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           I   State of Ohio,
                                           SS:
           2   County of Cuyahoga

           3                                - -  -

           4                     IN THE  COURT  OF COMMON PLEAS

           5                                - -  -

           6   Laura Jones, et al,

           7                     Plaintiffs,
                                                   Case No 153183
           8          VS

           9   Kaiser Foundation   Hospitals,
               et al,
          10
                                 Defendants
          11

          12                                - -  -

          13             DEPOSITION OF RICHARD FIELDS, MD

          14                  TUESDAY, OCTOBER 30, 1990

          15                                - -  -

          16   The deposition of Richard Fields, MD, a witness

          17   herein, called by the Plaintiffs for examination

          18   under the Ohio Rules of Civil Procedure, taken

          19   before me, Ivy J Gantverg, Registered Professional

          20   Reporter and Notary Public in and for the State of

          21   Ohio, by agreement of counsel and without further

          22   notice or other legal formalities, at the offices of

          23   Weisman, Goldberg, Weisman & Kaufman, 1600 Midland

          24   Building, Cleveland, Ohio, commencing at 12:35 pm,

          25   on the day and date above set forth



                                 MORSE, GANTVERG & HODGE

                                                                 2

            1  APPEARANCES:

            2  On behalf of the Plaintiffs:

            -3         Richard J  Berris,  Esq
                       Weisman, Goldberg, Weisman & Kaufman
            4          1600 Midland Building
                       Cleveland, Ohio     44115
            5
                       Leslie Chavers, Esq
            6          Jerome M Ellerin Company
                       1717 Bond Court Building
            7          Cleveland, Ohio  44114

            8  On behalf of the Defendants:

            9          Beverly A  Harris,  Esq
                       Cheryl D Atwell, Esq
          10           Gallagher, Sharp, Fulton & Norman
                       630 Bulkley Building
          11           Cleveland, Ohio  44115

          12   Also Present:

          13           Maurice  Soremekum,  MD
                       Douglas Clark, Videographer
          1 4

          1 5

          1 6

          1 7

          1 8

          1 9

          2 0

          2 1

          2 2

          2 3

          2 4

          2 5



                                 MORSE, GANTVERG    HODGE

                                                               3
           1                    RICHARD FIELDS, MD
           2   a witness herein, called by the plaintiffs for
           3   examination under the Rules, having been first duly
           4   sworn, as hereinafter certified, was deposed and
           5   said as follows:
           6                 MR BERRIS:  Let the record reflect
           7          that this is the deposition of Dr Richard
           8          Fields, expert called on behalf of the
           9          plaintiffs in the matter of Laura Jones, et
         10           al versus Kaiser Hospitals, case number
         11           153183, Court of Common Pleas, Cuyahoga
         12           County, Ohio
         13                  Waiver with respect to any defect in
         14           notice and service, counsel?
         15                  MS HARRIS:  Correct
         16                      DIRECT EXAMINATION
         17    BY MR  BERRIS:
         18    Q     State your full name, please?
         19    A     Richard Allen Fields
         20    Q     And your professional address?
         21    A     18211 West Twelve Mile Road, Southfield,
         22    Michigan
         23    Q     And you are a medical doctor?
         24    A     Yes, sir
         25           Can you tell the jury what your specialty

                                MORSE, GANTVERG & HODGE
                                                             4
          1   area is within your practice of medicine?
          2   A     I specialize in obstetrics  and  gynecology
          3   9     I am going to ask you now to  explain  very
          4   briefly for the jury what the field  of  obstetrics
          5   and gynecology is all about?
          6   A     Gynecology is essentially the primary health
          7   care of the female  It  includes  certain  surgical
          8   areas, but for all practical purposes, is the care
          9   of a woman
         10          Obstetrics is a specialty that  deals  with
         11   pregnancy  The obstetrician's role is to care for a
         12   woman from