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1 COMMON PLEAS COURT 2 GUERNSEY COUNTY 3 STATE OF OHIO 4 5 6 LINDA NEFF, ADMINISTRATRIX OF THE ESTATE OF 7 RICHARD NEFF, 8 PLAINTIFF, 9 VS : CASE NO 96-CV—432 JUDGE ELLWOOD 10 RICK E COX, DC, ET AL, 11 DEFENDANTS 12 13 14 DEPOSITION OF 15 SAMUEL J KIEHL, MD 16 JULY 21, 1999 17 18 19 20 21 22 E & A REPORTING SERVICE, INC 23 915 SOUTH FRONT STREET COLUMBUS, OHIO 43206 24 (614) 445—6300 2 2 DEPOSITION OF SAMUEL J KIEHL, MD, A 3 WITNESS CALLED BY THE DEFENDANTS AS IF UPON CROSS- 4 EXAMINATION, TAKEN BEFORE ME, MISTIANN OCANAS, A 5 NOTARY PUBLIC WITHIN AND FOR THE STATE OF OHIO, AT 6 THE OFFICES OF THE DEPONENT, 4619 KENNY ROAD, 7 COLUMBUS, OHIO 43220, COMMENCING AT 3:05 PM, SAID 8 DEPOSITION TAKEN PURSUANT TO THE STIPULATIONS 9 HEREINAFTER SET FORTH 10 11 APPEARANCES: 12 ROBERT V TRACI, ESQ, OF THE LAW FIRM 13 OF TRACI & MARX, 55 PUBLIC SQUARE, SUITE 1550, 14 CLEVELAND, OHIO, 44113, APPEARING ON BEHALF OF THE 15 PLAINTIFF 16 THEODORE M MUNSELL, ESQ, OF THE LAW 17 FIRM OF LANE, ALTON & HORST, 175 SOUTH THIRD STREET, 18 COLUMBUS, OHIO 43215, APPEARING ON BEHALF OF 19 DEFENDANTS DR HOJAT, DR MUNRO, AND HOLZER CLINIC 20 JAMES S OLIPHANT, ESQ, OF THE LAW FIRM 21 OF PORTER, WRIGHT, NORRIS & ARTHUR, 41 SOUTH HIGH 22 STREET, COLUMBUS, OHIO 43215, APPEARING ON BEHALF OF 23 DEFENDANT RICK E COX, DC 24 3 1 APPEARANCES (CONT'D): 2 3 GWEN S KARR, ESQ, OF THE LAW FIRM OF 4 REMINGER & REMINGER, SOUTH HIGH STREET, COLUMBUS, 5 OHIO 43215, APPEARING ON BEHALF OF DEFENDANT HOLZER 6 MEDICAL CENTER 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 STIPULATIONS 2 3 IT IS AGREED AND STIPULATED BY AND AMONG 4 COUNSEL FOR THE RESPECTIVE PARTIES HEREIN THAT THIS 5 DEPOSITION MAY BE TAKEN IN SHORTHAND BY MISTIANN 6 OCANAS, WHO MAY LATER, OUT OF THE PRESENCE OF THE 7 WITNESS, TRANSCRIBE OR CAUSE SAID SHORTHAND NOTES TO 8 BE TRANSCRIBED; THAT THE FORMALITIES AS TO THE TIME 9 AND PLACE OF THE TAKING OF THE DEPOSITION ARE BY 10 AGREEMENT OF COUNSEL; AND THAT THE QUALIFICATIONS OF 11 THE OFFICER BEFORE WHOM TAKEN SHALL BE EXPRESSLY 12 WAIVED 13 14 15 16 17 18 19 20 21 22 23 24 5 1 ~ TABLE OF CONTENTS 2 3 EXAMINER TYPE PAGE 4 MR MUNSELL CROSS-EXAMINATION 6 5 MR OLIPHANT CROSS-EXAMINATION 49 6 MS KARR CROSS-EXAMINATION 51 7 MR MUNSELL FURTHER CROSS-EXAMINATION 52 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 1 THEREUPON, 2 SAMUEL J~ KIEHL, MD 3 BEING BY ME FIRST DULY SWORN, 4 AS HEREINAFTER CERTIFIED, 5 TESTIFIES AS FOLLOWS: 6 CROSS-EXAMINATION 2 7 BY MR MUNSELL: 8 Q LET'S BEGIN BY STATING YOUR FULL NAME 9 A SAMUEL 3 KIEHL 10 Q AND WHAT IS YOUR CURRENT OFFICE ADDRESS? 