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CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT - LAW DIVISION
RICHARD J . ARQUILLA, a minor,
by his father and next friend,
RICHARD ARQUILLA, SR .,
Plaintiff,
VS . 185 L 9004-C
WEST SUBURBAN HOSPITAL MEDICAL
CENTER, a corporation, and
DR . RICHARD BLANKSHAIN .
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APPEARANCES : p~p~~~;;,,]]
COI2BOY Gar x ; \'S7 3:
Cr
For the Plaintiff,
BY : CYRIL J . MCILHIIRGIE .
CASSIDAY, SQHa.DE & GLOOR, P .C .,
33 West blacker Drive, Suite 1200,
Chicago, Illinois 60606-2289,
For the Defendant West Suburban Hospital,
BY : RUDOLF G . SCHADE, JR.
DEPOSITION OF STEVEN K . DONN, K .D .
(Taken on September 21, 1991)
NATIONAL COURT REPORTING, INC .
29580 Northwestern Highway
southfield, MI 313/358-3730 1
1 APPEARANCES (continued) :
2 WILDMAN, HARROLD, ALLEN b DIXON, P .C .,
3 225 West Wacker Drive,
4 Chicago, Illinois 60606,
5 For the Defendant Dr . Blankshain
6 BY : KEVIN T . MARTIN .
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The deposition of STEVEN M . DONN, H .L ., a
witness in the above-entitled cause, taken before
David J . Demski, Certified Shorthand Reporter and
Notary Public in and for Berrien County, Michigan,
(Acting in washtenaw County, Michigan,) at the
Ramada Inn, Ann Arbor, Michigan on Saturday, September
21, 1991, commencing at the hour of 1 :00 o\'clock p .m .,
pursuant to the applicable Court Rules for the State of
Illinois .
* ,t s +r ,r wr
I N D E X
Examination by Mr . McIlharqie
Examination by Mr . Martin
- Examination by !!r . McIlharqie
NATIONAL COURT REPORTING, INC .
\" 29580 Northwestern Highway
3outhlield, MI 313/358-3730
PAGE
3
123
121
2
C/`C~Z~~dc, T./z
1 E X H I B Z T S PAGE
Plai tiff\' 2 n s Exhibit 1 5
Plaintiff\'s Exhibit 1-A 5
4 Plaintiff\'s Exhibit 2 34
5 Plaintiff\'s Exhibit 2-A 36
6 Plaintiff\'s Exhibit 3 39 - .
7 Plaintiff\'s .Exhibit 4-a, B, C 99
8 Planitiff\'s Exhibit 5-a, B, C 99
9
10 MR . MCZLFiARGZE : Let the record reflect
11 that this is the discovery deposition of Dr . Steven M .
12 Donn, D-o-n-n, it is taken pursuant to the applicant
13 Rules of the Supreme Court of the State of Illinois,
\" 14 the local Rules of the Court of Cook County and the
15 applicable Rules of Civil Procedure for the State of
16 Illinois .
17 STEVEN M . DONN, M .D,
18 havinq been first duly sworn, was examined and
19 testified on his oath as follows :
20 EXAMINATION
21 BY MR . MCILFiARGIE :
22 Q would you state your tall name, sir, and spell
23 your last name for the record, please,
24 A Steven Mark Donn, M .D ., D-o-n-n .
25 Q Dr . Done, you\'ve been identified as a medical
NATIONAL COURT REPORTING, INC .
\" 29580 Northwestern Highway
Southfield, MI 313/358-3730 3
1 witness with expertise on behalf of West Suburban
s H it l i hi A 2 o p a n t s case . re you aware of that?
3 A Yes, sir . I am .
a Q Sit, I take it you\'ve had occasion to give your
5 deposition in the past?
6 A That\'s correct .
7 Q You understand then i! Z ask a question and it\'s
_nc2aar because et the spay I\'v9 put the q+1eRt.ion, the
9 way I articulated the question or anything about the
10 way I pronounce words, you\'re entitled to ask for
ii clarification. Do you understand that?
12 A Yes .
13 Q will you do so then, sir, at any point in time, 1!
\" 14 you don\'t understand a question or i! it lacks clarity,
15 will you insist upon clarification before you answer?
16 A I will .
17 Q So we have an understanding then that i! you
is answer a question, you do so because you believe you
19 understand what\'s being asked?
20 A That\'s lair enough .
21 Q Can you state !or us please, your currant address,
22 both hoax and work .
23 11 My homy address is 5712 woodridqa Court, Ann
24 Arbor, Michigan, 48103 : my office address is Box 0254
25 L, 3023 women\'s Hospital, University o! Michigan
<-
NATIONAL COURT REPORTING, INC .
\" 29580 Northwestern Highway
Southfield, MI 313/358-3730 4
i Medical Center, 200 East Hospital Drive, Ann Arbor,
41 Mi hi 2 c gan, 48109-0254 .
3 Q And how long has that been your work address, sir?
4 A I\'ve bean continuously employed by the University
5 of Michigan since 1978 . I can\'t remember the last time
6 that the address was changed .
7 Q About the time they fore down the old hospital, Z
9 imagine.
9 a similarly.
10 142 . MCILHARGIE : Let\'s mark this as Donn
11 Exhibit 1 for purpose of identification .
12 (Plaintiff\'s Exhibit No . 1 was
13 marked for identification .)
\" 14 Q (By Mr . McIlharqie) : Doctor, showing you what
15 we\'ve marked for purpose of identification as
16 Plaintiff\'s Exhibit l, captioned: \"Steven M. Done,
17 M.D ., Curriculum Vitae\" at its top, in it\'s upper-right
18 comas of the first page, \"October 29, 1990, and
19 numerically paged from the second page onward to
20 encompass the totality of 34 pages. I ask you to
21 examine that document, please .
22 MR . SCHADB : Yes, go ahead .
23 Q (By Mr