State of Ohio,
         2     County of Cuyahoga)
         3                             - - -
         4                 IN THE COURT OF COMMON PLEAS
         5                             - - -
         6     MARY PERNA, et al,
         7                   Plaintiffs,
         8           V                           Case No 152062
         9     JOHN J SMITH, MD,
       10                   Defendant
       11
       12             DEPOSITION OF ADRIAN M SCHNALL, MD
       13                 WEDNESDAY, SEPTEMBER 20, 1989
       14
       15      The deposition of Adrian M Schnall, MD, a
       16      witness, called for examination by the Plaintiffs,
       17      under the Ohio Rules of Civil Procedure, taken
       18      before me, Kathryn A Keeler, a Registered
       19      Professional Reporter and Notary Public within and
       20      for the State of Ohio, pursuant to notice, at the
       21      offices of Cleveland Physicians, Inc, 1611 South
       22      Green Road, South Euclid, Ohio, commencing at 3:30
       23      pm, the day and date above set forth
       24                              - - -
       25
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        1     APPEARANCES:

        2     On behalf of the Plaintiffs:

        3     RICHARD BERRIS, ESQ
              Weisman, Goldberg, Weisman & Kaufman
        4     1600 Midland Building
              Cleveland, Ohio  44114
        5
              On behalf of the Defendant:
        6
              Robert D Warner, Esq
        7     Reminger & Rominger Co, LPA
              The 113 Building
        a     Cleveland, Ohio  44114

        9                         - - -

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         1                    ADRIAH M SCHNALL, MD
         2     a witness, called for examination by the Plaintiffs,
         3     under the Rules, having been first duly sworn was
         a     examined and testified as follows:
         5                       CROSS-EXAMINATION
         6     BY MR  BERRIS:
         7     Q      State your full name, please
         s     A      Adrian M Schnall, S-C-H-N-A-L-L
         9     Q      And you are a physician?
         10    A      I am a physician
         11    Q      Doctor, I am going to ask you some questions
         12    about your review of the matter of Mary Perna versus
         13    Dr John Smith  If any of my questions -- well
         14                 MR WARNER:       The estate of Mary
         15            Perna
         16            Now the estate since she's passed away
         17            If any of my questions are not clear, please
         18    lot me  know I will rephrase it  I assume if you
         19    have answered the question, you have done so because
         20    you understood them  In that fair?
         21    A      Fair
         22    Q      Do you know Dr Smith?
         23    A      No, I don't
         24    Q      I have been provided a copy of the curriculum
         25    vitae,  I haven't had a chance to look at it, but let
                                                             4-



        1     me take a quick glance and save sometime

        2            You are an internist?

        3     A     I am both an internist and an

        4     endocrinologist

        5            And the field of endocrinology deals with

              what?
        6

        7     A     The field of endocrinology deals with

        8     disorders of hormones, including the hormone

        9     insulin, which is absent in people with diabetes

       10     Q     The physicians with the most or one of the

       11     group of physicians with a great deal of expertise

       12     in matters of diabetes are endocrinologists?

       13     A     That's right

       14     0     Do you know whether or not Dr Smith is an

       15     endocrinologist?

       16     A     I don't know for certain, but I believe he is

       17     not

       18     Q     Do the acceptable standards of care for the

       19     treatment of diabetic foot ulcers and diabetic foot

       20     infections differ among internists,

       21     endocrinologists, peripheral vascular people?

       22     A     Well, there are some differences of opinion

       23     I would say between doctors more within the same

       24     specialty, even

       25            In other words, I think some endocrinologists

                                                              5

        1     would treat diabetic foot ulcers in one way and
        2     other endocrinologists would treat them another