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IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI

AT KANSAS CITY

EMMA CALDWELL, )

Plaintiff, )

vs. ) No. 1016-CV02562

SOUTHTOWN WOMEN'S CLINIC, LLC, )

et al., )

Defendants. )

The deposition of RICHARD MICHAEL GORE,

called for examination, taken before CHRISTINE R.

MACINTYRE, a Notary Public within and for the

County of Cook, State of Illinois, and a Certified

Shorthand Reporter of said state, at Room 520AB,

2650 Ridge Avenue, Evanston, Illinois, on the 22nd

day of September, A.D. 2011, at 4:50 p.m.

3

1 PRESENT: (Continued)

2 SHAFFER, LOMBARDO & SHURIN,

3 (911 Main Street, Suite 2000,

4 Kansas City, Missouri 64105,

5 816-931-0500), by:

6 MR. CRAIG A. GRIMES,

7 appeared on behalf of Defendants

8 Jetinder Singh Marjara and Thomas E.

9 Hafer.

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23 REPORTED BY: CHRISTINE R. MACINTYRE, C.S.R.,

24 Certificate No. 84-2776.

21 PRESENT:2 DAVID R. SMITH, P.C.,3 (One Park Place Condominium Tower,4 700 West 31st Street, Suite 408,5 Kansas City, Missouri 64108,6 816-778-0957), by:7 MR. DAVID R. SMITH,8 appeared on behalf of the Plaintiff;9

10 POLSINELLI SHUGHART, P.C.,11 (12 Wyandotte Plaza,12 120 West 12th Street,13 Kansas City, Missouri 64105,14 816-421-3355), by:15 MR. CHRISTOPHER J. MOLZEN,16 appeared on behalf of Defendants17 Southtown Women's Clinic, LLC, Southtown18 Women's Healthcare, LLC, and Sharon Y.19 Harris-Baugh, M.D.;20

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41 (WHEREUPON, certain documents were2 marked Gore Deposition Exhibit3 Nos. 1 through 32, for4 identification, as of 9/22/11.)5 (WHEREUPON, the witness was duly6 sworn.)7 RICHARD MICHAEL GORE,8 called as a witness herein, having been first duly9 sworn, was examined and testified as follows:

10 EXAMINATION11 BY MR. MOLZEN:12 Q. Would you please state your full name.13 A. Yes. My name is Richard Michael Gore,14 G-o-r-e.15 Q. And are you a physician?16 A. That's correct.17 Q. What kind of physician are you?18 A. I'm a diagnostic radiologist.19 Q. All right. Dr. Gore, my name is20 Christopher Molzen. I represent Dr. Sharon21 Harris-Baugh in this matter.22 I understand you have been retained by23 the plaintiff, Emma Caldwell, as an expert for her24 to talk about some of the radiology issues. Is

Richard Gore September 22, 2011

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2700 Centennial Tower101 Marietta StreetAtlanta, GA 30303

www.esquiresolutions.com

5

1 that true?

2 A. I don't know if it's by her or whether

3 it was by Mr. Smith.

4 Q. The plaintiff's attorney?

5 A. Yes.

6 Q. All right. Do you understand your role

7 in this case is to serve as an expert?

8 A. As a medical expert, yes.

9 Q. All right. Now, you're here pursuant to

10 a deposition notice. Let me hand you what the

11 court reporter has marked as Exhibit No. 1.

12 Have you seen that notice before?

13 A. Yes, I have.

14 Q. It has attached to it an exhibit

15 denominated as Exhibit A. Have you had a chance to

16 go through the items that you were requested to

17 bring?

18 A. Yes.

19 Q. You have brought, it looks like, some

20 materials. Are there other materials that you have

21 looked at, prepared, or had supplied to you that

22 aren't here with us on this conference table this

23 afternoon?

24 A. Just I can't find the initial CDs that I

71 of the things that you have brought with you. One2 of the items that the court reporter has marked is3 a couple of handwritten pages. Can you identify4 that for us? It's denominated Exhibit 2.5 A. Yes. This is Gore Deposition No. 2, and6 these are the opinions I hold in this case.7 Q. I see that it is a handwritten set of8 notes or opinions that are on two notebook pages.9 Is that correct?

10 A. That's correct.11 Q. Have you prepared any written reports in12 this case?13 A. No.14 Q. In other words, have you put together15 some kind of summary of your opinions other than16 what has been marked as Exhibit No. 2?17 A. I -- these -- this deposition number18 which is No. 3, this is what Mr. Kurtz and19 Mr. Smith put together, and they read it to me, and20 I agreed with it, but I didn't author this.21 Q. All right. Well, let me go back and22 talk with you about Exhibit No. 2 --23 A. Okay.24 Q. -- which I believe you've labeled it as

61 got with all the medical records, so I printed out2 what I could, but I did receive all the medical3 records on two CDs, but I didn't bring them today.4 Q. Okay. So would you have them loaded on5 a computer somewhere?6 A. No. It was too big to download, so it's7 somewhere in my house.8 Q. Okay. So you have two CDs with nothing9 but medical records?

10 A. That's correct.11 Q. All right. Where are those, do you12 believe?13 A. Somewhere in my house with all my other14 CDs and materials like that.15 Q. With the exception of the two CDs of16 medical records, are there any other materials that17 you have looked at, been supplied with, or have18 prepared that aren't here with us today?19 A. No, sir.20 Q. Have you made an effort to bring21 everything that's responsive to the items outlined22 in Exhibit A of the deposition notice?23 A. Yes, I have.24 Q. Let me talk to you a little about some

81 opinions. Is that correct?2 A. That's correct.3 Q. And it spans two pages. How many total4 opinions do you have?5 A. Seven.6 Q. All right. Have you attempted to write7 out your opinions any other time other than what's8 recorded on Exhibit No. 2?9 A. No.

10 Q. In other words, have you set them forth11 in, say, an E-mail or in another scratch piece of12 paper somewhere at some time?13 A. No, sir.14 Q. Is that summary that's been marked as15 Exhibit 2 of your opinions -- is that fair,16 complete, and accurate?17 A. Yes, sir.18 Q. Do you anticipate giving any other19 opinions other than what is outlined in Exhibit20 No. 2?21 A. I'm still waiting for some plain x-rays,22 I think a plain chest x-ray, a plain abdominal23 x-ray, and also an ultrasound, and I am relying on24 the radiology report, so I assume the radiology


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91 reports are correct, but, you know, I would offer2 an amendment if I disagreed with the radiology3 report.4 Q. Do you happen to know which reports or5 dates you're still waiting on?6 A. Yes.7 THE WITNESS: Can I have, let's see, the8 folder saying "radiology reports"? Right here.9 MR. SMITH: Right on top.10 THE WITNESS: Okay. That's convenient.11 MR. GRIMES: Does that have an exhibit sticker12 on it?13 MR. MOLZEN: It does.14 THE WITNESS: No. 25.15 BY THE WITNESS:16 A. I'm still awaiting the pelvic ultrasound17 that was performed on January 10th, 2008.18 BY MR. MOLZEN:19 Q. I take it, by "waiting," you mean you20 have never seen it or been supplied --21 A. I have not seen it.22 Q. All right.23 A. And then we have an AP chest x-ray done24 on January 20th, 2008.

111 Dr. Gubin?2 A. I just -- just rereading the materials3 this weekend, I just realized that I actually had4 not imaged -- viewed these images. That's the only5 reason.6 Q. Do you have any reason to disagree with7 any of the findings in these three reports that go8 with the January 10th, the January 20th, and the9 January 23rd acute abdomen series? Is there

10 anything on the face of the reports written by any11 of these radiologists that causes you to question12 what's written there?13 A. Well, on Page 2 of the ultrasound of the14 pelvis, I think the radiologist made a mistake. On15 Line 2 of the impression, "some of the thyroid16 appear to be notable," I think he meant fibroid,17 and so it was a mistranscription.18 Q. Okay. Anything else on the January 10th19 film -- or, I should say, report of the film?20 A. No. Otherwise, it looks good.21 Q. All right. And what about the chest AP22 for the 20th read by Dr. Gubin; anything on that23 report strike you as inaccurate or questionable?24 A. Without looking at the film, that looks

101 Q. Read by Dr. Gubin?2 A. And that was interpreted by Dr. Barry3 Gubin, G-u-b-i-n.4 Q. Okay. And you don't have that one,5 either?6 A. That's correct.7 Q. Are you missing anything else?8 A. Yes. There is an acute abdomen series9 that was performed on January 23rd, and this was

10 also interpreted by Dr. Gubin.11 Q. All right. Let me just summarize to12 make sure I have heard you accurately. You are13 still waiting to review the actual films from14 January 10th, 2008, January 20th, 2008, and15 January 23rd, 2008, correct?16 A. Right. The first one's an ultrasound,17 the second one is a chest x-ray, plain chest x-ray,18 and the third one is a abdominal series with just19 plain x-ray.20 Q. The acute abdominal series interpreted21 by Dr. Gubin on January 23rd, right?22 A. That's right.23 Q. All right. Is there any reason that you24 haven't asked for the January 23rd film read by

121 good.2 Q. Okay. And how about the acute abdominal3 series interpreted by Dr. Gubin on the January 23rd4 set of films?5 A. I have not seen the x-rays, but he said,6 "Probable postoperative free intraperitoneal air."7 I would like to see where the distribution of the8 gas is before, you know, I would concur with that.9 Q. What would you be looking for on that?

10 A. Well, I would like to look at the amount11 of gas and where it's distributed.12 Q. And what would cause you to disagree13 with Dr. Gubin's impression that it was the result14 of the surgery on the 18th?15 A. Well, we have a -- the chest CT that was16 done, I think, the day before -- let's see. The17 chest CT was done on 1/21/08, and this x-ray was18 done on 1/23/08, so it was actually two days19 before. There was no free air under the diaphragm20 at that point, so I would like to see where that21 gas was and did we image that area on the patient's22 chest CT.23 Q. And what would you be specifically24 looking for?


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131 A. I would like to see, you know, the2 amount of gas, where it's distributed, and try to3 compare it with the CT, but, you know, it's4 very hard often to compare the amount of gas that5 you see on CT with the amount that you see on a6 plain x-ray. It's kind of like comparing apples7 and oranges often.8 Q. All right. And you have read9 Dr. Gubin's deposition?10 A. Yes, I have.11 Q. Let me hand you what the court reporter12 marked as Exhibit No. 6.13 Is that a summary of his testimony --14 his deposition testimony that you prepared?15 A. Yes, it is.16 Q. Did you see anything in his deposition17 and is anything reflected in Exhibit 6 that causes18 you to believe that maybe he had misinterpreted the19 January 23rd acute abdomen series?20 A. No.21 Q. Okay. Anything else that you're still22 waiting on other than those three sets of film?23 A. No, sir.24 Q. All right. There are some things that

151 testify to and then have you take the stand and say2 something different. Is that an agreement, or3 would you agree to let us know all of your opinions4 here today?5 A. Yes, sir. That seems fair.6 Q. And if for some reason between now and7 the time this case actually gets tried to a jury8 you see additional things -- for instance, you see9 these three sets of films, and they somehow modify

10 or change your opinions -- you need to let11 Mr. Smith know that so I have an opportunity to12 talk to you about your new or modified opinions.13 All right?14 A. Agreed.15 Q. All right. Are you under any time16 restriction tonight? Do you have to be somewhere17 at some time tonight?18 A. No.19 Q. I don't intend to prolong this. I just20 need to know that as a professional courtesy to21 you.22 A. Thank you.23 Q. Let me talk to you about some of the24 things that you have brought. We talked about

141 you have brought with you to this deposition.2 Exhibit 2 is a list of your opinions. Have you3 reviewed everything you need to with the exception4 of those three sets of films in order to give us5 full and final opinions here today?6 A. Yes, sir.7 Q. Okay. I only have one rule that I8 usually tell experts such as yourself. You have9 apparently given depositions before. Correct?

10 A. Yes, sir.11 Q. My rule is fairly simple. This is our12 only opportunity to learn of the opinions that you13 will offer to the jury at the time of trial. Do14 you understand that?15 A. Right. I understand you folks do not16 like surprises at trial.17 Q. Well, it goes to the basic fairness of18 things, and so if for some reason I haven't been19 artful enough in my question but you know you're20 going to talk about a subject in the form of an21 opinion that somehow or another you didn't get a22 chance to outline or speak up with here today, I23 need to know that because I don't want to leave24 here today thinking I know what you're going to

161 Exhibit 2, which is an outline of your seven2 opinions, correct?3 A. That's correct.4 Q. All right. We'll come back to that in a5 little bit. You don't anticipate any other6 opinions than what are outlined in Exhibit 2 at7 this point, do you?8 A. Not unless you ask me some questions9 about that.

10 Q. All right. All right. Let me hand to11 you what the court reporter has marked as Exhibit12 No. 3. You earlier referred to that. Is that a13 set of E-mails that include a designation of you as14 an expert in this case?15 A. Yes, it does.16 Q. I counted the pages. I think there's 2517 pages. Would you generally agree with that?18 A. Yes.19 Q. Okay. The second or third page of20 Exhibit No. 3 appears to be an E-mail to you asking21 if you agree with the expert designation that was22 drafted by plaintiff's counsel. Do you see that?23 A. Yes.24 Q. I see in your E-mail back to plaintiff's


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171 counsel that you apparently agreed that those would2 be the general areas on which you would testify.3 Correct?4 A. That's correct.5 Q. I do not see that you have been listed6 as a standard of care expert against any of the7 defendants. Now, standard of care means that you8 won't be talking about what some doctor or doctor's9 group or hospital or other physician did that was10 below the standard of care. Is that correct?11 A. I may have an opinion but not for12 standard of care outside of radiology, that's13 correct.14 Q. All right. Now, do you anticipate15 offering any standard of care opinions as it16 pertains to any of the radiologists that read the17 films on Emma Caldwell?18 A. No, sir.19 Q. In other words, let me be more precise.20 Do you have an opinion that Dr. Gubin or21 Dr. Bhargava breached the standard of care in this22 case?23 A. In terms of their interpretations of the24 scans, they complied with the standard of care.

191 A. Okay. I have the PE study, and I also2 have -- which was a CT examination, and I have the3 abdominal CT, and yes, he complied with the4 standard of care in interpreting those studies.5 Q. All right. Do you have an opinion that6 any radiologist other than Bhargava and Gubin, for7 instance, Dr. Mena, M-e-n-a, Dr. Sweeney,8 Dr. Depaolis, Dr. Rosen, Dr. Sweeney, Dr. Litwin,9 Dr. Graham Lee, Dr. Spittler, S-p-i-t-t-l-e-r,

10 Dr. Berg, Dr. Medberg, Dr. Waddle, or Dr. Stephens,11 breached the standard of care when they interpreted12 any of Emma Caldwell's radiological studies?13 A. I don't have an opinion in terms of14 those radiologists, correct.15 Q. You believe they all complied with the16 standard of care in their interpretations of those17 films?18 A. I honestly did not look at all the films19 subsequent to the second operation so --20 Q. Let me ask you, in terms of what you21 were asked to do in this case, what were you22 specifically asked by plaintiff's counsel to do in23 order to reach the opinions that you have outlined24 in Exhibit No. 2?

18

1 Q. Both Dr. Gubin and Dr. Bhargava

2 correctly read the films that were taken of Emma

3 Caldwell, is that correct?

4 A. That's correct.

5 MR. SMITH: I am going to object to the extent

6 that it lacks foundation on the series of films

7 that he doesn't have before him.

8 BY MR. MOLZEN:

9 Q. Well, let me be more precise. Do you

10 have an opinion that Dr. Gubin misread either the

11 January 20th or January 23rd, 2008, films?

12 A. Well, the reports seem reasonable.

13 Again, I need to look at the x-ray before I concur.

14 Q. As we sit here tonight doing this

15 deposition, you don't currently have an opinion

16 that Dr. Gubin breached the standard of care when

17 he interpreted these films, is that correct?


19 Q. And the same would be true with

20 Dr. Bhargava, who read the January 21st chest CT

21 and then the CT of the abdomen on January 24th; you

22 don't currently hold an opinion that he breached

23 the standard of care for a radiologist when he made

24 his interpretations, do you?

201 A. I was asked to look at the CT2 examinations that were performed on January 21st3 and January 24th and also look at the medical4 records, and that was last June, I believe, and5 then last week they sent me all these depositions6 to read.7 Q. Okay.8 MR. SMITH: I don't want there to be an9 inaccurate record, but there are other CTs that we

10 provided to him that he's made reference to already11 today, specifically the January 9th.12 BY THE WITNESS:13 A. Oh, and the January 9th CT, as well.14 BY MR. MOLZEN:15 Q. You correct me if I have heard wrong,16 but I understand that your principal request -- or17 the request of plaintiff's counsel to you in this18 case when they asked you to look at some of the19 films, you were asked to specifically look at the20 January 9th CT, the January 21st chest CT, and the21 January 24th abdominal CT, is that correct?22 A. That's right.23 Q. As well as look at other medical records24 and some other films, correct?


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211 A. That's correct.2 Q. But you were asked to concentrate on3 those, correct?4 A. Yes, sir.5 Q. Are there any films past January 25th,6 2008, that you have spent some time studying or7 interpreting?8 A. No, sir.9 Q. January 25th, as you know from looking10 at the medical records, was a period when Dr. Webb11 took Emma Caldwell back to surgery for an12 exploratory laparotomy procedure, correct?13 A. That's my understanding.14 Q. And you really haven't spent any time15 looking at CTs, x-rays, sonograms after that date,16 correct?17 A. That's correct.18 Q. Would it be fair to say that you don't19 anticipate offering opinions on what is shown20 radiographically on films after January 25, 2008?21 A. Unless I'm specifically asked by you or22 Mr. Smith.23 Q. Currently, as we sit here today and as24 outlined in Exhibit 2, which is a list of your

231 Q. Now, when you put together these2 summaries like Exhibit No. 7, you jotted down the3 page line -- or the page number where that4 testimony appears, right?5 A. That's right.6 Q. And then on the right-hand side -- on7 the right-hand side of the red column, you have8 tried to write down just a note as to what was9 important, in your mind?

10 A. What they said, correct.11 Q. All right. Was there a particular12 reason you put down certain information in a13 summary fashion like this?14 A. Well, I have had to review over a15 thousand pages of deposition and just to help my16 memory.17 Q. Okay. Is this an attempt to hit the18 highlights of what you consider to be important19 testimony?20 A. That's correct.21 Q. Let me hand you Exhibit No. 8. You tell22 me which deposition this is.23 A. All right. This is the deposition of24 the treating general surgeon, and that's

221 opinions, you're not currently anticipating talking2 about films after January 25th, correct?3 A. That's correct.4 Q. All right. In terms of the items that5 you have prepared besides Exhibit No. 2, you have6 also prepared summaries of some of the other7 depositions in this case, have you not?8 A. Yes, sir.9 Q. Let me hand you what's been marked as

10 Exhibit 7. Some of these are a little bit out of11 order. I apologize in advance. They have been12 premarked, and so I am kind of taking them a bit13 out of order. I don't do this to confuse you. All14 right?15 A. Okay.16 Q. Let me hand you Exhibit No. 7.17 A. Yes.18 Q. That is your summary of which19 deposition?20 A. This is of Dr. Neil, N-e-i-l, Bhargava,21 B-h-a-r-g-a-v-a.22 Q. And you recognize him as one of the23 treating radiologists in this case, correct?24 A. Yes, sir.

