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FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012
NYSCEF DOC. NO. 425 RECEIVED NYSCEF: 01/17/2023
EXHIBIT 16
FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012
NYSCEF DOC. NO. 425 A782 RECEIVED NYSCEF: 01/17/2023
Trial Transcript, date November 9, 9, 2016
[pp.
[pp. A782 - A998]
-A998]
[FILED:
FILED: RICHMOND
RICHMOND COUNTY
COUNTY CLERK
CLERK 03/23/2017
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1 SUPREME COURT OF THE STATE OF NEW YORK
RICHMOND COUNTY - CIVIL TERM - PART: DCM-6
2 ————————————————————————————————————————— ——X Index #
ROBERT VALENTI, 150116/12
3 PLAINTIFF, :
—against-
4 :
JOHN J. GADOMSKI, M.D., SHIMON OAMI, M.D.,
5 LABORATORY CORPORATION OF AMERICA HOLDINGS,:
LABORATORY CORPORATION OF AMERICA, PATRICIA
6 C. MC CORMACK, M.D.,PATRICIA C. MC CORMACK,:
M.D., PLLC; and PATRICIA C. MC CORMACK,
7 M.D. , P.C . ,
8 DEFENDANTS. Cont. Jury Trial
————————————————————————————————————————— ——X (Dr. Abbi)
9
26 Central Avenue
10 Staten Island, New York 10301
November 9, 2016
11
B E F O R E:
12
13 HONORABLE PHILIP G. MINARDO, Justice
14
15 APPEARANCES:
16
THE LAW FIRM OF RAVI BATRA, P.C.
17 Attorneys for the Plaintiff
The Batra Building — 142 Lexington Avenue
18 New York, New York 10016
BY: RAVI BATRA, ESQ. & TODD SHERMAN, ESQ.
19
20 MARSHALL DENNEHY WARNER COLEMAN S: GOGGIN, ESQS.
Attorneys for Defendant Gadomski
21 88 Pine Street — 21st Floor
New York, New York 10005
22 BY: JAMES P. CONNORS, ESQ.
Z3
24
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1 KELLER, O'REILLY E: WATSON, P.C.
Attorneys for Defendant Oami
2 242 Crossways Park
West Woodbury, New York 11797
3 BY: SCOTT C. WATSON, ESQ.
4
5 AMABILE & ERMAN, P.C.
Attorneys for Defendant Mccormack
6 1000 South Avenue — 2nd floor
Staten Island, New York 10314
7 BY: JONATHAN S. ERMAN, ESQ.
3 * * * * -k *
9 KARYN S. GUTKIN
FRANCESCA BUSH
10 SENIOR COURT REPORTERS
11
12
13
14
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1 THE COURT: Step up, counselors.
2 (whereupon, an off the record discussion was held
3 at the bench.)
4 THE COURT: Jury in.
5 COURT OFFICER: Ready for the jury, your Honor?
6 THE COURT: Jury in.
7 COURT OFFICER: All rise, come to order. Jury is
8 entering.
9: (whereupon, the jury enters the courtroom.)
10 THE COURT: Be seated, everyone.
11 COURT CLERK: Your Honor, the jurors are present
12 and properly seated.
13 THE COURT: Call your next witness.
14 MR. BATRA: The plaintiff calls Dr. Rakesh Abbi
15 to the stand, the plaintiff's expert witness.
16 Can we set up the screen in the meantime, your
17 Honor?
18 THE COURT: Set up the screen.
19 (whereupon, the witness steps forward.)
20 R A K E S H A B B I, M.D., called as a witness by the
21 Plaintiff, having been first duly sworn, was examined and
22 testifies as follows:
23 COURT CLERK: Put your hand down, have a seat,
24 Please state your name and your business address.
25 THE WITNESS: My name is Rakesh Abbi; and I‘m a
kg
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FILED: RICHMOND
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COUNTY CLERK
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Dr. Abbi - Plaintiff - irect
570
1 pathologist at Robert Wood Johnson University Hospital,
2 I'm the chairman and the medical director of the lab.
3 MR. BATRA: Just one moment, your Honor.
4 (whereupon, there is a short pause in the
5 proceedings.)
