0001
 1           IN THE COURT OF COMMON PLEAS
 2          DELAWARE COUNTY, PENNSYLVANIA
 3   MARIE PAYNTER and TODD   ) 
 4   V. PAYNTER,              )NO.  02-12907
 5         Plaintiffs,        )
 6          - vs-             )
 7   FARRELLY BROTHERS        )
 8   ELECTRIC and THERESA M.  )
 9   FARRELLY and DANIEL J.   )
10   FRANK and ROBERT LEVINE, )
11            Defendants.     )
12       Videotaped deposition of EDGAR J. KENTON, 
13   M.D., taken at the offices of EDGAR J. KENTON, 
14   M.D., 100 Lancaster Avenue, Wynnewood, 
15   Pennsylvania, on Wednesday, Spetember 29, 2004, 
16   at 7:10 p.m., before Dolores M. Horne, Shorthand 
17   reporter and Notary Public, in and for the 
18   commonwealth of Pennsylvania.
19           ESQUIRE DEPOSITION SERVICES
20           1880 John F. Kennedy Boulevard
21                15th Floor                  
22         Philadelphia, Pennsylvania  19103
23               (215) 988-9191
24   
0002
 1   APPEARANCES:  
 2   
 3   
 4            DUGAN, BRINKMANN, MAGINNIS & PACE
 5            BY:  HENRY LEWANDOWSKI, ESQUIRE
 6            1880 John F. Kennedy Boulevard
 7            Philadelphia, Pennsylvania  19103
 8            (215) 563-3500
 9            Attorneys for the Plaintiffs
10   
11   
12   
13   
14            GEORGE P. NOEL, ESQUIRE
15            25 East Second Street
16            Media, Pennsylvania  19063
17            (610) 565-0600
18            Attorneys for the Defendants
19   
20                
21   
22   
23   
24   
0003
 1                   I N D E X
 2   WITNESS           EXAMINATION       PAGE
 3   EDGAR J. KENTON, M.D.
 4   
 5     By:  Mr. Lewandowski  Direct    6, 23, 71
 6     By:  Mr. Noel         Cross        20, 51
 7   
 8   
 9   
10   
11               E X H I B I T S
12   
13   NO.         DESCRIPTION             PAGE
14   
15   D-1         Curriculum Vitae         5
16   D-2         Report                   5
17   
18   
19   
20   
21   
22   
23   
24   
0004
 1             DEPOSITION SUPPORT INDEX
 2   
 3   Direction to Witness Not to Answer
 4   Page     Line   Page    Line    Page    Line
 5   
 6    
 7   
 8   Request for Production of Documents
 9   Page     Line   Page    Line    Page    Line
10   
11   
12   
13   Stipulations
14   Page     Line   Page    Line    Page    Line
15   
16   
17   
18   
19   Question Marked
20   Page     Line   Page    Line    Page    Line
21   
22   
23   
24   
0005
 1                  (Documents marked Exhibits D-1 
 2   and D-2 for identification.)
 3                  THE VIDEO TECHNICIAN:  We are 
 4   now on the record.  My name is David Levin.  I'm 
 5   a videographer employed by Esquire Deposition 
 6   Services, 1880 JFK Boulevard, Philadelphia, 
 7   Pennsylvania 19103.  This is a video deposition 
 8   for the Court of Common Pleas, Delaware County, 
 9   Term No. 02-12907.  Today's date is Wednesday, 
10   September 29, 2004 and the video time is 7:02 
11   p.m. This deposition is being held at Lankenau 
12   Hospital, 100 East Lancaster Avenue, No. 2161, 
13   Wynnewood, Pennsylvania in the matter of Marie 
14   Paynter and Todd V. Paynter versus Farrelly 
15   Brothers Electric, et al.  The deponent is Edgar 
16   J. Kenton, M.D.  This deposition is being taken 
17   on behalf of the plaintiffs.  Present today are 
18   Henry Lewandowski, attorney for the plaintiffs.  
19   Also present is George P. Noel, attorney for the 
20   defendants.  The court reporter's name is 
21   Dolores Horne.  She will now swear in the 
22   witness.
23                  EDGAR J. KENTON, M.D., after 
24   having been first duly sworn, was examined and 
0006
 1   testified as follows:
 2                  * * *
 3                  DIRECT EXAMINATION
 4                  * * *
 5   BY MR. LEWANDOWSKI:
 6   Q.       Good evening, Doctor.  
 7   A.       Good evening.  
 8   Q.       As you know, I represent Marie Paynter 
 9   and Todd Paynter in a personal injury action 
10   that's being heard currently by a judge and a 
11   jury in the Court of Common Pleas of Delaware 
12   County.  
13   A.       Yes.  
14   Q.       We're taking your videotaped trial 
15   deposition this evening due to your busy 
16   clinical schedule?  
17   A.       Yes, sir.  
18   Q.       Before I begin asking you substantive 
19   questions about this case, I just want to ask 
20   you a few questions about your background, have 
21   you introduce yourself to the jury and ask you 
22   about your qualifications to testify.  
23   A.       Yes.  
24   Q.       When I'm finished Mr. Noel may have a 
0007
 1   few questions for you regarding your 
 2   qualifications.  We will then get to the 
 3   substantive nature of your testimony.  Is that 
 4   okay?  
 5   A.       Fine.
 6   Q.       Dr. Kenton, would you please tell us 
 7   your full name and your occupati