IN THE COURT OF COMMON PLEAS
is 1 69
OF SENECA COUNTY, OHIO
NELENE K. KECKLER, etc., et al.,
Plaintiffs,
VS. Case No. 44725
DONALD SHANABROOK, M.D., et al.,
Defendants.

Deposition of STEVEN M. DONN, M.D., a witness
herein, called by the Plaintiffs as upon Cross
Examination under the Ohio Rules of Civil
Procedure, taken before me, Dianne Bochi,
Registered Professional Reporter and Notary Public
in and for the State of Ohio, at the University of
Michigan Women's Hospital, 1500 East Medical Center
Drive, Ann Arbor, Michigan, on Tuesday, January 17,
1990, at 5:20 p.m.






-------------------------------------------------------
SeaGate Reporting Service, Inc.
Registered Professional Reporters
1636 National Bank Building
Toledo, Ohio 43604
(419)241-2070

E X H I B I T S

Plaintiff's Exhibit A . . . . . . . . . . . 3
Plaintiff's Exhibit B . . . . . . . . . . .41

Ljd re@
A

0 (o
.23

6@ 3Y"

32 CJ Ij
actworz, 9.2-5-elpi t4@
11,141'-Y @/o d a@ SI-10
f@ 4 6@4 eat, IWZ4 40
1@el@ 4@446@1

3




1 APPEARANCES:

2 on behalf of the Plaintiffs:

3 CONNELLY, SOUTAR & JACKSON:
Steven P. Collier
4 2100 Ohio Citizens Bank Building
Toledo, Ohio 43604 (419)243-2100
5
on behalf of Defendant Tiffin Mercy Hospital:
6
Arthur F. Graham
7 716 West Market Street
Tiffin, Ohio 44883 (419)447-7966
8



10 STEVEN M. DONN, M.D.,

11 being first duly sworn, testified and said as follows:

12 CROSS EXAMINATION

13 BY MR. COLLIER:

14 Q Would you please state your name for the record.

15 A Steven M. Donn, M.D.

16 Q And your professional address?

17 A Box 0254, L-3023 Women's Hospital, University of

18 Michigan Medical Center, 1500 East Medical Center

19 Drive, Ann Arbor, Michigan, 48119-0245.

20 Q I assume that's where we're at here today for your

21 deposition, the address you have just given?

22 A Actually we're sitting in Room L-3216, which is not

23 my mailing address but my office address.

24 Q Doctor, do you have a curriculum vitae that's

25 current?

4

1 A Yes.
2 Q Do you have a copy of that available?
3 MR. GRAHAM: I have it and
4 it's very thick, and I can either make
5 copies and get copies to everyone or you
6 can. whichever you want to do.
7 (Plaintiff's Exhibit A marked for
8 identification.)
9 Q Doctor, Mr. Graham has just provided me here what
10 has been marked as Exhibit A. Is that your
11 curriculum vitae?
12 A Yes.
13 Q Your medical school training is from where?
14 A Tulane University.
15 Q And that was followed directly by your internship,
16 a year at University of Vermont; is that correct?
17 A Not entirely.
18 Q Okay. Would you explain the gap, I guess?
19 A I graduated from medical school in November of 1974
20 and my internship did not start until actually June
21 23rd of 1975.  For about a six month period between
22 graduation and start of internship I worked for Dr.
2 3 Harry Scherkey who was at that time chairman of the
24 department of pediatrics at Tulane, and I did
25 things such as help him work on a textbook he was
5

1 preparing, proofread tables, worked in the
2 pediatric therapeutic section at Tulane University.
3 Q Was that an early graduation date or a later than
4 on schedule?
5 A Early.
6 Q How did you accomplish that?
7 A The medical school had tried a pilot program in
8 which the last two years of medical school were
9 done consecutively without vacation time to allow
10 people to graduate early and start their post
11 doctoral training, save tuition money. I don't
12 know whether they are still doing it but I agreed
13 to start it.
14 Q So in July of 1975 you started at the University of
15 Vermont your internship?
16 A Yes, although again, technically at that time the
17 internship had been phased out. It was really a
18 three-year residency program in pediatrics.
19 Q And you completed that in 1978 then?
20 A Yes.
21 Q And thereafter you began your fellowship at the
22 University of Michigan Medical Center; is that
2 3 correct?
24 A Yes.
25 Q Have you been here at the University of Michigan
6

1 ever since in one capacity or another?
2 A Yes.
3 Q And your current position here at the University of
4 Michigan is what?
5 A I'm an associate professor in the department of
6 pediatrics and the medical director of the neonatal
7 intensive care unit.
8 Q Are you board certified in any specialty?
9 A Board certified in pediatrics and sub-board
10 certified in neonatal-perinatal medicine.
11 Q What was the extent of your training in the
12 neonatal-perinatal medicine, the one-year
13 fellowship or anything beyond that?
14 A It was a two-year fellowship.
15 Q Anything beyond that?
16 A I have been involved in continuing medical
17 education ever since.
18 Q And you did sit for the boards in that and pass
19 those on the first attempt?
20