IN THE COMMON PLEAS COURT
                            CUYAHOGA   COUNTY, OHIO
           2

           3CAROLYN J  TOMAYKO,  Individually
            and aS Administrator of the
           4Estate of Gregory E Tomayko,
            Deceased,
           5
                                    Plaintiff,
           6
                 -vs-                                CAUSE NO
           7                                          9 4 - 4 4 2 2
            KETTERING MEMORIAL HOSPITAL,
           8et al,

           9                       Defendants

           10
                     DEPOSITION OF DOUGLAS P   ZIPES, MD
           11

           12
                      The deposition upon oral examination of
           13 DOUGLAS P ZIPES, MD, a witness produced and sworn
            before me, Judith Bellinger, RPR, CSR #94-R-1044, a
           14 Notary Public in and for the County of Marion, State
            of Indiana, taken on behalf of the defendants at the
           15 offices of Krannert Institute of Cardiology, 1111 West
            Tenth Street, Indianapolis, Marion County, Indiana, on
           16 the 13th day of October, 1995, pursuant to the Indiana
            Rules of Trial Procedure with written notice as to
           17 time and place thereof

           18

           19
                      JOHN E CONNOR & ASSOCIATES, INC
           20               1860 ONE AMERICAN SQUARE
                            INDIANAPOLIS, IN  46282
           21                    (317) 236-6022

           2 2

           23

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                           A P P E A R A N C E S

           2FOR THE PLAINTIFF(S):   Mr Eric Kennedy
                                    WEISMAN GOLDBERG & WEISMAN
           3                        1600 Midland Building
                                    Cleveland, OH  44115
           4

           5FOR THE DEFENDANT(S):   Ms Susan Blasik-Miller
                                    JENKS SURDYK & COWDREY
           6                        205 East First Street
                                    Dayton, OH  45402
           7

           8ALSO PRESENT:           Dr Bleser

           9

           10     I N D E X   0 F   E X A M I N A T I 0 N

           11 DIRECT EXAMINATION     3
             Questions by Ms Susan Blasik-Miller
           12

           13

           14         I N D E X   0 F   E X H I B I T S
                                                                 PAGE
           15 Defendant's Deposition Exhibit No:

           16 A - Dr Zipes' notes pertaining to the review   20
           C - Cardiogram     41
           17 D - Cardiogram    42
           B - Curriculum Vitae     20
           18

           19

           2 0

           21

           2 2

           23

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                 D 0 U G L A S   p    Z I P E S,   M D
          2having been first duly sworn to tell the truth, the
          3whole truth and nothing but the truth relating to
          4said matter, was examined and testified as follows:
          5
          6DIRECT EXAMINATION,
          7    QUESTIONS BY MS  SUSAN BLASIK-MILLER:
          8                     MS BLASIK-MILLI'@:  Let the
          9       record reflect we're here for the deposition  of
          10      Dr Douglas Zipes, being taken pursuant to
          11      notice and agreement
          12  Q   Dr Zipes, my name is Susan Blasik-Miller  I
          13      represent Scott Bleser, who's seated to my
          14      right, in a lawsuit filed by the Estate of
          15      Mr Tomayko
          16           You've been identified as an expert  on
          17      behalf of the plaintiff  I'm going  to  ask  you
          18      some questions  If you don't  understand  my
          19      question, please tell me; I'll repeat it  or
          20      rephrase it  Otherwise, if you  answer,  I  will
          21      assume you understood the  question  Also,  for
          22      the benefit of the court reporter,  please  make
          23      sure that all of your responses are  verbal,
                                                         4
         1        rather than nodding or shaking your head
         2            For the record, just state your full name
         3        and your business address, please?
         4   A    Douglas Peter Zipes, Indiana University School
         5        of Medicine, 1100 West Michigan Street,
         6        Indianapolis, Indiana
         7        Where did you obtain your undergraduate
         8        educa