-0
1700(oL

1 IN THE COURT OF COMMON PLEAS
LICKING COUNTY, OHIO
2

3 LUCINDA A. THOMPSON,
Individually and as Administratrix
4 of the Estate of
WILLIS D. FIELD, deceased
5
Plaintiff,
6
 Vs Case No. 95CV0005 GLF
7
LICKING MEMORIAL HOSPITAL,
8 et al.,

9  Defendants.

10

11
DEPOSITION OF JEFFREY A. ROSS, M.D.
12 THURSDAY, FEBRUARY 8, 1996

1 3

14

15 The deposition of JEFFREY A. ROSS, M.D.,

16 the Witness herein, called by counsel on behalf of

17 the Defendant for examination under the statute,

is taken before me, Vivian L. Gordon, a Registered

19 Diplomate Reporter and Notary Public in and for

20 the State of Ohio, pursuant to agreement of

21 counsel, at the offices of Weisman, Goldberg &

22 Weisman, 1600 Midland Building, Cleveland, Ohio,

23 commencing at 3:00 o'clock p.m. on the day and

24 date above set forth.

25


Vivian Gordon, RDR
MORSE, GANTVERG & HODGE

2


1 APPEARANCES:

2
On behalf of the Plaintiff
3 Weisman, Goldberg & Weisman
BY: HENRY W. CHAMBERLAIN, ESQ.
4 1600 Midland Building
Cleveland, Ohio 44115
5
On behalf of the Defendant Licking Memorial
6 Hospital
Reese, Pyle, Drake & Meyer
7 BY: CHRISTOPHER R. MEYER, ESQ.
36 North Second Street
8 P.O. Box 919
Newark, Ohio 43058-0919
9
On behalf of the Defendant Pasley
10 Jacobson, Maynard, Tuschman & Kalur
BY: PATRICK F SMITH, ESQ. (By telephone)
11 NBD Bank Building Suite 880
175 South Third Street
12 Columbus, Ohio 43215-5142

13 ALSO PRESENT:
Cara L. Evans, Legal Assistant
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15

16

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19

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2 5


Vivian Gordon, RDR
MORSE, GANTVERG & HODGE

3


1 JEFFREY A. ROSS, M.D., a witness herein,

2 called for examination, as provided by the Ohio

3 Rules of Civil Procedure, being by me first duly

4 sworn, as hereinafter certified, was deposed and

5 said as follows:

6 EXAMINATION OF JEFFREY A. ROSS, M.D.

7 BY-MR. MEYER:

8 Q. Doctor, could you please state your full

9 name.

10 A. Jeffrey Adam Ross.

11 Q. Doctor, I am handing you what has been

12 marked as Ross Deposition Exhibit 1. Is that a

13 copy of your curriculum vitae?

14 A. Yes, it is.

15 Q. And is that up to date or are there any

16 additions that you wish to make to that?

17 A. It's fine.

is Q. It is up to date?

19 A. Yes, it is.

20 Q_ Doctor, could you briefly describe for me

21 your current medical practice. I understand you

22 are practicing medicine here in Cuyahoga County?

23 A. That's correct. I'm a general internist in

24 the suburbs of Cleveland, and I am board certified

25 and have been in private practice for eight


Vivian Gordon, RDR
MORSE, GAMTVERG & HODGE

4


1 years.

2 My practice, I would say, is 90 percent

3 clinical practice, and the 10 percent that remains

4 is teaching on a voluntary basis and some

5 medical/legal work as it comes up.

6 Q. Do you have a hospital or hospitals where

7 you have staff privileges here in Cuyahoga County?

a A. Yes, I do.

9 Q. And what hospitals are those?

10 A. Meridia Hillcrest Hospital and University

11 Hospitals of Cleveland.

12 Q. And where is the majority of your hospital

13 base practice at? What institution?

14 A. It's really pretty much divided. My

15 practice is predominantly ambulatory, as the

16 nature of practice is heading. So I would say

17 it's 50-50 between the two hospitals.

18 Q. If you were to describe the patient

19 population that you serve as a physician, what age

20 groups do you provide medical services to?

21 A. Teenagers through geriatrics.

22 Q. And is there any particular concentration

23 of your practice in one age group or another or is

24 it spread among those groups?

25 A. It's spread pretty evenly throughout.


Vivian Gordon, RDR
MORSE, GANTVERG & HODGE

5


1 Do you have any specialty interest in

2 chemical dependency?

3 A. No.

4 Q. Have you received any particular training

5 in chemical dependency, formal training?

6 A. No, I have not.

7 Q. Have you ever served as an expert witness

8 before?

9 A. Yes, I have.

10 Q. And how many times have you served as an

11 expert witness in a medical/legal case?

12 A. Where I have actually testified or written

13 or --

14 Q. Let's start with just cases that you have

15 reviewed for attorneys in medical/legal cases,

16 approximately how many?

17 A. I would say three dozen.

is Q. And for how long a period of time have you

19 reviewed cases?

20 A. over the last eight years.

21 Q. How many times have you had your deposition

22 taken in medical/legal cases, approximately?

23 A. I think about ten.

24 Q. And have you testified as an expert witness

25 at a trial in a medical/legal case?


Vivian Gordon, RDR
MORSE, GANTVERG & HODGE

6


1 A. Yes, I hav