241 Dr. John M. Webb, W-e-b-b.2 Q. And then No. 9 is your summary of the3 deposition of whom?4 A. This is the summary of Dr. Paul Brune,5 B-r-u-n-e, and he's the infectious disease treater.6 Q. All right. And Exhibit No. 10 is what?7 A. Okay. Exhibit No. 10 is a number of8 pages on the deposition of our treating OB/Gyn9 physician, Dr. Sharon Harris, H-a-r-r-i-s, hyphen,

10 Baugh, B-a-u-g-h.11 MR. MOLZEN: All right. I think I am missing12 a page. Is that --13 MR. SMITH: There's multiple pages of14 Harris-Baugh.15 BY MR. MOLZEN:16 Q. That's actually a total of five pages,17 is it not?18 A. It says six, but I can't find Page 319 here. Oh, here it is, Page 3. It's six pages.20 Q. Okay. All right. And then Exhibit21 No. 11 is what?22 A. This is the deposition of one of the23 hospitalists, and this is Dr. Singh, S-i-n-g-h.24 Q. All right. And I have here -- and I


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25

1 have not marked these, but these appear to be the

2 depositions that you were just referring to,

3 correct?


5 Q. Can I ask you, I see that some of the

6 testimony is -- has been pulled out of the

7 deposition. Is there a reason for that, or did it

8 just come loose?

9 A. I think it just came loose in these

10 300-page depositions.

11 Q. All right. No particular reason --

12 A. No.

13 Q. -- why this is loose?

14 A. No.

15 Q. All right. And just so the record is

16 clear, we have a deposition of Dr. Singh,

17 Dr. Gubin, Dr. Brune, Dr. Bhargava, Dr.

18 Harris-Baugh, two volumes, and Dr. Webb. Have you

19 looked at any other depositions?

20 A. No.

21 Q. Have you reviewed the deposition of Emma

22 Caldwell, the plaintiff?

23 A. No, I have not.

24 Q. Have you seen any photographs of Emma

271 A. No, I don't.2 Q. I have seen previous depositions that3 you have given where you indicate that you keep a4 list of both trial and deposition work. Is that5 inaccurate?6 A. I might have in the past but no more7 because I understand that there are actually8 deposition services where you can actually find the9 depositions of the people who you are going to

10 ultimately depose.11 Q. Have you ever kept a list of the12 depositions that you have given?13 A. I think in the early days but not14 recently, no.15 Q. What's your best estimate to the total16 number of depositions you have given in your17 career?18 A. Since the mid '80s, probably maybe 130.19 Q. Okay. And does that list all of your20 trial testimony since 2000?21 A. Yes, it does.22 Q. All right. And when I said "that," I23 was referring to Exhibit No. 4.24 A. Yes.

261 Caldwell?2 A. No, I have not.3 Q. Are these all of the depositions that4 you have looked at?5 A. That's right.6 Q. Have you read every one of them?7 A. Yes.8 Q. Did you make any notes in any of these9 pages of the deposition?

10 A. No. The notes I made are on my little11 sheets here.12 Q. All right. Let me hand you what the13 court reporter has marked as Exhibit No. 4.14 Can you identify that for us?15 A. Okay. This is a list of the trials that16 I have participated in since the turn of the17 century. Unfortunately, my mind doesn't serve me18 before the year 2000, but I have been testifying at19 both trial and deposition since the mid 1980s.20 Q. Okay. That is a list of only trial21 appearances, correct?22 A. That's correct.23 Q. Do you keep a list of the depositions24 that you're involved in?

281 Q. All right. So 4 does list all of your2 trial appearances, is that correct?3 A. Since the turn of the century.4 Q. All right. When were you first5 contacted in this case?6 A. I believe I was contacted in the spring,7 probably May or June.8 Q. Of this year?9 A. Of this year.

10 Q. All right. Before I move on, let me ask11 you about Exhibit 4. Are there any cases on12 Exhibit 4 that you are aware of that have13 essentially the same or very similar issues to this14 case, the Caldwell case?15 A. No, they do not.16 Q. Okay. Do you recall giving a deposition17 in any case that has very similar issues to the18 opinions or the issues you have outlined in Exhibit19 No. 2?20 A. Yes, one does stick in my mind.21 Q. Which one is that?22 A. I don't recall the name of the case, but23 I think it was with Attorney Peter Palmer.24 Q. Where is Peter Palmer out of?


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291 A. He is in an Indiana suburb of2 Louisville, Kentucky.3 Q. Do you happen to remember any of the4 parties' names in that case?5 A. No.6 Q. Do you remember about how long ago it7 was?8 A. Probably about four or five years ago.9 Q. Okay.10 A. And his firm is Schad, S-c-h-a-d, and11 Palmer.12 Q. And you think you gave a deposition13 roughly 2005, '6?14 A. Correct.15 Q. All right. What was the issue in that16 case that you think is similar to this case?17 A. I think it was a postoperative18 complication following a hysterectomy or some other19 type of surgery, but I think it was a hysterectomy.20 Q. Is Peter Palmer a plaintiff's lawyer?21 A. Yes, sir.22 Q. And did you get hired by the plaintiff23 in that case?24 A. I was retained by the plaintiff,

311 best of your recollection, in that case?2 A. No, sir.3 Q. All right. Have you gone back and4 looked at that deposition in preparation for this5 case?6 A. No. I throw out my depositions.7 Q. Oh, you do?8 A. Yeah.9 Q. All right. So you have no deposition

10 that you have given in the past?11 A. I think depositions that, you know, are12 still potentially going to trial, yeah, that, I13 would have, but I believe it was settled.14 Q. Did the Peter Palmer case -- I call it15 "Peter Palmer" because that's who hired you -- did16 that case go to trial, and is it on your list of17 trials?18 A. It did not go to trial. I believe it19 was settled.20 Q. What's your best recollection as to21 where it was pending, the case?22 A. It either would have been in Louisville,23 Kentucky, or in -- across the river in southern24 Indiana right across from Louisville.

301 correct.2 Q. Did you give a deposition then?3 A. Yes.4 Q. Do you happen to recall the defense firm5 that took your deposition?6 A. No, I don't.7 Q. I am not trying to limit you, but if you8 can -- you say that that case does bear some9 similarity to this case in the sense that it dealt

10 with postoperative complications following a11 hysterectomy, is that correct?12 A. I believe it was a hysterectomy.13 Q. How did your services come into play in14 that case? In other words, what were you offering15 opinions on in that case?16 A. Just the opinions on what the CT scan17 showed.18 Q. What did you think it showed?19 A. The CT scan showed postoperative fluid20 collections and abscess.21 Q. And do you have a recollection of how22 long after the surgery that CT was taken?23 A. No, I don't.24 Q. Did you offer any other opinions, to the

32

1 Q. And you don't remember the plaintiff's

2 name?

3 A. I'm sorry. I don't.

4 Q. Okay. I handed you a number of

5 summaries of these depositions. Have you made any

6 other notes other than Exhibit 2 and the summaries

7 of the depositions?

8 MR. SMITH: Chris, we had some of them out.

9 You called it the pizza box.

10 MR. GRIMES: Oh, yeah, the pizza box.

11 MR. SMITH: It's cardboard-ish.

12 MR. GRIMES: It was sitting right on top of

13 the notes.

14 MR. MOLZEN: Folders?

15 MR. GRIMES: No. I mean --

16 MR. SMITH: It's a longer white piece of

17 paper, cardboard, like the back of a shirt box.

18 MR. MOLZEN: I have never seen that.

19 THE WITNESS: All right.

20 MR. GRIMES: Off the record.

21 (WHEREUPON, discussion was had off

22 the record.)

23 BY MR. MOLZEN:

24 Q. Okay. We took a little bit of a break.


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331 Mr. Smith is going to look for an additional piece2 of writing on the back of a piece of cardboard.3 Other than that, do you think you have4 written down anything else? Other than Exhibit 2,5 the summaries of the depositions, the back of that6 piece of cardboard, anything else you think you7 have written out by hand?8 A. No, sir.9 Q. Anything you have typed up and sent10 anybody E-mail-wise?11 A. No, sir.12 Q. Have you talked with any physicians here13 at this hospital or anywhere else about this case?14 A. No.15 Q. Have you ever seen Dr. -- I'm sorry.16 Have you ever spoken with Emma Caldwell?17 A. No, sir.18 Q. Has your extent of contact with other19 parties, other people, been the two attorneys that20 have retained you, John Kurtz and David Smith?21 A. Yeah, these are the only two individuals22 I have spoken to in regards to this case.23 Q. All right. So you have never examined24 Emma Caldwell or talked with her or had her up here

351 $2500?2 A. That's correct.3 Q. How is that broken down? Is it $500 per4 hour that you were charging?5 A. That's correct.6 Q. So up until the time of this bill, which7 was on June 16th of this year, you had8 approximately five hours in the case, correct?9 A. I had spent five hours of professional

10 time in the case.11 Q. All right. And since June 16th, how12 much additional time do you believe you have put13 into the case?14 A. It would just be these last few15 weekends.16 MR. GRIMES: Here it is.17 BY MR. MOLZEN:18 Q. Okay. So from June -- up until19 June 16th, you had about five hours, which is20 reflected on that Exhibit No. 5, and since June21 16th, you have put in how much time looking at22 these additional depositions?23 A. The additional depositions and talking24 with Mr. Smith, probably 12 hours.

341 to look at her, correct?2 A. No.3 Q. All right. Let me hand you Exhibit4 No. 5, which is -- looks to be a bill. Is that the5 only bill you have generated so far?6 A. That's correct.7 Q. Do you know how much time you have8 totally in the case thus far?9 A. Well, up until they sent me all these

10 new depositions, that was the extent of it, but11 boy, since I got all these new depositions,12 probably about 10 or 12 hours.13 Q. When you say "new depositions," is that14 this pile here?15 A. I mean the depositions, yeah, I guess.16 Q. All right. We went through a list of17 depositions that you have looked at so far. There18 aren't others somewhere else that you are still19 waiting to go through, is that correct?20 A. I hope not.21 (WHEREUPON, discussion was had off22 the record.)23 BY MR. MOLZEN:24 Q. Okay. Other than that bill for -- is it

361 Q. Okay. So there's another $6,000 bill in2 the works, is that correct?3 A. That's correct, in addition to the4 deposition time today.5 Q. You know, you may have supplied us with6 something, but I don't recall seeing what you7 charge for your attendance at trial. How does that8 work?9 A. That's $500 an hour, as well, but it

10 also -- it's $500 for travel time, you know, not11 sitting at O'Hare Airport, but the time on the12 plane and, you know, to and from the courthouse,13 and I guess if I meet with the attorneys14 beforehand, it would also be $500 hourly.15 Q. Help me understand. So if you leave16 your office here in Chicago, come to Kansas City,17 and happen to testify that very same day, how are18 you going to charge for that?19 A. Suppose I'm on the stand for two hours,20 that would be two hours there, and if I meet with21 the attorney maybe for three hours beforehand, so22 that would be another three hours, and -- let's23 see. If the flight time to Kansas City was an hour24 and a half or two, it would be that, as well, but


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371 not just sitting at the airport, if I stay2 overnight watching TV the night before.3 Q. All right. Do you happen to know what4 the trial date is for this case?5 A. No, I don't.6 Q. So you haven't reserved any particular7 date when you're planning to come to Kansas City?8 A. I didn't know there was a trial date.9 Q. Okay. You know, I forgot to ask you10 about Exhibit 4, on your trial testimony, is that a11 fair, complete, and accurate list of the cases as12 best you can recollect where you offered sworn13 testimony in a court of law since 2000?14 A. Yes, sir.15 Q. Okay. I have not marked these things,16 but it looks to me like you were supplied with a17 photocopy of a letter from our office dated18 March 15th that enclosed a disk. Is that correct?19 A. That's correct. I believe this was20 actually sent to me with the CDs that came in the21 spring.22 Q. All right. Let me just real quickly --23 would it have been these CDs?24 A. Yes.

391 A. Correct.2 Q. Did you go through it?3 A. No, because I had the imaging that I4 needed. This is in case there were some studies5 that I was missing.6 Q. Okay. So as it pertains to any one of7 the disks that are within the two and a half inch8 notebook, those images have never been loaded by9 you on a computer of any kind to view, correct?

10 A. That's correct.11 MR. SMITH: Say that again. I'm sorry.12 BY MR. MOLZEN:13 Q. Yeah. The images that are on the disks14 within this two and a half inch notebook have never15 been loaded by you on a computer to view, correct?16 A. That's correct.17 MR. SMITH: I don't want there to be any18 misunderstanding. The ones in the notebook are19 identical to the ones on the disk, and he has20 loaded from the other disk, although it's the same21 studies, for the computer to look at today.22 MR. MOLZEN: I understand. I'm asking23 specifically if he's loaded the disks that are in24 this notebook on the computer to view.

381 Q. Just so the record is clear --2 A. Plus -- oh, excuse me -- plus the CDs3 with the medical records.4 Q. Okay. Did those come with this letter,5 as well?6 A. I don't recall.7 Q. Okay. Let me hand you what have been8 marked as Exhibits 26 through 31, and again, I'll9 ask you, are these the CDs that you were supplied

10 with earlier this spring?11 A. Yes.12 Q. Okay. There is another notebook --13 MR. MOLZEN: Craig, can I have that?14 BY MR. MOLZEN:15 Q. There's another notebook called16 "Caldwell radiology book," and the court reporter17 has been kind enough to mark the insert of this as18 Exhibit No. 12, which looks to be a summary of some19 of the contents of the notebook.20 When did you get this?21 A. Actually, Mr. Smith brought it last22 night.23 Q. Okay. So this just came to you last24 night?

401 BY MR. MOLZEN:2 Q. You have not?3 A. No, I have not.4 Q. All right. Have you spent any time5 whatsoever looking at the notebook?6 A. No, I have not.7 Q. Is it important to you in any way in8 terms of your opinions here?9 A. No.

10 Q. All right. Now, I have -- I think I11 marked the radiology -- where is that pile of12 radiology --13 A. Reports?14 Q. -- reports. That actually goes with a15 stack of medical records that's about -- what do16 you think -- five or six inches thick?17 A. That's right.18 Q. Have you gone through all of these19 medical records that have been printed off?20 A. Yes.21 Q. Oh, you have?22 A. Oh, yes.23 Q. Okay.24 MR. SMITH: I think there's a deposition in


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411 there.2 (WHEREUPON, a certain document was3 marked Gore Deposition Exhibit4 No. 33, for identification, as of5 9/22/11.)6 BY MR. MOLZEN:7 Q. Mr. Smith was just kind enough to point8 out that there was a deposition contained within9 there. It's Craig Elson's deposition. I have had10 the court reporter mark it as 33. Have you had a11 chance to look at that one yet?12 A. Yes, I have a little checkmark here, so13 I have.14 Q. I didn't see a summary of his testimony.15 Did you summarize that in any way?16 A. I guess I did not.17 Q. Okay. Now, back to Exhibit No. 25,18 which is about a five or six inch stack of medical19 records, you have gone through all of these?20 A. Yes.21 Q. When did you go through all these22 records?23 A. I went through all the records when I24 first got the case, and then I went through the

431 with your highlighting?2 A. That's correct.3 Q. Is there any other portion of that stack4 of medical records which you have highlighted?5 A. I have highlighted something on the6 discharge summary.7 (WHEREUPON, a certain document was8 marked Gore Deposition Exhibit9 No. 35, for identification, as of

10 9/22/11.)11 BY MR. MOLZEN:12 Q. All right.13 A. And what says "consults" is actually an14 operative note from Dr. Webb on 1/25/08.15 Q. All right. We'll have her mark that16 since it's stapled.17 (WHEREUPON, a certain document was18 marked Gore Deposition Exhibit19 No. 36, for identification, as of20 9/22/11.)21 BY THE WITNESS:22 A. I believe that's all that I have23 highlighted.24 BY MR. MOLZEN:

42

1 highlights of them more recently, you know, within

2 the last week.

3 Q. Have you written on any page of the

4 medical records?

5 A. I believe so, yes.

6 Q. All right. Let me hand them back to

7 you. I am going to put a rubberband around them so

8 they don't pull apart. There you go.

9 A. I have written and highlighted on the

10 progress notes.

11 Q. Okay. And the reason you highlighted

12 certain material in the progress notes was for what

13 reason?

14 A. They were helpful in formulating my

15 opinions.

16 MR. MOLZEN: All right. This is actually

17 contained within Exhibit 25, but I am going to

18 separately mark the progress notes.

19 (WHEREUPON, said document was marked

20 Gore Deposition Exhibit No. 34, for

21 identification, as of 9/22/11.)

22 BY MR. MOLZEN:

23 Q. The court reporter has marked it as 34.

24 Would you agree that's the section of the records

441 Q. Okay. And just so the record is clear2 when we go back to read this at some later date,3 what was collectively marked as Exhibit 25, which4 is about a six inch stack of medical records, we5 have pulled out some things that you have6 highlighted. We first talked about the progress7 notes, which I think are marked as Exhibit --8 A. 34.9 Q. -- 34. And then 35 is the discharge

10 summary that you also highlighted, correct?11 A. That's correct.12 Q. And then there's a section that is13 stapled together called "consults" that the court14 reporter was kind enough to mark as 36, and you15 highlighted what was previously marked as16 Exhibit 43, the operative report, correct?17 A. Yes. This is the operative report of18 January 25th, 2008.19 Q. All right. We are going to put --20 anything else that you are aware of that you may21 have highlighted or outlined in any of these22 medical records?23 A. I don't believe so.24 Q. Okay. We are going to put those back


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451 with that stack so we don't mess up your file.2 Okay?3 And then you have brought with you a set4 of CVs or curriculum vitaes or resumes, some people5 might call it, and the court reporter has marked6 that as Exhibit 32. Is that your curriculum vitae?7 A. Yes, it is.8 Q. Is that curriculum vitae fair and9 complete and accurate as to your professional10 endeavors, including where you work, where you've11 been educated, and what you're currently doing?12 A. Yes, it is.13 Q. All right. Any additions, deletions,14 subtractions that you need to make to that in order15 to make it up to date and current?16 A. Well, this last weekend I spoke in17 Vancouver, so I gave four lectures there, which I18 have not put on this.19 Q. Okay. What were those on?20 A. Okay. One was staging colorectal21 cancer. The second one was multi detector CT of22 the acute abdomen. The third one was incidental23 lesions of the abdomen and pelvis. And the fourth24 one was extraluminal abdominal gas, and it was

471 think they're relevant. So the first -- the first2 two, 90 and -- what was it -- 93, how do you think3 No. 90 and 93 bear on the issues, as well as4 No. 136, on your CV?5 A. Well, in 90 and 93, I would have spoken6 about the CT appearance of postoperative abscesses7 and, I believe, their natural history and the8 treatment of them, as well. And then where do we9 go next?

