STATE OF FLORIDA
COUNTY OF COLLIER
††††††††††† BEFORE ME the undersigned authority personally appeared Dr. William Scott Russell, who being first duly sworn, deposes and says:
1.†††††††† My name is William Scott Russell, I am over the age of 18 years, and make this statement on personal information.
2.†††††††† I am a licensed medical doctor in the State of Florida and am presently retired.† I took my M.D. degree from the University of Virginia School of Medicine in 1963.† I did a a† residency in neurology at Jackson Memorial Hospital in Miami, followed by a position as Senior Resident in Neurology at the Medical College of Virginia.† Following that, I did fellowship training in cerebrovascular disease and electroencephalogy at the same institution.† I was in private practice in neurology in Miami from 1968 to 1989, and, in fact, was the first neurologist in that community with an office south of Flagler Street.†† While in Miami, I was either an active staff member or a consulting staff member of the medical staffs at the following institutions: South Miami Hospital, Baptist Hospital (where I conducted the bulk of my practice), Larkin General Hospital, Variety Childrenís Hospital, Coral Reef Hospital, Mercy Hospital, and James Archer Smith Hospital.† From 1989 until 1998, I was in private practice in Clearwater, Florida, as a neurologist.
3.†††††††† I have reviewed the medical records of Theresa Marie Schiavo, a videotape of her, the trial testimony of Dr. Barnhill, the affidavits of Drs. Carpenter and Young and that of Bishop Larkin filed in her guardianship court file, the motion for rehearing, and various letters from Ms Schiavoís family members.
4.†††††††† Based on these materials, it is my medical opinion that Ms Schiavo is not comatose, not vegetative and by no means brain dead.† Undoubtedly she is more aware of her surroundings than former President Reagan.† She appears to be responsive to her surroundings, not by talking, but by voluntarily looking at the source of sound.
5.†††††††† This patientís care has been marred by a lack of physical therapy, absence of which absolutely contributes to the evolution of contractures, which Ms Schiavo has, and† which will contribute to the appearance of a vegetative state.
6.†††††††† In addition, I have personal experience with the techniques employed by Dr. William Hammesfahr.† Toward the end of 1996, I awakened one morning in a confused and disoriented state, unable to speak.† I recognized the symptoms of expressive aphasia, or the inability to talk.† Immediately, I went to Dr. Hammesfahrís office.† He scheduled an MRI, an EEG† and other studies, which confirmed I had had a small stroke.† He then had me take one dose of medication, and I was talking again within a half-hour.†
FURTHER AFFIANT SAYETH NAUGHT.
††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††† ††††††††††††††††††††††††††††††††††† ††††††††††††††††††††††††††††††
††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††† William Scott Russell, M.D.
The foregoing instrument was acknowledged before me this ____ day of May, 2001, by William Scott Russell, who is personally known to me OR who produced a Florida driverís license as identification, and who did / did not take an oath.
††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††† Notary Public
My commission expires: