COPY

I STATE OF OHIO,
2 COUNTY OF CUYAHOGA.
3 IN THE COURT OF COMMON PLEAS
4 - - - - - - - - - - - - - -X
5 WILLIAM M. CRASI, etc.,
6 Plaintiff,
7 vs. Case No. 252,160
8 PARMA COMMUNITY GENERAL Judge Burt Griffin
9 HOSPITAL, et al.,
10 Defendants.
11 - - - - - - - - - - - - - -X
12 Durham, North Carolina
13 Thursday, September 7, 1995
14 Deposition of DR. DAVID FREEMAN PAULSON,
15 a witness herein, called for examination by
16 counsel for Defendant Dr. Coseriu, in the
17 above-entitled matter, pursuant to agreement, the
18 witness being duly sworn by SARA A. ROOTH-BURKETT,
19 a Notary Public in and for the State of North
20 Carolina, taken at Duke University Medical Center,
21 Hospital South, Division of Urology, Room 1573,
22 Durham, North Carolina, at 2:12 p.m., on Thursday,
23 September 7, 1995, and the proceedings being taken
24 down by Stenotype by SARA A. ROOTH-BURKETT, and
25 transcribed under her direction.

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2

I APPEARANCES:

2 On behalf of the Plaintiff:

3 RICHARD J. BERRIS, ESQ.

4 Weisman, Goldberg & Weisman Co., L.P.A.

5 1600 Midland Building

6 Landmark Office Towers

7 Cleveland, Ohio 44115

8 (216) 781-6747

9

10 On behalf of the Defendant Dr. Coseriu:

11 LESLIE J. SPISAK, ESQ.

12 Reminger & Reminger Co., L.P.A.

13 The 113 Building

14 Cleveland, Ohio 44114-1273

15 (216) 687-1311

16

17 on behalf of the Defendant Parma Community

18 General Hospital:

19 JOHN W. JEFFERS, ESQ.

20 Weston, Hurd, Fallon, Paisley & Howley

21 2500 Terminal Tower

22 50 Public Square

23 Cleveland, Ohio 44113-2241

24 (216) 241-6602

2 5



BRYANT COURT REPORTING SERVICES, INC.
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C 0 N T E N T S

2 THE WITNESS EXAMINATION BY COUNSEL FOR

3 DR. DAVID F. PAULSON PLAINTIFF DEFENDANTS

4 By Mr. Spisak  5

5 By Mr. Jeffers 113

6

7 E X H I B I T S

8 PAULSON DEPOSITION EXHIBIT NO. FOR IDENTIFICATION

9 1 150

10 2 150

11 3 113

12 4-A 113

13 4-B 113

14 5 130

15 6 130

16 7 130

17 8 130

18 9 130

1 9

2 0

21

2 2

2 3

2 4

25




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4

1 S T I P U L A T I 0 N S

2

3 It was stipulated by and between counsel

4 representing the respective parties, and the

5 witness, as follows:

6

7 1. That the signature of the witness

8 to the deposition is hereby waived.

9

10 2. That the Ohio Rules of Civil

11 Procedure shall control concerning the use of the

12 deposition in court.

13

14

15

16

17

is

19

20

21

2 2

2 3

2 4

2 5



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5

P R 0 C E E D I N G S

2 Whereupon,

3 DR. DAVID FREEMAN PAULSON,

4 business address at Duke University Medical

5 Center, Hospital South, Division of Urology, White

6 Zone, Room 1573, Box 2977, Durham, North Carolina

7 27710, (919) 684-5057, was called as a witness by

8 counsel for Defendant Dr. Coseriu, and, having

9 been duly sworn by the Notary Public, was examined

10 and testified as follows:

11 EXAMINATION BY COUNSEL FOR DEFENDANT DR.  COSERIU

12 BY MR.  SPISAK:

13 Q. Good afternoon. Would you state your

14 name, please.

15 A. David Freeman Paulson.

16 Q. All right. Dr. Paulson, my name is

17 Spisak.  We met just a moment or two ago.  I am

18 here today on behalf of my client, Dr. Coseriu,

19 and we are here because you have been identified

20 as an expert who will testify on behalf of the

21 plaintiffs in this case. All right?

22 Now, under our Ohio Rules, I am entitled

23 to take a deposition such as this, the purpose of

24 which is to have, hopefully, a free and open

25 exchange, find out what your opinions are, and the




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6

1 basis of your opinions. Okay?

2 A. I understand.

3 Q. All right. Give us your professional

4 address, please.

5 A. Box 2977, Duke Hospital, Durham, North

6 Carolina, area 27710.

7 Q. All right. And that is the Duke

8 University Medical Center, or at least a portion

9 of it, correct?

10 A. That's correct.

11 Q. All right. And are you -- you are

12 employed by the Duke University Medical Center?

13 The Duke University? What is it?

14 A. I am employed by the University as a

15 member of the faculty, and I have an appointment

16 at the Medical Center, and I am paid by the

17 partnership.

18 Q. Okay. Are you a salaried employee

19 within that context?

20 A. I am a salaried employee by the

21 University, and we are essentially in private