IN THE COURT OF COMMON PLEAS

2 CUYAHOGA COUNTY, OHIO

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Annie Aponte,
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Plaintiff,

5 Judge Francis E. Sweeney
VS.
6 Case No. 61165
St. Vincent Charity

7 Hospital, et al.,

8 Defendants.






11 Deposition of HOWARD J. TUCKER, M.D., taken


12 as if upon cross-examination before Pamela S. Green-


13 field, a Registered Professional Reporter and Notary


14 Public within and for the State of Ohio, at the offices


15 of Howard J. Tucker, M.D., 26900 Cedar Road, Third


16 Floort Beachwood, Ohio, on Monday, March 25, 1985 at


17 2:00 P.M., pursuant to notice and/or stipulations of


18 counsel, on behalf of the Defendants Denison R.


19 Stewart, M.D. and Drs.  Alfred and Steffee, M.D., Inc.

in this cause.
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I APPEARANCES:

2 Robert J. Zavesky, Esq.,
-Berger & Kirschenbaum,
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on behalf of the Plaintiff;
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Douglas X.Fifner, Esq.,
5 Reminger & Reminger,

6 on behalf of the Defendants
St. Vincent Charity Hospital,
7 Lawrence Bell, M.D.,
James D. Hayes, M.D. and
8 Aaron Combs, M.D.;

9 Cyril J. McIlhargle, Esq.,
Jacobson, Maynard, Tuschman & Kalur,
10 an behalf of the Defendants
11 Denison R. Stewart, M.D. and
Drs.  Alfred and Steffee, M.D., Inc.
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1 HOWARD J. TUCKER, M.D...., called by the

2 Defendants Denison R. Stewart, M.D. and

3 Dr. Alfred and Steffee, M.D., Inc. for the

4 purpose of cross-examination, as provided by

5 the Ohio Rules of Civil Procedure, being by

6 me first duly sworn, as hereinafter certified,

7 deposed and said as follows:

8 CROSS-EXAMINATION OF HOWARD J. TUCKER, M.D.

9 BY MR.  McILHARGIE:

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11 Whereupon, Defendants' Exhibits 1

12 through 5 were marked for purposes-df

13 identification.

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is MR. McILHARGIE: Lot the record

16 reflect that this is the deposition of

17 Dr. Howard Tucker. It is being taken

18 pursuant to notice and that all formalities

with respect to notice and service are waived,
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is that correct, Mr. Zavesky?
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MR. ZAVESKY: Correct.
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Q Doctor, would you please state your name and spell
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your last name?
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A Howard Tucker, T-u-c-k-e-r.
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Q Doctor, with the notice, I supplied a duces tecum
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1 requiring that certain matters be brought; with you

2 today and I asked that you bring all records,

3 X-ray films, documents, correspondence, textsi

41 articles reviewed by you with reference to your

5 review of the matter of Annie Aponte versus

6 St. Vincent Charity Hospital. Have you brought

7 records that are res