STATE OF OHIO
                                 ) SS
               COUNTY OF LUCAS

                                 COURT OF COMMCN PLEAS

               JACQUELINE WAINSCOTT-PETERS,
               et  al,

                      Plaintiffs,

               VS                                    Case No 86-1252
                                                      JUDGE SKOW
               HARIDAS DASANI, MD, et al,

                       Defendants

                            Deposition of STEVEN liARK,DONN, MD, a
                      Witness herein, called by the Plaintiffs as if upon
                      Cross-Examination under the Ohio Rules of Civil
                      Procedure, taken before mB, the undersigned,
                      Sandra L Furman, a Notar:( lublic and Registered
                      Professional Reporter in an@ for the State of Ohior
                      at University of Michigan Medical Center, Women's
                      Hospital, Ann Arbor, Mich gan, on Mondayr
                      September 12, 1988, at 5: 0 pm

               C 0 L L I N S  R E P 0 R T I N      S E R V I C Er  I N C
                          Registered Professior@al Reporters
                      405 North Huron Street     Toledo, Ohio   43 6 0 4
                                     (419) 244-@@385
                                                                        2

              APPEARANCES:

                     On behalf of the Plaintilfs:

                            FRANK W CUBBON JR, & ASSOCIATES
                            Thomas J McArdle
                            405 N Huron, Suite 500
                            Toledo, Ohio  43604
                            (419) 243-7243

                     On behalf of the Defendarts:

                            ROBISON, CURPHEY & 01-@ONNELL
                            E Thomas Maguire
                            Four SeaGate, 9th Flo)r
                            Toledo, Ohio  43604
                            (419) 249-7900

                                                                       3
         1                      STEVEN M DONN, tiD,
         2    a witness herein, called by the Pleintiffs as if  upon
         3    Cross-Examination, was by me first duly sworn, as
         4    hereinafter certified, deposed aad said as follows:
         5                        CROSS-EXAMINPT'ON
         6    BY MR  McARDLE:
         7           Q    Doctor, my name's TDm McArdle and I'm here
         8    representing the Plaintiff in this action  The record
         9    will show that Thomas Maguire is also here representing
       10     the Defendant Riverside Hospital  We're here by agreement
       11     of the parties today to take the d(position of  Steven
       12     Donn, MD  Is that pronunciatioi i-orrect?
       13            A    Donn
       14            Q    Doctor, if at any timc@ I ask you any question
       15     that seems confusing or that youlr(@ not exactly sure what
       16     I mean by it, please stop me and I 11 attempt to rephrase
       17     it I'll also try to keep things Jairly  brief  today
       18     Doctorp can you tell me your naml% end your current
       19     professional address?
       20            A    Steven Mark Donni MD , Women's  Hospital
       21     University of Michigan Medical Caner
       22            Q    How long have you bee  at this address?
       23            A    Ten years
       24            Q    Mr Maguire has proiicied me with a CV dated I

                           COLLINS REPORTING SERIRICE, INC
                                                                         4
          1   believe July 188  Is that current and correct?
          2           A    It's correct   It has I believe  been  updated
          3   once since then
          4           Q    Doctor, what is your  Drofessional  specialty?
          5           A    I am a neonatologist
          6           Q    What does that specialty entail?
          7           A    I'm a pediatrician whD subspecializes  in  the
          8   care of newborn infants
          9           Q    Have you further limi--ed your practice  beyond
        10    your slubspecialty?
        11            A    In a way that's a dif icuit question to
        12    answer yes or no in that at least  t the University of
        13    Michigan the neonatologists are th ones  who  have  assumed
        14    the follow-up care of infants who iave been hospitalized
        15    in the neonatal intensive care uni:  and  monitor  neurologic
        16    assessment, neurologic outcomes, miinagement of chronic
        17    diseases for a variable period of I:ime which would  in  some
        18    cases be well beyond the neonatal ])eriod
        19