IN THE COURT OF THE NINTH JUDICIAL CIRCUIT

2 IN AND FOR THE ORANGE COUNTYr FLORIDA COURT

3 - - -

4 JESUS RONQUILLO, ERNESTINA
RONQUILLO, and SONIA
5 RONQUILLO
Plaintiffs
6
VS.
7
ORLANDO REGIONAL MEDICAL
8 CENTER, INC, ORANGE
MEMORIAL HOSPITAL; and
9 FLORIDA PATIENTS'
COMPENSATION FUND,
10 Defendants,
Third Party Plaintiffs
11 VS.

12 AIR-SHIELDS, INC. Case No. CI 82-9035
 Third Party Defendant:
13
September 5, 1984
14 Upland, Pennsylvania

15

16 Deposition of Marshall Klavan, M.D., taken

17 pursuant to notice at the Crozer-Chester Medical Center,

18 15th and Upland Avenue, Upland, Pennsylvania,

19 beginning at approximately 8:30 a.m.,

20 on the above date, before Barbara Butler,

21 Registered Professional Reporter and Notary Public.

22 - - -

23 VINCENT VARALLO ASSOCIATES
221 North Olive Street
24 Media, Pennsylvania 19063
(215) 565-6150
VINCENT VARALLo ASSOCIATES.  INC.
FUR REGISTERED PROFESSIONAL REPORTERS

 2



1 APPEARANCES:

2 DANIEL H. HONEYWELL, ESQUIRE
Wooten, Honeywell, Kest & Martinez, P.A.
3 236 S. Lucerne Circle
Ordlando, Florida 32801
4
Counsel for Plaintiff

THOMAS P. PAGE, ESQUIRE
6 Mateer, Harbert, Prey, Bechtel & Phalin, P.A.
100 East Robinson Street
7 Post Office Box 2854
Orlandor Florida 32802
8

9 Counsel for Defendant? Orlando
Medical Center
10

11 (It is stipulated by and between counsel

12 for the respective parties that signing, sealing,

13 and certification are waived; and that all objections,

14 except as to the form of the question, are reserved until

15 the time of trial.)

16 - - -

7 ... MARSHALL KLAVANt M.D.# having been duly

I sworn, was examined and testified as follows ...

BY MR.  PAGE:

Q. Would you state your name please?

A. Marshall Klavan, K-L-A-V-A-N.

0. And your address, home address?

A. 255 New Darlington Road, Media, PA, 19063.

And your business address?

VINCENT VARALLO ASSOCIATES.  INC.
EUM REGINTIEN90 1000111[$910NAt.  REPONTRItS

3

MARSHALL KLAVAN, M.D.



I A. Suite 203 Professional Building, 15th and Upland

2 Upland, PA, 19013.

3 Q. And what is your profession?

4 A. I'm an obstetrician-gynecologist, physician.

5 Q. Are you an M.D.?

6 =A. Yes, sir.

7 Q. Where are you licensed to practice medicine?

8 A. Pennsylvania, California and Virginia. I'm

9 theoretically licensed throughout the United States

10 but those are places where I hold licenses.

11 Q. Why theoretically?

12 A. The Boards which I took after graduating medical

13 school allows me reciprocity -- to be licensed in all

14 states by reciprocity.

15 Q. Had you ever practiced medicine in the State of

1 6 Florida?

1 7 A . No, sir.

18 Q. Are you Board certified in obstetrics and

19 gynecology?

20 A. Yes, sir.

21 Q. When were you certified?

22 A. Initially in 1966 and voluntarily recertified in

23

24 Q. Are you Board certified in any other field?


VINCENT VARALLO ASSOCIATES.  INC.
REGISTERED PROFESSIONAL REPORTERS

4
MARSHALL KLAVANr M.D.


I A. No, sir.  I have a subspeciality interest in

2 perinatal medicine but because I practice general

3 obstetrics and general gynecology, I did not submit to

4 the Board's subspeciality.  I have, however, trained

5 fellows in perinatal medicine and do the high risk

6 o@stetrics in the area.

7 Q. What is perinatal medicine?

8 A. Perinatal medicine is fetal and maternal

9 medicine. Medicine that relates to primarily high

10 risk obstetrical practice.

11 Q. Do you have staff privileges at any hospitals?

12 A. Well, of course I have staff privileges here at

13 the Crozer-Chester Medical Center where I'm Chief of

14 Service, Chairman of the Department. I currently have

15 privileges at the Hahnemann University.

16 Q. I'm sorry?

17 A. Hahnemann University, H-A-B-N-E-M-A-N-N.  It's

18 one of the five medical schools in the Philadelphia

19 area. But I have not admitted patients there since

20 1971, since coming here. I have health privileges at

21 other hospitals. But since 1971 I have limited my

22 practice activities to this particular institution.

23 Q, Which is Crozer-Cbester Medical Center?

24 A. Yes.

VINCENT VARALLo ASSOCIATES.  INC.
[UV: REGISTERED PROFESSIONAL REPORTERS

5
MARSHALL KLAVAN, M.D.

1 Q. So is it true then, Doctor, that all of your

2 practice is presently conducted at Crozer-Chester

3 Medical Center?

4 A. That's correct.

5 Q. And it has been the case since 1971?

6 =A. That's correct.

7 Q. Will you describe the Crozer-Chester Medical

8 Center?

9 A. It's a high level two community hospital that

10 encompasses all of the specialties in medicine except

11 for cardiac surgery. It is a roughly 500 bed

12 institution. It is a teaching hospital. It is the

13 primary teaching hosp