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, M.D.
:~
MONDAY, OCTOBER 18, 1999





	The deposition of Ralph 3. Tuthill, M.D., 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 a.m., ~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



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1	RALPH 3. TUTHILL, M.D., 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

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	1		   (Plaintiff's Exhibit 1 was marked.)
	2
	3		         RALPH ~T. TUTHILL, M.D.
	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, M.D.
	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.



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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

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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
Cady & Wanous Reporting Services, Inc.

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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