1
           IN THE COURT OF COMMON PLEAS 
            OF CUYAHOGA COUNTY, OHIO            
     
     BLANCHE HULLUM, etc,  
     et al,     
                 Plaintiffs,
       vs                           Case No 460160
     UNIVERSITY HOSPITALS, 
     et al,
                 Defendants
     
           Videoconference Deposition of CYNTHIA 
     LOUISE WILHELM, PhD, called for examination 
     under the Applicable Rules of Ohio Civil 
     Procedure, taken before me, Michele E Eddy, a 
     Registered Professional Reporter and Notary 
     Public in and for the State of Ohio, pursuant to 
     notice and stipulations of counsel, at the 
     offices of xxxxxxxx Reporting Services, Erieview 
     Tower, Suite 2500, 1301 East Ninth Street, 
     Cleveland, Ohio, on Wednesday, the 19th day of 
     March, 2003, at 10:30 am
                 - - - - - 
     
     

                                                                     2
 1   APPEARANCES:
 2   
 3         On behalf of the Plaintiffs:
 4               Nurenburg, Plevin, Heller & 
 5               McCarthy Co, LPA, by         
 6               WILLIAM JACOBSON, ESQ 
 7               Standard Building, First Floor
 8               1370 Ontario Street
 9               Cleveland, Ohio  44113
10               (216) 621-2300
11    
12         On behalf of the Defendants: 
13               Norchi & Associates, Inc, by 
14               KEVIN M NORCHI, ESQ
15               23240 Chagrin Boulevard
16               Suite 600 
17               Cleveland, Ohio  44122
18               (216) 514-9500
19   
20    
21                    ----
22   
23   
24   
25   

                                                                     3
 1         CYNTHIA LOUISE WILHELM, PhD, of lawful 
 2   age, called for examination, provided by the 
 3   statute, being first duly sworn, as hereinafter 
 4   certified, and said as follows:
 5    EXAMINATION OF CYNTHIA LOUISE WILHELM, PhD
 6   BY MR NORCHI: 
 7         Q    Could you please state your name?
 8         A    Cynthia Louise Wilhelm
 9         Q    Is that Dr Wilhelm?
10         A    PhD, post hole digger, correct
11         Q    I'm just trying to figure out the 
12   best way to address you  I assume it's Dr 
13   Wilhelm; is that fine?
14         A    Whatever you're comfortable with
15         Q    Dr Wilhelm, my name is Kevin 
16   Norchi  We are taking this deposition by video 
17   conference  You are in Durham, and I am in 
18   Cleveland  And I can tell that just from the 
19   opening remarks that there seems to be some 
20   sort of a satellite delay or some sort of 
21   transmission delay between what appears to be 
22   the end of my sentence and the beginning of 
23   your answer
24               So please wait to listen to my 
25   complete sentence, when I've finished, 

                                                                     4
 1   formulate your answer and then provide it  But 
 2   it will be important that we do not talk over 
 3   each other during the video conference 
 4   deposition  Okay?
 5         A    Okay
 6         Q    Do you have a volume control there 
 7   that we can raise the volume, because it's 
 8   difficult to hear you
 9         A    Is that any better?
10         Q    I think you have to use the 
11   magnetic pen there instead of your finger, 
12   unless it's magnetic
13         A    It is
14         Q    Keep talking
15         A    Is that better?  Is that better?
16         Q    That's probably making me louder 
17   for you
18               Let's continue
19         A    That's the only volume control on 
20   here
21         Q    We'll do the best we can
22               If you could, please keep your 
23   voice up
24         A    Okay
25         Q    Dr Wilhelm, you've been identified 

                                                                     5
 1   as an expert witness on behalf of the 
 2   plaintiffs in this matter, correct?
 3         A    Correct
 4         Q    And you've reviewed information and 
 5   prepared a report regarding a life care plan 
 6   that you believe should be implemented for 
 7   Blanche Hullum, correct?
 8         A    That's correct
 9         Q    What I would like to do first is 
10   talk to you a little bit about your background, 
11   your professional background and educational 
12   background
13               You've been kind enough to provide 
14   us with a copy of your curriculum vitae, but on 
15   the last page, page 11, it says revised in 
16   November of 1995
17               Do you have a more current CV?
18         A    I do, but I don't have it with me  
19   Yes, I do
20         Q    Since 1995, have you had any 
21