1
 1    IN THE STATE COURT OF FULTON COUNTY
                      STATE OF GEORGIA
 2   
 3   
    BRENDA CARROLL and JON       )
 4   CARROLL, Individually, and   )
    as parents, natural          )
 5   Guardians and next friends   )CIVIL ACTION
    of NOAH CARROLL, a minor     )
 6   child,                       )FILE NO 01VS020149C
                                 )
 7                 Plaintiffs,    )
                                 )
 8       vs                      )
                                 )
 9   NORTHSIDE HOSPITAL, INC,    )
    and NORTHSIDE HEALTH         )
10   SERVICES, INC, d/b/a        )
    NORTHSIDE HOSPITAL, JOHN     )
11   W DONNELLY, MD, ATLANTA   )
    WOMEN'S HEALTH GROUP,        )
12   PC, d/b/a NORTH ATLANTA    )
    WOMEN'S SPECIALISTS, and     )
13   SANDRA L JAWORSKI, RN,      )
                                 )
14                 Defendants    )
                                 )
15   
                       DEPOSITION OF
16   
                     AUDREY ARONA, MD
17   
                        June 8, 2005
18                        9:00 am
19                  230 Peachtree Street
                         Suite 2700
20                     Atlanta, Georgia
21             Maureen S Kreimer, CCR NO B1379
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 1                   APPEARANCES OF COUNSEL
 2   
 3   On behalf of the Plaintiffs:
 4        DAVID F WALBERT, Esq
         Parks, Chesin & Walbert, PC
 5        75 Fourteenth Street
         Suite 2600 The Grand
 6        Atlanta, Georgia 30309
 7   On behalf of the Defendant, John W Donnelly, M D,
    Atlanta Women's Health Group, PC, d/b/a North
 8   Atlanta Women's Specialists:
 9        THOMAS E LAVENDER III, Esq
         The Weathington Firm, PC
10        230 Peachtree Street NW
         Suite 2700
11        Atlanta, Georgia  30309
12   On behalf of the Defendant, Northside Hospital, Inc,
    and Northside Health Services, Inc, d/b/a Northside
13   Hospital:
14        SUSAN V SOMMERS, Esq
         Sommers, Scrudder & Bass, LLP
15        900 Circle 75 Parkway
         Suite 850
16        Atlanta, Georgia  30339-3084
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                                                                     3
 1              (Reporter disclosure made pursuant to
 2        Article 8B of the Rules and Regulations of the
 3        Board of Court Reporting of the Judicial Council
 4        of Georgia)
 5                   AUDREY J ARONA, MD,
 6   having been first duly sworn, was examined and
 7   testified as follows:
 8              MR WALBERT:  This is the deposition of
 9        Dr Audrey Arona taken pursuant to agreement of
10        counsel and probably a Notice of Deposition I
11        suspect was sent at one time, being taken for
12        all purposes allowed under the Civil Practice
13        Act, and specifically for the purpose of
14        discovery and cross-examination of Dr Arona who
15        has been identified on behalf of Dr Donnelly as
16        an expert witness who may testify on his behalf
17        in this case
18              And I would suggest that we reserve all
19        objections except as to form of question and
20        responsiveness of the answer until such time as
21        we may use the deposition, if that works for
22        you
23              MR LAVENDER:  That's agreeable
24              MR WALBERT:  Does the Doctor want to read
25        and sign, too?

                                                                     4
 1              MR LAVENDER:  Yes
 2              MR WALBERT:  Okay  Would you swear
 3        Dr Arona, please
 4                   AUDREY J ARONA, MD,
 5   having been first duly sworn, was examined and
 6   testified as follows:
 7                        EXAMINATION
 8   BY MR WALBERT:
 9        Q     Doctor, I know Mr Lavender here has told
10   you a little bit about the deposition, I'll just
11   briefly tell you a couple of things  I'll ask you a
12   bunch of questions here today  If I ask you anything
13   that is ambiguous to you, or unclear, don't feel
14   reluctant to stop me and ask me to clarify something
15   just so we're clearly communicating
16              Nods and shakes don't work because we're
17   taking it down, so if you would try and make a habit
18   of saying yes and no instead of nodding and shaking
19   your head, I would appreciate it
20              To the extent that you can answer yes or
21   no when I put it to you, if you need to explain it,
22   that's fine, and if you can't answer it yes or no,
23   that's fine, too, but if you can, I would appreciate
24   that first, all right?
25