State of Ohio,

2 County of Cuyahoga.)

3
IN THE COURT OF COMMON PLEAS
4

5 KAREN PEDID, Executrix,
etc.,
6
Plaintiff,
7 Case No. 274,917
VS.
8
KAISER FOUNDATION HEALTH
9 PLAN OF OHIO,

10
Defendant.
11

12 DEPOSITION OF CHESTER L. PLOTKIN, M.D.
Tuesday, August 22, 1995
13

1 4

15 The deposition of CHESTER L. PLOTKIN, M.D.,

16 a witness, called for examination by the

17 Plaintiff under the Ohio Rules of Civil

18 Procedure, taken before me, Diane M. Stevenson, a

19 Registered Professional Reporter and Notary

20 Public in and for the state of Ohio, by agreement

21 of counsel, at the offices of Chester L. Plotkin,

22 M.D., 1611 South Green Road, South Euclid, Ohio,

23 commencing at 3:10 p.m., the day and date above

24 set forth.

25 - - -



Diane M. Stevenson, RPR, CM
Morse, Gantverq & Hodge

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1 APPEARANCES:

2 On behalf of the Plaintiff:

3 R. Eric Kennedy, Esq.
Marilena Lencewicz
4 David Landever
Weisman, Goldberg & Weisman Co., LPA
5 1600 Midland Building
Cleveland, Ohio 44115
6

7 On behalf of the Defendants:

8 Ezio A. LiBtati, Esq.
Porter, Wright, Morris & Arthur
9 1700 Huntington Building
Cleveland, Ohio 44115
10

11

12

13

14

1 5

1 6

17

18

1 9

2 0

21

2 2

2 3

2 4

2 5


Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

3

1 CHESTER L. PLOTKIN, M.D.

2 A witness, called for examination by the

3 Plaintiff, under the Rules, having been first

4 duly sworn, as hereinafter certified, was

5 examined and testified as follows:

6 CROSS-EXAMINATION

7 BY MR. KENNEDY:

8 Q. Would you please state your full name.

9 A. My name is Chester Lawrence Plotkin, P L 0 T K I N.

10 Q. Your professional address?

11 A. 1611 Green Road, South Euclid, 44121.

12 Q. You have been asked by attorneys for Kaiser to

13 review and evaluate a medical record in the care

14 and treatment rendered to Mrs. Bush?

15 A. Yes, I have.

16 Q. Can you tell me what you reviewed -- have you

17 arrived at opinions with respect to that chart?

18 A. Yes.

19 Q. Can you tell me what you reviewed to arrive at

20 those opinions?

21 A. I reviewed the hospital records, the outpatient

22 records of Kaiser, the depositions on Dr. Darr,

23 Dr. Abernethy, Dr. Jandi, and the expert

24 witnesses' statements.

25 Q. What expert witnesses?


Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

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