1
                IN THE COURT OF COMMON PLEAS
                  OF CUYAHOGA COUNTY, OHIO
     
     
     ARCHIE ROSS,
                 Plaintiff-Appellant,
            vs.                           Case No.
     ADMINISTRATOR, BUREAU OF             01-445680
     WORKERS COMPENSATION, et al.,
                 Defendants.
     
     
                          - - - - -
                 Videotaped deposition of PAUL C. 
     VENIZELOS, M.D., called for examination under the 
     statute, taken before me, Carina C. Meszaros, a 
     Registered Merit Reporter and Notary Public in 
     and for the State of Ohio, at the offices of Ohio 
     West Region Sleep Center, 15805 Puritas Avenue, 
     Cleveland, Ohio, on Wednesday, February 5, 2003, 
     at 2:30 o'clock p.m.
                          - - - - -
     
     
     

                                                                     2
 1   APPEARANCES:  
 2   
 3         On behalf of the Plaintiff-Appellant:  
 4               Kelley & Ferraro, L.L.P., by
 5               ROBERT A. MARCIS, II, ESQ.
 6               WILLIAM GAZLEY, ESQ.
 7               1901 Bond Court Building
 8               1300 East 9th Street
 9               Cleveland, Ohio  44114
10               (216) 575-0777
11   
12         On behalf of the Defendants:
13               EUGENE B. MEADOR, ESQ.
14               Assistant Attorney General
15               State Office Building, 11th Floor
16               615 West Superior Avenue
17               Cleveland, Ohio  44113-1899
18               (216) 787-3030
19                         ----
20   
21   ALSO PRESENT:
22               Ms. Kimberly DiMuzio, Videographer
23                         ----
24   
25   

                                                                     3
 1               MR. MEADOR:  On behalf of the 
 2   Defendant, I want to raise an issue that arose 
 3   when I received Dr. Venizelos's second report 
 4   in this case.  His second report I received 
 5   December 27, 2002, and it was faxed to me by 
 6   Shawn Acton from Kelley & Ferraro.  
 7               The report references an exam that 
 8   was done on November 14, 2002.  The problem is 
 9   that the report and exam were done after the 
10   Defense had already videotaped its expert 
11   witness and after this case had been set for 
12   trial already three di