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

               3

               4

               5  Katherine G. Kell, et al,

               6                 Plaintiffs,

               7         VS.                            No. 249409

               8  Reich, Seidelmann & Janicki
                    Co., et al,
               9

             10                  Defendants.


             11

             12

             13         Deposition of JAY THOMPSON, M.D., a witness

             14   herein, called for cross-examination by the

             15   Defendants, taken before Michelle A. Bishilany, a

             16   Registered Professional Reporter/CM and Notary

             17   Public within and for the State of Ohio, at the

             18   offices of Sachs, Ross & Associates, 6803 Mayfield

             19   Road, Cleveland, Ohio, on Tuesday, the 20th day of

             20   December, 1994, at 6:50 p.m.

             21

             22                         - - - -

             2 3

             2 4
                                  HOLLAND & ASSOCIATES
             25                      (216)621-7786

                                                                         2


                1 APPEARANCES:

                2

                3            Weisman, Goldberg & Weisman, by

                4            Mr. Richard J. Berris,


                5                 On behalf of the Plaintiffs;


                6

                7

                8            Jacobson, Maynard, Tuschman & Kalur, by

                9            Mr. Dale L. Kwarciany,


              10                  On behalf of the Defendants.


              11

              12

              13

              14                         - - - -
                                                            I Z-
              15         .2                I/ (Y

              16
                                                    74
                                                             //?   r- 7-
              17

              18

              1 9

              20

              21

              22                                                     f a

              23

              2 4

              2 5


                                                                   Id       ?

                                          /VI,                         (@ cw . )



                                   3 7

                                     7

                                                                       3

                1                  JAY THOMPSON, M.D.,
                2 of lawful age, a witness herein, called for
                3 cross-examination by the Defendants, being by me
                4 first duly sworn, as hereinafter certified, deposed
                5 and said as follows:
                6                  CROSS-EXAMINATION
                7 BY MR.  KWARCIANY:
                8 Q.     Doctor, my name iS Dale Kwarciany.  You and I
                9 have met before in other cases.  I haven't taken
             10   your deposition in a while so I just need a little
             11   update on yourself.
             12          What's the extent of your radiological
             13   practice at present?
             14   A.     Hospital-based practice in the Community
             15   Hospital of Bedford general diagnostic radiology
             16   usually two days a week.
             17   Q.     At Bedford?
             18   A.     Uh-huh.  And general diagnostic radiology at
             19   our Hillcrest office here probably three days a
             20   week.
             21   Q.     Now Bedford is a hospital-based practice and
             22   Hillcrest is what, an office-based practice?
             23   A.     That's right.
             24   Q.     You obviously have staff privileges at
             25   Bedford?
                                                                         4

                1 A.      That's correct.
                2 Q.      Do you have staff privileges at Hillcrest as
                3 well?
                4 A.      Yes, I do.
                5 Q.      Any other place?
                6 A.      No.
                7 Q.      How old are you now?
                8 A.      I am 56.
                9 Q.      Are you the head of the department either at
              10  Bedford or Hillcrest?
              11  A.      No, I am not.
              12  Q.      Have you ever been?
              13  A.      No.
              14  Q.      Give me an idea of how many x-ray films you
              15  read in a week, both at Bedford and at Hillcrest, a
              16  ball pa