1
 1   IN THE COURT OF COMMON PLEAS
                HAMILTON COUNTY, OHIO
 2   
 3   KENNEDI I. DODDS, a minor,
    by her Guardian
 4   PAUL HACKETT, ESQUIRE
 5   and
 6   KENNYATTA A. DODDS
    and WILLIAM WALLACE,
 7   parents and next friends of
    KENNEDI I. DODDS, a minor,
 8   INDIVIDUALLY,
                Plaintiffs,
 9   
           vs.       CASE NO. A0307777
10   
    ISRAEL T. WASHINGTON, M.D.,
11   et al.,
                Defendants.
12   
13   
14   DEPOSITION OF:   JANICE LAGE, M.D.
15   DATE:            May 17, 2005
16   TIME:            10:06 a.m.
17   
    LOCATION:        Medical University of
18                    South Carolina
                     165 Ashley Avenue
19                    Charleston, SC
20   TAKEN BY:        Counsel for the Plaintiff
21   REPORTED BY:     CAROL DENISE JAMES,
                     Registered Professional
22                    Reporter, CP
23   
24   
25   

                                                                     2
 1         APPEARANCES OF COUNSEL:
 2          ATTORNEYS FOR THE PLAINTIFF
                KENNEDI I. DODDS, a minor, by her
 3               Guardian PAUL HACKETT, ESQUIRE
                and KENNYATTA A. DODDS and
 4               WILLIAM WALLACE, parents and next
                friends of KENNEDI I. DODDS, a minor,
 5               INDIVIDUALLY:
 6               GERSHON, WILLOUGHBY, GETZ & SMITH
                BY:  ZEV GERSHON
 7               (APPEARING BY SPEAKERPHONE)
                10 Crossroads Drive
 8               McDonogh Crossroads, Suite 203
                Owings Mills, MD  21117
 9               (443) 394-8800
10          ATTORNEYS FOR THE DEFENDANT
                ISRAEL T. WASHINGTON, M.D.:
11   
                REMINGER & REMINGER
12               BY:  BRIAN D. GOLDWASSER
                (APPEARING BY SPEAKERPHONE)
13               7 West 7th Street, Suite 1990
                Cincinnati, OH  45202
14               (513) 721-1311
15          ATTORNEYS FOR THE DEFENDANT
                THE CHRIST HOSPITAL:
16   
                KOHNEN & PATTON, LLP
17               BY:  BRIAN E. McNAIR
                PNC CENTER SUITE 800
18               201 East 5th Street
                Cincinnati, OH  45202
19               (513) 381-0656
20          (INDEX AT REAR OF TRANSCRIPT)
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                                                                     3
 1                   STIPULATION
 2               It is stipulated by and among Counsel
 3   that this deposition is being taken in accordance
 4   with the Federal Rules of Civil Procedure; that all
 5   objections as to Notice of this deposition are
 6   hereby waived; that all objections except as to
 7   form are reserved until the time of trial; and that
 8   the witness waives reading and signing of this
 9   deposition.
10   *    *    *    *    *    *    *    *    *    *
11                  JANICE M. LAGE, M.D.,
12   being first duly sworn, testified as follows:
13                       EXAMINATION
14   BY MR. GERSHON:
15          Q.   Doctor, can you give us your name and
16   address for the record, please?
17          A.   Yes.  Janice Marie Lage, L-A-G-E, my
18   address is 165 Ashley Avenue, Charleston, South
19   Carolina.
20          Q.   Dr. Lage, as you know, my name is Zev
21   Gershon.  I'm one of the attorneys for the
22   Plaintiffs in this case.  I'm going to be asking
23   you a series of questions.  If at any time you do
24   not understand one of my questions, please tell me
25   so or ask me to rephrase it.  If you do answer,

                                                                     4
 1   though, I will assume you understood the question
 2   and I will hold you to your answer. Do you
 3   understand?
 4          A.   Yes, sir.
 5          Q.   Great.  Can you please list for me the
 6   materials you reviewed in connection with this
 7   case?
 8          A.   Yes.  I looked at the placental
 9   pathology slides and the pathology report -- do you
10   want the numbers or just -- is that sufficient?
11          Q.   That will be fine.  How many slides
12   were there?
13          A.   There are six slides.
14          Q.   Okay.
15          A.   And I looked at a set of medical
16   records from the mom's prenatal care, labor and
17   delivery, and I believe an admit and discharge
18   summary from the baby -- the live baby; and I have
19   seen Cynthia Kaplan's report; I've seen a
20   photograph of a stillborn baby and --
21          Q.   Right.
22          A.   I'm trying to think.  I don't think
23   there's anything else.  I haven't seen any
24   depositions.
25          Q.   Okay.  Have you looked at any other

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 1   materials in connec