McKee V. Laurion: Excerpts From Defendant’s Deposition

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JANUARY 6, 2011, and JANUARY 7, 2011

Tendentious Lawyer

Marshall Tanick, Plaintiff’s Attorney

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Dennis Laurion, Defendant

During David McKee MD V. Dennis K. Laurion, Sixth Judicial District Judge Eric Hylden had full transcripts of depositions placed into the case record. Defendant Laurion was deposed from 1:14 p.m. through 5:27 p.m. on Thursday, January 6, 2011. On Friday, January 7, 2011, he was deposed from 9:17 a.m. until 10:30 a. m. The deposition transcript was printed as 247 pages with a 37 page index. The word “factual” appears 6 times, the word “nurse” appears 16 times, the word “nurses” appears 16 times, the word “nursing” appears 5 times, the word “purpose” appears 11 times, the name “Stodghill” appears 19 times, and the word “tool” appears 12 times.

Below are excerpts of the Defendant’s deposition answers about Internet postings and correspondence.

TANICK: What you’ve told us up to now, Mr. Laurion, represents, to the best of your recollection, everything you can remember about the incident with Dr. McKee on April 29th – I’m sorry, April 19th, 2010, with your father in the hospital. Right?

LAURION: I think so, up to that point.

TANICK: Okay. And what you’ve given us and what you’ve told us are factual recitations of what you remember occurring. Right?

LAURION: They are my recollection of what happened.

TANICK: Well, they are the facts as you remember them. Right?

LAURION: Okay. Yes.

TANICK: All right. So what you were putting on there was your recollection of what had occurred at this incident on February 23rd – April 28th – the 19th. Right.

LAURION: Yes.

TANICK: It was a factual recitation of what you recall. Right?

LAURION: There again, I don’t know what you mean. I recited it as accurately as I recalled.

TANICK: Well, you believed you were putting facts on there. Right?

LAURION: I believed that I was giving an accurate account of what happened.

TANICK: A factual account?

LAURION: I don’t know.

TANICK: You don’t know if you were stating facts or not?

LAURION: I was stating my recollection, my impressions.

TANICK: Do you agree with what’s set forth in paragraph 4, that what you stated – the materials that you submitted to various entities, including the Minnesota Board of Medical Practice, constituted, quote, “a factual recitation of what you observed and heard” concerning Dr. McKee’s conduct when he was examining your father?

LAURION: I think they constitute the exactness of what I saw.”

TANICK: Was there anything else about [Dr. McKee’s] words, his body language, his attitude, his conduct, his facial features that indicated to you that he was either upset or irritated or disturbed to be having to do this?

LAURION: Through that point or by the end –

TANICK: Up to – no, up to the point we’re at now.

LAURION: No, I think there was his stride, and it was the tone of voice. His face looked a little rigid to me.

TANICK: Anything else?

LAURION: I don’t think so.

TANICK: Did he look like he was serious-minded?

LAURION: I really don’t know how to answer that.

TANICK: What do you mean, his face looked rigid?

LAURION: Kind of like the look he gave me just a moment ago when I made the comment that I thought he was too important to talk to people.

TANICK: How would you describe a rigid face? Facial feature?

LAURION: As a rigid facial feature.

TANICK: And you’ve told us everything that happened during that discussion. Right?

LAURION: I believe so.

TANICK: Okay. Did your father have any further interaction with Dr. McKee after he left the hospital?

LAURION: With Dr. McKee or Dr. McKee’s staff?

TANICK: Well, was he scheduled for a follow-up visit with Dr. McKee after – after your father’s discharge?

LAURION: That’s a matter of contention.

TANICK: Well, I’m asking you.

LAURION: Dr. McKee’s office says he was. My father says he wasn’t.

TANICK: So what – do you have an understanding one way or the other whether he was – there was a plan or an intent or a desire or a contemplation that he would be seeing Dr. McKee again, if you know?

