posted by admin on Feb 1
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1 deposition of Dr. H., deposition of Dr. P.. I
2 looked at brain images. I looked at ultrasound from
3 September 15th. I looked at MRI scan from September
4 18th. I looked at ultrasound from September 21st, an
5 ultrasound from September 27th. I looked at ultrasound
6 from October 10th. I looked at a CT scan from March
7 11th, 1999. The other films are all 1998.
8 Q Okay. Did you look at anything else before
9 you wrote your report of December 27th?
10 A I don’t think so.
11 Q Medical articles? Chapters in textbooks?
12 Medline Search?
13 A The only — I think when I sent the letter,
14 I sent along an abstract from a Volpe article, Annals
15 of month, year, month, pages 3 to 11 called
16 “Intraventricular Hemorrhage in the Premature Infant,
17 Current Concepts,” Part I. I also sent along abstracts
18 of an article from Pediatric Research, 1984, January,
19 Volume 18, pages 7 to 11 called “Cerebral Blood Flow
20 and Experimental Intraventricular Hemorrhage” by
21 Goddard-Finegold. G-O-D-D-A-R-D, F-I-N-E-G-O-L-D and
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1 M. –.
2 Q Did you send along any other articles with
3 your report aside from the two you just mentioned?
4 A No.
5 Q Why didn’t you cite those two articles in
6 your report?
7 A I’m not sure.
8 Q Did you review any more than the two
9 articles and just decide to send those two along?
10 A No. I think these were just — these
11 supported my position, so I didn’t review any others.
12 Q Did you discuss these two articles with
13 defense counsel before you sent them to him?
14 MR. J.: Objection. Go ahead.
15 A I think — no. I think what the sequence
16 was, I talked about my opinions on the phone, and then
17 I wrote the letter, and then I just — I mean, there
18 are many articles that document the same point, but I
19 just picked these two as examples and sent them along.
20 Q What did you expect defense counsel would
21 do with these two articles?
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1 A I thought they would read them, and that
2 they would see that the words in them corresponded to
3 my opinion that the premature infant is vulnerable to
4 intracranial hemorrhage related to hypotension,
5 especially hypotension related to hypovolemia.
6 For example, the article by
7 Goddard-Finegold documented in animals that five
8 minutes of hemorrhagic hypotension was associated with
9 intracranial hemorrhage. And Volpe indicated in humans
10 that abrupt increases and decreases in cerebral blood
11 flow in the premature are related to intracranial
12 hemorrhage.
13 And since this baby had — was very
14 premature and had a documented episode of bradycardia,
15 these articles supported the position that that episode
16 was probably related to the baby’s brain injury and
17 intracranial hemorrhage.
18 Q Did you write any other letters to defense
19 counsel?
20 A I don’t think so.
21 Q Have you ever passed along medical articles
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1 to defense counsel before?
2 A I’ve passed them along both to plaintiff
3 and defense counsel.
4 Q And when you’ve done such, don’t you have a
5 cover letter, Dear Attorney: Enclosed you’ll find
6 articles you may find helpful?
7 A I faxed these. This was faxed on –
8 actually, it was — looks like these were faxed
9 recently. month 9th, year to Jo E.L.–
10 , fax number: fax number.
11 Q So that when you told me earlier the
12 articles went along with your report, you were in
13 error, correct?
14 MR. J.: Objection. That doesn’t
15 follow at all.
16 A I’m not sure, but –
17 Q Well, is it now your testimony, sir, that
18 you sent the articles along with the December 27th
19 letter, and, in addition to that, faxed them in
20 Month year?
21 A I don’t know. It looks like — it looks
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1 like these were faxed independently.
2 Q Meaning?
3 A You mean in the same envelope as the
4 letter?
5 Q Did they go in the letter or not? Do you
6 want to change your testimony, or stick with your
7 earlier testimony?
8 MR. J.: Objection.
9 A No, I don’t think I’ll do either one. I’ll
10 just tell you what I have that I faxed them on Month
11 9th, year.
12 Q After the December 27th report, were you
13 provided with any other material to review in
14 connection with this case?
15 A Yeah. I have other — other reports. I
16 have expert reports.
17 MR. J.: He’s asking at the time, I
18 think, as opposed to subsequent to your report.
19 MR. GERSHON: No.
20 Q Subsequent. After December 27th –
21 MR. J.: Okay.
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