AFFIDAVIT

STATE OF FLORIDA
COUNTY OF DUVAL


BEFORE ME the undersigned authority personally appeared Dr. Jacob
Greene, who being first duly sworn, deposes and says:
1. My name is Jacob Green, and I am a medical doctor in Jacksonville,
Florida, practicing in a small group at the Southeastern Neuroscience Institute,
P.A. I make this statement on personal information, and I am over the age of
18 years.
2. I have been in practice as a physician for 34 years and am certified
by the American Board of Psychiatry and Neurology in neurology. Presently I
hold staff privileges at Memorial Hospital, St. Luke’s Hospital, and Methodist
Medical Center, all in Jacksonville. I hold a Ph.D. as well as an M.D. degree,
and I did post-graduate residencies in both neurology and neurological surgery
at the University of Alabama Hospital at Birmingham, as well as a residency in
neurology at the Medical University of South Carolina Medical Center. I have
taught medical students and have served on the teaching faculty at the
University of Florida’s Shands Hospital, among other institutions. Presently, I
am licensed to practice medicine in Florida, Alabama, Georgia and Virginia. I
have published three textbooks and more than sixty papers in various
peer-reviewed journals.
3. Although I have not physically examined Theresa Marie Schiavo, I
base my opinions about her condition on a review of her medical records and on
scrutiny of a videotape of the patient, dated January 22, 2000.
4. Ms Schiavo is not in a persistent vegetative state. There is clear
reactivity and an emotional responsitivity to the person who comes into her room
as shown on the videotape. This reactivity shows a significant amount of brain
damage, but it is my opinion based on reasonable medical probability that she is
not brain dead or in a persistent vegetative state as of the date of this
videotaping.
FURTHER AFFIANT SAYETH NAUGHT.


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