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                           IN THE COURT OF COMMON PLEAS

                             OF CUYAHOGA COUNTY, OHIO



                 ANNE KINDL,

                             Plaintiff,

                       vs.                   Case No. 387118

                 ELIZABETH RYDELL,

                 et al.,

                             Defendants.



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                             Deposition of BIENVENIDO D. ORTEGA,

                 M.D., called for examination under the statute,

                 taken before me, Terry D. Gimmellie, a Registered

                 Professional Reporter and Notary Public in and

                 for the State of Ohio, pursuant to agreement of

                 counsel, at the Medical Arts Center II, 6707

                 Powers Boulevard, Suite 201, Parma, Ohio on

                 Thursday, April 27, 2000, at 10:00 o'clock a.m.

                                  - - - - -

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                 APPEARANCES:



                       On behalf of the Plaintiff:

                             Joondeph & Bittel, LLP, by

                             THOMAS R. KELLY, ESQ.

                             Akron Center Plaza, Suite 700

                             50 South Main Street

                             Akron, Ohio  44308-1881

                             (330) 376-4500



                       On behalf of the Defendant:

                             Law offices of James Glowacki, by

                             JAMES L. GLOWACKI, ESQ.

                             510 Leader Building

                             Cleveland, Ohio  44114

                             (216) 696-7445



                 ALSO PRESENT:

                             Mrs. Elizabeth Rydell

                             Mr. Rydell



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            1          BIENVENIDO D. ORTEGA, M.D., of lawful

            2    age, called for examination, as provided by the

            3    Ohio Rules of Civil Procedure, being by me

            4    first duly sworn, as hereinafter certified,

            5    deposed and said as follows:

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            7       EXAMINATION