1 STATE OF OHIO

2  SS:

3 COUNTY OF CUYAHOGA )

4 IN THE COURT OF COMMON PLEAS (5

5

6 LAURA JONES, et al,

7 Plaintiffs,

a VS Civil Action

9 KAISER FOUNDATIONS HOSPITALS, No 153183

10 et al,

11 Defendants

12 --------------------------------- 1

13 APPEARANCES:

14 JEROME ELLERIN CO, LPA, 1717 Bond Court,

15 Cleveland, Ohio 44114

16 For the Plaintiffs

17 BY: JEROME ELLERIN

18 WEISMAN, GOLDBERG, WEISMAN & KAUFMAN CO, LPA,

19 1600 Midland Building, Landmark Office Towers,

20 Cleveland, Ohio 44115

21 For the Plaintiffs,

22 BY: RICHARD J BERRIS

23

24 DEPOSITION OF RICHARD A FIELDS, MD

25 Taken on June 14, 1990

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I APPEARANCES (Continued):

2 GALLAGER, SHARP, FULTON & NORMAN, 630 Bu2kley

3 Building, Cleveland, Ohio 44125

4 For the DEFENDANTS

5 BY: BEVERLY A HARRIS

6 The deposition of RICHARD A FIELDS, MD,

7 a witness in the above-entitled cause, taken before

a Loretta L Stump, Certified Shorthand Reporter and

9 Notary Public in and for Genesee County, Michigan

10 (Acting in Oakland County, Michigan), at 29580

11 Northwestern Highway, Suite 110, Southfield,

12 Michigan, on the 14th day of June, 1990, commencing

13 at 2:30 o'clock PM, pursuant to the Michigan Court

14 Rules

15

16

17 I N D E X

is PAGE

19 Examination by Ms Harris 3

20

21 E X H I B I T S

22 MARKED FOR

23 IDENTIFICATION

24 Deposition Exhibit Number 1 16

25

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1 RICHARD A FIELDS, MD

2 having been first duly sworn, was examined and

3 testified on his oath as follows:

4 EXAMINATION

5 BY MS HARRIS:

6 Q Would you state your full name for the record,

7 please?

8 A Richard Allen Fields

9 Q Did you bring a CV with you, Dr Fields?

10 A No I'll mail you one with the bill

11 Q Fine Can you tell me your educational background?

12 A Undergrad Wayne State University, Bachelor of Science

13 1963; MD degree 1967, same institution; rotating

14 internship Sinai Hospital of Detroit 167-68 followed

15 by a residency in OB/GYN again at Sinai Detroit,

16 completed in 171

17 Q That was what, a three-year residency?

18 A Yes

19 Q Any training after that?

20 A Nothing more than continuing medical education except

21 for courses in ultrasound and laser surgery

22 Q After you completed your three-year residency, what

23 did you do?

24 A Private practice

25 Q Since 1971 when you finished the residency, have you

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1 been in private practice?

2 A Yes

3 Q Do you practice with anyone, Doctor?

4 A No

5 Q Are you board certified?

6 A Yes

7 Q When were you certified?

8 A 174

9 Q That is both in oral and written boards?

10 A Correct

11 Q Did you pass both parts on the first try?

12 A Written first, oral second

13 Q Did you pass both parts on the first try?

14 A No, written is first, oral is second

15 Q Did you pass the written examination the first time

16 you took it?

17 A Yes

is Q Did you pass the oral examination the first time you

19 took it?

20 A No

21 Q Okay How many times did you take the oral exam?

22 A Twice

23 Q And I take it you passed it on the second?

24 A Correct

25 Q Did you have to wait any period of time before you

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1 can retake the one portion you don't Pass?

2 A One year

3 Q Now, have you testified before?

4 A Yes

5 Q How many times?

6 A Since late 19 -- oh, probably the past three or four

7 years about fifteen depositions a year and anywhere

8 from three to five trial appearances a year Before

9 that, less frequently

10 Q Let me see If I get It straight Fifteen depositions

11 a year and then in addition to that three to four

12 trials a year?

13 A Yes

14 Q How many reports do you write a year as opposed to

is giving testimony?

16 A Reports? You mean written reports?

17 Q Written reports, yes, sir

18 A Three or four a year at the most

19 Q When you give testimony, you said approximately

20 fifteen depositions a year, do you usually write

21 reports for those depositions?

22 A I would say 99 percent of the attorneys that I review

23 cases for specifically do not want a written report

24 Q Of these fifteen or so depositions or three to four

25 trials a that you do, that was over the last how many

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