1 State of Ohio,
 SS:
2 County of Cuyahoga

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4 IN THE COURT OF COMMON PLEAS

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6 Sharon A Walden, et al,

7 Plaintiffs,
Case No 277480
8 vs
Judge Gaughan
9 Family Dental Centers, et al,

10 Defendants

11

12 DEPOSITION OF KENNETH CALLAHAN, DDS

13 MONDAY, JANUARY 29, 1996

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is The deposition of Kenneth Callahan, DDS, a

16 witness herein, called by the Plaintiffs for

17 examination under the Ohio Rules of Civil Procedure,

18 taken before me, Ivy J Gantverg, Registered

19 Professional Reporter and Notary Public in and for

20 the State of Ohio, by agreement of counsel and

21 without further notice or other legal formalities,

22 at Southgate Medical Arts Building, 21100 Southgate

23 Park Boulevard, Maple Heights, Ohio, commencing at

24 4:30 pm, on the day and date above set forth

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1 APPEARANCES:

2 on behalf of the Plaintiffs:

3 Fred Weisman, Esq
Weisman, Goldberg & Weisman
4 1600 Midland Building
Cleveland, Ohio 44115
5
on behalf of the Defendants:
6
Richard J Rymond, Esq
7 Reminger & Reminger
113 St Clair Building
a Cleveland, Ohio 44114

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1 KENNETH CALLAHAN, DDS
2 a witness herein, called by the plaintiffs for
3 examination under the Rules, having been first duly
4 sworn, as hereinafter certified, was deposed and
5 said as follows:
6 CROSS EXAMINATION
7 BY MR WEISMAN:
8 Q State your name, Sir?
9 A Kenneth Robert Callahan, C-A-L-L-A-H-A-N
10 Q Your personal and professional addresses,
11 please?
12 A 19101 South Park Boulevard, Shaker Heights,
13 44122 And Southgate Medical Arts Building,
14 Southgate Park Boulevard, Maple Heights, Ohio,
15 44137
16 Q What is your profession?
17 A oral and maxillofacial surgeon
18 Q Are you an MD?
19 A No
20 Q What are your degrees?
21 A BSC and DDS
22 Q So as I understand it, you are a dentist who
23 specializes in oral and maxillofacial surgery?
24 A That is correct, Mr Weisman
25 Q You have been deposed many times before, have


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1 you not?
2 A That is correct
3 Q Fair to say --
4 A Pardon?
5 Q Fair to say, maybe a thousand times?
6 A No, less than that Maybe 600 times I am
7 using the average of -- no, between five and six
8 hundred, perhaps
9 Q And in recent years, you would be deposed how
10 many times a week, would you say?
11 A Oh, no Deposed, as in either a discovery
12 depo, or a video depo, or at trial?
13 Q Yes
14 A All three of those
15 Oh, once a month, perhaps
16 Q And these reviews of cases that you are asked
17 to do, do you have reviews that go to the question
18 of the quality of dental care by your colleagues,
19 for example?
20 A occasionally
21@ Q And how many of those do you do per week or
22 per month, would you say?
23 A Not very many
24 Q Well, your best estimate, sir
25 A In the last ten years, Mr Weisman, or in the


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1 last year?
2 Q The last year is fine
3 A I think I have had four or five in the last
4 year Prior to that time, I don't think I had a
5 dozen before that
6 Q During the whole ten year period?
7 A That is correct
8 Q And on being asked for those examinations, is
9 it ordinarily the defense that asks you to review
10 for quality of care, or is it mixed?
11 A It is mixed, Mr Weisman
12 Q What is the percentage?
13 A Oh, it is higher for defense
14 Q What would you say, out of ten, for example?
15 A Oh, it would probably be eight and two
16 Q Now, for whom do you ordinarily make these
17 reviews, that is, what law firms, for example, when
18 you examine for the defense?
19 A Well, any law firm who asks me to do an IME
20 I don't necessarily examine for the defense,
21 again, Mr Weisman, but whoever asks me to do an
22 independent medical examination, I do it So that
23 includes law firms from all over the state, and some
24 from out of the state
25 Q Name ones you are thinking about, and that


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1 you can recall right now, defense law firms, who
2 happen to make the request?
3 A Please specify whether you are talking about
4 personal injury cases, or whether you are talking
5 about "alleged malpractice cases"
6 Q Alleged malpractice cases, I will say
7 A I am sorry, Mr Weisman, I never pay much
8 attention to what law firms they are That is a
9 fault of mine, an oversight I don't know that
10 I do know Reminger, I have done some for
11 Reminger  But most of the other ones, the law firms
12 that I can whip off to you in a hurry, are all
13 personal in