Trialsmith Document Number 156937 accessed at www .trialsmith .com
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1 IN THE COURT OF COMMON PLEAS
2 ASHTABULA COUNTY, OHIO
3 KAYLA CIMORELLI, et al .,
4 Plaintiffs,
Civil Action No . :
5 v.
98 CV 00632
6 ASHTABULA COUNTY MEDICAL CENTER,
7 Defendant .
8
9
10 DEPOSITION OF STEVEN MARK DONN, M.D .
11 Taken at the Offices of Esquire Deposition Services,
12 215 East Washington, Ann Arbor, Michigan, on February 21,
13 2000 commencing at or about 5 :10 p .m.
14 APPEARANCES :
15 For the Plaintiff :
16 MS . LAUREL MATTHEWS
Kampinski & Mellino Co ., L .P .A.
17 The Standard Building
1370 Ontario Street, Suite 1530
18 Cleveland, Ohio 44113
(216) 781-4110
19
For the Defendant :
20
MR. DONALD H . SWITZER
21 Bonezzi, Switzer, Murphy & Polito Co ., L .P .A.
Leader Building, Suite 1400
22 526 Superior Avenue
Cleveland, Ohio 44114
23 (216) 875-2767
24 REPORTED BY :
25 Tami I . Watters, CSR-3639
Certified Shorthand Reporter
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I N D E X
WITNESS :
STEVEN MARK DONN, M.D .
Examination by Ms . Matthews
EXHIBITS :
Deposition Exhibit Nos . 1 and 2
Deposition Exhibit No . 3
Page
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1 Ann Arbor, Michigan
2 February 21, 2000
3 At or about 5 :10 p .m.
4
5 (Deposition Exhibit Nos . 1 and 2 marked for
6 identification)
7 S T E V E N M. D O N N, M. D .,
8 having first been duly sworn or affirmed by the
9 Notary Public, was examined and testified as follows :
10 EXAMINATION
11 BY MS . MATTHEWS :
12 Q Doctor, my name is Laurel Matthews . I represent the
13 plaintiff in this case .
14 Could you please state your name and office address for
15 the record?
16 A Steven Mark Donn, M.D ., F5790 CS Mott Children\'s,
17 1500 East Medical Center Drive, Ann Arbor, Michigan
18 48109-0254 .
19 Q Doctor, on how many occasions have you been deposed before?
20 A I have no idea .
21 Q Can you give me an estimate?
22 A No .
23 Q More than a hundred?
24 A Possibly .
25 Q More than 200?
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1 A I don\'t keep track . It\'s possible . It could be anywhere
2 between a hundred, 200, maybe more .
3 Q How many occasions have you been retained by Mr . Switzer?
4 A I would guess probably a dozen times .
5 Q What about St . Paul Insurance?
6 A I think there have only been about two or three cases where I
7 have been directly retained by St . Paul .
8 Q Do you have any idea how many