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2021 Cannon Neg Direct

Terms in this set (40)

Q: Will you please introduce yourself to the court?
A: Hi. My name is Dr. Raymond Cannon -- and yes, everybody does love me.
Q: What do you do for a living?
A: You see, I am a medical doctor with expertise in the fields of toxicology and pharmacology (1). Currently, I work for a private consulting firm where I conduct independent death investigations.
Q: How long have you worked as a consultant?
A: For a little over six years now.
Q: Where did you go to school?
A: I got my Bachelor's degree in Chemistry from the Ohio State University. Thereafter, I received my Doctorate of Medicine from Harvard Medical School.
Q: What did you do before consulting?
A: Before I joined the firm, I was a Professor of Toxicology at Midlands Medical School. And before that, I was the Director of Toxicology at Massachusetts General Hospital.
Q: What exactly is your job at your consulting firm?
A: I am retained by counsel, in various civil and criminal cases, for my expertise in general medicine, toxicology, and pharmacology. I review and critique medical reports and witness testimony, among other documents, that are presented in each case. And sometimes, I provide my own opinion on them.
Q: Is that what you did in today's case?
A: Yes, it is.
Q: Did you rely on any principles or methods when writing your report?
A: Yes, I did.
Q: What methods and principles did you use?
A: I used the "S.A.Q." method.
Q: Have you used this method before?
A: Yes, hundreds of times in fact.
Q: In that case, would you mind explaining the SAQ method?
A: Not at all! It's an acronym, standing for Study - Analyze - and Question. I start by STUDYING the respective report of the treating physician. In this case, that would be Dr. Kwon's. Next, I ANALYZE the facts and evaluate what occurred from a medical standpoint. Finally, I QUESTION the conclusion. And oftentimes, I come to my own conclusion as well.
Q: So, if part of your method is to study and analyze, what facts or data did you utilize to complete your method?
A: I reviewed a copy of Dr. Kwon's report, toxicology reports, the death certificate of the deceased, and the affidavit of Angel Rodriguez, among other various documents.
Q: Did you apply the SAQ method to the facts and data you just mentioned?
A: Yes, I did. It's considered the gold standard in my field.
Q: So, if you were asked to form your own conclusion based off of Dr. Kwon's report, did you come to the same conclusions?
A: No. While I find that the facts are most likely consistent with the cause of death being organophosphate pesticide poisoning, I cannot necessarily rule out another cause of death. Essentially, Dr. Kwon's cause of death cannot be accepted as true at face value.
Q: What other cause of death did you consider in today's case?
A: I considered the possibility that Genesis Petrillo died of alcohol poisoning.
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