STATE OF OHIO

              COUNTY OF LUCAS

                                COURT OF COMMON PLEAS

              JACQUELINE WAINSCOTT PETERS,
              administratrix,

                           Plaintiff

                     VS.                         Case No. 89-0361

              RIVERSIDE HOSPITAL, et al.,

                           Defendant.

                           Deposition of HERBERT J. GROSSMAN, M.D., a
                       tness herein, called by the Plaintiff as if upon
                       oss-Examination under the Ohio Rules of Civil
                       ocedure, taken before me, the undersigned, Renee
                     E. Brass, a Notary Public in and for the State of
                    l@Ohio, at the University of Michigain Hospital,
                     Pediatric Neurology Department, Room 1913, Ann
                     Arbor, Michiganr on Monday, September 24, 1990 at
                     4:20 p.m.
              ----------------------------------------------------------
               C 0 L L I N S  R E P 0 R T I N G  S E R V I C E, I N C.
                          Registered Professional Reporters
                     405 North Huron Street    Toledo, Ohio  43604
                                      41 9) 2 4 4- 93 85


            COLLINS REPORTING SERVICE, INC.    TOLEDO, OHIO    (419) 244-9385
                                                 x
               ,6xTpRNEY           DIRECT
               Mr. Gabalac                      4

                                     E   H        T S
               ElAintiff's                                           page

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             COLLINS REPORTING SERVICER 61 IN'C.  TIKLED   io@(419) 244-9385

                APPEARANCES:

                       on behalf of the Plaintiff:

                             FRANK W. CUBBONT JR. & ASSOCIATES, CO.,
                             L.P.A.:
                             Stephan M. Gabalac
                             500 Inns Court of Building
                             405 N. Huron
                             Toledo, Ohio 43604
                             ( 41 9) 2 43 -7 243

                       On behalf of the Defendant:

                             ROBISON, CURPHEY & O'CONNELL:
                             Thomas E. Maguire
                             Pour SeaGate, Ninth Ploor
                             Toledo, Ohio 43604
                             (419) 249-7900



        3








             COLLINS REPORTING SERVICER INC.     TOLEDOT OHIO    (419) 244-9385

                                                                         4
           1                       (The Court Reporter marked Plaintiff's
           2                 Exhibit 1.)
           3                    HERBERT J. GROSSMAN, M.D.,
           4   a Witness herein, called by the Plaintiff as if upon
           5   Cross-Examinationr was by me first duly sworn, as
           6   hereinafter certified, and deposed and said as follows:
           7
           8                       MR. GABALAC:  Let the record show that
           9                 this is a discovery deposition of Dr. Herbert
         10                  J. Grossman by agreement of counsel  with
         11                  stipulation as to qualifications.
         12                        MR. MAGUIRE:  Yes.
         13                               - - -
         14                         CROSS-EXAMINATION
         15    BY MR.  GABALAC:
         16                  Dr. Grossmant I'm sure you've done this
         17    before because I think I have taken your deposition
         18    before.  When I ask you a question if you don't
         19    understand   --
         20           A.     I thought I'd seen you before.
         21           Q.     Looked familiar. -- stop me and  we  will
         22    rephrase it so that when you give an answer, I will assume
         23    you understood the question and that's the  answer  you
         24    intended to give.  Those are the  simple  ground  rules.

            COLLINS REPORTING 6ERVICE, INC.     TOLEDO, OHIO    (419) 244-9385
                                                                          5
           1                 Yes.
           2                 You've given me your curriculum vitae which
           3    I've marked as Plaintiff's Exhibit Number I --
           4           A.    Yes.
           5           Q.    Is that correct?
           6           A.    Yes.
           7                 And is this up to date?
           8           A.    Oh, all except one