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2 THE STATE OF OHIO,
SS:
3 COUNTY OF CUYAHOGA.)

4

5 IN THE COURT OF COMMON PLEAS

MARIA FRANCESCA
6 BEDNARIK, et al.,

7 Plaintiffs,

B VS. Case No 108995

9 HOWARD JACOBSf M.D.f Robert Lawther, J.
et al.,
10
Defendants.
11

12

13 DEPOSITION OF DR.  ELLIOT S. H RSCHER

14 MONDAYf DECEMBER 15o 19 6

15

16 Deposition of Dr. Elliot S. Hersc@ er, a

witness called for examination by the Plaintiff
17
under the Ohio Rules of Civil Procedurep taken
18
beiore me, Richard G. Dellionico, a Registered
19
Professional Reporter and Notary Public within
20
and for the State of Ohio, pursuant to notice,
21 at 33001 Solon Road, Solon, Ohiop commencing
22

23 at 8':30 p.m. the day and date above set forth

24

25

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2 APPEARANCES:

3 On behalf of the Plaintiffs:

4 -HOWARD D. MISHKINDp ESQ.
Weisman, Goldberg, Weisman & Kauf an
5 540 Leader Building
Cleveland, Ohio 4 4 1 1 4
6

7 On behalf of the Defendants:

8 MARC W. GROEDEL, ESQ.
Reminger & Reminger
9 The 113 Building
Clevelandt Ohio 4 4 1 1 4
10

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13

14

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1 ELLIOT S. HERSCHER, M.D.

2 of lawful age, called as a witness by tie Plaintiff

3 pursuant to the Ohio Rules of Civil Procedure,

4 being by me f irst duly sworn, as herein f ter

5 certified, deposed and said as follows:

6 CROSS EXAMINATION

7 BY MR.  MISHKIND:

8 Q. Doctor, you have been previously worn in

9 so I will not go through that procedure with you.

10 You have heard the testimony of your pa tner, Dr.

11 Jacobs so you are somewhat familiar wit the

12 scope of the questioning, are you not?

13 A. Yes, I am.

14 Q. Would you first, for the record, ell us

15 who you are?

16 A. Elliot S. Herscher.

17 Q. And you are a pediatrician?

18 A. Pediatrician.

19 Q. And do you happen to have a curri ulum

20 vitae?

21 A. Not available, I am sorry.

22 Q. Where did you go to medical schoo r sir?

23 A. Penn State University.

24 Q. You graduated in what year?

25 A. 1978.



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1 And where did you do your post-graduate

2 training?

3 A. At Rainbow Babies and Children as an intern

4 for a year and then two years of pediatric

5 residency.

6 Q. And you are currently in private practice

7 here in Solon?

8 A. Yes.

9 Q. And have been in private practice since

10 what, about 1981?

11 A. Yes, July of 1 9 81

12 Q. And are you Board certif ied, doct )r?

13 A. Yes, I am.

14 Q. Do you have any speciality in ped atrics?

15 A. General pediatrics.

16 Q. An