1               IN THE COURT OF COMMON PLEAS
            2                 OF CUYAHOGA COUNTY, OHIO
            3             WORTH, etc.
            4                P 1 a i n t i f f s:
            5        VS.                 : Case No. 226873
            6   LUTHERAN  MEDICAL        : Judge Patricia Cleary
            7   CENTER, et al.           :
            8                Defendants  :
            9                       - - - - -
          10             DEPOSITION OF   ALAN WINE, M.D.
          11               THURSDAY, JANUARY 21, 1993
          12                        - - - - -
          13                  The deposition of ALAN WINE, M.D.,
          14    the Witness herein, called by counsel on behalf of
          15    the Defendants for examination under the statute,
          16    taken before me, Vivian L. Gordon, a Registered
          17    Professional Reporter and Notary Public in and for
          18    the State of Ohio, pursuant to agreement of
          19    counsel, at the offices of Meridia Suburban, 4200
          20    Warrensville Center Road, Warrensville Heights,
          21    Ohio, commencing at 3:00 o'clock p.m. on the day
          22    and date above set  forth.
          23                       - - - - -
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          2 5

                             Morse, Gantverg & Hodge
                                                                     2

            1   APPEARANCES:
            2           On behalf of the Plaintiffs:
            3                  Weisman, Goldberg & Weisman, by
            4                  RICHARD J. BERRIS, ESQ.
            5                  1600 Midland Building
            6                  Cleveland, Ohio  44115
            7                  781-1111
            8
            9           On behalf of the Defendants Oza and
          10            Kapoor:
          11                   Quandt, Giffels, Buck & Rodgers, by
          12                   BETH A. SEBAUGH, ESQ.
          13                   800 Leader Building
          14                   Cleveland, Ohio  44114-1460
          15                   2 4 1 - 2 0 2 5
          16
          17            On behalf of the Defendant Lutheran
          18            Medical  Center:
          19                   Arter & Hadden, by
          20                   KRIS H. TREU, ESQ.
          21                   1100 Huntington Building
          22                   Cleveland, Ohio  44115
          2 3                  6 9 6 - 1 1 0 0
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                              Morse, Gantverg & Hodge
                                                                   3

           I           on behalf of the Defendants Acute Care
           2           Specialists Inc., and David Pelini, M.D.:
           3                  Jacobson, Maynard, Tuschman & Kalur
           4                  THOMAS H. TERRY, III, ESQ.
           5                  1001 Lakeside Avenue - Suite 1600
           6                  Cleveland, Ohio 44115
           7                  736-8600
           8
           9           On behalf of the Defendants Medical Center
         10            Radiologists and Rodolpho Lontoc, M.D.:
         11                   Reminger & Reminger, by
         12                   DONALD J. MORACZ, ESQ.
         13                   The 113 St. Clair Building
         14                   Cleveland, Ohio 44113
         15                   687-1611
         16                       - - - - -
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                             Morse, Gantverg & Hodge
                                                                     4

            1           ALAN WINE, M.D., a witness herein, called
            2   for examination, as provided by  the  Ohio  Rules  of
            3   Civil Procedure, being by me  first  duly  sworn,  as
            4   hereinafter certified, was deposed and said as
            5   follows:
            6             EXAMINATION OF ALAN WINE, M.D.
            7   BY-MR.  TERRY:
            8   Q.      Doctor, my name is Tom Terry and I am going
            9   to be asking some questions.  If I ask you a
          10    question that you don't understand, I would
          11    appreciate it if you will tell me and I will
          12    attempt to rephrase it.
          13            If I use a phrase that doesn't make sense
          14    to you or you can't hear the question, the same
          15    thing applies.
          16            If you go ahead and answer  a  question,  the
          17    presumption is that both of  us  understand  what  it
          is    is I am talking about, which may or may not be
          19    accurate.  So don't try to  guess  what  I  am  asking