(An original PDF copy of this transcript is available)
Dr. Dennis Foster 2/5/2010 1
1 IN THE DISTRICT COURT OF CARTER COUNTY
2 STATE OF OKLAHOMA
3 EDYTHE KEETON,
4 Plaintiff,
5 vs. No. CJ-2009-139
6 YOUNG MENS CHRISTIAN
ASSOCIATION OF ARDMORE,
7
Defendant.
8
9
DEPOSITION OF DENNIS FOSTER, M.D.
10 TAKEN ON BEHALF OF THE PLAINTIFF
ON FEBRUARY 5, 2010, BEGINNING AT 12:30 P.M.
11 IN OKLAHOMA CITY, OKLAHOMA
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APPEARANCES
14
On behalf of the PLAINTIFF:
15
Scott Gallagher
16 Wallace Coppedge
LITTLE, LITTLE, LITTLE, WINDEL, COPPEDGE, OLIVER
17 & GALLAGHER
One West Main Street
18 Ardmore, Oklahoma 73401
(580)224-0900
19 scott@ardmorelaw.com
20 On behalf of the DEFENDANT:
21 Perry E. Kaufman
GOOLSBY, PROCTOR, HEEFNER & GIBBS
22 701 North Broadway, Suite 400
Oklahoma City, Oklahoma 73102
23 (405)524-2400
pkaufman@gphglaw.com
24
25 Reported by: Lana L. Phillips, CSR, RPR
Dr. Dennis Foster 2/5/2010 2
1 CONTENTS
2 DIRECT EXAMINATION BY MR. GALLAGHER 3
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4 STIPULATIONS
5 It is stipulated that the deposition of
6 Dennis Foster, M.D., may be taken pursuant to
7 agreement and in accordance with the Oklahoma
8 Discovery Code, on February 5, 2010, before Lana
9 L. Phillips, Certified Shorthand Reporter.
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Dr. Dennis Foster 2/5/2010 3
1 DENNIS FOSTER, M.D.,
2 being first duly sworn, deposes and says in reply
3 to the questions propounded as follows:
4 DIRECT-EXAMINATION
5 BY MR. GALLAGHER:
6 Q Will you state your name for the record,
7 please?
8 A I\'m Dr. Dennis Foster.
9 Q And, Dr. Foster, my name\'s Scott
10 Gallagher, and I represent Ms. Keeton.
11 You understand that?
12 A Yes, sir.
13 Q And also, your videotaped trial
14 deposition is coming up around the 23rd.
15 You understand that as well; right?
16 A I do, yes.
17 Q We\'re here today to -- as a discovery
18 deposition, to learn some opinions you have.
19 You understand that?
20 A I do.
21 Q This is not your first rodeo in giving a
22 deposition; correct?
23 A Correct.
24 Q Okay. Tell me, sir, what all you\'ve
25 reviewed to formulate opinions concerning
Dr. Dennis Foster 2/5/2010 4
1 Ms. Keeton.
2 Generally her medical records?
3 A That would be correct.
4 Q You did not examine her?
5 A I did not.
6 Q Other than the medical records, did you
7 review anything else? X-rays? And not just the
8 reports, but did you actually have the films,
9 themselves?
10 A I\'ve had a d