1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 2 FOR THE COUNTY OF FRESNO 3 -oOo- 4 In the Matter of, ) ) 5 LINDA K. ADANALIAN, ) ) 6 Deceased. ) No. 652295-7 7 8 -oOo- 9 Fresno, California; May 26, 2000 10 -oOo- 11 12 DEPOSITION OF DAVID HADDEN, M.D. 13 14 -oOo- 15 16 17 18 19 20 21 22 23 24 REPORTED BY: 25 GAE WERFEL, CSR, RPR *** CERTIFICATE NO. 4919 0001 FRESNO COURT REPORTERS *** 559.224.9700 1 I N D E X 2 EXAMINATION PAGE 3 4 BY MR. PABOOJIAN 4, 10 5 BY MR. MELIKIAN 10 6 BY MR. DAVID DALITION 11 7 8 9 -oOo- 10 11 EXHIBITS 12 13 NONE MARKED NOR ATTACHED 14 15 16 17 18 19 20 21 22 23 24 25 0002 FRESNO COURT REPORTERS *** 559.224.9700 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 2 FOR THE COUNTY OF FRESNO 3 -oOo- 4 In the Matter of, ) ) 5 LINDA K. ADANALIAN, ) ) 6 Deceased. ) No. 652295-7 ) 7 8 9 -oOo- 10 Fresno, California; May 26, 2000 11 -oOo- 12 The deposition of DAVID HADDEN, M.D. was scheduled 13 in the above-entitled matter pursuant to the provisions of 14 law pertaining to the taking and use of depositions, on May 15 26, 2000, at the hour of 4:52 P.M., at the offices of FRESNO 16 COUNTY CORONER'S OFFICE, 760 W. Nielsen, Fresno, California, 17 before Gae Werfel, C.S.R. No. 4919, a Certified Shorthand 18 Reporter of the State of California, having offices located 19 at Fresno, California. 20 21 22 23 24 25 0003 FRESNO COURT REPORTERS *** 559.224.9700 1 APPEARANCES OF COUNSEL: 2 For MARK ADANALIAN: 3 MARDEROSIAN, OREN & PABOOJIAN BY: WARREN R. PABOOJIAN 4 1260 Fulton Mall Fresno, California 93721 5 For GEORGE DALITION & DAVID DALITION: 6 THORTON DAVIDSON & ASSOCIATES 7 BY: ALLAN MELIKIAN 2055 San Joaquin Street 8 Fresno, California 93721 9 For the COUNTY OF FRESNO: 10 COUNTY COUNSEL BY: JULIANA F. GMUR 11 DEPUTY COUNTY COUNSEL 2220 Tulare Street, 5th Flr. 12 Fresno, California 93721 13 -oOo- 14 Also present was George Dalition, David Dalition, 15 and Mark Adanalian. 16 The following proceedings occurred at the hour of 17 3:25 p.m., and testimony taken, to wit: 18 -oOo- 19 DAVID HADDEN, M.D.: 20 Being first duly sworn by the 21 Reporter, testified as follows: 22 -oOo- 23 EXAMINATION BY MR. PABOOJIAN 24 Q. Please state your name for the record? 25 A. David M. Hadden, H A D D E N. 0004 FRESNO COURT REPORTERS *** 559.224.9700 1 Q. Dr. Hadden, what is your current employment 2 position? 3 A. I'm the Fresno County Public Administrator, Public 4 Guardian, Coroner. 5 Q. And how long have you held that position? 6 A. Twenty-one years. 7 Q. And have you in the last five years -- strike that. 8 You're an M.D. also; correct? 9 A. Correct, yes. 10 Q. And are you licensed to practice medicine in the 11 state of California? 12 A. Yes. 13 Q. And do you have a specialty area or are you board 14 certified in any area? 15 A. Pathology, clinical and anatomic. 16 Q. Okay. And are you board certified in any of those 17 areas? 18 A. In clinical and anatomic pathology. 19 Q. And in the last five years, have you performed any 20 autopsies yourself? 21 A. No. 22 Q. You have a staff that does that; correct? 23 A. Yes. A staff of forensic pathologists. 24 Q. Okay, thank you. And Doctor, you've had your 25 deposition taken before, I presume? 0005 FRESNO COURT REPORTERS *** 559.224.9700 1 A. Yes. 2 Q. You understand that you're under oath? 3 A. Yes. 4 Q. Same oath you take in front of a judge and jury; 5 you understand that? 6 A. Yes. 7 Q. No reason for me to go through all the formalities? 8 A. No. 9 Q. Okay. Doctor, you have been involved to some 10 extent in a particular case regarding Linda Adanalian; is 11 that correct? 12 A. In an administrative capacity. 