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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, MD 13 Thursday, September 10, 1987 1 4 15 The Deposition of KINGSBURY G HEIPLE, MD, 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, MD: 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, MD 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, MD 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 as an assistant professor 7 of orthopedic surgery in the School of medicine 8 I am the senior member and President of the 9 orthopedic group, that is, the co-existent private 10 practice group of which she is a member, that runs 11 the orthopedic Departments of Metropolitan General 12 Hospital, the Cleveland Veterans Administration 13 Hospital and University Hospitals of Cleveland 14 Q All right 15 And that private group would be University 16 Orthopedic Associates, Inc, is that the full name? 1 7 A R i g h t 18 Q Would it be fair to describe your relationship 19 with Dr Matejczyk in that organization, University 20 Orthopedic Associates, Inc, as partners? 21 A I would be her senior partner, althDugh it is 22 not a partnership 23 Q It is a professional corporation? 24 A It is a professional corporation 25 Q What records did you review in prepiration for 1 your testimony today? 2 A I have seen a number of things, including an 3 affidavit of Dr Matejczyk that was made sometime 4 back This one was made the 3rd of September, 1983 5 I have also at least scanned a number of 6 depositions that were taken 7 Q Are you able to tell me what depositions you 8 have reviewed? 9 A Oh, there were at least three of them, so I 10 would not be able to tell you by specifics 11 MR BERRIS: Maybe Mr Maynard 12 can help us 13 MR MAYNARD: Do you recall that 14 you scanned a portion of Dr Imbembo's 15 deposition? 16 THE WITNESS: Correct 17 MR MAYNARD: And you scanned a 18 portion of Dr Harry Figgie's deposition? 19 THE WITNESS: Correct 20 MR MAYNARD: I think you 21 scanned a portion of -- I am just trying to 22 think which ones I had there that day, Harry 23 Figgie, Dr Imbembo -- 24 THE WITNESS: Maybe tie third 25 document was the chart itself 6 1 MR MAYNARD: I thinR I hid a 2 third deposition 3 Let the record show I didn' physically 4 deliver Xerox copies, as we so frequently do 5 Dr Heiple reviewed my copies, and then I took 6 them back 7 THE WITNESS: Right 8 MR MAYNARD: So we have no 9 litany of exactly what he has reviewed, but he 10 has reviewed the pertinent portions of -- and 11 he can tell you what he regards as pertinent 12 portions of the hospital record, Dr 13 Katejczykls affidavit, Dr deWolfel 14 deposition -- do you recall that? 15 THE WITNESS: Correct 16 MR MAYNARD: The opinion 17 testimony and Dr deWolfe's testimony; did you 18 review that? 19 TH
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