1 IN THE COURT OF COMMON PLEAS

2 CUYAHOGA COUNTY, OHIO

3 ERMA J COLELLO, ET AL,

4 Plaintiffs,
JUDGE McALLISTER
5 _vs- CASE NO 96118

6 EUCLID GENERAL HOSPITAL,
ET AL,
7
Defendants
8

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10 Deposition of MICHAEL NOCHOMOVITZ, MD, taken

11 as if upon cross-examination before Linda A

12 Astuto, a Registered Professional Reporter and

13 Notary Public within and for the State of Ohio,

14 at the offices of University Hospitals,

15 Abbington Road, Cleveland, Ohio, at 4:30 pm on

16 Friday, November 6, 1987, pursuant to notice

17 and/or stipulations of counsel, on behalf of the

18 Defendant, Euclid General Hospital, in this

1 9 cause

2 0 - - - -

2 1
MEHLER & HAGESTROM, INC
22 Registered Professional Reporters
650 Engineers Building
23 Cleveland, Ohio 44114
(216) 621-4984
2 4

2 5



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APPEARANCES:

2
Eric Kennedy, Esq
3 Weisman, Goldberg & Weisman Co, LPA
540 Leader Building
4 Cleveland, Ohio 44114
(216) 761-1111,
5
On behalf of the Plaintiffs;
6

7 John D Baker, Esq
Weston, Hurd, Fallon, Paisley & Howley
8 2500 Terminal Tower
Cleveland, Ohio 44113
9 (216) 241-6602,

10 On behalf of the Defendant
Euclid General Hospital;
1 1
William D Bonezzi, Esq
12 Jacobson, Maynard, Tuschman & Kalur
100 Erieview Plaza
13 Fourteenth Floor
Cleveland, Ohio 44114
14 (216) 621-5400,

15 on behalf of the Defendant
Kevin Lee, MD
1 6

1 7

1 8

1 9

2 0

2 1

2 2

2 3

2 4

2 5



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1 MICHAEL NOCHOMOVITZ, MD, of lawful age,
2 called by the Defendant for the purpose of
3 cross-examination, as provided by the Rules of
4 Civil Procedure, being by me first duly sworn,
5 as hereinafter certified, deposed and said as
6 follows :
7 CROSS-EXAMINATION OF MICHAEL NOCHOMOVITZ, MD
a BY MR BAKER:
9 Doctor, what is your full name?
10 A Michael Leon Nochomovitz
11 I have been handed here a resume, curriculum
12 vitae, pardon me, of you
13 I presume you had the opportunity to look
14 at it and it is current?
15 A Yes, it is current
16 And it is multiple pages containing all of your
17 publications and everything?
1 8 A  Yes 
19 Q Are you currently a United States citizen?
20 A  Yes 
21 Q How long have you been a citizen?
22 A Since, well, for the last five years
23 Q The two hospitals that you currently hold staff
24 privileges at are University Hospitals of
25 Cleveland and Veteran's Administration, Wade

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1 Park?
2 A Yes 
3 Q Any other hospitals?
4 A No
5 You are Board Certified in internal medicine and
6 in pulmonary medicine?
7 A Correct
8 Q You are not a surgeon?
9 A No, I am not a surgeon
10 Q Do you have a file on this matter?
11 A These are my bits and pieces
12 Fine May I see it, please? Thank you
13 Doctor, Mr Kennedy originally sent you
14 some records to review in this case I take it,
15 because from your letter of August 5, 1986, I am
16 sorry, July 31, 1986 that we have, you say you
17 have reviewed the hospital records of Mrs
18 Colello, is that correct?
19 A That is correct
20 Q Which hospital records did you review?
21 A At that stage I had reviewed the records from
22 Euclid General
23 Q Now I note in here this bound colored tabbed
24 chart of Euclid General Hospital, which 1
25 presume is the entire Euclid General Hospital

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1 record, I note it was sent to you on October 26,
2 1987, just about two weeks ago
3 Where are the other Euclid General records
4 that you reviewed back prior to July 31, 1986?
5 A Scattered all over the place You know, I have
6 got some at home, you know
7 Q Where is the --
8 A I may have even discarded some of them
9 Where is the facts statement that Mr Kennedy
10 provided you and that you referred to in your
11 July 31, 1986 report?
12 A Probably at home or some place
13 Q Would you please look for it tonight?
1 4 A  Sure
15 I have a feeling we may have to come back and
16 you can bring it with you
17 MR BAKER: Do you have it with
18 you, Mr Kennedy?
19 MR KENNEDY: I don't have the
20 doctor's file which is one of the things 1
21 haven't brought I probably have it
22 MR BAKER: I will consider the
23 deposition recessed and I think we are entitled
24 to that before the Doctor takes the stand in
25 this case

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1 MR KENNEDY: Fine I will get
2 that for you I am sure I have got it
3 I note also --
4 MR BAKER: Off the record
5 - - - -
6 (Thereupon, a discussion was had off
7 the record)

9 I also see a letter of August 5, 1986 here from
10 Dr Conomy
11 When did you receive that, of the Cleveland
12 Clinic Foundation?
13 A Awhile ago I don't recall