70046

        S@ate OS #*iLo.               I
                                    Be:
        County of Ashtabula.

    3                                 - -  -

                          IN THE  COURT  OF COMMON PLEAS


    6   Ashley Sue  Hawkins,  a  Minor,
        et al.,
    7
                          Plaintiffs,
    8                                        Case No.  83682
               Vs.
    9                                        Judge  Cardinal
        Ashtabula  County Medical
  10    Center, et al.,

  11                      Defendants.

  12                                  - - -

  13               DEPOSITION OF LEROY DIBRXBR, M.D.

  14                  THURSDAY, SEPTEMBER 6, 1990

  15                                  - - -

  16    The deposition of LeRoy  Dierker,  M.D.,  a  witness

  17    herein, called by  the  Plaintiffs  for  examination

  is    under the Ohio Rules of Civil Procedure, taken

  3.9   before no, Xvy J. Gantverg, Registered Professional

  20    Reporter and Notary Public in and for the State of

  21    Ohio, by agreement of counsel and without further

  22    notice or other legal formalities, at the offices of

  23    Jacobson, Maynard, Tuschman & galur, 1001 Lakeside

  24    kwanue - Suite 1600, Cleveland, Ohio, commencing at

  25    10:10 a.m., on the day and  date  above  set  forth.



                          MORSR.  GAWTVRRN & FOnar

                                                      2

    I   APPEAP.44(

    2   On behalf

    3          L&Wrendt J. Smith, Esq.
               518 South Rampart Street
    4          New Orleans, Louisiana 70113

    5          Calvin F. Hurd, Jr., Esq.
               1750 Standard Building
    6          Cleveland, Ohio  44113

    7          Walter P. Mahle, Esq.
               207 Main Street - Suite 360
    a          Painesville, Ohio  44077

    9   On behalf of Defendant Ashtabula County Medical
           Center:
   10
               K. Richard Aughenbaugh, Esq.
   11          Roetzel & Andress
               75 East Market Street
   12          Akron, Ohio  44308

   13   On behalf of Defendant Harl&n Waid, Jr., M.D.:

   it          Thomas H. Terry, III, Esq.
               Jacobson, Maynard, Tuschman   Kalur
   15          1001 Lakeside Avenue - Suite 1600
               Cleveland, Ohio  44114
   16

   17

   is

   19

   20

   21

   22

   23

   24

                        1- I @  I., mme


    2    a witneas   holt-64jk, pali*d by the Olaint-iff*  @f,*4e.
    3    examinstion und*r   the  Rules,  having  boon  first duly
    4    sworn, as htt*inatter certified, was depos*4i *nd
    5    said as follows:
    6                        CROSS EXAMINATION
    7    BY MR.  SMITH:
    a    Q.      Doctor, I  am  looking  at  your  curriculum
    9    vitae,  and it says that you are Board certified in
   10    obstetrics?
   11    A.      I am.
   12    9-      And when did you so become Board certified?
   13    A.      1978.
   14    Q.      And where  did  you  take  the  examination?
   15    A.      Where did I take the oral exam?
   16    Q.      Yes.
   17    A.      Chicago.
   is    Q.      Did you pass it the first time?
   19    A.      I did.
   20    Q.      knd you took a writt*n axam, as well?
   21    A.      Yes.
   22    Q.      Where did you take the written exam?
   23    A.      Where?
   24    Q.      Yes.
   23    A.      licksont, Virwiaia.

                            MNRRV. aAWTVRRa X UnnaF
                                            V6,40 *ad 3kat t,

    3   A.     Yes
    A   0.     Is that a subspecialty of obstetrics?
    5   k.     It is.
    6   Q.     Tell me about what additional training did
    7   you have in maternal fetal medicine?
    8   A.     A two year fellowship here in Cleveland.
    9   Q.     With whom?
   10   A.     At Cleveland Metropolitan General Hospital,
   11   Case Western Reserve.
   12   Q.     Is that a Board approved specialty by the
   13   Ameridan board *f Specialties of the American
   14   Medical Association?
   15   A.     It is.
   16   Q.     And I take it you passed that exam the first
   17   time?
   is   A.     Yes, I did.
   Le   Q.     Vhert was that given?
   20   A.     In Cleveland.
   21   Q.     What is the subspecialty of maternal fetal
   22   medictn*?
   23   A.     High risk obstetrics.
   24   0.     So 7ou &re not a family practitioner?
        A .    I am ft*%.
                                        i@' o   4   e(Ao 00@ I

                         %Inv eV .A%Tmlrwv@ r_ umn@o

                   u
                I  don't practice.,        odiciat.
                ***, What i* YO?AR-        toik wttk Mr. Tatirr,
    4   or  Mr. kalur, or this firm, the   Jocobson law  firm?
    5   A.