IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY

                       FIRST JUDICIAL DISTRICT OF PENNSYLVANIA

                                 CIVIL TRIAL DIVISION

                                        - - -

              ESTER VIOLA BLOCKER                 : OCT. TERM, 1994

                     VS.

              NATIONAL RAILROAD PASSENGER CORP.   : NO. 652


                                       - - -

                      COURTROOM "M", COMPLEX LITIGATION CENTER
                                 WANAMAKER COMPLEX
                             PHILADELPHIA, PENNSYLVANIA

                                       - - -

                                    MAY 22, 1996

                                       - - -


                     BEFORE:  HONORABLE ALFRED J. DI BONA, JR.
                                    AND A JURY

                                       - - -

                          TESTIMONY OF WILLIAM SIMON, M.D.






                   GEORGE D'ANGELIS, RPR, OFFICIAL COURT REPORTER
                            1321 ARCH STREET - SUITE 302
                              PHILADELPHIA, PA   19107
                                   (215) 686-4240
 












              APPEARANCES:




                           FORCENO, HANNON AND ARANGIO
                           BY:  THOMAS J. JOYCE, III, ESQUIRE
                           COUNSEL FOR PLAINTIFF




                           GALLAGHER, REILLLY AND LACHAT, P.C.
                           BY: PAUL F.X. GALLAGHER, ESQUIRE
                           COUNSEL FOR THE DEFENDANT
 






                                      I N D E X
                                      _ _ _ _ _



              WITNESSES               DIRECT  CROSS  REDIRECT  RECROSS
              _________               ______  _____  ________  _______



              WILLIAM L. SIMON , M.D.   5,12  11,45     61
 

                                                                     4




         1

         2                      MORNING_SESSION
                                _______ _______

         3

         4                 (WHEREUPON, AT 9:45 A.M. THE FOLLOWING

         5           TOOK PLACE IN OPEN COURT, ALL PARTIES

         6           PRESENT:)

         7                       THE COURT: GOOD MORNING.

         8                 MR. GALLAGHER, YOUR NEXT WITNESS.

         9                       MR. GALLAGHER:  WE CALL DOCTOR

        10           WILLIAM SIMON.

        11                       COURT CRIER:  STATE YOUR FULL

        12           NAME FOR THE RECORD, PLEASE.

        13                       THE WITNESS:  WILLIAM L. SIMON,

        14           M.D.

        15                       COURT CRIER:  DO YOU SWEAR THAT

        16           YOU WILL ANSWER TRUTHFULLY ALL QUESTIONS PUT

        17           TO YOU TOUCHING UPON THE MATTER NOW BEFORE

        18           THIS COURT, SO HELP YOU GOD?

        19                       THE WITNESS:   I DO.

        20                 (THE WITNESS, HAVING BEEN FIRST DULY

        21           SWORN BY THE COURT CRIER, WAS EXAMINED AND

        22           TESTIFIED AS FOLLOWS:)

        23

        24                         -     -     -
 

                                                                     5




         1                     DIRECT EXAMINATION

         2                        -     -     -

         3    BY MR. GALLAGHER:

         4    Q.     DR. SIMON, WHAT DO YOU DO FOR A LIVING?

         5    A.     I AM A BOARD CERTIFIED ORTHOPEDIC SURGEON.

         6    Q.     WHERE DID YOU GET YOUR UNDERGRADUATE

         7    TRAINING?

         8    A.     I GRADUATED FROM PRINCETON UNIVERSITY IN

         9    1959.

        10    Q.     AND YOUR MEDICAL TRAINING?

        11    A.     I WAS GRADUATED FROM THE UNIVERSITY OF

        12    PENNSYLVANIA SCHOOL OF MEDICINE IN 1963.

        13    Q.     HOW ABOUT POSTGRADUATE TRAINING AND

        14    FELLOWSHIP APPOINTMENTS.  COULD YOU TELL THE JURY

        15    ABOUT THOSE?

        16    A.     YES, I SPENT A YEAR AS AN INTERNAL AT THE

        17    UNIVERSITY OF PENNSYLVANIA HOSPITAL.

        18                 THEN A SECOND YEAR AS A SURGICAL

        19    RESIDENT AT THE UNIVERSITY OF PENNSYLVANIA

        20    HOSPITAL.

        21                 THEN I SPENT THREE AND A HALF YEARS AS

        22    AN ORTHOPEDIC SURGICAL RESIDENT AT THE

        23    MASSACHUSETTS GENERAL HOSPITAL AND BOSTON CHILDREN

        24    HOSPITAL IN BOSTON, MASSACHUSETTS.
 

                                                                     6




         1                 I THEN SPENT TWO YEARS AT THE NATIONAL

         2    INSTITUTES OF HEALTH IN BETHESDA, MARYLAND, DOING