STATE OF OHIO,

                                  )  SS:
          2  COUNTY OF CUYAHOGA.  )                                         i

          3                          - - -

          4             IN THE COURT OF  COMMON PLEAS

          5                         - - -

          6  PRYSE THOMAS, et  al.,

          7
                           Plaintiffs,

          8
                   VS.                      case No. 36911
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             JOHN C. ELDER, M.D., INC.,

          10
                et al.,

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                           Defendants.

          12

          13

                  Deposition of DR.  DALE COWAN, a Witness called
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             by the Defendants pursuant to the Ohio Rules of Civil
          is
             Procedure, taken before me, George L. Blam, a
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             Registered Professional Reporter and Notary Public for
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             the state of Ohio, pursuant to notice of counsel, at
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             the office of Dr. Dale Cowan at Marymount Hospital,
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             12300 McCracken Road, Garfield Heights, Ohio, at 11:00
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             a.m., on Saturday, the 24th day of November, 1984.
          21

          22

          23

          24

          25


                                 GEORGE L. SLAM
                                  COURT REPORTERS
                                 505 LEADER EUILDING
                                 CLEVELAND.  OHIO 44114

          I APPEARANCES:

          2                                                            2

                 On behalf of the Plaintiffs:

          3         Weisman, Goldberg & Weisman:

          4
                      Robert E. Kennedy, Esq.

          5

          6
                 On behalf of the Defendants:
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                    Reminger & Reminger:
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                      Gary H. Goldwasser, Esq.

                    Rhoa, Pollen, Rawlin & Johnson:
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                      Albert J. Rhoa, Esq.
          11

          12                  DR. DALE COWAN,
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          14     a Witness called by the Defendants pursuant to

                 the Ohio Rules of Civil Procedure, was examined

                 and testified as follows:
          16

          17                 CROSS-EXAMINATION

            BY MR.  GOLDWASSER:
          18
            Q    Doctor, for the record, your name?
          19
            A    Dale Cowan.
          20

          210    We know you are a medical doctor and it's my

                 understanding you specialixe in oncology, correct?
          22
            A    I specialize in internal medicine, hematology and
          23

          24     medical oncology.

          25Q    What percentage of your practice is devoted to


                                 GEORGE L. BLAM
                                  COURT REPORTERS
                                 505 LEADER BUILDING
                                 CL.EVELANC). OHIO 44114

              A   One hundred percent.                                3
              Q   Doctor, it's been represented to me by
          3
                  Mr. Kennedy that you have been retained  to
          4
                  testify at time of arbitration or trial  in

                  particular as to the standard of care of my

                  client, Dr. Elder.  Is that your understanding
          7
                  as well?
          8
              A   That's correct.
          9

          10      In preparation for creating and drawing opinions

                  as to Dr. Elder's standard Of care, wbat

                  material have you reviewed?
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              A   The materials I reviewed included the medical
          13
                  records and office records of the patient and
          14
                  the depositions of three individuals.

                  Do you have your file there?
          16  A   Yes.
          17
              Q   Why don't you just read through it so we have
          18      it on the record as to what you reviewed.
          19
              A   My file here merely consists of copies of the
          20
                  depositions of Dr. Shannon, Jane Thomas and
          21

          22      of Dr. Elder, and this is my own letter which

          23      I wrote April 25, 1983, which summarized my

          24      opinion after reviewing the me ical records.

          25      What medical records have you reviewed?


                                  COURT REPORTERS
                                 SOS LEADER BUILDINO
                                CLEVELAND, OHIO 44114
          I       the medical records so I haven't kept them.          4


          2       They were the hospital records and the office


          3       records of Dr. Elder.


          4  Q    There are several admissions to Huron Road