STATE OF NORTH CAROLINA 1N THE GENERAL COURT O@ JUSTICE
SUPERIOR COURT DIVISION
COUNTY OF WAKE 83 CVS 336
7c) IL, -7

JENNIFER LOVE CAMPBELL, by
and through her Guardian ad
Litem, DUNCAN A MCMILLAN, 0 S I T I 0 N
MARGARET 0 CAMPBELL, and
JEFFREY L CAMPBELL, 0 F
 Plaintiffs; --

-v- M A R S\H A L L

L ri -@h9
ROBERT G DEYTON, JR,
GREENVILLE OBSTETRICS AND
GYNECOLOGY, PA, and PITT
COUNTY MEMORIAL HOSPITAL, INC,
 Defendants
-------------------------------- 6D


A@i P E A R A N C E S

For the Plaintiffs: Mr John R Edwards
Mr Burton Craige
Tharrington, Smith and Hargrove
P 0 Box 1151
Raleigh, North Carolina 27602

For the Defendants:
(Dr  Deyton) Mr James D Blount, Jr
Smith, Anderson, Blount, Dorsett,
Mitchell and Jernigan
P 0 Box 12807
Raleigh, North Carolina 27605

(Pitt Co Memorial) Ms Alene M Mercer
Patterson, Dilthey, Clay, Cranfill,
Sumner and Hartzog
P 0 Box 310
Raleigh, North Carolina 27602

In Chester, PA Reported by:
February 22, 1985 Kathryn M Anderson

PACE
REPORTING CRY
IM50SERVICE

POST OFFICE BOX 252 CARY, NORTH CAROLINA 27511 TELEPHONE: (919) 469-0199

Klavan -i-
2 E X A M I N A T I 0 N I N D E X
3 Examination By Whom Page Number
4 Direct Blount  4
5 Further Direct Mercer  65
6 Cross Edwards  106
7 Redirect Blount  110
8
9
to
71
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1 Klavan  -2-
2 S T I P U L A T I 0 N S
3 It is hereby stipulated and agreed between the
4 parties to this action, through their respective counsel
5 of record:
6 (1) That the deposition of DR  MARSHALL KLAVAN
7 may be taken on February 22, 1985, beginning at 2:00 P M,
8 in the Crozer-Chester Medical Center, located in Chester,
9 Pennsylvania, before Kathryn M Anderson, a Notary Public
10 (2) That the deposition shall be taken and used
11 as permitted by the applicable North Carolina Rules of
12 Civil Procedure
13 (3) That any objections of any party hereto as
14 to notice of the taking of said deposition or as to the
15 time or place thereof, or as to the competency of the
16 person before whom the same shall be taken, are deemed
17 to have been met
18 (4) objections to questions and motions to strike
19 answers need not be made during the taking of this deposition,
20 but may be made for the first time during the progress of
21 the trial of this case, or at any pretrial hearing held
22 before any judge of competent jurisdiction for the purpose
23 of ruling thereon, or at any other hearing of said case
24 at which said deposition might be used, except that an
25 objection as to the form of a question must be made at
1 Klavan -3-
2 the time such question is asked, or objection is waived
3 as to the form of the question
4 (5) That the witness reserves the right to read
5 and sign the deposition prior to filing
6 (6) That the sealed original transcript of this
7 deposition shall be mailed first-class postage or hand-
8 delivered to the party taking the deposition for preservation
9 and delivery to the Court, if and when necessary
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19 Whereupon,
20
21 DR  MARSHALL KLAVAN,
22 having been first duly sworn,
23 was examined and testified
24 as follows:
25
I Klavan Direct -4 -
2 DIRECT EXAMINATION BY MR BLOUNT:
3 Dr Klavan, my name is Jim Blount from Raleigh
4 And in the case that we're here about today, our
5 firm represents Dr Robert G Deyton, Jr, who is
6 one of the named Defendants I believe you and
7 I have just been introduced a few mintutes ago
8 for the first time
9 A That's correct, sir
10 Q Dr Klavan, when did you first hear about this
11 case?
12 A The last week in January
13 Q And how did you hear about it?
14 A I was called by telephone
15 Q By whom?
16 A By Mr Craige
QL All right And had you ever done any work with
17
18 or heard of that firm before that telephone call?
A No, sir
19
20 Q Do you know how that firm got your name as a
21 prospective expert witness?
22 A I do not
23 QL Have you ever had occasion to review records in
24 a medical malpractice case before this one?
25 A Yes, sir








7-@ - T
I Klavan Direct  -5-
2 Have you ever testified in medical malpractice
3 cases before this deposition today?
4 A Yes, sir
5 QL Approximately, how many times have you actually
6 given testimony at a deposition at this point?
7 A I'd have to give you a guesstimate I have been
8 providing testimony, both on behalf of plaintiffs
9 and on behalf of health care providers, extending
10 back to about 1970
11 In terms of numbers, if we're talking about
12 depositions, I'd have to give you a pure guess-
13 timate of more than a hundred and less than two
14 hundred over that period of time
15 And how many times would you have actually testified
16 in court, approximately?
17 A Ag