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7y' IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT, IN AND FOR JEFFERSON COUNTY ALABAMA ASHLEY MICHELE FLOWERS CIVIL ACTION WILLIAM C. FLOWERS, ET AL Plaintiffs VS. BAPTIST MEDICAL CENTER- MONTCLAIR, ET AL Defendants NO. -79-3839 Upland, Pennsylvania October 21, 1982 Deposition of MARSHALL KLAVAN, M.D., held in the offices of MARSHALL KLAVAN, M.D., CROZER- CHESTER MEDICAL CENTER, at 1:30 p.m. on the above date, before Barbara.Donatelli, a Registered Professional Reporter. APPEARANCES: HUIE, FERNAMBURG AND STEWART BY: WILLIAM B. FERNAMBURG, ESQUIRE Suite 825 First Alabama Bank Building Birmingham, Alabama 35203 Sel 1.91C7 m. i,,iavan 1 MR. HARPER: Thank you, Doctor. I have no 2 further questions. 3 (The deposition is concluded at 5:10 p.m.) 4 (Copies of Exhibits are attached to original and 5 all copie's of the transcript of this deposition 6 and original Exhibits marked at deposition are 7 in a separate envelope and attached to the original 8 transcript.) 9 10 - - - 11 12 13 14 15 16 17 18 19 20 21 22 23 24 PAGE 2a .4 I INDEX 2 WITNESS PAGE 3 MARSHALL KLAVAN, M.D. 4 By Mr. Fernamburg 3 121 5 By Mr. Harper 97, 122 6 7 EXHIBITS 8 NO. DESCRIPTION I.D. 9 Barnett-1 Monitoring strip 43 10 Barnett-2 Monitor strip 68 11 13 14 15 16 17 18 19 20 21 22 23 24 PAGE I APPEARANCES (Cont'd): 2 DONALD LUSK, ESQUIRE 725 First Alabama Bank Building 3 Birmingham, Alabama 35203 Attorneys for Defendant Dr. Robert Barnett 4 EMOND AND.VINES 5 BY: CLIFFORD EMOND, JR., ESQUIRE 1800 City Federal Building 6 Birmingham, Alabama 35203 Attorney for Plaintiffs 7 PORTERFIELD, SCHOLL, BAINBRIDGE, MIMS, 8 CLARK AND HARPER, P.A. BY: LARRY W. HARPER, ESQUIRE 9 2 Office Park Circle Birmingham, Alabama 35223 10 Attorney for Baptist Medical Center, et al 11 12 13 14 15 16 17 18 19 20 21 22 23 24 PPM PAGE 3 1 (it is stipulated by and among counsel 2 for the respective parties that sealing, 3 signing, certification and filing are waived, 4 and that all objections, except as to the 5 form of the questions, are reserved to the 6 time of trial.) 7 8 MARSHALL KLAVAN, M.D., having been 9 first duly sworn, was examined and testified 10 as follows: 11 EXAMINATION BY 12 MR. FERNAMBURG: 13 O. Doctor, would you state your full name, please? 14 A. Marshall Klavan, M.D. 15 Q. And what is your address? 16 A. My professional address is Suite 203 in the 17 Professional Building, Crozer-Chester medical Center, 18 Upland, Pennsylvania, 19103. 19 QL How long have you been practicing medicine? 20 A. As a practitioner in obstetrics -- I was 21 licensed shortly After I graduated from medical 22 school, which was in 1957. As a practitioner I 23 have been practicing since 1962, which includes two 24 years in the service. M. Klavan PAG. Do you have a specialty, Doctor? 2 X Yes. 3 What is that specialty? 4 X Obstetrics and gynecology. 5 OL Are you Board certified? 6 A. Yes, sir. 7 How long have you been practicing your 8 specialty? 9 A. Since 1964. 10 O. Do you have a specialty within your specialty? 11 A. No, I do not. 12 QL And your practice as a OB-GYN is what you 13 would expect other OB-GYNs to do in that typo of 14 work. Is that correct? 15 A. Yes. 16 OL And you have no specialty within that specialty 17 L That's correct. 18 QL Can you tell us something about your medical 19 background, not in great detail, but just briefly? 20 L Well, I attended the University of Virginia 21 from 1950 through,.1953. Then I went to the Medical 22 College of Virginia from 1953 to 1957. 23 I then I had a year of internship 24 and four years of residency training at Sinai M. Klavan PAGE--L- I Hospital in Baltimore, Maryland in obstetrics and 2 gynecology. 3 Following this, I was in the military 4 service, in the United States Army, for two years 5 in Germany doing obstetrics and gynecology. 6 Following that I entered the practice 7 of medicine in the Philadelphia area. 8 I have been involved academically 9 with a couple of medical schools in the Philadelphia 10 area. I was an instructor at the Medical College 11 of Pennsylvania when I entered practice here. In 12 1967 1 was appointed Assistant Professor at the 13 Hahnemann Medical College where I was involved in 14 the training of residents and medical students as 15 well as private practice. 16 I was elevated to the title of 17 Professor of Obstetrics and Gynecology and appointed 18 to the Hahnemann staff in 1970. 19 During the time I was at Hahnemann, 20 1 was Administrativg-Chie-f in the Obst
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