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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