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

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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.
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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
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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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2 APPEARANCES

3 On behalf of the Plaintirts:

4 PAUL KAUFMAN, ESQ.
Weisman, Golduerg, Weisman & Kaufman
5 540 Leader Building
Cleveland, Ohio 44114
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7 On behalf of the Defendants:

8 FRANK AVENI, ESQ.
Reminger & Reminger
9 113 St. Clair Avenue
Cleveland, Ohio 44114
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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:

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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?