LAURION: My mother received a phone call that said, “The doctor would like to see your husband again” or “Ken again” or “Mr. Laurion again.” My mother did not want to accede to that, but she didn’t want to argue with it either, so she said, “Oh, he’s still home-bound,” and she was told, “Oh, we’ll make the appointment in the future.” And I think at that point my mother didn’t respond any further. When she told my father that she had been called to make an appointment, he said, “Call them back and tell them I’m not coming in there. I’m not going to see him again.” My mother called back and said that she wanted to cancel the appointment and she was – when she hung up, she was not – my father said, “Did she ask why?” and she said, “Nope. They just said okay.” And he said, “I did not cancel an appointment. I refused an appointment. I wasn’t asked if I wanted an appointment.” Nor was anything said in his discharge summary about a return visit to Dr. McKee.

TANICK: Did your mother then, to your knowledge, have two conversations with Dr. McKee’s staff or office?

LAURION: Yes. She was called to establish the appointment. Then she called back at my father’s direction to cancel the appointment.

TANICK: Were you, Mr. Laurion, in the loop on either of those conversations?

LAURION: No.

TANICK: When did you become aware that those conversations occurred?

LAURION: Just at a subsequent visit to their house.

TANICK: They told you – your mother told you about it? Your mother and father told you about it?

LAURION: Yeah.

KELLY: All right. When you left Kenneth Laurion, did you give him any instructions or did you provide him with any information concerning a follow-up?

MCKEE: By follow-up?

KELLY: I mean seeing him at some later date.

MCKEE: We wouldn’t have talked about follow-up, like after discharge or anything like that at that point. That probably would have been – well, unless I expected him to leave later that day or something that would have been a little, you know, ahead of the game.

TANICK: Okay. All right. What was your reaction, if anything, when [the nurse] mentioned – made the comment about Dr. McKee being a, quote, “real tool?” What did that strike you as?

KELLY: Well, you’ve already asked that question twice, and it’s been answered twice. Take another swing at it, but there’s a limit.

KELLY: Just so that we can identify this for the record, what is the source of this particular Exhibit 1, Counsel?

TANICK: Don’t know. It is what it is.

REPORTER: Exhibit 2.

LAURION: You’re handing this to me?

TANICK: Yeah. You’ll have a copy there, Counselor. Just give me a minute, please. Maybe I don’t have an extra copy of it. All right, Mr. –

KELLY: Well, wait a minute.

TANICK: I don’t have a copy there.

KELLY: Well, we’ll get some copies.

LAURION: Then I have to clarify the question.

TANICK: Okay.

LAURION: Why did you not print the whole Web page so that it could be seen in its context?

TANICK: Well, I’m asking you. Okay?

LAURION: I’m asking you to clarify the question.

KELLY: Just a minute.

TANICK: My question – Go ahead. Let me finish here.

TANICK: Well, I take it, then, that you’re telling us that you presumably looked up the Wikipedia posting – Wikipedia on your computer?

KELLY: He hasn’t said that.

TANICK: No, I said, “I take it.”

KELLY: You’re putting words in his mouth. He hasn’t said that.

TANICK: All right. Well, I’ll take them – all right. Well, you don’t have to argue with me. You don’t have to shout. I’ll take it out. I’ll take it out of your mouth and put it in my mouth.

TANICK: Mark that as Exhibit 4.

KELLY: Isn’t that Exhibit 5?

TANICK: I’m sorry. Is that Exhibit 5?

REPORTER: Yes. I’m sorry. Exhibit 5.

TANICK: You didn’t care – you didn’t care what the affect would be in any way?

KELLY: He didn’t say that, Counsel. Objection. You’re putting words into his mouth again. And that wasn’t framed in the form of a question, so I object to it as well.

TANICK: Fair enough.

TANICK: Is that – is Exhibit 8 a true and correct copy of of the – is that 6?

LAURION: These are 6 and 7.

TANICK: Oh, I’m sorry do we have a – Let’s just go off the record.

TANICK: All right, Mr. Laurion, we just made a correction on the letter. Exhibit 6 is a copy of the letter I sent you dated May 7th, 2010.

TANICK: That’s at the top of page 3.

KELLY: We’ve got a problem. What’s page 2?

TANICK: Don’t you have page 2 there?

KELLY: I didn’t get page 2.

TANICK: Okay, it’s missing from your copy.

KELLY: All right. But I understand now, so that’s why we are page 3?

