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	1	COMMON PLEAS COURT
	2	 GUERNSEY COUNTY
	3	   STATE OF OHIO
	4

5
	6	LINDA NEFF, ADMINISTRATRIX
		OF THE ESTATE OF
	7	RICHARD NEFF,
	8	PLAINTIFF,
	9	VS.	:	CASE NO. 96-CV—432
				JUDGE ELLWOOD
	10	RICK E. COX, D.C., ET AL.,
	11	DEFENDANTS.

12

13
	14	   DEPOSITION OF
	15	SAMUEL J. KIEHL, M.D.
	16	   JULY 21, 1999
	17
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		E & A REPORTING SERVICE, INC.
	23	   915 SOUTH FRONT STREET
		   COLUMBUS, OHIO 43206
	24	       (614.) 445—6300

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	2	             DEPOSITION OF SAMUEL J. KIEHL, M.D., A
	3	WITNESS CALLED BY THE DEFENDANTS AS IF UPON CROSS-
	4	EXAMINATION, TAKEN BEFORE ME, MISTIANN OCANAS, A
	5	NOTARY PUBLIC WITHIN AND FOR THE STATE OF OHIO, AT
	6	THE OFFICES OF THE DEPONENT, 4619 KENNY ROAD,
	7	COLUMBUS, OHIO 43220, COMMENCING AT 3:05 P.M., SAID
	8	DEPOSITION TAKEN PURSUANT TO THE STIPULATIONS
	9	HEREINAFTER SET FORTH.
	10
	11	APPEARANCES:
	12	             ROBERT V. TRACI, ESQ., OF THE LAW FIRM
	13	OF TRACI & MARX, 55 PUBLIC SQUARE, SUITE 1550,
	14	CLEVELAND, OHIO, 44113, APPEARING ON BEHALF OF THE
	15	PLAINTIFF.
	16	             THEODORE M. MUNSELL, ESQ., OF THE LAW
	17	FIRM OF LANE, ALTON & HORST, 175 SOUTH THIRD STREET,
	18	COLUMBUS, OHIO 43215, APPEARING ON BEHALF OF
	19	DEFENDANTS DR. HOJAT, DR. MUNRO, AND HOLZER CLINIC.
	20	             JAMES S. OLIPHANT, ESQ., OF THE LAW FIRM
	21	OF PORTER, WRIGHT, NORRIS & ARTHUR, 41 SOUTH HIGH
	22	STREET, COLUMBUS, OHIO 43215, APPEARING ON BEHALF OF
	23	DEFENDANT RICK E. COX, D.C.
	24

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	1	APPEARANCES (CONT'D.):
	2
	3	             GWEN S. KARR, ESQ., OF THE LAW FIRM OF
	4	REMINGER & REMINGER, SOUTH HIGH STREET, COLUMBUS,
	5	OHIO 43215, APPEARING ON BEHALF OF DEFENDANT HOLZER
	6	MEDICAL CENTER.
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	24

	1	STIPULATIONS

2

3	IT IS AGREED AND STIPULATED BY AND AMONG
	4	COUNSEL FOR THE RESPECTIVE PARTIES HEREIN THAT THIS
	5	DEPOSITION MAY BE TAKEN IN SHORTHAND BY MISTIANN
	6	OCANAS, WHO MAY LATER, OUT OF THE PRESENCE OF THE
	7	WITNESS, TRANSCRIBE OR CAUSE SAID SHORTHAND NOTES TO
	8	BE TRANSCRIBED; THAT THE FORMALITIES AS TO THE TIME
	9	AND PLACE OF THE TAKING OF THE DEPOSITION ARE BY
	10	AGREEMENT OF COUNSEL; AND THAT THE QUALIFICATIONS OF
	11	THE OFFICER BEFORE WHOM TAKEN SHALL BE EXPRESSLY
	12	WAIVED.
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	24

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	1	~	TABLE OF CONTENTS

2
	3	EXAMINER	      TYPE	PAGE
	4	MR. MUNSELL	CROSS-EXAMINATION	6
	5	MR. OLIPHANT	CROSS-EXAMINATION	49
	6	MS. KARR	CROSS-EXAMINATION	51
	7	MR. MU