1    THE STATE OF OHIO,
                                         SS:  GORMAN, J.
           2    COUNTY OF CUYAHOGA.

           3                 IN THE COURT OF COMMON PLEAS

           4                       (CIVIL BRANCH)

           5    SHEENA TERRY, et al.         )
                                             )
           6                    Plaintiffs,  )
                                             )
           7    VS.                          )   Case No. 193206
                                             )
           8    KAISER  FOUNDATION  HEALTH   )
                PLAN OF OHIO, et al.         )
           9                                 )
                                Defendants.  )
          10
                                      --- 000---
          11             EXCERPT TRANSCRIPT OF PROCEEDINGS
                  CROSS-EXAMINATION OF WILLIAM DAVID GOLDIE, M.D.
          12                          --- 000---

          13                    Whereupon the following proceedings
                     were had in Courtroom 2-A, Lakeside Courthouse,
          14         Cleveland, Ohio, on Friday, January 8, 1993,
                     before the Honorable Judge Frank J. Gorman,
          15         and a Jury, upon the pleadings filed
                     heretofore.
          16                          --- 000---

          17
                APPEARANCES:
          18
                          Mr. Richard Berris, Esq., and Mr.
          19              Laurence Powers, Esq.,

          20                    On behalf of the Plaintiffs.

          21              Mr. Donald H. Switzer, Esq.,

          22                    On behalf of the Defendants.

          2 3

          24    JuliAnn M.  Adams,  RPR
                Official Court Reporter
          25    Cuyahoga  County,  Ohio

                                                                     2


                     FRIDAY MORNING SESSION, JANUARY 8, 1993

           2                          - - - - -

           3    . . . . .
           4                    THE COURT:           Please be seated.
           5           Mr. Switzer, you may cross examine.
           6                    MR. SWITZER:         Thank you, your
           7           Honor.
           8      CROSS-EXAMINATTON OF WILLIAM DAVID GOLDIE, M.D.
           9    BY MR. SWITZER:
          10    Q.     Good morning, Dr. Goldie.
          11    A.     Good morning.
          12    Q.     A little bit different setting than we were
          13    in Los Angeles?
          14    A.     Definitely, yes.
          15    Q.     Okay.  Doctor, you have been listed with
          16    various services that specialize in recruiting
          17    physicians for hire by attorneys in medical
          18    malpractice cases, haven't you?
          19    A.     I'm sorry, listed by what, different
          20    services?
          21    Q.     Yes.
          22    A.     I believe so.
          23    Q.     Services such as Medical Research Consultants
          24    out of Houston, Texas?
          25    A.     That's correct.
                                                                  3

           I   Q.      You have been affiliated with those in the
           2   past; is that right?
           3   A.      Yes, I have.
           4   Q.      Is it fair to say in the past two years  you
           5   reviewed approximately 80 to 90 medical  malpractice
           6   cases for attorneys?
           7   A.      I believe that's correct.
           8   Q.      Most of those have been more plaintiffs'
           9   attorneys?
         10    A.      That's probably true.
         11    Q.      Now, you're being paid today to testify by
         12    Mr. Berria; is that correct?
         13    A.      That's correct.
         14    Q.      Is it fair to say that about 30 to 40 percent
         15    of your income in the past two years has  been  from
         16    your involvement as a witness in  these  malpractice
         17    cases?
         18    A.      Yes.  That's true.
         19    Q.      Doctor, except for any articles you may bave
         20    written on pediatric neurology, you've not published
         21    any literature on the subject of perinatal or  birth
         22    asphyxia; is that correct?
         23    A.      That's correct.
         24    Q.      You have never lectured or given any
         25    presentation on perinatal or birth asphyxia to  your
                                                                     4

           I    peers at a national conference or seminar, have you?
           2    A.     That's  correct.
           3    Q.     You have no publications on the causes of
           4    cerebral palsy, do you?
           5    A.     No, I do not.
           6    Q.     You've never engaged in any formal research
           7    on the causes of cerebral palsy, have you?