posted by admin on Feb 1

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1 into the theory of the critical threshold being

2 reached?

3 A I’d say probably half of them do.

4 Q Can you identify for us which of the half

5 describe your personal research into the critical

6 threshold theory?

7 A No, I don’t think so.

8 Q Why not?

9 A Well, because it would — I’d have to go –

10 go over them in more detail to make an accurate –

11 Q Okay.

12 A – description.

13 Q If one would want to read those articles,

14 would it be clear from the plain language in the

15 articles that you’re describing your personal research

16 into the critical threshold theory?

17 A Yeah, I’m sure it would.

18 Q Okay. Now, you also mentioned another

19 article, the Finegold article, describes this critical

20 threshold theory, correct?

21 A Right.


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1 Q Is there any other article you can think of

2 in the world that describes the critical threshold

3 theory that you are a proponent of?

4 A I think most of the literature in this area

5 talks about the same thing.

6 Q Can you identify any of the articles that

7 you believe most subscribe to this critical threshold

8 theory?

9 A No.

10 Q Okay. You mention, “The outcome was

11 already determined at the time of the placenta previa

12 and slow heart rate was documented on ultrasound.”

13 What outcome are you referring to, the child’s current

14 condition?

15 A Yeah. The intracranial hemorrhages and the

16 white matter injury.

17 MR. GERSHON: Okay. Sir, I don’t have any

18 other questions for you. I thank you for your time as

19 always.

20 THE WITNESS: Okay. Thanks.

21 MR. J.: Anybody else?


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1 MR. GERSHON: Madam Reporter, we’d like a

2 minuscript and an ASCII disk, please.

3 MR. J.: Anybody else? Hello?

4 MR. C.: Yeah, I’d like a copy of the

5 transcript. This is Greg C.. Shannon, what’s your

6 phone number?

7 MR. K.: I think I may have some

8 questions, Greg, actually.

9 MR. C.: Oh, okay.

10 EXAMINATION BY MR. K.:

11 Q Dr. J., my name is J.K.. I

12 represent Dr. S.. Can you hear me okay?

13 A Yeah.

14 Q Okay. I’ll be very brief. I want to make

15 sure that we — that I get a good understanding of your

16 credentials. First, I assume you’re licensed to

17 practice medicine?

18 A Yes.

19 Q And what states are you licensed to

20 practice medicine in?

21 A In M. and Pennsylvania.


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1 Q Okay. And I see you’re affiliated with the

2 K.K.Institute and also Johns Hopkins

3 University School of Medicine?

4 A Yes.

5 Q How long have you been affiliated with each

6 of those institutions?

7 A I did all my training at Hopkins, so I was

8 there for seven years, and then I have been back as a

9 professor for 13 years.

10 Q And are you board certified in any

11 specialties and/or subspecialties?

12 A Yeah. I’m board certified in pediatrics

13 and in pediatric neurology.

14 Q And do you dedicate greater than 50 percent

15 of your time to either the active clinical practice of

16 medicine and/or teaching?

17 A Yeah. It’s about 60 percent patient care,

18 20 percent research, 15 percent administration and five

19 percent classroom teaching.

20 Q And you and I have never met before this

21 deposition here today, correct?


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1 A I don’t think so. I can’t see you, but I

2 don’t think we have.

3 Q I like to tell people that I look like Tom

4 Cruise, but since I’m technically under oath, I guess

5 we can’t.

6 A Okay.

7 Q I want to ask you some very brief questions

8 about your CV and then your opinions just so I have a

9 clear understanding.

10 A Okay.

11 Q I see from your curriculum vitae that you

12 have lectured all over the — all over the world

13 actually on pediatric neurology topics, correct?

14 A Right.

15 Q That includes places like Harvard

16 University, Stanford University as well as abroad,

17 correct?

18 A Right.

19 Q I see that you served in the U.S. Army, it

20 appears?

21 A Right.

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