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, MD, held at Children's Hospital,

13 Division of Neurosurgery, 34th Civic

14 Center Boulevard, Philadelphia, PA 19104,

15 commencing at 1:00 pm, 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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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, MD
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
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LUIS SCHUT, MD

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, MD, 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



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LUIS SCHUT, MD

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?



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LUIS SCHUT, MD

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?



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LUIS SCHUT, MD

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, MD

1 A