2-7-
1 State of Ohio,
2 County of Cuyahoga.
3 - - -

4 IN THE COURT OF COMMON PLEAS
5 - - -

6 MARGARET E. MARTIN, et al.,
7 Plaintiffs,
8 V. Case No. 88-142665
9 STEVEN A. LAMB, M.D., et al.,
10 Defendants.

12 DEPOSITION OF MARTIN I. RESNICK, M.D.
13 WEDNESDAY, AUGUST 22, 1989
1 4 - - -

15 The deposition of Martin I. Resnick, M.D., a
16 witness, called for examination by the Plaintiff,
17 under Ohio Rules of Civil Procedure, taken before
18 me, Kathryn A. Keeler, a Registered Professional
19 Reporter and Notary Public within and for the State
20 of Ohio, pursuant to agreement, at University
21 Hospitals of Cleveland, Lakeside Building,
22 Cleveland, Ohio, commencing at 2:00 a.m., the day
23 and date above set forth.
2 4 - - -

2 5
1 APPEARANCES:

2 On behalf of the Plaintiff:

3 R. ERIC KENNEDY, ESQ.
Weisman, Goldberg, Weisman & Kaufman
4 540 Leader Building
Cleveland, Ohio 44114
5
On behalf of the Defendant:
6
JOHN IRWIN, M.D., ESQ.
7 Reminger & Reminger
The 113 Building
8 Cleveland, Ohio 44114

9 - - -

1 0

1 1

1 2

1 3

1 4

1 5

1 6

1 7

1 8

1 9

2 0

2 1

2 2

2 3

2 4

2 5

3

1 MARTIN I. RESNICK, M.D.
2 a witness, called for examination by the Plaintiff,
3 under the Rules, having been first duly sworn was
4 examined and testified as follows:
5 CROSS-EXAMINATION
6 BY MR. KENNEDY:
7 Q. Doctor, my name is Eric Kennedy, and I
8 represent Margaret Martin in a case which is brought
9 against Dr. Lamb.
10 Have you had your deposition taken before?
11 A. Yes, I have.
12 Q. As in other depositions, it is important that
13 you answer everything verbally, so that the court
14 reporter can take down your answers accurately.
1 5 A . Yes .
16 Q. Also, I think that we will all agree that we
17 don't want you to answer any questions unless you
18 are certain that you understand the question, is
19 that agreeable?
20 A. That is agreeable.
21 Q_ Now, you have been retained by Dr. Irwin and
22 Reminger & Reminger to review various records?
23 A. That's correct.
24 Q. Can you tell me what records you reviewed
25 prior to rendering your report dated August 14,
4

1 1 9 8 9 ?
2 A. The records I reviewed were medical care of
3 Margaret Martin. Deposition transcript of Dr. Lamb,
4 deposition transcript of Richard Martin, deposition
5 transcript of Margaret Martin, Dr. Lamb's office
6 records, a letter from Eric Kennedy dated July 14,
7 1988, curriculum vitae of Dr. Lamb, medical records
8 from Margaret Martin.
9 Q. Can I see the -- did you review any summaries
10 of records or care or summaries of deposition
11 prepared by someone at Reminger & Reminger?
12 A. I don't believe so.
13 Q. Did you take any notes or create any rough
14 drafts or anything else with respect to this case?
15 A. No. Just the letter that you have.
16 Q. Do you have a curriculum vitae that we could
17 get at some other point in time?
18 A. Yes. My secretary is out to lunch.
19 Q- Could you include with that a bibliography of
20 your writings?
2 1 A . Yes .
22 Q. Is that up to date, the bibliography?
23 A. Yes, it is.
24 Q. Doctor, are there any textbooks of urology
25 that we could look to as being reliable and
5

1 authoritative textbooks?
2 A. Well, I think there are a variety of
3 textbooks that are around, whether you want to say
4 they are authoritative is really questionable. I
5 think the field is changing, the opinions are
6 changing and textbooks are the opinions of the
7 individuals who are writing them.
8 Q. Has the approach and the technique utilized
9 in the Stamey procedure changed in the last ten
10 years?
11 A. Yes. It has changed.
12 Q. Can you tell me how it has changed in the
13 last ten years?
14 A. Initially, the procedure was described as
15 placing sutures in the periureth -- excuse me, the
16 use of dacron pledgets that we use to help support
17 the bladder, that has evolved to the placement of
18 sutures in the periurethral fascia, also, now, to
19 the elimination of sutures in the periurethral
20 fascia, the perivaginal fascia.
21 Q- Why has the location of the sutures been
22 changed?
23 A. It is not necessarily location as much as how
24 the sutures are applied.
25 Why has there been that change?
6

1 A. Personal preference for individuals. Ease of
2 the operation, a variety of reasons.
3 Q- Other than that change, have there been other
4 changes in the last ten years in the performance of
5 the Stamey procedure?
6 A . Yes .
7 Q. What are those?
8 A. There are needles that have been redesigned
9 from his original description of needles, dacron
10 pledgets, which Stamey originally was described as
11 using in the vaginal area have also been used in the
12 rectus fascia, different types of material used by
13 different individuals.
14 Q. What textbooks would you describe as reliable
15 textbooks in the field of urology?
16 A. I think the standard source textbook is
17 Campbell's urology, there is also a textbook that
18 has been authored by a number of individuals, the
1