1
                IN THE COURT OF COMMON PLEAS
                OF ERIE COUNTY, PENNSYLVANIA
     
     
     ALAN F ROGERS, et al,
                 Plaintiffs,
           vs                          Case No
     McKEAN TOWNSHIP OF THE COUNTY      NO 10441-2001
     OF ERIE AND COMMONWEALTH OF 
     PENNSYLVANIA,                      
                 Defendant
     
     
                         ~ ~ ~ ~ ~
                 Videotaped deposition of WILLIAM E 
     BINGAMAN, MD, called for examination under the 
     statute, taken before me, Michelle A Bishilany, 
     RDR/CRR and Notary Public in and for the State of 
     Ohio, pursuant to notice and stipulations of 
     counsel, at the The Cleveland Clinic Foundation, 
     9500 Euclid Avenue, Cleveland, Ohio, on Tuesday, 
     February 4, 2003, at 10:16 am
                         ~ ~ ~ ~ ~
     
     

                                                                     2
 1   APPEARANCES:
 2   
 3         On behalf of the Plaintiffs:
 4               Conner, Riley & Fryling, by
 5               JAMES R FRYLING, ESQ
 6               The Bell Telephone Building
 7               17 West Tenth Street
 8               Erie, PA  16501
 9               (814) 453-3343
10   
11         On behalf of the Defendant:
12               Eiseman, Myers & Liero, by
13               JOHN L KWASNESKI, ESQ
14               1673 Two Gateway Center
15               Pittsburgh, PA  15222
16               (412) 434-6611
17                      ~ ~ ~ ~ ~
18   
19   ALSO PRESENT:
20               Kimberly DiMuzio, CLVS
21                      ~ ~ ~ ~ ~
22   
23   
24   
25   

                                                                     3
 1               VIDEOGRAPHER:  Today's February 4, 
 2   2003  We are going on the record at 10:16  
 3   Court reporter, can you please swear in the 
 4   witness?
 5         WILLIAM E BINGAMAN, MD, of lawful age, 
 6   called for examination, as provided by the Ohio 
 7   Rules of Civil Procedure, being by me first 
 8   duly sworn, as hereinafter certified, deposed 
 9   and said as follows:
10               MR FRYLING:  Good morning  My 
11   name is James Fryling, and I represent Alan and 
12   Wendy Rogers in this case  And we are here in 
13   Cleveland this morning with Dr Bingaman to 
14   take his deposition pursuant to notice for use 
15   at trial 
16               If Mr Kwasneski could introduce 
17   himself for the record as well 
18               MR KWASNESKI:  Good morning  I'm 
19   John Kwasneski, I represent McKean Township
20       EXAMINATION OF WILLIAM E BINGAMAN, MD
21   BY MR FRYLING:
22         Q    Doctor, could I have your full 
23   name, please?
24         A    William E Bingaman
25         Q    And what is your professional 

                                                                     4
 1   address?
 2         A    Cleveland Clinic Foundation, 
 3   department of neurosurgery, desk S, as in Sam, 
 4   80, 9500 Euclid Avenue, Cleveland, Ohio, 44195
 5         Q    And what is your occupation?
 6         A    I'm a neurosurgeon
 7         Q    And are you licensed in the state 
 8   of Ohio --
 9         A    Yes
10         Q    -- to practice medicine?
11         A    Yes
12         Q    How many years have you been 
13   licensed?
14         A    Since 1990 -- oh, boy, 1995, I 
15   believe
16         Q    Okay 
17         A    During my residency I was licensed
18         Q    And where did you receive your 
19   undergraduate education?
20         A    I went to Johns Hopkins University 
21   in Baltimore, Maryland
22         Q    And what medical school did you 
23   attend?
24         A    Temple University in Philadelphia, 
25   Pennsylvania

                                                                     5
 1         Q    And you received a degree from that 
 2   school?
 3         A    Yes
 4         Q    Where did you do your internship?
 5         A    I did my internship, my residency, 
 6   my chief residency and a spine fellowship here 
 7   at the Cleveland Clinic Foundation
 8         Q    All right  And the residency is a 
 9   specialty, or you did your residency --
10         A    A neurosurgical residency, yes
11         Q    Okay  And how long did your 
12   training and residency in neurosurgery take?
13         A    From 1990 through 1996, six years
14         Q    Okay  And, just briefly, what does 
15   a residency program consist of?
16         A    It consists of training in 
17   neurosurgical disorders, disorders of the 
18   central nervous systems including the 
19   peripheral nervous system, brain, spine, which 
20   is both clinically based and surgically based 
21   training
22