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.)
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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

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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

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PPM

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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