1(o878Z
1 State of Ohio,
) SS:
2 County of Cuyahoga.)

3

4 IN THE COURT OF COMMON PLEAS

5

6 THE ESTATE OF
DONALD SHOCK,
7
Plaintiff,
8
vs. Case No. 203,296
9
DILIP NARICHANIA, M.D.
10
Defendant.

12
DEPOSITION OF DAVID ROLLINS, M.D.
13 Wednesday, August 12, 1992

14 - - -

15 The deposition of DAVID ROLLINS, M.D., a

16 witness, called for examination by the Plaintiff

17 under the Ohio Rules of Civil Procedure, taken

18 before me, Diane M. Stevenson, a Registered

19 Professional Reporter and Notary Public in and

20 for the state of Ohio, by agreement of counsel,

21 at the offices of David Rollins, M.D., 26250

22 Euclid Avenue, Euclid, Ohio, commencing at 2:40

23 p.m., the day and date above set forth.

24 - - -

25

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

2

1 APPEARANCES:

2 On behalf of the Plaintiff:

3 R. Eric Kennedy, Esq.
Ben Antognoli, Esq.
4 Weisman, goldberg & Weisman Co., LPA
1600 Midland Building
5 Cleveland, Ohio 44115

6
On behalf of the Defendant Narichania, M.D.:
7
Robert Warner, Esq.
8 Reminger & Reminger Co., LPA
The 113 Building
9 Cleveland, Ohio 44114

10
On behalf of the Defendants Reich,
11 Seidelman & Janicki and Drs.  Williams,
Walter, Bernard and David:
12
Ellen H. Hirshman, Esq.
13 Jacobson, maynard, Tuschman & Kalur
1001 Lakeside Avenue - Suite 1600
14 Cleveland, Ohio 44114

15 - - -

16

1 7

1 8

19

2 0

21

2 2

2 3

2 4

2 5

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

3

1 DAVID ROLLINS, M.D.

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. Doctor, would you please state your full name.

9 A. David Rollins.

10 Q. And your professional address.

11 A. 26250 Euclid Avenue, in Euclid.

12 Q. Doctor, have you had your deposition taken

13 before?

1 4 A . Yes, sir.

15 Q. on how many occasions?

16 A. 8, 10, 12.

17 Q. If I ask you a question that is inarticulate for

is some reason--there may be a lot of reasons why it

19 might be--you are not sure you understand the

20 question, don't answer the question, and I will

21 attempt to rephrase it so that you do.

22 Can we agree that you will only answer the

23 questions that you certainly understand?

24 A. Yes.

25 Q. If you are not certain that you hear the

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

4

1 question, again, don't answer it. I will repeat

2 it so that, hopefully, you do understand it the

3 second time. Agreeable?

4 A. Agreeable.

5 Q. If at any time during the course of the

6 deposition you find or conclude that a prior

7 answer that you gave maybe wasn't complete or

8 wasn-t 100 percent accurate, and you want to

9 change the answer or supplement the answer, let

10 me know and we will go back and do that. Okay?

11 A. Fine.

12 Q. From reviewing your letter, would I be correct in

13 saying that you have concluded here that

14 Dr. Narichania met standards of appropriate care?

15 A . Yes, sir.

16 Q. Specifically, would it be your conclusion that

17 with respect to his decision not to come to the

18 hospital on the evening of the ist and into the

19 morning of the 2nd, that that met with standards

20 of appropriate care?

21 A. Yes, sir.

22 Q. And, further, would it be your opinion that he

23 met with standards of appropriate care in not

24 coming to the hospital on the morning of the 2nd,

25 say up until the noon hour?

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

5

1 A Yes, sir.

2 Q. Now, would I be correct in saying that probably

3 the key to this conclusion and this opinion of

4 yours in this case would be your understanding of

5 what was communicated to Dr. Narichania by

6 Dr. Williams, the house officer, at approximately

7 11:00 on the lst?

8 A. That's correct.

9 Q. Can you tell us what is your understanding of

10 what was communicated to Dr. Narichania by

11 Dr. Williams during their phone conversation at

12 approximately 11:00 on the ist?

13 A. From Dr. Narichariials perspective, he believed

14 that the patient had an acute abdominal problem

15 that was, most likely, an acute pancreatitis, or

16 an incarcerated umbilical hernia.

17 I would say that, from my reading of the

18 depositions, because that is the only place that

19 you get information, he would lean much stronger

20 toward acute pancreatitis, and he believed that

21 they needed to sort out the diagnosis at a later

22 time. He also believed that the patient at that

23 time was clinically stable.

24 I will also go ahead and add something

25 before you ask it. He, also, I don't believe at

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

6

1 any time entertained the notion that the patient

2 had an abdominal aortic aneurysm that was

3 rupturing; otherwise, he would have, I am sure,

4 come in.

5 Q. Now, in your conclusi