1
 1   IN THE COURT OF COMMON PLEAS, CUYAHOGA COUNTY, OHIO
 2   CASE NO 478622
 3   -----------------------------------------------------------
 4          VIDEO DEPOSITION OF ALVIN J SCHONFELD, DO
 5                          JUNE 9, 2003
 6   -----------------------------------------------------------
 7   ARTHUR SPRINGER,
 8   Plaintiff,
 9   v
10   FORD MOTOR COMPANY, et al,
11   Defendants
12   -----------------------------------------------------------
13                       A P P E A R A N C E S
14   FOR THE PLAINTIFF:           Corey W Frost, Esq
                                 Kelley & Ferraro, LLP
15                                1300 East Ninth Street
                                 Suite 1901
16                                Cleveland, Ohio  44114
17   FOR THE DEFENDANT            Robert C McClelland, Esq
    FORD MOTOR COMPANY:          Rademaker, Matty, McClelland &
18                                  Greve
                                 Suite 1775
19                                55 Public Square
                                 Cleveland, Ohio  44113
20                                (via telephone)
21   ALSO PRESENT:                Del Sharp, Videographer
                                 Katie Testa
22   
23   
24   
25   

                                                                     2
 1                     PURSUANT TO WRITTEN NOTICE, the video 
 2   deposition of ALVIN J SCHONFELD, DO, called for 
 3   examination by the plaintiff, was taken in the George 
 4   Townsend conference room at the Park Hyatt Beaver Creek 
 5   Resort and Spa, Avon, Colorado, commencing at 12:38 pm, on 
 6   the 9th day of June, 2003, before Gina C DiLuzio, a Notary 
 7   Public in and for the State of Colorado, and a Registered 
 8   Professional Reporter               
 9   
10          INDEX OF EXAMINATION                       PAGE
11               Examination by Mr Frost               4
12               Examination by Mr McClelland          37
13               Further Examination by Mr Frost       51               
14               Further Examination by Mr McClelland  55
15          INDEX OF OBJECTIONS
16                  By Mr McClelland               36/9; 36/21
17          INDEX OF EXHIBITS
18             (All exhibits were previously marked for
               identification before the commencement of the
19              deposition)
20   
21                     
22                     
23                     
24                     
25                     

                                                                     3
 1                     (Whereupon the video deposition commenced 
 2   at 12:38 pm)
 3                     MR FROST:  It has been previously 
 4   stipulated by counsel that the testimony of Dr Schonfeld  
 5   which was given in Roman versus Ford earlier this same date 
 6   as it regards his credentials, professional, and academic 
 7   background will be used also in this particular testimony in 
 8   the case of Arthur Springer versus Ford Motor Company  Is 
 9   that correct, Rob?
10                     MR McCLELLAND:  It is correct
11                     MR FROST:  Thank you  
12                     (Whereupon there was a brief delay in the 
13   proceedings)
14                     THE VIDEOGRAPHER:  Today is Monday, June 
15   9, 2003  The time is approximately 12:39 pm  The location 
16   is Park Hyatt at Beaver Creek, Colorado  My name is Del 
17   Sharp, videographer for Eagle Summit Reporting and Video, 
18   Breckenridge, Colorado  This is case number is 478622, 
19   entitled Arthur Springer versus Ford Motor Company, et al  
20   The deponent is Alvin J Schonfeld, DO  The video 
21   deposition is requested by the plaintiff  Counsel and all 
22   present will please identify for themselves for the record     
23                     MR FROST:  Good afternoon  This is Corey 
24   Frost on behalf of the plaintiff Arthur Springer
25                    MR McCLELLAND:  This is Rob McClelland on 

                                                                     4
 1   behalf of the Ford Motor Company
 2                    THE VIDEOGRAPHER:  The deponent may now be 
 3   sworn in by Gina DiLuzio
 4                    ALVIN J SCHONFELD, DO,
 5          called as a witness for examination under the Rules 
 6   by the plaintiff, having been first duly sworn according to 
 7   law, was examined and testified on his oath as follows:
 8                           EXAMINATION
 9          BY MR FROST:  
10               Q   Good afternoon, Doctor  
11               A   Hello
12               Q   Would you introduce yourself to the jury, 
13   please 
14                    THE DEPONENT:  Stop the tape
15                     MR FROST: