1 State of uhio,
SS:
2 County of Cuyahoga.)
3

4 IN THE COURT OF COMMON PLEAS

5 - - -
MARY DUCKWORTH, etc.,
6 et al.

7 Plaintiffs,

8 vs. Case No. 226,873

9 LUTHERAN MEDICAL CENTER,)
et al., Judge Patricia Cleary
10
Defendants.

12 DEPOSITION OF THEODORE J. CASTELE, M.D.
Monday, February 15, 1993
13

14

15 The deposition of THEODORE J. CASTELE, M.D., a

16 witness, called for examination by the Plaintiffs

17 under the Ohio Rules of Civil Procedure, taken

18 before me, Diane M. Stevenson, a Registered

19 Professional Reporter and Notary Public in and

20 for the state of Ohio, by agreement of counsel,
@j at the offices of Weisman, Goldberg & Weisman
I- -

22 Co., LPA, 1600 Midland Building, Cleveland, Ohio

23 commencing at 11:10 a.m., the day and date above

24 set forth.

25

Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

2 3





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2

1 APPEARANCES:

2 On behalf of the Plaintiffs:

3 Richard J. Berris, Esq.
Laurence Powers, Esq.
4 Weisman, Goldberg & Weisman Co., LPA
1600 Midland Building
5 Cleveland, Ohio 4 4 1 1 5

6
On behalf of the Defendant
7 Lutheran Medical Center:

8 Kris Treu, Esq.
Arter & Hadden
9 1100 Huntington Building
Cleveland, Ohio 44115
10

11 On behalf of the Defendants
Dr. Lontoc and Medical Center Radiologists:
12
Douglas K. Fifner, Esq.
13 Reminger & Reminger Co., LPA
The 113 Building
14 Cleveland, Ohio 4 4 1 1 4

15
On behalf of the Defendants
1 10 Dr. oza and Dr. Kapoor:

17 Beth Sebaugh, Esq.
Quandt, Giffels & Buck
18 800 Leader Building
Cleveland, Ohio 4 4 1 1 4
19

10 On behalf of the Defendants Dr. Pelini
and Acute Care Specialists, Inc.:
21
Thomas Terrv, Esa.
2-) Jacobson, Maynard, Tuschman & Kalur
1001 Lakeside Avenue, Suite 1600
23 Cleveland, Ohio 44114

4 - - -

5

Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge



F T R-  -1

3
1 THEODORE CASTELE, M.D.
2 A witness, called for examination by the
3 Plaintiffs, under the Rules, having been first
4 dulv sworn, as hereinafter certified, was
5 examined and testified as follows:
6 CROSS-EXAMINATION
7 BY MR.  BERRIS:
8 Q. State your full name, please.
9 A. Theodore J. Castele, M.D.
10 Q. Doctor, I am going to ask you some questions
11 today about some information that you have with
12 respect to this Duckworth matter. If any of my
13 questions are not clear or you don't understand
14 them, please let me know, and I will rephrase the
15 question for you. Okay?
16 A. Yes.
17 Q. You are a physician with a specialty in what
18 area?
19 A. Radiology.
20 Q. Are you Board certified in radiology?
21 A. Yes.
22 Q. Where did you attend medical school?
23 A. Case Western Reserve University.
24 Q. Graduated what year?
2 5 A . 5 7 .
Diane M. Ste@7enson, RPR, CM
Morse, Gantverg & Hodge

@Tff - I
1 Q. And you did your residency-

2 A Internship and residency at University Hospitals

3 of Cleveland.

4 Q. So all of your medical training is at University

5 Hospitals and Case Western?

6 A. Yes, that's correct. That is exactly correct.

7 Q. And you did a residency in radiology?

8 A. Radiology, correct.

9 Q. Is that the only residency that you did?

10 A. Yes, that's correct.

11 Q. And completed that in what year?

12 A. Residency was completed in 161.

13 Q. Following the completion of your residency, what

14 did you do?

15 A. Well, I had a fellowship at the same place while

16 I waS--T had a fellowship starting in, approxi-

17 mately, July of '61 and going through July of 162
1

13 at University Hospitals while I was also

19 practicing radiology at University Hospitals-

no excuse me, while I was also practicing radiology

21 at Lutheran Medical Center.

22 Q. So you have been on the staff of Lutheran Medical

23 Center since when?

24 A. Probably early 1961.

25 Q. And continuously since thaz time?

Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

5

1 A Continuously since that time, that Is correct.

2 Q. Do you know Dr. David?

3 A. I know who he is, yes. I don't know him well.

4 Q. From St. Thomas?

5 A . Yes.

6 Q. How is it that you know him?

7 A . He is a radiologist, and I have met him over the

8 years at various meetings. That is the only way

9 I know him.

1( Q. You have held various positions on the staff of

11 Lutheran Medical Center over the years?

12 A. Yes.

13 Q. What positions have you held?

14 A. Oh, wow, an awful lot. I have been Chief of

15 Staf f .

16 Q. You have been Chief of Radiology?

17 A. I have been Chief of Radiology.

18 Q. Over what period of time were you Chief of

19 Radiology?

20 A. I was Chief of Diagnostic Radiology, which is a

21 d