1

1
	2	IN THE COURT OF COMMON PLEAS OF
		      RICHLAND COUNTY, OHIO
3

4
		WILLIAM MANLEY,	)	CIVIL DIVISION
	5	ADMINISTRATOR OF THE	)
		ESTATE OF SHELLEY C.	)	No. 01-341o
	'6	MANLEY,	)
			)	Deposition of
	7	              plaintiff,	)	 JEFFREY GARRETT, M.D.
			)
	8	              vs.	)	Filed on behalf of
			)	the Defendants
	9	ASHLAND FAMILY	)
		PRACTICE, INC. and	)	Counsel of Record for
	10	VERN yORE, M.D.,	)	this Party:
			)
	11	              Defendants.	)	Michael Romanello,
			)	Esq.
	12		)
	•		)	Zeiger & Carpenter LLP
	13		•)	1600 Huntington Center
			)	Columbus, OH 43215
14

15
	REPRODUCTION OF THIS TRANSCRIPT IS PROHIBITED
16 WITHOUT AUTHORIZATION FROM THE CERTIFYING
	AGENCY
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LAWYER'S 'NOTES.

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	2

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2	DEPOSITION OF JEFFREY GARRETT, M.D.
	3	a witness herein, called by the Defendants for
	4	examination, taken pursuant to the Pennsylvania
	5	Rules of civil procedure, by and before
	6	Monica R. Chandler, a professional Court
	7	Reporter and a Notary Public in and for the
	8	Commonwealth of Pennsylvania, at the law
	9	offices of West Penn Cardiology Associates,
	10	P.c., 5140 Liberty Avenue, Pittsburgh, PA, on
	11	Tuesday, June 18, 2002, at 1:10 p.m.
	12
	13	COUNSEL PRESENT:
	14	For the Plaintiff:
	15	Traci & Marx
by Robert V. Traci, Esq.
16
For the Defendants:
17
Zeiger & carpenter LLP
	18	by Michael Romanello, Esq.

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1
	2	INDEX

3

4
	5	      WITNESS: JEFFREY GARRETT, M.D.
	6
	7	EXAMINATION:	PAGE
	8
	9	BY MR,. ROMANELLO	  4

10



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	13	E X H I B I T 5:	PAGE
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	15	NO EXHIBITS MARKED
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		4
	1
	2	PROCEEDINGS
	3
	4	JEFFREY GARRETT, M.D.
	S	a witness herein, having been first duly sworn,
	6	was examined and testified as follows:
	7	EXAMINATION

8	BY MR. ROMANELLO:
	9	Q.	Good afternoon, Dr. Garrett. Again,

10	allow me to briefly introduce myself. My name
	11	is Michael Romanello.	I'm representing the

12	defendants that have been named in a lawsuit

13	that Mr. Traci's office has filed. Mr. Traci

14	has identified you as an expert, and to that

15	end, I'm going to ask you some questions today

16	about your expected judgments that you probably

17	will be testifying about in this case.

18	if at any time I ask you a question,

19	Doctor, that you do not understand, would you

20	please let me know and I'll do the best I can

21	to rephrase it?
	22	A.	Sure.

•23	Q. Similarly, along that same line~, if
24 you respond to a question that I ask you,

25	Doctor, I'm going to assume that you have


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5

1	Dr. Garrett - by Mr. Romanello
	2	understood it.	Fair statement?

3	A. Fair.
	4	Q.	And one last instruction, if you

5	would, Doctor, if I ask you a question that

6	calls for a yes or a no response, would you

7	please answer in that fashion. It will make

8	the court reporter's job a lot easier and the

9	record a lot easier to understand.
	10	A.	Okay.
	11	Q.	For the record, Doctor, could you

12	tell us your full name, please.
	13	A.	My name is Jeffrey Garrett.
	14	Q.	Doctor, before we started this

15	deposition, you were kind enough to provide me

16	with a copy of your cv. I believe you have a
	17	copy of it in front of you.	Is this a current

18	CV, Doctor?
	19	A.	Yes, it is.
	20	Q.	If you could turn to pages 6 and 7

21	and the top of page 8 -- no, I'm sorry, 6 and 7

22	of your CV. You've listed some research

23	studies. Generally, Doctor, are any of the

24	research studies that are listed here directly

25	relevant, if you will, to the judgment that you


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1	Dr. Garrett - by Mr. Romanello

2	have expressed in your report in this case?
	3	A.	It's hard to give a yes or no there

4	because a lot of these trials deal with acute

5	myocardial ischemia, and none of them deal with

6	sudden death, so I believe, and it will come

7	out a little later, that this lady died of

8	sudden cardiac death as a result of acute

9	myocardia] ischemia. As I said, a lot of my

10	research had to involve with patients who were

11	having aggressive coronary disease and acute

12	myocardial ischemia, and I don't think any of

13	the trials that I done have anything to do with

14	sudden cardiac death.
	15	Q.	Same question to you, Doctor, with

16	regard to the publications that are on pages 8,

17	9, 10 and 11 on your CV. Are any of those

18	publications relevant to the judgments that you

19	have concerning this case and more specifically

20	the cause of death?
	21	A.	My answer would be exactly the same.

22	Most of these publications arise from the
	23	research s