1   State of Ohio,
                                                 SS:
                2   County of Cuyahoga.

                3                             - -  -

                4                IN THE COURT OF COMMON PLEAS

                5                             - -  -

                6   Norma  S.  Marlette,  Executrix,
                    etc.,
                7
                                      Plaintiff,
                8                                        Case No. 236117
                           VS.
                9                                        Judge Character
                    The Cleveland Clinic
              10    Foundation, et al.,

              11                      Defendants.

              12                              - -  -

              13               DEPOSITION OF JOSEPH SUTTON, M.D.

              14                   TUESDAY, FEBRUARY 2, 1993

              is                              - -  -

              16    The deposition of Joseph Sutton, M.D., called by the

              17    Plaintiff for examination under the Ohio Rules of

              18    Civil Procedure, taken before me, Ivy J. Gantverg,

              19    Registered Professional Reporter and Notary Public

              20    in and for the State of Ohio, by agreement of

              21    counsel and without further notice or other legal

              22    formalities, at the Cleveland Clinic Foundation,

              23    9500 Euclid Avenue, Cleveland, Ohio, commencing at

              24    9:10 a.m., on the day and date above Bet forth.

              25





                                      MORRR, RANTVFR(; F Pnnr-W

              1   APPEARANCES:

              2   On behalf of the Plaintiff:

              3          Fred Weisman, Esq.
                         Weisman, Goldberg & Weisman
              4          1600 Midland Building
                         Cleveland, Ohio   44115
              5
                  On behalf of the Defendants:
              6
                         Gary H. Goldwasser, Esq.
              7          Reminger & Reminger
                         113 St. Clair Building
              8          Cleveland, Ohio  44114

              9

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             25





                                   MNRSR, NANTVRRC r, T4C)DCR

               1                   JOSEPH SUTTON, M.D.
               2  called by the plaintiff for examination under the
               3  Rules, having been first duly sworn, as hereinafter
               4  certified, was deposed and said as follows:
               5                    CROSS EXAMINATION
               6  BY MR.  WEISMAN:
               7  Q.     Doctor, if you please, state your name for
               8  the record here, sir.
               9  A.     Joseph Michael Sutton.
             10   Q.     And your residence address, please?
             11   A.     1623 Compton Road, Cleveland Heights.
             12   Q.     And your professional address?
             13   A.     The Cleveland Clinic Foundation, Desk F-25.
             14   I am not sure of the street address.
             15   Q.     That is all right.
             16                 MR. GOLDWASSER:  You have a copy of
             17          the CV, do you not?
             18                 MR. WEISMAN:  Yes.
             19   Q.     (Continuing) I have a CV that was provided by
             20   counsel, by your attorney here, Mr. Goldwasser.
             21   A.     Okay.
             22          It is actually a little old, I think.
             23   Q.     Yes, well, I will hand this to you, it is
             24   seven pages -- it is five pages, I guess.
             25   A.     Okay.


                                   MORRR, C@AWTVP.Rr, & HOnrR
              1   Q.     And I am handing that to you now, we  will
              2   mark it in a moment.
              3          Just look it over, and what I am interested
              4   in is knowing whether or not that is complete and
              5   current.  If there are any changes, just  tell  us
              6   what they are.
              7   A.     My age is now thirty-three instead of
              8   thirty-two, since I had a birthday.
              9   Q.     Okay.
             10   A.     It does include my third son, or my  third
             11   child who was born.
             12          And the only other thing that will not  be
             13   current is the publications.
             14   Q.     All right.