2
3
4
5
6
7
8
9
10
11
12
1 3
14
15
16
17
18
19
20
21
22
23
24
_ 25
~,ao~~3
IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY
H  LEE CHOW, et al ,
Plaintiffs,
Civil Action No  :
v 
139E6Z-V
HOLY CROSS HOSPITAL, et al ,
Defendants 
DEPOSITION OF STEVEN M  DONN, M D 
Taken at the Offices of Hall and Beer
215 East Washington, Ann Arbor, Michigan, on
October 15, 1996 commencing at or about
6 :40 p m 
APPEARANCES :
For the Plaintiff :
MR  BURT A  BLITZ
Glaser, Shandell & Blitz
150 Broadway, 14th Floor
New York, New York 10038
For the Defendants :
M5  DENISE A  CLARK
Wharton, Levin, Ehrmantraut,
Klein & Nash, P A 
104 West Street
Annapolis, Maryland 21404
REPORTED BY :
Tami I  Watters, CSR-3639
Certified Shorthand Reporter
HALL AND DEER
(800) 321-3904
: 
;,
z
1 I N D E X
2 WITNESS :
3 STEVEN M  DONN, M D  Page
4 Examination by Mr  Blitz 3
5
6
7
8
9 EXHIBITS :
10 None
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
HALL AND DEER
(800) 321-3904
3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Ann Arbor, Michigan
October 15, 1996
At or about 6 :40 p m 
S T E V E N M  D 0 N N, M  D 
Having first been duly sworn or affirmed by the
Notary Public, was examined and testified as
follows :
EXAMINATION
BY MR  BLITZ :
Good evening, Dr  Donn
Yes 
Good evening 
Hello 
My name is Burt Blitz 
this case 
Dr  Donn?
I represent baby Chow in
I\'m going to ask you certain questions
concerning the matter 
If there\'s anything you don\'t
understand, please tell me and I\'ll try my best
to reword the question 
First, Doctor, I was sent by fax today
your curriculum vitae  Are you familiar with
the one that was sent to me?
Yes, sir 
HA :L AND \'JEER
(800) 321-3904
4
1 Is that an updated CV?
2 It\'s not the most recent one 
3 What does the most recent one contain that this
4 one does not contain?
5 it contains publications, committee
6 appointments, book chapters, speaking
7 engagements, visiting professorships which all
8 took place between September 1st, 1995 and I
9 believe June 30th of 1996 
10 I ask you to -- would you please arrange or
11 through Miss Clark arrange to send me those
12 updated pages which I do not have?
13 I can send you a copy of the most recent vitae 
14 Would you please do that, sir?
15 It would be easier than trying to sort out of
16 additions  I will do so 
17 Okay  Thank you  Now, Doctor, you are a
18 neonatologist ; is that correct?
19 Yes, sir 
20 And would you please define what a neoaatologist
21 is, what a neonatologist does?
22 Which would you like first?
23 Oh, I didn\'t know there was a difference 
24 I Okay  What is a neonatologist?
25 (~ A neonatologist is a pediatrician with a
HALL AHD DEER
(809) 321-3904
5
1 subspecialty interest in training in the field
2 of neonatal perinatal medicine 
3 And what does a neonatologist primarily do
4 vis-a-vis his clinical work?
5 Neonatologist generally cares for newborns who
6 have some type of medical problem 
7 You say a newborn  Is a neonatologist\'s role as
8 a subspecialty in pediatrics confined to any
9 general period of life or time regarding the
14 neonate?
11 I think that\'s variable according to the
12 individual 
13 Well, give me an example of the average period
14 of time that you would care for a child who has
15 some specific problem -- a neonate with a
to specific problem  For how long? Five years of
17 I age?
18 I The neonatal period is technically defined as
19 the first 28 days of life  However, a more
20 practical working definition for a neonatologist
21 would be the period of time that an infant
22 remains in a neonatal intensive care unit which,
23 in some unfortunate instances, could be as long
24 II as a year or even year and a half, and even on
25 II rare instances, perhaps as long as two years 
!TALL AND DEER
(800) 321-3904
6
1 In addition, some neonatoloqists, such
2 as myself, remain involved in the follow-up care
3 of newborns for whom he or she has cared as a
4 neonate for various periods of time  That can
5 be through school age or even longer depending
6 upon the way a developmental assessment clinic
7 is set up or personal preference 
8 Doctor, are you also a pediatric neurologist?
9 No, I\'m not 
10 What is the difference between a pediatric
11 neurologist and a neonatoloqist?
12 The best way to describe the difference is that
13 if you look at the practice of neonatoloqy -- I
14 wish I had a graph in front of me, I could do
15 this more easily than on the telephone, but if
16 we graphed on the Y axis a child\'s age beginning
17 at zero and going up through eighteen or twenty
18 years, and if across the X axis we were to label
19 the various subspecialties of pediatrics such as
20 neonatology, pediatric neurology, pediatric
21 cardiology, pediatr