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.