1


                           IN THE COURT OF COMMON PLEAS

                             OF CUYAHOGA COUNTY, OHIO





                 UNVERSITY HOSPITALS OF

                 CLEVELAND, et al.,

                              Plaintiffs,

                      vs.                        Case No.

                 MEDICAL CENTER COMPANY          393455

                             Defendant.





                       Deposition of JUDE R. FOULDS, Ph.D., P.E.,

                 taken before me, Michele E. Eddy, Registered

                 Professional Reporter and Notary Public in and

                 for the State of Ohio, at the offices of

                 Gallagher, Sharp, Fulton and Norman, 7th Floor

                 Bulkley Building, Cleveland, Ohio, on Tuesday,

                 the 10th day of October 2000, at 10:30 a.m.

                                     - - - - -

                                                                  2


                 APPEARANCES:



                       On behalf of the Plaintiffs:

                             Cozen & O'Connor, by

                             STEVE N. SMITH, ESQ.

                             The Atrium, Third Floor

                             1900 Market Street

                             Philadelphia, PA,  19106

                             (215) 665-2000



                       On behalf of the Defendant:

                             Gallagher, Sharp, Fulton

                             & Norman, by

                             THOMAS E. BETZ, ESQ.

                             7th Floor, Bulkley Building

                             Cleveland, Ohio  44115

                             (216) 241-5310

                                         3


            1          JUDE R. FOULDS, Ph.D., P.E., of lawful

            2    age, called for examination, as provided by the

            3    Ohio Rules of Civil Procedure, being by me

            4    first duly sworn, as hereinafter certified,

            5    deposed and said as follows:

            6      EXAMINATION OF JUDE R. FOULDS, Ph.D., P.E.

            7    BY MR. SMITH:

            8          Q.    Good morning, Dr. Foulds.  My name

            9    is Steve Smith, and I represent the plaintiff,

           10    University Hospitals, in a