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           The State of Ohio,  )
       3                       ) SS:
           County of Lorain.   )
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                     IN THE COURT OF COMMON PLEAS
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           Stanislaw Krzysztofik,
       8   et al.,

       9                  Plaintiffs;

      10        vs.                    No. 04 CV 137691
                                       Judge Mark A. Betleski
      11
           Daniel Holden, M.D.,
      12   et al.,

      13                  Defendants.

      14                         - - - -

      15        Deposition of MICHAEL BEESON, M.D., a Witness

      16   herein, taken as if under cross-examination before

      17   Debra A. Butzer, a Notary Public within and for the

      18   State of Ohio, at Akron City Hospital, Summa Health

      19   System, School of Nursing, 41 Arch Street, Akron,

      20   Ohio, commencing at 11:07 a.m., Wednesday, November 2,

      21   2005, pursuant to notice and stipulations of counsel,

      22   on behalf of the Plaintiffs.

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      25


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       2                  E X A M I N A T I O N

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       4   Witness                                      Page

       5   MICHAEL BEESON, M.D.

       6        By Mr. Lancione..........................4

       7        By Ms. Hess.............................22

       8        By Mr. Lancione.........................30

       9        By Ms. Hess.............................35

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           APPEARANCES:
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       4          Lancione & Lancione, by
                  Mr. John G. Lancione
       5          BP Tower, Suite 2945
                  200 Public Square
       6          Cleveland, Ohio   44114
                  (216) 623-4949
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                           On behalf of the Plaintiffs;
       8

       9          Reminger & Reminger, by
                  Ms. Erin Siebenhar Hess
      10          1400 Midland Building
                  101 Prospect Avenue, West
      11          Cleveland, Ohio   44115
                  (216) 687-1311
      12
                           On behalf of Defendants Silva
      13                   Murthy, M.D. and Northeast Ohio
                           Emergency Affiliates;
      14

      15          Moscarino & Treu, by
                  Mr. John T. Bulloch
      16          The Hanna Building, Suite 630
                  1422 Euclid Avenue
      17          Cleveland, Ohio   44115
                  (216) 621-1000
      18
                           On behalf of Defendant Community
      19                   Health Partners.

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                                 - - - -
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       1                         - - - -

       2                  P R O C E E D I N G S

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       4                       MICHAEL BEESON, M.D., of lawful

       5                  age, a Witness herein, called by

       6                  the Plaintiffs for the purpose of

       7                  cross-examination, as provided by the

       8                  Ohio Rules of Civil Procedure, being by

       9                  me first duly sworn, as hereinafter

      10                  certified, deposed and said as follows:

      11                         - - - -

      12                   CROSS-EXAMINATION OF

      13                   MICHAEL BEESON, M.D.

      14          BY MR. LANCIONE:

      15    Q.    Could you state your full name for the record,

      16          please?

      17    A.    Michael Scott Beeson.

      18    Q.    Are you presently licensed to practice

      19          medicine in the State of Ohio?

      20    A.    Yes.

      21    Q.    And your clinical practice and teaching

      22          responsibilities, does that take up at least

      23          75 percent of your professional time?

      24    A.    Yes.

      25    Q.    Tell me how you became involved in this case


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       1          as an expert witness, Doctor.

       2    A.    I'm not exactly sure.  I received a phone call

       3          from -- or -- either a phone call or an e-mail

       4          from an individual --

       5                       MR. BULLOCH:  Bob Austria.

       6    A.    -- from Robert Austria, asking me if I'd be

       7          interested in reviewing the case.

       8    Q.    Have you worked on medicolegal matters

       9          involving malpractice cases in the past?

      10    A.