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Expert Witness : Laxminarayana Rao MD


Case Jerry Smith vs. The Timken Company
Testimony Date June 04, 2003
Expert Type Pulmonary
Court State: Ohio County: Stark
Pages 55
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                                                                     1
               IN THE COURT OF COMMON PLEAS
                   OF STARK COUNTY, OHIO
     
     
     JERRY SMITH,
                 Plaintiff,
           vs.                           Case No.
     THE TIMKEN COMPANY,                 2002 CVO 3810    
                 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 
     6:37 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 the trial 
 2   deposition of Dr. Rao that has been scheduled 
 3   by Mr. Smith's attorney's office.  I was 
 4   advised moments before we began the depositions 
 5   today that Mr. Acton had discovered sometime, I 
 6   think he said in the past week, and he can 
 7   correct me if I'm wrong, that there is an x-ray 
 8   film that has never been provided to our office 
 9   and of which I was unaware until just moments 
10   ago.  It appears in reviewing the doctor's file 
11   that that x-ray is dated April 3 of 2003.  The 
12   film has never