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, MD






                   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, PC
                           BY: PAUL FX GALLAGHER, ESQUIRE
                           COUNSEL FOR THE DEFENDANT
 






                                      I N D E X
                                      _ _ _ _ _



              WITNESSES               DIRECT  CROSS  REDIRECT  RECROSS
              _________               ______  _____  ________  _______



              WILLIAM L SIMON , MD   5,12  11,45     61
 

                                                                     4




         1

         2                      MORNING_SESSION
                                _______ _______

         3

         4                 (WHEREUPON, AT 9:45 AM 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           MD

        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