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STATE OF OHIO,
COUNTY OF MUSKINGUM.		) SS:


IN THE COURT OF COMMON PLEAS


THELMA KAREN SPICER,

Plaintiff,
	vs.	) Case No. CA94-85l

BETHESDA HOSPITAL, et al.,

Defendants.




THE DEPOSITION OF DR. RICHARD W. WATTS
FRIDAY, AUGUST 4, 1995




	The deposition of DR. RICHARD W. WATTS, a
witness herein, called by the Defendants for
examination pursuant to the Ohio Rules of Civil
Procedure, taken before me, the undersigned,
Darlene Lowe, Court Reporter and Notary Public
within and for the Stat~e of Ohio, taken at the offices
of Wanous Reporting Service, 1225 Illuminating
Building, 55 Public Square, Cleveland, Ohio, commencing
at 2:03 p.m., the day and date above set forth.


WANOUS REPORTING SERVICE
55 PUBLIC SQUARE
1225 ILLUMINATING BUILDING
CLEVELAND, OHIO 44113
(216) 861-9270

2


1
APPEARANCES:
2

3
	4	On behalf of the Plaintiff:
	5	James A. Marx, Attorney at Law
		Traci & Marx
	6	1550 Illuminating Building
		55 Public Square
	7	Cleveland, Ohio 44113

8
	9	On behalf of Defendants Medical Specialists,
		Inc.~ and Dr. John E. Shaner:
	10
		   Kevin T. Brennan, Attorney at Law
	11	   Jacobson, Maynard, Tuschman & Kalur
		   Suite 880, 175 South Third Street
	12	Columbus, Ohio 43215
	13
	14
	15
	16
	17

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Computer Transcription - Wanous Reporting Service

3

	1		             DR. RICHARD W. WATTS
	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, was examined
	S	and testified as follows:
	6		     EXAMINATION OF DR. RICHARD W. WATTS
	7	BY MR. BRENNAN:
	8	Q	  Doctor, would you please state your name and
	9		  professional address for the record?
	10	A	  I'm Richard Ward Watts, M.D., 3885 Rocky River
	11		  Drive, Cleveland, Ohio.
	12	Q	  What is located at 3885 Rocky River Drive?
	13	A	  That is a one-story medical building.
	14	Q	  Okay. And your office is maintained there?
	15	A	  It is.
	16	Q	  Is there anyone else in that building with you?
	17	A	 Yes. There are four offices in that building.
	18	Q	 Okay. Do you practice. with anyone or are you a
	19		  solo practitioner?
	20	A	 No, I'm part of the West Side Cardiologist
	21		 Associates, Inc. I'm the president of it. We
	22		- also have Thomas Cumerford. He's been with me
	23		 15 years and