IN THE COURT OF COMMON PLEAS

2 STATE OF OHIO, COUNTY OF CUYAHOG17#Z


4 PATRICK TABANO, etc.,
et al.
5
V.

UNIVERSITY HOSPITALS
7 OF CLEVELAND, et al. NO. 270518


9 JANUARY 29, 1997

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11 Oral deposition of LUIS

12 SCHUT, M.D., held at Children's Hospital,

13 Division of Neurosurgery, 34th Civic

14 Center Boulevard, Philadelphia, PA 19104,

15 commencing at 1:00 p.m., on the above

16 date, before Kimberly S. Gordon, a

17 Registered Professional Reporter and a

18 Commissioner of the Commonwealth of

19 Pennsylvania.

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22 KRAUSS, KATZ ACKERMAN, INC.
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ORIGINAL

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1 A P P E A R A N C E S

2 WEISMAN, GOLDBERG & WEISMAN
BY: RICHARD J. BERRIS, ESQUIRE
3 1600 Midland Building
Cleveland, Ohio 44115
4 Counsel for the Plaintiffs

5 ARTER & HADDEN
BY: GEORGE MOSCARINO, ESQUIRE
6 1100 Huntingdon Building
925 Euclid Road
7 Cleveland, Ohio 44115
Counsel for University
8 Hospitals of Cleveland

9 JACOBSON, MAYNARD
BY: BARBARA JONES, ESQUIRE
10 1001 Lakeside Avenue, Suite 1600
Cleveland, Ohio 44114
11 Counsel for Dr. Mapstone
(via telephone)
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2 I N D E X
3 WITNESS PAGE NO.
4 LUIS SCHUT, M.D.
5 By Mr. Berris 4
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10 E X H I B I T S
11 NO. DESCRIPTION PAGE NO.
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13 P-1 Eight-page document 94
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KRAUSS, KATZ ACKERMAN, INC.
4
LUIS SCHUT, M.D.

1

2 (It is hereby stipulated

3 and agreed by and between counsel

4 that signing, sealing, filing and

5 certification are waived; and that

6 all objections, except as to the

7 form of questions, be reserved

8 until the time of trial.)

9

10 LUIS SCHUT, M.D., after

11 having been duly sworn, was

12 examined and testified as follows:

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14 EXAMINATION

1 S

16 BY MR.  BERRIS:

17 Q. State your full name,

1 8 please

19 A. I'm Dr. Luis Schut,

20 S-C-H-U-T.

21 Q. And your professional

22 address is here at Children's Hospital of

23 Philadelphia?

24 A. That's correct.



KRAUSS, KATZ & ACKERMAN, INC.

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LUIS SCHUT, M.D.

I Q. I have a copy of your CV, so

2 I'm not going to go into any great detail

3 about your background.

4 You are Board certified in

5 neurosurgery?

6 A. Correct.

7 Q. Do you have any other Board

8 certification other than in neurosurgery?

9 A. Pediatric neurosurgery.

10 Q. Are you Board certified in

11 pediatric neurosurgery?

12 A. That's correct.

13 Q. When were you Board

14 certified in pediatric neurosurgery?

is A. I think it's '91, but this

16 is a new Board just established.

17 Q. When did the Board become

18 available?

19 A. About 191, I guess.

20 Q- Is this not an updated CV

21 then that I have here because I've got --

22 this one lists American Board of

23 Neurologic Surgery but nothing about

24 pediatric neurosurgery?



KRAUSS, KATZ & ACKERMAN, INC.

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LUIS SCHUT, M.D.

I A. Probably is not up-to-date

2 then. It's not material. It does not

3 make a big difference.

4 Q. Do you have an updated CV;

5 is that your most recent CV?

6 A. I don't know. That's what

7 my secretary gave me. It doesn't say

8 here, no.

9 Q. It doesn't say pediatric

10 neurosurgery in there either?

11 A. No .

12 Q. You're telling me that you

13 were certified in 1991?

14 A. Go to my office and get it.

15 It's on top of my things, big diploma.

16 MR. MOSCARINO: You don't

17 want the diploma, do you?

18 MR. BERRIS: No.

19 BY MR. BERRIS:

20 Q. Is there an updated CV

21 though beyond the one you've got there?

22 A. I don't know. I don't do

2 3 that

24 Q. Who does your CV?



KRAUSS, KATZ & ACKERMAN, INC.

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LUIS SCHUT, M.D.

I MR. MOSCARINO: Do you want

2 this one?

3 MR. BERRIS: Apparently, I

4 don't know whether that's any

5 different than one.

6 MR. MOSCARINO: For the sake

7 of moving along, I'm giving you

8 that one which Dr. Schut gave, and

9 I will check with the secretary

10 afterwards. And if there is

11 another one that has that on

12 there, I'll get it to you. How's

1 3 t h a t ?

14 MR. BERRIS: That's fine.

15 BY MR. BERRIS:

16 Q. You're on the staff of two

17 hospitals, how many --

18 A. Several hospitals. I'm on

19 the staff of The University of

20 Pennsylvania, The Pennsylvania Hospital,

21 The AI DuPont Institute in Delaware and

2 2 here .

23 Q. And are you on the staff of

24 Children's Seashore House?



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LUIS SCHUT, M.D.

1 A