6 THE COURT: Doctor.
7 THE WITNESS: Yes .
B THE COURT: The lawyers are obviously going to
9 ask you questions. Make sure the question has been
10 completed before you begin to answer.
11 If you don't understand the question, do not
12 speak to the lawyer, tell me you don't understand the
13 question, I will have it rephrased for you.
14 If you hear an objection, stop testifying, give
15 me a chance to rule on the objection, and I will tell you
16 whether you can continue to answer or not.
17 In the meantime, make yourself comfortable, keep
18 your voice up, direct your answers to the jury.
19 Go ahead.
20 MR. BATRA; Thank you, your Honor.
21 DIRECT EXAMINATION
22 BY MR. BATRA;
23 Q Good morning, Dr. Abbi, thank you for being here.
24 I want to ask you a few questions about your
25 background, your training, your licenses and certifications,
kg
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Dr. Abbi - Plaintiff -Direct
57"?
1 etc.
2 So could you tell us, right now what is your
3 current position?
4 A My current position is medical director of the lab,
5 and chairman is my title.
6 Q Chairman of what?
7 A Chairman of the department of pathology at the Robert
8 Wood Johnson University Hospital in Hamilton.
9 Q Can you keep the microphone closer to you so the jury
103 can hear you. I heard you say-—
11% A Chairman of the department of pathology at the Robert
12 wood Johnson University Hospital in Hamilton.
13 Q And is Robert Wood Johnson the largest healthcare
14 system in Jersey?
15 A At the present time, yes.
16 Q Are you licensed by the State of New York?
17 A Yes.
18 Q Are you licensed in any other state?
19 A New Jersey and Connecticut.
20 Q And you're a licensed physician?
21 A Yes.
22 Q Do you hold any board certification?
~
23 A Yes.
24 Q Which?
25 A ‘tan Board of ‘3at‘nc:l3.cwc;‘y, pat1h:3?.o_m.r
cl3‘.1'.L:i.::a3,
b<)t.‘r=,
KEY
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1 and surgical pathology.
2 Q As chairman of the department of pathology at Robert
3 wood Johnson Hospital, would a dermatopathologist who worked
4 for Robert wood Johnson department of pathology, would that
5 doctor he answering to you?
6 MR. ERMAN: Objection, Judge.
7 THE COURT: Overruled.
8 A Yes.
9: Q Would a pathologist, surgical pathologist or something
10 else, be answering to you?
11 A Yes.
12 Q Could you tell us where you—-
13 Starting with at post—graduation as a doctor,
14 when you became a resident, can you tell us that?
15 A Yeah. I did my residency in Nassau County Medical
16 Center, which is in New York.
17 And I did my four years of residency; two years
18 included surgical pathology, where we look at slides, the
19 processing and the entire procedure, and two years include
20 clinical pathology, which covers microbiology, and other
21 things, your examination, etc.
22 And after my residency, I did one year of
23 fellowship in surgical pathology at the same place. which also
24 included covering dermatopathology, looking at all the skin
25 biopsies, diagnosis and workup of the cases.
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1 And after my fellowship in surgical pathology, I
2 went on to North Shore University Hospital in Manhasset, where
3 they gave me the position of a provisional attending, which is
4 kind of intermediate between a fellow and a full attending, and
5 I did that for about nine months.
6 And then I got a job at westchester Medical
7 Center as an assistant attending and an assistant professor.
8 And that was in pathology. And basically it was surgical
9 pathology, which included all aspects of pathology. All
10 specimens. And I worked there from 1990, April 1st, to 1993.
11 And then I moved on to St. Joseph's Medical E
12 Center in Yonkers, and that I stayed on for about 12 years.
13 Again, I did surgical pathology, completely covered it, and we
14 had all kinds of specimens.
15 And after my job at St. Joseph's, which was the
16 job of an assistant director of pathology, I moved on to
17‘ Lutheran Medical Center in Brooklyn, where I was working as a
18‘ staff pathologist, and later as an attending, as an assistant
19 director of pathology.
20 And I also was at St. John's Episcopal Hospital,
21 where I was the director for about six months, I worked there.
22 And now I got a job as the lab director and
23 chairxnan of pathology at Robert Wood Johnson, and thaws where
24 I'm working now.
25 1,2 And among the positions you held, you were also NYU
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1 Lutheran Medical Center?
