STATE OF OHIO (o@@5

UNTY OF CUYAHOGA
2 IN TH@EOCOURT OF COMMON ALEAS,

3 1
JOHN M WALKER, et al,
4
Plaintiffs,
5

6 Vs Case No 85118

7
KEUN LEE, MD, et al,
8
Defendants

10
DEPOSITION FOR PLAINTIFFS
11

12

13

14 The videotaped deposition of MARTIN J RAFF,

15 MD, taken pursuant to notice on behalf of the

16 Plaintiffs, before Patricia J Schneider, Notary

17 Public for the State of Kentucky at Large, in

18 accordance with the Ohio Rules of Civil Procedure,

19 at the offices of Weiss, Karp & Roseberry, 210

20 Morrissey Building, 304 West Liberty Street,

21 Louisville, Kentucky, on May 30, 1989, at 3:10

2 2 pm

2 3

24 CURTIN, SCHNEIDER & LAWREY
FIRST TRUST CENTRE, SUITE 500 NORTH
25 LOUISVILLE, KENTUCKY 40202
(502) 585-1076

1 Examination by Mr Kennedy 4

2 Examination by Mr Bonezzi 51

3 Examination by Mr McCrystal 66

4 Examination by Mr Kennedy  103

5 Examination by Mr McCrystal  112

6

7 DEFENDANTISDEPOSITION EXHIBITS

8 No 1 January 26, 1988 letter from Dr Raff
to Mr Kennedy 67
9
No 2 May 10, 1989 letter from Dr Raff to
10 Mr Kennedy 67

11 No 3 December 14, 1987 letter from Mr
Kennedy to Dr Raff 68
12
No 4 December 30, 1987 letter from Mr
13 Kennedy to Dr Raff 68

14 No 5 May 3, 1989 letter from Mr Kennedy
to Dr Raff 68
15

16

1 7

18

1 9

2 0

21

2 2

2 3

2 4

2 5

2


1 APPEARANCES:
R Eric Kennedy
2 Weisman, Goldberg, Weisman & Kaufman
Attorney for Plaintiffs
3 540 Leader Building
Cleveland, Ohio 44114
4
William D Bonezzi
5 Jacobson, Maynard, Tuschman & Kalur
Attorney for Defendants Lee and
6 Bullard
1301 East Ninth Street, Suite 1400
7 Cleveland, Ohio 44114-1824

8 James L McCrystal, Jr
Weston, Hurd, Fallon,
9 Paisley & Howley
Attorney for Defendant Euclid
10 General Hospital
25th Floor Terminal Tower
11 Cleveland, Ohio 44113

12 ALSO PRESENT: Lisa Crum, video operator

13

14

15

16 MR KENNEDY: Let the record reflect that

17 this is the deposition of Dr Martin Raff taken on

18 direct examination for the purpose of utilizing it

19 in lieu of live testimony at the trial of this

20 matter, that being Walker vs Euclid General, Dr

21 Lee, Dr Bullard, and that any defect in notice

22 would be waived, gentlemen?

23 MR BONEZZI: Correct

24 MR McCRYSTAL: Yes

25 MR KENNEDY: Can we also waive the filing

1 of the deposition and technical requirements with
2 respect to videotape depositions because of the
3 presence of the court reporter?
4 MR BONEZZI: Yes
5 MR McCRYSTAL: With regard to filing,
6 what are the technical requirements? You've still
7 got to comply with the civil rules
a MR KENNEDY: I'm talking about having a
9 counter at the bottom for time
10 MR McCRYSTAL: Date-time generator?
11 MR KENNEDY: Yeah
12 MR McCRYSTAL: The rules require it
13 MR KENNEDY: Do we have a date-time
14 generator here?
15 VIDEO OPERATOR: I can get the date and
16 the time on there
17 MR KENNEDY: Put that baby on there if
18 you would That's all I have with respect to
19 preliminary matters Anybody else?
2 0
21
2 2
23 MARTIN J RAFF, MD,
24 called upon oral examination by counsel for the
25 Plaintiffs, after having been first duly sworn,
4

1 was examined and deposed as follows:
2 EXAMINATION
3 BY MR KENNEDY:
4 Q- Doctor, my name is Eric Kennedy, and I
5 represent Mr and Mrs John Walker Could you
6 please state your name and professional address
7 for the record
8 A My name is Martin J Raff  My professional
9 address is University of Louisville School of
10 Medicine, Louisville, Kentucky
11 Q Doctor, have you been asked to review and
12 evaluate various medical records and depositions
13 of testimony with respect to the medical care and
14 treatment received by John Walker at Euclid
15 General Hospital?
16 A Yes, sir
17 Q Before we go into your review, Doctor, can
18 you tell us a little bit about your specialty in
19 the field of medicine
20 A I'm a general internist -- that is, internal
21 medicine -- with a subspecialty in infectious
22 diseases
23 Q And what is the study of infectious diseases
24 or the practice of infectious diseases?
25 A We deal with all situations in which patients
5
1 develop infections from whatever cause, and
2 predominantly do consultative work, so that we
3 provide recommendations for people about the
4 diagnosis, management, and results of infection
5 Q Does that bring you into contact with
6 antibiotics?
7 A Yes, sir, on a daily basis
8 Q Tell us about your education and training, if
9 you would
10 A How far back would you like me to go?
11 Q After college, please
12 A I did -- after college I did five years of
13 graduate work in medical microbiology, combining
14 my last year of graduate work with m