0001
    1   IN THE CIRCUIT COURT FOR KENT COUNTY
    2   MARYLAND
    3   -----------------------------------x
    4   WILLIAM E. COLE,
    5                        Plaintiff,
                                        Civil Action No.
    6             -against-              14-C-05-006502
    7   CHESTERTOWN NURSING CENTER,
        INC., d/b/a CHESTERTOWN
    8   NURSING AND REHABILITATION
        CENTER, et al.,
    9   
                             Defendants.
   10   
        -----------------------------------x
   11   
                             August 31, 2006
   12                        2:36 p.m.
   13      Deposition of RICHARD FRIEDLANDER, M.D, taken
   14   by Defendants, pursuant to notice, at 1056 Fifth
   15   Avenue, New York, New York, before SUZANNE
   16   PASTOR, a Shorthand Reporter and Notary Public
   17   within and for the State of New York.
   18   
   19   
   20   
   21   
   22   
 
                                                               0002
    1   A P P E A R A N C E S:
    2      ROBERT D. AHLSTROM, P.A.
           Attorneys for Plaintiff
    3             10320 Little Patuxent Parkway,
                  South 608
    4             Columbia, Maryland 21044
    5      BY:    ROBERT D. AHLSTROM  ESQ.
    6   
    7   
           WHITEFORD, TAYLOR & PRESTON LLP
    8      Attorneys for Chestertown Nursing
           Center, Inc.
    9             210 West Pennsylvania Avenue
                  Towson, Maryland 21204-4515
   10   
           BY:    DENA M. TERRA, ESQ.
   11             (Via Telephone)
   12   
   13      GOODELL, DeVRIES, LEECH & DANN, LLP
           Attorneys for Medical Staffing Network, Inc.
   14             One South Street
                  Baltimore, Maryland 21202
   15   
           BY:    RENEE N. SEWCHAND, ESQ.
   16   
   17   
   18   
   19   
   20   
   21   
   22   
 
                                                               0003
    1                RICHARD FRIEDLANDER, M.D,
    2   residing at 1056 Fifth Avenue, New York, New
    3   York, having been first duly sworn by the Notary
    4   Public (Suzanne Pastor), was examined and
    5   testified as follows:
    6   EXAMINATION CONDUCTED
    7   BY MS. TERRA:
    8         Q.     Good afternoon, Dr. Friedlander, my
    9   name is Dena Terra.  I represent Chestertown
   10   Nursing and Rehabilitation Center in this case.
   11                Have you had your deposition taken
   12   before?
   13         A.     Yes.
   14         Q.     So you know the ground rules that
   15   we need to be answering with verbal responses as
   16   opposed to head nods and mm-hmm and things of
   17   that nature.  Especially since we're on the
   18   telephone, is that fair?
   19         A.     I do understand, yes.
   20         Q.     And also, it's important that if
   21   you do not understand my question or you don't
   22   hear my question, please let me know, I'll be
 
                                                               0004
    1   happy to rephrase it.  If you answer the
    2   question, I'm going to assume that you
    3   understood it as asked.  Is that fair?
    4         A.     That is.
    5         Q.     And if you need to take a break,
    6   please let me know.
    7         A.     Certainly.
    8         Q.     Can you please state your name and
    9   professional address for the record.
   10         A.     Richard Paul Friedlander,
   11   F-R-I-E-D-L-A-N-D-E-R.  Address is 111-15 Queens
   12   Boulevard, Forest Hills, New York 11375.
   13         Q.     Is that your principal place of
   14   business or your only place of business?
   15         A.     It's the principal one, yes.
   16         Q.     Are you a solo practitioner or part
   17   of a practice?
   18         A.     Solo.
   19         Q.     How long have you been a solo
   20   practitioner?
   21         A.     My entire career.  Except for the
   22   three years that I spent with the pharmaceutical
 
                                                               0005
    1   industry.
    2         Q.     I have been provided with a copy of
    3   your curriculum vitae, and there is no date on
    4   it so I don't know if it's the most current CV.
    5         A.     Well, one easy way to find out, if
    6   we go to page 2, which is a continuation of
    7   hospital appointments, the last item should say
    8   attending cardiologist Parkway Hospital.
    9         Q.     That's what I have.
   10         A.     This pretty much should be up to
   11   date with the exception of one item missing from
   12   industrial experience.
   13         Q.     Okay, and what is that?
   14         A.     I'm currently licensed to perform
   15   medical exams for the F