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, P.A., 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

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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
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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
2