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               IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     
     ALAN ENSINGER, et al,
                Plaintiffs,
          vs                               Case No
     UNIVERSITY HOSPITALS                   413085
     HEALTH SYSTEM, et al,
                Defendants
     
     
                Deposition of JOSEPH P HANNA,
     MD, called for examination under the
     Applicable Rules of Ohio Civil Procedure, taken
     before me, Michele E Eddy, a Registered
     Professional Reporter and Notary Public in and
     for the State of Ohio, pursuant to notice and
     stipulations of counsel, at the offices of
     MetroHealth Medical Center, 2500 MetroHealth
     Drive, Cleveland, Ohio, on Friday, the 10th day
     
     of October, 2003, at 8:00 am
     
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                                                                     2
 1   APPEARANCES:
 2   
 3        On behalf of the Plaintiffs:
 4               Elk & Elk, by
 5               STEPHEN S CRANDALL, ESQ
 6               6110 Parkland Boulevard
 7               Mayfield Heights, Ohio  44124
 8               (440) 442-6677
 9   
10        On behalf of the Defendants Edward L
11        Westbrook, MD, Rana B Hejal, MD,
12        Dean A Nakamoto, MD, and Robert C
13        Gilkerson, MD:
14               Reminger & Reminger, by
15               GARY H GOLDWASSER, ESQ
16               1400 Midland Building
17               101 Prospect Avenue, West
18               Cleveland, Ohio  44115
19               (216) 687-1311
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25   

                                                                     3
 1   APPEARANCES, Continued:
 2   
 3        On behalf of the Defendants Alan Scarrow,
 4        MD, Sharon R May, MD, Stanley
 5        Litvak, MD, and Zohair Nanjiana, MD:
 6               Moscarino & Treu, by
 7               SEAN M SWEENEY, ESQ
 8               1422 Euclid Avenue, Suite 630
 9               Cleveland, Ohio  44115
10               (216) 621-1000
11   
12        On behalf of the Defendant Edward R
13        McFadden, Jr, MD:
14               Ulmer & Berne, by
15               JOHN G PETO, ESQ
16               900 Penton Media Building
17               Cleveland, Ohio  44114
18               (216) 621-8400
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25   

                                                                     4
 1   APPEARANCES, Continued:
 2   
 3        On behalf of the Defendant Susan M
 4        Snodgrass, MD :
 5               Roetzel & Andress, by
 6               JANIS L SMALL, ESQ
 7               222 South Main Street
 8               Akron, Ohio  44308
 9               (330) 376-2700
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                                                                     5
 1                   -  -  -  -  -
 2               (Thereupon, Plaintiffs' Deposition
 3              Exhibits 1 through 3 were marked
 4              for purposes of identification)
 5                    -  -  -  -  -
 6              JOSEPH P HANNA, MD, of lawful
 7   age, called for examination, provided by the
 8   statute, being first duly sworn, as hereinafter
 9   certified, and said as follows:
10               MR CRANDALL:  Before I ask you
11   questions, I want to put something on the
12   record
13              We've waited 15 minutes to start
14   the deposition  Someone from Murray Lenson's
15   office is not present  We're going to go ahead
16   and start the deposition  I know this
17   deposition was one that we scheduled some time
18   ago
19               (Attorney John Peto entered the
20   room)
21               MR GOLDWASSER:  That takes care of
22   that
23               MR SWEENEY:  Steve, I also want to
24   put on the record we object to this deposition
25   to the extent we asked that it be rescheduled

                                                                     6
 1   And our request was denied, if you will  We
 2   object to it going forward at this point in
 3   time
 4               MR GOLDWASSER:  I think that's an
 5   appealable error
 6               MR CRANDALL:  It was my
 7   understanding that we ended up agreeing to the
 8   time
 9         EXAMINATION OF JOSEPH P HANNA, MD
10   BY MR CRANDALL:
11         Q    Could you tell me your full name,
12   please?
13         A    Joseph P Hanna
14         Q    Dr Hanna, I'm Steve Crandall  You
15   and I have never met before, correct?
16         A    Not that I remember
17         Q    I'm one of the attorneys who
18   represents the plaintiff in this matter  It's
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