TANICK: Yes.

TANICK: Is Exhibit 9 – is that the complaint you made to the medical board after they sent you the form to fill out.

LAURION: I need to clarify the question.

TANICK: Well, what is Exhibit 9, to your knowledge?

LAURION: It’s a complaint registration with the Minnesota Board of Medical Practice.

TANICK: And attached to it, is there not a letter?

LAURION: There is a letter.

TANICK: And you sent that letter on or about May 22nd?

LAURION: I’m still waiting for the clarification of the question.

TANICK: Well, I’m not going to give it to you. You’re going to get my next question.

LAURION: Okay. If you’re not going to clarify the question, I’ll ask Mr. Kelly to clarify the question before I answer it.

TANICK: Just give it back to the court reporter, if you don’t mind, because it’s not part of Exhibit 9. It’s a separate document.

REPORTER: Exhibit 10.

TANICK: That’s going to be Exhibit 11, John.

Reporter: Exhibit 11.

KELLY: Let me see what you’ve got as Exhibit – what? Oh, yeah, this is not the right one.

TANICK: I’m sorry. Did I give you the wrong document?

KELLY: Okay. Yeah, all right.

TANICK: I’m sorry. Here you go.

KELLY: I see what we’re doing.

TANICK: That’s it, John. I’m sorry. My fault.

KELLY: Thank you.

TANICK: All right. Let’s mark this, then as the next number. Would that be 12?

REPORTER: Exhibit 12.

TANICK: All right. Exhibit 12, Mr. Laurion, actually that will come before – we’ll talk about it before Exhibit 11.

TANICK: Did you also say you thought it may relate to his being used by somebody in some way?

LAURION: No, I didn’t say that at all.

KELLY: Whatever he said is of record.

TANICK: I understand.

KELLY: And it was testified to.

TANICK: That’s –

KELLY: It’s been asked and it’s been answered –

TANICK: All right. Thank you.

KELLY: – repeatedly.

TANICK: Mr. Kelly. Thank you for reminding me about that.

TANICK: Okay, you can take a look at the exhibits there. Exhibit 10 – I’m sorry, Exhibit 9, would you take a look at that, please Mr. Laurion? Just – Carol, would you just make a note I want to make sure that John gets a copy of Exhibit 12 – no, 13, the one we used this morning. That was our first one this morning. I didn’t have an extra copy for him.

TANICK: Do you know when – whether doctor – well, strike that. That’s okay. Exhibit 7. Would you take a look at Exhibit 5, please. That’s a document that I believe you testified yesterday reflects a posting of the newspaper article that appeared in the Duluth News Tribune about this lawsuit, and it’s posted on DoctorScoreCard.com. Correct?

LAURION: Yes.

KELLY: Asked and answered.

TANICK: All right. Well, was there something that caused you to post this on or about that date?

KELLY: We went into this yesterday. It’s been asked and answered.

TANICK: I don’t remember that.

KELLY: Well –

TANICK: I think you told us what prompted you to put the postings on Vitals and InsiderPages, but what was your purpose in doing it?

LAURION: In doing what?

TANICK: In posting – in making those postings about your encounter with Dr. McKee. You told us, I think, that you said you saw he had a profile there and he was kind of mediocre, and that kind of prompted you to put something on there. But what was your purpose? What was your goal or objective?

LAURION: I think it was simply to state a case of bad behavior from that individual while sticking to not causing any conclusions. I didn’t make any reference to his skill as a doctor, but I –

TANICK: Well – go ahead.

LAURION: – felt the site exists for that purpose.

TANICK: For what purpose?

LAURION: If you see a doctor, you can go there and rate him. You can tell good things about him and you can tell bad things about him.

TANICK: And you told bad things?

LAURION: I told that one episode. I didn’t make any predictions or characterizations.

TANICK: Fair enough.

TANICK: And did you use any material – did you use any notes or source material or anything in connection with those various letters?

LAURION: No. I simply drafted it.

TANICK: And you sent it to St. Luke’s Hospital. Right?

LAURION: Yes.

TANICK: Why?

