1                  IN THE COURT OF COMMON PLEAS

                                                                 @ I
               2                      CUYAHOGA COUNTY, OHIO

               3  SHEENA TERRY, etc,

               4                       Plaintiff,
                                                            Civil Action No
               5  v
                                                                193206
               6  KAISER FOUNDATION HEALTH PLAN
                  OF OHIO, et al,
               7
                                       Defendants
               8

               9
                                 The video-taped deposition of
             10
                  HERBERT GROSSMAN, MD taken in the above-entitled cause
             11
                  before Tami I Harrison, CSR-3639, Notary Public for the
             12
                  County of Ingham, acting in the County of WaBhtenaw, State
             13
                  of Michigan, at 215 East Washington, Ann Arbor, Michigan, on
             14
                  November 16, 1992, commencing at or about 8:09 am
  I?
             15
                  APPEARANCES:
  ?          16
                       WEISMAN, GOLDBERG & WEISMAN
  0
             17        (By:  Richard  J  BerrIB)
                       1600 Nidland Building
             18        Cleveland, Ohio      44115

             19             Appearing on behalf of the Plaintiff

             20        WESTON, HURD, FALLON,
                       PAISLEY & HOWLEY
             21        (By:  Donald  H  Switzer)
                       2500 Terminal Tower
             22        Cleveland, Ohio      44113

             23             Appearing on behalf of the Defendants

             24  ALSO PRESENT:

             25        Brian Kelley - Video-Tape Technician       coo
                                             HALL AND DEER
                                            (800)  321-3904

                                                                              2

                                             I N D E X

               2 WITNESS:

               3 HERBERT GROSSMAN, MD                                    Page
               4      Examination by  Mr  Switzer                           3
               5      Examination by Mr Berris                             32
               6      Further Examination  by  Mr Switzer                  66
               7      Further Examination  by  Mr Berris                   69
               8      Further Examination  by  Mr Switzer                  71
               9

             10

             11

             12

             13                             @ii  I-o                   cp

             14                                                      61 '9/)

             15  EXHIBITS:

             16       None
                                             @31 2,1
             17

             18

             19                                      5

             20                                        s-

             21

             22

             23

             24

             25

                                           HALL AND DEER
                                           (800)  321-3904

                                                                             3

               1                                      Ann Arbor, Michigan

               2                                      November 16, 1992

               3                                     At or about 8:09 am

               4

               5                MR KELLEY:  On the record  This the

               6      video-taped deposition of Dr Herbert Grossman  It's

               7      being taken in Ann Arbor, Michigan  Today is

               8      November 16th, 1992, the time is 8:0950  My name is

               9      Brian Kelley, I'm a Notary in the County of Washtenaw

             10       Attorneys, please introduce yourselves

             11                 MR SWITZER:  My name is Donald Switzer, I

             12       represent the defendants in this case

             13                 MR BERRIS:  And my name is Richard Berris, I

             14       represent plaintiffs

             15                 MR KELLEY:  And will our court reporter

             16       please swear in the witness?

             17          H E R B E R T    G R 0 S S M A N,   M D,

             18  having first been duly sworn or affirmed by the Notary

             19 Public, was examined and testified as follows:

             20                          EXAMINATION

             21 BY MR  SWITZER:

             22 Q     Doctor, my name iS Don Switzer  We've obviously met