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RICHLAND COUNTY, OHIO 21 Carolyn Rucker Daugherty, et al., 4 Plaintiffs, 5 vs. No. 34-506-C 61 Richard C. Harris, M.D., 7 et al., 11 Defendants. 91 10 11@ Deposition of DR. HOWARD TUCKER, taken on 12@ cross-examination before William J. Mahan, Registered 13 Professional Reporter and Notary Public within and 14 for the state of Ohio, at the offices of Dr. Howard 15 Tucker, Suite 326, Mt. Sinai Medical Building, 26900 16 edar Road, Beachwood, Ohio, 44122, at 2:00 p.m., 17 Wednesday, April 16, 1986, pursuant to notice and/or C 18 stipulations of counsel, by the defendants in this 19 cause. 20 - - - - 21 22 23 24 25 2 I APPEARANCES: 2 David J. Elk, Esq. Bond Court Building 3 Cleveland, Ohio 44114 4 on behalf of the Plaintiffs; Peter P. Zawaly, Jr., Esq. Jacobson, Maynard, Tuschman & Kalur 6 175 South Third Street Columbus, Ohio 7@ (614) 224-1323 8@ on behalf of the defendants. 91 - - - - 101 DR. HOWARD TUCKER, called by the defendants for the purpose of 12 cross-examination, as provided by the 131 Ohio Rules of Civil Procedure, having 14 been first duly sworn, as hereinafter 15 certified, deposed and said as follows: 16 CROSS-EXAMINATION OF DR. HOWARD TUCKER 11 BY MR. ZAWALY: I 18 MR. ZAWALY: Let the 19 record show that we are here this afternoon and we are going to take this 20 21 deposition upon cross-examination in the 22 case of Carolyn Rucker Daugherty versus 23 Drs. Harris, Shook, Kautz, Baddour 24 and a CRNA by the name of Ruth Friel. I will be asking you these 25 3 questions as if on cross-examination. 2 Doctor, I will ask that vou 3 make all of your responses to my questions 4 verbally to aid the Court Reporter in 5 recording your responses. If you don't 6 understand any questions I ask you, let me know and we will attempt to make sure that there is an understanding because it 91 is extremely important in order for me to 101 discover the facts that I am here to 11 discover today. 12 A. Can I ask you a question? 13 Yes. 14 You gave me the initials after someone's name 15 that I am not familiar with. What was that? 16 Cl That is Ruth Friel, a CRNA, Certified Registered 17 Nurse Anesthetist. 18 A. okay. 19 (I You never heard of that before? 20 A. I have of course heard of Registered Nurses, but 21 I never heard of that before. 22 QL Doctor, would you please state your full name 23 for the record? 24 A. Howard Tucker. 25 Q- Are you a medical doctor? 4 A. Yes, I'm a medical doctor. QL when did you become a medical doctor? 3 A. 19 4 7 . 41 QL You graduated from what medical school? 5 A. Ohio State. 6 QL And did you do any internship at that time? A. I had a rotating internship. where was that? IL in Cleveland at Mt. Sinai Hospital. U Do you have a Curriculum Vitae? A. Not with me. 12 Could you supply one to your attorney? 13 A. Surely. 14 @1 or you can forward that to me. 15 A. Sure. 16 (I Have you prepared for this deposition today, 17 doctor? 18 IL Yes. 19 ti when did you prepare for it? 20 A. Last night. This morning. 21 How much time did you spend last night preparing 22 for it? 23 About two hours. And about two hours today. 24 QL what did that preparation entail last night for 25 two hours? 5 Reviewing a few records that were submitted. 2@ And also some textbooks that I had on the 3 subject. 4 Q@ Could you name those textbooks? A. Yes, I looked in Merrit's Textbook. And I looked in Victor and Adams. Adams and Victor is the 7 correct name. Those are the authors, Merrit and Victor and Adams. 91 Q. Can you give me the names of the books? 101 A. one is called Neurology by Merrit and it is edited 11 by Rowe. 121 The other one is called Clinical Neurology 13 by Adams and Victor. 14 Did you make reference to those books or refer to 15 them during the course of your preparation for 161 this deposition because you consider them to be 17 authoritative? A. No, it was just to.refresh my mind on general 19 principles. 20 QL Do you consider any of these textbooks in the 21 area of expertise that you are going to be 22 testifying in this afternoon to be authoritative? 23 A. No single authority, no. 24 Which books do you rely upon most in your practice 25 of medicine with regard to the issues that are 6 1@ raised in this lawsuit? 9 A. I can't answer that. I don't know. 3 By now, as you can gather, I have been 41 out of medical college since 1947 and I I-Lave 5 gained considerable experience of my own. 6@ OL So you rely a lot upon
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