Q. Does that figure come from one work of literature
in the field particularly?
A. It's an average.
Q. Does the average come from one work of literature
in the field in particular or is it your own average from
several sources?
A. I don't suppose--I suppose it is a combination of
multiple literature series.
Q. Dr. Corrigan, do you have any training in surgical
oncology, aside from what you received in your formal medical
school and residency?
A. No.
Q. Doctor, including surgical treatment and any other
modalities that you might have used, on approximately how
many occasions prior to March, 1998 had you treated cancer of
the colon?
A. I don't recall the exact number.
Q. Do you know whether it was more than ten cases?
A. Yes.
Q. Do you know whether it was more than one hundred
cases?
A. Could be.
Q. Dr. Corrigan, did you discuss any of Mr. Monahan's
surgeries with the patient or with any members of his family
prior to the surgeries themselves?
A. I don't recall.
Q. Were you aware, sir, of what the risks of
abdominoperineal resection were generally in March, 1998?
A. Yes, I was.
Q. Dr. Corrigan, what risks of Mr. Monahan's March 21
operation were you aware of prior to the time the operation
actually began?
A. The surgery of abdominoperineal resection is one of
the major surgeries that a patient could undergo. The risks
and possible complications are innumerable. You can start
from patient undergoing shock and anaphylactic shock right
from the time of induction of anesthesia until the time the
patient wakes up. If you have any specific areas of
complications, I will be glad to discuss.
Q. Was bleeding that is difficult to control a known
risk of abdominoperineal resection in 1998?
A. Yes, it is.
Q. Was coagulopathy a known risk of the procedure?
A. Coagulopathy is a known risk of a procedure after
multiple transfusions or if the patient has an inherent
bleeding disorder to begin with.
Q. Did you ever have grounds to believe that
Mr. Monahan had had an inherent bleeding disorder
preoperatively?
A. I don't recall.
Q. Was abdominoperineal resection appropriate for
patients such as Mr. Monahan if the patient had a prior
bleeding disorder?
A. I would say no.
Q. Is trauma to the urological organs a known risk of
abdominoperineal resection for the removal of bowel cancer?
A. Yes, it is.
Q. Had you ever encountered trauma of urological
organs in any surgery prior to Mr. Monahan's?
A. No.
Q. How did you become familiar with the risk of trauma
to the urological organs in a surgery such as Mr. Monahan's?
A. Reading about the surgical procedure itself.
Q. What was done during Mr. Monahan's March 21 surgery
as a precautionary measure to prevent the possibility of
excessive bleeding?
A. I don't recall.
Q. What was done during Mr. Monahan's surgery, if you
know, to prevent the possibility of trauma to the urological
organs intraoperatively?
A. I don't recall.
Q. Did the particular location of Mr. Monahan's tumor
affect the risks of his abdominoperineal resection?
A. Yes.
Q. How?
A. As I reviewed my operative notes, since this was
done in 1998, my recollection of the events is strictly from
the operative notes and some I happen to remember. The tumor
had such severe desmoplastic reaction and attachment to the
urethra and the bladder we -- when we had isolated the tumor
from the rest of its connections we had divided a portion of
the urethra and the left ureter in order to get the tumor
out.
Q. Was the tumor attached to the ureter and urethra by
invading them or some other way?
A. It couldn't be invasion, because the pathology
report does not show that. It is the reaction that the tumor
produces in the adjacent tissues that makes these attachments
very, I should say strong that will, that we will have to
devise certain structures in order to remove the tumor.
Q. Did the attachment consist of fibrosis or something
else?
A. We usually call them desmoplastic reactions.
Q. Did you spell desmoplastic?
A. D-e-s-m-o-p-l-a-s-t-i-c.
Q. How do you define desmoplastic reaction?
A. You could say it is fibrosis, but it is
specifically seen in areas of cancer and the reaction it
produces in the surrounding tissues.
Q. Do you remember the appearance of the attachment
that you attribute to desmoplastic reaction in Mr. Monahan?
Q. Specifically do I remember?
Q. Yes, do you remember the appearance?
A. I don't remember.
Q. When did you conclude that desmoplastic reaction
was involved in Mr. Monahan's case?
A. At the time of surgery.
Q. Had you previously had any experience with a
desmoplastic reaction involving the ureter, urethra or
bladder in any patient?
A. No.
Q. Had you previously encountered in reviewing medical
literature any incidence of desmoplastic reaction involving
the ureter, bladder or urethra in a patient?
A. Yes.
Q. Was there any desmoplastic reaction in
Mr. Monahan's case involving any structure other than the
urethra, bladder or ureter?
A. I don't recall.
Q. Can desmoplastic reaction be produced to form an
attachment between tumor and bone, such as the sacrum?
A. It's possible.
Q. Did you ever form an impression as to whether
Mr. Monahan's sacrum was attached to his tumor by
desmoplastic reaction?
A. I don't recall the desmoplastic reaction.