1  State of Ohio,       )
                                 )  SS:
         2  County of Cuyahoga  )

         3
                        IN THE COURT OF COMMON  PLEAS
         4

         5  Jeffrey D Sanders, et  al,

         6                  Plaintiffs,

         7         VS                             No 285625

         8  Emergency Professional
               Services, Inc, et al,
         9
                            Defendants
        1 0

        1 2
        13        Deposition of NEAL V DAWSON, MD, a witness
        14  herein, called for cross-examination by the
        15  Plaintiffs, before Michelle A Bishilany, RMR and
        16  Notary Public within and for the State of Ohio, at
        17  the offices of Jacobson, Maynard, Tuschman & Kalur,
        18  1600 North Point Tower, 1001 Lakeside Avenue,
        19  Cleveland, Ohio, on Wednesday, the 18th day of
        20  September, 1996, at 12:10 pm
        21
        22                         - - - -
        2 3

        2 4
                             HOLLAND & ASSOCIATES
        25                      (216)621-7786

                                                                2


        1  APPEARANCES:

        2             Mr Richard D Topper, Jr,
                              and
        3             Weisman, Goldberg & Weisman, by
                      Mr Fred Weisman,
        4
                           On behalf of the Plaintiffs;
        5

        6
                      Jacobson, Maynard, Tuschman & Kalur, by
        7             Mr Robert C Maynard,

        8                  On behalf of Defendant John Vance,
                              MD;
        9

        10
                      Richards and Meola, by
        11            Mr Charles L Richards,

        12                 On behalf of Defendants St Joseph
                              Riverside Hospital,
        13                 Humility of Mary Health Care
                              Corp
        14

        15

        16                        - - - -

        17

        18

        19

        2 0

        21

        2 2

        2 3

        2 4

        2 5

                                                                    3


                     EXAMINATION OF NEAL V DAWSON, MD

         2
                          By Mr Topper         4
         3

         4

         5

         6

         7

         8
                                EXHIBITS MARKED
         9

        10             Plaintiff's exhibit 1       55

        11

        12

        13                          - - - -

        14

        15

        16

        17

        18

        19

        2 0

        21

        2 2

        2 3

        2 4

        2 5

                                                                4

        1                  NEAL V DAWSON, MD,
        2   of lawful age, a witness herein, called for
        3   cross-examination by the Plaintffs, being by me
        4   first duly sworn, as hereinafter certified, deposed
        5   and said as follows;
        6                     CROSS-EXAMINATION
        7   BY MR  TOPPER:
        8   Q     Would you please tell us your name and your
        9   profeBSional address?
        10  A     Neal, N-E-A-L, V Dawson, D-A-W-S-0-N
        11  MetroHealth Medical Center, 2500 MetroHealth Drive,
        12  Cleveland, Ohio, 44109-1998
        13  Q     I know you were at Case for a while and now
        14  you're with Metro  How long have you been at Metro?
        15  A     Since 1982
        16  Q     Are you on the staff there, Dr Dawson?
        17  A     YeB, I am
        18  Q     Are you associated -- does Metro have a
        19  department of addiction medicine?
        20  A     Not as a separate department
        21  Q     Is there a separate specialty or subspecialty
        22  of addiction medicine?
        23  A     There is within the Case system, there's
        24  actually a fellowship in addiction
        25  Q     Are you involved with that at all?
                                                                 5

         1  A     Indirectly  I have done some  work  with  Ted
         2  Parran who runs the fellowship, he and I  have  --  or
         3  actually are still in the process of submitting a
         4  grant that has to do with screening  for  alcoholism
         5  in a primary care setting
         6  Q     Is that a program Bob Smith worked  with  you
         7  on at one time?
         8  A     That was a separate -- that was  actually  just
         9  a paper  It was a project that we did  with  one  of
        10  the residents who was interested in trying to do
        11  some research while he w