I 1 70-?,05-
2 THE STATE OF OHIO, 40
S S
3 COUNTY OF CUYAHOGA.)

4
IN THE COURT OF COMMON PLEAS
5
HOLLY HULT, et al.,

7  Plaintirfs,

8 Vs . Case No. 156,117

9 CLEVELAND METROPOLITAN
GENERAL HOSPITAL, et al.,
10
 Defenuants.
11

12
DEPOSITION OF DONALD SEYMOUR, M.D.
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TUESDAY, OC-20BER 31, 1989
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Deposition of Donald Seymour, M.D., a
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witness callea for examination by the Plaintiffs
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under the Ohio Rules of Civil Procedure, taken
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Defore me, Richard G. DelMonico, a Professional
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Reporter and Notary Public within and ror the
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State of Ohio, pursuant to notice, at 6681
21
Ridge Roaa, Parma, Ohio, commencing at
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12:15 p.m. the day and date above set forth.
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24 - - -

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2


2 APPEARANCES

3 On behalf of the Plaintirts:

4 PAUL KAUFMAN, ESQ.
Weisman, Golduerg, Weisman & Kaufman
5 540 Leader Building
Cleveland, Ohio 44114
6

7 On behalf of the Defendants:

8 FRANK AVENI, ESQ.
Reminger & Reminger
9 113 St. Clair Avenue
Cleveland, Ohio 44114
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3
1 IIIR . KAU FM AN Put on the wr itten


2 record that we are here at the of f ice


3 Of Donald E. Seymour at 6681 Ridge


4 Road, Parma, Ohio. That it is Octooe r


5 31st, 1989.  We are here for the


6 purpose of taking the testimony oi Dr.


7 Seymour for preservation and use at the


8 trial of the within captioned matter.


9 That the deposition


10 testimony is being taken by agreement


11 with Dr . Seymour ana by notice that has


12 been issued to defense counsel An a


1 3 counsel representing the defenaant,


14 Clevelancl Metropolitan General


15 Hospital, is present ana there should


16 De a waiver as to any other possible


17 defects in notice or service.


18 Do we agree?


19 14R . AV ENI Th at I s co r rect .


2 U


2 1 DONALD A. SEYMOUR, M.D.


22 of lawtul age, called as a witness by the Plaintiff


23 pursuant to the Ohio Rules of Civil Procedure,


24 being by me first duly sworn, as hereinafter


25 certifieu, deposed and said as follows:

4
1 DIRECT EXAMINATION

2 BY MR. KAUFMAN:

3 Q. Would you tell this court and jury your

4 full name, please?

5 A. Donald E. Seymour.

6 Q. And what is your occupation or profession?

7 A. Physician.

8 Q. Dr. Seymour , what is your professional or

9 K)usiness address, please?

10 A. 6681 Ridge Road.

11 Q. And that is located in the community of?

12 A. Parma, Ohio .

13 Q. And are we presently located at your

14 of f ice?

15 A. We are.

1 6 Q - Dr . Seymo ur , how many yea rS have yo u be en

1 7 in the practice of medicine, sir?

18 A. 2 8.

19 Q. Ana at tne present time are you affiliated

20 with any other pnysicians in your private

21 pr actice ?

22 A. No.

2 3 Q - Ana nave you similarly been engaged in

24 private practice for the 28 years?

25 A. Yes.

5
1 Q Ana has that oeen as a sole practitioner


2 the entire time?


3 A. That has been.


4 Q. Dr. Seymour, what is your area of practice


5 or your specialty as such?


6 A. General internal medicine.


7 Q. Ana it you wouldn't mind going a little bit


8 into your background ana training, if you would,


9 tell our jury where you attenued medical school,


10 sir?


11 A. Western Reserve, Case Western Reserve now.


12 Q. And in what year did you obtain your MD


13 degree from Case?


14 A. 1 9 5 5 .


15 Q. Atter you obtained your MD degree aid you


16 pursue some further studies?


17 A. Y e s .I was an intern at St. Luke's


18 Hospital in Cleveland and then a resident at the


19 Henry Ford Hospital in Detroit for one year. I


2U went to the military service for two years, and


21 then was a resident at the Cryle VA Hospital and


22 University Hospitals tor two or three more years.


23 Q. In what area did you do your residency


24 training?


25 A. Again in internai medicine.

6
1 Q When you were in the military were you

2 tnere in the capacity as a physician?

3 A. Yes.

4 Q. And did you receive an honorable discharge

5 from the military?

6 A. Yes.

7 Q. What branch of the military was that, sir?

8 A. Air Force.

9 Q. Atter you completed your residency at

10 University Hospitals, what did you do then?

11 A. It was actually, I think, a VA hospital

12 program rather than a University Hospital

13 program. We spent time at both institutions buc

14 it was predominantly the VA hospital program.

15 Q. Ana after you completed that residency

16 training what did you do?

17 A. Startea practice in Parma in internal

18 medicine .

19 Q - Ana that would have been in what year then,

20 si r?

21 A . 1 9 6