State of Ohio,


County of Cuyahoga
SB:

IN THE COURT OF COMMON PLEAS


JOSEPHINE HORTON, Executrix for
the estate of Leo A Horton,
vs
Plaintiff,
Case No 348894 -
Anthony O Calabrese
THE CLEVELAND CLINIC FOUNDATION,)
et al,
Defendants
)


)





THE DEPOSITION OF RALPH J
TUTHLLL, MD
:~
MONDAY, OCTOBER 18, 1999





	The deposition of Ralph 3 Tuthill, MD, called
by the Plaintiff for examination pursuant to the Ohio
Rules of Civil Procedure, taken before me, the
undersigned, Charles A Cady, Registered Merit
Reporter and Notary Public within and for the State of
Ohio, taken at the Cleveland Clinic Foundation, 9500
Euclid Avenue, Cleveland, Ohio, commencing at
10:15 am, ~he day and date above set forth
CABY & WAHOOS REPORTING SERVICES, INC
55 PUBLIC SQUARE
	1225 ILLUMINATING BUILDING
CLEVELAND, 01110 44113
		(216) 861-9270

2
	1	APPEARANCES:

2	On behalf of the Plaintiff:

3	Robert V Traci, Esq
Traci & Marx
4	1550 Illuminating Building
Cleveland, Ohio 44113
5

6
	On behalf of the Defendant Cleveland Clinic
7 Foundation:

8	Edward B Taber, Esq
Bonezzi, Switzer, Murphy & Polito Co, LPA
9	1400 Leader Building
Cleveland, Ohio 44114
10

11
	On behalf of the Defendant Dr Nedorost:
12
Gary H Goldwasser, Esq
13	Reminger & Reminger Co, LPA
113 St Clair Building - 7th Floor
14	Cleveland, Ohio 44114

15

16	On behalf of the Defendant Dr Kantharaj:

17	Murray K Lenson, Esq;
Ulmera Berne, LLP
18	900 Bond Court Building
Cleveland, Ohio 44114
19

20

21

22

23

24

25



	Cady & Wanous Reporting Services, Inc

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1	RALPH 3 TUTHILL, MD, DEPOSITION INDEX

2
	3	EXHIBIT NO	PAGE NO
	4	    1	4

5

6
	7	EXAMINATION BY:	PAGE NO
	8	MR TRACI	4
	9
	10
	11
	12
	13
	14
	15
	16
	17
	18
	19
	20
	21
	22
	23
	24

25



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	1		   (Plaintiff's Exhibit 1 was marked)
	2
	3		         RALPH ~T TUTHILL, MD
	4		of lawful age, called by the Plaintiff for
	5		examination pursuant to th~ Ohio Rules of Civil
	6		Procedure, having been first duly sworn, was
	7		examined and testified as follows:
	8		  EXAMINATION OF RALPH J TUTHILL, MD
	9	BY MR	TRACI:
	10	Q	Doctor, would you state your name and address
	11		for us, please
	12	A	Ralph James Tuthill I live at 60 Church Street
	13		in Chagrin Falls, Ohio
	14	Q	And you are employed by the Cleveland Clinic
	15		Foundation?
	16	A	Yes
	17		For how long?
	18	A	Since 1981
	19	Q	What is your current position?
	20	A	It's abdut 19, 20 years, twenty years
	21		      What's that?
	22	Q	What's your current position with them?
	23	A	Staff
	24	Q	And you're a pathologist?
	25	A	Yes



Cady & Wanous Reporting Services, Inc

your CV
We marked it as Exhibit 1
Is that, to your knowledge, a relatively
current CV?
Q
A
5
Q
A
And are you board certified in that field,
pathology?

Anatomic pathology
And when was that?
1 74~
Q
A
Q
A
1

2

3

4

S

6

7

8

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
Q
Any other board certifications?
I have subspecialty boards in dermatopathology,
which is '76, and cytopathology, which is '97,
'98 I can't remember, but it's just a couple
years ago

Dermatopathology is what?

The study of skin disease, usually in
morphologic techniques of light microscopy and
special stains and so forth

And th~t is a special certification?
It's a subspecialty of the American Board of
Pathology and the American Board of Dermatology
Okay And cytopathology is what?

That's the study of individual cells, basically,
that are obtained with smears or brushes or
needles
A
Q
A
Q
Okay I'm going to hand you what I was given as
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	1	A	Yes, July 22 of this year
	2	Q	Is there anything that you'd like to add to that
	3		CV?
	4	A	Not that I can think of at the moment
	5	0	Okay As a pathologist here at the Clinic, what
	6		information do you have about a patient when you
	7		perform any of the studies that you do as a
	8		pathologist? Meaning, do you get access to the
	9		records? Is there some form that's filled out
	10		with inforniation on it? What do you get?
	11	A	There's a requisition slip that comes with
	12		usually a differential diagnosis, you know, bne
	13		or more items that are being entertained by the
	14		clinician
	15	Q	And is the requisition slip typically filled out
	16		by the clinician?
	17	A	It should be, but not always Sometimes it's
	18		one of the, you know, associates in the Clinic
	19		that are filling it out for the physician, but
	20		it's really under the direction of the physician
	21		that's taken the biopsy
	22	Q	When you say "one of the associates," are you
	23		talking about one of the residents perhaps?
	24	A	Residents, yes, or a nurse, sometimes a nurse
	25	Q	Sometimes a nurse?



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	1	A	Yes
	2	Q	Okay Are those requisition slips maintained as
	3		part of the permanent record?
	4	A	You know, I think so I don't know how far
	S		back, but I know that when I request one to
	6		revi