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Expert Witness : PETER JOHN BROOKS M.D.


Case WILLIAM NICHOLS V. FAMILY MEDI-CENTER
Testimony Date February 08, 1994
Expert Type Orthopedic Surgery
Court State: Ohio County: Scioto
Pages 44
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I State of Ohio,
SS,
2 County of Scioto.)
3 - - -
4 IN THE COURT OF COMMON PLEAS

6 WILLIAM NICHOLS, et al.,
7 Plaintiffs,
8 VS. Case No. 93-CI-193
9 FAMILY MEDI-CENTER,
et al.,
10
Defendants.
11
12
13 DEPOSITION-OF PETER JOHN BROOKS, M.D.
14 Tuesday, February 8, 1994
15 - - -
16 The deposition of PETER JOHN BROOKS, M.D., a
17 witness, called by counsel for the Defendants for
la examination under the Ohio Rules of Civil Procedure,
19 taken before me, Kristin A. Beutler, a Registered
20 Professional Reporter and Notary Public in and for
21 the State of Ohio, by agreement of counsel, at The
22 Cleveland Clinic Foundation, 9500 Euclid Avenue,
23 Cleveland, Ohio, commencing at 10:00 a.m., on the
24 day and date above set forth.
25 - - -
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I APPEARANCES:

2 On behalf of the Plaintiff:

3 RICHARD BERRIS, ESQ.
Weisman, Goldberg & Weisman Co., L.P.A.
4 1600 Midland Building
Cleveland, Ohio 44115
5
On behalf of the Defendants:
6
ROBERT E. DEVER, ESQ.
7 Bannon, Howland & Dever
325 Masonic Building
8 Portsmouth, Ohio 45662

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I PETER JOHN BROOKS, M.D.
2 a witness, called by counsel for the
3 Defendants for examination under the Rules,
4 having been first duly sworn, as hereinafter
5 certified, was deposed and said as follows:
6 CROSS-EXAMINATION
7 BY MR. DEVER:
8 Q. Now, Doctor, for the record, would you state
9 your full name and your business address, sir?
10 A. Peter John Brooks, The Cleveland Clinic
11 Foundation, Cleveland, Ohio.
12 Q. Now, Dr. Brooks, your secretary, prior to my
13 coming in here, gave me a copy of your
14 curriculum vitae. Is it up-to-date?
15 A. Yes, it is.
16 MR. DEVER: Would you mind if we
17 mark this, Richard, and have this as an
18 exhibit?
19 MR. BERRIS: No.
20 (Defendants' Exhibit A marked.)
21 Q. Doctor, in looking over your curriculum vitae,
22 I think I noticed that obviously you are a
23 specialist in orthopedics?
24 A. Yes, right, orthopedic surgery.
25 Q. And you are Board certified?
4
1 A Right.
2 Q. And is that exclusively what you do --
3 A. Yes.
4 Q. -- orthopedics, you don't treat patients for
5 any other specialty?
6 A. orthopedic patients.
7 Yes. And you've been doing that for how long?
8 From the beginning, really, I noticed your
9 training was in that.
10 A. I finished my training in 1984, and I've been
11 treating orthopedic