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                            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



                                     - - - - -

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                 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

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            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

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            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