LAURION: Because he has privileges from St. Luke’s, and at that point, I thought that somebody with an M.D. after his name would call him in and say, “We don’t like getting complaints like this. Could you be a little friendlier in the future, and we’ll consider this over.”

TANICK: So the reason you wrote to St. Luke’s – you wanted somebody in authority there to admonish Dr. McKee. Right?

LAURION: I wanted somebody to tell him that they either felt that that was poor behavior or that the writer thought that was poor behavior, and we don’t like getting letters like this.

TANICK: Did you have any communications back from St. Luke’s?

LAURION: Yes.

TANICK: Was that Dr. Gary Peterson?

LAURION: Yes.

TANICK: He was the medical director there. Right?

LAURION: I’m not sure what his title is, but he’s the senior medical officer, by whatever name.

TANICK: And what – what did he tell you?

LAURION: Initially I got a letter from him that said that Dr. McKee is not their employee, and that, therefore, his recourse was limited to giving a copy of my complaint to Dr. McKee, and that he had done so.

TANICK: You also wrote to the Minnesota Medical Association?

LAURION: Yes.

TANICK: And what was your purpose in doing that?

LAURION: My purpose was the same as my purpose in all of the others. They were either regulatory bodies or they were peer-review bodies, and my ultimate goal was that somebody would say, “You should be careful how you address your patients so that we don’t get these complaint letters.”

TANICK: Well, the next thing, I take it, is you posted on somewhere.

LAURION: Yes

TANICK: Okay.

LAURION: I posted on two of those Web sites.

TANICK: All right. And you thought you posted on four. Right?

LAURION: Yes.

TANICK: What accounts for that discrepancy?

LAURION: I don’t know, but when I went back to look a couple of days later, there was no remark on Doctor Scorecard, and when I wrote to ask the sites to delete them, Health Grades wrote back something to the effect that “You must be mistaken. We don’t accept narratives. All you could have done is filled out the number of stars.”

TANICK: All right. So you think your posting only appeared on Insider Pages and Vitals?

LAURION: Yes.

TANICK: Didn’t you have to enter the two other ones too? You thought you did at least?

LAURION: I thought I had, but apparently was mistaken.

TANICK: Okay.

TANICK: Well, if I understand you correctly, you’re telling us that this was posted on Insider Pages, Doctors — Vitals, and you thought you posted it on the other two, but those apparently didn’t get on there, according to what you know?

LAURION: It was actually only posted on Insiders and –

TANICK: Vitals?

LAURION: Vitals.

TANICK: Okay, and I take it the reason you were drawn those two web sites is because – after Googling his name –

LAURION: Yes.

TANICK: It came up that he was listed on those two. Right?

LAURION: He was listed on all four of them.

TANICK: On all four? Right. Was he listed on anything else?

LAURION: I think he was, but I didn’t go any farther than the first four.

LAURION: I looked at the sites to see if my comments were posted.

TANICK: And they were posted on two, but not the other two. Right?

LAURION: Exactly.

TANICK: The letter goes on, then, to include the two enclosures, the first one is – the enclosure 1 is the Web site information that you posted on the two Web sites?

LAURION: Yes.

TANICK: When you did your posting on the three – or the two Web sites that you say you posted, Insider Pages and Vitals.com. Right?

LAURION: Okay.

TANICK: On page 3, you state at the end of the first paragraph you had no intention of doing anything more about it, posting any more information about Dr. McKee or corresponding with anybody about Dr. McKee. Right? That’s what you said in your letter?

LAURION: I said that with the preface “otherwise.”

TANICK: “Otherwise.” So what did you mean, “otherwise?”

LAURION: I meant that if there’s no further need to post about him, that I won’t. If I’m left alone, I’m fine.

TANICK: All right. And you conclude by saying, “I am no longer inclined to discuss Dr. McKee’s behavior with anybody.” And the next paragraph is “I’ll consider this matter finished. Right? And “Will Doctor McKee” question mark. Right?

LAURION: Yes, and I was taking your threat letter at face value, that if I complied with what you wanted, that would be the end of the issue.

TANICK: However, you decided not to do that. Right?

LAURION: No, I don’t agree with that.

TANICK: All right. So the letter prompted you to do something?

