1-7 C) -7
                   KATHERINE G. KELL, et al,  ) STATE OF OHIO
           2                    Plaintiffs     ) COUNTY OF CUYAHOGA
           3                                   )
           4              VS.                  ) NO. 349409
           5                                   )
           6                                   )
           7       REICH, SEIDELMANN, JANICKI  )
           8       COMPANY, et al,             )
           9                    Defendants     )
         10                                 - - -
         11
         12                     Oral deposition of HARVEY LERNER,
         13        M.D., taken at the doctor's office at 330 South
         14        9th Street, First Floor, Philadelphia,
         is        Pennsylvania, on Thursday, January 12, 1995, at
         16        3:00 p.m., before Cecelia Nicolosi, a Court
         17        Reporter and Notary Public of the Commonwealth of
         18        Pennsylvania, pursuant to notice.
         19                              - - -
         20                        SCHULMAN/DeSIMONE
         21                       THE COURT REPORTERS
         22                  1880 JFK Boulevard, 15th Floor
         23                 Philadelphia, Pennsylvania 19103
         2 4                         (215) 732-6900
                                                                       2
                  APPEARANCES:
           2
           3                   WEISMAN, GOLDBERG a WEISMAN
           4                   COMPANY, L.P.A.
           5                   BY: RICHARD J. BERRIS, ESQUIRE
           6                   1600 Midland Building
           7                   Landmark Office Towers
           8                   Cleveland, Ohio 44115
           9                   Attorney for Plaintiff
         10
         11
         12                    JACOBSON, MAYNARD, TUSCHMAN & KALUR
         13                    BY: DALE L. KWARCIANY, ESQUIRE
         14                    1001 Lakeside Avenue
         is                    Suite 1600
         16                    Cleveland, Ohio  44114-1192
         17                    Attorney for Defendants
         18
         19
         20
         21
         22
         23                             - - -
         24
                                                                        3
                                          I N D E X
           2
           3      WITNESS               INTERROGATION BY         PAGE
           4
           5      HARVEY LERNER, M.D.  Mr. Richard J. Berris       4
           6
           7
           8
           9                              - - -
         10
         11
         12
         13                        N 0     E X H I B I T S
         14
         15
         16
         17
         18
         19
         2 0
         2 1                              - - -
         2 2
         2 3
         24
                                  HARVEY LERNER, M.D.                  4
           1                    (It is agreed by and between  counsel
           2             that all objections, except as to  the  form
           3             of the questions, are reserved until the
           4             time of trial.)
           5                                - - -
           6                   HARVEY LERNER, M.D., having been duly
           7             sworn, was examined and testified as
           8             follows:
           9
         10       EXAMINATION BY MR.  BERRIS:
         11       Q-     State your name for the record.
         12       A.     Harvey Lerner.
         13       Q.     I have a copy of your CV, so I'm  not  going
         14       to go into any great detail about your education
         15       and training. what is your  present  position  here
         16       at Pennsylvania Hospital?
         17       A.     I'm Head of Surgical Oncology and  Chief  of
         18       Cancer Chemotherapy.
         19       Q.     Are you an oncologist?
         20       A.     I'm a surgical oncologist.  I'm not a
         21       medical oncologist.
         22       Q.     You're a surgical oncologist and you are
         23       board certified in general surgery?
         24       A.     Yes.
                                 HARVEY LERNER, M.D.                   5
           1      Q.     Is there a sub-certification or special
           2      certification in surgical oncology?
           3      A.     There is not, and the closest thing to it
           4      is, I guess, the Society of Surgical Oncology, but
           5      there are no formal boards for surgical oncology
           6      at the present time.
           7      Q.     Okay.  What specialized training do you
           8      have then with respect to oncology over and above
           9      your general surgery training?
         10       A.     I