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                       IN THE SUPERIOR COURT OF CATOOSA COUNTY

                                   STATE OF GEORGIA





                 BOBBIE FAY CHAUNCEY, et al

                              Plaintiffs,

                     vs                          Civil Action No

                 UHS/PRUITT CORPORATION,          99-CV-01155

                 et al,

                             Defendants

                                      - - - - -



                             Deposition of ALAN JAY LERNER, MD,

                 called for examination under the statute, taken

                 before me, Carina C Meszaros, a Registered Merit

                 Reporter and Notary Public in and for the State

                 of Ohio, by agreement of counsel, at University

                 Hospitals, 12200 Fairhill Road, Cleveland, Ohio,

                 on Monday, July 31, 2000, at 1:04 o'clock pm

                                      - - - - -

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                 APPEARANCES:



                       On behalf of the Plaintiffs:

                             Watkins, Lourie & Roll, by

                             LANCE D LOURIE, ESQ

                             Tower Place 200

                             3348 Peachtree Road, Suite 1050

                             Atlanta, Georgia  30326

                             (404) 760-7403

                                   and

                             Kennedy, Koontz & Farinash, by

                             JAMES W CLEMENTS, III, ESQ

                             320 North Holtzclaw Avenue

                             Chattanooga, Tennessee  37404

                             (423) 622-4535



                       On behalf of the Defendants:

                             Weinberg, Wheeler, Hudgins,

                             Gunn & Dial, by

                             CAROL P MICHEL, ESQ

                             999 Peachtree Street, NE Suite 2700

                             Atlanta, Georgia  30309

                             (404) 876-2700

                                         ----

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            1                MR LOURIE:  This will be the

            2    deposition of Alan Jay Lerner taken by

            3    agreement of counsel for the purpose of

            4    discovery and all other purposes allowed under

            5    the Georgia Civil Practice Act, including

            6    cross-examination of an expert witness

            7    designated by the Defendants in the above

            8    referenced case

            9                We'll reserve all objections except

           10    those going to the form of the question or

           11    responsiveness of the answer until further use

           12    of the deposition  All other formalities with

           13    respect to Notice and taking the deposition are

           14    waived

           15                I assume he wants to read and sign?

           16                MS MICHEL:  Yes

           17                MR LOURIE:  The deposition will be

           18    read and signed by the Witness  He can sign

           19    before any notary

           20                MS MICHEL:  That's fine

           21                     -  -  -  -  -

           22                (Thereupon, Plaintiffs' Deposition

           23                Exhibits 1 and 2 were marked for

           24                purposes of identification)

           25                      -  -  -  -  -

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            1            ALAN JAY LERNER, of lawful age, called

            2    for examination, being by me first duly sworn,

            3    as hereinafter certified, deposed and said as

            4    follows:

            5          EXAMINATION OF ALAN JAY LERNER, MD

            6    BY MR LOURIE:

            7          Q    Dr Lerner, I'm going to show you

            8    what I have marked as Plaintiffs' Exhibit

            9    Number 1 and ask you if that is a true and

           10    accurate copy of your curriculum vitae?

           11          A    Yes

           12          Q    Are there any articles that you

           13    have written that -- articles, chapters,

           14    abstracts or anything listed in here that you

           15    think is particularly applicable to the issues

           16    in this case?

           17          A    Can I review that?

           18          Q    Sure

           19          A    The answer to that would be yes