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 parties hereto,

12 through their attorneys appearing herein, that the officer

13 taking this deposition may return and file the same

14 without the signature of the witness thereto, said

is signature of the witness being waived by all parties and

16 by the witness, maid deposition to be used on the trial of

17 this cause with the same force and effect as though the

18 same had been read and signed by said witness.
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FULLER AND PARKER, INC.  DALLAS, TEXAS 214/783-7661

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P R 0 C 3 Z D I N G S
2 MR. KENNEDY: Put on the record that --
3 that we will be waiving the filing of this deposition now
4 for the purposes of trial, and that any service or defect
5 of notice is waived. Is that correct?
6 MR. BAUMAN: Yes.
7 MR. KENNEDY: All right. If you
a would --
9 MR. BAUMAN: Let me also say I -- we
10 previously said the filing of the video --
11 MR. KENNEDY: Yeah.
12 MR. BAUMAN: -- not the --
13 MR. KENNEDY: Transcript.
14 MR. BAUMAN: -- transcript per so.
15 MR. KENNEDY: Yeah. Do you want to --
16 do you want to waive both the filing of the video and the
17 transcript?
18 MR. BAUMAN: Yeah. We're not going to
19 be filing any dispositive notions so the Court doesn't
20 have to look at it --
21 MR. KENNEDY: Right.
22 MR. BAUMAN: -- but we're going to have
23 to go through it prior to trial anyhow.
24 MR. KENNEDY: Right, yeah.
25 MR. BAUMAN: That's fine.

FULLER AND PARKER, INC.  DALLAS, TEXAS 214/783-7661
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1 COURT REPORTER: Doctor, if you'll
2 raise your right hand I'll swear you in.
3 THE WITNESS: (complies.)
4 COURT REPORTER: Do you solemnly swear
5 that the testimony you are about to give will be the
6 truth, the whole truth and nothing but the truth, so help
7 you God?
8 THE WITNESS: I do.
9 JAMES P. KNOCKEL, N.D.,
10 the witness hereinbefore named, being of lawful age and
11 being first duly cautioned and sworn in the above cause,
12 testified on his oath as follows:
13 DIRECT EXAMINATION
14 BY MR. KENNEDY:
15 Q Doctor, my name in Eric Kennedy and I represent
16 the family of Margaret Fasko.  For the record, could you
17 please state your full name?
is A James P. Knochel.
19 Q And what is your professional address?
20 A Presbyterian Hospital, 8200 Walnut Hill Lane,
21 Dallas, Texas.
22 9 And is that where we are today?
23 A That's where we are today.