1
                IN THE COURT OF COMMON PLEAS
                 OF MAHONING COUNTY, OHIO
     
     
     ALEX BROWN,
                 Plaintiff,
           vs.                       Case No.
     YSD INDUSTRIES, INC.,           01 CV 2709
     et al.,
                 Defendants.
     
     
                      - - - - -
                 Videotaped deposition of PAUL 
     VENIZELOS, M.D., called for examination under the 
     statute, taken before me, Claudine Kelly, a 
     Notary Public in and for the State of Ohio, 
     pursuant to notice and stipulations of counsel, 
     at the offices of Dr. Venizelos, 15805 Puritas 
     Avenue, Cleveland, Ohio, on Friday, March 21, 
     2003, at 2:19 p.m.
                      - - - - -
     
     
     

                                                                     2
 1   APPEARANCES:
 2   
 3         On behalf of the Plaintiff:
 4               Kelley & Ferraro, by
 5               PAMELA ANN ARMOUR, ESQ.
 6               1300 East Ninth Street, Suite 1901
 7               Cleveland, Ohio  44114 
 8               (216) 575-0777 
 9   
10         On behalf of the Defendants:
11               Henderson, Covington, Messenger,
12               Newman & Thomas, by
13               GEORGE L. WHITE, IV, ESQ.
14               34 Federal Plaza West
15               600 Wick Building
16               Youngstown, Ohio  44503
17               (330) 744-1148
18                         ----
19   
20   ALSO PRESENT:
21               Kim DiMuzio, Video Tech
22                         ----
23   
24   
25   

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 1                         -  -  -  -  -
 2               (Thereupon, Defendant's Deposition 
 3               Exhibit B was marked for purposes of 
 4               identification.)
 5                         -  -  -  -  -
 6                         -  -  -  -  -
 7               (Thereupon, Plaintiff's Deposition 
 8               Exhibits 1 through 3 were marked for 
 9               purposes of identification.)
10                         -  -  -  -  -
11               MS. DiMUZIO:  Today is March 21st, 
12   2003.  We're going on the record at 2:19.   
13   Will the reporter swear in the witness. 
14               PAUL VENIZELOS, M.D., of lawful 
15   age, called for examination, as provided by the 
16