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 R.N., 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 a.m.
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., L.P.A., 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., L.P.A., 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, Rennillo
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, R.N. BY-MR. SPISAK: Q.
87 15 OF MARILYN M. MELISON BY-MR. KALUR: Q. I'm
94  3 M. MELISON, R.N. 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, Rennillo
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, Rennillo
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, Rennillo
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 witness or an
20 expert witness as a nurse before?
21 A. No, I have not.
22 Q. Please tell me what materials were
23 supplied to you right up to today?
24 A. I have reviewed the chart for
25 mother and baby