1 IN THE UNITED STATES DISTRICT COURT

2 FOR THE NORTHERN DISTRICT OF OHIO

3 EASTERN DIVISION 6

4 - - -

5 SANDRA CIRINO, et al.,

6 Plaintiffs,

7 V. Case No. 1:90CV1225
Judge Manos
8 UNITED STATES OF AMERICA,

9 Defendant.

10 - - -

11 DEPOSITION OF DR. DEBORAH EWING-WILSON

12 WEDNESDAY, DECEMBER 19, 1990

13 - - -

14 The deposition of DR. DEBORAH EWING-WILSON, a

15 witness, called for examination by the Plaintiffs,

16 under the Federal Rules of Civil Procedure, taken

17 before me, Janet M. Hoffmaster, Registered Professional

18 Reporter and Notary Public in and for the State of

19 Ohio, pursuant to notice and agreement of counsel, at

20 Kaiser Permanente Medical Center-West Side, 12301 Snow

21 Road, Parma, Ohio, commencing at 2:15 p.m., the day and

22 date above set forth.

23 - - -

24

25

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1 APPEARANCES:

2
On behalf of the Plaintiffs:
3
HOWARD D. MISHKIND, ESQ.
4 Weisman, Goldberg, Weisman & Kaufman
1600 Midland Building
5 Cleveland, Ohio 44115

6
On behalf of the witness, Dr. Deborah Ewing-Wilson:
7
LYNN L. MOORE, ESQ.
8 Gallagher, Sharp, Fulton & Norman
7th Floor, Bulkley Building
9 Cleveland, Ohio 44115

10
On behalf of the Defendant:
11
KATHLEEN ANN SUTULA, ESQ.
12 KENT W. PENHALLURICK, ESQ.
United States Department of Justice
13 Office of the United States Attorney
1404 East Ninth Street, Suite 500
14 Cleveland, Ohio 44114

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INDEX

2 PAGES

3
EXAMINATION BY MR.  MISHKIND 4
4

5

6

7 PLAINTIFF'S EXHIBITS MARKED

8 1 4
2 26
9 3 32
4 44
10 5 54
6 66
11

12

13

14
OBJECTIONS BY
15
MS. SUTULA 30
16 43
56
17
MS. MOORE 50
18 58
61(2)
19

20

21

22

23

24

25

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1 DR. DEBORAH EWING-WILSON
2 a witness, called for examination by the Plaintiffs,
3 under the Rules, having been first duly sworn, as
4 hereinafter certified, deposed and said as follows:
5 (Thereupon, Plaintiff's Exhibit I to the
6 deposition of Dr. Deborah Ewing-Wilson was
7 marked for identification)
8 MR. MISHKIND: Let the record
9 reflect that the plaintiffs in the case of
10 Sandra Cirino, et al. versus United States of
11 America are taking the deposition of Dr. Deborah
12 Ewing-Wilson, and that the deposition is being
13 taken pursuant to notice and with the
14 cooperation of Counsel Lynn Moore, counsel for
15 Kaiser, and the doctor is here for purposes of
16 the deposition.
17 To the extent that there are any defects
18 that may exist in notice or service, may we have
19 a waiver of same?
20 MS. SUTULA: From u