LAURION: Yes.

TANICK: And what is it, it prompted you to do?

LAURION: You told me not to talk to anybody else and to delete the postings. I deleted the postings and stopped talking to anybody else.

TANICK: Did you do anything else relative to that?

LAURION: Ask me something specific, so I can answer it one way or the other.

TANICK: Did you do anything relative to the Dr. McKee situation other than try to delete postings?

LAURION: I successfully deleted the postings, those sites I wrote to and asked them to delete them, and they deleted them. The sites that hadn’t posted them wrote and told me that they hadn’t posted them. I just did not delete them manually.

TANICK: Did you have any communication at any time, Mr. Laurion, with any members of the media respecting or regarding Dr. McKee and the situation with he (sic) and your father?

LAURION: Not by name. I wrote to – only after I got your threat letter, I wrote to Mark Stodghill and to two television stations. I said, “I have been threatened by a lawsuit by a doctor. If he follows through, is it newsworthy?” Nowhere in these contacts did I say his name or even my father’s name or St. Luke’s Hospital as a track back.

TANICK: Mr. Laurion, I have before you Exhibit 11, and that’s a collection of communications that you made to members of the media, right, concerning the situation with Dr. McKee. Right?

LAURION: It was concerning the fact that a doctor was suing me, and I asked if that was newsworthy.

TANICK: Sure.

TANICK: Exhibit 12 is a document that you sent to Improve Vitals and to Legal – or to Insider Pages and also to City Search – well, no. City – that’s their response. These are – Exhibit 12 is correspondence that you sent to Improve Vitals and Insider Pages asking to delete the postings you had made. Right?

LAURION: Yes.

TANICK: And that was a response to my letter to you on May 7th. Right?

LAURION: Yes.

TANICK: Okay, why did you – I think you indicated that the reason you sent these letters to these people was to see if my communications to you on behalf of Dr. McKee was (sic) somehow newsworthy. Right?

LAURION: Oh, no. No.

TANICK: All right. Well you tell me why you sent those letters.

LAURION: I sent them to ask if a resulting lawsuit would be noteworthy. I didn’t ask them anything about your letter, nor did I want them to do a piece about my father’s treatment. I was not contacting any of those sources and saying “A doctor was rude to my father. Would you run with it?” because, obviously, that wouldn’t be newsworthy. I asked “If I’m sued, will it be newsworthy?”

TANICK: Why were you asking if this was newsworthy? What was your purpose?

LAURION: From what I’ve read on the Internet, this is a precedent type of situation. If you Google doctors who are suing their patients, you will find only six or seven names.

MCKEE: I’m not suing a patient.

TANICK: Go ahead.

LAURION: And there are several – this apparently is a hot topic. Not only doctors suing families, but anybody suing somebody for Internet defamation. I think even your own website describes Internet defamation as a brand new field, a brand new area of experience. There’s a lot of conversation about it. There are a lot of sites written by doctors for doctors, some of them internists, some of them dentists, and so forth, and inevitably on all of them there’s a question of “How do I respond when somebody complains about me on the Internet?” And the advice generally given is either ask them to retract it, which they probably won’t do, or ignore it, it will make the Web site go higher, and if you sue anybody, it will garner publicity. Also, I never cared about Internet defamation before, but I’ve been converted and I’ve read sites about Internet defamation, and they generally all say if somebody sues you for defamation, you should shine a spotlight on it; and therefore, I felt that if he sues me, he should have the courage of his convictions and let the entire community know it. The article says he rebuts all of those statements. So fine, he got to say he rebutted them. I got to say that I affirmed them. It’s a public debate.

TANICK: All right. And on May 11th, you were contacting media to see if there was some interest on their part in writing an article if you were sued. Right?

LAURION: But I was not writing about Dr. McKee. I was writing and saying I might be sued by a doctor and is that newsworthy.

TANICK: Right.

LAURION: I purposely redacted everything from my complaint letter that would even lead them to what hospital. Had he not sued me, and they contacted me again and said what’s happening, I would have said nothing, and I would have never revealed his name.

LAURION: I Googled complaints about Dr. – “complaints” plus “David C. McKee.”

