1
              IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     
     ARTHUR MONCRIEF,
                Plaintiff,
          vs                               Case No
     FORD MOTOR COMPANY,                    477932
     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 4:50 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              CHARLES W KINKOPF, ESQ
17              55 Public Square, Suite 1775
18              Cleveland, Ohio  44113
19              (216) 621-1127
20                         ----
21   
22   ALSO PRESENT:
23              Steve Soltz, CLVS
24                         ----
25   

                                                                     3
 1               MR FROST:  Counsel, it's my
 2   understanding that you are willing to stipulate
 3   on behalf of your client that the credentials
 4   section of Dr Schonfeld's testimony that was
 5   previously recorded in the matter of Leon
 6   Bennett versus Ford Motor Company will be used
 7   also in this matter, Arthur Moncrief versus
 8   Ford Motor Company, rather than duplicating the
 9   same section of the tape on the record  And I
10   also understand that during the deposition of
11   Dr Schonfeld in the matter of Bennett versus
12   Ford that there's also a segment in which you
13   cross-examine Dr Schonfeld regarding his
14   credentials that will also be spliced and
15   reused in this particular matter; is that fair
16   to say
17               MR KINKOPF:  That is absolutely
18   correct
19               MR FROST:  Great  Okay
20               MR SOLTZ:  Okay  This is the
21   videotape deposition of Dr Alvin J Schonfeld
22   taken by the plaintiff in the matter of Arthur
23   Moncrief versus Ford Motor Company in the Court
24   of Common Pleas, Cuyahoga County, 477932  This
25   deposition is being held at the offices of

                                                                     4
 1   Kelley & Ferraro on October 13th, 2003
 2               My name is Steve Soltz from the
 3   firm of xxxxxxxx Reporting Services with
 4   offices at 1301 East Ninth, Cleveland, Ohio and
 5   I am the videographer  The reporter is Denise
 6   Munguia from the firm of xxxxxxxx Reporting
 7   Services with offices at 1301 East Ninth,
 8   Cleveland, Ohio
 9               We are now going on the record and
10   the time is 4:52  Counsel will now state their
11   appearances for the record
12               MR FROST:  This is Corey Frost on
13   behalf of Plaintiff Arthur Moncrief
14               MR KINKOPF:  Charles W Kinkopf
15   with Rademaker, Matty, McClelland & Greve on
16   behalf of Ford Motor Company
17              ALVIN J SCHONFELD, DO, of lawful
18   age, called for examination, as provided by the
19   Ohio Rules of Civil Procedure, being by me
20   first duly sworn, as hereinafter certified,
21   deposed and said as follows:
22        (The following is previous testimony
23   included herein by agreement of counsel)
24       EXAMINATION OF ALVIN J SCHONFELD, DO
25   BY MR ACTON:

                                                                     5
 1         Q    Doctor, good afternoon  Could you
 2   please introduce yourself to the jury?
 3         A    My name is Alvin Schonfeld and I am
 4   a physician and I specialize in lung disease
 5         Q    Well, Doctor, I think it's it is
 6   appropriate for me to introduce myself  My
 7   name is Shawn Acton and I, along with other
 8   attorneys in my office, represent the plaintiff
 9   in this case
10               Doctor, what I have done is I have
11   handed you a document that has been marked for
12   identification purposes as Plaintiff's Exhibit
13   A  Correct me if