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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, 8 Case No. 348894 9 10 11 '$2 4. DEPOSITION OF JOHN N. GALGIANI, M.D. July 27, 2000 16 Tucson, Arizona 17 18 19 COLVILLE & ASSOCIATES 20 By: G. Allen Sonntag, CCR No. 50194 21 1309 East Broadway Boulevard 22 Tucson, Arizona 85719 (520) 884—9041 23 . . FAX (520) 623—1688 24 3 Si DEPOSITION OFJOHN N. GALGIANI, M.D. 2 3 INDEX 4 * * * * * 5 EXAMINATION 6 Pg Ln 7 By Mr. Traci 4 8 9 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 14 15 16 - 17 18 19 20 21 22 23 - 24 2 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. 1 2 3 4 5 6 7 B 9 10 11 12 .3 14 15 16 17 18 19 20 21 22 23 24 •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 4 - 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 5 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 — I 2 3 4 5 6 7 B 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 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 6 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
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