SS:
2 County of Cuyahoga,

13 IN THE COURT OF COMON PLEAS

4 Christ Glaros, etc, 401 M '77

5 S 2,-
Plaintiffs,

6 -vs- No 893,790

7 Cleveland Clinic Foundation,
et al,

Defendants


10
Deposition of DR  EDUARD EICHNER, called as a witness
11 I
by the Defendants, pursuant to the provisions of Rule 26-B-
12
4(b) of the Ohio Rules of Civil Procedure, taken before
13
Norman Stern, a Notary Public within and for the State of
14
Ohio, at the offices of Dr Eduard Eichner, Severance
15

16 Medical Center, Cleveland Heights, Ohio, on Thursday, the

17 6th day of December, 1973, at 5:55 pm, pursuant to

agreement of counsel
18


APPEARANCES:
2(
Mr Fred We isman,

On behalf of the Plaintiffs
9@

23 Arter and Hadden, by
Mr David G Davies,
24
On behalf of the Defendants
25

I DR  EDUARD EICHNER 2
2 of lawful age, called as a witness by the Defendants, being
3 by me first duly sworn, as hereinafter certified, deposed
4 and said as follows:
5 MRDAVIES: May the record state
6 that this deposition is being taken of the
7 witness under the provisions of Rule 26-B-4(b)
8 of the Ohio Rules of Civil Procedure, Dr Eduard
9 Eichner having been identified as an expert
10 witness who will testify at the trial of this
11 matter
12 Dr  ELchajor, what this -Ann is that I
13 will ask you questions I am limited by the
1 4 Rule to asking you questions that will discover
15 your opinions and the grounds for those opinions
16 AhLah-@ AM mdm hAua crlupn f-hpm en Mr We isman or
17 as you will testify on direct examination I am
28 not allowed, as I understand the Rule, to
1!1 cross examine you
20 1 particularly ask that if you are having
21 difficulty understanding my questions -- and
22 this is quite possible in a very fechntcal case
that you will free to interrupt me or to ask
24 me for clarification, and I will try to clarif
25 the questions
I DR  EDUARD EICHNER 2
2 of lawful age, called as a witness by the Defendants, being
3 by me first duly sworn, as hereinafter certified, deposed
4 and said as follows:
5 MRDAVIES: May the record state
6 that this deposition is being taken of the
7 witness under the provisions of Rule 26-B-4(b)
8 of the Ohio Rules of Civil Procedure, Dr Eduard
9 Richner having been identified as an expert
W witness who will testify at the trial of this
11 matter
12 Dr Hichner, what this neana is that I
13 will ask you questions I am limited by the
14 Rule to asking you questions that will discover
15 your opinions and the grounds for those opinions
16 0""AL-AAL Mau have given them to Mr Weisman or
17 as you will testify on direct examination I am
18 not allowed as I understand the Rule, to
cross examine you
20 T particularly ask that if you are having
21 difficulty understanding my questions -- and
22 this is quite possible in a very @eechntcal came
that you will free to interrupt me or to ask
24 me for clarification, and I will try to clarify
25 the questions
I DR EDUARD EICHNER 2
2 of lawful age, called as a witness by the Defendants, being
3 by me first duly sworn, as hereinafter certified, deposed
4 and said as follows:
5 MR  DAV IE S: May the record state
6 that this deposition is being taken of the
7 witness under the provisions of Rule 26-B-4(b)
8
of the Ohio Rules of Civil Procedure, Dr Eduard
Eichner having been identified as an expert
10 witness who will testify at the trial of this
11 matter
1 2 Dr Richaer, WLat this means is that I
13 will ask you questions I am limited by the
14 Rule to asking you questions that will discover
15 your opinions and the grounds for those opinions
-4 AU Mn2j have eiv,en them to Yx  Weisman or
as you will testify on direct examination  I am
18 not allowed, as I understand the Rule, to
1@@ cross examine you
20 1 particularly ask that if you are having
difficulty understanding my questions -- and
y
this is quite possible in a ver bechnical case
2:11 -- that you will free to interrupt me Or to ask
2 4 me forclarification, and I will try to clarify
25
the questions

I As I believe you know, I am David Davies,
2 and I am an attorney for the Cleveland Clinic
9 Fo undation, Dr Krieger, Dr Weakley, Dr
4 McHenry and several of the residents who are
5 named as Defendants
6
7 EXAMINATION
8 BY MR DAVIES:
9 Q Your name for the record is what, sir?
10 A Eduard Eichner
11 Q And you are a practicing physician, I believe?
12 A Yes, sir
Q Specializing in?
14 A Obstetrics and gynecology
15 Q What is the general nature of your practice at the
present time, doctor?
IT A All gynecology I have given up obstetrics
11; Q This would include I take it, performance of abdomi-
iq nal hysterectomies?
2( A Yes
21 Q At what hospitals do you practice?
22 A Mt Sinai only
2@ Q Have