Item: Miller & Zois, Attorneys at Law
Rating: 5
Author: Terry Waldron

I, Thomas E. Jones, M.D., hereby certify, attest, and affirm that:

That I am a physician licensed to practice medicine in the State of Maryland and have been continuously licensed to practice medicine in the State of Maryland since 1971.
That I am a board certified physician in the field of Obstetrics and Gynecology and have been board certified since 1980.
That up to and including the date of this certificate, I have over 30 continuous years of surgical/clinical experience in the field of Obstetrics and Gynecology which include performing hysterectomies.
That I have reviewed the medical records of Cindy Smith for a medical procedure (attempted hysterectomy) that was performed by Steven T. Forrest, M.D. on January 13, 2006, at the Parks Medical Center in Baltimore, Maryland.
That it is my opinion, within a reasonable degree of medical probability, that Steven T. Forrest, M.D. departed from the applicable standard of medical care when he operated on Cindy Smith on January 3, 2007, by cutting Cindy Smith’s left illiac vein and artery, and that this departure from the applicable standard of medical care directly and proximately caused a physical injury to Cindy Smith ( i.e. the severed left illiac vein and artery), and that as a direct and proximate result of this departure from the applicable standard of medical care and resulting physical injury that Cindy Smith required additional emergency medical care and treatment to repair the damage to her left illiac vein and artery and she has required additional follow up medical care and treatment.
That it is my opinion within a reasonable degree of medical probability that Steven T. Forrest, M.D. P.A, , by and through the actions of its agent/servant/employee, Steven T. Forrest, M.D., departed from the applicable standard of medical care when operated on Cindy Smith on January 3, 2007, and cut Cindy Smith’s left illiac vein and artery, and that this departure from the applicable standard of medical care directly and proximately caused a physical injury to Cindy Smith ( i.e. the severed left illiac vein and artery), and that as a direct and proximate result of this departure from the applicable standard of medical care and resulting physical injury that Cindy Smith required additional emergency medical care and treatment to repair the damage to her left illiac vein and artery and she has required additional follow up medical care and treatment.
That I do not devote annually more than 20% of my professional activities to activities that directly involve testimony in personal injury claims.
That I am not a party to the pending litigation; that I am not an employee or partner of any party to the pending litigation; that I am not an employee or stockholder of any professional corporation of which any party of the pending litigation is a stockholder.
That it is my opinion, within a reasonable degree of medical probability, that John M. Woods, (and Steven T. Forrest, M.D., P.A. by and through the actions of Steven T. Forrest, M.D.) departed from the applicable standard of medical care when Steven T. Forrest, M.D. operated on Cindy Smith, on January 13, 2006, and continued to dissect in an area where he did not clearly visualize all of the surrounding blood vessels, thereby proximately causing in an injury to Cindy Smith, that being, a severed left illiac vein and artery.

___________________________
THOMAS E. JONES

___________________________
DATE

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