DR.

ARROJO (CROSS)

Q: What other hospitals are you affiliated with?

A: No other hospital other than SLU-HSH

Q: Do you go to these other hospitals and clinics?

A: No

Q: In the OPD of SLU Hospital, How many patients do you usually have in a given schedule? I
understand that you would not stay in the Hospital for the whole day.
A: I have about 20 patients a day on average

Q: With every patient you have, how do you go about them?

A: Most of my patients appear for consultations

Q: So in the average, how long does it usually take for you to examine a single patient?
A: About 20 minutes on average

Q: And you said that you had training with Andrology and Male Fertility, would that mean that it
would be easier for you to determine whether the patient has a problem with his reproductive
system than any other doctor?
A: Yes

Q: And because you have more experiences with these kinds of patients, nonetheless you already
have an idea as to what proper examinations you will conduct with them?
A: Yes

Q: Do you have a secretary, doctor?

A: No

Q: And you said that you conducted the cardiovascular examinations yourself and took the vital
signs? Is that not supposed to be the job of the OPD nurses?
A: I personally took them. Yes, but it is possible that I can do them myself.

Q: Is that why it took you nearly an hour in your first encounter with the patient? And almost 2
hours in the next examination?
A: More or less those times

Q: This honorable court would like to know doctor, how long does it take for you to ask him about
his medical history? How long does it take to conduct the physical examination? Would it
really take you an hour or two?
A: Yes, if everything is normal

Q: The laboratory tests I believe are not readily available in your office right?
A: Yes

Q: You also said that you conducted physical examinations on his cardiovascular, neurologic and
genitourinary system, correct me if I am wrong Doctor but these are Internal organs right?
How could you physically examine them?
A: Some tests can be done in the office, like certain neurologic tests such as reflex testing, gait
testing, sensory and motor examinations. When other tests require microscopic analysis like
blood and urine testing, samples are taken in the office and are then forwarded to the
Laboratory and results are forwarded to me. Some tests like x-rays and CT-scans require the
patient to personally be there, I refer the patient for a quick examination they come back and
the results are forwarded to me at a later time. It’s just a quick walk to the facilities and they
come back after. That is standard procedure here in the hospital.

Q: The patient when he came to you only said that he wanted to be examined whether he has
erectile dysfunction for his annulment case. Is that right?
A: Yes

Q: And you said that you immediately proceeded with the physical examination, that includes
physical examination on his genitals.
A: Yes

Q: Would it be possible doctor that in your first meeting with the patient, you would be able to
identify whether he has an erectile dysfunction or not given that you are an expert in the field,
so you can issue the necessary medical report that same day?
A: I did not issue a medical report on the same day. (Refer to the medical report; date of issue =/=
date of examination) The date on the medical report refers to the date of examination. I issued
the medical report on the second meeting.

Q: So what is the necessity of meeting for the second time to spend with your patient for less than
2 hours?
A: The next meeting is to follow up on lab results and conduct additional tests that do not require
other facilities. It was also the date of issue of the medical report.

Counsel: No further questions your Honor

DR. ARROJO (R DIRECT)

Q: Doctor, you mentioned you handle 20 clients in one day. How do you handle so many cases in
a typical workday?
A: I have other people assisting me.

Q: Who are these people?

A: They are my residents, interns, and clerks. Sometimes, nurses.

Q: Please break down the staff you have in your office.

A: In one day, I have at least two residents, two interns, and five clerks.

Q: What do they do?

A: On typical days, I let my residents handle less serious cases so that they may learn from on-the-
job experience. The interns and clerks handle less serious work. I only supervise my residents’
diagnoses. That is standard operating procedure in the hospital.

Q: Why do the residents handle them?

A: Residents are already licensed physicians, training under my specialty. It is only normal for
them to learn this way.

Q: What are the cases you handle then?

A: I handle more atypical cases and cases which especially need my expertise.

Q: Why did you personally examine my client?

A: His concern involved my professional determination whether he was healthy or not.

Q: What makes his case so different from the others?

A: All the other cases that go through my office are typically consultations. Patients for
consultation already know there’s something wrong with them, and usually they manifest
symptoms showing an abnormality or disease; not in Mr. Agliam’s case. Mr. Agliam appeared
before me saying that he wanted to be examined for any disease in relation to his sexual
function, not really sure whether he is sick or not. He told me that his wife filed a case against
him for not being able to become erect during sex, although he says he does become erect and
they do have sex. I found it peculiar that his wife is doing this.

Q: How do I know that you are not in collusion with the client?
A: Mr. Agliam told me he is willing to go through another medical and physical examination from
another physician. It is also possible that he could have gone to another physician without my
knowledge, and that physician could have concluded with distinctly different results. He is also
very likely to be medically and physically examined by a court-ordered physician. If you’re
saying I am in collusion with the client and I made the results in his favor, it would be glaringly
easy to disprove me and ruin my reputation as a Urologist. I would never do that to for a
patient.