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I IN THE COURT OF COMMON PLEAS 2 OF CUYAHOGA COUNTY, OHIO 3 CAITLIN ANN PEARSTON et al, 4 Plaintiffs, 5 vs Case No 6 ST JOHN & WEST SHORE 179856 7 HOSPITAL, et al, 8 Defendants 9 - - - - - 10 Deposition of MARILYN M MELISON, 11 RN, a Witness herein, called by the 12 Defendants for examination under the statute, 13 taken before me, Wendy L Klauss, a Registered 14 Professional Reporter and Notary Public in and 15 for the State of Ohio, pursuant to notice and 16 stipulations, at the offices of Weisman, 17 Goldberg & Weisman, 1600 Midland Building, 18 Cleveland, Ohio, on Monday, March 1, 1993, at 19 10:03 o'clock am 20 - - - - - 21 2 2 2 3 (COO FT 2 4 2 5 CLEVELAND, OHIO (216) 687-1161 Ceforatti, Rennillo AKRON, OHIO (216) 253-8119 & lftttheWS Court Peportm Ce 2 1 APPEARANCES: 2 On behalf of the Plaintiffs: 3 Weisman, Goldberg & Weisman, by 4 FRED WEISMAN, ESQ 5 1600 Midland Building 6 Cleveland, Ohio 44115 7 781-1111 8 On behalf of the Defendant Balevice: 9 Jacobson, Maynard, Tuschman & 10 Kalur Co, LPA, by 11 JEROME S KALUR, ESQ 12 JOSEPH A FARCHIONE, ESQ 13 North Point Building 14 1001 Lakeside Avenue, Suite 1600 15 Cleveland, Ohio 44114 16 736-8600 17 On behalf of the Defendant 18 St John & West Shore Hospital: 19 Reminger & Reminger Co, LPA, by 20 LESLIE J SPISAK, ESQ 21 The 113 St Clair Building 22 Cleveland, Ohio 44114 23 687-1311 24 ---- 2 5 CLEVELAND, OHIO (216) 687-1161 Cefar-atti, ******** AKRON, OHIO (216) 253-8119 & Matthews cmt Rpotes A PG LN [Ngl]PEARSTON-MELISON 3-1-93 WK --- COMPUTER INDEX PG LN BY-M* 312 OF MARILYN M MELISON BY-MR KALUR: Q 60 20 M MELISON, RN BY-MR SPISAK: Q 87 15 OF MARILYN M MELISON BY-MR KALUR: Q I'm 94 3 M MELISON, RN BY-MR SPISAK: Q I PG LN MARK'D 821 Exhibit 1 was markld for purposes of PG LN AFTERNOON-SESSION PG LN --- THIS INDEX IS RESEARCHED BY COMPUTER--- CLEVELAND OHIO (2161 687-1161 Cefaratti, ******** AKIZON, OHIO (216) 253-8119 & Matthews co,,t Rep@ters 3 1 MR KALUR: The record should 2 reflect that this deposition is taken pursuant 3 to agreement of counsel and under the 4 provisions of Rule 26 (b)(4)(b) governing the 5 taking of the depositions of expert witnesses 6 MARILYN M MELISON, of lawful age, called 7 for examination, as provided by the Ohio Rules 8 of Civil Procedure, being by me first duly 9 sworn, as hereinafter certified, deposed and 10 said as follows: 11 EXAMINATION OF MARILYN M MELISON 12 BY-MR KALUR: 13 Q Would you state your full name, 14 please 15 A Marilyn M Melison 16 Q Would you spell the last name, 17 please 18 A M E L I S 0 N 19 Q_ And could you please, although it 20 is right in front of me here, I have to have it 21 on the record, give us your residence address, 22 please? 23 A 9 Nokomis Drive in Timberlake, 24 Ohio, 44095 25 Q Since you've got your left hand I I CLEVELAND OHIO (216) 687-1161 Cefaratti, ******** AKRON, OHIO (216) 253-8119 & Matthews C,t Rp,,tr, 4 1 own, I can't tell, should I call you Mrs 2 Melison? 3 A Mrs is fine, thank you 4 Q Would you tell me how you became 5 involved in this matter? 6 A Mr Weisman called and asked me if 7 I would be interested in reviewing a case as an 8 expert nurse witness, and I agreed to review 9 the chart and give him a decision 10 Q Have you ever been involved in 11 another matter, lawsuit, claim, with Mr 12 Weisman or someone else from his office? 13 A I have not been involved with any 14 claims with Mr Weisman, no 15 Q What knowledge do you have as to 16 how he got your name so that he could get in 17 touch with you? 18 A Apparently there are some mutual 19 acquaintances that know the both of us, but 20 neither he nor I knew each other 21 Q Who were the acquaintances? 22 A A nurse I used to work with 23 Q What is her name? 24 A Marie Kerr 25 Q Have you reviewed other matters CLEVELAND OHIO (216) 687-1161 Ceforatti, ******** AKRON, OHIO (216) 253-8119 & Ifttthews C0,,t pep,"e,, 5 1 involving claims of medical malpractice before? 2 A No, I have not 3 Q So this is your maiden voyage in 4 this area then? 5 A Perhaps I need to clarify that I 6 have not reviewed a case of medical 7 malpractice I have been involved in one suit 8 as a nurse It was at the time Euclid General 9 Hospital It is the same hospital I work for 10 now, but a different name, and that was about 11 five years ago 12 Q Was that a claim against Euclid? 13 A Yes, that's correct 14 Q And you were a fact witness in that 15 case? 16 A Yes, I was 17 Q Have you ever been involved in any 18 other medical malpractice, and I'm widening my 19 question then, as either a fact witnes
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