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, MD
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TUESDAY, OC-20BER 31, 1989
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Deposition of Donald Seymour, MD, 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 pm the day and date above set forth
23

24 - - -

25

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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
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, MD


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?

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

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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

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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