The State of Ohio
       County of Cuyahoga.      SS:



                     IN THE  COURT OF COMMON PLEAS


       Edith Miller, Executrix
       of the Estate of Edward L.
       Killer, Deceased,

                      Plaintiff,

            Vs.                            Came No. 966,735

       University Hospitals, at al.,

                      Defendant.


           Deposition of R. Ben Dawson, N.D., called by
       Defendant University Hospitals for the purpose of crons-
       examination, before Judith A. Broquet, a Notary Public
       within and for the State of Ohio, at the American Airlinei
       Admirals' Club, Cleveland Hopkins International Airport,
       Cleveland, Ohio, at ls3O p.m., Tuesday, November 17, 1981,
       pursuant to agreement of counsel.



       APPEARANCES:

               Mr.  Jed Weisman,

                             For the Plaintiffi

               Arter & Haddon, by
               Mr.  Harry T. Quick,

                             For the Defendant University
                             Hospitals?

               Gallagher, Sharpe Fulton, Norman a Mollison, by
               Mr.  James Gowan,

                             For Defendant Puritan-Bennett

                        REILENDER, FERRIS& SKOMSKI
                              COURT REPORTERS
                    1001 EUCLID AVE.. SUITE 402 - CLEVELAND, OHIO 441 15
                                 241 4 3 0 3

        I                  R. BEN DAWSON, M.D., of lawful age,        2

        2        a witness herein, called by Defendant University

        3        Hospitals for the purpose of cross-examination,

        4        as provided by the Ohio Rules of Civil

        15       Procedure, being by me first duly sworn, as

        6        hereinafter certified, deposed and said as

        7        follows:

        8


        9               EXAMINATION OF R. BEN DAWSON, M.D.



        10   BY MR.  QUICK:



        11   Q   Doctor, I'm going to be askinq you some



        12       questions about this case of Miller versus



        13       University Hospitals, and if at any time I ask



        14       you a question and you do not understand the



        15       question, please don't answer it.  Just indicate



        16       that you don't understand the question, and I



        17       will try to rephrase it.  All right?



        18   A   All  right.



        19   Q   Could you give us your name for the record?



        20   A   Initial R, Ben, Dawson,  D-a-w-s-o-n, M.D.



        21   Q   And what is your business address?



        22   A   University of Maryland Hospital, Baltimore,



        23       Maryland, 21201.



        24   Q   And what's your date of birth?


             A   11-16-34.
        25

         I  Q    And where did you go to medical school?            3

         2  A    The University of Virginia School of Medicine
         3       in Charlottesville.
         4  Q    And what year did you graduate?

         5  A    1 9 6 3 .

         6  Q    And how about undergraduate?
         7  A    Hampeen-Sidney College, H-a-m-p-d-e-n dash
         8       S-i-d-n-e-y, in Virginia.
         9  0    Graduating?
         10 A    5s.
         11 Q    Now, following your graduation from the University
         12      of Virginia, did you take any post-graduate
         13      training courses?
         14 A    Yes.  Endless training.
         15 0    I don't mean an internship or residency.  I mean
         16      towards an advanced degree beyond the M.D.
         17 A    Not towards a degree, no.  I did take some
         is      special post-graduate courses at Harvard-MIT
         19      after internship and residency.
         20 Q    Let's start with the internship.  where did you
         21      take your internship?
         22 A    Jefferson medical College Hospital in Philadelphia
         23      '63 to '64.  That's in internal medicine, or
         24      medical intern.
         25 Q    How about residency?
       I   A   Residency was from 164 to '68 at Rahnemann,         4
       2       H-a-h-n-e-m-a-n-n Medical College Hospital
       3       in Philadelphia.
       4   Q   Did you focus on any area of medicine?
       .5  A   Yes.  Internal medicine.
       6   Q   Now, where did the Harvard-MIT experience come in?
       7       Is that in between?
       8   A   No.  That came the next year.  It was part of
       9       a hematology academic traineeship at Tufts-
       10      New England Medical Center, the dates of which
       11      were '66 to '68.  During the first of those two
       12      years I was a special graduate student at flarvard,
       13      Harvard medical School, and MTT.
       14  Q   Could you give me that