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 1      STATE OF NORTH CAROLINA           IN THE GENERAL COURT
         COUNTY OF SURRY                        OF JUSTICE
 2                                        SUPERIOR COURT DIVISION
 3        CHRISTOPHER ANDERSON, a minor, ) 
         by his Guardian ad litem,      )     No:  02 CvS 459 
 4        JANET BROWN,                   ) 
                                        )
 5                       Plaintiff,      )
                                        )
 6             v                        )
                                        )
 7        MARTIN VILES, MD;            )
         PIEDMONT WOMEN\'S CENTER, PA; )
 8        and HUGH CHATHAM               )
         MEMORIAL HOSPITAL, INC,       )
 9                                       )
                        Defendants     )      
10        ______________________________ )     
11                  DEPOSITION OF STEVEN M DONN, MD      
12             Taken at 2355 East Stadium Boulevard, Ann Arbor,    
              Michigan, on August 26, 2003, commencing at or      
13             about 5:25 pm
14        APPEARANCES:
15        For the Plaintiff:
16             MS ROBIN R SMITH (Via Telephone)
              Janet, Willoughby, Gershon, Getz & Jenner, LLC
17             Woodholme Center
              1829 Reisterstown Road, Suite 320
18             Baltimore, Maryland   21208
              (410) 653-3200                        
19   
              MR JOHN C HENSLEY, JR (Not Present)
20             Cloninger, Lindsay, Hensley & Searson, PLLC
              366 Merrimon Avenue
21             Asheville, North Carolina   28801
              (828) 252-1786                         
22   
         For the Defendants:
23   
              MR J DENNIS BAILEY
24             Carruthers & Bailey, PA
              155 Sunnynoll Court, Suite 102
25             Winston-Salem, North Carolina   27106

                                                                     2
 1             MR BRIAN H ALLIGOOD (Via Telephone)
              Sharpless & Stavola, PA
 2             826 North Elm Street
              Greensboro, North Carolina   27401
 3             (336) 333-6400         
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25        REPORTED BY:  Deborah Bjorling Uhley, CSR-2735

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 1                          I  N  D  E  X
 2   
 3        WITNESS:                                       Page
 4   
 5        STEVEN M DONN, MD     
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 7             Examination by Ms Smith                    4
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10        EXHIBITS:
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12             Deposition Exhibit A                       30       
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                                                                     4
 1                                          Ann Arbor, Michigan
 2                                          August 26, 2003
 3                                          At or about 5:25 pm
 4                            -   -   -
 5                       STEVEN M DONN, MD,
 6        having first been duly sworn or affirmed, was examined
 7        and testified as follows: 
 8                  MS SMITH:  Doctor Donn, my name is Robin 
 9        Smith  I\'m one of the attorneys for the Plaintiffs  
10        I\'m going to be asking you a series of questions  If 
11        you don\'t understand one of my questions, please let me 
12        know and I will clarify it  On the other hand, if you 
13        answer my question, I will assume that you understood it 
14        and will hold you to your answer  Is that understood to 
15        you, sir?
16                  THE WITNESS:  Yes  
17                  MS SMITH:  Great  
18                           EXAMINATION 
19        BY MS SMITH:  
20   Q    Can you give us your name and address for the record, 
21        please?
22   A    Steven Mark Donn, MD, F-5790 CS Mott Children\'s 
23        Hospital, 1500 East Medical Center Drive, Ann Arbor, 
24        Michigan 48109-0254
25   Q    Thank you  

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 1                  You\'ve given a deposition before, sir?
 2   A    Yes
 3   Q    So, you know that you need to answer verbally as opposed 
 4        to a shrug of the shoulders, and since we\'re on the 
 5        telephone, it will be even more important for us to try 
 6        not to talk over each other so we get a clear 
 7        transcript, okay?
 8   A    Yes
 9   Q    Doctor, I was provided a copy of your Curriculum Vitae  
10        Unfortunately, I don\'t have it in front of me, but I