11 A I'M SORRY? 12 Q WHAT IS YOUR CURRENT OFFICE ADDRESS? 13 A 4619 KENNY ROAD, COLUMBUS, OHIO 43220 14 Q AND THIS IS AN OFFICE BUILDING? DO YOU 15 SEE PATIENTS HERE OR ANYTHING LIKE THAT, DR KIEHL? 16 A I SEE SOME PATIENTS HERE I TAKE CARE 17 OF THE MORMON MISSIONARIES IN THIS AREA, SO WHEN THEY 18 GET SICK, I HAVE THEM COME HERE 19 Q BESIDES THE MORMON MISSIONARIES, DO YOU 20 SEE ANYONE ELSE HERE? 21 A WELL, I'VE DONE A COUPLE YOUTH PHYSICALS 22 FOR ATHLETICS I DON'T -- THIS IS NOT -- I DON'T DO 23 PATIENTS HERE AS A RULE, BUT I MEAN I'VE DONE -- I 24 DO -- WHEN I'M HERE •AND I NEED TO DO SOMETHING, I DO 7 1 IT 2 Q YOUR STAFFS -- OR POSITIONS HAVE CHANGED 3 SINCE I THINK YOU AND I LAST NET A COUPLE YEARS AGO 4 WHERE ARE YOU CURRENTLY WORKING? 5 A I'M AN EMERGENCY DOCTOR AT LONDON, OHIO 6 AT MADISON COUNTY EMERGENCY DEPARTMENT 7 Q AND HOW MANY HOURS ARE YOU AT LONDON 8 WORKING THERE? 9 A TWENTY-FOUR HOURS A WEEK 10 Q ARE YOU A SUPERVISOR OR EMPLOYEE? 11 ANOTHER ER DOCTOR LIKE YOU WERE BEFORE? 12 A I'M AN INDIAN 13 Q YOU'RE AN INDIAN AND NO LONGER THE 14 CHIEF? 15 A THAT'S CORRECT 16 Q ARE YOU STILL AFFILIATED WITH OLENTANGY 17 EMERGENCY ROOM PHYSICIANS, THE OLD CORPORATION? 18 A THAT'S MY COMPANY 19 Q THAT'S YOUR COMPANY? 20 A AND I STILL HAVE IT IN ADDITION TO 21 THAT, I ALSO DO PRESURGICAL PHYSICAL EXAMINATIONS AT 22 RIVERSIDE 23 Q HOW MANY HOURS A WEEK OR A MONTH DO YOU 24 DO PRESURGICAL PHYSICALS? 8 1 A PROBABLY ABOUT FIVE OR SO A MONTH, FIVE 2 TO TEN A MONTH I'M AFFILIATED WITH THREE OTHER 3 PHYSICIANS WHO -- WE SHARE THAT DUTY 4 Q TWENTY-FOUR HOURS A WEEK YOU'RE AN 5 EMERGENCY ROOM PHYSICIAN, FIVE OR SO HOURS A MONTH 6 YOU DO PRESURGICAL PHYSICALS? 7 A RIGHT 3 8 Q ANY OTHER TIME SPENT PROFESSIONALLY? 9 A IDO ABOUT EIGHT HOURS A WEEK OF 10 CONSULTING WORK ON EMERGENCY MEDICINE ISSUES 11 Q IS THAT WHAT THIS IS? 12 A YES, THAT'S PART OF THIS 13 Q OKAY LET'S BREAK DOWN THIS CONSULTING 14 WORK HOW MUCH OF IT IS WHAT WE CALL MEDICAL-LEGAL? 15 A
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