1 State of Ohio,
SS:

2 County of Cuyahoga.

3 - - -


4 IN THE COURT OF COMMON PLEAS

5 - - -


6 Rudy Seuffert, et al.,

7 Plaintiffs,
Case No. 193581
8 VS.
Judge Cleary
9 Kaiser Foundation Hospitals,
et al.,
10
Defendants.
I 1

1 2 - - -


13 DEPOSITION OF MARTIN RESNICK, M.D.

14 FRIDAY, MAY 31, 1991

1 5 - - -


16 The deposition of Martin Resnick, M.D., a witness

17 herein, called by the Plaintiffs for examination

18 under the Ohio Rules of Civil Procedure, taken

19 before me, Ivy J. Gantverg, Registered Professional

20 Reporter and Notary Public in and for the State of

21 Ohio, by agreement of counsel and without further

22 notice or other legal formalities, at University

23 Hospitals of Cleveland, 2074 Abington Road,

24 Cleveland, Ohio, commencing at 9:30 a.m., on the day

25 and date above set forth.




MORSE, GANTVERG & HODGE

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2

1 APPEARANCES:

2 On behalf of the Plaintiffs:

3 Paul M. Kaufman, Esq.
Weisman, Goldberg, Weisman & Kaufman
4 1600 Midland Building
Cleveland, Ohio 44115
5
On behalf of the Defendants:
6
James F. Sweeney, Esq.
7 Gallagher, Sharp, Fulton & Norman
Bulkley Building - Seventh Floor
8 Cleveland, Ohio 44115

9

10

11

12

13

14

15

16

1 7

18

19

2 0

21

22

2 3

2 4

2 5


MORSE, GANTVERG & HODGE

-----I----------- --------- --

3
1 MARTIN RESNICK, M.D.
2 a witness herein, called by the plaintiffs for
3 examination under the Rules, having been first duly
4 sworn, as hereinafter certified, was deposed and
5 said as follows:
6 MR. KAUFMAN: Let the record reflect
7 that this is Friday, May 31st, 1991, and we
8 are at University Hospitals of Cleveland for
9 the purpose of taking the discovery
10 deposition of Dr. Martin Resnick, who has
11 been identified as an expert on behalf of the
12 defendant in the within captioned case; that
13 this deposition is being taken for purposes
14 of discovery pursuant to Rule 26(B)(4)(b),
15 and that the deposition has been arranged by
16 agreement of counsel and Dr. Resnick, and
17 there should be a waiver as to any defect in
18 notice or service; is that agreed?
19 MR. SWEENEY: That is correct.
20 CROSS EXAMINATION
21 BY MR. KAUFMAN:
22 Q. Dr. Resnick, just for the record, would you
23 state your full name, please?
24 A. Martin I. Resnick.
25 And you are a physician?

MORSE, GANTVERG & HODGE
4
1 A Yes, I am.
2 Q- And your particular area of practice or
3 specialty?
4 A. Urology.
5 Q- Dr. Resnick, have you been involved in a
6 deposition proceeding before?
7 A. Yes, I have.
8 Q. So you are familiar with the basic procedure
9 that is involved?
10 A. Yes, I am.
11 Q. I am going to ask you some questions this
12 morning. If at any time I ask you a question that
13 is not clear to you, please do not try to answer it.
14 Tell me that it is unclear, or garbled, or mixed up,
15 or doesn't make any sense, or whatever, and I will
16 attempt to clarify it, or rephrase it for you, or we
17 can even have the court reporter read it back. But
18 if you don't understand my question, please don't
19 answer it, okay?
20 A. That is fine.
21 Q. We can have that agreement.
22 If you give an answer, Miss Gantverg is going
23 to record your answer, and I am going to assume you
24 understood the question.
25 A. I understand.

MORSE, GANTVERG & HODGE
----- -----
5
1 Also, from your prior experience you would
2 know that you must respond verbally or audibly, as
3 the court reporter can not interpret nods of the
4 head, or shrugs of the shoulders, or things like
5 that, so please speak your answers out loud.
6 A. I understand.
7 okay, good.
8 I have just been handed your curriculum
9 vitae, which is quite extensive, and what I will ask
10 you about it, is this a current one, the curriculum
1 1 vitae?
12 A. Yes, it is up-to-date in the last few months.
13 So it is current in the last few months.
14 What is your age?
15 A. Forty-eight.
16 Q. How long have you been practicing urology?
17 A. I completed my residency in 1975.
18 Q. And at the current time, or at least
19 according to your letterhead on the letter that was
20 supplied to me addressed to Mr. Sweeney dated
21 February 4th, 1991, you are currently chief of the
22 division of urology here at University Hospitals?
23 A. That is correct.
24 How long have you been in that position?
25 A. Since September, 1981.

MORSE, GANTVERG & HODGE
 6
1 How many urologists are on the staff at
2 University Hospital?
3 A. On the full-time faculty of the university,
4 we have seven full-time urologists. Practicing
5 primarily at University Hospital, there are four.
6 Q. Your various lists of publications, articles,
7 chapters in books, presentations, et cetera, run on
8 for many pages in your CV.  What I would ask you
9 specifically is if you have done any publishing or
10 writing or research that would be identified in
11 these various lists