IN THE COURT OF COMMON PLEA

2
LORAIN COUNTY, OHIO





4 Susan Galvan, et al,


Plaintiffs,



6 -Vs- Case No *96



7 John J BittMan, MD,

et al,


Defendants

9


10


11 Deposition of DR ROBERT A

12 taken before William J Mahan, Regist red

13 Professional Reporter and Notary Publ@c within

14 and for the State of Ohio, at the off ces of


15 Weisman, Goldberg & Weisman, 54D Lead r Building,


16 Cleveland, Ohio, at lt45 PM, Friday September


17 7, 1979, pursuant to notice and stip]ations of


18 counsel by the defendants in this cause


19


20


21


22


2-


24


25

2
APPEARANCES:

2
Fred Weisman, Esq,

3 Weisman, Goldberg & Weisman,

4 and

5 Joseph Schneider, Esq
Meyers, Stevens & Rea,

6 On behalf of the Plaintiffs

7 Charles Kitchen, Esq,
Kitchen, Messner & Deery,
8

On behalf of Defendant
9 Lorain Community Hospita

10 James J Morey, Esq,

11 McCray, Muzilla, Morey & Smith Co LPA

On behalf of Defendant
12 N P Restifo, MD;

13 Harley McNeal, Esq,
McNeal, Schick & Archibald,
14

On behalf of Defendant
15 John J Bittman, MDi

16 Robert C McFadden, Esq,
Arter & Hadden,
17
On behalf of Defendant
18 J G Dakters, MD;

19 Ms Carolyn Cappel,
Weston, Hurd, Fallon, Paisley & Houley,
20
On behalf of Defendant
21 Amherst Hospital

22



21

DRe ROBERT A HINGSON, of lawful

2
age, called by the defendants for he pur-

3 pose of examination as provided by the

4 Ohio Rules of Civil Procedure,, being by

5 me first duly sworn, as hereinafter

6 certified, deposed and said as follows:

7


8 EXAMINATION OF DR  ROBERT A HINGSON

9 MR WEISMAN: Before we


10 start, in the interest of avoiding unnecessary

11 correspondence, as long as everyone is here,

12 1 would like to present everyone at this time


13 with a copy of a report of Edward  Siegler,


14 MD, Director of Laboratories at Southgate


15 Medical Laboratories Service, and --hief of


16 Pathology, I believe, at Mt Sinai Hospital


17 This report is dated August 29, 1979


18 and it pertains to his examination of the


19 slides that were submitted to us be counsel


20 for the hospital that enabled this inspection


21 of the tissue that was taken on Sc:)tember 23,,


22 1972, apparently from Susan Galvan


23 fr-@e is a copy just for the purpose of


2-i arkn,_)7:T1_r,c1,:rrent and perhaps we migh attach this


at the en@'L of the deposition if yoi wish

I Your appearance here is on behalf of 4
2 whom?
3 MS CAPPEL: Amherst
4 Hospital I ain replacing Andrew B ckner today
5 MR WEISMAN: V ry good
6 Thank you
7 MR McNEAL: A e we ready?
8 MR WEISMAN: W are set
9 MR KITCHEN: 0 f the record
10 (Discussion had off the rec rd)
11 MR McNEAL: I it agreed
12 that I should start the deposition, the
13 interrogation?
14 Let the record show that this deposition
15 is being taken not for use during :he trial
16 of this case, but it is taken only for
17 information purposes, as has been oted in
18 the Notice to take deposition, and in accordanca
19 with Ohio Civil Rule 26(B)4, I hel eve, if 1
20 remember correctly
21 MS CAPPEL: T at is
22 correct
2 3 BY MR McNEAL:
@4 Q What is your name, please?
A Robert A Hingson, 11-i-n-g-s-o-ri
1 MR WEISMAN: L t the record
2 show that Mr McNeal is examining r Hinqson
3 an behalf of Dr Bittnan in this c se, the
4 attending physician and the anesth siologist
5 involved
6 Q where do you live?
7 A In Pittsburgh, Pennsylvania
8 0 What is the address?
9 A 824 Grandview Avenue
10 Q For how long have you lived there, si ?
11 A I have lived there for four years at hat address
12 in Pittsburgh  I was previously seve years at
13 another address in Pittsburgh, so it s eleven
14 years in Pittsburgh
15 Q Could you give me the month and year hen you did
16 leave Cleveland to reside in Pittsbur h?
17 A Yes, sir, that was in May of 1968
18 Q Just immediately prior to your leavin@  Cleveland,
19 with which hospital were you connecte ?
20 A I was at University Hospitals and aff liated
21 hospitals in the University series, t at is,
22 Metropolitan, Sunny Acres, Veterans, ighland View
23 and Rainbow
24 Q At that time what was your title or what was your
25 connection with each of those hospitals?
6
A I was Professor of Anesthesiology in the medical

2
school  I was Chairman of Anesthesio ogy in

3
University Hospitals  I was Organizirg Director

4
of all of the other hospitals in which I had

5
active directors from time to time, and during

6
vacancies I resumed directorship of these

7 hospi-tals

8 Q In the last two years before you left Cleveland,

9 which would be 1966, 1967 and 1968, were you

10 actively engaged in doing anesthesiology, were

11 you actually in the surgical suites during

12 operations?

13 A Yes, sir

14 Q Up until what time did you do such active work?

15 A Throughout my 17 years in Cleveland ir that

16 p