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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. 13 TUESDAY, OC-20BER 31, 1989 14 15 Deposition of Donald Seymour, M.D., a 16 witness callea for examination by the Plaintiffs 17 under the Ohio Rules of Civil Procedure, taken 18 Defore me, Richard G. DelMonico, a Professional 19 Reporter and Notary Public within and ror the 20 State of Ohio, pursuant to notice, at 6681 21 Ridge Roaa, Parma, Ohio, commencing at 22 12:15 p.m. the day and date above set forth. 23 24 - - - 25 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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
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