STATE OF 01110,
SS;
3 COUNTY OF LORAIN.

4
IN THE COURT OF COMMON PLEAS
5

6
Sandra F. Kirschner, et al.,
7
Plaintiffs,

v s No. 89277-82
9
The Elyria Memorial Hospital,
I 0 et al. ,

11 Defendants.

1 2

1 3

1 4

15 Deposition of HAROLD L. REKATE, VI.D., taken

16 as it under examination before Angelika P. Veres,

17 a Notary Public within and for the State of Ohio,

18 at the offices of Harold L. Rekate, M.D., Room

19 5206, University Hospital, Cleveland, Ohio, at

20 2:40 p.m., Monday, the 7th day of November, 1983,

21 pursuant to stipulations of counsel, on behalf of

22 the Defendant Elyria Memorial Hospital.

23 ROBERT J. RUA & ASSOCIATES
Court Reporters
/2 4 700 Superior Building
Cleveland, Ohio 44114
25 241-5500

1 APPEARANCES:

2 Weisman, Goldberg & Weisman, by
Mr. R. Eric Kennedy,
3
on behalf of the Plaintiffs;
4

5 Kitchen, Messner & Deery, by
Mr. Steven W. Albert,

on benalt of the Defendant
7 Elyria Memorial Hospital;

8
Ashenbach, Tattersall, Gallagher & Glavas, by
9 Mr. J. C. William Tattersall,

10 on behalf of the Defendant
Elyria Emergency Medical Services,
Inc.

1 2 - - -

1 3
14 S T I P U L A T I 0 N S

15 It was stipulated by and between counsel

16 for Plaintiffs and Defendants that this deposition mai

17 be taken in stenotypy by Angelika P. Veres, and that

18 all requirements of the Ohio Rules of Civil Procedure

19 with regard to notice of time and place of taking

20 this deposition are waived.

21 - - -

2 2

23

2 4

2 5

 3

2 HAROLD L. REKATE, M.D., of lawful
3 age, called by the Defendant Elyria
4 Memorial Hospital for the purpose of
5 examination, as provided by the Ohio
6 Rules of Civil Procedure, being by
7 me first duly sworn, as hereinafter
8 certified, deposed and said as follows:
9 - - -
10 MR.  ALBERT: I'm Steve Albert,
11 Doctor, and I'm going to ask you a
12 number of questions pursuant to Rule
1 3 26(B) deposition, which is a rule in
14 the Ohio Rules of Civil Procedure, and
15 1 have discussed with Mr. Kennedy your
16 fees, et cetera, concerning this, ana
17 to alleviate any fears which you may
18 have, I wish to assure you that the
19 Rule provides for reasonable payment,
20 you know, reasonable charges, ana we
21 will guarantee, on behalf of my client
2 2 and my firm, the payment of reasonable
23 charges with respect to this particular
2 4 aeposition.  I wanted to put that on
2 5 the regard.

- - - - - - - - - - - - - -
4
1 1 told Mr. Kennedy that I would

2 assure you in case you had had former

3 experi