13 Q. Right. And you have met with Linda's family 14 members, and when I say family members, I mean her immediate, 15 have you met with Linda's dad, Mr. Dalition? 16 A. Yes. 17 Q. You met with Dave Dalition? 18 A. Yes. 19 Q. Have you met with Meg Dalition, the sister from 20 Texas? 21 A. I believe so. If that's the young lady from Texas 22 or someplace. 23 Q. Sure. 24 A. Yes. 25 Q. And what were the purposes of those meetings? 0006 FRESNO COURT REPORTERS *** 559.224.9700 1 A. They wished to express to me their concerns about 2 our inability to determine the cause of death. 3 Q. And what were their comments about that? 4 A. That they felt that we should do everything 5 possible to determine a cause of death. I assured them we 6 would. 7 Q. And as far as determining the cause of death, did 8 the discussion of exhuming the body ever come up? 9 A. I believe it came up toward -- just recently, not 10 initially, but just recently. 11 Q. Okay. Was that a suggestion made to you by the 12 Dalition family, and then you consulted with your coroner or 13 how did this come about? 14 A. I believe the first time I heard about the 15 exhumation was from Dr. Gopal. 16 Q. And what did he tell you about that? 17 A. He said that this was an item for discussion. 18 Q. Did he explain why? 19 A. Yes. 20 Q. And what did he say? 21 A. That we do not have any blood to test for mercury 22 that is not already contaminated with mercury. 23 Q. I read your petition, and I assume your petition is 24 correct, the one submitted in court? 25 A. Yes. 0007 FRESNO COURT REPORTERS *** 559.224.9700 1 Q. And with the primary reason, as far as in your 2 mind, for exhuming the body would be to disprove this mercury 3 toxicity? 4 A. No. 5 Q. What would be the primary reason? 6 A. To either prove or disprove the mercury toxicity. 7 Q. It's my understanding that there are indications 8 that the current mercury toxicity level that was found in the 9 blood was from a tainted test; is that your understanding? 10 A. That's my understanding. 11 Q. And so you're basically going in and exhuming the 12 body just to make sure that that's correct; would that be a 13 fair statement? 14 A. That would be a fair statement. 15 Q. Anything else you're looking for? 16 A. I believe that since we're going to exhume the 17 body, we should also obtain other specimens so that if, in 18 the future, there are any other testing or other laboratories 19 need to be involved, that we have enough specimen that we can 20 share it or have other tests run which may be unknown to us 21 at this time. 22 Q. Dr. Gopal is your senior forensic pathologist 23 that's overseeing this; is that correct? 24 A. He's our chief forensic pathologist. 25 Q. As far as exhuming the body, would you defer to him 0008 FRESNO COURT REPORTERS *** 559.224.9700 1 as far as the need to do that? 2 A. I would. 3 Q. And your petition and declaration submitted to the 4 court is basically, in large part, based upon your 5 discussions with Dr. Gopal and his need to harvest additional 6 samples? 7 A. That's correct. 8 Q. All right. Have you at all met with the Fresno 9 Police Department in regard to this particular case? 10 A. No. 11 Q. Did you personally ever contact the Fresno Police 12 Department in regard to Linda Adanalian's death? 13 A. No. 14 Q. And you're not aware of anyone from your office 15 ever contacting the Fresno Police Department? 16 A. I'm unaware of anyone contacting the department. 17 Q. Are you aware that the Fresno Police Department 18 have been contacted? 19 A. I have heard that. 20 Q. What have you heard? 21 A. Just that they were contacted. 