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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
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