2 A Yes, yes.
3 Q And you were also medical director of St. John's
4 Episcopal Hospital?
5 A Yes.
6 Q And you are certified, ma'am, by the American Board of
7 Pathology?
8 A Yes.
9 Q And that's a nationwide certification?
10 A Yes.
11 Q Now, have you written scholarly articles that have
12 been peer reviewed, in peer reviewed journals?
13 A Yes.
14 Q And are there about 30 of them?
15 A I have a lot of them, I don't know exactly. But my
16 best article was the one published in New England Journal of
17 Medicine, that was at start of my career.
18 Q I'm looking at three pages of publications.
19 A Yes.
20 Q I counted every one.
21 A Yes.
22 Q Okay.
23 Now, in your experience of about 25—— you did
24 that more than 25 years, as a pathologist and now director of
25 pathology, have you dealt with biopsies of skin specimens?
’ ii A A’ 7 i M
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1 A Yes.
2 Q And over the course of more than 25 years at various
3 facilities, various hospitals, how many would you estimate you
4 have done?
5 A A lot.
6 Q Over 10,000 over 25 years?
7 A I'm not very good in math. But every week we got
8 about six or seven, at least, specimens, at least.
9 Q Okay. So over a period of more than 25 years,
10 whatever that adds up, okay?
11 A Yes.
12 Q And in your examinations, did you teach other doctors,
13 be them residents or fellows, about pathology, as to the goal
1.4 of pathology?
15 A All the time, yes.
16 Q Could you tell us what you told your students?
17 A Well, the students, I taught the fellows——
18 THE COURT: Members of the jury, if you can't
19 hear this witness or you don't understand the witness,
20 just raise your hand and we will have the question and
21 answer repeated.
22 Go ahead, doctor.
23 THE WITNESS: Thank you.
24 A I taught the medical students, the residents, the
25 fellows; and at times at dififerent conferences we deallt with
7 7 77 W77” W V V N IN H7777”
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1 other clinicians in other specialties.
2 And regarding the goal of pathology, appropriate
3 diagnosis in appropriate time. The earlier the diagnosis,
4 especially the grave ones, the better it is. And not to
5 hesitate to do tests, if indicated.
6 Q Ma'am, if you would keep your voice up, because it
7 seems to taper off if you move away from the microphone.
8 A Sorry.
9 Q So is the goal of pathology, then, to aid the treating
10 dermatologist to better protect the patient's health?
11 A Yes.
12 Q Is a purpose of pathology to let the dermatologist who
13 is treating the patient know all the possibilities of danger
14 that exists in that specimen?
15 A Yes.
16 Q And is that what a differential diagnosis is called?
17 A Yes.
18 Q That all of the possibilities that could exist, given
19 that specimen, should be—— that information should be given to
20 the treating doctor; is that correct?
21 A Yes.
22 Q Now, before a pathologist gets a specimen, the
23 treating dermatologist has a duty to tell the pathologist, as
24 well, correct?
