RICHLAND COUNTY, OHIO
21



Carolyn Rucker Daugherty,

et al.,
4

Plaintiffs,
5

vs. No. 34-506-C
61

Richard C. Harris, M.D.,
7 et al.,




11 Defendants.

91


10


11@ Deposition of DR. HOWARD TUCKER, taken on


12@ cross-examination before William J. Mahan, Registered


13 Professional Reporter and Notary Public within and


14 for the state of Ohio, at the offices of Dr. Howard


15 Tucker, Suite 326, Mt. Sinai Medical Building, 26900


16 edar Road, Beachwood, Ohio, 44122, at 2:00 p.m.,


17 Wednesday, April 16, 1986, pursuant to notice and/or
C

18 stipulations of counsel, by the defendants in this


19 cause.


20 - - - -


21


22


23


24


25

2

I  APPEARANCES:

2 David J. Elk, Esq.
Bond Court Building
3 Cleveland, Ohio 44114

4 on behalf of the Plaintiffs;

Peter P. Zawaly, Jr., Esq.
Jacobson, Maynard, Tuschman & Kalur
6 175 South Third Street
Columbus, Ohio
7@ (614) 224-1323

8@ on behalf of the defendants.

91 - - - -

101 DR. HOWARD TUCKER, called by

the defendants for the purpose of

12 cross-examination, as provided by the

131 Ohio Rules of Civil Procedure, having

14 been first duly sworn, as hereinafter

15 certified, deposed and said as follows:

16 CROSS-EXAMINATION OF DR. HOWARD TUCKER

11 BY MR.  ZAWALY:
I

18 MR. ZAWALY: Let the


19 record show that we are here this

afternoon and we are going to take this
20

21 deposition upon cross-examination in the


22 case of Carolyn Rucker Daugherty versus


23 Drs.  Harris, Shook, Kautz, Baddour


24 and a CRNA by the name of Ruth Friel.

I will be asking you these
25

3
questions as if on cross-examination.

2 Doctor, I will ask that vou

3 make all of your responses to my questions

4 verbally to aid the Court Reporter in

5 recording your responses. If you don't

6 understand any questions I ask you, let

me know and we will attempt to make sure

that there is an understanding because it

91 is extremely important in order for me to

101 discover the facts that I am here to

11 discover today.

12 A. Can I ask you a question?

13 Yes.

14 You gave me the initials after someone's name

15 that I am not familiar with. What was that?

16 Cl That is Ruth Friel, a CRNA, Certified Registered

17 Nurse Anesthetist.

18 A. okay.

19 (I You never heard of that before?

20 A. I have of course heard of Registered Nurses, b