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                            IN THE COURT OF COMMON PLEAS

                               OF MEDINA COUNTY, OHIO





                 PAUL KASZIAN, et al,

                             Plaintiffs,              Case Number

                       v                             01-CIV-0807

                 KUNAL MITRA, MD,

                             Defendant





                             Deposition of NATHAN LEVITAN, MD,

                 called for examination under the statute, taken

                 before me, Jaci R Traver, RPR, CRR, and Notary

                 Public in and for the State of Ohio, at the

                 offices of Hermann, Cahn & Schneider, 500

                 Erieview Tower, 1301 East Ninth Street,

                 Cleveland, Ohio, on Tuesday, the 27th day of

                 August 2002 at 6:15 pm

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                 APPEARANCES:



                       On behalf of the Plaintiffs:

                             Hermann, Cahn & Schneider, by

                             KERRY S VOLSKY, ESQ

                             500 Erieview  Tower

                             1301 East Ninth Street

                             Cleveland, Ohio  44114

                             (216) 781-5515



                       On behalf of the Defendant:

                             Sutter, O'Connell, Mannion &

                             Farchione, by

                             JOSEPH A FARCHIONE, JR, ESQ

                             3600 Erieview Tower

                             1301 East Ninth Street

                             Cleveland, Ohio  44114

                             (216) 928-2200

                                     - - - - -

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            1                NATHAN LEVITAN, MD, of lawful

            2    age, called for examination, as provided by the

            3    statute, being first duly sworn, as hereinafter

            4    certified, said as follows:

            5          EXAMINATION OF NATHAN LEVITAN, MD

            6    BY MR VOLSKY:

            7          Q    Would you state your name for the

            8    record, please

            9          A    Dr Nathan Levitan

           10          Q    What is your business address?

           11          A    University Hospitals of Cleveland,

           12    11100 Euclid Avenue, Cleveland, 44106

           13          Q    Doctor, what are your specific

           14    areas of expertise?

           15          A    I'm Board-certified in medical

           16    oncology, hematology and internal medicine

           17          Q    Doctor, what were you asked to do

           18    in this case originally?

           19          A    Well, I can tell you when I review

           20    any case, I'm given the records and I'm asked

           21    to review them and render an impartial opinion

           22    regarding the case before I really have a sense

           23    of what any attorney's agenda is  I do that

           24    because if I don't feel comfortable with the

           25    case, I wouldn't get involved in it

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            1                As far as my specific involvement

            2    in this case, I've been asked to render

            3    opinions principally regarding proximate cause,

            4    and in particular, the staging and prognosis of

            5    this tumor at different points in time

            6          Q    Have you ever reviewed cases for

            7    Mr Farchione before this case?

            8          A    I don't think so  No

            9          Q    What about since this case, have

           10    you reviewed any other case before?

           11          A    I don't think so

           12          Q    Mr Farchione was with the law firm

           13    of Reminger & Reminger  Have you reviewed

           14    cases for that firm?

           15          A    Yes

           16          Q    Tell me who at that firm you've

           17    reviewed cases for and the number of cases for

           18    that firm

           19          A    Well, I don't keep -- I don't keep

           20    strict track of such things  I can tell you

           21    that I probably reviewed eight to ten or so

           22    cases a year in the last few years; somewhat

           23    less before that  That is to say, one a month

           24    or a little bit less than that