12 1 COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
2
ROSE A. HAWES, X
3 Co-Administratrix of the X
Estate of Margaret Fasko X
4 and HELEN MOORCROFT, X
Co-Administratrix of the X
5 Estate of Margaret Fasko X CASE NO. 169651
 Plaintiffs X HON.  JAMES F. KILCOYNE
6 Vs X
PARMA NURSING HOME, INC. X
7 and BROADVIEW NURSING X
HOME, INC., X
8  Defendants X

9 VIDEOTAPED

10 ORAL DEPOSITION

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12 OF

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14 JAMES P. KNOCHEL, M.D.

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16 ANSWERS AND DEPOSITION OF JAMES P. KNOCHEL, M.D.

17 produced as a witness at the instance of the Plaintiffs

18 taken in the above-styled and numbered cause on the 30th

19 of April, 1991, at 2:00 p.m., before Elizabeth Lynch, a

20 Certified Shorthand Reporter in and for the State of

21 Texas, at Presbyterian Hospital, Department of Internal

22 Medicine, 8200 Walnut Hill Lane, in the City of Dallas,

23 County of Dallas, State of Texas, in accordance with the

24 Ohio Rules of Civil Procedure and Ohio Rules of Evidence.

25

 ORIGINAL

FULLER AND PARKER, INC.  DALLAS, TEXAS 214/783-7661

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1 A P P 9 A R A N C E S

2
MR. ERIC KENNEDY
3 Weisman, Goldberg, Weisman & Kaufman
-1600 Midland Building
4 Cleveland, Ohio 44115

5 APPEARING FOR THE PLAINTIFFS

6
MR. KENNETH BAUMAN
7 Ogne, Alberta & Stuart, P.C.
Suite 1800 Top of Troy
8 755 West Big Beaver Road
Troy, Michigan 48084
9
APPEARING FOR THE DEFENDANTS
10

11 ALSO PRESENT: Tim Salzman
Video Technician
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FULLER AND PARKER, INC.  DALLAS, TEXAS 214/783-7661

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I N D E X
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3 Witness: JAMES P. KNOCHEL, M.D.
4
5 Direct Examination by Mr. Kennedy Page 6
6 Cross Examination by Mr. Bauman Page 22
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10 Witness' Signature (Waived) Page 28
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12 Reporter's Certificate Page 29
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FULLER AND PARKER, INC.  DALLAS, TEXAS 214/783-7661
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A G R Z 3 M 3 N T S

2

3 IT IS AGREED by and between the parties hereto,

4 through their attorneys appearing heroin, that any and all

5 objections to any question or answer herein, except an to

6 the form of question or unresponsive answers, may be made

7 upon the offering of this deposition in evidence upon the

8 trial of this cause with the same force and effect as

9 though the witness were present in person and testifying

10 from the witness stand.

11 IT IS AGREED by and between the p