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                            IN THE COURT OF COMMON PLEAS

                              OF CUYAHOGA COUNTY, OHIO





                 RICARDO MONTALVO, JR.,

                 et al.,

                             Plaintiffs,      Case No.



                       vs.                    43117

                 GIOVANNA ORAVEC,             Judge John D.

                 Sutula

                             Defendant.





                                     - - - - -

                             Deposition of KENNETH S. MOSS, M.D.,

                 called for examination under the statute, taken

                 before me, Donnalee Cotone, a Registered

                 Professional Reporter and Notary Public in and

                 for the State of Ohio, pursuant to notice and

                 stipulations of counsel, at the offices of

                 Kenneth S. Moss, M.D., 2012 West 25th Street,

                 Suite 916, Cleveland, Ohio, on Wednesday,

                 February 6, 2002, at 5:06 o'clock p.m.

                                     - - - - -

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                 APPEARANCES:



                       On behalf of the Plaintiff:

                             Walter & Haverfield LLP, by

                             BRIDEY MATHENEY, ESQ.

                             1300 Terminal Tower

                             50 Public Square

                             Cleveland, Ohio  44113-2253

                             (216) 781-1212



                       On behalf of the Defendants:

                             PERRIN I. SAH, ESQ.

                             Allstate Insurance Company

                             113 St. Clair, Suite 525

                             Cleveland, Ohio 44114

                             (216) 771-8214

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            1                KENNETH S. MOSS, 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: