I-N THE COURT OF COMMON PLEAS

      2                   CUYAHOGA   COUNTY, OHIO

      3
          Willie Ann Steele, parent and    )
      4   guardian of Sunseria Steele,     )
                                           )
      5                   Plaintiffs,      )
                                           ) Case No. 935,703
      6         -vs-                       )
                                           )
      7   Salvation  Army, Incorporated,   )
          et al.,                          )
      8                                    )
                          Defendants.      )
      9

      10                          - - - -

      11
                          Deposition of  DR.  ARUII  JAYAVANT,
      12
                taken under cross-examination before William
      13
                J. Mahan,  Certified  Shorthand  Reporter  and
      14
                Notary Public within and for the State of
      15
                Ohio, at the offices of Weisman, Goldberg
      IG
                  Weisman,  540  Leader  Building,  Cleveland,
      17
                Ohio, at approximately 10:45 A.M., Thursday,
      18
                November 21, 1974, pursuant to notice and
      19                      -
                stipulations  of counsel,  by  the  plaintiffs
      20
                in this cause.
      21

      22



      24

      25

                APPEARANCES:                                           2

     2             Mr. Fred Weisman,
                   Weisman, Goldberg & Weisman,
     3
                          On behalf of the Plaintiffs;
     4
                   Mr. Michael R. Gallagher, and
     6             Mr. Gregory  G.  Baran,
                   Hauxhurst,  Sharp,  Mollison  &  Gallagher,
     6
                          On  behalf  of  Defendant  Salvation
     7                        Army;

     8             Mr. Robert C. Maynard,
                   Squire, Sanders & Dempsey,
     9
                          On behalf  of  Defendant  Huron  Road
    10                        Hospital;

    11             Mr. Harley  J.  McNeal,
                   McNeal, Schick, Archibald & Carlson,
    12
                          On behalf  of  Defendant  Felino  P.
    13                        Reyes,  M.D.

    14

    15                            - - -  -

    16

    17                    DR.  ARUN  JAYAVANT,  of  lawful  age,

    18             called by the  plaintiffs  for  the  purpose

    19             of cross-examination,  as  provided  by  the

    20             Ohio Rules of  Civil  Procedure,  being  by

    21             me first duly sworn, as hereiiiakrer

    22             certified, deposed  and  said  as  follows:

    2',@

    24             CROSL;-EXAMINATION OF DR.  ARUN JAYAVANT

    2,j   BY MR.   WEISMAN:

                                                                  3
     1     (.2 tiould you state your name, sir, and your

     2         residence address?

     3     A   My first name is Arun, A-r-u-n.  My last name

     4         is Jayavanr-, J-a-y-a-v-a-n-t.

     5           My address is 5135 Ridgebury Boulevard,

     6         Lyndhurst, 44124.

     7     Q   I am going to ask, if you would, since  there

     8         are several people in the room, keep your voice

     9         up a bit so that everyone can hear you  well.

     10          iihat is your professional address, Doctor?

     11    A   3070 Mayfield Road, Cleveland Heights,  Ohio.

     12    Q   What is your profession, Doctor?

     13    A   Gynecologist and obstetrician.

     14    Q   Where did you attend medical school?


     15    A   Bombay, India.


     16    Q   What year did you graduate from medical school


     17        in Bombay, India?


     18    A   I finished undergraduate in 1957, and graduation


     19        as an obstetkician and gynecologist in  1962.


     20    Q   Also in Bombay?


     21    A   Yes.


     22    Q   lahen did you come to the United States?


     2@.   A   I was in the United States on two  occasions.


     2el       One %.ias between July, 1964, through Tuixe, 1966.


     25    Q   ilas that postgraduate training?

    1     A    Right.
    2     Q    Where did that take place?
    3     A    I spent my first year at St.  John's  Hospital
    4          on Detroit Avenue in Cleveland.
    5             And the next year, Juiy, 1965, through
    6          June, 1966, at Huron Road.
    7                    MR. WEISMAN:         off the  record.
    8                     (Discussion had off the record.)
    9     Q    Did you have any other  postgraduate  training,
    10         Doctor, other than St. John's Hospital and
    11         Huron Road Hospital?
    12    A    Postgraduate training in I