I              IN THE COURT OF COMMON PLEAS

            2                   CUYAHOGA COUNTY, OHIO

            3     da Lea Damm, etc.,         )
               et al.,                       )
            4                                )
                           Plaintiffs,       )
            5                                ) Judge James F. Ki       ne
                    VS.                      )
            6                                ) Case No. 985,427
               William  G. Gilger, M. D.,    )
            7  et al-,                       )
                                             )
            8               Defendants.      )

            9

            10              Deposition  of  THEODORE  M.  KING,  M.  D.,

            11 taken before Kenneth F. Barberic, a Registered Pro-

            12  fessional Reporter and Notary Public within and for

            12  the State  of  Ohio,  at  the  Cuyahoga  County  Justice

            14  Center,  Cleveland,  Ohio,  at  2:00  p.m.,  on  Monday,

            151 January 28, 1980, pursuant to notice and/or stipula-

            16  tions of counsel, on behalf of the Defendant Parma

            17  Community General liospital in this cause.



            19  APPEARANCES:

            20       Fred Weisman, Esq., and
                     James R. Goldberg, Esq.,
            21       Weisman, Goldberg & Weisman,

            22               on behalf of the Plaintiffs;

            23       Lawrence Tucker, Esq.,

            24               oi, behalf of the Plaintiffs;

            25

                                                                        2
                 Andrew P. Buckner, Esq.,
                 Weston, Hurd, Fallon, Paisley & Howley,
           2
                          on behalf of the Defendant
                          Parma Community General Hospital;

           4      Robert  C. Maynard, Esq.,
                  Squire, Sanders & Dempsey,

                          on behalf of the Defendant
           6              John Budd, M. D.;

           7      Albert  J. Rhoa, Esq.,
                  Rhoa, Follen, Rawlin & Johnson,

                          on behalf of the Defendant
           '9             William G. Gilger, M. D.



           1101 ALSO PRESENT:         - - -



           12     John Budd, M. D.

           14                     THEODORE M. KING, M. D., called
           15             by the Defendant Parma Community General
           16             Hospital for the purpose of cross-
           17             examination, as provided by the Ohio Rules
           is             of Civil Procedure, being by me first
           19             duly sworn, as hereinafter certified,
           20             deposed and said as follows:
           21      CROSS  FXAMINATION OF THEODORE M' TING' M' D-
           22  BY MR. BUCKNER:
           2',t                    MR. BUCKNER:         Let the record
           24              show that the deposition of Dr. Theodore
           2"i             M. King is being taken pursuant to the
                                                                        3
           1              RUIes of Civil Procedure and in particular
           2              Rule 26 (b) (4) (b) for discovery purposes.
                          I believe this is by agreement of Counsel
           4              as to everything.  Fair enough, Mr. Weisman?
           5                      MR.  WEISMAN:        Yes.
           6                      MR.  BUCKNER:        Everything
           7              is set up by agreement.
           8                      MR.  WEISMAN:        Well, as to
           9              everything you just said.
           10                     MR.  BUCKNER:        I mean in
           11             terms of notice and everything we did it
           12             pretty much by agreement.
               QL  I'm going to be asking you some questions,
           14      Doctor, with respect to your background and my
           15      area of particular interest will be the
           IC)     hospital's involvement in this case.
           17             If I ask you a question that you don't
           is  I   understand or if you don't hear me completely,
           19      tell me that.  If you will, answer each question
           20      out loud because if you nod or shake your head
           21      he doesn't get an answer for that, okay?
           22  A-  All right.
           2-@' Q. If you want to stop at any time, let me know
           24      and we will do that.
                        Will you state your full name for the record,
                                                                      4
           1       please?
           1
           2    A. Theodore Matthew Kinq.

                (L What is your age and date of birth?

           4    A. My date of birth was 2-13-31.  it makes me 49