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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 Cady & Wanous Reporting Services, Inc. 3 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 25 Cady & Wanous Reporting Services, Inc. 4 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. 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 Cady & Wanous Reporting Services, Inc. 6 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? Cady & Wanous Reporting Services, Inc. 7 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
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