3                State of Ohio,         )
                                         )    SSI
                 County of Cuyahoga.     )


                                IN THE   COURT OF COMMON PLEAS

                 Alan Baer, Individually
                  And &s Administrator of
                  Tho Estate Of M011ye Baer,)
                  Deceasede et al.,

                              Plaintiffs,,

                         Vs,                           Case  No. 87036
                 Hillcreat Hospital,
                  et &I,,

                               Defendants,

                          Depogition Of DANIEL C. WILKERSON? M.D.v a
                Witness hereinp taken by the Defendants# before Cheryl
                Le Casperf a Registered PrOfessional Reporter and
                Notary Public within and for the State of Ohiol at the
                Offic*B of Weisman# Goldbergp Weisman & Kaufman, 540
                The Leador Building# Clevelandt Ohio, on Friday,
                the 21st day of Novembert 1986# commencing at ls3O
                o'clock P,Mop pursuant to Agreement.




                                   D.L. LINDEE & ASSOCIATES
                                   REGISTERED PROFESSIONAL REPORTERS
                                         450 THE ARCADE
                                       CLEVELAND, OlqlO 44114
                                         (216) 861-3260

                APPEARANCESG

                       Weisman, Goldoergr Weisman & Raufmanr by
                       Ms. Laurie P, Starr
                       540 The Leader BUilding
                       Clevelandl Ohio

                             On behalf of the Plaintiffs;

                       JacobSOnr MaynardF Tuachman & Kalurt by
                       Mr. Anthony P, Dapore
                       Me. Anna Moorg
                       100 Erieview Plaza - 14th Floor
                       Clevelandl Ohio

                             On behalf of the Defendants.

               F--
                                                                             3


           1                      DANIEL C. WILKERSONT M.D.

           2      Of lawful  ager a witness hereint called by the

           3      Defendants,  as provided by the Ohio Rules of Civil

           4      Procedurer being by me first duly swornt as hereinafter

           5      certifiedr was deposed and said as follows:

           6             EXAMINATION OF DANIEL C. WILKERSON, M.D.

           7      BY   MR.  DAPORE:

           8      Q      Would you state your full name for the record,

           9             please.

         10       A      Daniel C. Wilkerson.

         11       Q      What is your  ager  Sir?

         12       A      64.

         13       0      And what is your date of birth?

         14       A      October Sth, 1922.

         15       Q      And where do you currently reside?

         16       A      In Annapolisr  Maryland.

         17       Q      How long have you been there?

         is       A      Approximately 13  years.

         19       Q      And are you -- or have you ever lived in the

         20              Cleveland area?

         21       A      No.

         22                         MR*   DAPORE:          Let the record

         23                   show that this is the discovery deposition

         24                   of Dr. Daniel Wilkerson identified by

         25                   Plaintiffs as an expert witness in the




                          D. L. LINDEE & ASSOCIATES  861-3260

           I                   case of the EState of Mollye Baer versus
           2                   Samuel Teitelbaump et al.  The deposition
           3                   is being taken pursuant  to  agreement  by
           4                   and between counselt and there is a
           5                   waiver of notice and  filing  of  notice.
           6                         MS. STARRT            That's correct.
           7     BY MR.  DAPORET
           8            Doctorf during this period  of  this  depositionr
           9            I'm going to be asking you some questions.  And
         10             if at any time I ask you a  question  you  don't
         11             know an answer tof tell me you don't knowf okay?
         12      A      Okay.
         13      0      You have to answer out loud for  the  benefit  of
         14             the court reporter, because  it's  difficult  to
         15             pick up a nod or a shake of the head, okay?
         16      A      Correct.
         17      Q      If at any time I ask you a  question  you  don't
         18             understand, tell me you don't understand the
         19             questiont and I'll try to rephrase it  or  define