1
               IN THE COURT OF COMMON PLEAS
                   OF STARK COUNTY, OHIO
     
     
     DAVID L. PENNELL,
                 Plaintiff,
           vs.                       Case No.
     SANJEEV DEWAN, et al.,          1999 CV 02936
                 Defendants.
     
     
                      - - - - -
                 Deposition of HOWARD S. SIEGEL, M.D., 
     called for examination under the statute, taken 
     before me, Claudine Kelly, a Notary Public in and 
     for the State of Ohio, pursuant to notice and 
     stipulations of counsel, at the offices of Howard 
     S. Siegel, M.D., 2475 East 22nd Street, 
     Cleveland, Ohio, on Monday, May 5, 2003, at 9:05 
     a.m.
                      - - - - -
     
     
     
     

                                                                     2
 1   APPEARANCES:
 2   
 3         On behalf of the Plaintiff:
 4               Elk & Elk, by
 5               MARTIN S. DELAHUNTY, ESQ.
 6               Landerhaven Corporate Center 
 7               6110 Parkland Boulevard 
 8               Mayfield Heights, Ohio  44124
 9               (440) 442-6677 
10   
11         On behalf of the Defendants:
12               Sutter, O'Connell, Mannion 
13               & Farchione, by
14               DAVID W. SKALL, ESQ.
15               3600 Erieview Tower
16               1301 East Ninth Street
17               Cleveland, Ohio  44114
18               (216) 928-4537
19                         ----
20   
21   
22   
23   
24   
25   

                                                                     3
 1         HOWARD S. SIEGEL, M.D., of lawful age, 
 2   called for examination, as provided by the Ohio 
 3   Rules of Civil Procedure, being by me first 
 4   duly sworn, as hereinafter certified, deposed 
 5   and said as follows:
 6        EXAMINATION OF HOWARD S. SIEGEL, M.D.
 7   BY MR. SKALL:
 8         Q.    Dr. Siegel, we've met before and 
 9   I'll introduce myself to you just for record 
10   purposes.  My name is David Skall.  I'm 
11   representing Dr. Dewan and his professional 
12   group in a lawsuit filed by one of your I think 
13   patients and to whom you were referred for an 
14   expert opinion, David Pennell. 
15               In as much as you've already given 
16   a deposition in 2001 in this case, I'd like to 
17   just visit some of