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, MD, 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 pm
                      - - - - -
     
     
     

                                                                     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   

                                                                     3
 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, MD, of lawful 
15   age, called for examination, as provided by the 
16   Ohio Rules of Civil Procedure, being by me 
17   first duly sworn, as hereinafter certified, 
18   deposed and said as follows:
19               MR WHITE:  Objection 
20               For the record Attorney George 
21   White representing the Defendant in this case 
22   YSD Industries, Inc 
23               I hereby make a motion in limine 
24   that will be supplemented later with the court  
25   The ground for the motion in limine is the fact 

                                                                     4
 1   that Dr Venizelos has never been identified by 
 2   the Plaintiff as a potential witness in this 
 3   case 
 4               There has been no supplementation 
 5   of discovery in this case and there was no 
 6   notice of the Defendant that Dr Venizelos 
 7   would be testifying in this matter  So on that 
 8   ground the Defendant makes a motion in limine 
 9   to strike this entire deposition
10               With that said let's go forward
11               MS ARMOUR:  Just a quick response 
12   to the objection 
13               We are here on the case of Alex 
14   Brown and Dr Venizelos did render a report in 
15   this matter dated September 4th, 2002  The 
16   report was served on defense counsel well in 
17   advance of this deposition  And we'll then 
18   proceed as it was properly noticed as well 
19         EXAMINATION OF PAUL VENIZELOS, MD
20   BY MS ARMOUR:
21         Q    Good afternoon, Doctor?
22         A    Hello
23         Q    I'm Pamela Armour from Kelley & 
24   Ferraro  We're here on the matter of Alex 
25   Brown versus YSD Industries 

                                                                     5
 1               Doctor, could you state your name 
 2   for the record please?
 3         A    Paul Venizelos
 4         Q    And what's your occupation?
 5         A    I'm a medical physician, medical 
 6   doctor, trained in internal medicine and 
 7   pulmonary diseases
 8         Q    What states are you licensed?
 9         A    Ohio
10         Q    Okay  And can you briefly describe 
11   for the jury your educational background?
12         A    Yes  Attended Northwestern 
13   University from 1968 to 19 -- 1968 to 1972  
14   Received a Bachelor's of Science and Chemistry 
15   there  From there went to Columbus, Ohio, 
16   studied medicine at Ohio State School of 
17   Medicine  Received a medical