0001
 1         IN THE COURT OF COMMON PLEAS
                PORTAGE COUNTY, OHIO
 2                    -  -  -
 3   
 4   RYLEE DiTULLIO, a minor  :
     by and through her       :
 5   parents, Gregory and Lisa:
     DiTullio, et al.,        :
 6          Plaintiffs        :
                              :
 7          vs.               : CASE NO.
                              : 03-CV-00974
 8   ROBINSON MEMORIAL        :
     HOSPITAL, et al.,        :
 9          Defendants        :
10   
11                    -  -  -
                 November 11, 2005
12                    -  -  -
13   
14                Oral deposition of MONA
            GOLDMAN YUDKOFF, R.N., M.P.H.,
15          taken pursuant to notice, was held
            at the Renaissance Airport Hotel,
16          500 Stevens Drive, Philadelphia,
            Pennsylvania, commencing at 10:20
17          a.m., on the above date, before
            Darlene Lowrance, a Federally
18          Approved Registered Professional
            Reporter, Certified Shorthand
19          Reporter and Notary Public in and
            for the Commonwealth of
20          Pennsylvania.
21   
                      -  -  -
22          ESQUIRE DEPOSITION SERVICES
           Four Penn Center, Suite 1210
23      1600 John F. Kennedy Boulevard
         Philadelphia, Pennsylvania  19103
24                 (215) 988-9191
0002
 1   A P P E A R A N C E S:
 2   
 3   
            ELK & ELK
 4          By:  JAMES M. KELLEY, ESQ.
            6110 Parkland Boulevard
 5          Mayfield Heights, Ohio 44124
            (440) 442-6677
 6          Representing the Plaintiffs
 7   
 8   
            ROETZEL & ANDRESS
 9          By:  STACY A. RAGON, ESQ.
            222 South Main Street
10          Akron, Ohio  44308
            (330) 376-2700
11          Representing the Defendants
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0003
 1                    -  -  -
                     I N D E X
 2                    -  -  -
 3   
     Testimony of:               MONA YUDKOFF
 4   
     By Ms. Ragon...........................5
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                      -  -  -
11               E X H I B I T S
                      -  -  -
12   
     EXHIBIT NUMBER  Description   PAGE MARKED
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14          A     Life Care Plan         5
                  report dated 5/6/04
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            B     Curriculum vitae      16
16   
            C     Four-page document    19
17                dated 11/9/2005
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0004
 1           DEPOSITION SUPPORT INDEX
 2   
     Direction to Witness Not to Answer
 3   Page   Line  Page    Line  Page    Line
 4                NONE
 5   
     Request for Production of Documents
 6   Page   Line  Page    Line  Page    Line
 7                NONE
 8   
     Stipulations
 9   Page   Line  Page    Line  Page    Line
      5     1-6
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     Question Marked
12   Page   Line  Page    Line  Page    Line
13                NONE
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0005
 1          (It is hereby stipulated by and
 2   between counsel for the respective
 3   parties that the filing and certification
 4   are waived, and that all objections,
 5   except as to the form of the questions,
 6   be reserved until the time of trial.)
 7                   -  -  -
 8                (Exhibit A marked for
 9          identification.)
10                    -  -  -
11                MONA YUDKOFF, R.N., M.P.H.,
12   after having been first duly sworn, was
13   examined and testified as follows:
14                    -  -  -
15                  EXAMINATION
16                    -  -  -
17   BY MS. RAGON:
18          Q.    Tell us your name.
19          A.    Mona Yudkoff.
20          Q.    What is your educational
21   background, Mona?
22          A.    I have a Bachelor's degree
23   in nursing and a Master's degree in
24   public health.
0006
 1          Q.    Any other advanced degrees
 2   of any kind?
 3          A.    No.
 4          Q.    You do not have a Ph.D.; is
 5   that correct?
 6          A.    Yes.
 7          Q.    And you don't have a medical
 8   M.D. or D.O. degree?
 9          A.    I'm not any kind of a
10   doctor.
11          Q.    Okay, very good.
12                How long have you been
13   preparing life care plans?
14          A.    About 16 years.
15          Q.    How did you first get
16   involved in preparing life care plans?
17          A.    I was working at a case
18   management rehabilitation company.  We
19   were approached by an attorney to do a
20   life care plan.  I did it.
21                I then -- the lawyer who was
22   on the other side called me and offered
23   me some work and the rest is history.
24   I've been doing it