1


                           IN THE COURT OF COMMON PLEAS

                             OF CUYAHOGA COUNTY, OHIO



                 DAVID L RAY, et al,

                             Plaintiffs,

                       vs                           Case No

                 KIM STEARNS, MD, et al,          395119



                             Defendants



                                     ~ ~ ~ ~ ~

                             Deposition of ROBERT B ANCELL,

                 PhD, called for examination under the statute,

                 taken before me, Kelly A Holden, a Notary Public

                 in and for the State of Ohio, by agreement of

                 counsel, at the offices of Linton & Hirshman, 700

                 West St Clair Avenue, Cleveland, Ohio, on

                 Monday, April 16th, 2001 at 9:30 am

                                     ~ ~ ~ ~ ~

                                                                  2


                 APPEARANCES:



                       On behalf of the Plaintiffs:

                             Linton & Hirshman, by

                             TOBIAS J HIRSHMAN, ESQ

                             Hoyt Block, Suite 300

                             700 West St Clair Building

                             Cleveland, Ohio  44113

                             (216) 781-2811



                       On behalf of the Defendants:

                             Buckingham, Doolittle &

                             Burroughs, LLP, by

                             RONALD WILT, ESQ

                             1700 One Cleveland Center

                             1375 East Ninth Street

                             Cleveland, Ohio  44114

                             (216) 621-5300

                                     ~ ~ ~ ~ ~

                                        3


            1          ROBERT B ANCELL, PHD, of lawful age,

            2    called for examination, as provided by the Ohio

            3    Rules of Civil Procedure, being by me first

            4    duly sworn, as hereinafter certified, deposed

            5    and said as follows:

            6         EXAMINATION OF ROBERT B ANCELL, PhD

            7    BY MR WILT:

            8          Q    Doctor, would you please state your

            9    full name?

           10          A    Robert Bruce Ancell                   08:23:42

           11          Q    And what's your current address?

           12          A    23077 Greenfield Road, Suite 185,

           13    Southfield, Michigan

           14          Q    I hand you what I believe is your

           15    curriculum vitae, and review that and tell me      08:23:56

           16    if that's current and up to date

           17          A    It is

           18          Q    Okay  Go ahead and attach that as

           19    Defendant's Exhibit Number A

           20                     -  -  -  -  -

           21                (Thereupon, Defendant's Deposition

           22                Exhibit A was marked for purposes of

           23                identification)

           24                      -  -  -  -  -

           25          Q    Doctor, just as a matter of            08:24:46

                                        4


            1    inventory and everything, I have here what

            2    you've handed me to be represented as your

            3    complete file on David Ray --

            4          A    Yes

            5          Q    -- in this case?                       08:24:56

            6          A    Yes, sir

            7          Q    I have your career assessment

            8    inventory, and I have two of them  They appear

            9    to be the exact same report?

           10          A    They are  They're duplicates         08:25:06

           11          Q    Okay  Have you reviewed any other

           12    depositions other than Mr Ray's?

           13          A    No, I believe that's the only

           14    deposition I have

           15          Q    Other than Mr Hirshman and Mr        08:25:38

           16    Ray, have you spoken to anyone else regarding

           17    the facts in this case such as Dr Klejka?

           18          A    No, I have not spoken to any other

           19    individuals other than Mr Hirshman, Mr Ray

           20    and now yourself                                  08:25:52

           21          Q    Okay

           22                MR HIRSHMAN:  Let me just make

           23    sure you're accurate on that  I know Mr Davis

           24    wrote a