STATE OF OHIO
                                 COUNTY OF CUYAHOGA
                              COURT OF COMMON PLEAS


             SHEENA TERRY, etc., et al.,   )
                                           )
                           Plaintiffs,     )
                                           )
                         VS.               )    CASE NO. 193,206
                                           )    JUDGE CARL CHARACTER
             KAISER FOUNDATION HEALTH      )
             PLAN OF OHIO, etc., et al.,   )
                                           )
                           Defendants.     )




                       Videotaped deposition of HOWARD S. SCHUB,
                  M.D., taken on behalf of the Defendants, pursuant
                  to the stipulations agreed to herein, before
                  Nancy G. Lucas, Certified Court Reporter and
                  Notary Public, at 5455 Meridian Mark Road, Suite
                  530, Atlanta, Georgia, on the 23rd day of November,
                  1992, commencing at the hour of 5:25 p.m.



                       HUSEBY & AssociATES, INC.

                           CERTIFIED SHORTHAND COLJRT REPORTERS

              1401 Peaclitree Sireet, N. F.          459 F. F. Butler Parkway, S. E.
                   Suite 360                              P.O. Box 719
               Atlaiiia, Georgii 30309                Giiiiesville, Georgia 30503
                  (404) 875-0400                         (404) 536-7028

                                                                   2


          1                  INDEX TO EXAMINATION

          2                                          Page

          3 EXAMINATION BY MR.  SWITZER                  3
            EXAMINATION BY MR.  BERRIS                  24
          4 FURTHER EXAMINATION BY MR.  SWITZER         76

          5

          6

          7

          8

          9

          10

          11

          12                   INDEX TO EXHIBITS

          13           Plaintiff's Exhibit 1            45

          14

          15

          16

          17

          18

          19

          2 0

          21

          2 2

          2 3

          2 4

          2 5

                         HUSEBY & ASSOCIATES COURT REPORTERS
                                   (404) 875-0400

                                                                     3


          I  APPEARANCES OF COUNSEL:
                 On Behalf  of the Plaintiffs:
          2
                            RICHARD BERRIS, ESQ.
          3                 1600 Midland Building
                            Cleveland, Ohio  44115
          4
                 On Behalf  of the Defendants:
          5
                            DONALD H. SWITZER, ESQ.
          6                 Weston Hurd Fallon Paisley & Howley
                            2500 Terminal Tower
          7                 Cleveland, Ohio  44113-2241

          8  videographer:  Ms. Gloria J. Shepard

          9                             - - -
          10                 MR. SWITZER:  Can we stipulate, Richard,
          11 as to the competency of two court reporters here and the
          12 waiver of the reading and signing and the filing of the
          13 deposition transcripts before trial?
          14                 MR. BERRIS:  Yes.
          15                 DR. SHUB:  I'll waive signature.
          16                 MR. SWITZER:  I can't of anything else
          17 right now.
          18                 HOWARD S. SCHUB, M.D.
          19 being first duly sworn, was examined and deposed as
          20 follows:
          21                       EXAMINATION
          22 BY MR.  SWITZER:

          23      Q     Would you state your full name, Doctor?

          24      A     Howard S. Schub.

          25      Q     Dr. Schub, as you are aware, my name is Don

                         HUSEBY & ASSOCIATES COURT REPORTERS
                                    (404) 875-0400

                                                                     4
          1  Switzer.  i represent the Defendants in this case.
          2             Would you tell the jury what your profession
          3  is?
          4        A    i'm a pediatric neurologist.
          5        Q    What is your age, Doctor?
          6        A    42.

          7        Q    And would you tell the jury your current

          8  employment?

          9        A    I'm a member of  Child  Neurology  Associates

          10 which is a pediatric neurology practice in Atlanta,

          11 Georgia that consists of four physicians.

          12       Q    How long have you been in the private

          13 practice of pediatric neurology?

          14       A    Eight an