IN THE COURT OF COMMON PLEAS
                        CUYAHOGA COUNTY, OHIO
      2                    CASE NO 285625

         JEFFREY D SANDERS, ET AL
      4
                 Plaintiffs                 DEPOSITION OF@
      5
         VS                               GLADYS LOVASH, LPN
      6
         EMERGENCY PROFESSIONAL
      7  SERVICES, INC, ET AL

      8          Defendants

      9

      10

      11           Deposition taken before me, Micheline

      12 Simoni, Notary Public within and for the State of

      13 Ohio, on the 14th day of July, 1995, at 3:05 PM,

      14 pursuant to agreement, taken at St Joseph Riverside

      15 Hospital, 1400 Tod Avenue, NW, Warren, Ohio, to be

      16 used in accordance with the Ohio Rules of Civil

      17 Procedure or the agreement of the parties in the

      is aforesaid cause of action pending in the Court of

      19 Common Pleas within and for the County of Cuyahoga

      20 and State of Ohio

      21

      2 2


                          SIMONI COURT REPORTING
                         WARREN/YOUNGSTOWN, OHIO
                          (216) 399-1400, 746-0934

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     2

     3                 A P P E A R A N C E S

     4

     5  On Behalf of the Plaintiff, Jeffrey D Sanders:
        Richard D Topper, Jr, Attorney at Law
     6
        On Behalf of the Plaintiff, Judith Schneider:
     7  Thomas J Silk, Attorney at Law
        SMITH, CONDENI & ABEL CO, LPA
     8
        On Behalf of the Defendant, St Joseph Riverside
     9  Hospital:
        Charles L Richards, Attorney at Law
   10   RICHARDS & MEOLA

   11
        On Behalf of the Defendants, Emergency Professional
   12   Services, Inc, and Dr Sudimack:
        R Mark Jones, Attorney at Law
   13   JACOBSON, MAYNARD, TUSCHMAN & KALUR

   14

   1 5

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                         SIMONI COURT REPORTING

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     1

     2                         I N D E X

     3

     4   DEPOIIEIIT -- GLADYS LOVASH, LPN        PAGE NO

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     6        Index of Objections                    4

     7        CroBB Examination by Mr Topper        5

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                          SIMONI COURT REPORTING

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    2                    INDEX OF OBJECTIONS
    3
    4   DEPONENT -- GLADYS LOVASH, LPN
    5
    6   Keyword index for: Object
    7   Page #24
    8          7           MR JONES:  Objection
    9
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                         SIMONI COURT REPORTING
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                       P R 0 C E
     2                  GLADYS LOVASH, LPN
     3   having been duly sworn according to law, on her
     4   oath, testified as follows:
     5   CROSS EXAMIUATIOR BY MR  TOPPER:
     6   Q   Mrs Lovash, would you please give us your
     7            name and your home address?
     8   A   my name is Gladys Lovash  I live at 1767
     9            Lexington, Warren, Ohio
     10  Q   I think you're the first person from Warren we
     11           have talked to  Do you know Judy
     12           Schneider, or Jeff Sanders, or Ken
     13           Sanders?
     14  A   Not by name

     15  Q   You don't know them personally?

     16  A   No

     17  Q   How long have you worked at St Joels?

     18  A   Fifteen years

     19  Q   Where did you get your LPN?

     20  A   Illinois -- Saulk Valley College

     21  Q   When was that?

     22  A   1988 -- it's a long time ago  I was 30 years


                         SIMONI COURT REPORTING

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      1             old, so it was 21 years ago because I'm

      2             51

      3  Q    Where did you first work as an LPN before St

      4             Joel 9?

      5  A    Institution for the Retarded, Dixon Mental

      6             Health Development

      7  Q    How long did you work there?

      8  A    About two years

      9  Q    How about after that?

    10   A    University of Utah Hospital, Salt Lake City,

    11              Utah

    12   Q    What type of position did you have there?

    13   A    That was an oncology floor  You mean Utah?

    14              Oncology floor

    15   Q-    At the Institute fo