25‘ A Yes,
7 7 7 77 7 7 7 7 77 7
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Preview
FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 RECEIVED NYSCEF: 01/17/2023 EXHIBIT 16 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A782 RECEIVED NYSCEF: 01/17/2023 Trial Transcript, date November 9, 9, 2016 [pp. [pp. A782 - A998] -A998] [FILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM PM INDEX INDEX NO. NO. 150116/2012 150116/2012 NYSCEF DOC_ DOC. NO’ NO. 290 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 557' 1 SUPREME COURT OF THE STATE OF NEW YORK RICHMOND COUNTY - CIVIL TERM - PART: DCM-6 2 ————————————————————————————————————————— ——X Index # ROBERT VALENTI, 150116/12 3 PLAINTIFF, : —against- 4 : JOHN J. GADOMSKI, M.D., SHIMON OAMI, M.D., 5 LABORATORY CORPORATION OF AMERICA HOLDINGS,: LABORATORY CORPORATION OF AMERICA, PATRICIA 6 C. MC CORMACK, M.D.,PATRICIA C. MC CORMACK,: M.D., PLLC; and PATRICIA C. MC CORMACK, 7 M.D. , P.C . , 8 DEFENDANTS. Cont. Jury Trial ————————————————————————————————————————— ——X (Dr. Abbi) 9 26 Central Avenue 10 Staten Island, New York 10301 November 9, 2016 11 B E F O R E: 12 13 HONORABLE PHILIP G. MINARDO, Justice 14 15 APPEARANCES: 16 THE LAW FIRM OF RAVI BATRA, P.C. 17 Attorneys for the Plaintiff The Batra Building — 142 Lexington Avenue 18 New York, New York 10016 BY: RAVI BATRA, ESQ. & TODD SHERMAN, ESQ. 19 20 MARSHALL DENNEHY WARNER COLEMAN S: GOGGIN, ESQS. Attorneys for Defendant Gadomski 21 88 Pine Street — 21st Floor New York, New York 10005 22 BY: JAMES P. CONNORS, ESQ. Z3 24 ~ 570 of 1532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A783 RECEIVED NYSCEF: 01/17/2023 IFILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM] PM INDEX INDEX N°~ NO. 150115/2°12 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 568 1 KELLER, O'REILLY E: WATSON, P.C. Attorneys for Defendant Oami 2 242 Crossways Park West Woodbury, New York 11797 3 BY: SCOTT C. WATSON, ESQ. 4 5 AMABILE & ERMAN, P.C. Attorneys for Defendant Mccormack 6 1000 South Avenue — 2nd floor Staten Island, New York 10314 7 BY: JONATHAN S. ERMAN, ESQ. 3 * * * * -k * 9 KARYN S. GUTKIN FRANCESCA BUSH 10 SENIOR COURT REPORTERS 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 571 571 of 1532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A784 RECEIVED NYSCEF: 01/17/2023 IFILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM PM ImEXNO'15“1“2“2 INDEX NO. 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 569 1 THE COURT: Step up, counselors. 2 (whereupon, an off the record discussion was held 3 at the bench.) 4 THE COURT: Jury in. 5 COURT OFFICER: Ready for the jury, your Honor? 6 THE COURT: Jury in. 7 COURT OFFICER: All rise, come to order. Jury is 8 entering. 9: (whereupon, the jury enters the courtroom.) 10 THE COURT: Be seated, everyone. 11 COURT CLERK: Your Honor, the jurors are present 12 and properly seated. 13 THE COURT: Call your next witness. 14 MR. BATRA: The plaintiff calls Dr. Rakesh Abbi 15 to the stand, the plaintiff's expert witness. 16 Can we set up the screen in the meantime, your 17 Honor? 18 THE COURT: Set up the screen. 19 (whereupon, the witness steps forward.) 20 R A K E S H A B B I, M.D., called as a witness by the 21 Plaintiff, having been first duly sworn, was examined and 22 testifies as follows: 23 COURT CLERK: Put your hand down, have a seat, 24 Please state your name and your business address. 25 THE WITNESS: My name is Rakesh Abbi; and I‘m a kg 572 572 of 1532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A785 RECEIVED NYSCEF: 01/17/2023 IFILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM] PM INDEX INDEX NO~ NO. 150115/2°12 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff - irect 570 1 pathologist at Robert Wood Johnson University Hospital, 2 I'm the chairman and the medical director of the lab. 3 MR. BATRA: Just one moment, your Honor. 4 (whereupon, there is a short pause in the 5 proceedings.) 6 THE COURT: Doctor. 7 THE WITNESS: Yes . B THE COURT: The lawyers are obviously going to 9 ask you questions. Make sure the question has been 10 completed before you begin to answer. 11 If you don't understand the question, do not 12 speak to the lawyer, tell me you don't understand the 13 question, I will have it rephrased for you. 14 If you hear an objection, stop testifying, give 15 me a chance to rule on the objection, and I will tell you 16 whether you can continue to answer or not. 17 In the meantime, make yourself comfortable, keep 18 your voice up, direct your answers to the jury. 19 Go ahead. 