STATE OF OHIO,
COUNTY OF MUSKINGUM.	) SS:


IN THE COURT OF COMMON PLEAS


JOLENA McCONNELL,
Administratrix of the Estate
of Trevor D. McConnell,
deceased,

Plaintiff,
	vs.	) Case No. CA950528
		   Judge Wolfe
BETHESDA HOSPITAL, et al.,

Defendants.


THE DEPOSITION OF JOHN P. CONOMY, M.D., J.D.
MONDAY, NOVEMBER 4, 1996


	The deposition of John P. Conomy, M.D., J.D., a
Witness herein, called by the Defendants for
examination pursuant to the Ohio Rules of Civil
Procedure, taken before me, the undersigned,
Marcie S. Smith, a Registered Professional Reporter and
Notary Public within and for the State of Ohio, taken
at the offices of Traci & Marx, 55 Public Square,
Suite 1500, Cleveland, Ohio, commencing at 3:50 p.m.,
the day and date above set forth.


WANOUS REPORTING SERVICE
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	1	JOHN P. CONOMY, M.D., J.D.
	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, as

5 .	hereinafter certified, was examined and
	6		testified as follows:
	7		EXAMINATION OF JOHN P. CONOMY, M.D., J.D.
	8	BY MR.	LODICO:
	9	Q	While we're waiting for your curriculum vitae,
	10		Dr. Conomy, have you prepared any written
	11		reports or letters other than a letter to
	12		Mr. Marx of March 25, 1996?
	13	A	No, I haven't.
	14	Q	All right. At the time this was prepared, back
	15		in March, you were apparently on your way to
	16		San Francisco for some sort of meeting.
	17		      Had you had the opportunity at that point
	18		to review any materials relating to Trevor
	19		McConnell?
	20	A	Yes.
	21	Q	What had you reviewed at that time?
	22	A	I'll be able to showyou. I had a series of
	23		plain skull films obtained early in his first
	24		visit to the emergency room, the event with
	25		which we're concerned. This was on the 2nd of



Computer Transcription - Wanous Reporting Service

5


	1		July, 1993. I had the results of his second
	2		visit to the emergency room. I'm not certain
	3		that I had the deposition of Dr. Stein and
	4		Jolena Mcconnell at that point. I just simply
	5	.	don't recall. I may or may not have. But I
	6		have those.
	7		      I had received, from Mr. Marx, guidelines
	8		or standards of care from Bethesda Hospital
	9		emergency department in Zanesville, Ohio
	10		regarding head injuries, child abuse and neglect
	11.		reporting and identification.
	12		      subsequent to that, I received a
	13		deposition that was given by Dr. R. Daryl
	14		Steiner.
	15	Q	When did you get Dr. Steiner's deposition?
	16	A	I'm not insure. I know I didn't have the
	17		report.
	18	Q	Have you seen Joe Stein's deposition,
	19		Dr. stein's deposition?
	20	A	I mentioned that I had gotten the deposition of
	21		Dr. stein and Jolena Mcconnell.
	22	Q	How about any of the emergency department
	23		nurses, have you reviewed their depositions?
	24	A	No, I haven't
	25	Q	All right.



computer Transcription - Wanous Reporting Service

6
	1	A	I also have -- I also received, I believe this
	2		was with the original materials, an autopsy
	3		report regarding Trevor McConnell.
	4	Q	All right. Since you wrote this report on March
	5		25, 1996, have any of the opinions that you've
	6		set out in this report changed in any way?
	7	A	No.
	8	Q	All right. Do you have a copy of your letter
	9		with you by any chance?
	10	A	I do.
	11	Q	All right. That has been marked in
	12		Dr. Steiner's deposition as Defendant's
	13		Exhibit E. We'll just leave it with that
	14		designation for now.
	15		      In your report, on the first page you make
	16		some comment in the third paragraph, numbered
	17		one through four, under paragraph number one it
	18		says -- or number one it says, Trevor appears in
	19		the emergency room having, quote, fallen
	20		yesterday. And you make the comment, This is
	21		not the time that most concerned mothers bring a
	22		chi