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                      STATE OF OH3:0
              2       COUNTY OF CUYAHOGA

              3                   IN THE COURT OF COMMON PLEAS


                - - - - - - - - - - - - - - - - -  -X
              4 PAUL R. WORTHING, Individually
                and as Administrator of the
              5 estate of Paul Worthing, Jr.,

              6 deceased,


              7                     Plaintiff,
                                                      Case No. 55,257
                        V.

                HILLCREST HOSPITAL, et al.,

              10                    Defendants.

              11 - - - - - - - - - - - - - - - - -  -x

              12              DEPOSITION OF MERVYN JEFFRIES, M.D.
              13                                Washington, D. C.
              14                                Thursday, May 31, 1984

              is      Deposition of MERVYN JEFFRIES, M.D., called for exam-
                ination pursuant to agreement by counsel, at 444 North Capitol
              16 Street, N.W., Suite 341, at 4:30 p.m. before PAULA L.  STERN,
                a Notary Public within and for the District of Columbia  when
              17 were present on behalf of the respective parties:

              18      ERIC KENNEDY, ESQ., 540 Leader Boulevard, Cleveland,
                      Ohio 44114; dn behalf of the Plaintiffs.
              19      STEVEN ALBERT, ESQ., 1305 The Superior Building,
              20      Cleveland, Ohio 44114; on behalf of Hillcrest Hospital.

              21      GARY H. GOLDWASSER, ESQ., Reminger & Reminger  Company,
                      L.P.A. 300 Leader Building, Cleveland, Ohio 44114;
              22      on behalf of the Defendants, Doctors Gindi  and  Reddy.

                                                           --continued--

                                                                          2


               2                CONTINUED

               3              C- MHYNARD, ESQ., Squire, Sanders & Dempsey,
                             Union commerce Building, Cleveland, Ohio 44115;
               4        on behalf of the DefendantDoctor Luria.





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               2                      S2EZEETS

               3                                                   EXAMINATION
                 Mervyn Jeffries, M.D.
               4   by Mr. Goldwasser                                      4
                   by Mr. Albert                                         69
               5   by Mr. Maynard                                        72
               a
               7                      E X H I B I T S
                 DEPOSITION EXHIBITS                               IDENTIFIED
                Exhibits 1, 2-A and  2-B                                 18
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            I                         P R 0 C E.E D I N G S
            2  Whereupon,
            3                            MERVYN JEFFRIES
            4  was called as a witness and, having been first duly sworn,
            5  was examined and testified as follows:
            6                            EXAMINATION
            7             BY MR.  GOLDWASSER:
            S     0       What is your full name for the  record,  Doctor?
            9     A       Mervyn Jeffries.
          10      Q       You're a medical doctor?
          11      A       Yes.
          12      0       For the record, this is a  discovery  deposition
          13   taken pursuant to the Ohio rules of  civil  procedure,  the
          14   rule 26B-4B.
          15      Doctor, I have been handed a copy of your curriculum
          16   vitae, and I ask you to take a brief look at  it  and  tell
          17   me if it is current.
          18      A       Yes.
          19      0       There are three publications listed at the
          20   bottom of  the second page.  Is that the extent of your
          21   publications to date?
          22      A       Yes.
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