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Expert Witness : Laxminarayana Rao MD


Case Anita Earley vs. The Timken Company
Testimony Date June 04, 2003
Expert Type Pulmonary
Court State: Ohio County: Stark
Pages 106
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                                                                     1
               IN THE COURT OF COMMON PLEAS
                   OF STARK COUNTY, OHIO
     
     
     ANITA EARLEY,
                 Plaintiff,
           vs.                            Case No.
     THE TIMKEN COMPANY,                  02 CV 03815    
                 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 
     4:31 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   
22   ALSO PRESENT:
23               Scott Morrison CLVS
24                         ----
25   

                                                                     3
 1               MR. MATASICH:  This is Stephen 
 2   Matasich representing The Timken Company in the 
 3   case of Anita Earley v. The Timken Company, 
 4   Stark County Court of Common Pleas, Case Number 
 5   2002 CV 03815.  I had filed with the court 
 6   yesterday a motion in limine pertaining to 
 7   expert medical testimony in this case.  I'll 
 8   try not to belabor the points too much as 
 9   everything is set forth in detail in that 
10   motion.  
11               Of particular concern is the fact 
12   that we had requested, I believe it was in 
13   early January of th