0001
 1          COMMONWEALTH OF PENNSYLVANIA
            BUREAU OF LABOR AND INDUSTRY
 2      DEPARTMENT OF WORKERS' COMPENSATION
                       - - -
 3   MATTHEW HUTTER       : 
             CLAIMANT     :  
 4          v.            :  194-50-3356       
     UPPER DUBLIN TOWNSHIP:
 5           DEFENDANT    :
 6                     - - -
                   AUGUST 7, 2002
 7                     - - -
 8   
 9                Oral deposition of DAVID 
10   CLEMENTS, M.D., taken pursuant to notice, 
11   was held at the office of David Clements, 
12   M.D., at the Jeanes-Temple Medical 
13   Building, Suite 101, 9331 Old Bustleton 
14   Avenue, Philadelphia, Pennsylvania 19115, 
15   commencing at 5:10 p.m. on the above 
16   date, before Stanley D. Krevitz, Jr., a 
17   court reporter and notary public in the 
18   Commonwealth of Pennsylvania.
19   
20                                                   
21                     - - -
22          ESQUIRE DEPOSITION SERVICES
           1880 John F. Kennedy Boulevard
23                   15th Floor
          Philadelphia, Pennsylvania 19103
24                 (215) 988-9191
0002
 1   APPEARANCES:
 2          CHRISTINA J. BARBIERI & ASSOCIATES
            BY: CHRISTINA J. BARBIERI, ESQUIRE
 3          1518 Walnut Street
            13th Floor
 4          Philadelphia, Pennsylvania 19102
            (215) 772-3020
 5          Representing the Claimant
 6   
 7   
 8          TIMONEY, KNOX, HASSON & WEAND
            BY:  KARL COOPER, ESQUIRE
 9          400 Maryland Drive
            P.O. Box 7544
10          Fort Washington, PA 19034
            (215) 646-6000
11          Representing the Defendant
12          
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0003
 1                        
                       - - -
 2                   I N D E X
                       - - -
 3   
     WITNESS:                          PAGE
 4   
     DAVID CLEMENTS, M.D.
 5   
 6   VOIR DIRE TESTIMONY:
 7       By Mr. Cooper:                 6
 8      
     TESTIMONY:
 9   
         By Mr. Cooper:                  8, 22
10   
         By Ms. Barbieri:                18
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                       - - -
15                E X H I B I T S
                       - - -
16   
     NO.          DESCRIPTION             PAGE
17   
     Clements-1   Curriculum Vitae         5     
18   
     Clements-2   Physician's Affidavit    5       
19                of Recovery
20   
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0004
 1   
                       - - -
 2            DEPOSITION SUPPORT INDEX
 3                     - - -
 4   
 5   Direction to Witness Not to Answer
 6   Page Line    Page Line     Page Line
 7    None
 8   
 9   
10   Request for Production of Documents
11   Page Line    Page Line     Page Line
12    None
13   
14   
15   Stipulations
16   Page Line    Page Line     Page Line
17    None
18   
19   
20   Question Marked
21   Page Line    Page Line     Page Line
22    None
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0005
 1                     - - -
 2                (Clements-1 and Clements-2 
 3          were marked for identification.) 
 4                     - - -
 5                DAVID CLEMENTS, M.D., after 
 6          having been duly sworn, was 
 7          examined and testified as follows: 
 8                     - - -
 9                MR. COOPER:  Good afternoon.  
10          My name is Karl Cooper.  We're 
11          here in the offices of Dr. David 
12          Clements for his deposition 
13          testimony in the case of Matthew 
14          Hutter versus Upper Dublin 
15          Township.  Dr. Clements is 
16          testifying here at this deposition 
17          in lieu of his live appearance in 
18          front of the Judge.  Therefore, I 
19          would ask that all objections be 
20          placed on the record, the doctor 
21          to answer over the objection, and 
22          the Judge will rule on the 
23          objection later provided it is 
24          preserved in accordance with the 
0006
 1          Rules and Regulations.  Is that 
 2          acceptable?
 3                MS. BARBIERI:  Yes. 
 4                     - - -
 5                  EXAMINATION
 6                     - - -
 7   BY MR. COOPER:
 8          Q.    Doctor, I'm going show you a 
 9   copy of what's already been marked as 
10   Clements-1 and ask you if you recognize 
11   that (indicating).
12          A.    Yes, it's my Curriculum 
13   Vitae.
14          Q.    And is that accurate and up 
15   to date?
16          A.    Yes.
17          Q.    Doctor, if you could just 
18   briefly describe your educational and 
19   clinical background for the Judge?
20          A.    I graduated from Temple 
21   University School of Medicine in 1982.  I 
22   complet