-7o k(ALA

I State of Ohio,
 SS:
2 County of Lake.

3 - - -

4 IN THE COURT OF COMMON PLEAS

5 - - -

6 Victor Bukky, Admr. of the
Estate of Victoria L. Bukky,
7
Plaintiff,
)Case No. 90 CV 001435
VS.
9 )Judge Parks
Lake Hospital System, et al.,
10
Defendants.
11

12

13 DEPOSITION OF KEITH A. KERSTEN, D.O.

14 THURSDAY, DECEMBER 17, 1992

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16 The deposition of Keith A. Kersten, D.O., a witness

17 herein, called by the Defendant for examination

18 under the Ohio Rules of Civil Procedure, taken

19 before me, Ivy J. Gantverg, Registered Professional

20 Reporter and Notary Public in and for the State of

21 Ohio, by agreement of counsel and without further

22 notice or other legal formalities, at 50 Normandy

23 Drive, Painesville, Ohio, commencing at 4:10 p.m.,

24 on the day and date above set forth.

25




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1 APPEARANCES:

2 on behalf of the Plaintiff:

3 Jeffrey Haines, Esq.
Weisman, Goldberg & Weisman
4 1600 Midland Building
Cleveland, Ohio 44115
5
on behalf of Defendant Efren Glorioso, M.D.:
6
David Sumner, Esq.
7 Jacobson, Maynard, Tuschman & Kalur
1001 Lakeside Avenue - Suite 1600
8 Cleveland, Ohio 44114

9 on behalf of Keith A. Kersten, D.O.:

10 James Grove, Esq.
Arter & Hadden
11 1100 Huntington Building
Cleveland, Ohio 44115
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1 (Thereupon, Defendant's Exhibits I and
2 J were marked for identification.)
3 KEITH A. KERSTEN, D.O.
4 a witness herein, called by the defendant for
5 examination under the Rules, having been first duly
6 sworn, as hereinafter certified, was deposed and
7 said as follows:
8 DIRECT EXAMINATION
9 BY MR. SUMNER:
10 Q. State your full name, please?
11 A. It is Keith A. Kersten, middle name is Alan.
12 Q. And what is your profession, sir?
13 A. Doctor of osteopathic medicine.
14 Q. What specialty do you practice within?
is A. Family practice.
16 Q. What kind of practice do you have in
17 Painesville, Ohio now?
18 A. Private practice involved in a
19 multi-specialty clinic, and on staff at Lake East
20 Hospital in Painesville in their family practice
21 department.
22 Q. Dr.  Kersten, have you ever had an opportunity
23 to treat patients at Frank Sailors' office, which is
24 also referred to as the Center for Health and
25 Wellness?


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1 A. Yes.
2 Q. That is 2999 McMackin Road, Madison, Ohio?
3 A. Yes.
4 Q. Under what circumstances did you occasionally
5 see patients at Dr. Sailors, office?
6 A. I covered for Dr. Sailors when he needed time
7 out of the office, and also when he needed
8 additional coverage for patients.
9 Q. I have requested records from Dr. Sailors'
10 office pertaining to Victoria Bukky, any care or
11 treatment that she may have received at Dr. Sailors'
12 office, and Gloria Campbell, Dr. Sailors' office
13 manager, graciously produced several documents for
14 me.
15 I would like to show them to you, and ask you
16 whether you recognize what I have marked as
17 Defendant's Exhibit I?
18 A. Yes, this is a medical history and physical
19 exam form.
20 Q. Would you be able to tell from what has been
21 marked as Defendant's Exhibit I, Dr. Sailors' office
22 record of Victoria Bukky's visit, whether or not you
23 were involved in any care and treatment of Victoria
24 Bukky on October 23, 1989?
25 A. To my recollection, independently, I cannot


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1 say I remember the patient specifically, however,
2 this is my handwriting, and I do recognize that.
3 MR. GROVE: Just for the record, so
4 that the record is clear, this is a three
5 page document, and the last page -- the first
6 two pages are medical history -- the first
7 page is a medical history form, the second
8 page is a physical examination form, and the
9 last page is entitled, Easy to Take, Easy to
10 Tolerate.  PCE Erythromycin Particles in
11 Tablets.
12 BY MR. SUMNER:
13 Q. Based upon your review of Defendant's Exhibit
14 I, would it be a fair statement that you did chart
15 on Victoria Bukky on that particular date,
16 therefore, you were involved in her care and
17 treatment for that office visit by her?
18 A. Yes.
19 Q. Can you tell me whether or not, on that
20 particular day, a nurse by the name of Melissa
21 Palmer was working in the office, and also charted
22 on the patient for that visit?
23 A. I cannot.
24 Q. Can you look at the second page of the
25 Exhibit I?


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1 A. (Witness complies).
2 Q. Specifically where it documents that a
3 Bicillin injection is given, and maybe that would
4 refresh your recollection?
5 A. Yes, her signature is here.
6 Q. Based upon her signing that record, can you
7 tell me whether or not you believe