TANICK: Where did you Google that?

LAURION: On Google.

TANICK: I mean where? At your home?

LAURION: Yes.

TANICK: I thought you said, though, that you looked at Wikipedia and that kind of confirmed your view?

TANICK: Did you consult or refer to anything when you put it on the – put that on the Web site?

LAURION: No.

TANICK: Did you look at any notes or documents you had written up or anything like that?

LAURION: No.

TANICK: All right. So what you were putting on there was your recollection of what had occurred at this incident on February 23rd – April 28th – the 19th. Right?

LAURION: Yes.

TANICK: You went on Wikipedia after you had some discussion with your mother and wife about, “What is it McKee said about – what is it Dr. McKee said in the room.” Right?

LAURION: Yes.

TANICK: And there were some discrepancies as to what they – what the three (sic) of you heard?

LAURION: I would say differences.

TANICK: All right. You said you heard this 44 percent. Your wife said she heard some kind of reference to a percent, but not sure of the exact, and your mother said she heard something, a reference to mortality, but not necessarily tied to a percentage. Is that right?

LAURION: Yes.

TANICK: All right. So you went and checked it out, or you went to Wikipedia and you saw this 44 percent. Right?

LAURION: Yes.

TANICK: And you felt, well, that confirms; I guess he must have said it, because that’s what Wikipedia says. Right.

LAURION: Yes.

TANICK: And you say you did that after your posting. Right?

LAURION: Yes.

TANICK: All right. How much after your posting did you do that?

LAURION: After I spoke to my parents, and presumably before I wrote to St. Luke’s.

TANICK: All right. Well, you wrote to St. Luke’s on April 22nd.

LAURION: Then it would have been after – April – to St. Luke’s, I may still quote that figure.

TANICK: Right. So you must have seen it before you wrote to St. Luke’s?

LAURION: No, I did not. I heard it before I wrote to St. Luke’s.

TANICK: All right. My – all right. My question was when you – when you went to look – when you saw it in Wikipedia.

LAURION: I went down and looked it up after the family conversation about what had been said. When I showed it to my wife, and she still insisted she hadn’t heard 44 percent, so I didn’t make any more reference to 44 percent.

LAURION: I looked at Wikipedia after having a conversation with my parents and my wife at my father’s house.

TANICK: Where did you find the Wikipedia? Where did you find the Wikipedia entry? Or a Wikipedia entry about stroke? Where did you find that? Was it on your computer at home?

LAURION: I looked it up.

TANICK: I know, but where did you look it up?

LAURION: I don’t know.

TANICK: Did you look it up on a computer?

LAURION: Obviously, I looked it up on a computer.

TANICK: Do you remember whose computer you looked it up on?

LAURION: No, I don’t.

TANICK: Do you remember what computers you were looking up – or using in April of 2010?

LAURION: I have used my father’s computer at his home. I’ve used either of my sons’ computers at their homes.

TANICK: All right. How about your computer at your home?

LAURION: I have, yes.

TANICK: All right. So if one were trying to – if one were trying to locate where – where – when you saw that Wikipedia entry – if you were trying to locate it, how would you go about locating it?

LAURION: Where I’d locate it?

TANICK: When? I’m sorry. When? If someone – if there is an issue, “When did Mr. – when did Dennis Laurion go on a computer and find this Wikipedia reference to the 44 percent?” If someone were just trying to ascertain that, how would they do that to your knowledge?

LAURION: I don’t know.

TANICK: How would you do it?

LAURION: I wouldn’t because I know when I looked it up.

TANICK: What if someone said, “Can you show us” – “Can you substantiate or corroborate when you looked it up?”

LAURION: No, I would have to tell them that my stepson came in November and fixed our computer and refigured it and put on new profiles and, so far as I know, new software.

TANICK: Therefore, what?

LAURION: I – I don’t know.

TANICK: Well, I take it, then, that you’re telling us that you presumably looked up the Wikipedia posting – Wikipedia on your own computer.

KELLY: He hasn’t said that.

TANICK: All right. Well, I’ll take them – all right. Well, you don’t have to argue with me. You don’t have to shout. I’ll take it out. I’ll take it out of your mouth and put it in my mouth.

