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1
IN THE COURT OF COMMON PLEAS
OF CUYAHOGA COUNTY, OHIO
ANDREW J MOTIL, JR,
Plaintiff, Case Number
v 474714
FORD MOTOR COMPANY,
Defendant
Videotaped deposition of JAY S
THOMPSON, 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 xxxxxxxx Reporting
Services, Cleveland, Ohio, on Monday, the 3rd day
of March 2003 at 7:11 pm
- - - - -
2
APPEARANCES:
On behalf of the Plaintiff:
Kelley & Ferraro, LLP, by
COREY W FROST, ESQ
1901 Penton Media Building
1300 East Ninth Street
Cleveland, Ohio 44114
(216) 575-0777
On behalf of the Defendant:
Rademaker, Matty,
McClelland & Greve, by
THOMAS F GREVE, ESQ
55 Public Square, Suite 1775
Cleveland, Ohio 44113
(216) 621-6570
ALSO PRESENT:
Patrick Von Ahn, Video Technician
3
1 VIDEO TECHNICIAN: On the record,
2 7:11 pm, March 3, 2003 This is the videotape
3 deposition, videotaped videoconference
4 deposition of Jay S Thompson, MD, taken in
5 the case of Andrew Motil, Plaintiff, versus 19:10:48
6 Ford Motor Company, Defendant
7 We are located at 1408 Bayview
8 Court, Fort Myers, Florida, and 1301 East Ninth
9 Street, Cleveland, Ohio The court reporter is
10 Jaci R Traver The videographer is Patrick
11 Von Ahn
12 Will Counsel please identify
13 themselves for the record
14 MR GREVE: Tom Greve on behalf of
15 Ford Motor Company 19:11:12
16 MR FROST: And Corey Frost on
17 behalf of Andrew Motil
18 VIDEO TECHNICIAN: Doctor, would
19 you raise your right, please
20 Do you swear or affirm that the
21 testimony you're about to give will be the
22 truth, the whole truth, and nothing but the
23 truth?
24 THE WITNESS: I do
25 MR GREVE: We are convened here
4
1 pursuant to the videotaped deposition of
2 Dr Jay Thompson in Andrew Motil versus Ford
3 Motor Company, Case Number 474714, currently
4 assigned to Timothy McGinty, Cuyahoga County
5 Common Pleas Court 19:11:41
6 This deposition is being taken for
7 purposes for use at trial And Mr Frost, do
8 you waive any defects in notice and stipulate
9 to court reporter and videographer
10 qualifications? 19:11:51
11 MR FROST: Tom, I have no
12 objection whatsoever to the qualifications of
13 either the videographer or the court reporter
14 I do have one objection in general
15 to the taking of this particular deposition 19:12:01
16 And that is that although Dr Thompson's report
17 in the case was authored on December 10th of
18 2002, it wasn't supplied to me until January
19 the 8th, I believe it was, which is after the
20 deadline for submitting expert reports in this 19:12:17
21 particular case
22 MR GREVE: Thank you, Corey
23 EXAMIN
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