2.	I






IN THE qouRT OF COMMON PLEAS
	2	CUYAHOGA COUNTY, OHIO
	3	*	*	* * *
	4
	5 JOSEPHINE		HORTON, etc., plaintiff,
	6			 VS.
	7	THE CLEVELAND CLINIC FOUNDATION,
		       et al., defendants,
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Case No. 348894
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'$2
4.
DEPOSITION OF JOHN N. GALGIANI, M.D.
July 27, 2000
	16	Tucson, Arizona

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COLVILLE & ASSOCIATES
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	By:	G. Allen Sonntag, CCR No. 50194
21
1309 East Broadway Boulevard
	22			Tucson, Arizona 85719
				    (520) 884—9041
	23	.	.	 FAX (520) 623—1688

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Si	DEPOSITION OFJOHN N. GALGIANI, M.D.

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3	INDEX
	4			* * * * *
	5			EXAMINATION
	6				Pg	Ln
	7	By Mr. Traci			4

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	10	EXHIBITS
	ii	No.	Description
	12	1	CV of John N. Galgiani, M.D.	8	4
	2	Report of Findings by John N.
		Galgiani, M.D.	8	4
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	16	-
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	23	    -
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APPEARANCES
By:
TRACI & MARX
ROBERT V.TRACT, Esq
For the Plaintiff;
BY:
SWITZER, MURPHY & POLITO, CO.
BONEZZI,
L.P.A
WILLIAM
For the
D.	BONEZZI, Esq.
Defendants.
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•25
the
the
	BE IT REMEMBERED that pursuant to notice
deposition of JOHN N. GALGIANI, M.D., was taken at
University Park Marriott, in the City of Tudson,
County of Pima, State of Arizona, before C. Allen
Sonntag, Certified Shorthand Reporter, Certifisd
Realtime Reporter, a Notary Public in and for the
State of Arizona, on July 27, 2000, commencing at
hour of 3:30 p.m., in a certain cause now pending
before the Court of Common Pleas of Cuyahoga County,
Ohio.
the

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- 1	(The witness was thereupon duly sworn.)
	2	                 JOHN N. GALGIANI, M.D.,
	3	having been first duly sworn to state the truth, the
	4	whole truth and nothing but the truth, testified on
	5	his oath as follows:
	6		EXAMINATION
	7	BY MR. TRACI:

a	Q Doctor, so I don't forget to do it, I am
9 going to keep these. Bill, this is what you just
io handed to me.

We are going to mark this as Exhibit 1,

12	your CV, which was just handed to me, which is, I
understand, 39 paged and is the one most currently

14	available; is that correct?

15	A That's correct.

16	Q And, also, I am going to mark as Exhibit 2

17	your report; and let me hand this to you just to make

is	sure that that is your report.

19	A It is. Could I may be —— if I could just

20	mention two things that I found in that just for

21	clarification, two quick typos --

22	Q Sure.

23	A -— that, actually, would maybe be confusing

24	if I don't tell you about them.

•25	On Page 6 —— I am sorry. On Page 5, the

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very last sentence, it says, "specifically" —— at the
very bottom, it says, "specifically I believe that the
symptoms that Mr. Horton had during the spring and
summer of 1996," it reads, "was due," and it should
read, "was not due" ——
Q
That is —
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A	—— "to activity "

	Q As a matter of fact, that confused me
dramatically, because thought you said something
differently earlier in the report

	A Yes. The sentence before that, tn the
context of the sentence before, "I find no evidence
that the coccidioidal," c-o-c-c-i-d—i—o-idal,
"infection was active prior to October 2nd," and
just is -— I thought you might like me to clarify
that
this
	Q

to "was

	A

S

	A
	So the top of Page 6, you are changiflg that
not due?
That's correct

Is that correct?

That's correct
	Q Okay

	The other thing, which is less complicated,
is the dates on Page 3. I think you will see that I
got confused on some dating there. Those are all just

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references. The dates are accurate in the record.
And I tried to transcribe them as —-

3	october 2nd to October 14th, I think, is November 2nd

4	through 14th. Anyway, you will see that those are in
	S	errdr.

6	Q I didn't even notice those, but some of the

7	dates on Page 3 are typos?

8	A They are not representing what actually is

9	the case and it was my mistake in typing that up.

10	Q where it says Solu-Medrol administered in

11	doses -—
12 A Correct.

I•3	Q —— October 7th through 14th, that should be
14 November 2nd through 14th?

A	It's true. Those are probably wrong is all

16	I mean to say.

17	Q Okay. whatever is, in fact, true, did you

18	notice any other dates were incorrect other than those

19	particular ones?

20	I don't mean for you to g~ through each and

21	every one right now but if there are any that jumped

22	out at you that may have been incorrect.
	23	A	I think that's the only one.

24	I believe that's it.

•25	Q What I have handed you, was that the full

	7
	report