TANICK: Is it the case that you read that on your own computer?

LAURION: I don’t know.

TANICK: All right. Let me ask you this, Mr. Laurion. I’m just jumping back to our discussion about your computer and your – your computer activity. Have you taken – have you done anything to remove from any of the hard drives of any of your computers that you’ve used any information regarding Web sites you visited?

LAURION: No, I wouldn’t know how to do that.

TANICK: How about your son-in-law. Did he –

LAURION: He’s not my son-in-law. He’s my stepson.

TANICK: Stepson. I’m sorry.

LAURION: When we came back from dinner with my – at my sister’s house, our computer was no longer working. The computer was given to my wife by her son. He gets rid of his every five years and he brings it to us. So, he was here right before Christmas and he got our computer working again. What he did to it, I don’t know.

TANICK: So you don’t know if he’s removed anything from your hard drives that would be reflective of Web sites you’ve visited in connection with this matter concerning Dr. McKee? You don’t know one way or the other?

LAURION: No.

TANICK: How would you find out?

LAURION: I don’t know.

TANICK: Well, one way would be to check your hard drive. Right?

LAURION: If somebody wanted to look at all of my finances and my passwords and my letters to my mother and so forth?

TANICK: Did you have any discussions with – strike that. John, I want to go maybe about five, ten more minutes, and then we’ll take a break. Is that all right with you?

KELLY: That’s going to coincide just about exactly with my tolerance here.


Defendant Dennis Laurion’s Web Posting

Defendant Dennis Laurion’s Patient Complaint

Plaintiff David McKee’s Reply To Patient Complaint

Plaintiff David McKee’s Cease And Desist Letter To Defendant Dennis Laurion

Defendant Dennis Laurion’s Complaint To Minnesota Board Of Medical Practice

Plaintiff David McKee’s Complaint To Sixth Judicial District Duluth Court

Plaintiff David McKee’s Response To Minnesota Board Of Medical Practice

Defendant Dennis Laurion’s Answer To Plaintiff David McKee’s Complaint

Defendant Dennis Laurion’s Motion For Summary Judgment

Defendant Dennis Laurion’s Deposition Extracts

Plaintiff David McKee’s Deposition Testimony About Circumstances Before Encounter With Laurion Family

Plaintiff David McKee’s Deposition Testimony About Encounter With Laurion Family

Plaintiff David McKee’s Deposition Testimony About Circumstances After Encounter With Laurion Family

Plaintiff David McKee’s Deposition Testimony In Response To Questions By Marshall Tanick

Affidavits By Defendant Dennis Laurion’s Parents

Defendant Dennis Laurion’s Supplemental Motion For Summary Judgment

Plaintiff David McKee’s Motion To Oppose Summary Judgment

Defendant Dennis Laurion’s Reply Memo In Support Of Motion For Summary Judgment

Sixth Judicial District Court’s Order On Motion For Summary Judgment

Plaintiff David McKee’s Appeal Of Order On Motion For Summary Judgment

Plaintiff David McKee’s Brief To Minnesota Court Of Appeals

Defendant Dennis Laurion’s Brief To Minnesota Court Of Appeals

Plaintiff David McKee’s Reply Brief To Minnesota Court Of Appeals

Minnesota Court Of Appeals Order To Strike Portion Of Plaintiff David McKee’s Reply Brief

Minnesota Court Of Appeals Announces Decision

Defendant Dennis Laurion’s Petition For Review By Minnesota Supreme Court

Plaintiff David McKee’s Opposition To Review By Minnesota Supreme Court

Defendant Dennis Laurion’s Brief To Minnesota Supreme Court

Plaintiff David McKee’s Brief To Minnesota Supreme Court

Defendant Dennis Laurion’s Reply Brief To Minnesota Supreme Court

Minnesota Supreme Court Decision On David McKee MD V. Dennis K. Laurion

David McKee MD v. Dennis Laurion 2010

David McKee MD v. Dennis Laurion 2011

David McKee MD v. Dennis Laurion 2012

David McKee MD v. Dennis Laurion 2013

McKee V Laurion Is A Textbook Case

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