Legal filings from John Q. Kelly, New York brain injury lawyer, claim that Gunn should have used a shunt, a small plastic tube that diverts blood flow around the surgically opened carotid artery and assures adequate blood flow to the brain, before attempting to clear the artery. According to court documents, he did not use one.
Gunn's operative report describes "a complete disintegration of the internal carotid artery that did not allow the hold of stitches in any form."
In a later deposition, Gunn said that "the vessel wouldn't hold stitches, the vessel disintegrated, the vessel was weak, the vessel wall was mushy, the vessel wall was like wet toilet paper."
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