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1 1 STATE OF WISCONSIN 2 IN THE CIRCUIT COURT FOR THE COUNTY OF MILWAUKEE 3 SARA E BONFIGLIO, a minor, by Gerald J Bloch, her 4 Guardian ad Litem, DEBRA J BONFIGLIO, and 5 ANTHONY BONFIGLIO, MD, 6 Plaintiffs, 7 and 8 COMPCARE HEALTH SERVICES INSURANCE CORPORATION, STATE OF WISCONSIN 9 DEPARTMENT OF HEALTH AND SOCIAL SERVICES and EMPLOYERS 10 HEALTH INSURANCE COMPANY, 11 Subrogated Plaintiffs, 12 Civil Action No: v 13 94-CV-001983 ST MARY\'S HOSPITAL, 14 PHYSICIANS INSURANCE COMPANY OF WISCONSIN, INC (PICWIS), 15 WISCONSIN HEALTH CARE LIABILITY INSURANCE PLAN (WHCLIP), 16 KAREN KRENZKE, MD, NEIL R GUENTHER, MD and WISCONSIN 17 PATIENTS COMPENSATION FUND 18 Defendants _____________________________/ 19 20 21 DEPOSITION OF STEVEN M DONN, MD 22 Taken at the Offices of Hall and Deer, 23 215 East Washington, Ann Arbor, Michigan, on 24 October 25, 1994 commencing at or about 25 9:25 am HALL AND DEER (800) 321-3904 2 1 APPEARANCES: 2 For the Plaintiffs: 3 GERALD J BLOCH Warshafsky, Rotter, Tarnoff, 4 Reinhardt & Bloch, SC 839 North Jefferson Street, 6th Floor 5 Milwaukee, Wisconsin 53202-3796 6 For Defendant Wisconsin Patients Compensation Fund: 7 MR JAMES G DOYLE 8 Schellinger & Doyle, SC 445 South Moorland Road 9 Brookfield, Wisconsin 53008-0464 10 For Defendant St Mary\'s Hospital: 11 MS MARILYN M CARROLL Kravit, Gass & Weber, SC 12 825 North Jefferson Street, Suite 500 Milwaukee, Wisconsin 53202 13 For Defendants Neil R Guenther, MD 14 and WHCLIP: 15 MR TODD M WEIR Otjen, Van Ert, Stangle, 16 Lieb & Weir 700 North Water Street, Suite 800 17 Milwaukee, Wisconsin 53202-4206 18 For Defendants Karen Krenzke, MD and PICWIS: 19 MR JOSEPH M FASI, II 20 Hinshaw & Culbertson 100 East Wisconsin Avenue, Suite 2600 21 Milwaukee, Wisconsin 53202 22 REPORTED BY: 23 Tami I Harrison, CSR-3639 Certified Shorthand Reporter 24 25 HALL AND DEER (800) 321-3904 3 1 I N D E X 2 WITNESS: 3 STEVEN M DONN, MD Page 4 Examination by Mr Weir 4 5 Examination by Ms Carroll 52 6 Examination by Mr Fasi 108 7 Further Examination by Mr Weir 124 8 Further Examination by Mr Fasi 139 9 Further Examination by Ms Carroll 142 10 Examination by Mr Bloch 156 11 12 13 14 15 EXHIBITS: 16 Deposition Exhibit Nos 23, 24, 17 24-A and 25 4 18 Deposition Exhibit No 24-B 20 19 Deposition Exhibit No 26 25 20 Deposition Exhibit No 27 28 21 Deposition Exhibit No 28 57 22 23 24 25 HALL AND DEER (800) 321-3904 4 1 Ann Arbor, Michigan 2 October 25, 1994 3 At or about 9:25 am 4 * * * 5 (Deposition Exhibit Nos 23, 24, 24-A 6 and 25 marked for identification) 7 S T E V E N M D O N N, M D, 8 having first been duly sworn or affirmed by the 9 Notary Public, was examined and testified as 10 follows: 11 EXAMINATION 12 BY MR WEIR: 13 Q You are Dr Steven Donn, correct? 14 A Correct 15 Q You\'ve given depositions before, correct? 16 A I have 17 Q So you understand the process I\'m here to ask 18 you some questions Some of the other lawyers 19 will have some other questions as well You 20 understand that if you have any problem 21 understanding our question, you\'ll let us know 22 And you have to answer verbally and wait until 23 we\'re done and I\'ll try and wait until you\'re 24 done with your response before I ask the next 25 question Fair enough? HALL AND DEER (800) 321-3904 5 1 A Yes, sir 2 Q We have marked Exhibit No 23, which is a copy 3 of your curriculum vitae dated July 1, 1994; is 4 that correct? 5 A Yes, sir 6 Q Is that a current curriculum vitae? 7 A Reasonably so 8 Q Would there be any publications that might have 9 any relevance with regard to the medical issues 10 in this case which are not reflected on that 11 curriculum vitae? 12 A I don\'t think so 13 Q Would the same be true with regard to 14 presentations? Any events in your life which 15 might not be reflected on that curriculum vitae 16 which might have relevance to the medical issues 17 in this case? 18 A No 19 Q We\'re here because of a case entitled Bonfiglio 20 against St Mary\'s Hospital and some others 21 You understand that, correct? 22 A Yes 23 Q You\'ve testified in the past on behalf of 24 Mr Bloch as well as other members of his firm 25 at depositions, haven\'t you? HALL AND DEER (800) 321-3904 6 1 A Yes, sir 2 Q Do you know how many files you have reviewed for 3 Mr Bloch and/or his law firm? 4 A I would estimate about a dozen 5 Q When did you first have any contact with 6 Mr Bloch or other members of his firm? 7 A Probably early to mid-1980s 8 Q When did you first testify in a medical 9 negligence case on behalf of anyone, whether it 10 be for the physician, the patient? When did you 11 first become involved in this type of work? 12 A 1980, to my recollection 13 Q As of today, do you have an estimate as to the 14 number of cases you\'
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