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                                IN THE DISTRICT COURT

                             OF JEFFERSON COUNTY, TEXAS



                 CHARLES WILCOX, Individually

                 and on Behalf of the Estate of

                 BONNIE WILCOX, Deceased, et al,

                             Plaintiffs,

                       vs                            Cause No

                 MEMORIAL HERMANN BAPTIST             B-165894



                 BEAUMONT HOSPITAL,

                             Defendant



                                     ~ ~ ~ ~ ~

                             Videotaped deposition of

                 ROSE ANNE LONSWAY, RN, BSN, MA, CRNI, called for

                 examination under the Applicable Rules of Federal

                 Civil Procedure, taken before me, Judy L Wagner,

                 a Court Reporter and Notary Public in and for the

                 State of Ohio, pursuant to notice and

                 stipulations of counsel, at the Sheraton

                 Cleveland Airport Hotel, 5300 Riverside Drive,

                 Cleveland, Ohio, on Tuesday, September 17, 2002,

                 at 10:00 am

                                     ~ ~ ~ ~ ~

                                                                  2

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                 APPEARANCES:



                       On behalf of the Plaintiffs:

                             The Peveto Law Firm, by

                             REX PEVETO, ESQ

                             118 Border Street

                             Orange, Texas 77630

                             409-883-0220



                       On behalf of the Defendant:

                             Orgain, Bell & Tucker, LLP, by

                             MIKE L PAINTER, ESQ

                             470 Orleans Street

                             Beaumont, Texas 77701

                             409-838-6412

                                     ~ ~ ~ ~ ~



                 ALSO PRESENT:

                       Videographer:

                             Mr Keith E McGregor, CLVS

                             Videographics

                             419 Dover Center Road

                             Bay Village, Ohio 44140

                             440-899-1961

                                     ~ ~ ~ ~ ~                      09:44:07

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            1                (Thereupon, Plaintiffs' Deposition

            2                Exhibits 1 and 2 were marked for

            3                purposes of identification)

            4                      -  -  -  -  -

            5                THE VIDEOGRAPHER:  We're on the        09:54:08

            6    record

            7                ROSE ANNE LONSWAY, RN, BSN, MA,

            8    CRNI, of lawful age, called for examination, as

            9    provided by the Federal Rules of Civil

           10    Procedure, being by me first duly sworn, as

           11    hereinafter certified, deposed and said as

           12    follows:

           13                     EXAMINATION OF

           14          ROSE ANNE LONSWAY, RN, BSN, MA, CRNI

           15    BY MR PEVETO:

           16          Q    Would you please give me your full

           17    name?

           18          A    Rose Anne Lonsway

           19          Q    Ms Lonsway, where do you live?

           20          A    I live in Painesville, Ohio           09:54:24

           21          Q    Could you give me your address?

           22          A    It's 1437 Madison Avenue,

           23    Painesville, Ohio

           24          Q    And your phone number?

           25          A    440-350-3894                          09:54:33

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            1          Q    Now, Ms Lonsway, you've brought a

            2    copy of your curriculum vitae here today, is

            3    that right?

            4          A    That's correct

            5          Q    And just for the benefit of            09:54:44

            6    everyone involved, a curriculum vitae is

            7    basically a professional resume  It includes

            8    your education, your professional experience,

            9    any publications, any honors you may have

           10    received, things of that nature, is that           09:54:55

           11    correct?

           12          A    That's correct

           13          Q    All right  Let me show you

           14    Plaintiffs' Exhibit Number 1 and ask you to

           15