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1 State of Ohio, 1-7 0

SS:

2 County of Cuyahoga.)

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4 IN THE COURT OF COMMON PLEAS

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6 MICHELLE S. RUTHERFORD,

7 Plain tiff,

8 vs. Case No. 198,757

9 KAISER FOUNDATION
HOSPITALS, et al., Judge Patricia Cleary
10
Defendants.
11

12
DEPOSITION OF WAYNE K. KAWALEK, M.D.

13 Thursday, March 19, 1992

14

15 The deposition of WAYNE K. KAWALEK, M.D., a

16 witness, called for examination by the Plaintiff

17 under the Ohio Rules of Civil Procedure, taken

18 before me, Diane M. Stevenson, a Registered

19 Professional Reporter and Notary Public in and

20 for the state of Ohio, by agreement of counsel,

21 at the offices of Weisman, Goldberg & Weisman

22 Co., LPA, 1600 Midland Building, Cleveland,

23 Ohio, commencing at 10:20 a.m., the day and date

24 above set forth.

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Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

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1 APPEARANCES:

2 On behalf of the Plaintiff:

3 R. Eric Kennedy, Esq.
Weisman, Goldberg & Weisman Co., LPA
4 1600 Midland Building
Cleveland, Ohio 44115
5

6 On behalf of the Defendants:

7 Leslie J. Spisak, Esq.
Reminger & Reminger Co., LPA
8 The 113 Building
Cleveland, Ohio 44114
9

10 ALSO PRESENT:

11 Fred Palcho, Videographer

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Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

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1 MR. KENNEDY: What do you want

2 to waive here?

3 MR. SPISAK: What do you want

4 me to waive?

5 MR. KENNEDY: Everything, the

6 filing of the transcript, the filing of the

7 video, service, notice, technical requirements.

8 I think there are technical requirements

9 written into video depositions that nobody ever

10 pays any attention to.

11 MR. SPISAK: I don't think

12 there is any problem with any of those things.

13 If something should come up in the video, but

14 other than that, I will waive all the technical

15 requirements and the filing and notice

16 requirements, that type of thing.

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Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

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1 WAYNE K. KAWALEK, M.D.

2 A witness, called for examination by the

3 Plaintiff, under the Rules, having been first

4 duly sworn, as hereinafter certified, was

5 examined and testified as follows:

6 DIRECT EXAMINATION

7 BY MR. KENNEDY:

8 Q. Do