posted by admin on Feb 1

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1 Q With anything.

2 A These are in prematures and –

3 Q Well, how many weeks do you think this

4 child was, sir?

5 A I think it was between 28 and 31 weeks.

6 Q Okay. Any literature out there with

7 preemies of that same gestational age suffering a low

8 heart rate, any literature out there with subsequent

9 neurological outcome?

10 A Well, I think I’d go back and explore this

11 Volpe literature indicating that fluctuations in

12 cerebral blood flow are linked to intraventricular

13 hemorrhage. And I think that there’s, you know, a

14 series of articles that his groups worked on looking at

15 the relationships between fluctuations in blood flow

16 and hemorrhage. But that’s the — you know, I think

17 the accepted mechanism of hemorrhages, fluctuations in

18 cerebral flood flow. And bradycardia is a prominent

19 cause from that. And in a premature infant like this,

20 we can assume that the cerebral circulation is pressure

21 passive. So any bradycardia in the premature infants


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1 is going to be translated into reduced blood flow in

2 the infant.

3 Q Do you know of any of that Volpe literature

4 that talks about bradycardia for even a few seconds

5 causing brain damage in a subsequent infant?

6 A In a what?

7 Q Subsequently for that infant.

8 A Yeah, I think there’s — I think if you

9 follow the Volpe literature, there’s certainly

10 correlations between oscillations and cerebral flood

11 flow and bradycardia in the newborn nursery linked to

12 periventricular leukomalacia.

13 Q And in all of those articles by Volpe, and

14 even in his textbooks, isn’t it fair to say that

15 bradycardia has to last for a certain amount of time

16 before it will affect the fetus?

17 A I’m not sure of that. The main issue is

18 that the — it’s related to oscillations of blood flow,

19 ups and downs in blood flow. I don’t think there’s a

20 good connection between exactly how much time the

21 bradycardia occurs.


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1 Q Okay. In all of Volpe’s literature where

2 he talks about the oscillations, wouldn’t you agree

3 that those infants who are brain damaged have multiple

4 oscillations of bradycardias and normal heart rates?

5 A Well, at least they — I’m not sure if they

6 all have multiple. They have — I’m not sure there’s a

7 good connection between exactly how many and how long

8 they last, but there is a strong link between

9 bradycardia and — and oscillations in cerebral blood

10 flow.

11 Q Do you know of a single article, sir,

12 whether it’s by Volpe or anybody else, that says just

13 one or two oscillations of heart rate to a premature

14 fetus is enough to cause neurological brain damage to

15 the extent that this fetus has?

16 A I don’t — I can’t really think of

17 literature that’s addressed that one way or the other.

18 Q You mention in your report in the middle of

19 the paragraph, “My general opinion is based on research

20 indicating that injury to the developing brain occurs

21 when a critical threshold is reached as opposed to


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1 occurring incrementally in the cumulative dose-related

2 fashion.” Do you see that sentence?

3 A Yeah.

4 Q Are you referring to your own research,

5 sir?

6 A No. Well, I think my research, but other

7 research indicates that the — for example, the

8 Goddard-Finegold research, you withdraw blood, you

9 reinsert blood, and once you — once you’ve reached a

10 threshold of reduced blood flow, then that’s enough to

11 damage the brain.

12 Q Would your own research be included in

13 those articles you identified at the beginning of the

14 deposition from your CV?

15 A No. I just actually cited review articles

16 which are more clinical in nature. Mine is — related

17 to this topic is — is more related to — I guess I

18 don’t have anything definitely related to clinical work

19 on this topic, so I cited reviews that I wrote.

20 Q Then why did you tell me your opinion’s

21 based on your own research and others’ research,


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1 including the Finegold articles? Really it’s not based

2 on your own research.

3 A Yeah, my opinion is, but I just chose not

4 to — not to cite those articles because the other

5 articles I wrote, the review articles, incorporate my

6 own research plus others’ research.

7 Q So there are other articles on your CV now

8 that indicate you did personally your own research

9 which backs up your theory of this critical threshold,

10 correct?

11 A Well, I think they’re consistent with it.

12 I think that the ones that I cited are the — are

13 better ones because they’re broader. They cover a

14 wider range.

15 Q So the articles you cited on your CV at the

16 beginning of the deposition mention your personal

17 research about this critical threshold theory, correct?

18 A Right.

19 Q Okay. Do all the articles you cited at the

20 beginning mention that, or is there one or two

21 particular articles that mention your personal research

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