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IN THE COURT OF COMMON PLEAS
LAKE COUNTY, OHIO
2

3 VICTOR BUKKY, Admr of the Estate CASE NO 90 CV 1435
of Victoria L Bukky
4
Plaintiff
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VS VIDEO DEPOSITION
6
LAKE HOSPITAL SYSTEM, et al
7
Defendants
8

9 The Video Deposition of Dr Albert Briggs, Jr,

10 taken before Brenda Morris, Notary Public and Court

11 Reporter for the State of Virginia at Large, at

12 Community Hospital of Roanoke Valley, Roanoke, Virginia,

13 on July 27, 1992, at 12:45 o'clock pm, taken by the

14 Defendant Glorioso, by counsel, taken pursuant to Rule 4

15 of the Rules of Court

16

17 APPEARANCES: ERIC KENNEDY
Counsel for Plaintiff
18
DAVID W SUMNER
19 Counsel for Defendant Glorioso

20

21
Account Number
22 Tape Number 92-RlOl
Disk Number R-9
23 Case Number 92-RlOl

24

25



VIDEO FILMTRONICS COURT REPORTING, INC
P0 BOX 3363
DANVIUE, VIRGINIA 24543
I-SM-638-8128 804-799-9622

1 C 0 N T E N T S

2

3 DR ALBERT BRIGGS, JR

4

5 Direct Examination by Mr Sumner 02

6 Cross Examination by Mr Kennedy 35

7 Re-Direct Examination by Mr Sumner 62

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VIDEO FILMTRONICS COURT REPORTING, INC
PO BOX 3363
DANVILLE, VIRGINIA 24543
1800-638-8128 804-7(9,8622

E





1 For the record, I am Brenda Morris, a Notary Public

2 and Court Reporter for the State of Virginia, also the

3 operator of the camera My employer is Video

4 Filmtronics Court Reporting, Inc, 2321 Riverside Drive,

5 Danville, Virginia For the record, I hereby certify

6 that the date and the time now appearing in the video

7 tape is true and correct to the best of my knowledge

8 The style of the case is Victor Bukky, Administrator of

9 the Estate of Victoria L Bukky versus Lake Hospital

10 System, et al This deposition is being taken on behalf

11 of Mr David W Sumner, attorney for the defendant, Dr

12 Efren Glorioso  The place of the deposition is

13 Community Hospital of Roanoke Valley, Roanoke,

14 Virginia The name of the witness is Dr Albert

15 Briggs Doctor, will you please raise your right hand

16 to be sworn?

17

18 The witness, ALBERT BRIGGS, JR, after first being
duly sworn, deposes and says:
19
BY MS  MORRIS, (COURT REPORTER):
20
Mr Sumner, identification for the jury, please
21
BY MR  SUMNER:
22
State your full name, please?
23
BY DR  BRIGGS:
24
Albert Leon Briggs, Jr
25
BY MS  MORRIS, (COURT REPORTER):



VIDEO FILMTRONICS COURT REPORTING, INC
PO BOX 3363
DANVILLE, VIRGINIA 24543
1-900-638-9129 804-799-8622

1 Would you identify yourself, Mr Sumner?

2 BY MR SUMNER:

3 Okay  Dave Sumner  I represent Dr Glorioso

4 BY MS MORRIS, (COURT REPORTER):

5 Thank you Mr Kennedy, would you identify

6 yourself for the jury, please?

7 BY MR KENNEDY:

8 Yes Eric Kennedy I represent the family of

9 Victoria Bukky

10 BY MS MORRIS, (COURT REPORTER):

11 Thank you We're ready to proceed

12

13 DIRECT EXAMINATION BY MR SUMNER:

14 Q Dr Briggs, could you give us your professional

15 address, please?

16 A My professional address is Roanoke Memorial

17 Hospital and Community Hospital of Roanoke Valley

18 Q What are your current professional or clinical

19 responsibilities?

20 A Right now, I'm engaged in the full time practice of

21 emergency medicine which involves treating patients

22 in the emergency room at the above-two hospitals,

23 as well as teaching residents from the University

24 of Virginia

25 What kind of emergency room schedule do you keep on


PAGE 2

VIDEO FILMTRONICS COURT REPORTING, INC
PO BOX 3363
DANVILLE, VIRGINIA 24543
1-800-638-8128 SD4-799-8622

1 a monthly basis?

2 A I work full time in the clinical practice and

3 average between thirty and forty hours per week

4 seeing patients in the emergency department

5 Q How many patients would you say you see on a

6 monthly basis given your current emergency room

7 responsibilities?

a A A ballpark figure I'd say it would probably be

9 between seven and eight hundred patients per month

10 Q Did you previously practice emergency medicine in

11 the Cleveland, Ohio area?

12 A Yes I practiced full time at Mount Sinai Medical

13 Center in Cleveland, Ohio, for three and a half

14 years as an attending physician

15 Q Is that where you were practicing when you were

16 first contacted by me in 1991 to review the case?

17 A Yes, I was

i8 Q What type of emergency room practice did you have

19 at Mount Sinai?

20 A I was, as I mentioned, one of the attending

21 physicians in the department of emergency medicine,

22 and I also was on the faculty of the emergency

23 medicine residency program at Mo