I   State of Ohio,
                                          S S
          2   County of Cuyahoga.

          3                                 - - -

          4                     IN THE  COURT  OF COMMON PLEAS

          5                                 - - -

          6   James Peskin,  a  minor,  etc.,
              et al.,
          7
                                Plaintiffs,
          8                                       Case No. 148870
                     VS.
          9                                       Judge Gaughan
              The Mt.  Sinai Medical Center,
        10    et al.,

        11                      Defendants.

        1 2                                 - - -

        13             DEPOSITION OF WILLIAM   A. COOK, M.D.

        14                 THURSDAY, JANUARY   10, 1991

        1 5                                 - - -

        16    The deposition of William A. Cook, M.D., a witness

        17    herein, called by the Plaintiffs for exarnination

        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 agreernent of counsel and without further

        22    notice or other legal formalities, at Akron General

        23    Medical Center, 400 Wabash Avenue, Akron, Ohio,

        24    commencing at 7:40 p.m., on the day and date above

        25    set forth.



                                MORSE, GANTVERG & HODGE

                                                                                                                             I

                                                            2

          1  APPEARANCES:

          2  Ori behalf of the Plaintiffs:

          3         Richard J. Berris, Esq.
                    Laurence Powers, Esq.
          4         Weisman, Goldberg, Weisman & Kaufman
                    1600 Midland Building
          5         Cleveland, Ohio    44115

          6  On behalf of Defendants Gerald Weinberg, M.D. and
                LeRoy Dierker, M.D.;
          7
                    John M. Baker,  Esq.
          8         Weston, Hurd, Fallon, Paisley & Howley
                    2500 Terminal  Tower
          9         Cleveland,  Ohio  44113

        10              and

        11          Emery J. Leuchtag, Esq.
                    Gallagher, Sharp, Fulton & Norman
        12          630 Bulkley Building
                    Cleveland,  Ohio  44115
        13
             On behalf of Defendants Cleveland Anesthesia Group;
        14      Sidney Katz, M.D. and Joyce Hardaway, M.D.:

        15          Robert G. Quandt,  Esq.
                    Quandt, Giffels, Buck & Rodgers
        16          800 Leader  Building
                    Cleveland,  Ohio  44114
        17
             On behalf of Defendant Mt.  Sinai Medical Center:
        18
                    Francis X. Gardner, Esq.
        19          Reminger &  Reminger
                    113 St. Clair  Building
        20          Cleveland,  Ohio  44114

        21

        2 2

        2 3

        2 4

        25



                              MORSE, GANTVERG   HODGE

                                                           3
         I                   WILLIAM A. COOK, 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                     CROSS EXAMINATION
         7   BY MR.  BERRIS:
         8   Q.     State your full name, please?
         9   A.     William A. Cook.
        10   Q.     You are a physician specializing in
        11   obstetrics and gynecology?
        12   A.     Correct.
        13          Are you a perinatologist?
        14   A.     No, sir.
        15   Q.     I have been provided with a copy of your
        16   curriculum vitae, which I am looking for right now.
        17          Is this an up-to-date curriculum vitae?
        18   A.     You will have to let me see it.
        19                 (Thereupon, the document was handed to
        20          the witness and handed back to Mr. Berris.)
        21   A.     (Continuing) Yes, it is.
        22   Q.     I am not going to go into detail with regard
        23   to your curriculum vitae, but can you tell me what
        24   your present position is?
        25   A.     Yes, I am -- well, I have several positions.

                              MORSE, GANTVERG & HODGE
                                                            4
         1   I am chairman of the department of obstetrics and
         2   gynecology, Akron General Medical Center, chairman
         3   of the department of obstetrics and gynecology at
         4   Northeastern Ohio Universities College of Medicine,
         5   and dire