20 MR. BATRA; Thank you, your Honor. 21 DIRECT EXAMINATION 22 BY MR. BATRA; 23 Q Good morning, Dr. Abbi, thank you for being here. 24 I want to ask you a few questions about your 25 background, your training, your licenses and certifications, kg 573 573 of 1532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A786 RECEIVED NYSCEF: 01/17/2023 [FILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM] PM INDEX INDEX NO~ NO. 15°11‘/2°12 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff -Direct 57"? 1 etc. 2 So could you tell us, right now what is your 3 current position? 4 A My current position is medical director of the lab, 5 and chairman is my title. 6 Q Chairman of what? 7 A Chairman of the department of pathology at the Robert 8 Wood Johnson University Hospital in Hamilton. 9 Q Can you keep the microphone closer to you so the jury 103 can hear you. I heard you say-— 11% A Chairman of the department of pathology at the Robert 12 wood Johnson University Hospital in Hamilton. 13 Q And is Robert Wood Johnson the largest healthcare 14 system in Jersey? 15 A At the present time, yes. 16 Q Are you licensed by the State of New York? 17 A Yes. 18 Q Are you licensed in any other state? 19 A New Jersey and Connecticut. 20 Q And you're a licensed physician? 21 A Yes. 22 Q Do you hold any board certification? ~ 23 A Yes. 24 Q Which? 25 A ‘tan Board of ‘3at‘nc:l3.cwc;‘y, pat1h:3?.o_m.r cl3‘.1'.L:i.::a3, b<)t.‘r=, KEY 574 574 of 1532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A787 RECEIVED NYSCEF: 01/17/2023 [FILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM] PM INDEX INDEX NO‘ NO. 150116/2012 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff - Direct 572 1 and surgical pathology. 2 Q As chairman of the department of pathology at Robert 3 wood Johnson Hospital, would a dermatopathologist who worked 4 for Robert wood Johnson department of pathology, would that 5 doctor he answering to you? 6 MR. ERMAN: Objection, Judge. 7 THE COURT: Overruled. 8 A Yes. 9: Q Would a pathologist, surgical pathologist or something 10 else, be answering to you? 11 A Yes. 12 Q Could you tell us where you—- 13 Starting with at post—graduation as a doctor, 14 when you became a resident, can you tell us that? 15 A Yeah. I did my residency in Nassau County Medical 16 Center, which is in New York. 17 And I did my four years of residency; two years 18 included surgical pathology, where we look at slides, the 19 processing and the entire procedure, and two years include 20 clinical pathology, which covers microbiology, and other 21 things, your examination, etc. 22 And after my residency, I did one year of 23 fellowship in surgical pathology at the same place. which also 24 included covering dermatopathology, looking at all the skin 25 biopsies, diagnosis and workup of the cases. 575 575 of l532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A788 RECEIVED NYSCEF: 01/17/2023 [FILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM] PM INDEX INDEX NO‘ NO. 150116/2012 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff - Direct 573 1 And after my fellowship in surgical pathology, I 2 went on to North Shore University Hospital in Manhasset, where 3 they gave me the position of a provisional attending, which is 4 kind of intermediate between a fellow and a full attending, and 5 I did that for about nine months. 6 And then I got a job at westchester Medical 7 Center as an assistant attending and an assistant professor. 8 And that was in pathology. And basically it was surgical 9 pathology, which included all aspects of pathology. All 10 specimens. And I worked there from 1990, April 1st, to 1993. 11 And then I moved on to St. Joseph's Medical E 12 Center in Yonkers, and that I stayed on for about 12 years. 13 Again, I did surgical pathology, completely covered it, and we 14 had all kinds of specimens. 15 And after my job at St. Joseph's, which was the 16 job of an assistant director of pathology, I moved on to 17‘ Lutheran Medical Center in Brooklyn, where I was working as a 18‘ staff pathologist, and later as an attending, as an assistant 19 director of pathology. 20 And I also was at St. John's Episcopal Hospital, 21 where I was the director for about six months, I worked there. 