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STATE OF SOUTH CAROLINA )
) IN THE COURT OF COMMON PLEAS
COUNTY OF ANDERSON )
Margaret McKinney and )
Loyce A. McKinney, )
)
Plaintiffs, )
)
vs. ) C.A. 2002-CP-04-3201
)
Terry K. Holdredge, M.D., )
erry K. Holdredge, M.D., )
P.A., and Bearwood )
Ambulatory Surgery Center, )
P.A., )
)
Defendants. )
DEPOSITION OF TERRY K. HOLDREDGE, M.D.
PURSUANT to Notice and/or Agreement, the deposition of TERRY K. HOLDREDGE called by the Plaintiff was taken before Elaine C. Hamby, Reporter, at the offices of CLARKSON, WALSH, RHENEY & TURNER, 1164A Woodruff Road, Greenville, South Carolina on Friday, April 11, 2003 commencing at approximately 2:20 P.M.
ASSOCIATE REPORTING AGENCY, INC.
Sandra S. Freeman, CCR-CVR-CM
31 Tindal Avenue
Greenville, South Carolina 29605
Ring: 864 233-8111
APPEARANCES:
W. BRADFORD SEARSON, ESQUIRE
CLONINGER, LINDSAY, HENSLEY & SEARSON, P.L.L.C.
366 MERRIMON AVENUE
ASHEVILLE, NORTH CAROLINA 28801
AND
MARK S. MEGLIC, ESQUIRE
MEGLIC & WILKES, L.L.C.
201 WHITSETT STREET
POST OFFICE 2061
GREENVILLE, SOUTH CAROLINA 29602
ATTORNEYS FOR THE PLAINTIFFS.
N. HEYWARD CLARKSON, ESQUIRE
CLARKSON, WALSH & RHENEY & TURNER
P. O. BOX 6186
GREENVILLE, SOUTH CAROLINA 29606
ATTORNEY FOR DEFENDANT.
ALSO APPEARING:
HOLLY FURCHES, LEGAL ASSISTANT
TO MARK MEGLIC
STIPULATIONS:
This deposition is taken pursuant to the Circuit Court Rules; reading and signing of the deposition by the witness are expressly reserved.
NOTATIONS:
Two exhibits were marked to this deposition.
INDEX OF EXAMINATION
BY MR. SEARSON PAGE 4
REPORTER\'S CERTIFICATE PAGE 167
SIGNATURE PAGE PAGE 168
ERRATA PAGE PAGE 169
KEYWORD INDEX PAGE 170
INDEX OF EXHIBITS
PLAINTIFF\'S ENTERED
NO. DESCRIPTION AT PAGE
1 VITAE OF TERRY HOLDREDGE, M.D. 10
2 DRAWING 87
TERRY K. HOLDREDGE, M.D.
Having been duly sworn to tell the truth, the whole truth and nothing but the truth of his own knowledge concerning the matters herein responds to the questions propounded as follows:
DIRECT EXAMINATION
BY MR. SEARSON:
Q. Would you state your full name, please, sir?
A. Terry King Holdredge.
Q. Dr. Holdredge, we met informally just a moment ago. I went on the record to clarify that I\'m Brad Searson and I\'m a lawyer from Asheville, North Carolina. I\'m associated in this case with Mark Meglic sitting to my right and he and I represent the plaintiffs in this case. Also, in the room, Holly Furches is a legal assistant with Mark\'s firm working with us in the case and then our clients are here, and I think you know Margaret McKinney and Tony McKinney and they will be sitting in here with us today but the good news is I\'m the only person who is entitled to ask you questions on this side of the table and so you will not have to put up with hearing other people speak to you today. Have you ever given a deposition before?
A. I have.
Q. I\'ll ask you something about that in a moment but I want to just make a few statements to your comments. One is truly as a human being I want you to know that I make clumsy sentences when I speak publicly sometimes and if I do that today you are under no obligation to even attempt to answer a question that makes no sense to you so I would like you to understand that if for any reason you don\'t understand what I say, you need to let me know and ask me to repeat or rephrase it.
A. Okay.
Q. If you need a break today I want you to just let me know because I don\'t want you to have to sit there one minute physically uncomfortable or whatever. You don\'t have to tell me why but I would like you to attempt to answer the pending question before you take a break. Do you understand that, what I mean by that?
A. I do.
Q. The other detail is that it\'s important and you have figured this out already. Give a verbal response. In conversation it\'s tempting to nod or say uh-huh (affirmative) or uh-uh (negative) and I would like to make sure you use words, yes, no, or whatever words you intend to express for your answer and then finally, I\'m going to try not to talk over you when you are answering and if you will wait until I\'m done speaking to begin your answer, it will make it easier on the court reporter and give us a better transcript. I said, \"finally,\" but actually there\'s one other housekeeping matter. Under the South Carolina rules I understand if we take a break you are not to discuss the deposition and its progress and the information that we are covering unless there is some issue regarding privilege that yo
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