1 State of Ohio,
S S
2 County of Cuyahoga.

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4 IN THE COURT OF COMMON PLEAS

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6 LAURIE SMITH,
Plaint if f ,
VS. Case No. 76,756
8
CLEVELAND METROPOLITAN
9 GENERAL HOSPITAL, et al.,

10 Defendants.

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12 DEPOSITION OF KINGSBURY G. HEIPLE, M.D.

13 Thursday, September 10, 1987

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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.
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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
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2 2 at 12: 00 o Iclock noon, on the day and d ate above set

23 forth.

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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

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12 ALSO PRESENT:

13 Mary B. Matejczck, M.D.

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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.
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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