O(D 15 kA
          1                IN THE COURT OF COMMON PLEAS
          2                   OF CUYAHOGA COUNTY, OHIO
          3     MARY DUCKWORTH, etc    :
          4                Plaintiffs   :
          5          VS                :  Case No 226873
          6     LUTHERAN MEDICAL        :  Judge Patricia Cleary
          7     CENTER, et  al         :
          8                 Defendants  :
          9                     - - - - -
         10             DEPOSITION OF ALLEN J JONES, MD
         11                   MONDAY, FEBRUARY 1, 1993
         12                     - - - - -
         13                   The deposition of ALLEN J JONES,
         14     MD, the Witness herein, called by counsel on
         15     behalf of the Plaintiff for examination under the
         16     statute, taken before me, Vivian L Gordon, a
         17     Registered Professional Reporter and Notary Public
         18     in and for the State of Ohio, pursuant to
         19     agreement of counsel, at the offices of Jacobson,
         20     Maynard, Tuschman & Kalur, 1001 Lakeside Avenue,
         21     Cleveland, Ohio, commencing at 10:00 o'clock am
         22     on the day and date above set forth
         23                      - - - - -
         2 4
         2 5


                              Morse, Gantverg & Hodge
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             1    received
             2    Q     You don't recall reading any testimony that
             3    that was the practice of sending these copies of
             4    the interpretation out to various people?
             5    A     I recall the testimony that this was the
             6    customary practice, but  not  that  this  specific
             7    report was sent or received
             8    Q     I think I understand what you are saying
             9    Again, you don't know whether or not it was
           10     received by anybody in the emergency department?
           11     A     Or sent
           12     Q     Or sent  You have no idea?
           13     A     Correct
           14     Q     I take it, though, that if it was sent and
           15     received by the emergency department, that someone
           16     in the emergency department there had
           17     responsibility to respond appropriately to the
           18     information that was contained in the
           19     interpretation?
           20     A     If indeed it was sent  and  received,  yes
           21                   MR TERRY:  Wait  a  second  if  it
           22            was sent like his green sheets are sent
           23            so that it is flagged or just  be  shot  up
           24            to ER?
           25     Q     I want you to assume that the procedure

                               Morse, Gantverg & Hodge
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             1    APPEARANCES:
             2           On behalf  of  the  Plaintiffs:
             3                   Weisman, Goldberg & Weisman, by
             4                   RICHARD J BERRIS, ESQ
             5                   1600  Midland  Building
             6                   Cleveland, Ohio  44115
             7                   781-1111
             8
             9           On behalf of the Defendants Oza and
           10              Kapoor:
           11                    Quandt, Giffels, Buck & Rodgers, by
           12                    BETH A SEBAUGH, ESQ
           13                    800 Leader Building
           14                    Cleveland, Ohio  44114-1460
           15                    2 4 1 - 2 0 2 5
           16
           17            On behalf of the Defendant Lutheran
           18            Medical Center:
           19                    Arter & Hadden, by
           20                    KRIS H TREU, ESQ
           21                    1100 Huntington Building
           2 2                   Cleveland, Ohio  4 4 1 1 5
           2 3                   6 9 6 - I 1 0 0
           2 4
           2 5


                               Morse, Gantverg  &  Hodge
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             1           On behalf of the Defendants Acute Care
             2           Specialists Inc, and David Pelini, MD:
             3                  Jacobson, Maynard, Tuschman & Kalur
             4                  THOMAS H TERRY, III, ESQ
             5                  1001 Lakeside Avenue - Suite 1600
             6                  Cleveland, Ohio 44115
             7                  736-8600
             8
             9           On behalf of the Defendants Medical Center
           10