Statft of Ohio, 1-7 (D ICA

SS:
2 County of Cuyahoga )

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4 IN THE COURT OF COMMON PLEAS

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6 LINDA DAMM, et al,

7 Plaintiffs,

8 Vs Case No 985,427

9
WILLIAM GTLGER, MD, et al,)
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Defendants
11

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Deposition of DR  LOUIS KEPPLER
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Friday, January 25, 1980
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Deposition of Dr Louis Keppler, called by the

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plaintiffs pursuant to the Ohio Rules of Civil Procedure

17 taken before me, Sidney Gantverg, Registered ProfessionaL

18
Reporter and Notary Public within and for the State of

19 Ohio, pursuant to notice, at the offices of WeismanF

20 Goldberg & Weisman, 540 Leader Building, Cleveland,

21 Ohio, beginning at 10 o'clock am, on the day and

22 date above set forth

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2@ APPEARANCES:


on behalf of the Plaintiffs:

3
Fred Weisman, Esq

4 James Goldberg, Esq

Weisman, Goldberg & Weisman

5 and

6 Lawrence Tucker, Esq

7 On behalf of the Defendant Parma Community General

8 Hospital:



9 Andrew Buckner, Esq

Weston, Hurd, Fallonr Paisley Howley

10 on behalf of the Defendant Dr Gilger:

ij Albert J Rhos, Esq

Rhoa, Fallen, Rawlin a Johnson
12

On behalf of the Defendant Dr Budd:
13

Ms Roberta Spurgeon, Esq
14 Squire, Sanders & Dempsey


15 On behalf of the witness Dr Keppler:


16 Gary Goldwasser, Esq

Reminger Reminger

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3

DR LOUIS KEPPLER
2
a witness called by the plaintiffs, pursuant to the

Ohio Rules of Civil Procedure, having been first duly
4@
sworn, as hersina fter certified, was examined and

deposed an follows:

EXAMINATION

BY MR  WEISMAN:

Q Give us your name, sir
9 A Louis Keppl*r

lo Q Your residence address?

A 5745 Edgehill Drive, Parma

Q Your professional address?
13 A 5500 Ridge Road
14@1 Q Doctor, you are a Board certified pediatrician,
15 are you not?
16 A Yes

17 Q Where did you attend medical school?

18 A St Louis University

19 0 When were you Board certified?

20 A March, 1958

21 Q When did you graduate from medical school?

22 A 1951

23 0 Just briefly, what was your postgraduate training?

24 A I went to St John's Hospital, Cleveland, Ohio,

2o for internship, that was 151-52;'52 to'54, I was at

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Milwaukee Childrens Hospital
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Q Then from there?
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A I went into private practice

Q What hospital did you become affiliated with
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after you went into private practice, what hospital

or hospitals?
7
A The hospitalowere St John's, Deaconess, Fairview,

Metropolitan General  I think I was on the courtesy

91 staff of Berea  I aiR not sure
10
What about Parma?

A Parma wasn't in existence then

12
0 When did you become affiliated with Parma?

13 A I was one of the founding fathers I don't know

14 when it opened It was in the '6019, I think

15
Does anybody know?

16 Q Would it be fair to say that, generally speaking,

17@ the standards of practice at the hospitals that you have


11 mentioned are all essentially the same in the pediatric

11 field, I am talking about standards?

20 MR BUCKNER: Excuse me,OI have to

21 object and ask a question Are you talking about

22 some promulgated, published standards?

231@@ MR WEISMAN: No, standards of practice

24 MR BUCKNER: Just general standards?

25 BY MR WEISMAN:

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What is understood to be good practice at Fairview
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Hospital, let us say, or Deaconess Hospital, would be
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good practice at Parma Community General Hospital, would
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you agree with that?
5
A When I started in practice, Parma Hospital wasn't
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in existence
7
0 1 am talking as of 1964 we are particularly

focusing on the time of birth of baby Linda Damn in
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this lawsuit, and let us say 1964 and for years before,
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during that time, were the standards essentially the
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same at all the hospitals, standards and practice?
12
A I would may no
13 Q How were they different, Doctor?
14 A Metropolitan General Hospital had a full time
15 house staff, a full time faculty, and the other hospitals
16 did not
17 Q Are you telling us that they practiced a higher
18 standard of care at that hospital, then, because they

19@ had --
20 A I am not saying they practiced a higher standard

21 Q Were the standards essentially the same, Doctor,

22, at Cleveland Metropolitan General, St John's, Deaconess,

23 Parma Community, Berea Hospital, on and for the years

24 before 1964, that you are familiar with?

25 A I am not in a position to measure their standards

of care
2
Q You are not familiar