1-7 CO Z-



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 Richard Dalziel, etc.,

7 Plaintiff, Case No. 256240

8 VS.

9 Kaiser Foundation Health
Plan of Ohio, et al.,
10
Defendants.
11

12

13 THE DEPOSITION OF JEFFREY R. RUBIN, M.D.

14 WEDNESDAY, SEPTEMBER 28, 1994

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16 The deposition of JEFFREY R. RUBIN, M.D., a witness,

17 called for examination by the Plaintiff, under the Ohio

18 Rules of Civil Procedure, taken before me, Michelle R.

19 Hordinski, Registered Professional Reporter and Notary

20 Public in and for the State of Ohio, pursuant to

21 agreement, at the offices of Jeffrey R. Rubin, M.D., 500

22 Gypsy Lane, Youngstown, Ohio, commencing at 11:00 a.m.,

23 the day and date above set forth.

24

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1 APPEARANCES:

2

3 On behalf of the Plaintiff:

4 RICHARD BERRIS, ESQ.
Weisman, Goldberg & Weisman
5 1600 Midland Building
Cleveland, Ohio 44113
6

7
on behalf of the Defendants:
8
GARY GOLDWASSER, ESQ.
9 Reminger & Reminger
The 113 St. Clair Building
10 Cleveland, Ohio 44113

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14

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1 JEFFREY R. RUBIN, M.D.
2 a witness, called for examination by the Plaintiff, under
3 the Rules, having been first duly sworn, as hereinafter
4 certified, deposed and said as follows:
5 CROSS-EXAMINATION
6 BY MR.  BERRIS:
7 Q. State your full name.
8 A. Jeffrey Reed Rubin.
9 Q. Is there a CV available?  I know I had one.
10 MR. GOLDWASSER: Oh, I have --
11 MR. BERRIS: You know what,
12 it was attached to the report.
13 MR. GOLDWASSER: Yes.
14 Well, Eric has used Dr. Rubin as a
15 witness before, so I'm sure he has material
16 on him.
17 Q. Did you testify for Eric Kennedy in a case?
18 A. I've reviewed records for him. I haven't testified
19 for him.
20 MR. GOLDWASSER: He did testify
21 in deposition once.
22 MR. BERRIS: For Eric?
23 MR. GOLDWASSER: For Eric in a
24 case I defended.
25 MR. BERRIS: Which case?
4



1 MR. GOLDWASSER: That was a
2 double amputee case of a lady, Fern
3 Hayes.
4 BY MR.  BERRIS:
5 Q. I was provided with a copy of your CV.
6 Is this your full CV?
7 A. No. It's probably the face sheet.
8 Q. This is just the face sheet of your CV?
9 A. Probably an old one.
10 Q. Is there a new full CV available?
11 A. Yes.
12 Q. We can get that before we leave?
13 A. Yes.