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.