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The State of Ohio,
SS:

County of Cuyahoga.




IN THE COURT OF COMMON PLEAS




KENNETH ROSE,

 Plaintiff,

VS. Case Number 299356
Judge Frank Celebrezze
KAISER FOUNDATION HEALTH PLAN
OF OHIO,

 Defendant.



DEPOSITION OF JEFFREY ADAM ROSS, M.D.
Wednesday, April 21, 1993



Deposition of JEFFREY ADAM ROSS, K.D., called by the

Plaintiff for examination under the Ohio Rules of Civil

Procedure, taken before me, the undersigned, Janice K.

Wicinski, a Notary Public in and for the State of Ohio, at

the offices of Gallagher, Sharp, Fulton & No-man, 6th Floor,

Bulkley Building, Cleveland, Ohio 44115, commencing at 9:12

a.m., the day and date above set forth.






CORSILLO GRANDILLO
COURT REPORTERS
950 Citizens Building
Cleveland, Ohio 44114
216-523-1700

2

APPEARANCES:

On Behalf of the Plaintiff:

Richard J. Berrie, Esquire
Weisman, Goldberg & Weisman
1800 Midland Building
Cleveland, Ohio 44113

On Behalf of the Defendant:

Beverly Harris, Require
Gallagher, Sharp, Fulton & Norman
6th Floor - Bulkley Building
Cleveland, Ohio 44115

1 JEFFREY ADAM ROSS, M.D.

2 called by the Plaintiffs for examination under the Ohio Rules

3 of Civil Procedure, after having been first duly sworn, as

4 hereinafter certified, was examined and testified as follows:

5 - - - - -

6 EXAMINATION

7 - - - - -

8 BY MR.  BERRIS:

9 Q State your full name.

10 A Jeffrey Adam Ross.

11 Q And you are a physician; correct?

12 A Correct.

13 Q I'm going to ask you some questions today about your

14 review of this matter involving Ken Rose. If any of my

is questions are not clear or you do not understand me, let me

16 know, and I will rephrase the question for you. Okay?

17 A Fine.

18 Q How much are you charging for your time for this

19 deposition?

20 A $250 an hour.

21 Q Is that your normal charge?

22 A Yes, it is.

23 Q What has your medicolegal experience been?  Can you

24 describe that?

25 A Yes. I've done over the last five years numerous chart



Computer-Aided Transcription By
Corsillo & Grandillo Court Reporters

4


1 reviews involving personal injury, medical malpractice for

2 both the defense and for the plaintiff. And I have testified

3 on one occasion and I've been to depositions before. And

4 I've worked for a series of firms in Cleveland and also in

5 Columbus.

6 0 What firms have you worked for in Cleveland?

7 A Gallagher, Sharp; Weisman, Weisman & Goldberg.

8 Q You have worked for my firm?

9 A That's correct.

10 Q Somebody in our firm mentioned that you know --

11 A Mitch.

12 0 Mitch Weisman, you have worked for Mitch Weisman?

13 A That's correct.

14 Q On a medical malpractice case or a personal injury?

15 A Actually both, personal injury and malpractice.

16 Q What kind of malpractice case was it?

17 A It involved pneumothorax after a trigger point

18 injection. That was one case.

19 There has been some nursing home cases, also, so

20 there's been a series of a couple things. I'd amend that, 1

21 think those were really not medical malpractice as much as

22 involving the nursing home itself.

23 Q Nursing care?

24 A But the case with regard to the pneumothorax was a

25 malpractice case.



Computer-Aided Transcription By
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5


1 What was your opinion in this case, that there was

2 substandard care?

3 MS. HARRIS: Objection. Go ahead.

4 A Yes, there was.

5 Q They punctured the lung doing an injection?

6 A That's correct.

7 Q Do you have a CV?

8 A Yes, I do.

9 Q An extra one for me?

10 A Actually I brought that for you.

11 MS. HARRIS: Well, you can't keep it,

12 because I don't have a copy.

13 MR. BERRIS: Let me just take a look at

14 it.

is MS. HARRIS: At the end of the

16 deposition, we can do that.

17 You did a residency in internal medicine at University

18 Hospitals and the VA; correct?

19 A That's correct, a combined program.

20 0 A combined program?

21 A Right.

22 Q Completed that residency?

23 A That's correct.

24 Q And then the combined program was with diagnostic

25 radiology?



Computer-Aided Transcription By
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6


1 A No. What happened, it was --

2 Q Explain that for me.

3 A I finished my internal medicine residency in 1986.  At

4 that time, I decided -- well, actually, it was probably in

5 185, that I had applied to internal medicine, but also to go

6 into diagnostic radiology. And I applied and was accepted at

7 University Hospitals.

8 I completed two of four years of diagnostic radiology.

9 And by my choice, I decided I really wanted to take the route

10 of going back to primary care. Although many people thought

11 th