2                 COURT OF COMMON PLEAS

              3                 HAMILTON COUNTYP OHIO

              4

              5  - - - - - - - - - - - - -
                 CARLA DENISE ZWEIGART,
              6  et al.,

              7            Plaintiffs,

              8       vs.                     CASE NO.  A84090606

              9  THEODORE W. STRIKER,

           10    M.D., et al.,
                                                COPY
                          Defendants.
           11    - - - - - - - - - - - - -

           12        Deposition of ALICE A. JOHNSON, R.N.,

           13    B.S.N., a witness herein, called by the

           14    defendants for cross-examination, pursuant to the

           15    Ohio Rules of Civil Procedure, taken before me,

           16    Angie Lautner Portune, a Registered Professional

           17    Reporter and Notary Public in and for the State

           18    of Ohio, at the offices of Jacobson, Maynard,

           19    Tuschman & Kalur, 30 Garfield Place, Cincinnati,

           20    Ohio 45202, on Tuesday, June 25, 1991, at 11:00

           21    a.m.

           2  2

           2  3

           2  4



                                               Merit (513)381-8228

                                                                   3

            1    and that proof of the official character and

            2    qualifications of the notary are expressly

            3    waived.

            4                         I N D E X

            5    ExaTnination of ALICE A. JOHNSON             Pacte

            6    By Mr. Darby                                  4

            7                         - - -

            8         Defendants' Exhibit            Page Identified

            9         No.  1                               4
                      No.  2                             3 4
           10         No.  3                             3 4
                      No.  4                             3 6
           11

           12                         - - -

           13

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           15

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           2 0

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           2 2

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           2 4



                                                  Merit (513)381-8228

                                                                      5
             1    in 1971.
             2          A.   Yes.
             3          Q.   And  then  it  says  post-graduate  studies
             4    in  occupational  health  nursing.  Do  you  hold  any
             5    advanced  degrees  beyond  the  bachelor  of  nursing
             6    obtained at  the  University  of  Maryland  in  1971?
             7          A.   No.
             8          Q.   All  right.  Do  you  hold  any  particular
             9    certifications in nursing other than a nursing
            10    license?
            11          A.   Yes.  I hold a CR RN.
            12          Q.   All right.  Any others?
            13          A.   No.
            14          Q.   okay.
            15          A.   I'm trying to  think  of  the  others  that
            16    Ilin about to sit for.
            17          Q.   Okay.  Like  I  said,  we'll  just  add  to
            18    the deposition.  We'll mark that.  Have you
            19    consulted with Mr. Metz in the past on any
            20    litigation that he was involved in?
            21               MR. METZ:  Objection.  Go ahead.
            22          A.   I've worked with  Mr.  Metz  on  one  other
            23    case.
            24          Q.   All right.

                                                    Merit (513)381-8228
                                                                       7
             1         A.    There  is  an  additional  addendum  report
             2    prepared following Michaells recent
             3    hospitalization at Children's.
             4         Q.    All right.  And  havd  you  got  that  with
             5    you   today?
             6         A.    I have my copy.
             7         Q.    All right.  Let  me  just  take  a  look  at
             8    it.
             9         A.    (Handing document.)
            10         Q.    All right.  I haven't been provided
            11    this report yet.  So after the deposition we'll
            12    just make a copy of it.
            13               MR. METZ:  Sure.  Okay.
            14         Q.    All right.  Mrs. Johnson, when was
            15    Michael first put into the residential care
            16    facility here in Cincinnati?
            17         A.    I'll have  to  ask  you  which  residential
            is    care.
            19