10 Q. 136.11 A. On 136, discussing the various types of12 fluid collections in the belly, which our patient13 had, and here I describe the various different14 types of fluid collections.15 Q. Okay.16 MR. SMITH: What was that last number?17 MR. MOLZEN: 136.18 BY THE WITNESS:19 A. And then Reference 200, "Pathways of20 abdominal and pelvic spread" -- "pelvic disease21 spread," I talk about how tumors and infections in22 the belly and pelvis spread.23 And then 201 is actually the same24 chapter as the earlier one but in the second

461 subtitled, "Looking for Air in All the Wrong2 Places."3 Q. Okay. Your CV lists quite a number of4 publications. Have any -- have you written5 anything that you think is particularly instructive6 on the issues in this case?7 A. Yes, sir.8 Q. Okay. What might that be? And I'll9 give you back your CV so you can find it for us.

10 A. On Page No. 22, Reference No. 90, and11 this is a chapter on CT of the pelvis, and I would12 have -- so this is Page 22, Reference No. 90, and13 it's a chapter on CT of the pelvis in which I would14 have talked about postoperative -- or pelvic15 abscesses.16 Then on the same page, Page 22,17 Reference 93, there's a reference called "CT of18 postoperative abdominal complications."19 Q. Any others you think are relevant?20 A. Yes. Yes, there are.21 Q. Okay.22 A. Page 26, Reference No. 136, "Ascites and23 peritoneal fluid collections."24 Q. As you go through these, tell me how you

481 edition of my book, and so this was an updated2 chapter.3 BY MR. MOLZEN:4 Q. So 201 updates No. 136?5 A. That's correct.6 Q. All right.7 A. Page 217 -- I'm sorry -- Reference8 No. 217 on Page 34, "CT diagnosis of postoperative9 abdominal complications," and so that's at the top

10 of the page of 34, and I guess the CT appearance of11 postoperative complications, which would include12 abscess.13 Q. What else?14 A. And then on Page 36, References 245 and15 246 are updated chapters of -- this is the third16 edition of my book and just updated chapters from17 the second and first editions.18 Q. Well, interestingly, I was going to ask19 you if you got the third edition done. It looks20 like you have.21 A. Yes.22 MR. SMITH: That was just 2008. Keep going.23 BY MR. MOLZEN:24 Q. Tell us real quickly how 245 and 246 you


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491 believe kind of bear on some of the issues in this2 case?3 A. Well, again, I talk about the spread of4 abdominal and pelvic infections and tumors and how5 pus and tumor cells spread in the peritoneal6 cavity, and then I talk in No. 246, you know, about7 the differences on imaging of different types of8 intraperitoneal fluid collections.9 Q. Very good. What else?10 A. Page 37, 249, I talk about the acute11 abdomen, and I talk about abdominal abscess in12 that, as well. I don't believe I spoke13 specifically about postoperative complication but14 just postoperative abscess.15 Q. All right.16 A. Okay. And that's it for the17 publications.18 Q. All right. You have a number of19 presentations that you have done. Do you recall20 any of the presentations that would bear21 specifically on the issue you're here to talk22 about?23 A. Yes, sir.24 Q. Before we do that, can you tell me

511 to Mr. Smith, we can talk about whether I can take2 a look at it. Okay?3 MR. SMITH: I'm sure we don't have any4 problem. Just get it to me, though, first.5 THE WITNESS: All right.6 MR. MOLZEN: Yeah, give it to him, and he'll7 send it on to me then. I appreciate that.8 BY MR. MOLZEN:9 Q. Any other that you know you have current

10 possession of either a slideshow or written11 materials that would bear on some of the issues in12 this case?13 A. That's the one that comes to mind that14 would be the most pertinent and the handiest.15 Q. All right. You were also supplied with16 a copy of the petition in this case, is that17 correct?18 A. That's correct.19 Q. And then I see that you were given20 some -- well, actually, three other exhibits,21 Exhibit No. 52, Exhibit No. 46, and Exhibit 52. I22 guess you were given it twice. Those were supplied23 to you, as well, correct?24 MR. GRIMES: Just for the record, those are

501 whether or not you still have written materials2 from any of the presentations?3 A. Some, I might.4 Q. Why don't we do it this way to speed5 things along. If you have written materials of6 some of the presentations that might bear on some7 of the issues, let's talk about those. All right?8 A. All-righty. I am not sure I would9 because nowadays, you know, for the last five or

10 six years, rather than giving hard copy, you know,11 to the attendants of the courses, they actually put12 them on a flash drive or a CD-ROM.13 Q. Do any of these look like they would be14 pretty pertinent?15 A. Well, actually, the lecture -- why don't16 I E-mail the lecture to you that I gave in17 Vancouver this weekend talking about postoperative18 air, you know, free air. I think that's probably19 the closest, because I talk about --20 Q. How long is that lecture?21 A. I can make it from 20 minutes to 4522 minutes. There, they gave me 35 minutes for that23 lecture, and there were about 120 slides.24 Q. Okay. And if you would get that first

521 exhibit numbers from the prior deposition as2 opposed to not a new exhibit number today?3 MR. MOLZEN: That is correct.4 BY THE WITNESS:5 A. So should I read which number they are?6 BY MR. MOLZEN:7 Q. No. We have them in the record. But8 you were supplied with those. Did you look at9 those?

10 A. Yes, I did.11 Q. All right. You were also supplied with,12 were you not, Exhibit No. 16 with some attached13 records?14 A. Yes. These were given to me by15 Mr. Smith last night.16 Q. Did you look at that?17 A. Yes, I did.18 Q. Was there anything of particular19 importance or help to you in forming any of the20 opinions outlined in Exhibit 2?21 A. Well, I actually knew where the white22 count was going up and down and the left shift, so23 it actually put it in a very neat form, but it24 provided nothing new for me in terms of formulating


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531 my opinions.2 Q. How about Exhibit No. 15; what is that?3 A. Okay. This is the patient's urinalysis4 reports from 1/17/08 and 1/24/08.5 Q. Have you seen that?6 A. Yes, I have.7 Q. And does it factor into your opinions as8 outlined in Exhibit 2?9 A. Again, I had seen this before. Yes, it10 does.11 Q. In what way?12 A. That I am just looking at, you know, the13 bacterial content and, you know, the amount of14 blood in the urine, and it was not terribly15 impressive on 1/24/08 or 1/17/08.16 Q. Both of these last two exhibits we were17 just talking about, these were not documents you18 prepared; they are documents that were prepared for19 you by plaintiff's counsel, correct?20 A. Actually, the first page was prepared by21 Mr. Smith. The second page is actually from the22 medical record.23 Q. Correct. That is not something you24 prepared, correct?

551 A. Okay. And then so that's at 5:45 a.m.2 on the 19th.3 And then at 11:00 a.m. on 1/19/08, her4 white blood cell count was 15,000, which is getting5 up there, and now she's got 80 percent neutrophils,6 and so, again, that's too high.7 And then on 1/20 her white blood cell8 count goes up to 20,200, which is pretty high, and9 then it says she's got 67 percent segmented

10 neutrophils and 28 percent bands, b-a-n-d-s. So11 that means there's a pretty big infection going on12 there.13 Q. Do you have any training as an14 infectious disease physician?15 A. No, sir.16 Q. Have you ever performed surgery?17 A. No, sir.18 Q. What are you board certified in?19 A. Diagnostic radiology.20 Q. Is that all the board certifications21 that you hold?22 A. That's correct.23 Q. In other words, you are not board24 certified as a pulmonologist, correct?

541 A. The first page, no, sir.2 Q. And then Exhibit 14 is what?3 A. Okay. Exhibit 14 is the CBC, or4 complete blood count, on Miss Caldwell over a5 series of days. I did not prepare it, but it's6 from the medical record, which is listed on the7 next page, which I had seen prior to his8 preparation of this.9 Q. Anything new or surprising to you in

10 that summary?11 A. No, sir.12 Q. Anything important to you in that13 summary that factors into one of your seven14 opinions?15 A. Yes.16 Q. Tell us what it was.17 A. Okay. The fact that on 1/19, which is18 the day -- first day postop, I believe, Miss19 Caldwell's white blood cell count was 12,500, which20 is slightly elevated. She also had 81 percent21 neutrophils, which is elevated. Usually we don't22 like to see it greater than 60. It depends upon23 the lab. Should I keep going?24 Q. Yes.

561 A. Correct.2 Q. Or board certified in infectious3 disease, correct?4 A. That's correct.5 Q. Nor in surgery, correct?6 A. Correct.7 Q. And have you treated patients in the8 context of an obstetrician?9 A. No, other than 35 years ago as a medical

10 student.11 Q. In other words, you are not a board12 certified OB/Gyn, correct?13 A. No.14 Q. All right. Let me hand you Exhibit15 No. 13. What is that?16 A. These are the blood culture results on17 Ms. Caldwell.18 Q. Okay. Anything that you saw in19 Mr. Smith's summary that was provided to you there20 that you weren't already aware of?21 A. No.22 Q. Anything of particular importance to one23 of your seven opinions that's reflected on that24 exhibit?


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571 A. Yes.2 Q. What is it?3 A. Okay. That Ms. Caldwell had Bacteroides4 fragilis, and then the final diagnosis was made5 with this bug on 1/24/09. However, they did Gram6 stain, g-r-a-m stain, on 1/21. They actually did7 it on three blood cultures. And then they also did8 blood cultures on 1/22 and 1/24 and 1/23, and these9 were positive.10 Q. Okay. How is that important to your11 opinions in this case?12 A. Well, I think it's very key because it13 implies or it indicates that there is a big-time14 GI-related abscess going on in the body.15 Q. When do you believe or have you tried to16 form an opinion as to when she actually developed17 the infection that she had in her abdomen? Have18 you attempted to figure that out?19 A. Yes, I have.20 Q. And what date do you pinpoint as the21 date in which she had an infected abdomen?22 A. I think we definitely know on -- you23 know, the blood cultures were drawn on 1/20/09, so24 we know she had, you know, a big-time abdominal or

591 person who did the greatest amount of dissection of2 the gynecologic organs from the bowel.3 Q. So you don't know?4 A. I suspect it was probably the5 gynecologist because she said that she did -- there6 was a serosal injury when she was doing her7 dissection.8 Q. Do you believe the perforation was in9 the location of the serosal injury?

10 A. It might have been, but it is quite11 likely it may not have been.12 Q. Does the serosal injury appear13 radiographically on any of the films that you have14 looked at?15 A. No, sir.16 Q. Why doesn't it show up?17 A. Because a serosal injury is just a tear18 that was sutured up of one of the layers of the19 colon wall, and, you know, it's barely visible to20 the naked eye, and it would certainly be beneath21 the resolution of a CT scan.22 Q. A serosal injury such as described in23 the operative report is not the kind of injury that24 would enter the lumen of the intestine, correct?

581 a GI-related abscess that day. You know, the2 results weren't known until the next day and the3 final until four days later, but we know definitely4 on that day.5 But the fact that her white count was6 going pretty high on 1/19 makes me suspect that,7 you know, there was a significant infection going8 on there on the 19th.9 Q. Have you attempted to figure out what

10 was causing this infection?11 A. Yes, sir.12 Q. And what do you believe that was?13 A. The infection was due to a perforation14 of the GI tract, and since it's Gram-negative rods,15 it would be of the colon and in the region of the16 sigmoid, and ultimately, on the 25th surgery, they17 did find a one-inch hole in the sigmoid colon.18 Q. Who perforated her sigmoid colon, in19 your opinion?20 A. Which physician?21 Q. Yes.22 A. I guess there were two surgeons involved23 on the 20 -- on the 18th, and that would be24 Dr. Harris-Baugh and Dr. Webb, so I guess it's the

601 A. That's correct.2 Q. And hence, you can't even see it3 radiographically on any of the films that you have4 seen, correct?5 A. That's correct.6 Q. Where is the first clear evidence on any7 radiographic film of the perforation, what date?8 A. The perforation -- again, I have not9 seen the CT -- well, first of all, we certainly see

10 evidence of it on the CT study of 1/24.11 Q. Can you see the perforation?12 A. No, but I can see the footprint of it in13 that I see some extravasated contrast material from14 the colon sitting outside of the colon in the15 pelvis. So there's a leak at that point.16 Q. We're going to look at the films in a17 minute. Have you prepared any kind of a slideshow18 or summary of the films that you believe show the19 evidence or footprint of the perforation?20 A. No, I have not, but I anticipate doing21 one before trial, and I understand that, you know,22 we have to present it to you well before trial.23 Q. You will?24 A. Yes.


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611 Q. And I would ask that you -- you, no2 doubt, will be working with Mr. Smith, but I would3 like to be made aware of that before you come and4 testify as to a certain number of films and slides5 that you say show evidence of the footprint of a6 perforation. All right?7 A. That's correct. In fact, we'll send you8 the CD.9 Q. Have you attempted to go through and do10 you have any listing here on this table in any of11 these documents of the particular slices that12 support any of the opinions outlined in Exhibit 2?13 A. No, I did not, but we can do it as we14 look at the images.15 Q. All right. Do you see anything16 radiographically prior to January 24, 2008 --17 A. 2008.18 Q. You know we may want to -- I need to19 rephrase this because I think several times you20 have used the year 2009. I think you used it about21 four times. And I believe the year is actually22 2008, is it not?23 A. Yes, sir. I'm sorry.24 Q. Let me rephrase my question. Do you see

631 A. All-righty. Because this is in the same2 area where she found adhesions on her study of --3 on her surgery of 1/18/08. So she circled on her4 Deposition Exhibit No. 42 kind of the same area5 where the adhesions were is actually where the perf6 subsequently was found. So on Exhibit No. 18 she7 is circling, you know, where the adhesions were,8 and that's the same area that's outlined as where9 the hole was found on 1/25/08.

10 Q. Just so the record is clear, you first11 referred to Exhibit No. 17 where you believe she's12 marked an area that indicated some injury?13 A. To the sigmoid colon on 1/25/08.14 Q. And then you have looked at Exhibit15 No. 18, which is a diagram, and you have16 interpreted what she has marked on there as17 evidence of adhesions that she encountered on18 January 18th, is that correct?19 A. That's correct.20 Q. And putting those two things together,21 you believe that there were adhesions in the area22 where the perforation was ultimately found?23 A. That's correct. And as I recall,24 reading her deposition and her operative note,

621 any evidence on any of the radiographic films that2 you have looked at prior to January 24, 2008, where3 there is clear evidence of a perforation?4 A. No.5 Q. It's your opinion that the perforation6 occurred at the time of surgery on January 18th, is7 that correct?8 A. That's correct.9 Q. All right. You were also supplied with

10 a number of diagrams, were you not? And the court11 reporter has marked them Exhibit 17 through 24.12 Have you spent any time looking at these?13 A. Yes. These were handed to me by14 Mr. Smith last night.15 Q. Let's talk about the ones that were16 important to you in some form or fashion in forming17 your opinions. Can you direct us to any one of18 those seven diagrams and tell us which ones were19 important to you?20 A. Okay. On Deposition Exhibit No. 17 --21 and I believe this is Dr. Harris-Baugh -- she22 marked where she found the hole in the sigmoid23 colon on her surgery of 1/25/08.24 Q. How is that important to you?

64

1 there were adhesions all over the place, you know.

2 The endometriosis had caused fibrosis and adhesions

3 of her ovaries and her uterus, you know, to the

4 adjacent bowel.

5 Q. That was something that was

6 unanticipated?

7 A. Yes.

8 Q. Did you see any indication in the

9 operative report of January 18th where that

10 resulted in some form of a complication in the

11 surgery?

12 A. Let's see. May I see the operative

13 report, please?

14 Q. Sure. I think it's in this pile.

15 A. Actually, I think it's there.

16 Q. Okay.

17 MR. SMITH: I am trying to keep it organized

18 here.

19 BY MR. MOLZEN:

20 Q. Just so the record is clear, what are

21 you looking at there?

22 A. Actually, I am looking at Exhibit

23 No. 36, which I think I may have inadvertently put

24 it with counsel's preop history and physical


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651 examination, and the operative report of 1/25, so I2 don't think I have quite found it quite yet.3 I am now reading from the operative note4 of Dr. Sharon Harris-Baugh, and this is from the5 study of January 18th, 2008, and she says during6 the process of dissection, the serosas seemed to be7 damaged, and at that time she asked Dr. Webb to8 come in and help her with lysis of adhesions,9 and -- let's see. Can I see my deposition10 summaries? Here we go.11 MR. SMITH: While you're looking at that, I am12 going to take a little break.13 (WHEREUPON, a recess was had.)14 (WHEREUPON, a certain document was15 marked Gore Deposition Exhibit16 No. 37, for identification, as of17 9/22/11.)18 BY THE WITNESS:19 A. The question -- or the concern was how20 did endometriosis, the presence or lack thereof,21 impact on the surgery and the complication. On22 Page 40 of her dep, Dr. Harris-Baugh says the23 endometriosis made the surgery extremely difficult.24 On Page 44 she said she didn't know

671 believe that there was a perforation that was2 sustained in that operation on the 18th? Anything3 else you rely on other than the operative report4 and that deposition testimony?5 A. And also what's happening with the6 patient clinically, the fact that, you know, she7 developed, you know, the fever and the increased8 heart rate and the high white count and the shift9 to the left.

