5


9-

IN THE COURT OF COMMON PLEAS

2 CUYAHOGA COUNTY, OHIO

3 JOSHUA PARAMORE, etc.,

4 Plaintiffs,
CA E NO.
5 v.
JUDGE:
6 S. H. BUTT, M.D., et al.,

7 Defendants.

8

9

10 The Deposition of STEVEN DONN, M.D., taken

11 in the above-entitled cause before Mary A. Ansbro,

12 CSR-3570, RPR, Notary Public in and for the County of

13 Livingston, acting in the County of Washtenaw, State

14 of Michigan, at 215 East Washington Street, Ann Arbor,

15 Michigan, on June 25, 1992, commencing at or about

16 5:15 p.m.

17

18 APPEARANCES:

19 THOMAS R. THEADO
JANET D. TOMKO
20 446 Broadway
Lorain, Ohio 44052-1797
21
Appearing on behalf of Plaintiffs.
22

23

24

25


HALL AND DEER
(800) 321-3904

2




1 APPEARANCES, CONTINUING:

2 JACOBSON, MAYNARD
(By: Joseph Farchione)
3 1001 Lakeside Avenue
Suite 1600
4 Cleveland, Ohio 44114-1192

5 Appearing on behalf of Defendant Shahid Butt, M.D.
(via telephone)
6
WESTON@_ HURD, FALLON, PAISLEY & HOWLEY
7 (By: Donald H. Switzer)
2500 Terminal Tower
8 Cleveland, Ohio 44113-2241

9 Appearing on behalf of Defendant Southwest
General Hospital.
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25



HALL AND DEER
(800) 321-3904

3





2 I N D E X

3

4

5 WITNESS:

6 STEVEN DONN, M.D. Page

7

8 Examination by Mr. Theado 5

9

10

11

12

13 EXHIBITS:

14

15 Deposition Exhibit No. 60(a) 4

16 Deposition Exhibit No. 60(b) 4

17 Deposition Exhibit No. 60(c) 4

18 Deposition Exhibit No. 61 4

19 Deposition Exhibit No. 62  76

20

21

22

23

24

25



HALL AND DEER
(800) 321-3904

4




1 Ann Arbor, Michigan

2 June 25, 1992

3 At or about 5:15 p.m.

4

5 S T E V E N D 0 N N, M. D.,

6having first been duly sworn or affirmed by the Notary Public,

7was examined and testified as follows:

8 (Deposition Exhibit Nos. 60(a), (b),

9 (c) & 61 were marked for identification)

10 MR. THEADO: This is a deposition taken in

11 case No. 207608 now pending in the Court of Common

12 Pleas of Cuyahoga County, Ohio. It's being taken

13 pursuant to and under the Ohio Rules of Civil

14 Procedure, pursuant to notice and agreement of party.

15 Present is, in addition to the deponent witness,

16 Mr. Switzer representing the hospital, Miss Tomko and I

17 representing the plaintiffs.  Mr. Farchione is

18 attending by telephone; is that correct, Joe?

19 MR. FARCHIONE: That's correct.

20 MR. THEADO: Is there any objections as to

21 notice or service of notice or the qualifications of

22 the court reporter?

23 MR. SWITZER: No.

24 MR. FARCHIONE: Looks pretty good from here.

25 MR. THEADO: Dr. Donn, you've had your



RALL AND DEER
(800) 321-3904

5




1 deposition taken before, correct?

2 THE WITNESS: Yes, sir.

3 MR. THEADO: And you've testified at trials

4 before?

5 THE WITNESS: Yes, sir.

6 MR. THEADO: Okay.  I won't take you through

7 my nine instructions then with respect to deposition

8 witnesses. I'd just like to remind you of this. If I

9 talk too quickly or too confusedly so that you don't

10 understand a question that I put to you, please ask me

11 to rephrase it or restate it, okay?

12 THE WITNESS: Yes, sir.

13 MR. THEADO: If you don't know an answer,

14 tell me you don't know it and if you don't remember an

15 answer, tell me you don't remember it. I'll understand

16 that if you answer a question I put to you, that you

17 have heard it and understood it and gave me your best

18 answer, okay?

19 THE WITNESS: Fair enough.

20 EXAMINATION

21 BY MR.  THEADO:

22 I understand consequent to your report in this suit

23 that's been dated January 31, 1992, that you've

24 reviewed some documents in preparation for or

25 anticipation of rendering opinions that are recorded



HALL AND DEER
(800) 321-3904

6




1 there, and those documents are the Southwest General

2 Hospital records, and for today's deposition, I'll

3 point out that a copy of those records are here and

4 marked as Exhibit 1; a copy of the child's

5 hospitalization at University Hospital of June 29 to

6 July 26, 1990, and those have been marked and are

7 presented here today, if you should need reference to

8 them, in three volumes, 60(a), 60(b), and 60(c).  I

9 also note that you had reviewed, when you issued your

10 January 31, 1992, report, a CT scan of January 15,

11 1991, but I also understand that between the time of

12 your report and now, you've had an opportunity to

13 review additional films, be they sonographs, or CTs, or

14 x-rays; is that correct?

15 A That's correct. Let me, though, just correct one part

16 of your question. I had not seen the CT scan prior to

17 tod