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1
1 IN THE UNITED STATES DISTRICT COURT
2 FOR THE SOUTHERN DISTRICT OF OHIO
3 EASTERN DIVISION
4 - - - - -
5 Aleksandra S :
Balalovski,
6 :
Plaintiff,
7 :
vs Case No C2-00 189
8 :
Lucent Technologies,
9 Inc C/O Prentice :
Hall Corp System
10 Statutory Agent, :
11 Defendant :
12 - - - - -
13 Deposition of J NICK MARZELLA, PHD,
14 a Witness, herein, called by the Defendant
15 for cross-examination under the Applicable
16 Rules of Federal Civil Procedure, taken
17 before me, Laura E Thornsberry, a
18 Registered Professional Reporter and Notary
19 Public in and for the State of Ohio,
20 pursuant to notice and stipulations of
21 counsel, at the offices of J Nick Marzella,
22 PhD, 785 East Broad Street, Columbus,
23 Ohio, on Tuesday, August 7, 2001, at 2:57
24 o'clock pm
25
2
1 APPEARANCES:
2 Mahata & Carter
341 South Third Street
3 Suite 300
Columbus, Ohio 43215
4 By John M Mahata, Esquire,
5 and
6 Schottenstein Co, LPA
341 South Third Street
7 Suite 300
Columbus, Ohio 43215
8 By James M Schottenstein,
Esquire,
9
and
10
Collin N Thomas, Esquire
11 341 South Third Street
Suite 300
12 Columbus, Ohio 43215
13 On behalf of the Plaintiff
14 Ulmer & Berne LLP
Bond Court Building
15 1300 East Ninth Street
Suite 900
16 Cleveland, Ohio 44114
By Ronald H Isroff, Esquire and
17 Stephanie E Kennedy, Esquire,
18 On behalf of the Defendant
19
20
21
22
23
24
25
3
1 Tuesday Afternoon Session
2 August 7, 2001
3 2:57 o'clock pm
4 - - - - -
5 It is stipulated by and between
6 counsel for the respective parties that the
7 deposition of J NICK MARZELLA, PHD, a
8 Witness herein, called by the Defendant for
9 cross-examination under the statute, may be
10 taken at this time by the Notary, pursuant
11 to notice and stipulations of counsel; that
12 said deposition may be reduced to writing in
13 stenotypy by the Notary, whose notes may
14 thereafter be transcribed out of the
15 presence of the witness; that proof of the
16 official character and qualification of the
17 Notary is waived
18 - - - - -
19
20
21
22
23
24
25
4
1
2 INDEX
3 Defendant's Exhibit Page No
4 A - Resume 6
5 B - Letter, 9/7/99 13
6 C - Fax, 11/6/00 16
7 D - Letter, 11/25/96 28
8 E - Office Note, 1/10/00 40
9 F - Letter, 5/25/00 42
10 G - Copy of MMPI and Results 56
11 H - Office Notes 61
12 I - Office Notes 62
13 J - Office Notes 66
14 K - Office Notes 70
15 L - Office Notes 84
16 M - Office Notes 93
17 N - Office Notes 98
18 O - Office Notes 101
19
20 Examination By Page No
21 Mr Isroff - Cross 5
22
23
24
25
5
1 J NICK MARZELLA, PHD
2 by me first duly sworn, as hereinafter
3 certified, deposes and says as follows:
4 - - - - -
5 CROSS-EXAMINATION
6 BY MR ISROFF:
7 Q Would you please state your name
8 for the record?
9 A My name is Nick Marzella
10 Q And your age?
11 A I am 53 years old
12 Q And your Residence address?
13 A 134 Ashbourne Road, Columbus,
14 Ohio
15 Q Profession?
16 A I'm a psychologist
17 Q Do you have a doctorate in
18 psychology?
19 A It's a doctorate of philosophy,
20 spe
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