10 And then, you know, on the 20th we had11 Bacteroides growing in the blood. You know, we12 didn't know the organism at that time, but on the13 20th there were Bacteroides growing in the blood,14 and just seeing, you know, the natural history of15 postoperative abscesses and dealing with hundreds16 of them over the years.17 Q. Okay. Do you think you have had an18 opportunity to tell me where it is that you have19 relied upon or reviewed material that causes you to20 believe that the perforation was sustained during21 that operation?22 A. Yes. On the basis of the depositions,23 on the basis of the patient's clinical history, on24 the basis of where the hole was found in the colon

661 about the endometriosis preoperatively, and she2 says endometriosis led to bowel injury, and it3 leads to adhesions, too.4 On Page 46 she said -- the doctor said5 she saw endometriosis immediately.6 And on Page 47 she brought in Dr. Webb7 as she suspected she nicked the bowel at the time8 she saw the adhesions to the bowel. And that's9 what I recall from reading my notes on Dr. Sharon

10 Harris-Baugh.11 BY MR. MOLZEN:12 Q. All right. You indicated on Page 46 she13 said she thought she nicked it. Can you tell where14 on Page 46?15 A. No, I said on Page 46 she saw16 endometriosis immediately.17 Q. Okay. And where is it that you think18 she testified she nicked it?19 A. Okay. Page 47 -- let's see. I don't20 see it here, but I recall reading it. Maybe I put21 the wrong page number down.22 Q. Okay. Based on your review of the23 January 18th operative report and her deposition,24 have you outlined for us the reasons why you

681 on the 24th.2 Q. And then the way we got on to this3 subject is we were comparing Exhibit 17 and 18, and4 I think we have already talked about those. Are5 there any other exhibits in 19, 20, 21, 22, 23, and6 24 that you have relied on or were important to you7 in forming any one of your seven opinions?8 A. On Exhibit No. 60, and I think it was9 Dr. Webb, he said there was a serosal tear, and I

10 don't know if he's outlining small bowel or whether11 he's outlining sigmoid colon here.12 Q. And just so the record is clear, it's13 Webb Exhibit 60, and it's our exhibit here numbered14 what?15 A. 19.16 Q. No. 19. Thank you. How is that17 important to you then, that you are not sure what18 he's outlining?19 A. Well, it seems like there was a big mess20 there because of all the endometriosis, and I can21 imagine how difficult it was having all these22 endometrial implants, all this scarring, all this23 fibrotic tissue, and so it was just a mess down24 there, and this is all in the same general ball


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691 park where you have to do that dissection.2 Q. Any of the other exhibits important to3 you in your seven opinions?4 A. Not that come to mind now, no.5 Q. Okay. At the break the court reporter6 marked as Exhibit 37 kind of a long piece of7 cardboard that has some notes on it.8 Is that the one item that you had also9 written that you were looking for earlier, but we10 have now found and marked as an exhibit?11 A. That's correct.12 Q. Any other -- and that's Exhibit 37?13 A. Yes.14 Q. Are there any other handwritten15 materials other than the summaries of the16 deposition, Exhibit No. 2, which is the outline of17 your opinions, and Exhibit 37, which were some18 handwritten notes? Anything else?19 A. No.20 Q. All right. Now, on 37 you have written21 some random thoughts. What was the purpose in22 keeping this?23 A. This is just to remind me of points that24 were brought up in, actually, various depositions.

711 why -- you know, we are pouring a lot of fluid into2 the patient, and not a lot is coming out, so where3 is this fluid going, so even if no perf, I am just4 saying, yeah.5 Q. Let me look at it a bit more, and then6 we'll be done with it.7 A. Sure.8 Q. You have the medical term "sepsis"9 written, and you have "what is it."

10 A. Yes.11 Q. What's that a reference to?12 A. Okay. Well, because in terms of13 Dr. Harris-Baugh did not think the patient was14 septic, you know, prior to the 24th, but that15 sounds like sepsis to me, what the patient was16 experiencing.17 Q. What do you understand to be the signs18 or symptoms of sepsis?19 A. Again, I would defer to an infectious20 disease person, of course, on this, but I guess the21 beginning part of sepsis is SIRS, which is systemic22 inflammatory syndrome, in which you can have23 elevated white count or your white count can be too24 low, and I forgot the exact numbers, if it's lower

701 Q. Okay. You --2 A. I don't think it relates to any one3 specific deposition.4 Q. Is this before you prepared the5 summaries of each deposition?6 A. Correct.7 Q. Do you know when this was made?8 A. Within the last week.9 Q. When were the summaries of the

10 depositions made?11 A. Within the last week.12 Q. What is this a reference to, "even if no13 perf"?14 A. Okay. "Even if no perf," that was to15 remind me that, you know, suppose the surgery had16 gone absolutely swimmingly, suppose there was no17 endometriosis at all, suppose lickety-split,18 beautiful operation. The fact that, you know, you19 have got this fever, you have got this white count,20 and you have got this anemia postoperatively would21 have -- at least should have raised some alarm22 bells that, hey, what's going on in the pelvis23 here, or why does this patient have a fever, why is24 the hemoglobin and hematocrit so low, and also,

721 than a certain number or higher than a certain2 number.3 Also, if you have a fever that's higher4 than a certain number but, also, if your5 temperature is too low, that can be a sign of it,6 as well.7 And then, also, you can have an abnormal8 blood pressure, and also, I think you actually call9 it sepsis when you actually say, "Hey, there's a

10 real good source here," either the patient has got11 a pneumonia or there's a big abscess in the belly12 or something like that.13 Q. That's what you understand sepsis to be?14 A. Sepsis is that you have got an infection15 that's going on, and in her case, you know, she's16 got bacteria growing in her blood, and she's got17 high white cell count, and she's got tachycardia,18 and her heart rate -- and her respiratory rate is19 high, and that's my interpretation of sepsis, but20 again, I defer to an ID person.21 Q. What do you believe the tachycardia is22 signalled by, heart rate of what?23 A. Okay. Let's see. You know, I am24 concerned when it's over 100.


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731 Q. And then increased respiration?2 A. Okay. You know, if it's -- you don't3 like to see it over 20, but 24, 25, then you get4 concerned.5 Q. And then temperature, what do you think6 septic on a temperature would be?7 A. All right. I guess, by definition, I8 think if it's too low -- I forgot the exact9 number -- if it's too low or too high, I think if10 it's over 101.5, but I have to look it up, and11 again, I defer to an infectious disease person.12 Q. And did you see anything with regard to13 her blood pressure that you thought clearly14 signalled that she was septic?15 A. No. Actually, I think her blood16 pressure was pretty good on the 20th, 21st, and17 22nd, but I think, you know, when you start really18 affecting the blood pressure, when that starts19 tubing, then I think you got septic shock.20 Q. Is there a difference between sepsis and21 septicemia?22 A. Sepsis -- I think I would have to defer23 to an infectious disease person on that.24 Q. All right. And then with regard to

751 offer opinions at the time of trial concerning2 whether she was or was not septic?3 A. No.4 Q. Any other notes like Exhibit No. 37 that5 you have anywhere else?6 A. No, sir.7 Q. All right. Have we gone through8 everything that you have brought with you to this9 deposition?

10 A. We haven't gone through the images.11 Q. Well, and I was going to ask you about12 that. You have disks here, but you have referred13 to some others that you have loaded. And you tell14 me, since I don't want to keep you here all night,15 what would be easier. Would it make more sense to16 go through Exhibit 2 and ask you about the details17 of your opinions, or would it make more sense to18 have you show me the slides you think that support19 the opinions outlined in Exhibit 2?20 A. Why don't we actually do it side by21 side.22 Q. Why don't we do that. I will let you23 teach me.24 A. Okay. Let's go to my first opinion, and

741 end-stage organ failure, did you see any end-stage2 organ failure in any of her vital signs?3 A. Well, in her vital signs -- well,4 actually, in her BUN and creatinine, that would --5 you know, she went into renal failure by6 approximately January 24th.7 Q. So you think she was in renal failure on8 the 24th?9 A. As I recall, her BUN and creatinine was

10 going up, and that's why they didn't give her IV11 contrast to do the CT scan, and I think that's why12 they obtained a renal consult at that time.13 Q. Is there any other information that you14 saw in the 6,000-plus pages of medical records that15 would cause you to believe that she was septic on16 or before January 24th, 2008?17 A. Well, you know, when you got Bacteroides18 growing in your blood, that's not a good thing, and19 that's a big-time Gram-negative rod, and that, with20 your high white count and your abnormal temperature21 and your elevated respirations, you know, that's22 concerning for sepsis, but again, I would defer to23 an infectious disease person.24 Q. I'd take it then you aren't going to

761 I say the preoperative CT of 1/9/08 shows a big2 uterus with fibroids and large ovarian cystic3 masses which subsequently proved to be4 endometriomas. And you know, the big uterus -- let5 me start turning it on while I'm talking.6 Q. Sure. Doctor, while we do this, since7 many people will probably review your deposition,8 it would probably -- since we won't have a slide9 that's part of that transcript, if you could refer

10 to the slice number or the slide number, however11 you want to refer to it, so that we can track it if12 we had the disk, that would be much appreciated.13 A. Yes, sir.14 Q. So let's talk about Opinion No. 1 and15 the large uterus.16 A. Should I read the entire first17 disclosure?18 Q. I'm sorry?19 A. Should I read the entire first20 disclosure, and then we'll go into the imaging that21 supports that?22 Q. Yes. Yes.23 A. Okay. To continue, "shows a big uterus24 with fibroids and a large" -- "and large ovarian


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77

1 cystic masses, which proved to be endometriosis" --

2 "endometriomas, that abut and compress the adjacent

3 sigmoid colon, pelvic small bowel loops, and cecum.

4 No fat plane is discernible between these

5 gynecologic structures and the bowel. Each of

6 these segments was at risk for inadvertent injury

7 at the time of a subtotal abdominal hysterectomy,"

8 and so I am going to abbreviate in the future as

9 TAH-BSO, but actually, it was a subtotal since they

10 left the cervix in, but for the sake of ease, I am

11 going to say TAH-BSO.

12 All right. We are now looking at the

13 imaging performed on Emma Caldwell.

14 THE WITNESS: Off the record. Sorry.

15 (WHEREUPON, discussion was had off

16 the record.)

17 BY MR. MOLZEN:

18 Q. Tell us the date of the film, who

19 interpreted it, and what kind of film it is.

20 A. Okay. This is a -- oh, the one who

21 interpreted it -- can I get the radiology reports?

22 Q. Let me just set this up. So we are

23 talking about your first opinion, we are talking

24 about a large uterus with some fibroids, and you're

791 Emma Annette Caldwell on January 9th, 2008.2 And we see -- start seeing the right3 ovary, which is way too big, on Set No. 2, Image4 No. 65, and we see that extending all the way south5 to Image No. 83, and again, I am going to be6 talking exclusively about Set No. 2 now.7 Q. All right.8 A. On Image No. 65 we see this right9 ovarian mass is just plastered -- just there's not

10 an inch of daylight, an inch of fat.11 Q. Do you have a pointer where you can12 demonstrate that for us?13 A. Sure. There's not an inch or -- an inch14 of daylight between this right ovarian cyst --15 cystic mass and the cecum. You know, usually you16 like to see some fat between the ovary and the17 cecum, but this thing is plastered right next to18 it. I don't see any fat.19 All right. Now let's look at the left20 ovary, and we see the left ovary starting on Image21 No. 68, and again, everything is Set No. 2, and we22 see this big left ovary going south and ending at23 Image No. 86. Now, this big ovary -- we see this24 big left ovary just plastered against the proximal

781 going to show us the slides that you believe that2 demonstrate that, is that correct?3 A. I am going to be showing you the slides4 that show the big uterus, the -- which contains5 fibroids. I am going to be showing you big ovaries6 that subsequently proved to be big endometriomas.7 And then I am going to show you, you know, the8 small bowel and colon loops, sigmoid loops, that9 are just plastered against these gynecologic

10 structures. There is not an inch of daylight of11 fat between these structures and these gynecologic12 structures.13 Q. Before you get started, can you give us14 an idea about how many different slides you have15 under this one opinion?16 MR. SMITH: I don't think they're slides.17 They're the whole film.18 BY THE WITNESS:19 A. They are going to be a series, and I'll20 probably give you a range, which shows --21 BY MR. MOLZEN:22 Q. Okay. Very good. Go ahead.23 A. Anyway, we are looking at the CT scan24 that was performed at Research Medical Center on

801 sigmoid colon on Image No. 73, 74, 75, 76, 77, 78,2 and finally we see some daylight here, and by3 "daylight," I mean some fat.4 We're looking for -- you know, when you5 are going to be doing a resection or dissection,6 you like to have a nice fat plane between the bowel7 and the ovary and the uterus, but here there's no8 fat plane there. It was subsequently found in9 surgery that, you know, it was all adhesions from

10 the endometriosis.11 Q. Can you point at that?12 A. Okay. So on Image No. 80, we can13 actually see some fat, this black area, interposed14 between the patient's left ovary and the distal15 sigmoid colon and proximal rectum.16 Okay. Although there is daylight17 between the left ovary and the distal sigmoid18 colon, there is no daylight between the uterus --19 and now let's talk about the uterus. We see the20 uterus in Miss Caldwell on Images No. 74 to Image21 94, and you can see her uterus is very22 inhomogeneous. Usually you like to see a uterus23 that's kind of uniform in density and in texture,24 but here we can see some dark areas, we can see


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811 some light areas, and these are the patient's2 fibroids that we are seeing.3 Q. Are the darker areas the fibroids?4 A. The central area is actually some fluid5 in her endometrium, and they found endometrial6 thickening at the time of pathology, and so here we7 see endometrial thickening on Image No. 87, so this8 is this dark area in the center of the uterus.9 Q. You have seen a few uteruses before10 radiographically?11 A. Yes.12 Q. Is this fairly atypical?13 A. For a fibroid uterus, no.14 Q. And maybe I worded that wrong. This15 isn't a normal uterus, is it?16 A. No, it is not.17 Q. This uterus has a number of fibroids,18 and it has a lot of variation in wall thickness,19 would that be fair?20 A. That's correct. And also, the21 endometrium is too wide, as well.22 Q. Go ahead.23 A. All right. We see an absence of24 daylight; that is, we don't see a nice fat plane

831 A. You would like to but not necessarily.2 Q. Okay.3 A. You typically do, but it's not4 essential.5 All right. On Images No. 74 through 80,6 we see the mid and distal sigmoid colon again just,7 you know, smack dab against the back aspect of8 the -- back and top aspect of the uterus. And once9 you finish writing, I'll show you.

10 Okay. So here's little bit of the11 sigmoid colon, and we are coming down, and again,12 there's no daylight between this and the back13 aspect of the uterus.14 Q. Why do you believe that you can't find15 any daylight there?16 A. Well, now I know because -- through the17 benefit of hindsight, I know that Dr. Harris-Baugh18 found adhesive disease there, but, you know,19 typically you see it, but in some patients you just20 don't see it.21 Q. Is this extensive adhesive disease?22 A. I don't know if I can make that call23 prospectively or retrospectively.24 Q. You don't have an opinion one way or the

821 between the small bowel loop, which is a segment of2 ileum, which is this white area. It's filled with3 that positive contrast material. So on Image4 No. 74 we see the ileum and not a spec of daylight,5 no dark area, between this and the top of the6 uterus.7 Okay. We are following the uterus down,8 and on Image No. 79 and 80 and 81 we again see9 small bowel just plastered against the front part

10 of the uterus.11 Q. When you use the word "plastered," do12 you mean stuck?13 A. Well, I know now that, you know, it is14 stuck, but I don't see any daylight there, and so15 having the benefit of knowing subsequently what the16 operative findings -- can you say prospectively17 here that, you know, they're going to find18 endometrial fibrosis and scarring? I think you can19 suggest there is some endometriomas which are20 responsible for the ovarian masses, but I don't21 think prospectively you can say -- you know, in22 some individuals you just don't see the fat plane.23 Q. Would you expect to have fat between24 these planes?

841 other?2 A. No, I don't.3 Q. Okay. Go ahead.4 A. But certainly Dr. Harris-Baugh described5 that at the time of her surgery.6 All right. Now, in view of the fact7 that we have got the cecum and these ileal loops8 and the sigmoid colon just very closely adherent to9 these structures, you know, unfortunately, they

10 could inadvertently be injured during the time of a11 TAH-BSO. You're less likely to get an injury if12 there's a nice juicy fat plane between your bowel13 and your gynecologic structures. But you don't see14 it here.15 Q. Any other slides that you need to show16 us with regard to your first opinion?17 A. No.18 Q. And just to be clear for the record,19 those all -- all of the slide numbers you were20 talking about come from Set No. 2 on the21 January 9th, 2008, CT?22 A. That's correct.23 Q. Okay. Go ahead and go to your next24 opinion and tell us what slides support that.


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851 A. Okay. And I guess this is kind of a2 variation on the theme. In order to perform, I3 state, the subtotal TAH-BSO, Dr. Harris-Baugh4 needed to dissect these closely adherent bowel5 loops from these gynecologic structures, and, you6 know, there's certainly well less than an inch of7 space between these bowel loops and these8 gynecologic structures.9 So again, it's the same images that I10 was alluding to earlier. There's not a spec of11 daylight, no black area, between these bowel loops12 and the uterus.13 Q. So for your support radiographically for14 Opinion No. 2, you would point to all the same15 slides out of Set 2 that we talked about with16 regard to Opinion No. 1?17 A. That's correct.18 Q. Okay. Go ahead.19 A. All-righty. For No. 3 I guess I'll sit20 down. And in my Opinion No. 3 I state that the21 sigmoid colon perforated, allowing colon contents22 to leak into the peritoneal cavity before 1/20/0823 but most likely at the time of surgery.24 And this opinion is actually based on

871 A. I don't know -- ask an infectious2 disease person, but I am not aware of Bacteroides3 being in degenerating fibroids, and often in4 infected fibroids you can see gas bubbles, but I5 don't see anything like that on the CT study.6 Q. Tell me, you offer two variations of7 this opinion that the perforation was likely there8 before January 20 but more likely at the time of9 surgery. Do you have an opinion based on a

10 reasonable degree of medical certainty when it was11 that the perforation was actually sustained?12 A. The perforation within a fairly high13 degree of medical certainty occurred at the time of14 the original surgery on the 18th.15 Q. Okay. And you believe that was16 Dr. Harris-Baugh that caused the perforation?17 A. More likely than not.18 Q. What does reasonable medical certainty19 mean to you?20 A. In Illinois a reasonable degree of21 medical certainty is 51 percent.22 Q. Is that the standard that you have23 applied to your opinion formation in this case?24 A. Some, I have reasonable, and some, I

861 the fact that Miss Caldwell was having a fever, and2 on the 20th, she was growing Bacteroides fragilis3 out of her blood. It was not identified at that4 time, but she had Bacteroides onboard at the time5 of the first set of blood cultures, which is6 January 20th, 2008.7 Okay. And when you have the Bacteroides8 growing at that time, you got something big-time9 going on in your pelvis, something related to the

10 gut. All right. And so with the benefit of11 knowing her clinical condition, the presence --12 that there was Bacteroides, the fact that a hole13 was found in that area, you know, on the surgery of14 the 25th, that is what leads me to come up with the15 third opinion.16 Q. Which is?17 A. That the sigmoid colon was perforated,18 and it most likely occurred at the time of the19 original surgery.20 Q. Were any of the fibroids or endometrial21 pockets that were handled and surgically removed --22 could any of those actually have contained the23 infectious organism which later she was diagnosed24 with, do you know?

881 have a high degree of medical certainty.2 Q. Where you have something less than a3 high degree of probability, will you let us know4 that?5 A. That's correct.6 Q. So on this particular opinion, No. 3,7 you hold that to what degree; 51 percent?8 MR. SMITH: I object, asked and answered.9 BY THE WITNESS:

10 A. No. To the fact that it occurred on11 the -- before the 20th, at the time of, to a high12 degree of medical certainty. As to whether13 Dr. Webb or Dr. Harris-Baugh caused the initial14 injury, I think more likely than not 51 percent.15 BY MR. MOLZEN:16 Q. And I might as well ask you with regard17 to No. 1 and No. 2, how do you hold those opinions;18 to 51 percent?19 A. A high degree of medical certainty.20 Q. And what does a high degree of medical21 certainty mean to you?22 A. Well, I can't really quantify it but,23 you know, just looking at these things for 34 years24 now and, you know, having the benefit of hindsight


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891 and going through the images and the medical2 records and the depositions, very high degree of3 medical certainty.4 Q. Is that the best you can explain it?5 A. Yes. I wish I could say it's 79.86 percent, but I can't.7 Q. I have read some of your earlier8 depositions, and I note that many times when9 lawyers have asked you how you conduct a review of10 a case, you typically like to do what they call a11 cold review, meaning you only look at the films12 first. Did you do that here?13 A. Yes.14 Q. Which films did you look at first?15 A. I looked at the CT studies.16 Q. All right. And we went through those17 earlier. I think they were the ones taken on the18 9th and then the 24th, correct?19 A. And the pulmonary embolism study, as20 well.21 Q. All right. You reviewed those after22 talking with Mr. Smith?23 A. Yes.24 Q. How did you know what you were looking

911 Q. Well, and, in fact, when you looked at2 any of these films, you did have the benefit of3 hindsight, did you not? You knew it was in4 litigation?5 A. Correct.6 Q. You knew the patient, now plaintiff, had7 hired a lawyer, correct?8 A. Correct.9 Q. And you knew there was some issue as to

10 the films and what role they may have played in11 either diagnosing or being involved in uncovering12 her injury, correct?13 A. That's correct. But again, as I said,14 when I am working with the plaintiff or defense15 side, I try to put myself in the same position as16 the radiologist, you know, as best as I humanly17 can.18 Q. Opinion No. 4 is what?19 A. Okay. Okay. The CT scan of 1/24/0820 shows a complex high density fluid collection, or21 abscess, next to the sigmoid colon, and this22 extends into the upper abdomen, and it has a23 density ranging between 24 and 54 Hounsfield units.24 Q. Can you show us?

901 for? Did he tell you?2 A. The other images that he showed me were3 cervical spines and things unrelated to, you know,4 my area of expertise, so that's what I came to.5 Q. Well, by virtue of the fact that you6 were talking to a plaintiff's lawyer and by virtue7 of the fact that you were asked to look at certain8 things, what did you understand -- what did you9 understand you were supposed to be looking for?

10 A. When either a plaintiff's or defense11 attorney calls me -- you know, especially the12 plaintiff's attorney love to spill the beans,13 "Dr. Gore, I am calling about a missed lung cancer14 here. Would you mind reviewing the images?" So I15 got to stop them right in their tracks, and so I16 want to be in the same position the radiologist is17 when interpreting the images.18 Q. Do you believe you were in the same19 position as either Dr. Gubin or Dr. Bhargava when20 they looked at these films?21 A. You know, I try my best, you know, to be22 in their position, but you are quite right; when23 there's a medical/legal case involved, you know,24 they are not going to send you a normal case.

921 A. Sure.2 Q. Thank you.3 (WHEREUPON, discussion was had off4 the record.)5 BY MR. MOLZEN:6 Q. And again, just tell us what the date is7 of the film and the set or slides you are looking8 at.9 A. This is, again, a CT that was performed

10 at Research Medical Center on Emma Annette11 Caldwell, and this was a CT of the abdomen and12 pelvis that was performed on January 24th, 2008.13 I guess I should add for the prior study14 that that was performed with oral and intravenous15 contrast, so the study we looked at before was done16 with oral and intravenous contrast. By the 24th17 Miss Caldwell's kidney function was not good, and18 so that's why they did not give her any intravenous19 contrast material.20 And I'm just starting from the first21 image. We can see some positive contrast material22 in the esophagus, and we see that on Slices No. 123 through 15. And again, this is -- everything is on24 Set No. 2 on this patient.


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931 And then on Images 16 through 35, we see2 it in the stomach. And then on Images 21 through3 94 we see this positive high density contrast, this4 big white area, and we see that in the descending5 colon and also in the rectum and sigmoid colon.6 All-righty. On this examination we also7 see some high density fluid, and this is this area8 along the left lateral aspect of the descending9 colon, and the descending colon is this white area.10 And then we see this other complex fluid collection11 that contains gas bubbles, and we see this nicely12 on Image No. 79, and this is to the left of the13 distal sigmoid colon.14 And then on Images No. 87 through 93 we15 see some high density material in a fluid16 collection in the left side of the pelvis, and then17 we also see another high density fluid collection18 more deeply and centrally in the pelvis on Images19 No. 83 through 90, and --20 Q. When you say more deeply in the21 pelvis --22 A. More centrally and further south in the23 pelvis.24 Q. Is it close to any particular structure?

951 was"? No, I can't do that.2 Q. Is Image 81 probably the best view or3 slide that you can find where you believe there4 could be some extravasation and a possible5 perforation, or are there other images?6 A. Oh, in terms of perforation, actually7 there are other images that are very convincing for8 the perforation, and on --9 Q. Before you move on, you would agree then

10 81 does not show the perforation then?11 A. No, it shows -- it shows a track of12 barium into the wall, but does it show that13 contrast actually pouring out of the wall? No.14 But it shows the footprint of -- you know, it shows15 the abscess down there. It shows that abnormal16 fluid collection that's got -- you know, it's17 complex, it's got some hyperdense areas, so that's18 the abscess, but do I see that's exactly where the19 hole is? No.20 Q. Are you going to move to something else,21 or can you show us those other images now?22 A. Oh, can I show you the other images that23 show the -- in terms of perforation, you mean free24 air in the belly?

941 A. Oh, yeah, it's in the bed where the2 uterus used to be, and it's right next to the3 proximal rectum and distal sigmoid colon.4 Q. Thank you.5 A. And on Image No. 81 I see a little6 streak of this high density barium, which may be --7 it could be an ulcer, it could be the site of where8 the hole is, but I can't be entirely sure. It's9 this little -- white little area coming through

10 here.11 Q. That's almost -- that's in the top half12 of the --13 A. No. So this is the sigmoid colon.14 Q. All right.15 A. And so it's mid to distal sigmoid colon.16 So as I said, I can't be sure if that's where the17 leak is.18 Q. Show us again where you think it is.19 A. I see -- no, I see this little track of20 contrast going into the wall, but I don't see frank21 extravasation of contrast material at that point,22 but that's the most suspicious thing I see. As I23 said earlier, can I say, "Oh, yeah, that's exactly24 where the leak was. That's exactly where the hole

961 Q. Well, what I was hoping to see is your2 best selection of images you think that are as --3 that are as suspicious as No. 81 -- although they4 may not show the perforation, they are, in your5 mind, suggestive of the point of extravasation and6 perforation.7 A. Since we are up north, why don't I just8 show you where there's free intraperitoneal air.9 Q. Okay.

10 A. And try to remember these images because11 I am going to show you on the CT study that was12 done on January 21st, the pulmonary embolism CT,13 there was no air back at that point.14 So on CT air is black-black. So I'm15 looking at Image No. 4 here. You see the blackness16 here in the lung and the blackness here in the17 lung.18 And then on Images No. 11, 12, 13, 14,19 15, 16, 17, 18, 19, 20, 22, we see these black20 pockets of air up interposed between the liver and21 the right hemidiaphragm. We also see smaller22 pockets of air interposed between the left lobe of23 the liver and the left hemidiaphragm.24 Q. And how is that significant?


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971 A. Well, the fact that there is -- the fact2 that there is not gas there three days before makes3 me concerned, you know, there is active perforation4 going on in the belly that the -- that there was a5 contained perforation down south back on the 18th,6 it had not worked its way up the belly by the time7 of the patient's chest CT study of the 21st, but8 now it's all over the belly; the gas and the pus9 are all over the belly.10 Q. You have called it free air, correct?11 A. Correct.12 Q. Meaning that it could move anywhere in13 the peritoneal cavity over time, correct?14 A. That's correct. Okay.15 Q. Any other images show free air that's16 suspicious for the perforation?17 A. Okay. We see free gas within -- or gas18 bubbles within these abscess collections in the19 pelvis, and they can be seen on Images No. 85 --20 this little black dot here --21 Q. We are still in Set 2, correct?22 A. Yeah, these are all in Set 2. On Image23 No. 85. And then we also see three black dots on24 Image No. 82 again, another black dot, another

991 when, more than two weeks prior, when the patient2 actually had the CT study to look at her fibroids3 and to look at her ovaries. That stuff was still4 sitting in her colon, believe it or not.5 Q. How could that happen?6 A. Huh? I don't know how to explain it.7 Q. What makes you believe -- what image, by8 the way, is showing it still sitting in her colon?9 A. Okay. We see this dense barium -- or

10 dense contrast material within the colon on Image11 No. 19 extending all the way down to her rectum.12 Okay. And I think the reason that, you13 know, this is important is that, you know, had we14 done a CT scan earlier, you know, which I'm15 suggesting in another one of my opinions, that this16 contrast would have been very helpful in showing17 either extravasated contrast, or maybe at that18 point it might have even showed the leak, where it19 was coming from.20 Q. All right. You started with Image21 No. 19, and how far do you go from there?22 A. Well, actually, I am going all the way23 south. I am going from -- all the way from the24 splenic flexure of the colon down the descending

981 black dot, these three guys over here. And then on2 Image No. 79 we see a black dot that shouldn't be3 there and also on 79 another black dot that4 shouldn't be there. And we see on Image No. 76 a5 black dot that shouldn't be there, and to the right6 of the midline, we see another black dot where it7 doesn't belong.8 And then other findings, we see this9 abnormal fluid collection -- this complex fluid

10 collection actually rising up to the diaphragm or11 into the upper abdomen to the left of the midline.12 All this is this infected fluid.13 Q. What images are we on?14 A. Okay. So I am talking about -- these15 are Images No. 21 down through Image No. 76. We16 see this large fluid collection to the left of the17 midline, and part of it is in the left paracolic18 gutter, and we see it extending all the way up19 through the region of the splenic flexure of the20 colon.21 Another important finding here is that22 the contrast we see here in the colon wasn't23 actually from the stuff that Ms. Caldwell drank24 that day. That stuff actually was from way back

1001 colon into the sigmoid down to the rectum.2 Q. And what image do you finish up with?3 A. Okay. I am seeing that contrast going4 all the way down to actually Image No. 96.5 Q. Okay. And what is it about the contrast6 imaging that makes you believe it is from two weeks7 earlier?8 A. Okay. First of all --9 Q. And if there's a good slide between 19

10 and 96 that would explain why you don't believe11 it's new contrast, new being the 24th as opposed to12 two weeks before, can you show us that?13 A. Yes. In order for -- unless there was a14 fistula present, there is no way that contrast15 given by the mouth which is sitting in the16 esophagus, which is sitting in the stomach, which17 is sitting in the top part or proximal part of the18 small bowel -- we don't see any of that contrast19 really in the southern part of the small bowel or20 jejunum, and so the only way that contrast could21 have gotten there would be a fistula if it were22 given that day.23 So we have contrast up north. Then we24 bypassed a whole lot of the small bowel, and then


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1011 by some miracle we have got contrast in the colon.2 So either there's a fistula between the small bowel3 and colon at that point, or much more likely that4 contrast was left from before. And actually, the5 radiologist reported on the study that I have --6 this is -- can I finish my point?7 Q. Sure.8 A. Thank you. The radiologist reported --9 okay. On the x-ray of 1/23/08, which I have not10 visualized, Dr. Gubin reports a small amount of11 barium is present within the rectum. Okay. So how12 did that barium get there? This was the day before13 we gave Miss Caldwell some contrast material, and I14 don't believe she was given barium during the15 course of her hospital stay. It had to be there16 from beforehand.17 Q. Beforehand being when?18 A. The time of her first CT, which was --19 Q. January 9th?20 A. -- 1/9, yes, the 9th.21 Q. Do you entertain the possibility that22 maybe she had a fistula on the 9th?23 A. No, I have not, but I didn't see -- the24 small bowel contrast and the colonic contrast

1031 A. Okay. Other areas where we see gas2 where it shouldn't be is on -- and this is in the3 midline, and we are seeing these slivers of4 blackness which are gas bubbles on Images No. 68,5 69, 70, and 75.6 Q. Any others?7 A. Let's see. There's some gas bubbles8 where they shouldn't be on Image No. 93 and also9 91, but these don't look like they're intra-

10 peritoneal. I think these may be in the space of11 Retzius, and that's actually an extraperitoneal12 space in front of the bladder, and when you do a13 hysterectomy, you can get gas bubbles there.14 Q. So you entertain the possibility that15 the gas bubble shown on 93 and 91 may have been16 introduced at the time of the surgery?17 A. That's correct.18 Q. Okay. Any other slides that demonstrate19 free air or unexpected gas bubbles?20 A. Again, I don't know if I had mentioned21 Slides No. 37 -- there's a little pocket of gas22 there -- and 36 and 34.23 Q. And are those showing free air?24 A. These are in the peritoneal cavity.

1021 seemed appropriate. No, I don't consider that.2 Q. So how would it have gotten into the3 colon then if it was there from the 9th?4 A. No, the patient drank the contrast5 material, and because of sluggish motility -- I6 don't know due to what; maybe it's her MS, some7 other abnormality -- that contrast was just sitting8 there. And sometimes I have seen it there for9 months, and sometimes it can become so hard and

10 impacted that it actually leads to a bowel11 obstruction in somebody, but it didn't occur,12 happily, in Ms. Caldwell.13 Q. That would distinctly raise the14 possibility that she might be suffering from ileus,15 as well?16 A. Or that she has -- yes, or that she has17 some motility disorder of the GI tract, correct.18 Q. And you introduced the concept of MS.19 Do you know whether or not MS can affect bowel20 motility?21 A. I have seen it, yes.22 Q. All right. Go ahead and tell us the23 rest of the slides that support your fourth24 opinion.

1041 Q. Are these gas bubbles or free air?2 A. I guess they're kind of the same thing.3 Q. Okay. Well, you were drawing a4 distinction when you used those terms. Can I use5 both of those terms interchangeably; a gas bubble6 is free air?7 A. No, but you -- a gas bubble when it's in8 the peritoneal cavity is free air, but you can have9 it extraperitoneally, or you can have it in the

10 space of Retzius, in which case it's not free air.11 Q. And you see these on 36, 37, and 34, and12 they're inside the peritoneum?13 A. Those look like they're inside the14 peritoneal cavity, correct.15 Then there's some gas bubbles that are16 in her subcutaneous tissues, and the fact that she17 had surgery -- let's see. This is -- 18 to 24 is18 six days. It is possible that that still could be19 normal, seeing some subcutaneous gas at that point.20 Q. Any good slides there you can point us21 to?22 A. Oh, sure. Let's see. We see these gas23 bubbles on Images 86, 85, 84, 83, 82, 81, 80, 77,24 76, 75, 74, and just -- do you want me to talk


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1051 about the other findings on CT?2 Q. I am trying to stay focused right now on3 Opinion No. 4. Are you done with the slides that4 support your fourth opinion?5 A. Yes, sir.6 Q. Can we go to No. 5, and then maybe we'll7 get into this again, the same with the CT, but can8 you read the fifth opinion and tell us which slides9 you think support it?10 A. Okay. This is more based on her11 clinical and laboratory findings.12 Q. Okay.13 A. And in my fifth opinion I say there was14 compelling clinical and laboratory findings that15 should have led to a CT of the abdomen on 1/21/0816 but certainly by, you know, 1/22/08.17 And I mean, what were these things that18 were compelling? First of all, she had an elevated19 white count, a left shift, her heart rate was fast,20 her respiratory rate was elevated. You know, by21 the 22nd, they knew she had positive blood22 cultures, and then also Miss Caldwell had, you23 know, anemia. You know, she lost a lot of blood24 during the time of surgery, but her hemoglobin and

1071 to, you know, an internist or renal person or a2 hospitalist, but that -- boy, she is really --3 where is all that fluid going? And I often get4 requisitions that, first of all, this patient is5 postop. You know, we have got this fever. We have6 got this heart rate and positive blood cultures.7 Where is this stuff -- you know, why do we have8 this process?9 And remember Willie Sutton used to

10 say -- you know, he was asked, "Why do you rob11 banks?"12 "Well, that's where the money is."13 Well, where is the most likely source of14 the infection going to be? And that's going to be15 where they were operating. So if the patient had a16 high white count after shoulder surgery, I would17 take a look at the shoulder. If the patient had18 big-time belly surgery and had some postoperative19 white count and fever, I look at the belly. And so20 you got to go where they was or where they were.21 Q. Did you read Dr. Harris-Baugh's22 testimony where she didn't consider her to exhibit23 signs of a sick abdomen on the 21st or 22nd?24 A. That's correct.

1061 hematocrit were still kind of low even though they2 gave her two units of blood.3 And another thing that I found I could4 not explain is her abnormal I and O. I and O5 stands for intake and output. And so intake is6 what is the patient drinking or what is the patient7 getting through the IV. And output is what is8 coming through the nasogastric tube, what is the9 patient vomiting, what is the patient pooping, if

10 at all, and what is the patient urinating.11 And so there is something being called12 ahead on your fluids and being behind on your13 fluids. And sometimes when you have surgery,14 especially when it's difficult surgery, sometimes15 you get a little bit behind on your fluids. You16 have lost blood, and you are not up to snuff in17 maintaining your intravascular volume. So usually18 the doctors of the patient will just flood the19 system with fluid.20 So on 1/18/08 she was -- she had 3,33221 excess -- cc's of excess fluid, so she was getting22 3.3 liters more fluid than she was getting rid of.23 Okay. On 1/19 she was ahead 5,127 cc's24 or 5.1 liters. And again, I certainly would defer

1081 Q. Do you disagree with that?2 A. I didn't do the physical exam there;3 however, I am quite concerned about the4 laboratories.5 Q. All right. So if I understand your6 fifth opinion, you believe that a CT needed to be7 done on January 21st, 2008, at the latest on8 January 22nd, 2008, and you base it on the9 following seven types of vitals: Increased white

10 blood count, a left shift, an increased heart rate,11 increased respiration, positive blood culture,12 signs of anemia, and then I and O's that were out13 of kilter?14 A. That's correct. And continuing on the I15 and O's, on 1/20 she was 3.3 liters ahead, and on16 1/21 she was 3.8 liters ahead, and on 1/22 she was17 3.1 liters ahead. And sometimes saying that, you18 know, we get requisitions, "I am pouring fluid into19 this patient. I don't know where it's going."20 Q. I understand that. Any other kinds of21 vitals or signs that you believe would have22 required a CT to be done on January 21st or 22nd?23 A. No.24 Q. Okay. What kind of CT needed to be done


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1091 on those dates?2 A. A CT of the abdomen and pelvis.3 Q. Any particular type of series or views?4 A. I would have preferred to get it with5 oral and, if her kidneys were okay, intravenous6 contrast material, and since, you know, she was7 showing that white count, at our place, you know,8 they would have thrown in a CT of the chest, as9 well, to make sure there is not something nasty10 going on in the chest, and they often will combine11 a pulmonary embolism study because, you know, the12 patient's got this rapid heart rate, and so while13 you're in there, make sure there's no pulmonary14 embolism, but hey, there are positive enteric blood15 cultures. You could also make sure there's nothing16 nasty going on in the belly.17 Q. Is there a -- I am not a radiologist, so18 help me out. Is there a -- is there a term of art19 that you would expect to see in the type of CTs20 that were -- that would need to have been done on21 the 21st or 22nd? How would you expect the22 requisition to read?23 A. Okay. CT -- assuming her kidneys were24 okay and she didn't have any contrast allergy,

111

1 pulmonary embolism study on the 21st.

2 Q. You have not seen that?

3 A. Yes, I have.

4 Q. And is there anything significant about

5 that film that was done for the pulmonary embolism

6 study that factors into any of your remaining

7 opinions?

8 A. Yes. The fact that on her pulmonary

9 embolism study on 1/21/08 -- remember I was showing

10 you all those crescents of blackness, those gas

11 collections underneath the diaphragm? None of them

12 were there on the 21st. So that means that the

13 abscess, you know, the nastiness that was going on

14 in the pelvis, had not spread up to the diaphragm

15 at that point, so it was more contained, more

16 liable to be treated, more likely -- you know, very

17 likely to be able to be imminently treated at that

18 point.

19 Q. Anything else under the fifth opinion

20 that you have in the way of supportive vital signs

21 or data that you are relying on?

22 A. Not that come to mind, no.

23 Q. Okay. Let's go to the sixth opinion.

24 A. Okay.

1101 which we are not aware of, postop fever and2 leukocytosis, rule out abscess status post TAH-BSO,3 and that's what we would often get.4 Q. And the specific type of filming that5 needed to be done?6 A. All right. It would be a CT of the7 abdomen, pelvis with oral and intravenous contrast8 material, and at our place we would typically get9 one scan through the portal venous phase and then

10 one delayed image -- delayed images to look at the11 kidneys.12 Q. And then you would also include a chest13 CT?14 A. Well, I guess that depends upon your15 index of clinical suspicion. At our place I think16 the minimum would be a CT of the abdomen and17 pelvis, but since, you know, the patient had big-18 time surgery, and big-time surgery can give you19 blood clots, you know, they often add a pulmonary20 embolism study at that time.21 Q. Okay. You have reviewed all of the22 films. Those films were not done on the 21st or23 the 22nd?24 A. No, actually I think she had a CT

112

1 Q. First of all, before I move on, you tell

2 me, is there anything else under the fifth opinion

3 that you need to point me to as support for that

4 opinion?

5 A. No, sir.

6 Q. Okay. What is your sixth opinion then?

7 A. Okay. The sixth opinion is a CT of the

8 abdomen and pelvis done on the 21 -- on

9 January 21st, January 22nd, and January 23rd would

10 have shown the abscess and a complex or complicated

11 fluid collection.

12 And seeing this, when you see an

13 abscess, your first step is you try to drain it by

14 interventional radiology. And I also state here

15 that -- with a high degree of reasonable certainty

16 that, you know, had we at least done it on the 21st

17 or 22nd, you know, we could have drained that

18 abscess, and maybe we could have spared the patient

19 surgery.

20 I have seen people who have had holes in

21 their colons. They are sick, sick, sick. We drain

22 their abscess. They get a whole lot better. And

23 as if by magic, the hole heals up. But the longer

24 you wait, the more likely that is that hole is not


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1131 going to heal up, and the more likely it's going to2 spread and contaminate your belly.3 Q. Do you know whether that happened?4 A. That it -- oh, yes, it did.5 Q. How do you know that?6 A. Because I have the CT study of 1/24/087 which shows that, you know, she's got this free gas8 in her belly, and she's got this pus all over the9 place. Remember it was going up to the region of10 the splenic flexure?11 Q. And you don't believe that on 1/21,12 1/22, or 1/23 it was as widespread as demonstrated13 on the 1/24 film?14 A. That's correct.15 Q. How do you know what filming CT-wise on16 any one of those three dates would have shown?17 A. Just -- I think just 34 years of18 experience and looking at these abscesses in their19 natural progression.20 Q. With all due respect, it's a guess,21 isn't it?22 A. It's a very highly educated guess on the23 natural history and based on the patient's clinical24 imaging.

1151 Q. Would you expect it to show any fluid2 collection?3 A. Probably not because CT is far more4 sensitive in the depiction of fluid collections.5 Q. Do you know how the acute abdominal6 series was actually read?7 A. And may I get the radiology reports,8 which I think are up there now?9 Q. Okay.

10 A. Shall I read it?11 Q. No. Have you found it?12 A. Yes, I have.13 Q. Is there any mention of the term "pus"14 in that series?15 A. No, sir.16 Q. And is there any mention of complex17 fluid collection consistent with an abscess?18 A. No, sir. And again, one would not19 expect to see that on a CT scan -- on a plain20 abdominal x-ray. You need a CT or an ultrasound or21 an MR to show it.22 Q. What is the purpose in taking an acute23 abdominal series? Let me start with the simple24 question of why do they call it an acute abdominal

1141 Q. You don't have films for any of those2 days, and you're guessing at what they might have3 shown?4 MR. SMITH: I am going to object, asked and5 answered, misstates his testimony.6 BY MR. MOLZEN:7 Q. Correct?8 A. No, it's not a guess. This is an9 educated opinion based on my, you know, draining,

10 you know, hundreds of these abscess and looking at11 the natural progression of thousands of these over12 the years.13 Q. Did the chest CT show any evidence of14 complex fluid collection with an abscess?15 A. No.16 Q. Did the acute abdominal series that was17 taken both in the supine upright and included a18 chest x-ray show any complex fluid collection with19 an abscess?20 A. Nor would I have expected it to. No, it21 did not.22 Q. You would not expect that to show an23 abscess?24 A. Correct.

1161 series?2 A. An acute abdominal series is patient's3 who have an acute belly and they are worried about4 a perforation or bowel obstruction. So the primary5 reasons for getting an acute abdominal series is to6 look for free intraperitoneal gas to see if there's7 perforation. Also, you are trying to see if8 there's a bowel obstruction. Also, you can see9 kidney stones and gallstones that way, but it's

10 horribly insensitive in terms of looking for11 abscesses.12 Q. Did it show any evidence of a13 perforation?14 A. It showed that there is probable15 postoperative free intraperitoneal air, so it did16 show free intraperitoneal air.17 Q. But did it show a perforation?18 A. Did it show an exact site of19 perforation? No.20 Q. Wouldn't the fairest way to read the21 evolution of these radiological findings be that22 she perforated sometime on the evening of the 23rd?23 A. No.24 Q. In fact, we have an acute abdominal


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1171 series taken on January 23rd, and it was done in a2 supine upright and included a chest x-ray, and3 there's no evidence of a perforation on any of4 those films, is there?5 A. Well, again, one would not actually see6 the site of perforation on a plain abdominal x-ray7 or the acute abdominal series. You would need a CT8 scan or a Gastrografin enema or some type of9 contrast enema to show where the leak or the10 perforation was.11 Q. Did this abdominal series taken on12 January 23rd show any signs of ileus?13 A. Yes. The radiologist said there are14 numerous loops of small bowel with abnormal15 distension consistent with an ileus versus16 obstruction.17 Q. Can ileus lead to a tear or perforation18 in the bowel?19 A. Can it lead to a small bowel20 perforation? Yes, it can.21 Q. In fact, that happens more than doctors22 like to see, true?23 A. No, it happens more commonly in the24 colon than in the small bowel, but here, actually,

1191 is that correct?2 A. Correct.3 Q. Can you tell me what your seventh4 opinion is?5 A. In her deposition Dr. Harris-Baugh6 stated that her belief that the perforation7 occurred late, you know, maybe the 23rd or 24th,8 and the reason for that is that the sigmoid colon9 was distended, that distension led to thinning of

10 the sigmoid wall, and that ultimately caused the11 perforation.12 (WHEREUPON, there was a short13 interruption.)14 BY MR. MOLZEN:15 Q. Right before we took a break, we were16 talking about your seventh opinion, and if you17 would, you were reviewing or educating us a little18 bit about some of Dr. Harris-Baugh's testimony and19 how there were no, in your opinion, radiological20 findings to support her theory of perforation. Did21 I get that right?22 A. That is correct.23 Q. If you would, what do you understand her24 theory of perforation to be?

1181 the colon is normal in caliber.2 Q. But it does occur, correct?3 A. It can, yes.4 Q. Ileus can stretch the diameter of the5 small colon so much that it can actually tear open,6 correct?7 A. Yes, it can.8 Q. In fact, one of the things as a member9 of the American College of Radiology, when you see

10 ileus of a certain degree, that's why you are to11 pick up the phone and call the treating and12 attending physician, correct?13 A. Similarly, when you see ileus or bowel14 obstruction and you see dangerous enlargement of15 bowel, yes.16 Q. And on January 23rd the bowel was17 becoming enlarged, was it not?18 A. The small bowel, absolutely.19 Q. Anything else on your sixth opinion20 regarding the timing of CTs on the 21st, 22nd that21 you haven't already explained? Any other reasons22 why you have that opinion?23 A. Not that come to mind, no.24 Q. All right. You have one last opinion,

1201 A. Her theory of perforation -- and I2 guess, you know, this is a theory of perforation of3 both the small bowel and colon -- that when you4 have got a massively distended segment of bowel,5 that leads to ischemia of the bowel. The wall6 becomes thin. It's not getting a good enough blood7 supply. And it just pops, you know, like a balloon8 that's just been overdistended. You know, it just9 pops like that.

10 Now, this occurs far more commonly in11 the colon than it does in the small bowel. It's12 kind of unusual, you know, in the small bowel, but13 it's far more commonly seen in the colon, and in14 the colon, it's really dangerous because you have15 got all those nasty organisms sitting in there.16 The small bowel perforation, you17 certainly don't like that, but that's somewhat more18 benign because the small bowel contents are far19 more -- I wouldn't say sterile, but, you know, the20 contents are far less noxious in terms of bacteria21 than what you see it growing up in your colon.22 So Dr. Harris-Baugh is saying that our23 lady, Miss Caldwell, had a massively distended24 sigmoid colon. This massive distension led to


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1211 ischemia. This ischemia led to thinning of the2 bowel wall. The ischemia and thinning led to her3 colon to pop -- her sigmoid colon to pop.4 Q. And just so I understand you, you5 believe there's no filming -- no radiographic films6 that would support an idea that somewhere along the7 intestinal tract that it became swollen or enlarged8 to the point that it could become compromised in9 the blood flow?10 A. In terms of her colon, no. Okay? And11 if things are going to pop in the colon because12 it's distended, it usually occurs in the cecum, and13 the sigmoid is actually kind of the thickest part14 of your colon. It also has the narrowest caliber.15 So except for diverticulitis, that's not16 a common area for, you know, a blowout when you17 have got a dilated colon. And again, I harken back18 to the x-ray of -- on January 23rd, 2008, and19 Dr. --20 Q. Gubin?21 A. -- Gubin states very little gas is --22 very little gas within the colon. So if anything,23 there's not too much gas. There's very little gas24 in the colon. And he sees a small amount of barium

1231 Q. Have you seen situations where MS2 patients because of slowed bowel motility -- in3 other words, the contents in the intestine aren't4 moving downstream towards the anus fast enough or5 in a normal fashion -- have you seen situations6 where that leads to either a perforation or some7 kind of rupturing of the intestinal tract?8 A. In older individuals -- and I don't know9 whether it's due to their MS or whether it's due to

10 the fact that they're older -- they just get11 horribly obstipated. You know, they just get a12 tremendous amount of stool in their colon, and they13 get what is called a sterculic colitis, and that14 leads to inflammation, and that inflammation can15 subsequently lead to perf. So yes, I have seen16 that, but it's in older MS patients.17 Q. The amount of stool then in the colon or18 in the rectum, would that be not an unusual finding19 in an MS patient?20 A. Well, actually, in anybody it would not21 be unusual to find stool in the colon and rectum.22 Q. Well, I noticed on several of her films23 that the radiologist frequently mentioned a large24 amount of stool. Would that be something in

1221 within the rectum. So on the basis of his report,2 I don't see any evidence to support that the colon3 or the sigmoid colon was big at that point.4 Q. You have been a radiologist for quite a5 while now, have you not?6 A. 34 years.7 Q. Have you had opportunities to see8 radiographic filming of the abdomen in MS patients?9 A. Yes.

10 Q. What kind of complications have you seen11 play out radiographically in the abdomen for MS12 patients?13 A. In patients with MS, I have seen14 abnormal swallowing, I have seen abnormal15 esophageal motility, I have seen poor gastric16 emptying, I have seen hypomobility or motility of17 their small bowel and colon.18 Q. And for the jury that means -- hypo-19 motility means slow movement?20 A. Slow movement, yes.21 Q. Okay. What else have you seen22 radiographically on MS patients in the abdomen?23 A. Those are the ones that come to mind24 now.

1241 keeping with an MS patient more than an average2 person?3 A. Well, no, I think it primarily depends4 on your diet, and in this area, boy, I see lots of5 stool all the time.6 Q. All right. Any other kinds of MS7 complications you see from time to time in the8 abdomen on chronic MS patients?9 A. There may be, but none come to mind.

10 Q. Any other opinions you anticipate11 offering at the time of trial?12 A. Well, depending on what those new films13 show or -- I don't anticipate, and I understand you14 folks don't like surprises. If I do have an15 epiphany, I will certainly let you know.16 Q. All right. A couple of other questions17 real quickly. Do you have all the reports in front18 of you?19 A. The radiology reports?20 Q. Yes.21 A. For the images that I evaluated, yes.22 Q. All right. Do you have the report from23 March 28th, 2008?24 A. No, I do not.


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1251 Q. Okay. Do you have -- were you aware of2 the fact that Dr. Litwin did an AP of the abdomen3 on that date and found no acute findings in her4 abdomen? This would be about -- just a moment.5 This would be about 63 days after the second6 surgery that Dr. Webb performed, about two months7 later, and it was read as no acute findings in the8 abdomen. Have you seen that before?9 A. Yes.10 MR. SMITH: What's the Bates number on that,11 lower right-hand corner? Caldwell RMC RAD 62.12 BY THE WITNESS:13 A. Yes, I see this.14 BY MR. MOLZEN:15 Q. Have you seen the film?16 A. No, I have not.17 Q. All right. And then have you seen any18 of the subsequent films after March 28, 2008, that19 document fistulas?20 A. No, I have not.21 Q. For instance, have you seen the film or22 the report dated April 15th?23 A. I have not seen the images nor have I24 seen this report.

127

1 note did I know that she had developed

2 enterocutaneous fistula.

3 Q. Have you seen the June 30th report

4 and/or film indicating that those fistulas were

5 severe enough that they ended up communicating with

6 her sigmoid colon?

7 A. No, I have not seen these images or

8 report.

9 Q. Have you seen the CT pelvis done on

10 June 30, 2008, that showed pooling contrast in the

11 area of a fistula that was communicating with the

12 sigmoid colon? Have you seen that film?

13 A. No, sir.

14 Q. So you have not seen that report?

15 A. Nor image, correct.

16 Q. All right. And were you familiar with

17 the fact that on June 30th they did a fluoroscopic

18 guided ultrasound to put in a PICC in her vena cava

19 to deliver antibiotics to treat these newly

20 developed fistulas? Were you aware of that?

21 A. No, sir.

22 Q. Can I have those back?

23 A. Yes.

24 Q. You have not seen any of these before?

126

1 Q. Would you have any understanding as to

2 where those fistulas came from or why she developed

3 them?

4 A. Well, in somebody who has got -- you

5 know, had Bacteroides fragilis growing in your

6 belly and you have got a contaminated belly for

7 five or six days and you have had holes in your

8 small bowel and colon, I think that's a wonderful

9 substrate for the development of fistulas.

10 Q. Do you know when she was discharged from

11 Research Medical Center?

12 A. Yes. I think I have Dr. Harris-Baugh's

13 discharge summary, and I think it was sometime in

14 May.

15 Q. Do you know whether or not she was free

16 of sepsis by the time she was discharged in May?

17 A. I don't recall.

18 Q. Have you seen the June 19, 2008, fistula

19 study that was done approximately 144 days after

20 Dr. Webb's second surgery?

21 A. No, I have not.

22 Q. You were unaware of the fact that she

23 developed additional fistulas at that time?

24 A. Just from reading Dr. Harris-Baugh's

1281 A. No.2 Q. All right. And you haven't seen the3 films before?4 A. No.5 Q. Any idea why she would have gone on to6 develop additional fistulas after being cured of7 sepsis?8 A. Well, I believe I guess I would talk --9 defer to a general surgeon or an infectious disease

10 person, but, you know, it's probably hard to clean11 up a belly, you know, that's been contaminated by12 fecal material, and I would imagine it's hard to13 clear that infection.14 MR. MOLZEN: I am going to pass you now to15 Mr. Craig Grimes. He is going to have questions16 for you. I may come back with just a few more, but17 it's his turn to ask questions.18 EXAMINATION19 BY MR. GRIMES:20 Q. Doctor, I just have a few follow-ups.21 If I lose you because I'm jumping around, let me22 know.23 A. I understand.24 Q. All right. You mentioned earlier you


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1291 are not a hospitalist, correct?2 A. That's correct.3 Q. How often in your practice as a4 radiologist do you assess a patient's labs?5 A. Well, actually, we now have electronic6 medical record, and actually, on every ER case that7 I read when I am working the 5:00 to 11:00 shift, I8 actually go into the electronic medical record and9 see what's up and see, you know, if a patient has10 abnormal aldolase levels. So I do it on a routine11 basis, and that's one of the benefits of the12 electronic medical record.13 Q. You talked about this whatever inches of14 medical records that you have looked at in this15 case to be here today and testify. Do you16 routinely as a radiologist go through a patient's17 entire chart?18 A. No, sir.19 Q. When did you start doing medical/legal20 work?21 A. In the mid 1980s.22 Q. And I may have missed some of these23 earlier. What is your best estimate of the number24 of cases you have reviewed since the mid 1980s?

1311 Q. Did they settle?2 A. Three --3 Q. Were any of them settled?4 A. Three were settled, and two -- two were5 settled, and the other three were dropped.6 Q. Did you give a depo in any of those?7 A. Yes.8 Q. Was that -- what county?9 A. Cook County.

