I State of Ohio, (?
S S
2 County of Lake.

3 - - -

4 IN THE COURT OF COMMON PLE S

5 - - -

6 Victor Bukky, Admn., etc.,

7 Plaintiff,
)Case No. 91 CV 001463
8 VS.
)Judge Parks
9 Lake Hospital System, Inc.,
et al.,
10
Defendants.
11

12 TELEPHONE DEPOSITION OF

13 ALBERT BRIGGS, JR., M.D.

14 WEDNESDAY, JULY 22, 1992

1 5 - - -

16 The deposition of Albert Briggs, Jr., M.D., a

17 witness herein, called by the Plaintiff for

18 examination under the Ohio Rules of Civil Procedure,

19 taken before me, Ivy J. Gantverg, Registered

20 Professional Reporter and Notary Public in and for

21 the State of Ohio, by agreement of counsel and

22 without further notice or other legal formalities,

23 at the offices of Weisman, Goldberg & Weisman, 1600

24 Midland Building, Cleveland, Ohio, commencing at

25 2:25 p.m., on the day and date above set forth.


MORSE, GANTVERG & HODGE

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1 APPEARANCES:

2 On behalf of the Plaintiff:

3 R. Eric Kennedy, Esq.
Weisman, Goldberg & Weisman
4 1600 Midland Building
Cleveland, Ohio 44115
5
On behalf of the Defendants:
6
David W. Sumner, Esq.
7 Jacobson, Maynard, Tuschman & Kalur
1001 Lakeside Avenue - Suite 1600
8 Cleveland, Ohio 44114

9

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MORSE, GANTVERG & HODGE

3
I MR. KENNEDY: Hello.
2 MR. SUMNER: Hello.
3 MR. KENNEDY: Are we all here?
4 THE WITNESS: I am here.
5 MR. SUMNER: I mean here.
6 MR. KENNEDY: All right.
7 Doctor, my name is Eric Kennedy.
8 How are you today?
9 THE WITNESS: Good.
10 How are you?
11 MR. KENNEDY: Good.
12 David, are we going to waive the fact
13 that the court reporter cannot administer the
14 oath in Virginia?
15 MR. SUMNER: Right.
16 MR.  KENNEDY: All right.
17 MR. KENNEDY: Ivy Gantverg is here,
18 Doctor, who is a court reporter, in my
19 office, and she is going to be taking
20 everything that you say down word for word on
21 her machine here.
22 The first thing that we need to do is
23 have her swear you in, all right?
24 THE WITNESS: Certainly.
25 MR. KENNEDY: It is important that

MORSE, GANTVERG & HODGE
4
1 everybody talk loud, because we are using a
2 speaker phone here, and Ivy needs to take
3 everything down as accurately as possible.
4 If she has any difficulty keeping up
5 because the lawyers choose to talk at the
6 same time you are talk