State of Ohio,

2 County of Cuyahoga)

3
IN THE COURT OF COMMON PLEAS
4

5 KAREN PEDID, Executrix,
etc,
6
Plaintiff,
7 Case No 274,917
VS
8
KAISER FOUNDATION HEALTH
9 PLAN OF OHIO,

10
Defendant
11

12 DEPOSITION OF CHESTER L PLOTKIN, MD
Tuesday, August 22, 1995
13

1 4

15 The deposition of CHESTER L PLOTKIN, MD,

16 a witness, called for examination by the

17 Plaintiff under the Ohio Rules of Civil

18 Procedure, taken before me, Diane M Stevenson, a

19 Registered Professional Reporter and Notary

20 Public in and for the state of Ohio, by agreement

21 of counsel, at the offices of Chester L Plotkin,

22 MD, 1611 South Green Road, South Euclid, Ohio,

23 commencing at 3:10 pm, the day and date above

24 set forth

25 - - -



Diane M Stevenson, RPR, CM
Morse, Gantverq & Hodge

2

1 APPEARANCES:

2 On behalf of the Plaintiff:

3 R Eric Kennedy, Esq
Marilena Lencewicz
4 David Landever
Weisman, Goldberg & Weisman Co, LPA
5 1600 Midland Building
Cleveland, Ohio 44115
6

7 On behalf of the Defendants:

8 Ezio A LiBtati, Esq
Porter, Wright, Morris & Arthur
9 1700 Huntington Building
Cleveland, Ohio 44115
10

11

12

13

14

1 5

1 6

17

18

1 9

2 0

21

2 2

2 3

2 4

2 5


Diane M Stevenson, RPR, CM
Morse, Gantverg & Hodge

3

1 CHESTER L PLOTKIN, MD

2 A witness, called for examination by the

3 Plaintiff, under the Rules, having been first

4 duly sworn, as hereinafter certified, was

5 examined and testified as follows:

6 CROSS-EXAMINATION

7 BY MR KENNEDY:

8 Q Would you please state your full name

9 A My name is Chester Lawrence Plotkin, P L 0 T K I N

10 Q Your professional address?

11 A 1611 Green Road, South Euclid, 44121

12 Q You have been asked by attorneys for Kaiser to

13 review and evaluate a medical record in the care

14 and treatment rendered to Mrs Bush?

15 A Yes, I have

16 Q Can you tell me what you reviewed -- have you

17 arrived at opinions with respect to that chart?

18 A Yes

19 Q Can you tell me what you reviewed to arrive at

20 those opinions?

21 A I reviewed the hospital records, the outpatient

22 records of Kaiser, the depositions on Dr Darr,

23 Dr Abernethy, Dr Jandi, and the expert

24 witnesses' statements

25 Q What expert witnesses?


Diane M Stevenson, RPR, CM
Morse, Gantverg & Hodge

4

1 A Dr Conomy and Dr Antos

2 Q Do you know Dr Conomy?

3 A Yes

4 Q Have you worked with him at any time?

5 A Yes

6 Q Are you familiar with his reputation in the

7 community?

8 A Yes

9 Q Would you consider him to be a qualified and

10 competent physician in the specialty of

11 neurology?

12 A Yes, I would

13 Q Have you reviewed any medical literature relating

14 to your opinions in this case?

15 A No

16 Q Is your practice confined to that of internal

17 medicine?

18 A Yes

19 Q With respect to the hospital -- let's first talk

20 about office charts I am assuming you keep

21 office charts in relation to your patients; is

22 that correct?

23 A Yes

24 Q What would be your practice with respect to what

25 is recorded in your office chart?


Diane M Stevenson, RPR, CM
Morse, Gantverg & Hodge

1 A I don't understand your question

2 Q Is it your practice to record all significant

3 positive findings with respect to your patients

4 when they visit your office?

5 A Yes

6 Q Would that be standard practice in the medical

7 community to report all or to record all

8 significant positive findings?

9 A Yes

10 Q And that relates not only to history, but to

11 physical examination; is that true?

12 A Yes

13 Q Would it be your practice to also record in your

14 office chart all significant negative findings?

15 A If it relates to the problem, yes

16 Q And would that, again, be a standard practice

17 within this community?

18 A Yes

19 Q Have you taught at all?

20 A Yes

21 Q Is that something that you teach your medical

22 students or residents or interns, to record

23 significant positive and negatives in office

24 charts?

25 A Yes


Diane M Stevenson, RPR, CM
Morse, Gantverg & Hodge

6

1 Q Now, with respect to the office chart that you

2 keep, say, on your patients in your office, you

3 keep that office chart, would I be correct that

4 you keep that so that you have an understanding

5 and a reference with respect to the patient's

6 condition prior to, say, the present visit? Is

7 that one of the reasons that you keep an office

8 chart?

9 A Do you mean would we normally take a past history

10 on a patient?

11 Q No, I am not saying absent a pasthistory I am

12 saying one of the reasons you keep an office