1
 1                 IN THE COURT OF COMMON PLEAS
 2                   CUYAHOGA COUNTY, OHIO
 3                           - - -
 4   
 5   BARBARA RAM, et al,            )  Case No 424910
 6                Plaintiffs,        ) 
 7            vs                    )  Pages 1 - 97
 8   THE CLEVELAND CLINIC FOUNDATION,)
 9                Defendant         )
10                                   )
11            
12   
13   VIDEOTAPED DEPOSITION OF:  
14                 MELVIN J SILVERSTEIN, MD
15                 THURSDAY, OCTOBER 18, 2001
16                 3:44 PM
17   
18   
19   
20   
21   
22   Reported by:  
23             ALFRED J LONG
24             CSR No 2024
25   

                                                                     2
 1            VIDEOTAPED DEPOSITION OF MELVIN J 
 2   SILVERSTEIN, MD, taken on behalf of the Defendant 
 3   at 1441 Eastlake Avenue, Room 7415, Los Angeles, 
 4   California, on Thursday, October 18, 2001, at 
 5   3:44 pm, before ALFRED J LONG, CSR No 2024 
 6   
 7   APPEARANCES OF COUNSEL: 
 8                
 9   FOR THE PLAINTIFF:
10            KAMPINSKI & MELLINO CO, LPA
11            BY:  LAUREL A MATTHEWS, ESQ
12            1370 Ontario Street, Suite 1530
13            Cleveland, Ohio 44113
14            (216) 781-4110
15   
16   FOR DEFENDANT THE CLEVELAND CLINIC FOUNDATION:
17            BONEZZI, SWITZER, MURPHY & POLITO 
18            CO, LPA 
19            BY:  WILLIAM D BONEZZI, ESQ
20            526 Superior Avenue, Suite 1400
21            Cleveland, Ohio 44114-1491
22            (216) 875-2767
23   
24   ALSO PRESENT:
25            BRIAN MESSNER, VIDEOGRAPHER

                                                                     3
 1                         I N D E X
 2   
 3   WITNESS          EXAMINATION             PAGE
 4   MELVIN J SILVERSTEIN, MD
 5                    (By Mr Bonezzi)       5, 88
 6                    (By Ms Matthews)        53
 7   
 8   
 9                
10                      E X H I B I T S
11   
12   NO  PAGE    DESCRIPTION
13    1    7   Curriculum Vitae               
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15   
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17   
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19   
20           
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25   

                                                                     4
 1                 LOS ANGELES, CALIFORNIA; 
 2           THURSDAY, OCTOBER 18, 2001; 3:44 PM
 3   
 4   
 5   
 6            THE VIDEOGRAPHER:  Here begins Volume 1, 
 7   Videotape No 1, in the deposition of Dr Melvin 
 8   Silverstein, in the matter of Barbara Ram versus 
 9   Cleveland Clinic Foundation, in Cuyahoga County 
10   Common Pleas Court  The case number is 424910
11            Today's date is October 18th, 2001  The 
12   time on the video monitor is 3:44
13            The videotape operator today is Brian 
14   Messner, a certified legal video specialist, 
15   contracted by WishnowTearneyKillion, at 16830 
16   Ventura Boulevard, Encino, California 
17            This video deposition is taking place at 
18   the University of Southern California Norris Cancer 
19   Center, and was noticed by William Bonezzi, of 
20   Bonezzi, Switzer, Murphy & Polito 
21            Counsel please voice identify yourselves, 
22   and state whom you represent
23            MR BONEZZI:  My name is William Bonezzi  
24   I represent the defendant, Cleveland Clinic 
25   Foundation

                                                                     5
 1            MS MATTHEWS:  My name is Laurel Matthews  
 2   I represent the plaintiff, Barbara Ram  
 3            THE VIDEOGRAPHER:  And the court reporter 
 4   today is Fred Long, of WishnowTearney
 5            Would the court reporter please swear in 
 6   the deponent 
 7                             
 8               MELVIN J SILVERSTEIN, MD,
 9             having been first duly sworn, was
10             examined and testified as follows:
11                             
12                        EXAMINATION
13   
14   BY MR BONEZZI: 
15        Q  Sir, would you give us your name and 
16   professional address, please 
17        A  My name is Melvin Silverstein, and I'm at 
18   the USC Norris Cancer Center, 14624 -- no, no -- 
19   1441 Eastlake, Los Angeles, California
20        Q  And you have a profession, do you not?
21        A  Yes
22        Q  What is it?
23        A  I am a cancer surgeon
24        Q  Doctor, would you be kind enough to give us 
25   a little bit of your educational background, please 

                                                                     6
 1        A  I went to Johns Hopkins University in 
 2   Baltimore for undergraduate school  I went to 
 3   Albany Medical College for medical school  I spent 
 4   five years at the Boston City Hos