MM

 0"IGINAL

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
CHARLES SMITH CASE NO. 1-92-CV-0507
VERSUS
UNITED STATES OF AMERICA
DEPARTMENT OF VETERAN AFFAIRS
The videotape deposition of DR.  MICHAEL E.
CAREY taken in the above-entitled cause,
pursuant to the following stipulation, before
Ruby Kurz, C.S.R., authorized to administer
oaths of witnesses pursuant to Section 961.1 of
Title 13 of the Louisiana Revised Statutes of
1950, as amended.  Taken at the offices of Dr.
Michael E. Carey, 1542 Tulane Avenue, New
Orleans, Louisiana on Saturday, May 21, 1994.








ASSOCIATED REPORTERS, INC./RUBY KURZ, C.S.R.
(504) 529-3355

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APPEARANCES:

ATTORNEY FOR THE PLAINTIFF, CHARLES SMITH:

WEISMAN & GOLDBERG
1600 MIDLAND BUILDING
CLEVELAND, OHIO 44115
BY: MR.  FRED WEISMAN, ESQ.

ATTORNEY FOR THE DEFENDANT:

UNITED STATES DEPARTMENT OF JUSTICE
NORTHERN DISTRICT OF OHIO
1800 BANK ONE CENTER
600 SUPERIOR AVENUE, EAST.
CLEVELAND, OHIO 44114
BY: MR.  WILLIAM J. KOPP, ESQ.
ASSISTANT U.S. ATTORNEY

ATTORNEY FOR THE DEFENDANT:

UNITED STATES DEPARTMENT OF JUSTICE
NORTHERN DISTRICT OF OHIO
1800 BANK ONE CENTER
600 SUPERIOR AVENUE, EAST.
CLEVELAND, OHIO 44114
BY: MS.  MAUREEN MURPHY, ESQ.
ASSISTANT U.S. ATTORNEY

ATTORNEY FOR THE DEFENDANT:

UNITED STATES DEPARTMENT OF JUSTICE
NORTHERN DISTRICT OF OHIO
1800 BANK ONE CENTER
600 SUPERIOR AVENUE, EAST.
CLEVELAND, OHIO 44114
BY'.  MR.  CHARLIE WILK, ESQ.
ASSISTANT U.S. ATTORNEY








ASSOCIATED REPORTERS, INC./RUBY KURZ, C.S.R.
(504) 529-3355




1 1 1

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INDEX



EXAMINATION BY:  PAGE:

MR. WEISMAN 5

MR. KOPP 149

MR. WEISMAN 202

MR. KOPP 205


EXHIBITS


EXHIBIT NUMBER:  PAGE:

EXHIBIT NUMBER 1 6

EXHIBIT NUMBER 3 23

EXHIBIT NUMBER 3A 24

EXHIBITS NUMBER 4 AND 5 25

EXHIBIT NUMBER 6 26

EXHIBIT NUMBER 14 30

EXHIBIT NUMBER 8 35

EXHIBIT NUMBER 9 36

EXHIBIT NUMBER 10 41

EXHIBITS NUMBER 11 AND 12 42

EXHIBIT NUMBER 13 43

EXHIBIT NUMBER 15 44

EXHIBIT NUMBER 16 105

EXHIBIT NUMBER 17 149


ASSOCIATED REPORTERS, INC./RUBY KURZ, C.S.R.
(504) 529-3355

4

1 STIPULATION

2 It is stipulated and agreed by and

3 between all parties that this deposition is

4 hereby being taken pursuant to Notice under

5 the Rules of Civil Procedure for all

6 purposes permitted under the law.

7 All formalities, with the exception of

8 reading an