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                          IN THE UNITED STATES DISTRICT COURT

                          FOR THE EASTERN DISTRICT OF VIRGINIA

                                  NORFOLK DIVISION





                 RAYMOND ADELMAN, M.D.,

                              Plaintiff,

                      v.                         Case No.

                                                 2:00CV785



                 MEDICAL COLLEGE OF HAMPTON

                 ROADS,

                              Defendant.

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                           Deposition of ELLIS D. AVNER, M.D.,

                 called for examination under the statute, taken

                 before me, Renee L. Pellegrino, Registered

                 Professional Reporter in and for the State of

                 Ohio, by agreement of counsel, at Rainbow Babies

                 & Children's Hospital, 11100 Euclid Avenue,

                 Cleveland, Ohio, on Monday, October 28, 2002, at

                 10:10 a.m.



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                 APPEARANCES:



                           On behalf of the Plaintiff:

                                 Howell, Daugherty & Brown, by

                                 ROBERT E. BROWN, ESQ.

                                 One East Plume Street

                                 Post Office Box 3929

                                 Norfolk, Virginia  23514-3929

                                 (757) 623-7334



                           On behalf of the Defendant:

                                 Troutman & Sanders, by

                                 ALAN D. ALBERT, ESQ.

                                 150 West Main Street

                                 Suite 1600

                                 Norfolk, Virginia   23510

                                 (757) 687-7755



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            1               ELLIS D. AVNER, M.D., of lawful age,

            2    called for examination, provided by the

            3    statute, being first duly sworn, as hereinafter