STATE OF OHIO,
COUNTY OF MUSKINGUM.		) SS:


IN THE COURT OF COMMON PLEAS


THELMA KAREN SPICER,

Plaintiff,
	vs.	) Case No. CA94-85l

BETHESDA HOSPITAL, et al.,

Defendants.




THE DEPOSITION OF DR. RICHARD W. WATTS
FRIDAY, AUGUST 4, 1995




	The deposition of DR. RICHARD W. WATTS, a
witness herein, called by the Defendants for
examination pursuant to the Ohio Rules of Civil
Procedure, taken before me, the undersigned,
Darlene Lowe, Court Reporter and Notary Public
within and for the Stat~e of Ohio, taken at the offices
of Wanous Reporting Service, 1225 Illuminating
Building, 55 Public Square, Cleveland, Ohio, commencing
at 2:03 p.m., the day and date above set forth.


WANOUS REPORTING SERVICE
55 PUBLIC SQUARE
1225 ILLUMINATING BUILDING
CLEVELAND, OHIO 44113
(216) 861-9270

2


1
APPEARANCES:
2

3
	4	On behalf of the Plaintiff:
	5	James A. Marx, Attorney at Law
		Traci & Marx
	6	1550 Illuminating Building
		55 Public Square
	7	Cleveland, Ohio 44113

8
	9	On behalf of Defendants Medical Specialists,
		Inc.~ and Dr. John E. Shaner:
	10
		   Kevin T. Brennan, Attorney at Law
	11	   Jacobson, Maynard, Tuschman & Kalur
		   Suite 880, 175 South Third Street
	12	Columbus, Ohio 43215
	13
	14
	15
	16
	17

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Computer Transcription - Wanous Reporting Service

3

	1		             DR. RICHARD W. WATTS
	2	of lawful age, called by the Defendants for
	3	examination, pursuant to the Ohio Rules of Civil
	4	Procedure, having been first duly sworn, was examined
	S	and testified as follows:
	6		     EXAMINATION OF DR. RICHARD W. WATTS
	7	BY MR. BRENNAN:
	8	Q	  Doctor, would you please state your name and
	9		  professional address for the record?
	10	A	  I'm Richard Ward Watts, M.D., 3885 Rocky River
	11		  Drive, Cleveland, Ohio.
	12	Q	  What is located at 3885 Rocky River Drive?
	13	A	  That is a one-story medical building.
	14	Q	  Okay. And your office is maintained there?
	15	A	  It is.
	16	Q	  Is there anyone else in that building with you?
	17	A	 Yes. There are four offices in that building.
	18	Q	 Okay. Do you practice. with anyone or are you a
	19		  solo practitioner?
	20	A	 No, I'm part of the West Side Cardiologist
	21		 Associates, Inc. I'm the president of it. We
	22		- also have Thomas Cumerford. He's been with me
	23		 15 years and Dr. Marcello Mellino who has been
	24		 associated with us for two years. -
	25	Q	  I take it you've given a deposition before?



Computer Transcription - Wanous Reporting Service

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	1	A	Ihave.
	2	Q	My name is Kevin Brennan. I represent
	3		John Shaner, the physician involved in this
	4		litigation. You've been identified as
	5		plaintiffs' expert witness and I'm here,
	6		hopefully as you know, to try and learn from you
	7		the opinions you hold regarding my client's care
	8		and treatment, the basis for those opinions, and
	9		kind of what you're going to testify at the
	10		trial in this matter. Do you understand that?
	11	A	I do.
	12	Q	Okay. If at any time you don't understand my~
	13		question, please let me know and I'll do my best
	14		to rephrase it, okay?
	15	A	Okay.
	16	Q	What I'd like to do first is just discuss your
	17		background. You told me you practice in a
	18		cardiology practice and you just handed me your
	19		CV. I guess I'm just going to run through it
	20		here. I'm reading it and talking to you at the
	21		same time, so bear with me as questions come up,
	22		I just may be commenting on something. It may
	23		require an answer, it may not, okay?
	24		      Upon completion of your undergraduate in
	25		'42, you went to medical school, correct?



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	1	A	Correct.
	2	Q	You obtained a Bachelor of Science in 1942. Was
	3		there any major associated with that or is that
	4		a pre-med major?
	5	A	Pre-med major.
	6	Q	Graduated from Case '46. Tell me what residency
	7		you completed, it's difficult for me here --
	8	A	Well, I had a residency in internal medicine,
	9		residency in pathology, two years in the Army in
	10		Japan, another residency in medicine; and then a
	11		final year as a cardiac fellow at University
	12		Hospitals.
	13	Q	Did you ever do just a general internship?
	14	A	No.
	15	Q	Okay.
	16	A	My internship was a straight internship in
	17		medicine.
	18	Q	My understanding of residency, they last several
	19		years --
	20	A	That's right.
	21	Q	-- in the present educational system?
	22	A	Yes.
	23	Q	You did one year of medicine residency in '47,
	24		correct?
	25	A	Correct.



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	1	Q	Then you didn't complete -- that's not a
	2		complete residency at that point in time?
	3	A	Well, let me explain. At the end of World War
	4		II, we were still on nine-m