1 IN THE COURT OF COMMON PLEAS
I 0 7@
2 CUYAHOGA COUNTY, OHIO

3 SHEENA TERRY, etc,

4  Plaintiffs,
Civil Action No:
V
193206
6 KAISER FOUNDATION HEALTH PLAN
OF OHIO, et al,
7
 Defendants


9 The deposition of STEVEN M DONN, MD,

10 taken in the above-entitled cause before Susan A Deer,

11 CSR-2049, RPR-CP, CM, Notary Public in and for the

12 County of Washtenaw, State of Michigan, at Hall and

13 Deer, 215 East Washington Street, Ann Arbor, Michigan,

14 on November 19, 1992, commencing at or about 4:45 pm

15 APPEARANCES:

16 WEISMAN, GOLDBERG & WEISMAN
(By: Richard J Berris)
17 1600 Midland Building
Cleveland, Ohio 44115
18
Appearing on behalf of the Plaintiffs
19
WESTON, HURD, FALLON, PAISLEY & HOWLEY
20 (By: Warren Rosman)
2500 Terminal Tower
21 Cleveland, Ohio 44113

22 Appearing on behalf of the Defendants

23

24

25



HALL AND DEER
(800) 321-3904

2

1 N D E X
2 WITNESS:
3 STEVEN M DONN, MD Page
4 Examination by Mr Berris 3
5
6
7
8
9
10
11
12
13 EXHIBITS:
14 None
15
16
17
18
19
20
21
22
23
2 4
25

HALL AND DEER
(800) 321-3904

1
3


1 Ann Arbor, Michigan

2 November 19, 1992

3 At or about 4:45 pm

4

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

6 having first been duly sworn or affirmed by the

7 Notary Public, was examined and testified as follows:

8 EXAMINATION

9 BY MR  BERRIS:

10 Q State your full name, please

11 A Steven Mark Donn, MD

12 Q And your residence address?

13 A 5712 Woodridge Court, Ann Arbor, Michigan 48103

14 Q I have a copy of your CV, so I'm not going to go

15 through that in any great detail

16 How long have you been at the University of

17 Michigan?

18 A Since July lst of 1978

19 Q Did you do your -- I didn't notice Did you do your

20 residency here?

21 A No

22 Q Where did you do your residency?

23 A University of Vermont

24 Q And what is the -- how is it that you ended up at

25 University of Michigan, offered a position here or --


HALL AND DEER
(800) 321-3904

4

1 A I came back to Michigan to do my fellowship in neonatal
2 and perinatal medicine  And I was offered a position
3 when I completed that
4 Q And what's the hospital, University Hospital?
5 A University of Michigan Hospitals
6 Q Is there a name of the pediatric hospital?
7 A Which one?
8 Q I don't know because -- you tell me
9 A There are several pediatric entities  CS Mott
10 Children's Hospital, Women's Hospital, Maternal and
11 Child Health Center, and Holden Perinatal Hospital
12 Q Is -- are you out of Holden Perinatal Hospital?
13 A Well, I'm technically in all four of them
14 Q Okay You have the neonatal intensive care unit?
15 A That's correct
16 Q Is it a tertiary care unit?
17 A It's tertiary and beyond It's actually a Quaternary
18 or Level IV unit
19 Q What's the significance of that? What does that mean?
20 A About 25 percent of our patients are referred from
21 other Level III hospitals for services that are not
22 available in typical Level III centers such as
23 extracorporeal membrane oxygenation, high frequency
24 ventilation, hemodialysis, other sorts of things like
25 that

HALL AND DEER
(800) 321-3904

I
1 Q You're Board certified in what?
2 A Pediatrics
3 Q Are you -- is there a subspecialty in neonatology?
4 A There is a sub Board in neonatal and perinatal
5 medicine, which I am also certified
6 Q You're Board certified?
7 A Sub Board certified
8 Q When did you become Board certified in neonatal and
9 perinatal --
10 A Perhaps you misunderstood There is no Board It's a
11 sub Board in neonatal and perinatal medicine
12 Q How do you apply and become Board -- when you say it's
13 a sub Board, what do you do to become certified?
14 A One first has to become certified in general
15 pediatrics; secondly, to complete a fellowship training
16 program in an accredited program of neonatal and
17 perinatal medicine; and, third, to pass an
18 examination
19 Q And when did you become certified?
20 A 1981
21 Q And in pediatrics?
22 A Same year
23 Q Do you know Dr Alfred Brann?
24 A Yes, I do
25 Q How do you know him?

HALL AND DEER
(800) 321-3904

7 1 - I - -
6


1 A Dr Brann is a neonatologist who has had interests

2 similar to those of my own in the area of neonatal and

3 perinatal asphyxia  We first became acquainted through

4 a collaboration in what was hoped to be a multicenter,

5 national trial, which did not come to pass

6 Dr Brann subsequently invited me to come to

7 Emory as a consultant and recruited me for a position

8 there And I have also invited him to speak at

9 meetings in Michigan

10 Q Okay  Do you consider Dr Brann to be generally

11 authoritative and reliable in the field of

12 neonatal/perina