22 And now I got a job as the lab director and 23 chairxnan of pathology at Robert Wood Johnson, and thaws where 24 I'm working now. 25 1,2 And among the positions you held, you were also NYU ,__,,_ _,,, ,_.x WIL}, 576 576 of 1532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A789 RECEIVED NYSCEF: 01/17/2023 [FILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM] PM INDEX INDEX NO‘ NO. 150116/2012 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff -Direct 574 1 Lutheran Medical Center? 2 A Yes, yes. 3 Q And you were also medical director of St. John's 4 Episcopal Hospital? 5 A Yes. 6 Q And you are certified, ma'am, by the American Board of 7 Pathology? 8 A Yes. 9 Q And that's a nationwide certification? 10 A Yes. 11 Q Now, have you written scholarly articles that have 12 been peer reviewed, in peer reviewed journals? 13 A Yes. 14 Q And are there about 30 of them? 15 A I have a lot of them, I don't know exactly. But my 16 best article was the one published in New England Journal of 17 Medicine, that was at start of my career. 18 Q I'm looking at three pages of publications. 19 A Yes. 20 Q I counted every one. 21 A Yes. 22 Q Okay. 23 Now, in your experience of about 25—— you did 24 that more than 25 years, as a pathologist and now director of 25 pathology, have you dealt with biopsies of skin specimens? ’ ii A A’ 7 i M kg 577 577 of l532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A790 RECEIVED NYSCEF: 01/17/2023 [FILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM PM nmEXNO‘15M1W2m2 INDEX NO. 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff - Direct 575 1 A Yes. 2 Q And over the course of more than 25 years at various 3 facilities, various hospitals, how many would you estimate you 4 have done? 5 A A lot. 6 Q Over 10,000 over 25 years? 7 A I'm not very good in math. But every week we got 8 about six or seven, at least, specimens, at least. 9 Q Okay. So over a period of more than 25 years, 10 whatever that adds up, okay? 11 A Yes. 12 Q And in your examinations, did you teach other doctors, 13 be them residents or fellows, about pathology, as to the goal 1.4 of pathology? 15 A All the time, yes. 16 Q Could you tell us what you told your students? 17 A Well, the students, I taught the fellows—— 18 THE COURT: Members of the jury, if you can't 19 hear this witness or you don't understand the witness, 20 just raise your hand and we will have the question and 21 answer repeated. 22 Go ahead, doctor. 23 THE WITNESS: Thank you. 24 A I taught the medical students, the residents, the 25 fellows; and at times at dififerent conferences we deallt with 7 7 77 W77” W V V N IN H7777” ‘Sig’ 578 578 of 1532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A791 RECEIVED NYSCEF: 01/17/2023 [FILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM PM nmEXNO‘15M1W2m2 INDEX NO. 150116/2012 NYSCEF DOC. DOC. NO. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff - Direct 576 1 other clinicians in other specialties. 2 And regarding the goal of pathology, appropriate 3 diagnosis in appropriate time. The earlier the diagnosis, 4 especially the grave ones, the better it is. And not to 5 hesitate to do tests, if indicated. 6 Q Ma'am, if you would keep your voice up, because it 7 seems to taper off if you move away from the microphone. 8 A Sorry. 9 Q So is the goal of pathology, then, to aid the treating 10 dermatologist to better protect the patient's health? 11 A Yes. 12 Q Is a purpose of pathology to let the dermatologist who 13 is treating the patient know all the possibilities of danger 14 that exists in that specimen? 15 A Yes. 16 Q And is that what a differential diagnosis is called? 17 A Yes. 18 Q That all of the possibilities that could exist, given 19 that specimen, should be—— that information should be given to 20 the treating doctor; is that correct? 21 A Yes. 22 Q Now, before a pathologist gets a specimen, the 23 treating dermatologist has a duty to tell the pathologist, as 24 well, correct? 25‘ A Yes, 7 7 7 77 7 7 7 7 77 7 "dig I I 579 579 of l532 1532 FILED: RICHMOND COUNTY CLERK 01/17/2023 01:27 PM INDEX NO. 150116/2012 NYSCEF DOC. NO. 425 A792 RECEIVED NYSCEF: 01/17/2023 IFILED: FILED: RICHMOND RICHMOND COUNTY COUNTY CLERK CLERK 03/23/2017 03/23/2017 01:17 01:17 PM PM INDEX INDEX NO. NO. 150116/2012 150116/2012 NYSCEF DOC. DOC. No. NO. 290 RECEIVED NYSCEF: NYSCEF: 03/23/2017 03/23/2017 Dr. Abbi - Plaintiff - Direct i 7