In the Superior Court of Pennsylvania - How Appealing

Q: Well, when I asked the first question, “Has your doctor told you
that your breast cancer is caused by hormone therapy,” and you said,
“Not in so many words”; right? Is that right?
A: Is that what I said?
Q: And then, my next question was, “Well, in what words are you
thinking they told you that?” And you said. “They told me it was
estrogen receptor positive”; right?
A: And it is — it was.
Q: Absolutely, that’s what the records say about it?
A: That’s right.
Attachments at 10–11.
R.188a.
Q: It is estrogen receptor positive. Did you think that meant that
your breast cancer was caused by hormone therapy?
A: Yes. I guess. Yes.
Later in her deposition, however, Mrs. Coleman clarified her response:
Q: Is there anything about your answer you want to change?
A: The doctor and I never discussed hormone therapy as a cause. I
have seen it in the medium — media, 2003 or so, and that was my
recollection of when I thought it was — might have been breast cancer
related — you know related.
Q: All right. So, is your testimony now that when the doctor told
you that your cancer was estrogen receptor positive, is your testimony,
now, after this break, that you don’t think that meant it was related to
hormones?
A: At the time, I — we did not discuss it, and I — I never gave it a
thought as to that.
– 18 –