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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
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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 - - -
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1 APPEARANCES:
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3 On behalf of the Plaintiffs:
4 LAURENCE J POWERS, ESQ
Weisman, Goldberg, Weisman & Kaufman
5 1600 Midland BUilding
Cleveland, Ohio 44115
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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
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4 CROSS-EXAMINATION BY
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6 MR GOLDWASSER 4
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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
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