1
               IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     
     ALFRED McCANN,
                Plaintiff,
          vs                               Case No
     FORD MOTOR COMPANY,                    489746
     et al,
                Defendants
     
     
                        ~ ~ ~ ~ ~
                 Videotape deposition of ALVIN J
     SCHONFELD, DO, called for examination under
     the statute, taken before me, Denise M
     Munguia, a Registered Merit Reporter and Notary
     Public in and for the State of Ohio, pursuant
     to notice and stipulations of counsel, at the
     offices of Kelley & Ferraro, LLP, 1901 Penton
     Media Building, 1300 East Ninth Street,
     Cleveland, Ohio, on Monday, October 13, 2003,
     at 6:23 o'clock pm
     
                        ~ ~ ~ ~ ~

                                                                     2
 1   APPEARANCES:
 2   
 3        On behalf of the Plaintiff:
 4              Kelley & Ferraro, LLP, by
 5               COREY W FROST, ESQ
 6               SHAWN M ACTON, ESQ
 7              1901 Penton Media Building
 8              1300 East Ninth Street
 9              Cleveland, Ohio  44114
10              (216) 575-0777
11   
12        On behalf of the Defendant Ford Motor
13        Company:
14              Rademaker, Matty, McClelland &
15              Greve, by
16              ROBERT C McCLELLAND, ESQ
17               CHARLES W KINKOPF, ESQ
18              55 Public Square, Suite 1775
19              Cleveland, Ohio  44113
20              (216) 621-1127
21                         ----
22   
23   ALSO PRESENT:
24              Steve Soltz, CLVS
25                         ----

                                                                     3
 1               MR FROST:  It's my understanding
 2   from conversations with Mr McClelland that we
 3   have a stipulation that the credentials that
 4   Dr Schonfeld previously testified to in the
 5   matter of Bennett versus Ford Motor Company,
 6   which was recorded earlier this same date, will
 7   be used as the credentials section of
 8   Dr Schonfeld's testimony in this particular
 9   matter, the matter of McCann versus Ford Motor
10   Company  Is that correct, Mr McClelland?
11               MR McCLELLAND:  That is correct
12               MR FROST:  Great
13          (Discussion had off the record)
14               MR SOLTZ:  This is the videotape
15   deposition of Dr Alvin J Schonfeld taken by
16   the plaintiff in the matter of Alfred McCann
17   versus Ford Motor Company in the Court of
18   Common Pleas of Cuyahoga County, Cuyahoga
19   County, number 489746  This deposition is
20   being held at the offices of Kelley & Ferraro
21   on October 13th, 2003
22               My name is Steve Soltz from the
23   firm of xxxxxxxx, xxxxxxxx Reporting Services
24   with offices at 1301 East Ninth, Cleveland,
25   Ohio  I am the videographer  The reporter is

                                                                     4
 1   Denise Munguia from the firm of xxxxxxxx
 2   Reporting Services with offices located at 1301
 3   East Ninth, Cleveland, Ohio
 4               We are going on the record and the
 5   time is 6:25  Will counsel now please state
 6   their appearances for the record?
 7               MR FROST:  This is Corey Frost on
 8   behalf of Alfred McCann
 9               MR McCLELLAND:  This is Rob
10   McClelland who, along with Kirk Henrikson,
11   represent the Ford Motor Company
12              ALVIN J SCHONFELD, DO, of lawful
13   age, called for examination, as provided by the
14   Ohio Rules of Civil Procedure, being by me
15   first duly sworn, as hereinafter certified,
16   deposed and said as follows:
17        (The following is previous testimony
18   included herein by agreement of counsel)
19       EXAMINATION OF ALVIN J SCHONFELD, DO
20   BY MR ACTON:
21         Q    Doctor, good afternoon  Could you
22   please introduce yourself to the jury?
23         A    My name is Alvin Schonfeld and I am
24   a physician and I specialize in lung disease
25         Q    Well, Doctor, I think it's it is

                                                                     5
 1   appropriate for me to introduce myself  My
 2   name is Shawn Acton and I, along with other
 3   attorneys in my office, represent the plaintiff
 4   in this case
 5               Doctor, what I have done is I have
 6   handed you a document that has been marked for
 7   identification purposes as Plaintiff's Exhibit
 8   A  Correct me if I'm wrong, Doctor, that is
 9   your curriculum vitae or resume, correct?
10         A    That's right
11         Q    And at least my understanding of
12   that document is th