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2 State of Ohio,

3 County of Scioto.

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IN THE COURT OF COMMON PLEAS

6 WILLIAM NICHOLS, et al.,

7 Plaintiffs,
Case No. 93-CI-193
8 VS.
Judge Burton
9 FAMILY MEDI-CENTER,
et al.,
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Defendants.
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12 DEPOSITION OF PETER J. BROOKS, M.D.
Tuesday, September 27, 1994
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15 The deposition of PETER J. BROOKS, M.D., a

16 witness called for examination by the Plaintiffs

17 under the Ohio Rules of Civil Procedure, taken

18 before-me, Diane M. Stevenson, a Registered

19 Professional Reporter and Notary Public in and

20 for. the state of Ohio, by agreement of counsel,

21 at The Cleveland Clinic Foundation, 9500 Euclid

22 Avenue, Cleveland, Ohio, commencing at 9:40 a.m.,

23 the day and date above set forth.

24 - - -

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Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

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1 APPEARANCES:

2 On behalf of the Plaintiffs:

3 Benito Antognoli, Esq.
Weisman, Goldberg & Weisman Co., LPA
4 1600 Midland Building
Cleveland, Ohio 44115
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6 On behalf of the Defendants:

7 Robert E. Dever, Esq.
Bannon, Howland & Dever
8 325 Masonic Building
Portsmouth, Ohio 45662
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Diane M. Stevenson, RPR, CM
Morse, Gantverg Hodge

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1 PETER J. BROOKS, M.D.

2 A witness, called for examination by the

3 Plaintiffs, under the Rules, having been first

4 duly sworn, as hereinafter certified, was

5 examined and testified as follows:

6 DIRECT EXAMINATION

7 BY Mr. Antognoli:

8 Q. Doctor, for the record, would you state your name

9 and business address.

10 A. It is Peter John Brooks. The Cleveland Clinic

11 Foundation in Cleveland.

12 Q. Doctor, what is your profession?

13 A. I am an orthopedic surgeon.

14 Q. What is orthopedic surgery?

15 A. That is surgery of the musculoskeletal system,

16 the bones, joints, spine, extremities, ligaments,

17 tendons, that sort of thing.

is Doctor, tell us about your education and

19 training. Where did you attend college?

20 A. I went undergraduate work at the University of

21 Toronto, did medical school at the University of

22 Toronto graduating in 1979.

23 I did orthopedic surgery training at Harvard

24 University in Boston, Massachusetts. I did two

25 and a half years of subspecialty training in hip


Diane M. Stevenson, RPR, CM
Morse, Gantverq Hodge

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