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1 STATE OF ILLINOIS )
ss :
2 COUNTY OF C O O K )
3 IN THE CIRCUIT COURT OF THE NINETEENTH
JUDICIAL CIRCUIT, LAKE COUNTY, ILLINOIS
4
RIA ROSAN NAVARRO, a minor, by )
5 RENATO NAVARRO and ESTER NAVARRO, )
her parents and next friends, and )
6 RENATO NAVARRO and ESTER NAVARRO, )
individually, )
7 Plaintiffs, )
1
8 -vs-
9 EULOGIO ANDAYA, M D and
ST  THERESE HOSPITAL, a
10 corporation, TAMI VARGHESE, R N ,
SYLVIA NORTHROP, R N , NADINE
11 SEDAR, R N , and GLENDA
JOHNSON, R N ,
12 Defendants 
No  86 L 1435
13 Discovery deposition of DR  STEVEN M  DONN,
14 taken before LAURA L  DeVRIES, C S R  and Notary Public,
15 pursuant to the provisions of the Illinois Code of Civil
16 Procedure and the Rules of the Supreme Court thereof,
17 pertaining to the taking of depositions ,for the purpose
18 of discovery, at Suite 300, 222 North LaSalle Street,
19 Chicago, Illinois, commencing at 10 :40 o\'clock a m  on
20 the 15th day of June, AD  1989 
21 There were present at the taking of this
22 deposition the following counsel :
23 LAW OFFICES OF PATRICK A  SALVI by
MR  PATRICK A  SALVI,
24
1
HARTNSTT & CATEILAATI, LTD
Certified Shorthand Reporters
1 on behalf of the Plaintiff ;
2 MESSRS  BRYDGES, RISEBOROUGH, MORRIS, FRANKE &
MILLER by
3 MR  DARRELL S  DUDZIK,
4 on behalf of the Defendant Dr  Eulogio
Andaya ;
5
MESSRS  HINSHAW, CULHERTSON, MOELMANN, HOBAN &
6 FULLER by
MR  MICHAEL HENRICK,
7
on behalf of the Defendant St  Therese
8 Hospital ;
9 MESSRS  BRENNER, MAVRIAS, DORN & ALM by
MR  BRUCE FARREL DORN,
10
on behalf of the Defendant Glenda Johnson,
11 R N 
12
13 (Donn Deposition Exhibit One marked )
14 (Witness duly sworn )
15 DR STEVEN M  DONN,
16 called as a witness herein, having been first duly
17 sworn, was examined upon oral interrogatories and
18 testified as follows :
19 MR  HENRICK : Would you state your full name for the
20 record, please?
21 THE WITNESS : Steven Mark Donn, M D 
22 MR  HENRICK : Let the record show this is the
23 discovery deposition of Steven Mark Donn, taken pursuant
24 to the applicable sections of the Civil Practice Act,
2
HARTNETT do CATELLANI, LTD
Certified Shorthand Reporters
1 Supreme Court Rules of the State of Illinois, and the
2 local rules of the Nineteenth Judicial Circuit 
3 EXAMINATION
4 by Mr  Henrick :
5 Q Doctor, I\'m going to be asking you a series of
6 questions with regard to your review of the materials
7 that Mr  Salvi has supplied you and particularly your
8 opinions with regard to this particular case which is
9 the subject litigation 
10 My understanding from my informal 220
11 conference with Mr  Salvi, that you are not here to
12 render any opinions with regard to the standard of care
13 and you are here to render opinions with regard to what
14 you believe is the cause of the child\'s neurological
15 deficit  Is that correct?
16 A That\'s my understanding 
17 Q So it\'s fair to say that you will neither at
18 this deposition or at the time of trial be offering any
19 opinions with regard to the standard of care of any of
20 the defendants in this lawsuit  Is that correct?
21 A Yes 
22 Q And Mr  Salvi has supplied me with what I have
23 marked -- or I should say the court reporter has marked
24 as Exhibit Number One for identification which is your
3
HARTNET\'f do CATELLANI, LTD
Certified Shorthand Reporters
1 curriculum vitae 
2 Would you take a look at that, please? Is that
3 document complete and up to date?
4 A No, it is not 
5 Q What additions or deletions would you want to
6 make, or do you want to make?
7 A I\'m sorry?
8 Q Or do you want to make?
9 A It\'s dated November 14, 1986, which makes it two
10 and a half years or so old  The present edition of this
11 document is approximately 30-some pages long  It
12 contains the additional publications, abstracts,
13 et cetera, that have been added since this was put
14 together in November of 1986  Those changes are rather
15 extensive, and if it would be all right, I could forward
16 an updated copy to Mr  Salvi which he could give to you
17 at his convenience 
18 Q Yes, I\'d appreciate that 
19 With regard to your affiliations with hospitals
20 and teaching affiliations, are they the same as they
21 were in \'86, or has that changed?
22 A The hospital affiliations are the same with the
23 exception of Westland Medical Center as a result of an
24 institutional disaffiliation between the University of
4
HARTNETT do CATELLAIII, LTD
Certified Shorthand Reporters
1 Michigan and Westland Medical Center  And though it\'s
2 on the C V , I never saw, treated, or was otherwise
3 involved in patient care at that facility 
4 Q And I take it based on the disassociation, you
5 don\'t anticipate seeing any patients there in the
6 future?
7 A No, I don\'t 
S Q Any other changes other than your disassociation
9 with We