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IN HE COURT OF COMMON PLEAS

OF FRANKLIN COUNTY. OHIO ra

JODY BURRIS, et al,
 Plaintiffs

Vs 84CV-04-2125

RICHAR W. LAMPREChT,
M.D., et GI,
 Defandants




Oral deposition of MARSHALL KLAVAN, M.D.,

Witness. on behalf of the Plaintiffs, Pursuant to the Ohio

Rules of Civil Procedure, taken in the offices of Marshall

Klovan, M.D., Crozer-Chester Medical Center, Upland,

Chester, Pennsylvania, May 5th, 1987, commencing at or

about one o'clock p.m., Eastern Doylig@)t Saving Time,

before Robin Turk.  Registered Professional

Reporter-Commissioner.








Irving L. Starkman Associates
Registered Professional Reporters
1601 Walnut St., Suite 307
Philadelphia, Pa. 19103
Phone (215) 568-5313 7Y


 j

1 I-N-D-E-X
2
3 MARSHALL KLAVAN, M.D. PAGE
4 By Mr. Davis .................................. 3,103
5 By Mr. McKenzie .................................. 89
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Irving L. Starkman Associates
2




I APPEARANCES:

2 GORDON K. BOLON, ESQ.,
502 South Third Street,
3 Columbus, Ohio 43215-5763
Attorney for Plaintiff
4
JACOBSON, MAYNARD, TOSCHMAN
5 & KALUR CO, LPA
BY: WILLIAM A. DAVIS, ESQS.,
6 One Capitol South,
175 South Third Street, Suite 890,
7 Columbus, Ohio 43215
Attorneys for Defendants
8 Dr. Scott McIlory and
Dr. Richard W. Lamprecht
9
KNEPPER, WHITE, ARTER & HADDEN, ESQS.,
10 BY: W. LOCKE McKENZIE, JR., ESQ.,
180 East Brood Street,
11 Fourth Floor,
Columous, Onio 43215
12 Attorneys for Defendants
Mt. Carmel Medical Center and
13 Dr. John F. Vickers

14 - - -

15 (It was agreed by and among counsel that

16 signing, sealing, certification and filing of the

17 within deposition are hereby waived.

18 (All objections, except as to the form of

19 the question, ore reserved until the time of

20 trial .

21

22

23 MARSHALL KLAVAN, M.D., having been duly

24 sworn, was examined and testifiec as follows:





Irving L. Starkman Associates

1 BY MR. DAVIS:
2 Q. Dr. Klovon, we've been introduced upon our arrival.
3 My name is Bill Davis, and I'm one of the attorneys
4 representing Dr. Lamprecht and Dr. McIlory in this case In
5 which you have been identified as one of the expert
6 witnesses who will testify on behalf of the Plaintiffs.
7 We're here to take Your deposition to
8 find out something about Yourself and Your background,
9 what opinions you hold in this case, and some other
10 matters.
11 If at anytime any of my questions are
12 unclear to You, or don't make sense either logically,
13 gromaticolly, medically, or otherwise, I'll expect You to
14 please speak up and let me know so we can have a meeting
i5 of the mi-nos.  Agreed?
16 A. Yes, sir.
17 Q. Secondly, during the course of this deposition, I
18 will be asking You for Your opinions, and if you do hold
19 opinions in this case, and so that I do not have to repeat
20 myself, may we agree that what I will be asking you for is
21 your opinion to a reasonable medical Probability.
22 Do You understand that term?
23 A. Yes, sir.
24 0. All right. And again simply for the record, what




Irving L. Starkman Associates
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I we're talking about is to a degree of Probability over
2 fifty Percent.
3 A . Yes, sir.
4 0. Fine. Now, would you please state your full name
5 and Professional address for the record?
6 A. Marshall Klavan, Suite 203 Professional Building,
7 Upland, PA, 19013.
8 Q. Do you have any other offices?
9 A. Yes, sir.
10 Q. Where is that?
ii A. At the Providence Meoical Center, Beatty ond
22 Providence Road, media Pennsylvania, 19063,
13 Q. Are You associated in Practice with any other
14 Physicians?
15 A. Yes, sir.
16 O. Who are those doctors?
17 A. My second Partner is Arthur T. Lover, and my third
18 partner is Paul Zamostien.
19 Q. Are they both OB-GYNs, as you are?
20 A. Yes.
21 0. You've Provided us with a copy of your Curriculum
22 Vitae, which I've had a chance to skim through briefly,
23 and I understand most of what's down here, but on your
24 residency Program at Sinoi hospital Center in Baltimore, I



Irving L. Storkman Associates
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1 take it that was on OB-GYN residency?
2 A. Yes, sir.
3 Q. What Is. you have listed on here Progressive
4 Pyramid for your residency, what is that?
5 A. The Pyramid system was a former residency training
6 that existed until the '60's, where one began with a large
7 number of junior residents, and Progressively workeo up to
8 a smaller number of senior residents.  So we began, as I
9 recall, with twelve at the first year level, and Hound up
10 with two at the fourth Year level.
11 Q. how does that differ from the Present OB-GYN
12 residency?
15 A. The Present residencies are wnat are called bloc