IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
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JUDITH A. SARNOVSKY, ET AL.,
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PLAINTIFFS,
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VS. CASE NO. 85CV-02-905
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SNYDER, EVANS & ANDERSON, INC., ET AL.
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DEFENDANTS.
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11 DEPOSITION

12 OF DR. GERALD M. PENN, THE WITNESS HEREIN, CALLED BY

13 THE DEFENDANT UNDER THE APPLICABLE RULES OF CIVIL

14 PROCEDURE, TAKEN BEFORE ME, ANITA SAINE, A NOTARY

15 PUBLIC IN AND FOR THE STATE OF OHIO, AT THE OFFICES

16 OF DR. GERALD M. PENN, GRANT MEDICAL CENTER,

17 COLUMBUS, OHIO, ON THURSDAY, SEPTEMBER 20, AT 1:00,

18 P.M.

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21 PROFESSIONAL REPORTERS, INC.
145 NORTH HIGH STREET
22 COLUMBUS, OHIO 43215
PHONE 614/464-0675
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1 APPEARANCES:

2 MESSRS. WEISMAN, GOLDBERG,
WEISMAN & KAUFMANN CO., L.P.A.
3 BY MR. PAUL M. KAUFMAN
1600 MIDLAND BUILDING
4 LANDMARK OFFICE TOWERS
CLEVELAND, OHIO 44115
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ON BEHALF OF THE PLAINTIFF.
6
MR. DANIEL R. FREYTAG
7 ATTORNEY AT LAW
TEN WEST LOCUST STREET
P.O. BOX 486
NEWARK, OHIO 43055
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ON BEHALF OF THE DEFENDANTS.
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SEPTEMBER 20
THURSDAY AFTERNOON SESSION
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3 STIPULATIONS

4 IT IS STIPULATED BY AND BETWEEN COUNSEL FOR

5 THE RESPECTIVE PARTIES THAT THE DEPOSITION OF DR.

6 GERALD M. PENN, THE WITNESS HEREIN, CALLED BY THE

7 DEFENDANT UNDER THE APPLICABLE RULES OF CIVIL

a PROCEDURE, MAY BE TAKEN AT THIS TIME BY THE NOTARY;

9 THAT SAID DEPOSITION MAY BE REDUCED TO WRITING IN

10 STENOTYPY BY THE NOTARY, WHOSE NOTES THEREAFTER MAY

11 BE TRANSCRIBED OUT OF THE PRESENCE OF THE WITNESS;

12 AND THAT THE PROOF OF THE OFFICIAL CHARACTER AND

13 QUALIFICATION OF THE NOTARY IS WAIVED; THAT THE

14 READING AND SIGNATURE OF THE SAID WITNESS TO THE

15 TRANSCRIPT OF THE DEPOSITION ARE EXPRESSLY WAIVED BY

16 COUNSEL AND THE WITNESS; SAID DEPOSITION TO HAVE THE

17 SAME FORCE AND EFFECT AS THOUGH SIGNED BY THE SAID

18 WITNESS.

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2 INDEX OF EXAMINATION
3 BY MR.  FREYTAG --PAGE 5, 53
4 BY MR. KAUFMAN --PAGE 41, 56
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6
7 INDEX OF EXHIBITS
a
9 EXHIBIT NO. 1: DOCUMENT ENTITLED,
10 REPORT OF PATHOLOGIST --PAGE 16
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12 EXHIBIT NO. 2: A BLOCK OF
13 PARAFIN IMBEDDED TISSUE --PAGE 21
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15 EXHIBIT NO. 3: A SLIDE --PAGE 23
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1 GERALD M. PENN
2 BEING BY ME FIRST DULY SWORN, AS HEREINAFTER
3 CE