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              1                         STATE OF OHIO
                                    COUNTY OF CUYAHOGA
              2                IN THE COURT OF COMMON PLEAS

              3 3HEENA TERRY, etc.,

              4                Plaintiff,
                                                      Case No. 193206
              5
                                                      Judge C.J. Character
              6 KAISER FOUNDATION, et  al.,

              7                Defendants.

              8

              9

 0           10                The Deposition of HERBERT J. GROSSMAN, M.D.,

 0           11     taken in the above-entitled cause before Mary A. Ansbro,

             12     CSR-35701 RPR, Notary Public in and for the County of

             13     Livingston, acting in the County of Washtenaw, State of

             14     Michigan, at 215 East Washington Street, Ann Arbor,

             15     Michigan, on November 9, 1992, commencing at or about

             16     8:10 a.m.

             17
 0
 Cc
             18 NPPEARANCES:

             19      WEISMAN, GOLDBERG & WEISMAN
                     (By:  Richard J. Berris)
             20      1600 Midland  Building
                     Cleveland, Ohio  44115
             21
                          Appearing on behalf of Plaintiff.
             22
                     WESTON, HURD, FALLON, PAISLEY & HOWLEY
             23      (By:  Warren Rosman)
                     25th Floor Terminal Tower
             24      Cleveland, Ohio  44113

             25           Appearing on behalf of Defendants.



                                        HALL AND DEER
                                        (800) 321-3904

                                                                            2





             2                       I  N   D   E   x

             3

             4

             5  QITNESS:

             6  IERBERT J. GROSSMAN, M.D.                             Page

             7

             8      Examination by Mr. Berris                            3

             9

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  9         15 EXHIBITS:

            16
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            17      Deposition Exhibit No. 1                            4
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            18

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            21

            22

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            25



                                       HALL AND DEER
                                       (800) 321-3904

                                                                                 3

              I                                             Ann Arbor, Michigan
              2                                             Movember 9, 1992
              3                                             At or about 8:10 a.m.
              4
              5        H E R B E R T     J.   G R 0 S S M A N,     M. D.,
              6  iaving first been duly sworn or affirmed by the Notary Public,
              7  qas examined and testified as follows:
              8                            EXAMINATION
              9  BY MR.  BERRIS:
             10      State your full name, please.
             11  k   Herbert J. Grossman.
             12      And you are a physician, correct?
             13  Pi  Yes.
             14      Doctor, I'm gonna ask you some questions today about
             15      your review of this matter of Sheena Terry versus
             16      Kaiser.  If any of  my  questions  are  not  clear  to  you,
             17      please let me know  and  I'll  rephrase  the  question  for
             18      you.
             19  A   Yes.
             20  Q   I'll assume that  if  you've  answered  the  question,  you
             21      have done so because you've understood the question; iB
             22      that fair?
             23  A   Yes.
             24  Q   I have a copy of your CV,  so  I'm  not  gonna  go  through
             25      your background and training in any great detail.

                                          HALL AND DEER
                                          (800) 321-3904

                                                                           4



             I               MR. BERRIS:  Why don't we just have this

             2     marked as an exhibit and we can attach it to the back

             3     of the deposition.

             4               (Deposition Exhibit No. 1

             5               was marked for identification)

             6  3Y MR.  BERRIS, CONTINUING:

             7  1  Your specialty is pediatric neurology?

             8  k  Yes.

             9     Are you board certified?

  0         10  k  In pediatrics.

  0
            11  )  When did you become board certified in pediatrics?

            12  k  1954.

            13