Chronological Deposition Summary
Name
Institution

SPENCER FLANNIGAN
Plaintiff, Civil Action no. 1015-7507
V.
LASSITERCENTRAL CLINIC OF VERMONT, et al.
Defendants

Appearances
Bradford, Miller and Hutchinson
By: Roger Hutchinson
For the Plaintiff:

Reeves, Allyn, and Cain
By: William Radcliff
For the Defendants
STIPULATIONS:
It is hereby stipulated and agreed by and between counsel that all objections, except as to the form of the questions be reserved until the time of the trial.
EXAMINATION BY MR. HUTCHINSON
Q: Would you please state your full name for the record?
A: Jonathan Harbinger
Q: Where are you employed?
A: Lassiter Central Clinic of Vermont (LCCV)
Q: Mr. Harbinger, would you briefly list your educational background?
A: I attended Concord County Community College where I earned an associate of applied science degree in radiologic technology.
Q: Do you have any board certification?
A: I became a registered radiologic technologist in the year 2012 and a certified radiologic technologist in the year 2013
Q: Would you explain the process required to become a certified radiologic technologist?
A: At a minimum, an associate degree is needed, coupled with satisfactory performance on a state-administered, nationally recognized examination.
Q: How many hours of clinical work were you required to perform as part of your education?
A: I was required to complete 320 hrs of supervised radiologic work at a center that is approved.
Q: At what approved center did you perform your clinic work?
A: At Lassiter Central Clinic of Vermont. I actually completed more than 320 hours in LCCV; under the state rules, once an individual is in the 2nd year of an accredited radiologic program, one can work in a department so long as he/she is under the Certified Radiologic Technologist’s supervision.
Q: So, you were hired by LCCV during your second year in the program at Concord County Community College?
A: That is correct
Q: How many hours per week did you work?
A: Well, it varied, but usually around 20
Q: So, before being hired on a full-time basis, you had worked how long for LCCV?
A: About six months
Q: When were you hired on a full-time basis?
A: Right after graduation
Q: Totaling all this time, how long have you worked for the Radiology Department at LCCV?
A: Two years
Q: Are you familiar with the procedure manual at LCCV?
A: Yes. Every person working at LCCV is required to read it and sign a form that indicates one has done so.
Q: And did you read and sign the appropriate form?
A: Yes, I did