1
 1  IN THE COURT OF COMMON PLEAS
    CUYAHOGA COUNTY, OHIO
 2   
    Case No 477316
 3   
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 4   DEPOSITION OF ALVIN J SCHONFELD, DO
 5   
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    BILL WISE,
 6   
    Plaintiff,
 7   
    v
 8   
    FORD MOTOR COMPANY,
 9   
    Defendant
10   
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           The deposition of ALVIN J SCHONFELD, DO was
11   taken by the Plaintiff on July 2, 2003, at the Vail
    Valley Foundation, 90 Benchmark Road, Avon, Colorado
12   commencing at the hour of 3:44 pm, before ROSANNE M
    STAHL, Certified Shorthand Reporter and Notary Public
13   within and for the State of Colorado
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14   
                 A P P E A R A N C E S
15   
    ROBERT A MARCIS, II, ESQ
16   KELLEY & FERRARO, LLP
    1300 East Ninth Street, Suite 1901
17   Cleveland, OH  44114
    Ph 216-575-0777
18   
    CHARLES KINKOPF, ESQ
19   RADEMAKER, MATTY, MCCLELLAND & GREVE
    55 Public Square, Suite 1775
20   Cleveland, Ohio  44113
    Ph (216) 621-6570
21   
    ALSO PRESENT:  Del Sharp, Videographer
22   
23   
24   
25   

                                                                     2
 1                            INDEX
 2   EXAMINATION BY                            PAGES
 3   MR FROST (CREDENTIALS)                   4 - 22
    MR MARCIS                                22 - 38
 4   MR KINKOPF                               38 - 80
    MR MARCIS                                70 - 77
 5   -----------------------------------------------------------
    REPORTER'S CERTIFICATE                    78
 6   
    DEPONENT'S SIGNATURE PAGE and
 7     CORRECTION SHEET ADDENDUM               WAIVED
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 8                           EXHIBITS
    DEPOSITION  INITIAL
 9   EXHIBIT     REFERENCE      BRIEF DESCRIPTION
10   1           29             09/22/99 B READ REPORT BY
                               DR GRAUEL ON BILL WISE
11   
    2           3              DICTATED B READ REPORT,
12                              07/16/02, BY DR SCHONFELD
                               FOR BILL WISE
13   
    3           3              07/16/02 SPIROMETRY FOR BILL
14                              WISE
15   4           3              DR SCHONFELD'S QUESTIONNAIRE
                               FILLED OUT BY BILL WISE,
16                              09/16/02
17   5           3              11/16/02 DICTATED B READ
                               REPORT BY DR SCHONFELD FOR
18                              BILL WISE
19   6           29             09/22/99 B READ REPORT BY
                               DR SCHONFELD FOR BILL WISE
20   
21   
22   
23   
24   
25   

                                                                     3
 1   
 2                     P R O C E E D I N G S
 3          (The following was not recorded on the videotape
 4   at 3:44 pm)
 5          MR MARCIS: We have agreed ahead of time that
 6   credentials were done of Dr Schonfeld today in the
 7   Watson case and have agreed with Tom and Chuck from the
 8   law firm of Rademaker representing Ford that we will
 9   just go ahead and just use those same credentials in
10   this case to save time and sanity
11          Doctor, correct me if I am wrong, but I can
12   represent the fact that the only things that you have in
13   your file are the exhibits I gave you which are
14   Plaintiff's Exhibit 1, 2, 3, 4, 5 and 6
15          THE DEPONENT: That's right  That's the total
16   amount of my file
17          MR MARCIS: Okay  I think we're ready whenever
18   you all are
19          (The follow is the above-mentioned credentials of
20   Dr Schonfeld which was given on 07/02/01 in the case of
21   James L Watson v Ford Motor Company, Case No 47130 at
22   8:46 am)
23                      ALVIN J SCHONFELD, DO,
24   the deponent herein, having been duly sworn, was
25   examined and testified as follows:

                                                                     4
 1                          EXAMINATION
 2   BY MR FROST:
 3     Q   Doctor, would you introduce yourself to the jury,
 4   please?
 5     A   My name is Alvin Schonfeld  I'm a lung
 6   specialist, a physician  I specialize in diseases of
 7   the lung
 8     Q   And, Doctor, so that the jury understands, where
 9   are you located this morning?
10     A   I'm in Colorado
11     Q   And this deposition is being conducted by a video
12   link teleconference so that Mr Greve and I are here in
13   Cleveland; is that correct?
14     A   T