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| Medical 004ABuy steno drill CDs at StenoDrills.com MR. MILLER: This is the time and place for the deposition of Dr. Peter Stone in the matter of Harold Mason versus James King and Son. This is the Doctor’s deposition in place of his personal appearance before Referee Moore Jennings who is hearing this matter and will issue a determination. My name is George Miller. I’m here on behalf of the defendant employer. Also here is Attorney Mark Bannon on behalf of the claimant. Before we start, can we agree that all objections will be noted on the record for review by Referee Jennings when he receives the transcript? MR. BANNON: Sure. MR. MILLER: Doctor, do you agree to waive the reading and signing of the deposition? DR. STONE: Yes, 1 do. PETER ALAN STONE, M.D. DIRECT EXAMINATION ON QUALIFICATIONS BY MR. MILLER Q. Would you state your name please and your professional address. A. Peter Alan Stone, 428 West Linden Street, Wilkes-Barre, Pennsylvania. Q. Are you a licensed physician to practice medicine in the Commonwealth of Pennsylvania? A. Yes, I am. Q. How long have you been licensed? A. Twelve to fifteen years. I’m not exactly sure. Twelve years, I think. Q. I’m going to show you a document which I will have marked as Defendant’s 1 and ask you if that is a copy of your curriculum vitae. A. Yes, it is. Q. Does that accurately and currently reflect your educational background and your hospital affiliations and your professional society memberships? A. Yes. Q. In addition, Doctor, are you also board certified in any fields? A. Yes. I’m board certified in orthopedic surgery and arthroscopy. MR. MILLER: I offer the Doctor as a medical expert. His board certifications are noted. Are there any questions on his qualifications? MR. BANNON: Can I take a moment and look at the curriculum vitae. MR. MILLER: Certainly. CROSS EXAMINATION ON QUALIFICATIONS BY MR. BANNON: Q. Doctor, I just have one or two questions. Could you tell us for the record about the field of endeavor that you referred to as arthroscopy? A. Arthroscopy is putting small tubes into joints to view the joint and to do surgery microscopically through the tubes. Q. Your other specialty, Doctor, was orthopedic surgery; is that correct? A. That’s correct. Arthroscopy is a subspecialty of orthopedic surgery. MR. BANNON: I will stipulate to the Doctor’s qualifications as a specialist in the field of arthroscopy and orthopedic surgery, and I have no other questions on his background. I have no objection to the introduction of his curriculum vitae. DIRECT EXAMINATION BY MR. MILLER Q. Doctor, did you have an occasion to examine Harold Mason? A. Yes, I did. Q. How many times did you examine him? A. I examined him twice. Q. What were the dates? A. The exam dates were April 26, 1990, and June 28, 1991. Q. Doctor, turning to the June 28, 1991, examination did you prepare a report of your findings? A. Yes, I did. Q. I’m going’ to show you a two-page document that I’ m going to have marked as Defendant’s Exhibit 2 and ask you if that is a report of your examination of June 28, 1991, directed to a Betty Parsons. A. Yes, it is. Q. Doctor, at the time of your examination, did you obtain a history of a work injury that Mr. Mason suffered on February 13, 1990? A. Yes, I did. Q. What history did you obtain? A. The history that he gave me was that he was picking up a gang box while at work and slipped, injuring his low back. Q. Did you obtain any information regarding whether Mr. Mason suffered from any prior back problems A. Yes, I did. Q. What was that? A. I had been informed that he had previous back problems dating to 12 to 15 years prior and that he had had intermittent stiffness and discomfort since that time. Q. Doctor, at the time of your more recent examination in June 1991, did you have the benefit of any records of any treatment that Mr. Mason had received? A. Yes. Q. What were those records? A. Those were records from the Crocker Institute of Rehabilitation regarding a work hardening program and evaluation. Q. Did you have any other records that were a part of your file from the prior examination also? A. Yes, I did. Q. What were those records? A. Those were reports of chiropractic treatment, job description report, occupational injury report form. Q. Doctor, when Mr. Mason presented himself on July 28, 1992, what were his complaints? A. He told me that he could sit for about “15 to 20 minutes at a time"; and then if he got up and walked around, he felt good and could sit again. He indicated that he was on no medication. If he didn’t, quote, do anything heavy, he felt good. End of quote. He told me he not returned to work. He said he could stand for about 20 minutes. He was able to dress himself. He was able to drive and had driven to the office on the day of the examination which is about a twenty-minute ride. He said that if he had to drive for more than an hour at a time, he had to stop and take a walk; but then he was good for another one or two hours of driving. He indicated he was on no physical therapy and that he saw his family doctor about once a month. Q. Now, the complaints that he offered or that you noted, are they his subjective complaints? A. Yes. |
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