118teo








               STATE OF OHIO,
                                       SS:
      a,       COUNTY OF LORAIN.

      LQ                   I@l TliE COUR@ OF CO@IIIONT PI,PAS


               Carolyn r. Patterson,
      (i       Extrx., et al.,

                             Plaintiffs,

                     v s .                          No. 97648

               Elyria !Iemorial ITospital,
               et al.

                             Defendants.





                     Deposition of KURT A. BERTS   'IT INGEP,, 'I.D., a

               witness, taken as if under exa-nination before

               Angelika P. Veres, a Notary Public within and for

               the State of Ohio, at the offices of Simon

               Bertschinger, 35550 Curtis Boulevard, TIilloughby,

               Ohio, at 2:1.0 p.m., Friclay, th@e 7th day of October,

               1988, pursuant to s-.ipulations of counsel, on behalLI

               of the Defendant Elyria rlemorial Ilospital.


                      ROBERT J. RUA & ASSOCIATES
                                    Court Reporters
                   i 150 THE ILLUMINATING BUILDING - CLEVELAND, OHIO 44113
                                      241-5500

                                                                  2


           2   APPEARANCES:

           3
                     Weisman, Goldberg, Weisman & Kaufman, by
           4         Mr. Howard D. Mishkind,

           5                on behalf of the Plaintiffs;

           6
                     Kitchen, Messner & Deery, by
           7         Ms. Janet D. Tomko,

           8                on behalf of the Defendant
                            Elyria Memorial HoSpital;
           9

         10          Reminger & Reminger, by
                     Mr. Frank Aveni,
         11
                            on behalf of the Defendant
         12                 Mental Health Management, Inc.

         13

         14
         15                  S T I P U L A T I 0 N S
         16                 It was stipulated by and between counsel
         17    for Plaintiffs and Defendants that this deposition ma)
         18    be taken in stenotypy by Angelika P. lieres, that said
         19    r-tenotype notes may be subsequently transcribed into
         20    typewriting in the absence of the witness; that the
         21    reading and signing of the deposition by the witne