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       IN THE CIRCUIT COURT OF STATE OF MICHIGAN
                      COUNTY OF WAYNE
     
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     Marshall Powell, Jr     :
    and Barbara Jarrells,
     Co-Personal              :
    Representatives of the
     Estate of Florcie Mae    :
    Powell, Deceased, and      Case No 04-407872-NH
     Marshall Powell, Jr,    : Judge John H Gillis,
    Individually,              Jr
                              :
            Plaintiffs,
                              :
            vs
                              :
    Oakwood Healthcare,
     Inc, et al,            :
             Defendants      :
     
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          DEPOSITION OF DOUGLAS A RUND, MD
     
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                  Taken at 171 Means Hall
                    1654 Upham Drive
                    Columbus, OH 43210
               August 12, 2008, 2:56 pm
     
     
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                 Spectrum Reporting LLC
         333 Stewart Avenue, Columbus, Ohio 43206
              614-444-1000 or 800-635-9071
                 wwwspectrumreportingcom
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 1         A P P E A R A N C E S
 2   
    ON BEHALF OF PLAINTIFFS:
 3   
    Villari Law Firm
 4   161 Washington, 8 Tower, Ste 400
    Conshohocken, PA 19428
 5   By J Lee Tilson, Esq
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    ON BEHALF OF DEFENDANT:
 7   
    Siemion Huckabay
 8   One Towne Square, Ste 1400
    Southfield, MI 48086
 9   By James W Bodary, Esq
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 1                        Tuesday Afternoon Session
 2                         August 12, 2008, 2:56 pm
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 4                 S T I P U L A T I O N S
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 6        It is stipulated by counsel in attendance that
 7   the deposition of Douglas A Rund, MD, a witness
 8   herein, called by the Plaintiffs for
 9   cross-examination, may be taken at this time by
10   the notary pursuant to notice and subsequent
11   agreement of counsel, that said deposition may be
12   reduced to writing in stenotypy by the notary,
13   whose notes may thereafter be transcribed out of
14   the presence of the witness; that proof of the
15   official character and qualification of the notary
16   is waived
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 1                        I N D E X
 2   Examination By                                  Page
 3   Mr Tilson - Cross                                 5
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    Plaintiff's Exhibits                            Page
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     1 - Curriculum Vitae                              7
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     2 - Article                                      53
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22   (Exhibits attached to original transcript)
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 1              MR TILSON:   Would you state your name
 2   for the record, please
 3              THE WITNESS:  Douglas A Rund
 4              MR TILSON:  Let the record reflect
 5   this is the deposition of Dr Rund taken pursuant
 6   to notice  I assume it's a discovery-only
 7   deposition, but counsel and I can argue about that
 8   later
 9              It's being taken in the case of Florcie
10   Powell, the Estate of Florcie Powell versus, at
11   this point, Alok Shukla, and then we can sort out
12   the rest of some of the paper stuff later
13              I'm going to be asking you some
14   questions today concerning the Powell case
15   Please let me know if you don't understand any
16   questions  I can repeat it or have the court
17   reporter read it back
18              The other thing I will ask of you is
19   that you give me verbal responses to my questions
20   There's a number of issues that come up with
21   respect to that, but in particular, if you could
22   give verbal responses, yes or no, as opposed to
23   uh-huh or huh-uh
24              There may also be some ambiguities when

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 1   you give a negative response to a negative
 2   question  Sometimes I'll ask a negative question
 3   instead of asking positive questions, and a
 4   negative response may be ambiguous between
 5   agreeing with the negative premise or disagreeing
 6   with the negative premise  I'll jus