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

I

2



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

15

16

17

18

19

20

21

22

23

24

25

3



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

4

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 us?
21 MR. MISHKIND: From you.
22 MS. SUTULA: Sure.
23 EXAMINATION
24 BY MR.  MISHKIND:
25 Would you state your full name for the record,





I
5

1 please?
2 A. Deborah Ewing-Wilson.
3 Q. You are a physician?
4 A. Yes, I am.
5 Q_ Do you have an area of specialization?
6 A. Adult neurology.
7 Q. Doctor, before the deposition began you were
s kind enough to provide me with a copy of your
9 curriculum vitae, and was the curriculum vitae that you
10 provided me with current?
11 A. Yes, it is.
12 Q. And does it contain all of your publications,
13 your professional societies?
14 A. That's correct.
15 Q. Professional training and Board certifications?
16 A. Yes, it does.
17 Q_ I am going to show you a document which I've had
18 marked as Plaintiff's Exhibit 1, Dr. Ewing-Wilson, a
19 three-page document.
20 Is this a copy of your current curriculum vitae?
21 A. Yes, it is.
22 Q. You did your training, as I can gather from
23 reviewing the curriculum vitae, at least in part at the
24 Cleveland Clinic Foundation.
25 A. That's correct.
 6

1 You are also Board certified in neurology?
2 A. That's correct.
3 Q. How long have you been affiliated with Kaiser?
4 A. Since August of 1987.
5 Q. Do you hold a position within the department
6 here at Kaiser?
7 A. Active staff, Section of Neurology, Department
8 of Medicine, Ohio Permanente Medical Group.
9 Q- Obviously I am going to be asking you some
10 questions concerning a patient of yours by the name of
11 Steven Locigno.  Before I get to that, though, I want
12 to ask you some brief background questions, and I will
13 try to move as quickly as I can to Mr. Locigno, and
14 certainly you can refer to the chart as necessary in my
15 questioning.
16 A. Okay.
17 Q. In connection with your background and
18 experience, have you had occasion to treat patients who
19 are epileptics?
20 A. Yes.
21 Q. Are there different classifications of epilepsy?
22 A. Yes, there are.
23 Q. Can you give me the various classifications?
24 A. According to the international classification of
25 epilepsy there are two distinct classes of seizures,
1 partial seizures which refer to seizures which begii.
2 a localized area of the brain, and generalized seizures
3 which have a more diffuse localization, may begin in
4 deeper midline structures.
5 Within those two broad classifications there are
6 several other different types of seizures.
7 For instance, under partial, I will try to be
8 brief, there are.comp