10 Q. Were any of those cases involving issues11 similar to this case?12 A. No.13 Q. In cases in which you were sued, did the14 plaintiff's identify experts critical of your care?15 A. Yes.16 Q. Did you disagree with those experts and17 their opinions?18 A. Yes.19 Q. You talked about the depositions you20 have read. I didn't hear Dr. Hafer's name. Did21 you ever read Dr. Hafer's deposition?22 A. No, I did not.23 Q. And are you a member of American College24 of Radiology?

1301 A. In review cases probably maybe 350, 4002 cases.3 Q. When you review currently, did you say4 it's $500 an hour?5 A. That is correct.6 Q. And deposition is also $500 an hour?7 A. That's correct.8 Q. The list that was marked as an exhibit,9 you said, was from 2000 to current?

10 A. That's correct.11 Q. How many times have you testified at12 trial, what's your best estimate, prior to 2000?13 A. Well, actually, 18 total and equally14 divided, interestingly, 50/50 defense and15 plaintiff.16 Q. I'm sorry. 18 total before 2000 or 1817 total your entire clear?18 A. 18 total my entire career.19 Q. Okay. Have you ever been sued?20 A. Yes.21 Q. How many times?22 A. Five times.23 Q. Did any go to trial?24 A. No.

132

1 A. Yes, I am.

2 Q. Have you signed the expert witness

3 affirmation statement that's put out by the

4 American College of Radiology?

5 A. I wasn't aware that one was -- I am

6 actively involved in American College, and I am not

7 aware of that.

8 Q. Do you know Dr. William Banzhaf,

9 B-a-n-z-h-a-f?

10 A. Yes, I do.

11 Q. Has he referred patients to you, or have

12 you read films of his patients?

13 A. Yes, I have.

14 Q. Did you suggest to the plaintiff's

15 attorneys that they consult with him?

16 A. Actually, they wanted the name of a

17 top-notch OB/Gyne individual, and so I recommended

18 his name.

19 Q. Have you and he talked about this case?

20 A. No.

21 Q. Over the years have you ever received

22 any cases from an expert service called Rieback,

23 R-i-e-b-e-c-k?

24 A. Not that I am aware of.


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1331 Q. Do you know how the plaintiffs got your2 name?3 A. That, I don't know.4 Q. Have you reviewed other cases in5 Missouri or Kansas?6 A. In Missouri, yes.7 Q. Do you remember the names of -- I think8 one of them you mentioned was Sean McGrevey that9 you talked about off the record. Do you remember10 any other lawyers in Missouri?11 A. Yes. I have looked at a number of cases12 for Brown & James, and I have worked most closely13 with Bob Rosenthal. And then Scott McCormick and14 Sean McGrevey, you know, in the Kansas City area.15 MR. SMITH: I think it's Scott Adam.16 THE WITNESS: What did I say?17 MR. SMITH: Scott McCormick.18 THE WITNESS: Scott Adam, right.19 BY MR. GRIMES:20 Q. You testified earlier that -- if I21 misstate it, I apologize -- that you definitely22 knew from the blood cultures on January 20th that23 there was a big-time abscess. Do you recall that?24 A. Yes.

1351 bowel; they can also come from the vagina, correct?2 A. That's correct.3 Q. Your opinion as to where the perforation4 was, was that on the patient's right side or on her5 left side?6 A. It's in the sigmoid colon, and the7 sigmoid colon is in the midline, and it goes to the8 left. So on what wall did the perforation occur?9 I'd have to look at, you know, the operative note

10 and the surgical pathology note to recall11 specifically where they found that hole.12 Q. From the films that you looked at, you13 aren't able to tell?14 A. Remember I said there was one suspicious15 area there, but since I didn't see active leak16 there, I can't state with certainty.17 Q. And I know this was covered. This is18 one of those paranoid lawyer things. You don't19 intend to offer standard of care opinions as to20 Dr. Marjara or Dr. Hafer at the time of trial,21 correct?22 A. Correct.23 MR. GRIMES: I have nothing else.24

1341 Q. How was it from the blood cultures that2 you know it was an abscess as opposed to just3 fluid?4 A. It's either an abscess or infected fluid5 or free fecal material in the peritoneal cavity,6 but there's something really nasty going on when7 you got Bacteroides growing in your blood.8 Q. So it may not necessarily be an abscess;9 it could be some other item such as you said free

10 fluid or fecal material?11 A. No, infected free fluid or maybe free12 fecal material.13 Q. And you talked about the Bacteroides.14 You knew that because those were available,15 correct?16 A. Yeah, in hindsight, I know that, yes.17 Q. When the blood is drawn, it takes a18 number of days before the identity of the organism19 is able to be determined, correct?20 A. That's correct. However, I believe by21 the 22nd, the doctors were informed that we have22 got some Gram-negative rods, probably enteric23 organisms.24 Q. And enterics can come not just from the

1361 FURTHER EXAMINATION2 BY MR. MOLZEN:3 Q. Just a couple of follow-up questions.4 Is there any film that you have seen --5 and when I say film, any series of films or6 particular slides -- that clearly and unequivocally7 demonstrates a perforation prior to January 25th?8 A. Yes, the CT study of the 24th.9 Q. And maybe you can help me, or maybe you

10 can refresh my recollection. Was there a11 particular image that you thought actually shows12 the opening where there is a hole into the13 intestinal wall?14 A. No. As I said, there was one area that15 I was suspicious, but do I see it actively leaking16 out? No, I do not.17 Q. And I think -- let me see here. Can we18 find that again, that one image where you think --19 A. Sure.20 Q. And I hate to put you to it, but I want21 to make sure when I leave here I have a good22 understanding of what you think comes the closest23 to being suspicious or at least shows the footprint24 of the perforation.


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1371 A. Okay. And so this is not to a2 reasonable degree of medical certainty.3 Q. Okay.4 A. Okay. On Image No. 81 I see some barium5 or some contrast material going into the wall of6 the sigmoid colon, but as I said, I don't see it7 leaking out.8 Q. That's 81 of Set --9 A. Of Set No. 2, and this is the CT study10 done on January 24th, 2008.11 Q. Okay. Is that particular image the best12 one that you can find that is highly suspicious for13 the perforation?14 A. Well, you know, we see the footprint of15 the perforation all over the belly, all over the16 abdomen and pelvis. We see these complex fluid17 collections. We see these gas bubbles and stuff18 like that.19 Q. And I am not fussing with you, but I am20 talking about the actual opening.21 A. Okay. And as I said, that's my --22 that's the best image, but is that absolutely, you23 know -- to a reasonable degree of medical24 certainty, is that the point where the perf

1391 Q. And can you state that to a reasonable2 degree of medical certainty?3 A. Yes.4 Q. All right. What do you -- what is your5 current practice like?6 A. Okay. My current practice is -- well,7 actually, believe it or not, it changes on a8 monthly basis.9 Q. And that's why I am asking.

10 A. Okay. Because as I'm getting old, you11 know, I am now the third from the -- fourth from12 the oldest member of the group, and as a13 consequence, the young people, they like to do the14 drainages, they like to do the biopsies, they like15 to do the sexy CT and MR and things like that.16 So I am a very early riser, and I am17 doing a lot of plain x-rays. Actually, the most18 common x-ray I read these days is actually the19 chest x-ray, and it's usually the ICU films, and20 then I also, you know, read the resident out in21 plain films.22 And so my practice is a general23 radiologist, you know, with a major in24 gastrointestinal imaging where I do CT, ultrasound,

1381 occurred? No, I can't say that.2 Q. So you can't state to a reasonable3 degree of medical certainty that No. 81, even4 though it is suspicious, is, in fact, the point of5 perforation?6 A. That's correct.7 Q. All right. A couple other questions8 real quick, and I think we'll be about done.9 The reports that we had in front of you

10 earlier, would any of those reports, in your11 opinion, be below the standard of care in the way12 they are written and reported on based on the films13 that you have looked at?14 A. Of course I don't have the films on15 certain of these images.16 Q. Right. And understanding that every17 radiologist may have a slightly different18 nomenclature or way of expressing things, my19 question is a little bit more specific. Are any of20 the reports that you have reviewed up through21 January 25th, 2008, below the standard of care as22 expected for a radiologist reporting on the film23 under the same or similar circumstances?24 A. They comply with the standard of care.

1401 MR of the chest, abdomen, and pelvis. I look at2 plain films throughout the body, including spines3 and hips and things like that. The interventional,4 I am doing less and less of because the younger5 people want to do it because it's more exciting, I6 guess, to do.7 And in terms of our hospital system8 keeps on buying additional hospitals, and so they9 like to put a senior face like mine out there, and

10 so especially this year I have been away from the11 residents more than I have in the past because they12 want to see an old wizened face for, you know, the13 new acquisitions for the hospital.14 Q. How many abdominal CTs do you think you15 currently read per day or week, however makes the16 most sense?17 A. Okay. All right. And it depends what18 hospital I am at, so it can be 50; it can be 100.19 Q. Per week?20 A. No, per week, probably more like 100.21 Q. And did you specialize in abdominal CTs22 and studies?23 A. Yes. Actually, I did my fellowship in24 abdominal imaging at UCSF way back in 1981, 1982.


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1411 Q. All right. And then what else are you2 doing besides -- and how many hours per day do you3 spend reading films?4 A. Well, as I said, I am a very early5 riser, so it's usually probably ten or eleven hours6 a day. And assuming everybody is in town and not7 everybody is away on vacation, I get one academic8 day a week, but they're getting rarer and rarer.9 Q. I ask this of all experts. Please don't10 be offended.11 Any pending charges, felony or12 misdemeanor?13 A. No, sir.14 Q. Any in your background?15 A. No.16 Q. Any Board of Healing Arts complaints or17 inquiries?18 A. No.19 Q. Any suspensions of medical staff20 privileges or other forms of right to practice in a21 hospital?22 A. No.23 Q. Any current malpractice claims or24 lawsuits that you have had to put a carrier on

1431 MR. SMITH: I am going to go real quickly,2 Doctor.3 MR. MOLZEN: Just don't lead him.4 MR. SMITH: I can lead him.5 MR. MOLZEN: You cannot lead him.6 MR. SMITH: We'll argue about it later.7 MR. MOLZEN: Why don't you just grant me a8 continuing leading objection.9 MR. SMITH: All right. You can do that. I

10 just want you to understand what his opinions are.11 MR. MOLZEN: I understand.12 MR. SMITH: I don't plan on reading this at13 trial.14 EXAMINATION15 BY MR. SMITH:16 Q. With regard to Opinion No. 7, you are17 relying in part on the x-ray -- abdominal x-ray18 series of January 23rd, is that correct?19 A. That's correct.20 Q. And you are relying on both the findings21 made and the findings not made in that report?22 A. That's correct.23 Q. And you would like to verify the24 findings made and the findings not made by looking

1421 notice?2 A. No.3 Q. All five of your lawsuits, I think I4 have seen described in other depositions. I won't5 go through those here.6 Any that you know of that just haven't7 been filed yet?8 A. No.9 MR. MOLZEN: I think that's all the questions

10 I have for you today. It looks like we have gone11 exactly three hours. Would you agree?12 MR. SMITH: I have got a couple questions.13 MR. MOLZEN: Oh, are you going to question14 him?15 MR. SMITH: Well, I just want to make sure you16 guys are not walking away from here not knowing17 what his opinions are. And I think maybe it's18 covered, but I am not sure.19 THE WITNESS: What time did we start? Did we20 start at quarter to 5:00?21 MR. SMITH: We started at a quarter to 5:00.22 MR. MOLZEN: Oh, okay.23 MR. SMITH: Can I go?24 MR. MOLZEN: You can go.

1441 at the actual film itself?2 A. That's correct.3 Q. And we have for the record requested4 those x-rays for today's deposition, although not5 until yesterday. We thought we already had them.6 And you have an opinion that the air in7 the abdomen following the abdominal surgery should8 be going down in amount as opposed to going up in9 amount following the surgery?

10 A. That's correct.11 Q. And when you look at the actual films12 of -- the January 24th CT films, you can do13 measurements of the density of the film, and you do14 intend to tell us the density levels of the fluid15 collections at trial, correct?16 A. Yes, I did, and as I said, they range in17 density between 24 and 54 Hounsfield units.18 Q. And do some of the films on January 2419 show contrast dye outside the colon and in the20 abdominal cavity?21 A. Yes, they do.22 Q. And likewise, when you go to the23 preoperative CT studies, you can actually measure24 the size of the uterus and measure the size of the


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1451 ovaries, and you intend to do that at trial?2 A. Yes, I do.3 MR. SMITH: I just wanted to make sure you4 guys had an opportunity to follow up on that or5 know that was what he was going to be doing.6 That's all the questions I have.7 FURTHER EXAMINATION8 BY MR. MOLZEN:9 Q. The density levels that he just asked10 you about, how do those play in -- you have given11 us a range. How do those demonstrate either the12 timing of the perforation, location of the13 perforation, or whether there's even a perforation?14 A. The fact that this stuff is so dense15 implies that -- or indicates that this is the16 contrast material that's leaked out of the bowel,17 because it's so high in density in the bowel, and18 then when it's kind of diluted in the adjacent19 fluid, it gets lower in density.20 Q. So the further you get from the leak in21 the bowel, the more diluted it will be, and22 therefore, the density level numbers will come23 down?24 A. Theoretically, but it doesn't always

147

1 of trial in this case?


3 Q. If for some reason you do prepare some

4 exhibits, you do look at this January 23rd

5 abdominal series and it modifies, changes, or

6 enhances or makes you come up with new opinions, I

7 need to know about that as soon as you come up with

8 those opinions.

9 MR. SMITH: We agree to do that.

10 BY MR. MOLZEN:

11 Q. All right. You have had a little slide

12 show here. You have burned some of the images.

13 Can I get you to make a copy of that?

14 MR. SMITH: I think those are the images.

15 BY MR. MOLZEN:

16 Q. Is that actually the disk with the

17 films?

18 MR. SMITH: Yes.

19 BY THE WITNESS:

20 A. Yes.

21 BY MR. MOLZEN:

22 Q. You didn't, like, select a second set or

23 a series of the films?

24 A. No. That's actually what came on the

1461 work that way.2 Q. All right. Have you attempted to make3 those calculations yet?4 A. In terms of density?5 Q. Yes.6 A. Oh, yes, I have.7 Q. Have you set forth the images that8 reflect the certain density levels?9 A. No, we did not discuss it, but again,

10 when this comes to trial, I will show you the11 exhibit or the slice number and also the density on12 it, and you will have that well beforehand.13 Q. Very good. Your opinions, have you had14 an opportunity you believe here this evening to15 express all of your opinions?16 A. Assuming I agree with the x-rays that I17 am about to get, yes, or unless you or Mr. Smith18 have some new information to give me, yes, I don't19 plan on surprising you with anything else.20 Q. In other words, you had an opportunity21 tonight -- we have been going for about three hours22 and 15 minutes, 20 minutes -- you have had an23 opportunity to tell us all of your thoughts that24 you anticipate expressing to the jury at the time

1481 disk.2 MR. MOLZEN: Okay. Very good. I think that's3 all the questions I have for you. Would you agree4 that we have been going for about three hours, 205 minutes?6 THE WITNESS: Yes, sir.7 MR. MOLZEN: Okay. I will owe you $500 per8 hour.9 THE WITNESS: In Illinois you pay your own

10 experts but not in Missouri?11 MR. MOLZEN: No.12 THE WITNESS: But here, you'll agree to that?13 MR. SMITH: You'll get paid.14 THE WITNESS: This was a joke off the record.15 I'm sorry.16 MR. SMITH: I need to stay on the record,17 Doctor, and then we can let the court reporter wind18 down and pack up. Do I have permission to take19 Exhibit 12, which was my copy of the radiology20 notebook?21 MR. MOLZEN: If you burn me a copy of it when22 you get back to Kansas City.23 MR. SMITH: It's the entire -- it's the disk24 you guys gave me.


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149

1 MR. MOLZEN: No, no, no. Let's stay on the

2 record. What's been marked as Exhibit 12 is the

3 summary of all --

4 MR. SMITH: It's just an index.

5 MR. MOLZEN: I know. Can I get a copy of that

6 index?

7 MR. SMITH: Absolutely.

8 MR. MOLZEN: Everything else, the court

9 reporter is going to take possession of, make

10 copies for us, and then she'll send it back to you.

11 Is that agreeable to you?

12 THE WITNESS: Sounds good.

13 MR. SMITH: We would like to read and sign.

14 FURTHER EXAMINATION

15 BY MR. GRIMES:

16 Q. Before you go off, the density that you

17 talked about, the measurements, no radiologist back

18 in 2008 made those measurements that you are aware

19 of, correct?


21 MR. GRIMES: Okay. That's it.

22 FURTHER DEPONENT SAITH NOT.

23

24

151

1 IN WITNESS WHEREOF, I do hereunto set my

2 hand of office at Chicago, Illinois, this 6th day

3 of October, 2011.

4

5

6

7

8 Notary Public, Cook County, Illinois.

9 My commission expires 6/13/15.

10

11 C.S.R. Certificate No. 84-2776.

12

13

14

15

16

17

18

19

20

21

22

23

24

1501 STATE OF ILLINOIS )2 ) SS:3 COUNTY OF C O O K )4 I, CHRISTINE R. MACINTYRE, a Notary5 Public within and for the County of Cook, State of6 Illinois, and a Certified Shorthand Reporter of7 said state, do hereby certify:8 That previous to the commencement of the9 examination of the witness, the witness was duly

10 sworn to testify the whole truth concerning the11 matters herein;12 That the foregoing deposition transcript13 was reported stenographically by me, was thereafter14 reduced to typewriting under my personal direction15 and constitutes a true record of the testimony16 given and the proceedings had;17 That the said deposition was taken18 before me at the time and place specified;19 That I am not a relative or employee or20 attorney or counsel, nor a relative or employee of21 such attorney or counsel for any of the parties22 hereto, nor interested directly or indirectly in23 the outcome of this action.24

1521 I N D E X2 WITNESS EXAMINATION3 RICHARD MICHAEL GORE4 By Mr. Molzen 4, 136, 1455 By Mr. Grimes 128, 1496 By Mr. Smith 1437

8

E X H I B I T S10 NUMBER MARKED FOR ID11 Gore Deposition12 Exhibit Nos. 1 through 32 413 Exhibit No. 33 4114 Exhibit No. 34 4215 Exhibit No. 35 4316 Exhibit No. 36 4317 Exhibit No. 37 6518

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20

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24


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153

1 DEPOSITION ERRATA SHEET

2

3 Our Assignment No. 273356

4 Emma Caldwell v. Southtown Women's Clinic, LLC, et

5 al.

6

7 DECLARATION UNDER PENALTY OF PERJURY

8

9 I declare under penalty of perjury that I

10 have read the entire transcript of my Deposition

11 taken in the captioned matter or the same has been

12 read to me, and the same is true and accurate, save

13 and except for changes and/or corrections, if any,

14 as indicated by me on the DEPOSITION ERRATA SHEET

15 hereof, with the understanding that I offer these

16 changes as if still under oath.

