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                      IN THE CIRCUIT COURT OF RALEIGH COUNTY,

                                    WEST VIRGINIA



                 AMANDA J DAVIS, as natural

                 mother, next friend and guardian

                 of JACOB HANSON, an infant, and

                 AMANDA J DAVIS, individually,

                               Plaintiffs,

                        vs                              Case No

                 CARLOS LUCERO, MD, MARCIA             97-C-4111

                 KHALIL, MD, RALEIGH GENERAL

                 HOSPITAL, INC, a West Virginia

                 Corporation d/b/a COLUMBIA

                 RALEIGH GENERAL HOSPITAL,

                               Defendants



                                     - - - - -

                       Deposition of DAVID BURKONS, MD, called

                 for examination under the statute, taken before

                 me, Jill A Kulewsky, a Notary Public in and for

                 the State of Ohio, pursuant to notice and

                 stipulations of counsel, at University Suburban

                 Hospital, 1611 South Green Road, South Euclid,

                 Ohio, on Wednesday, July 18, 2001, at 5:30 pm

                                     - - - - -

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                 APPEARANCES:



                       On behalf of the Plaintiffs:

                             Tabor Lindsay & Associates, by:

                             RICHARD D LINDSAY, ESQ

                             1223 Virginia Street E

                             Charleston, WV  25301

                             (304) 344-5155



                       On behalf of Defendant Marcia Khalil,

                       MD:

                             Mundy & Adkins, by:

                             DEBRA A NELSON, ESQ

                             One Plaza South

                             422 Ninth Street

                             Huntington, WV  25701

                             (304) 525-1406



                       On behalf of the Defendant Raleigh

                       General Hospital:

                             Farrell, Farrell & Farrell, by:

                             JOSEPH M FARRELL, JR, ESQ

                             Post Office Box 6457

                             Huntington, WV  25772-6457

                             (304) 522-9100

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            1    APPEARANCES, Continued:

            2

            3          On behalf of the Defendant Carlos Lucero,

            4          MD via telephone:

            5                McQueen, Harmon & Murphy, by:

            6                cHANIN WOLFINGBARGER KRIVONYAK, ESQ

            7                Geary Plaza, Suite 400

            8                700 Washington Street, East

            9                Post Office Box 1831

           10                Charleston, WV  25327-1831

           11                (304) 342-4200

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            1          DAVID BURKONS, MD, 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        CROSS-EXAMINATION OF DAVID BURKONS, MD

            7    BY MS NELSON:

            8          Q    Doctor, my name is Debra Nelson, I

            9    represent Dr Khalil in this case, and you've

           10    been designated as an expert witness on behalf

           11    of the Plaintiffs, and I'm here to take your

           12    deposition with regard to that today

           13          A    Yes

           14          Q    And your full name is Dr David

           15    Burkons?

           16          A    Burkons, that's correct

           17          Q    And your professional address is

           18    1611 South Green Street in South --

           19          A    Green Road

           20          Q    Green Road, South Euclid, Ohio; is

           21    that correct?

           22          A    Correct

           23          Q    And I understand you're an

           24    obstetrician-gynecologist?

           25          A    Yes

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            1          Q    I have a