0001
 1   
 2      SUPERIOR COURT OF THE STATE OF NEW JERSEY
 3            LAW DIVISION MIDDLESEX COUNTY
 4                          
 5   DEBRA ROBINSON,                )
                                    )
 6                    Plaintiff,    )
                                    )
 7               vs.                )
                                    )
 8   AMERICAN HOME PRODUCTS         )
     CORPORATION, et al,            )
 9                                  )
                      Defendants.   )
10   -------------------------------)
11   
12   
13            DEPOSITION OF DR. GORDON SZE
14                 New York, New York
15            Wednesday, December 29, 2004
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23   Reported by:
     Jeremy Frank, MPM
24   JOB NO. 168422
25   
0002
 1   
 2                           December 29, 2004
 3                           11:05 a.m.
 4   
 5         Deposition of DR. GORDON SZE, held at 
 6   the offices of Porzio Bromberg & Newman, P.C., 
 7   156 West 56th Street, New York, New York, 
 8   pursuant to Notice, before Jeremy Frank, 
 9   a Notary Public of the State of New York. 
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0003
 1   
 2   A P P E A R A N C E S:
 3   
 4         WILLIAMS CUKER BEREZOFSKY, ESQS.
 5         Attorneys for Plaintiff
 6               210 Lake Drive East
 7               Suite 210
 8               Cherry Hill, NJ 08002
 9         BY:   KEVIN HAVERTY, ESQ.
10   
11         PORZIO BROMBERG & NEWMAN, PC
12         Attorneys for Defendants
13               156 West 56th Street
14               New York, NY 10019
15         BY:   FRANK FAZIO, ESQ.
16   
17         NELSON MULLINS RILEY & SCARBOROUGH, LLP
18         Attorneys for Defendants
19               Liberty Center
20               151 Meeting Street
21               Charleston, SC 29401
22         BY:   JANE THOMPSON DAVIS, ESQ.
23   
24         
25   
0004
 1   
 2         IT IS HEREBY STIPULATED AND AGREED,
 3   by and between counsel for the respective 
 4   parties hereto, that the filing, sealing and
 5   certification of the within deposition shall
 6   be and the same are hereby waived;
 7         IT IS FURTHER STIPULATED AND AGREED 
 8   that all objections, except as to the form 
 9   of the question, shall be reserved to the 
10   time of the trial;
11         IT IS FURTHER STIPULATED AND AGREED 
12   that the within deposition may be signed  
13   before any Notary Public with the same force
14   and effect as if signed and sworn to before
15   the Court.
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0005
 1                        Sze
 2   D R.  G O R D O N  S Z E,   called as a  
 3         witness, having been duly sworn by a 
 4         Notary Public, was examined and 
 5         testified as follows:
 6   EXAMINATION BY
 7   MR. HAVERTY:
 8         Q.    Good morning, Dr. Sze.  We are 
 9   finally underway here.  As you know my name is 
10   Kevin Haverty, we have met before the 
11   deposition and I represent the plaintiff, 
12   Debra Robinson in this matter. 
13         A.    Yes.
14         Q.    And you wrote a report giving 
15   expert opinions concerning interpretations of 
16   her radiographic films, and I just want to 
17   take your deposition concerning those findings 
18   and your interpretations. 
19         A.    Yes.
20               (Sze Exhibit 1, premarked, for 
21         identification.)
22         Q.    And you have been deposed a 
23   number of times in these PPA cases?
24         A.    Right.
25         Q.    There is no reason for me to 
0006
 1                        Sze
 2   repeat the instructions that go with these 
 3   depositions?
 4         A.    Only if you want to.
 5         Q.    You're pretty familiar with the 
 6   way these things work?
 7         A.    Yes.
 8         Q.    Let me show you what we had marked 
 9   as Sze 1, a copy of your CV which is attached 
10   to your report dated April 22, 2004. 
11         A.    Yes.
12         Q.    And can you review that and tell 
13   me whether that's up-to-date, current, and if 
14   it is accurate?
15         A.    It is not a totally current copy.  
16   And obviously it was e-mailed to you since the 
17   pagination is terrible.  But it is not so far 
18   out of date that anything that would be added 
19   would be particularly relevant to this case.
20         Q.    Are there additional publications 
21   that you have had since this CV was prepared?
22         A.    Yes.
23         Q.    What else have you published since 
24   this CV?
25         A.    I believe there was one paper on 
0007
 1                        Sze
 2   amyloid angiography, and I think there was one 
 3   paper on new techniques in spinal MR imaging. 
 4   And there ha