17

18 Signed on the ______ day of

19 ____________, 20___.

20 ______________________________

21 RICHARD MICHAEL GORE

22

23

24

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A

A.D1:19

abbreviate77:8

abdomen10:8 11:913:19 18:2145:22,2349:11 57:17,21 91:2292:11 98:11105:15 107:23109:2 110:7,16 112:8122:8,11,22124:8 125:2,4,8 137:16140:1 144:7abdominal8:22 10:18,2012:2 19:320:21 45:2446:18 47:2048:9 49:4,1157:24 77:7114:16 115:5,20,23,24116:2,5,24117:6,7,11140:14,21,24143:17 144:7,20 147:5able111:17 134:19135:13

abnormal72:7 74:2095:15 98:9106:4 117:14122:14 129:10abnormality102:7

abscess30:20 48:1249:11,1457:14 58:172:11 91:2195:15,1897:18 110:2111:13112:10,13,18,22 114:10,14,19,23 115:17133:23 134:2,4,8

abscesses46:15 47:667:15 113:18116:11

absence81:23

absolutely70:16 118:18137:22 149:7abut77:2

academic141:7

accurate8:16 37:1145:9 153:12accurately10:12

acquisitions140:13

action150:23

active97:3 135:15actively132:6 136:15actual10:13 137:20144:1,11

acute10:8,20 11:912:2 13:1945:22 49:10114:16 115:5,22,24 116:2,3,5,24 117:7125:3,7

Adam133:15,18

add92:13 110:19addition36:3

additional15:8 33:135:12,22,23126:23 128:6140:8

additions45:13

adherent84:8 85:4adhesions63:2,5,7,17,21 64:1,265:8 66:3,880:9

adhesive83:18,21

adjacent64:4 77:2145:18

advance22:11

affect102:19

affirmation132:3

afternoon5:23

ago

29:6,8 56:9agree15:3 16:17,2142:24 95:9142:11 146:16147:9 148:3,12

agreeable149:11

agreed7:20 15:1417:1

agreement15:2

ahead78:22 81:2284:3,23 85:18102:22106:12,23108:15,16,17

air12:6,19 46:150:18 95:2496:8,13,14,20,22 97:10,15 103:19,23104:1,6,8,10116:15,16144:6

Airport36:11 37:1al1:8 153:5alarm70:21

aldolase129:10

allergy109:24

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belly47:12,2272:11 95:2497:4,6,8,9107:18,19109:16 113:2,8 116:3 126:6128:11 137:15belong

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bill34:4,5,2435:6 36:1biopsies139:14

bit16:5 22:10,1232:24 71:583:10 106:15119:18 138:19black80:13 85:1196:19 97:20,23,24 98:1,2,3,5,6

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blackness96:15,16103:4 111:10bladder103:12

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C

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C.S.R3:23 151:11calculations146:3

CALDWELL1:4 4:2317:17 18:321:11 25:2226:1 28:1433:16,2438:16 54:456:17 57:377:13 79:180:20 86:192:11 98:23101:13 102:12105:22 120:23125:11 153:4Caldwell's19:12 54:1992:17

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called1:14 4:8 32:938:15 44:1346:17 97:10106:11 123:13

132:22

calling90:13

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case5:7 7:6,1215:7 16:1417:22 19:2120:18 22:7,2328:5,14,17,2229:4,16,2330:8,9,14,1531:1,5,14,16,21 33:13,2234:8 35:8,10,

13 37:4 39:441:24 46:649:2 51:12,1657:11 72:1587:23 89:1090:23,24104:10 129:6,15 131:11132:19 147:1cases28:11 37:11129:24 130:1,2 131:10,13132:22 133:4,11

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cavity49:6 85:2297:13 103:24104:8,14134:5 144:20CBC54:3

cc's106:21,23

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century26:17 28:3certain4:1 23:1241:2 42:1243:7,17 61:465:14 72:1,490:7 118:10138:15 146:8certainly59:20 60:984:4 85:6105:16 106:24120:17 124:15certainty87:10,13,18,21 88:1,12,19,21 89:3112:15 135:16137:2,24138:3 139:2Certificate3:24 151:11certificatio

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chapter46:11,1347:24 48:2chapters48:15,16

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Chicago36:16 151:2Chris32:8

CHRISTINE1:14 3:23150:4

CHRISTOPHER2:15 4:20chronic124:8

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CITY1:2 2:5,133:4 36:16,2337:7 133:14148:22

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close93:24

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continue76:23

Continued3:1

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corner125:11

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30:1,11 34:1,6,19 35:2,5,836:2,3 37:18,19 39:1,9,10,15,16 43:244:10,11,1648:5 51:17,18,23 52:353:19,23,2455:22,2456:1,3,4,5,6,12 59:2460:1,4,5 61:762:7,8 63:18,19,23 69:1170:6 78:281:20 84:2285:17 88:589:18 91:5,7,8,12,1397:10,11,13,14,21 102:17103:17 104:14107:24 108:14113:14 114:7,24 118:2,6,12119:1,2,22127:15 129:1,2 130:5,7,10134:15,19,20135:1,2,21,22 138:6143:18,19,22144:2,10,15147:2 149:19,20

corrections153:13

correctly18:2

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counsel's64:24

count52:22 54:4,1955:4,8 58:567:8 70:1971:23 72:1774:20 105:19107:16,19108:10 109:7counted16:16

COUNTY1:1,16 131:8,9 150:3,5151:8

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CT-wise113:15

culture56:16 108:11cultures

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current45:15 51:9130:9 139:5,6141:23

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curriculum45:4,6,8

CV46:3,9 47:4CVs45:4

cyst79:14

cystic76:2 77:179:15

D

D152:1

dab83:7

damaged65:7

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darker81:3

data

111:21

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dated37:17 125:22dates9:5 109:1113:16

DAVID2:2,7 33:20day1:19 12:1636:17 54:1858:1,2,498:24 100:22101:12 140:15141:2,6,8151:2 153:18daylight78:10 79:10,14 80:2,3,16,18 81:2482:4,1483:12,1585:11

days12:18 27:1354:5 58:397:2 104:18114:2 125:5126:7,19134:18 139:18dealing67:15

dealt30:9

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declare

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deeply93:18,20

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density80:23 91:20,23 93:3,7,15,17 94:6144:13,14,17145:9,17,19,22 146:4,8,11149:16

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DEPONENT149:22

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depositions14:9 20:522:7 25:2,10,19 26:3,2327:2,9,12,1631:6,11 32:5,7 33:5 34:10,11,13,15,1735:22,2367:22 69:2470:10 89:2,8131:19 142:4descending93:4,8,999:24

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126:2,23127:1,20

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134:21

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download6:6

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early27:13 139:16141:4

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easier75:15

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educated45:11 113:22

114:9

educating119:17

effort6:20

either10:5 18:1031:22 51:1072:10 90:10,19 91:1199:17 101:2123:6 134:4145:11

electronic129:5,8,12

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Elson's41:9

E-mail8:11 16:20,2450:16

E-mails16:13

E-mail-wise33:10

embolism89:19 96:12109:11,14110:20 111:1,5,9

EMMA1:4 4:2317:17 18:219:12 21:1125:21,2433:16,2477:13 79:1

92:10 153:4employee150:19,20

emptying122:16

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exact71:24 73:8116:18

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Exhibit4:2 5:11,14,15 6:22 7:4,16,22 8:8,15,19 9:1113:12,17 14:216:1,6,11,2019:24 21:2422:5,10,1623:2,21 24:6,7,20 26:1327:23 28:11,12,18 32:633:4 34:335:20 37:1038:18 41:3,1742:17,2043:8,18 44:3,7,16 45:651:21 52:1,2,12,20 53:2,854:2,3 56:14,24 61:1262:11,2063:4,6,11,1464:22 65:1568:3,8,1369:6,10,12,16,17 75:4,16,19 107:22130:8 146:11148:19 149:2152:12,13,14,15,16,17

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exploratory21:12

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extensive83:21

extent18:5 33:1834:10

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eye59:20

F

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53:7

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figure57:18 58:9file45:1

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filled82:2

film10:24 11:19,24 13:22 60:777:18,1978:17 92:7111:5 113:13125:15,21127:4,12136:4,5138:22 144:1,13

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fluid30:19 46:2347:12,14 49:871:1,3 81:491:20 93:7,10,15,1795:16 98:9,12,16 106:19,21,22 107:3108:18 112:11114:14,18115:1,4,17134:3,4,10,11 137:16144:14 145:19fluids106:12,13,15

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focused105:2

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137:14

foregoing150:12

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formation87:23

forming52:19 62:1668:7

forms141:20

formulating42:14 52:24forth8:10 146:7found62:22 63:2,6,9,22 65:267:24 69:1080:8 81:583:18 86:13106:3 115:11125:3 135:11foundation18:6

four29:8 45:1758:3 61:21fourth45:23 102:23105:4 139:11fragilis57:4 86:2126:5

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front82:9 103:12124:17 138:9full4:12 14:5function92:17

further93:22 136:1145:7,20149:14,22

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G

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gas12:8,11,2113:2,4 45:2487:4 93:1197:2,8,17103:1,4,7,13,15,19,21104:1,5,7,15,19,22 111:10113:7 116:6121:21,22,23137:17

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122:15

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generally16:17

generated34:5

getting55:4 106:7,21,22 116:5120:6 139:10141:8

GI58:14 102:17GI-related57:14 58:1give14:4 30:246:9 51:674:10 78:13,20 92:18110:18 131:6146:18

given14:9 27:3,12,16 31:1051:19,2252:14 100:15,22 101:14145:10 150:16

giving8:18 28:1650:10

go5:16 7:2111:7 31:16,1834:19 39:241:21 42:844:2 46:2447:9 61:965:10 75:16,24 76:2078:22 81:2284:3,23 85:1899:21 102:22105:6 107:20111:23 129:8,16 130:23142:5,23,24143:1 144:22149:16

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99:22,23100:3 107:3,14 108:19109:10,16111:13 113:1,9 114:4121:11128:14,15134:6 137:5142:13 143:1144:8 145:5146:21 148:4149:9

gone31:3 40:1841:19 70:1675:7,10 128:5142:10

good11:20 12:149:9 72:1073:16 74:1878:22 92:17100:9 104:20120:6 136:21146:13 148:2149:12

GORE1:13 4:2,7,13,19 7:541:3 42:2043:8,18 65:1590:13 152:3,11 153:21154:24 155:24G-o-r-e4:14

gotten100:21 102:2Graham19:9

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G r a m -

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H

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help23:15 36:1552:19 65:8109:18 136:9helpful42:14 99:16hematocrit70:24 106:1hemidiaphragm96:21,23

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her4:23 5:233:24 34:143:15 55:3,757:17 58:5,1859:6 62:2363:2,3,2464:3 65:8,2266:23 72:15,16,18 73:13,15 74:2,3,4,9,10 80:2181:5 84:586:3,11 91:1292:18 99:2,3,4,8,11101:15,18102:6 104:16105:10,19,20,24 106:2,4107:22 109:5,23 111:8113:8 119:5,6,20,23 120:1121:2,3,10123:22 125:3127:6,18135:4

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herein4:8 150:11hereof153:15

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hereunto151:1

hey70:22 72:9109:14

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higher72:1,3

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highlighting43:1

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I

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imagine68:21 128:12

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inadvertentl

y64:23 84:10inch39:7,14 41:1844:4 78:1079:10,13 85:6

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index110:15 149:4,6

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indicated63:12 66:12153:14

indicates57:13 145:15indicating127:4

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inflammatory71:22

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initial5:24 88:13injured84:10

injury59:6,9,12,17,22,23 63:1266:2 77:684:11 88:1491:12

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instance15:8 19:7125:21

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involving131:10

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issues4:24 28:13,17,18 46:647:3 49:150:7 51:11131:10

item69:8 134:9items

5:16 6:21 7:222:4

IV74:10 106:7

J

J2:15

JACKSON1:1

James133:12

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jejunum100:20

Jetinder3:8

John24:1 33:20joke

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jotted23:2

juicy84:12

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jury14:13 15:7122:18 146:24Just5:24 10:11,1811:2,3 15:1923:8,15 25:2,8,9,15 30:1635:14 37:1,2238:1,23 41:744:1 48:16,2249:14 51:4,2453:12,1759:17 63:1064:20 67:1468:12,2369:23 71:377:22 78:979:9,24 82:9,22 83:6,1984:8,18 88:2392:6,20 96:7102:7 104:24106:18 113:17120:7,8 121:4123:10,11125:4 126:24128:16,20134:2,24136:3 142:6,15 143:3,7,10145:3,9 149:4


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keep26:23 27:348:22 54:2364:17 75:14keeping69:22 124:1keeps140:8

Kentucky29:2 31:23kept27:11

key57:12

kidney92:17 116:9kidneys109:5,23110:11

kilter108:13

kind4:17 7:1513:6 22:1238:17 39:941:7 44:1449:1 59:2360:17 63:469:6 77:1980:23 85:1104:2 106:1108:24 120:12121:13 122:10123:7 145:18

kinds108:20 124:6knew52:21 91:3,6,9 105:21133:22 134:14know5:2 9:1,412:8 13:1,314:19,23,2415:3,11,2021:9 31:1134:7 36:5,10,12 37:3,8,942:1 49:650:9,10,1851:9 53:12,1357:22,23,2458:1,3,759:3,19 60:2161:18 63:764:1,3 65:2467:6,7,10,11,12,14 68:1070:7,15,1871:1,1472:15,2373:2,17 74:5,17,21 76:478:7 79:1580:4,9 82:13,17,21 83:7,16,17,18,2284:9 85:686:13,24 87:188:3,23,2489:24 90:3,11,21,2391:16 95:14,16 97:3 99:6,13,14 102:6,19 103:20105:16,20,23107:1,5,7,10108:18,19

109:6,7,11110:17,19111:13,16112:16,17113:3,5,7,15114:9,10115:5 119:7120:2,7,8,12,19 121:16123:8,11124:15 126:5,10,15 127:1128:10,11,22129:9 132:8133:1,3,14134:2,16135:9,17137:14,23139:11,20,23140:12 142:6145:5 147:7149:5

knowing82:15 86:11142:16

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L

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labeled7:24

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large76:2,15,2477:24 98:16123:23

last20:4,5 35:1438:21,23 42:245:16 47:1650:9 52:1553:16 62:1470:8,11118:24

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later44:2 58:386:23 125:7143:6

lateral93:8

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lawsuits141:24 142:3lawyer29:20 90:691:7 135:18lawyers89:9 133:10layers59:18

lead117:17,19123:15 143:3,

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leaking136:15 137:7learn14:12

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leave14:23 36:15136:21

lecture50:15,16,20,23

lectures45:17

led66:2 105:15119:9 120:24121:1,2

Lee19:9

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level145:22

levels129:10 144:14145:9 146:8liable111:16

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light81:1

likely59:11 84:1185:23 86:1887:7,8,1788:14 101:3107:13111:16,17112:24 113:1

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limit30:7

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listed17:5 54:6listing61:10

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litigation91:4

little6:24 16:522:10 26:1032:24 41:1265:12 83:1094:5,9,1997:20 103:21106:15 119:17121:21,22,23138:19 147:11Litwin19:8 125:2liver96:20,23

LLC1:7 2:17,18153:4

loaded

6:4 39:8,15,20,23 75:13lobe96:22

location59:9 145:12LOMBARDO3:2

long29:6 30:2250:20 69:6longer32:16 112:23look12:10 18:1319:18 20:1,3,18,19,23 33:134:1 39:2141:11 50:1351:2 52:8,1660:16 61:1471:5 73:1079:19 89:11,14 90:7 99:2,3 103:9104:13107:17,19110:10 116:6135:9 140:1144:11 147:4looked5:21 6:1725:19 26:431:4 34:1759:14 62:263:14 89:1590:20 91:192:15 129:14133:11 135:12138:13

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40:5 46:153:12 62:1264:21,2265:11 69:977:12 78:2380:4 88:2389:24 90:992:7 96:15113:18 114:10116:10 143:24looks5:19 11:20,2434:4 37:1638:18 48:19142:10

loop82:1

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O

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20003:3 26:1827:20 37:13130:9,12,16

200529:13

20089:17,2410:14,1518:11 21:6,2044:18 48:2261:16,17,2262:2 65:574:16 79:184:21 86:692:12 108:7,8121:18 124:23125:18 126:18127:10 137:10138:21 149:18200961:20

20147:23 48:420111:19 151:32020055:8

20th9:24 10:1411:8,22 18:1167:10,1373:16 86:2,688:11 133:222168:5 93:298:15 112:821748:7,8

21st18:20 20:2,2073:16 96:1297:7 107:23108:7,22109:21 110:22111:1,12112:9,16118:20

22


Toll Free: 888.486.4044



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23rd10:9,15,21,2411:9 12:313:19 18:11112:9 116:22117:1,12118:16 119:7121:18 143:18147:4

2461:16 62:2,1168:6 73:391:23 104:17144:17,18

24548:14,24

24648:15,24 49:624949:10

24th18:21 20:3,2168:1 71:1474:6,8,1689:18 92:12,16 100:11119:7 136:8137:10 144:12259:14 16:1621:20 41:1742:17 44:3

73:3

250035:1

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2638:8 46:2226501:18

273356153:3

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3

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3.3106:22 108:153.8108:16

30127:10

300-page25:10

30th127:3,17

3138:8

31st2:4

324:3 45:6

152:12

3341:4,10152:13

3332106:20

3442:20,2344:8,9 48:8,10 88:23103:22 104:11113:17 122:6152:14

3543:9 44:950:22 56:993:1 152:15350130:1

3643:19 44:1448:14 64:23103:22 104:11152:16

3749:10 65:1669:6,12,17,2075:4 103:21104:11 152:17

4

426:13 27:2328:1,11,1237:10 91:1896:15 105:3152:4,12

4065:22

400130:1

4082:4

41152:13

4263:4 152:144344:16 152:15,16

4465:24

4550:21

4501:19

4651:21 66:4,12,14,15

4766:6,19

5

534:4 35:20105:6

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50140:18

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5127106:23

5251:21

520AB1:17

5491:23 144:1754555:1

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6/13/15151:9

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6000-plus74:14

62125:11

63125:5

641052:13 3:4641082:5

6579:4,8 152:176755:9

6879:21 103:469103:5

6th151:2


Toll Free: 888.486.4044



7

722:10,16 23:2143:16

70103:5

7002:4

7380:1

7480:1,20 82:483:5 104:247580:1 103:5104:24

7680:1 98:4,15104:24

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84104:23

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8679:23 104:238781:7 93:14

9

924:2

9/22/114:4 41:542:21 43:10,20 65:179046:10,1247:2,3,593:19

91103:9,15

9113:3

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9480:21 93:396100:4,10

9th20:11,13,2079:1 84:2189:18 101:19,20,22 102:3


Toll Free: 888.486.4044



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