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 1                     VOLUME:  I
                        PAGES:  1 - 69
 2                       EXHIBITS:  Per index
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 4          IN THE COURT OF COMMON PLEAS
 5              CUYAHOGA COUNTY, OHIO
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 7   
 8   *********************************
    BARBARA RAM, Et Al,             )
 9              Plaintiffs            )
                                     )
10                                    )
    vs                              )  Case No
11                                    )  424910
                                     )
12   THE CLEVELAND CLINIC FOUNDATION, )
               Defendant             )
13   *********************************
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          DEPOSITION OF JAMES L CONNOLLY, MD,
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    taken on behalf of the Defendant, on Monday,
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    October 15, 2001, beginning at 7:08 pm
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    in Boston, Massachusetts before me,
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    Denise M Rae
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22                    -  -  -  -
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                                                                     2
 1   APPEARANCES:
 2   
 3   KAMPINSKI & MELLINO CO, LPA
 4      (By Attorney Laurel A Matthews)
       1370 Ontario Street, Suite 1530
 5      Cleveland, Ohio  44113
       Telephone No (216) 781-4110
 6      for the Plaintiffs;
 7   
    BONEZZI, SWITZER, MURPHY & POLITO CO,
 8   LPA
 9      (By William D Bonezzi, Esquire)
       Leader Building, Suite 1400
10      526 Superior Avenue
       Cleveland, Ohio  44114-1491
11      Telephone No (216) 875-2767
       for the Defendant
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                                                                     3
 1                    I N D E X
 2   
 3   DEPONENT                                PAGE
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    JAMES L CONNOLLY, MD
 5   
 6    Examination By Mr Bonezzi              4
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11                    EXHIBITS
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    NO          For Identification         PAGE
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    1   Letter dated September 17, 2001     4
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                                                                     4
 1                At the Beth Israel-Deaconess
 2       Medical Center, Pathology Department,
 3       330 Brookline Avenue, Boston,
 4       Massachusetts:
 5                (Letter dated September 17, 2001
 6                is marked Exhibit No 1 for
 7                Identification)
 8                JAMES L CONNOLLY, MD, having
 9       duly sworn that his testimony would be the
10       truth, the whole truth, and nothing but the
11       truth, testified as follows:
12                MR BONEZZI:  Let the record show
13       this is the deposition of James L Connolly,
14       MD, who has been identified as an expert
15       in the case of Ram, R-a-m, versus The
16       Cleveland Clinic Foundation
17                   DIRECT EXAMINATION
18       By Mr Bonezzi:
19   Q  Doctor, I'm going to be asking you some
20       questions this evening pertaining to
21       opinions that you hold in this case, which I
22       believe are set forth in a report you
23       authored dated September 17, 2001  If for
24       any reason you don't understand my
25       questions, at the conclusion of the

                                                                     5
 1       question, indicate that  I will attempt to
 2       rephrase the question, so that we can
 3       communicate  Would you do that for me,
 4       please?
 5   A  Yes
 6   Q  Most importantly, I'm going to ask that you
 7       answer my questions in some type of audible
 8       fashion, yes, no, or in sentence structure,
 9       as opposed to a nod of the head one way or
10       the other, so that the court reporter can
11       take everything down  Would you do that for
12       me, please?
13   A  Yes
14   Q  And if I ask you something that you don't
15       know the answer to, let me know and we'll
16       just move on  Also, I see you have a file
17       in front of you  If for any reason you need
18       to review any parts of that file during my
19       questioning, please feel free to do so
20       Don't even ask  Okay?
21   A  Sure
22   Q  Full and complete name, please?
23   A  James Leo Connolly
24   Q  Doctor Connolly, we are at what
25       institution?

                                                                     6
 1   A  The Beth Israel-Deaconess Medical Center
 2   Q  How long have you been affiliated with this
 3       institution?
 4   A  I've been affiliated with the Beth Israel
 5       Hospital since 1974
 6   Q  What is your present capacity?
 7   A  Director of Anatomic Pathology
 8   Q