(A           3@
           1              IN THE COURT OF COMMON PLEAS
           2                OF @IUYAHOGA COUNTY, OHIO
           3   EUGENE FEDOR, et al.,
           4             Plaintiffs,
           5        VS.                     Case No. 75237
           6   JON HARDACRE, M.D.,
           7   and
           8   MOHAN BAFNA, M.D.,
           9   and
          10   COMMUNITY HOSPITAL OF BEDFORD,
          11             Defendants.
          1 2                      - - - -  -
          13            Deposition of DR.  MELVIN SHAFRON, a
          14   witness herein, called by the Plaintiff
          15   for examination under the statute,  taken  before
          16   me, Sheila K Moore, a Registered Professional
          17   Reporter and Notary Public in and for  the  State
          18   of Ohio, pursuant to notice and  stipulations  of
          19   counsel and by agreement of counsel, at  the  Mt.
          2 0  Sinai Medical Building, 26900 Cedar Road,
          21   Cleveland, Ohio, on Friday, June 20th,  1986,  at
          22   5:00 o'clock p.m.
          2 3                      - - - -  -
          2 4
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                                  Cefara"i, Rennillo
                                   & Ma"hews Coort Reporters
                                                                2
            1  APPEARANCES:
            2        On behalf of the Plaintiff:
            3            Greene &  Hennenberg,  by
            4            WILLIAM GREENE, ESQ.
            5                  and
            6            JEAN McQUILLAN, ATTORNEY AT LAW
            7            801 Bond  Court  Building
            8            Cleveland, Ohio  44114
            9            687-0900
            10        On behalf of the Defendant Dr. Hardacre:
            1 1          Reminger &  Reminger,  by
            12           GARY GOLDWASSER, ESQ.
            13           300 Leader Building
            14           Cleveland, Ohio  44114
            1 5          6 8 7 - 1 3 1 1
            16        on behalf of the Defendant Dr. Bafna:
            17           Arter & Hadden, by
            18           RAYMOND J.  MARVAR,  ESQ.
            19           1100 Huntington Building
            20           Cleveland, Ohio  44115
            2 1          6 9 6 - 1 1 0 0
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            2 5
                                   Cefaratti, Rennillo
                                    & Mc3tthews CourtReporters
                                                                         3

              1         on behalf of the Defendant Community

              2         Hospital of Bedford:

              3             Kitchen, Messner & Deery, by

              4             TIMOTHY X. McGRAIL, ESQ.

              5             1305 The Superior Building

              6             Cleveland, Ohio  44114

              7             2 4 1 - 5 6 1 4

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                                        Cefaratti, Rennillo
                                         & Matthews Court Reporters

                                                             4

         1           DR. MELVIN SHAFRON, of lawful age,

         2   called for examination, as provided by the Ohio

         3   Rules of Civil Procedure, being by me first

         4   duly sworn, as hereinafter certified, deposed

         5   and said as follows:

         6            EXAMINATION OF DR.  MELVIN SHAFRON

         7   BY-MR.  GREENE:

         8   Q.     Would you state your name for the record,

         9   please.

         10  A.     Melvin Shafron.

         11  Q.     Dr. Shafron, your name has been given to

         12  me as  an expert who will testify on behalf of

         13  the defendant Dr. Hardacre in a case that I am

         14  the plaintiff's counsel on; Eugene Fedor versus

         15  Bedford Community Hospital and Dr. Hardacre.

         16         You wrote a letter for Mr. Goldwasser;

         17  did you not?

         1 8 A .    Yes, sir.

         19  Q.     Can you tell me what materials you relied

         20  on in  writing that correspondence?

         21  A.     I reviewed the records that I have here,

         22  I saw  the patient's x-rays which were taken

         23  before he was transferred from Bedford Hospital.

         24  Q.     Anything else?

         25  A.     I revi.ewed the