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 2      SUPERIOR COURT OF THE STATE OF NEW JERSEY
 3            LAW DIVISION MIDDLESEX COUNTY
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 5   GERALD NICHOLAS PACE and MARY  )
     PACE, h/w,                     )
 6                                  )
                      Plaintiff,    )
 7                                  )
                 vs.                )MID-L-009537-
 8                                  )02 MT
                                    )Case Code 264
 9   AMERICAN HOME PRODUCTS         )
     CORPORATION, et al,            )
10                                  )
                      Defendants.   )
11   -------------------------------)
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14            DEPOSITION OF DR. GORDON SZE
15                 New York, New York
16            Wednesday, December 29, 2004
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24   Reported by:
     Jeremy Frank, MPM
25   JOB NO. 168422
0002
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 3                           December 29, 2004
 4                           1:45 p.m.
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 6         Deposition of DR. GORDON SZE, held at 
 7   the offices of Porzio Bromberg & Newman, P.C., 
 8   156 West 56th Street, New York, New York, 
 9   pursuant to Notice, before Jeremy Frank, 
10   a Notary Public of the State of New York. 
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0003
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 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.
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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.
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0004
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 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 afternoon, Dr. Sze.
 9         A.    Good afternoon.
10         Q.    We are now on the Pace case.
11         A.    Right.
12               (Sze Exhibits 1 and 2, premarked, 
13         for identification.)
14         Q.    And let me ask real quick 
15   questions, hopefully we can get cleared away 
16   and things will move on pretty quickly. 
17               Is it your opinion, Mr. Pace, 
18   based on your review of the medical records 
19   and films that you have been provided, 
20   suffered a medial occipital lobe hemorrhage?
21         A.    Yes. 
22         Q.    Other than the medial occipital 
23   lobe, you don't describe any other structures 
24   that are involved in this hemorrhage, correct?
25         A.    Well, of course in my report of 
0006
 1                        Sze
 2   November 9th, 2004, I do describe other areas 
 3   that perhaps are not quite so medial, but 
 4   basically in the occipital lobe.
 5         Q.    Other than the occipital lobe, 
 6   there are no other structures involved at 
 7   least according to your review of the films, 
 8   correct?
 9         A.    Right.  Keep in mind that the 
10   division between the occipital and parietal is 
11   not one that is easily seen radiologically 
12   always.
13         Q.    We can agree that Mr. Pace 
14   suffered was a low bar hemorrhage, correct?
15         A.    Yes.
16         Q.    Now during the Robinson deposition 
17   we talked about your method of interpreting 
18   these films and giving your reports in these 
19   particular cases.
20               And did I understand you to say 
21   that the way that you reviewed them, you 
22   looked at them, you compared them with medical 
23   records, you go back and look at films again 
24   and keep comparing and contrasting the dates 
25   that you get?
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