Q.   Dr. Koback, now that your office records are in 
             evidence, would you be kind enough to refer to your records 
             to the first date that you saw William Reiber as a patient? 
                  A.   That was on May 6th, 1982. 
                  Q.   Under the circumstances, was what was the reason 
             for the visit and what you did for him? 
                  A.   According to my chart, Mr. Reiber had a bursitis, 
             which is an inflammation around the metatarsal joint, that is 
             the bottom of the foot behind the little toe.  Again, 
             inflammation.  We gave Mr. Reiber hydrotherapy which helps to 
             reduce inflammation and aids in circulation.  We also put a 
             padding on the area to take pain or pressure off the area 
             when he walked. 
                  Q.   How does hydrotherapy aid in circulation?
                  A.   It is a combination of the temperature of the 
             therapy, which is approximately about 97 degrees and that the 
             warmth itself stimulates circulation, and as does the 
             agitation of the water. 
                  Q.   Why did you want to stimulate circulation?
                  A.   Well, bursitis, it generally gets more blood to the 
             area and helps bathe the area and in turn reduces 
                  Q.   When was the next time? 
                  A.   December 16th, 1982. 
                  Q.   That is approximately seven months later.
                  A.   Correct. 
                  Q.   Would you tell us what you saw then and what you 
             did for him then? 
                  A.   The exact same thing. 
                  Q.   The exact same thing? 
                  A.   Hydrotherapy and also--well, this doesn't have 
             padding this time.  But the diagnosis was the same, bursitis 
             on the left fifth MT joint.
                  Q.   In layman's terms, so when you say bursitis on the 
             left MT joint, could you tell us what foot? 
                  A.   This is the left foot behind the little toe and  
             bursitis is generally inflammation with redness and swelling.
                  Q.   Redness and swelling behind the left--
                  A.   Fifth toe. 
                  Q.   And again you gave him the hydrotherapy? 
                  A.   Yes, that is correct. 
                  Q.   When did you see him again? 
                  A.   January 28, 1983. 
                  Q.   '83. 
                  A.   Yes, sir, and this time the diagnosis was left 
             hallux, which is the great toe, infected other fibula 
             aspects, and the fibula simply means the side of the big toe 
             that is towards the little toe. 
                  Q.   Which foot are we talking about? 
                  A.   The left foot. 
                  Q.   When you talk about the big toe, what is that? 
                  A.   That is the first toe or the big toe, hallux or 
             great toe. 
                  Q.   What did you find on that visit? 
                  A.   There was an infection on the fibula aspect. 
                  Q.   And fibula aspect means? 
                  A.   Towards the little toe, tibial meaning towards the 
             big toe, midline of the body. 
                  Q.   When you say "infection," could you tell us what 
             that means in layperson's definition? 
                  A.   Layman's terms, redness and pain upon pressure. 
                  Q.   What did you do for him on that visit? 
                  A.   According to that visit, okay, this is not my 
             handwriting.  Dr. Bloodstein did hydrotherapy.  Although it 
             does not state that a sterile dressing was put on the toe, 
             with this diagnosis it would be safe to assume it. 
                  Q.   You don't know from that? 
                  A.   Yes. 
                  Q.   That is Dr. Bloodstein who made the entry? 
                  A.   Yes. 
                  Q.   As far as you know, that record reflects the 
                  A.   Yes, that is correct.
                  Q.   Could you go to the next one? 
                  A.   1/4/83.  Again, Dr. Bloodstein is there.  And is on 
             the bottom plantar, which simply means the bottom of the heel 
             of the left foot, there is an infected fissure, which is 
             simply a crack in the skin.  It's not unusual for germs to 
             get into this crack and cause mild infection and that was 
             treated by incising and draining the infected fissure. 
                  Q.   Incising and draining? 
                  A.   Cutting into and allowing any kind of pus to come 
             out or any kind of infectious material. 
                  Q.   Was that done by you or your associates?
                  A.   Done by me, but Bloodstein started it. 
                  Q.   When is the next time that you saw Mr. Reiber? 
                  A.   June 30th, 1983. 
                  Q.   Would you tell us what he presented at that visit? 
                  A.   Yes.  On his right foot there was an ulceration 
             narrow pathic ulcers, which basically means that the narrow 
             pathic of the nerve endings were such that the feeling was 
             not as great in that particular area.  That is very commonly 
             seen with diabetes. 
                       There was extra pressure under the fourth fifth 
             metatarsal heads on the bottom of the foot around the area 
             where the ball of the foot hits the ground. 
                  Q.   The fourth? 
                  A.   Around towards the middle toe and the ones next to 
                  Q.   What was done at that time? 
                  A.   The hard skin around the ulceration was debrided.
                  Q.   What does that mean? 
                  A.   Scraped off to reduce the pressure area of the 
             ulcer.  If you reduce it, it tends to heal up rather quickly.
                  Q.   Continue. 
                  A.   Apply a Biozyme C dressing.  Biozyme C debriding 
             enzymes, it helps to clean the area and allow for the body to 
             help heal itself.
                  Q.   How was that applied? 
                  A.   That is an ointment and it is applied right over 
             the ulceration and then there is a sterile dressing gauze put 
             on it. 
                  Q.   Anything else? 
                  A.   Two of the Biozyme was prescribed to Mr. Reiber and 
             instructed to apply this to the wound twice a day, this is 
                  Q.   I see an entry there with the initials H202. 
                  A.   Yes. 
                  Q.   What is that? 
                  A.   Patient received hydroperoxide.  What is that, what 
             is hydroperoxide?  If you ever put it on your hand or spilled 
             it, you would see a lot of bubbles.  Those bubbles are oxygen 
             and it helps to kill any germs on the wound. 
                  Q.   You say he was advised, he was told to do it by 
                  A.   Yes. 
                  Q.   Anything else on that visit? 
                  A.   That is the only treatment and advice rendered. 
                  Q.   What did the PTR1WK stand for? 
                  A.   Patient returned one week. 
                  Q.   What does that mean? 
                  A.   That we wanted to see Mr. Reiber back in the office 
             to see in one week to see how he was doing. 
                  Q.   Why was that? 
                  A.   He had an open ulcer on his foot. 
                  Q.   Did you see him again? 
                  A.   Yes, July 7th. 
                  Q.   About one week later? 
                  A.   Yes. 
                  Q.   And what did that visit reveal? 
                  A.   That the ulceration was responding to the treatment 
             that we had rendered and advice that we had given.  The wound 
             was debrided, scraped around the hard skin to reduce the 
             pressure and the patient was advised to continue as directed 
             previously, and the fact it was showing improvement was 
             needed again, that was Dr. Bloodstein's entry. 
                  Q.   Did you ever do a blood culture to determine what 
             the nature of the infection was? 
                  A.   It was a skin culture that was done on June 30th 
             and the results are in the chart after the 7/7 entry. 
                  Q.   What did that reveal? 
                  A.   It reveals that there was a staphylococcus 
             ulceration.  Staphylococcus to the common person is 
             contamination, which means it is very commonly seen on the 
             feet in general, even without an infection.
                  Q.   Do you see Mr. Reiber again? 
                  A.   Yes, one week after the 7/7 visit, we saw him July 
             14th, 1983. 
                  Q.   What did that visit reveal? 
                  A.   The fact that the ulceration was responding to the 
             therapy, the treatment we were giving and the patient was 
             advised to continue the dressing as directed with the Biozyme