1                        IN THE COURT OF COMMON PLEAS

       2                           HAMILTON COUNTY, OHIO      )7o 19 7
       3   WENDY MICHELLE DRAPER,
           a minor, by and through                                 7
       4   her father and next friend,
           Larry E. D@ aper,
       5         and
           LARRY E. DRAPER
       6        and
           SHARON D. DRAPER,
       7
                          Plaintiffs,                 A-754024
       8
                 VS.
       9
           BETHESDA HospiTAL @d
      10   DEACONESS ASSOCIATION
                 and
      11   JOHN A. BRUNSMASI

      12                  Defendapts.

      1 3

      1 4
      15             Deposition of CLAAK P. SEARLE, M.D., defendant Bruns-
      16   man's witness herein, taken by plaintiffs as on direct examina-
      17   tion, pursuanj; to the Ohio Rules of Civil Procedure and pursuant
      18   to agreement between counsel as to time and plave and atipula-
      19   tions hereinafter set forth, at the offices of Rendigs, Pry, Kiel(
      20   & Dennis, 900 Central Trust Tower, Cincinnati, Ohio, between the
      21   hours of 10:30 a.m. and 1:20 p.m., Friday, September 15, 1978,
      22   before Adeline M. Womack, a notary public within and for the
      23   Statp gf Ohio.
      24
      25
                                                                           2


       I        APPEARANCES:

       2              On  behalf of Plaintiffs:

       3                  FRED WEISMAN, ESQ.
                          Weisman, Goldberg & Weisman
       4                  540 Leader Building
                          Cleveland, Ohio  44114
       5
                      On  behalf of Defendants, Bethesda Hospital and
       6                  Deaconess Association:

       7                  BRUCE B. McINTOSH,  ESQ.
                          3312 Carew Tower
       8                  Cincinnati,  Ohio  45202

       9              On  behalf of Defendant, John A. Brunsman:

       10                 D. MARC ROUTT, ESQ.
                          Rendigs, Fry, Kiely & Dennis
       11                 900 Central Trust  Tower
                          Cincinnati,  Ohio  45202
       12

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

       14             It is stipulated by and between counsel for the

       15  respective parties that the deposition of CLARK P. SEARLE, M.D.,

       16  defendant Brunsman's witness herein, may be taken  at  this  time

       17  as on direct examination for purposes of discovery, pursuant to

       18  the Ohio Rules of Civil Procedure, all  other  legal  formalities

       19  being waived by agreement; that the deposition may  be  taken  in

       20  stenotypy by the notary public and transcribed by her out of the

       21  presence of the witness; that the transcribed  deposition  is  to

       22  be submitted to the witness for his  examination  and  signature.

       23

       24

       25

                                                                         3
       1               MR. WEISMAN:  A discovery deposition  being taken
       2         pursuant to agreement between counsel for the respective
       3         parties.  And there is a waiver with respect to any
       4         defects in connection therefor with service or notice.
       5               Is that agreeable?
       6               MR. ROUTT:  Yes.
       7               MR. McINTOSH:  Yes.

       8                         CLARK P. SEARLE, M.D.


       9   of lawful age, being first duly sworn, was examined and deposed


      10   as   follows:



      11                          DIRECT EXAMINATION


      12   BY MR.  WEISMAN:



      13         Q     Would you please give us your name, sir?


      14         A     Clark P. Searle, M.D.



      15         Q     And what is your age, Doctor?


                 A     69.
      16


      17         Q     Your address, please?


                 A     Business or resident?
      18


      19         Q     Give us both addresses.



      20         A     3113 Burns Avenue, residence.


                       305 Crescent.
      21


      22               Both in Wyoming.



      23         Q     All right.  And is that Crescent Avenue address what has



      24   been  referred to in this lawsuit as the Wyoming Medical Center?


                 A     Yes; it is.
      25

                                                                      4
       1         Q    And are you the senior physician at the Wyoming
       2   Medical Center?
       3         A    I am the oldest person there.
       4         Q    Did you establish the Wyoming medical Center Group?
       5         A    Yes.
       6         Q    And would you te