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	1 IN THE COURT OF COMMON PLEAS
		OF WASHINGTON	COUNTY, OHIO
	2
		SAMUEL D. KIGGANS,          	CIVIL DIVISION
	3	ADMINISTRATOR OF THE ESTATE
		OF JUDY KIGGANS, DECEASED,
	4
		Plaintiff,	Case No. 95 PT000112
	S
		- vs -
	6
		THOMAS TARNAY, M.D., ET AL.,	DEPOSITION TRANSCRIPT OF:
	7		STANTON FORREST DODSON, M0D.
		Defendants.
8
	9		DEPOSITION DATE:
			May 15, 1996
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			PARTY TAKING DEPOSITION:
	12		Defendants

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	14		COUNSEL OF RECORD
			FOR THIS PARTY:
	15		Gregory D. Rankin, Esquire
			LANE, ALTON & HORST
	16		Seventh Floor
			175 South Third Street
	17		Columbus, Ohio 43215-5100

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	19		REPORTED BY:
			April B. Franco
	20		Court Reporter

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	23	~~tnW
	CAT-LINKS IM	Pittsburgh, PA 15222
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1	DEPOSITION OF STANTON FORREST DODSON, M.D.,
	a witness, called by the Defendants for examination, in
2 accordance with the Ohio Rules of Civil Procedure, taken
	by and before April D. Francp, a Notary Public in and for
3 the Commonwealth of Pennsylvania, at the offices of
	Stanton Forrest Dodson, M.D., University of Pittsburgh
4 Medical Center, Falk Clinic, 3601 Fifth Avenue,
	Pittsburgh, Pennsylvania 15213, on Wednesday, May 15,
5 1996, commencing at 11:45 a.m.

6
	7	APPEARANCES:

8	FOR THE PLAINTIFFS:
	James A. Marx, Esquire -
	9	TRACI & MARX
		55 Public Square, Suite 1550
	10	Cleveland, Ohio 44113

11
FOR THE DEEENDANTS:
	12~	Gregory D. Rankin, Esquire
		LANE, ALTON & HORST
	13	Seventh Floor
		175 South Third Street
	14	Columbus, Ohio 43215-5100

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	22	-

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DISCOVERY TM	(412) 261-2323

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1
*INDEX*
2
	Examination by Mr. Rankin 	4
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Certificate of Court Reporter	70
4

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*	INDEX OF EXHIBITS *
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Deposition Exhibit 1                               
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	DiSCOVERY	(412) 261-2323

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	1	    STANTON FORREST DODSON, M.D.,
	2	      having been duly sworn, -
	3	was examined and testified as follows:

4
	S	EXAMINATION
	6	  -
	7	BY MR. RANKIN:
	8	Q.	Good morning, Doctor,	Would you state your full
	9		name, please.	-
	10	A.	Stanton Forrest Dodson.
	11	Q.	And your current appointment?
	12	A.	Assistant Professor of Surgery.
	13	Q.	University of Pittsburgh?
	14	A.	Correct.
	15	Q.	Doctor, we've -been provided with a CV, and I think
	16		you're in the process of obtaining an up-to-date CV,
	17		but is the information that's contained in the one
	18		presently before you accurate with the exception of
	19		some more recent publications?
	20	A.	Yes.
	21	Q.	And as far as the additional publications, they
	22		would be included in your current CV, which is
	23		arriving now.

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	(Document marked for identification
Deposition Exhibit A.)
5
BY

Q.
MR. RANKIN

I'm handing you what's been marked Exhibit A.
it appear to be the current up-to-date CV?
Yes
A.
Does
A.
I haven't really had a chance to look at that before
today, but can you just very briefly summarize your
educational background and professional experience?
Education after high school, I went to the
University of Richmond, Richmond, Virginia.
Following that, I.went to medical school, Eastern
Virginia Medical School in Norfolk, Virginia. Then

I did a general surgery residency in Western Reserve

Care System, Youngstown, Ohio. Then I did a

transplant and hepatialary fellowship at the

University of Pittsburgh

When did you do your fellowship?

From '91 to '93
Q.,

A.

Q.
A.
And then since '93, you have been an assistant
professor?

Correct
Q.
At the University of Pittsburgh; is that correct?

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	1	A.	Yes.

2 Q.	Other than this case, have you had occasion to serve

3	as an expert witness?
	4	A.	No.

5 Q.	How did you come to be retained as an expert on

6	behalf of the plaintiff in this case?
	7	A.	I was the lead surgeon involved in the case.

8 Q.	And when were you first approached about serving as

9	a witness in the legal proceedings arising out of

10	Ms. Kiggans' death?
	11	A.	It had to be from Attorney Marx's office. I believe

12	I would say what, six months ago, approximately.

13	MR. MARX: I think it actually was longer

14	than that, but I'm not sure. I would have to look

15	at my file.

16 ~A.	Correëpondence in February of '96, but I'm sure we

17	had some phone calls before that.

18 BY MR.	RANKIN:

19 Q.	Does the February of '96 correspondence basically

20	confirm that you have agreed to testify in this

21	case?
	22	A.	Yes.

23 Q.	How much are you charging for your expertservices

24	in this case?
	CAT-LINKS TM	Pittsburgh, PA 15222
	DISCOVERY TM	(412) 261-2323

None.

How much are you charging for your deposition time
today?

None
Have you
which is
No
7
been asked to testify at trial in this case

pending in Marietta, Ohio?
If asked, will you be wi