I IN THE COURT OF COMMON PLENS

2 CUYAHOGA COUNTY, OHIO

3 EDITH N. MILLER, EXECUrRIX
OF THE ESTATE OF EDWARD L. MILLER
4
VS. NO. 966,735
5
UNIVERSITY HOSPITALS- OF
6 CLEVELA@ND, ET AL

7

8

9

10

11

12 DEPOSITION OF RICHARD BOMBERGER, M.D.

13

14 DEPOSITION AND ANSWERS OF RICHARD BOMBERGER,

15 M.D. , taken before Jenny Floyd, a certified shorthand

16 reporter and notary public in and for Harris County and

17 the State of Texas, at the Host International Hotel,

18 Houston Intercontinental Airport, Houston, Texas,

19 beginning at 11:00 a.m. on the 31st day of January, A.D.

10 1981, pursuant to the following stipulations and waiver of

21 counsel., viz.:

22

23
k3
1.4 Cost Paid by Plaintiff $

2 5






HOUSTON REPORTING SERVICE
609 FANNIN, SUITE 11 2 1, HOUSTON, TEXAS, PHONE 237-8666

2


S T I P U L A T I 0 N S
2
3 IT IS STIPULATED AND AGREED by and between
4 @counsel for the respective parties hereto that the
5 1
deposition shall be sent to the witness, and he shall read
6 land sign the deposition before any notary public.
7
8 IT IS STIPULATED AND AGREED by and between
9
counsel for the respective parties hereto that the
10 original of the deposition shall be sent to Mr. Jed
it I
Weisman, and that Mr. Weisman will be responsible for the
12 filing of the deposition.
J3
14

16

18
19
no

22
23
24
2 5




HOUSTON REPORTING SERVICE
609 FANNIN, SUITE 2 I2 1, HOUSTON, TEXAS, PHONE 237-8666

3

A P P E A R A N C E S

3 MR. JED WEISMAN, Attorney at Law, 540 Leader
4 @Btlilding, Cleveland, Ohio 44115, representing the
5 Plaintiff.

17 MR. JIM GOWAN, Attorney at Law, Bulkley
8 @Building, 6th Floor, Cleveland, Ohio 44115, representing
9 Defendant Puritan-Benett.
10
11 MR. HARRY T. QUICK, Attorney at Law, 1144
12 Union Comnerce Building, Cleveland, Ohio 44115,
13 representing Defendant University Hospitals of Cleveland.
14
15
16
17
18
19
@O
21
22
23
24
2 5



HOUSTON REPORTING SERVICE
609FANNIN,SUITE21-.1,HOUSTON.TEXAS,PHONE 237-8666

4



RICHARD BOMBERGER, M.D.,

called as a witness, having been first duly sworn upon his
3 oath, was examined by counsel and testified as follows:
4
EXALMINATJON
5

6 QUESTIONS BY MR. WEISMAN:
7 Q Doctor, for the record would you state your name,
8 please?
9 A Richard Bomberger.
10 Q Doctor, I'm going to ask you a number of questions

here today, particularly pertaining to a patient at

the University Hospitals of Cleveland back in May of
13 1976, a Edward Miller. And if any of the questions I
14 ask are not clear or if in any way you do not
15 understand the question, please ask me to repeat or
16 rephrase the question, will you please?
17 A Yes, sir.
18 Q Now I am going to presume -- and correct me if I'm
19 wrong -- that prior to your coming here today for the
20 taking of this deposition that you had the opportunity
11
to meet with Mr. Quick who is the attorney for
22 University Hospitals of Cleveland and that you also
2 3 had an opportunity to review the records of Edward
1.4 Miller from University Hospital; am I correct on that?
15
A Yes, sir.




HOUSTON REPORTING SERVICE
609 FANNIN.  SUITE 212 1, HOUSTON.  TEXAS, PHONE 237-8666

 5








Q If at any time during the course of this deposition


you are asked questions in which you wish to refer to

3 the hospital records, please do so. Nobody expects

4 you to have in your mind each and every incident that

5 we may be speaking of here. Will you do that?

6 A Yes, sir.

7 Q What is your present address, residence address,

8 Doctor?

9 A Apartment 2210, 1800 El Paseo, E-1 P-a-s-e-o, two

10 words, Houston, Texas 77054.

11 Q And how long have you resided in the Houston, Texas

11
area?

13 A Seven months.

14 Q Prior to residing here in Houston, where did you

15 reside?

16 A Chicago, Illinois.

17 Q Here in Houston are you affiliated with any hospital?

18 A Baylor University, Methodist Hospital.


19 Q And you were in Chicago for how long?

10
A Two years.

21 Q Were you affiliated with a hospital there?

22 A University of Chicago.

23 Q I take it that's not a hospital -- is it called the

24 University of Chicago Hospital?

25 A University of Chicago Clinics and Hospital. It's a







HOUSTON REPORTING SERVICE
609 FANNIN, SUITE 1. 12 1, HOUSTON, TEXAS.  PHONE 237-8666

6







I hospital of the university -- it's the hospital of the

2 University of Chicago.

3 Q Doctor, are you married?

4 A No.

5 Q Ever been married?

6 A Yes.

7 0 And how did that marriage terminate?

8 A In separation.

9 Q What is your -- I'm going to ask you a little bit

10 about your background as far as your education and

11 training in the medical -- particularly in the medical

12