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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 1 0 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. 2 0 2 1 22 KRAUSS, KATZ ACKERMAN, INC. Legal Support Services 23 1880 John F. Kennedy Boulevard 15th Floor 24 Philadelphia, Pennsylvania 19103 (215) 988-9191 ORIGINAL KRAUSS, KATZ & ACKERMAN, INC. 2 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) 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 20 2 1 2 2 2 3 2 4 KRAUSS, KATZ ACKERMAN, INC. 3 2 I N D E X 3 WITNESS PAGE NO. 4 LUIS SCHUT, M.D. 5 By Mr. Berris 4 6 7 8 9 10 E X H I B I T S 11 NO. DESCRIPTION PAGE NO. 1 2 13 P-1 Eight-page document 94 1 4 1 8 1 9 2 0 2 1 2 2 2 3 2 4 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: 1 3 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. 5 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. 6 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. 7 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? KRAUSS, KATZ & ACKERMAN, INC. 8 LUIS SCHUT, M.D. 1 A
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