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1 State of Ohio, S S 2 County of Cuyahoga. 3 4 IN THE COURT OF COMMON PLEAS 5 6 LAURIE SMITH, Plaint if f , VS. Case No. 76,756 8 CLEVELAND METROPOLITAN 9 GENERAL HOSPITAL, et al., 10 Defendants. 1 1 12 DEPOSITION OF KINGSBURY G. HEIPLE, M.D. 13 Thursday, September 10, 1987 1 4 15 The Deposition of KINGSBURY G. HEIPLE, M.D., a 16 witness called by the Plaintiff pursuant to the Ohio Rules of Civil Procedure, taken before me, Robert A. 1 7 18 Cangemi, a Notary Public within and for the State of 19 Ohio, by agreement of counsel and without further 20 notice or other legal formalities, at University Hospitals of Cleveland, Cleveland, Ohio, c 2 1 2 2 at 12: 00 o Iclock noon, on the day and d ate above set 23 forth. 2 4 2 5 I 2 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 Weisman, Goldberg, Weisman & Kaufman Richard Berris, Esq. 540 Leader Building 4 Cleveland, Ohio 44114 5 On behalf of Defendant Metropolitan General Hospital: 6 Reminger & Reminger John R. Irwin, Esq. 7 The 113 Building Cleveland, Ohio 44114 8 On behalf of Defendant Mary B. Matejczyk, M.D.: 9 Jacobson, Maynard, Tuschman & Kalur Robert C. Maynard, Esq. 10 100 Erieview Plaza - 14th Floor Cleveland, Ohio 44114 1 1 12 ALSO PRESENT: 13 Mary B. Matejczck, M.D. 1 4 1 5 1 6 1 7 1 8 1 9 2 0 2 1 2 2 2 3 2 4 2 5 3 1 KINGSBURY G. HEIPLE, M.D. 2 called by the Plaintiff for examination under the 3 Ohio Rules of Civil Procedure, having been first duly 4 sworn, as hereinafter certified, was examined and 5 deposed as follows: 6 CROSS-EXAMINATION 7 BY MR. BERRIS: 8 Q. State your full name. 9 A. Kingsbury Grall Heiple. 10 Q. And you are a medical man, a physician? 11 A. I am a physician. 12 Q. Doctor, I am going to ask you questions about 13 your review of various records relating to the matter. 14 of Laurie Smith versus Cleveland Metropolitan General 15 Hospital and Dr. Matejczyk. 16 A. Okay. 17 Q. If you don't understand any of my qlestions, 18 or you feel that I should make the question clearer, 1 9 please let me know and I will try to do that for you, 20 okay? 2 1 A . F i n e . 22 Q. I will assume that if you answer my question, 23 you have done so because you understood the question, 24 is that fair? 25 A. Correct. 4 1 Q. Could you describe your relationship with Dr. 2 Matejczyk? 3 A. I am Chairman of the Department of Orthopedic 4 Surgery at Case Western Reserve University School of 5 Medicine, and as such I am her academic supervisor, 6 in terms of her appointment
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