1	 IN THE COMMON PLEAS COURT OF GUERNSEY COUNTY, OHIO
	2
	3	 LINDA NEFF, ADM OF THE
	4	 ESTATE OF RICHARD NEFF,
	5	       PLAINTIFF, )
	6	    -vs- ) CASE NO 96CV432
	7	 RICK E COX, DC, ET AL,
	8	       DEFENDANTS
	9
	10
	11	       DEPOSITION of DOUGLAS A RUND, MD, FACEP, a
	12	Witness herein, called by the Plaintiff for examination
	13	under the statute, taken before me, Debbie M Bobo,
	14	Registered Professional Reporter, Notary Public in and
	15	for the State of Ohio, pursuant to the stipulations of

16	counsel hereinafter set forth at 376 West Tenth Avenue,
	17	Columbus, Ohio, on Monday, October 11, 1999, beginning at
	18	3:15 pm
	19

20
	21	TAHYI VIDEO & COURT REPORTING, LTD
		         334 Main Street
	22	     Zanesville, Ohio 43701
		         (800) 526-6508
23

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	25	-


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APPEARANCES:


2	ON BEHALF OF THE PLAINTIFF:

3
		James A Marx, Esq
	4	TR~CI & MARX
		55 Public Square
	5	Suite 1550
		Cleveland, Ohio 44113
6
	7	ON BEHALF OF THE DEFENDANTS:


8	(Rick E Cox, DC)
		James S Oliphant, Esq
	9	PORTER, WRIGHT, MORRIS & ARTHUR
		41 South High Street
	10	Columbus, Ohio 43215

11	(Holzer Medical Center)
		Gwenn S Karr, Esq
	12	REMINGER & REMINGER, CO, LPA
		505 South High Street
	13	Columbus, Ohio 43215

14	(Dr Hojat, Dr Munro, and Hoizer Clinic)
		Theodore M Munsell, Esq
	15	LANE, ALTON & HORST
		175 South Third Street
	16	Columbus, Ohio 43215
	17
	18
	19
	20
	21
	22
	23
	24

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	1	STIPtJLATIONS

2	It is stipulated by and among counsel for the

3 respective parties that the deposition of DOIJGLAS A RUND,

4 MD, FACEP, a Witness herein, called for examination by

5 the Plaintiff under statute, may be taken at this time by

6 the Notary and by agreement of counsel without notice or

7 other legal formality; that said deposition may be reduced

8 to writing in stenotype by the Notary whose notes may

9 thereafter be transcribed out of thepresence of the
	10	witness; that proof of the official character and
	11	qualification of the Notary is waived

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INDEX OF EXATVIINATION
			PAGE NO
	2	BY MR MARX	5
		BY MR OLIPHANT~	66
	3	BY MR MARX	67

4
INDEX OF EXHIBITS
	5		PAGE NO
		Exhibit 1	   6
	6	Curriculum vitae

7

8

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10

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12

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	5
	1	DOUGLAS A RUND, MD, FACEP

2	being by me first, duly sworn, as hereinafter

3	certified, deposes and says as follows:
	4	EXAMINATION

5	EY MR MARX:
	6	Q		Doctor, would you please state your name for

7	the record
	8	A	Douglas A Rund
	9	Q	And what is your current address, Doctor?
	10	A	016 Prior Health Sciences Library, 376 West

11	Tenth Avenue
	12	Q		And you reside in what county?
	13	A		Frank --, Franklin County
	14	Q		Okay What's your birth date, Doctor?
	15	A		July 20th, 1945
	16	Q		Have you had your deposition taken before?
	17	A		Yes
	18	Q		And have you testified in court before?
	19	A		Yes '
	20	Q		Okay So you know how this works, obviously,
	21	having done it If I ask you any questions today that
	22	you	don't understand, it's very important that you
	23	please let me know that Okay?
	24	A		Yes
	25	Q		And I will expect that if you don't let me


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A
6
know that, that you understood the questions when you

answered it Fair éiiotigh~
Yes
Q	All right If you need to take a break, for
whatever reason, let me know, and we'll do that
A Yes

Q	Okay How many times have you previously been
deposed, approximately?

MR MUNSELL:	On medical/legal cases?
MR MARX: We can limit it to
1

2

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25
60
medical/legal cases, sure

A	I don't know exactly I would say maybe 50 to
for
S --
I
Q	Okay And do you usually testify for doctors,
or claimants in medical malpractice cases?

A	I would say, in the testimony have given,
it it's been more for doctors than claimants

Q	Okay And can you give me an approximation,
in percentages, as to how often you've testified for
doctors in medical malpractice cases versus claimants?

A	I would say it's 80 to 90 percent
Q
Okay
(Plaintiff's Exhibit 1 marked)
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			                                           7
	1	Q	    Doctor, I've had the reporter mark Exhibit 1,
	2	which is your curriculum vitae, which you just gave me:
	3	is that correct?
	4	A	    Yes
	5	Q	   And is that up to date and current?
	6	A	   Reasonably so There are a few presentations
	7	that	aren't here, but it's --
	8	Q	   Okay Is there anything that would be
	9	pertinent to the issues in this case that is not on
	10	your