 MR. J.: That will take awhile.

10 There’s so many.

11 MR. GERSHON: You wish.

12 MR. J.: I meant looking at it.

13 A Okay. I’ll take a few minutes. You want

14 to take a few minutes now, or –

15 Q Whatever you’d like, that’s fine with me.

16 MR. J.: Yeah, go ahead and do it.

17 A Okay. Okay.

18 MR. J.: Zeev, just so you know, and

19 everybody else, he just circled article 51 on page 26

20 of his CV.

21 MR. GERSHON: Okay.

5

1 A And 58 on twenty — page 26. And then I

2 guess 61, page 27. And then 63 on page 27. And 72 on

3 page 27.

4 MR. J.: Pardon me?

5 THE WITNESS: Seventy-two.

6 MR. J.: Okay.

7 A And those are the — those are the ones

8 that are relevant.

9 Q Great. Do you have a copy of your report,

10 the December 27th report, in front of you?

11 A Let’s see. Yeah.

12 Q Can you list for me the material you

13 reviewed in connection with this case before you wrote

14 your report?

15 A Okay. Here I have it, yeah. I looked at

16 the records from Community Health Partners, including

17 the newborn and maternal records. I looked at the

18 Metro Health Medical records, including progress notes,

19 labs, radiology and special diagnostics. Outpatient

20 records from Metro Health Center. I looked at the

21 depositions of both parents, deposition of Dr. S.,

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