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        1               THURSDAY, NOVEMBER 20, 1986
        2                      AFTERNOON SESSION
        3                         - - - o 0 o - - -
        4                   THE COURT:           Dr. Botwin,
        5          you are  still under oath.
        6                   THE WITNESS:         Yes.
        7                   T H ECOURT           Ren?
        8                   MR. KELLER:          Thank you,
        9          your   Honor.
        10
        11     CROSS-EXAMINATION OF DR.  BOTWIN, CONTINUED
        1 2
        1 3 BY MR.  KELLER:
        14  Q      Doctor, I don't suppose you had a chance
        15  to, over the noon hour, to call and check and
        16  see whether or not Heather Hill is a certified,
        17  approved by the State of Ohio, that is a
        18  skilled nursirig care center for this type of
        1 9 treatment, did you?
        20  A      Y e s ,  did.
        2 1 Q      W b a tdid you find out?
        22  A      Al 1 ri g h t .
        23         1 called someone at the Board of Mental
        24  Retardation that deals with residential
        25  service, placed the call to liesther Hill which
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        1  is licensed by the Department of Health, not  by
        2  the Department of Mental Retardation and
        3  Developmental Disabilities.
        4        There are two sections, and as far as  we
        5  are able to ascertain, that they are  serving
        6  a d u I t s .
        7        One section is a "rehabilitation  center,"
        8  and the other a "nursing home."
        9  Q     That Section A is rehabilitation --
        10 A     Yes, and the other section is the  nursing
        11 home.  The nursing home has  some  non-ambulatory
        12 people.  Some of them have  cerebral  palsy.  No
        1 3one in either section has fnental retardation.
        14 Q     Well, I am not sure -- there's  different
        15 degrees of levels of intelligence, and  there
        16 are cerebral palsy patients there who are  less
        17 than what we would call a normal  intelligent
        18 quotient, are there not?
        19 A     Well, when they were asked about having
        20 anyone who is mentally retarded, they  replied,
        21 not now, not at this time.
        22 Q     All r ight .
        23       Prior to lunch, we were discussing some
        24 of the -- did you find out their rates were  $73
        25 a day, by the way, for a .iouble?
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                1       A         Tht- person iid not get the cost.
                2       Q         or wouldn't you know if it was $68 a day
                3       for a     double, and $73 a day for a single, and
                4       $25 an hour fox physical therapy then?
                5       A         It was not established.
                6       Q         0 k a y .
                7       A         I asked what services, and the person who
                8       responded apparently was either confused or
                9       lackinq in knowledge.
                10                That is at the facility, and evidently,
                11      could not supply our staff with an adequate
                12      response as to what services they indeed
                13      provided, and for whom and these other details.
                14      Q         You're telling me that you were unable to
                15      make contact with the right person then?
                16      A         Well,   in  one  instance,  the  person
                17      evidently was someone who was supposed to be
                18      knowledgeable about that.
                19      Q         Did you talk to them personally?
                20      A         I d   id not talk to them.
                21      Q         You had somebody do that?
                22      A         Yes   .
                23      Q         And     then  you  talked  to  a  member  of  your
                24      9 t a f f ?
                25      A         Yes,  who  is  --  whose  responsibility  it
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                        is, in fact, to keep information about such
                2       f a c i I it i e s.
                3       Q          Okay.  You talked to that person and that
                4       person had talked to someone at Heather Hill?
                5       A          That's correct.
                6       Q          Okay.     Now,   we  were  talking  about  the
                7