22 Q. Did they tell you by whom? 23 A. No, I haven't had any conversations with them. 24 MR. PABOOJIAN: All right. Doctor, I don't have 25 any more questions. 0009 FRESNO COURT REPORTERS *** 559.224.9700 1 A. Thank you. 2 MR. MELIKIAN: I just have two questions. 3 EXAMINATION BY MR. MELIKIAN 4 Q. Doctor, you said that one of the purposes -- the 5 primary purpose, I think you described, is the proving or 6 disproving the mercury toxicity? 7 A. Yes. 8 Q. There are other tests and so forth that will be 9 performed; is that not correct? 10 A. Well, at this time, I would defer to Dr. Gopal and 11 that's why we want the additional specimens. If he or 12 Dr. Siu decide that there's something else they would like to 13 do, then, we will have the specimen available. 14 FURTHER EXAMINATION BY MR. PABOOJIAN 15 Q. You have no objections, on behalf of my client, of 16 me having a forensic pathologist present at the time that the 17 body his being exhumed? 18 A. None whatsoever. 19 FURTHER EXAMINATION BY MR. MELIKIAN 20 Q. Also you won't have any problem if we had 21 Dr. Pfeifer or somebody else present, as long as it didn't 22 disrupt any type of testing and so forth at the harvesting? 23 A. I have no problem with outside professional people 24 being present, as long as both parties aren't going to use 25 this as a contentious -- 0010 FRESNO COURT REPORTERS *** 559.224.9700 1 Q. Of course. 2 A. -- event. 3 MS. GMUR: How many questions do you have? 4 THE WITNESS: You have one more question, 5 Counselor. You requested two. 6 MR. MELIKIAN: You have a question, Dave, you want 7 to ask? 8 EXAMINATION BY MR. DAVID DALITION 9 Q. Just with regard to the heart, Dr. Hadden, and 10 whether it would show any signs of infarct, if a person had 11 been experiencing chest and left radiating arm pain two to 12 three days before -- 13 A. I just want you to know that I'm testifying here as 14 the administrative head of the department. I'm referring all 15 medical questions to Dr. Gopal, who is a forensic 16 pathologist. 17 MR. PABOOJIAN: I'm going to object, lacks 18 foundation and goes beyond his expertise. 19 MR. DALITION: Thank you. 20 MS. GMUR: I think we're done. 21 (The deposition was concluded at 5:15 p.m.) 22 -oOo- 23 24 25 0011 FRESNO COURT REPORTERS *** 559.224.9700 1 2 3 I hereby declare under penalty of perjury that 4 I have read the foregoing and it is true and correct to the 5 best of my knowledge, including any corrections that I have 6 made. 7 8 DAVID HADDEN, M.D. 9 Subscribed to this day of , 20 . 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0012 FRESNO COURT REPORTERS *** 559.224.9700 1 State of California, ) ) ss. 2 County of Fresno. ) 3 4 I, GAE WERFEL, a Certified Shorthand Reporter of 5 the State of California, do hereby certify that the witness 6 in the foregoing deposition, named 7 DAVID HADDEN, M.D., 8 was by me duly sworn to testify to the truth, the whole truth 9 and nothing but the truth in the within-entitled cause; that 10 said deposition was taken at the time and place therein 11 named; that the testimony of said witness was reported by me, 12 a disinterested person, and thereafter transcribed into the 13 foregoing pages. 14 15 And I further certify that I am not of counsel or 16 attorney for either or any of the parties to said deposition, 17 nor in any way interested in the outcome of the cause named 18 in said caption. 19 20 In Witness Whereof, I have hereunto set my hand at 21 my office in Fresno, California, this 29th day of May, 2000. 22 23 GAE WERFEL, C.S.R. No. 4919 24 25 0013 FRESNO COURT REPORTERS *** 559.224.9700