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Expert Witness : Laxminarayana Rao MD


Case Lorene Brown vs. The Timken Company
Testimony Date June 04, 2003
Expert Type Pulmonary
Court State: Ohio County: Stark
Pages 68
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                                                                     1
               IN THE COURT OF COMMON PLEAS
                   OF STARK COUNTY, OHIO
     
     
     LORENE BROWN,
                 Plaintiff,
           vs.                            Case No.
     THE TIMKEN COMPANY,                  02 CV 03821    
                 Defendants.
     
     
                         ~ ~ ~ ~ ~
                 Videotape deposition of LAXMINARAYANA 
     C. RAO, M.D., 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 Old Oak Medical 
     Pavilion, 7255 Old Oak Boulevard, Middleburg 
     Heights, Ohio, on Wednesday, June 4, 2003, at 
     7:35 o'clock p.m.
                         ~ ~ ~ ~ ~
     
     
     

                                                                     2
 1   APPEARANCES:
 2   
 3         On behalf of the Plaintiff:
 4               Kelley & Ferraro LLP, by
 5               SHAWN M. ACTON, ESQ.
 6               1901 Penton Media Building
 7               1300 East Ninth Street
 8               Cleveland, Ohio  44114
 9               (216) 575-0777
10   
11         On behalf of the Defendant The Timken 
12         Company:  
13               Day, Ketterer, Raley, Wright & 
14               Rybolt, Ltd., by
15               STEPHEN E. MATASICH, ESQ.
16               Millennium Center - Suite 300
17               200 Market Avenue North
18               Canton, Ohio  44701-4213
19               (330) 458-2143
20   
21   ALSO PRESENT:
22               Scott Morrison, CLVS
23                         ----
24   
25   

                                                                     3
 1               MR. MATASICH:  This is Stephen 
 2   Matasich representing The Timken Company in the 
 3   case of Lorene Brown v. The Timken Company, 
 4   Stark County Court of Common Pleas Case Number 
 5   2002 CV 03821.  We filed a motion in this case 
 6   on June 3, I guess that was yesterday, and it's 
 7   a motion in limine to exclude all of the 
 8   plaintiffs' expert and nonexpert medical 
 9   testimony.  The issues are set forth in detail 
10   in that motion.  
11               To briefly summarize, in addition 
12   to the delays and problems we encountered 
13   scheduling depositions, we ha