3C

             1   State of  Ohio,      )  SS:
             2   County of Cuyahoga  )
             3
             4                 IN THE COURT OF COMMON PLEAS
             5                             - - -
             6   FLORENCE STEVENSON, et al,
             7                 Plaintiffs,
             8        V                            Case No  173934
             9   HAMLET MANOR NURSING  HOME,
            10                 Defendant
            11
            12         THE DEPOSITION OF ELIZABETH K BALRAJ, MD
            13                   TUESDAY, JUNE 4, 1991
            14                             - - -
            15        The deposition of ELIZABETH K BALRAJ, MD, a
            16   witness, called for examination by the Defendant, under
            17   the Ohio Rules of Civil Procedure, taken before me,
            18   Janet M Hoffmaster, Registered Professional Reporter
            19   and Notary Public in and for the State of Ohio,
            20   pursuant to notice, at the County Coroner's Office,
            21   Cleveland, Ohio, commencing at 2:10 pm, the day and
            22   date above set  forth
            23                             - - -
            2 4
            2 5
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             1   APPEARANCES:

             2

             3   On behalf of the Plaintiffs:

             4        LAURENCE J POWERS, ESQ
                      Weisman, Goldberg, Weisman & Kaufman
             5        1600 Midland BUilding
                      Cleveland, Ohio  44115
             6

             7   On behalf of the Defendant:

             8        GARY GOLDWASSER, ESQ
                      Reminger & Reminger
             9        The 113 St Clair Building
                      Cleveland, Ohio  44114
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             1                            INDEX

             2                                             PAGES

             3

             4   CROSS-EXAMINATION BY

             5

             6        MR  GOLDWASSER                           4

             7

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             1                  ELIZABETH K BALRAJ, MD
             2  a witness, called for examination by the Defendant,
             3  under the Rules, having been first duly sworn, as
             4  hereinafter certified, deposed and said as follows:
             5                      CROSS-EXAMINATION
             6  BY MR  GOLDWASSER:
             7  Q-     Doctor, for the record, would you state your
             8  full name, please?
             9  A     Elizabeth K Balraj, B-A-L-R-A-J
           10   Q     Your famous, everyone knows how to spell your
           11   name
           12          Doctor, it has been represented to me that you
           13   will be testifying in a civil matter as pertains to the
           14   estate of the late Harold Stevenson versus Hamlet Manor
           15   Nursing Home, which is my client
           16          Is that your understanding as well?
           17   A     Yes
           18   Q     It has also been represented to me, Dr Balraj,
           19   that the subject of your testimony will be primarily,
           20   in fact, solely limited to the question of what we
           21   lawyers refer to as proximate cause, that's the cause
           22   of death
           23          Is that your understanding as well?
           24   A     That is correct
           25   Q     You will not be rendering any opinions as to the
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             1  standard of care or the violations thereof of  my
             2  clients at the nursing home
             3         Is that your understanding?
             4  A     That is right
             5  Q     Doctor, you have been kind enough to hand me a
             6  copy of the coroner's verdict
             7         Is this an extra copy?
             8  A     Yes, you may keep that
             9  Q     All right  Thank you
           10          I have seen the death certificate which has your
           11   signature on it  I had not seen the coroner's verdict
           12   until just now