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STATE OF OHIO, COUNTY OF CUYAHOGA, SS IN THE COURT OF COMMON PLEAS JOHN GRANTHAM, et al, Plaintiffs, VS Case No 184289 Judge M Corrigan ZIMMER, INC, Defendant The deposition of GARY I KATZ, MD, called for examination, via videotape and court reporter, by the Plaintiffs, pursuant to the Ohio Rules of Civil Procedure, taken before Janice L Andrews, a Registered Professional Reporter and Notary Public within and for the State of Ohio, taken at the May Medical Building, 14100 Cedar Road, University Heights, Ohio, on Wednesday, the 6th day of March, 1991, commencing at 1:00 pm, pursuant to agreement WANOUS REPORTING SERVICE 55 PUBLIC SQUARE 1225 ILLUMINATING BUILDING CLEVELAND, OHIO 44113 (216) 861-9270 2 I APPEARANCES: 2 3 ON BEHALF OF THE PLAINTIFFS: 4 5 David G Davies, Esq, 6 Ray, Robinson, Hanninen & Carle 7 1650 East Ohio Building 8 Clevelandr Ohio 44114-2898 9 10 - - - - - 11 12 13 ON BEHALF OF THE DEFENDANTt 14 15 Richard J Berris, Esq, 16 Lawrence J Powerer Esq, 17 Weisman, Goldberg, Weisman & Kaufman 18 1600 Hidland Building 19 Cleveland, Ohio 44115 20 21 - - - - - 22 23 ALSO PRESENT: 24 John Smith# Videotape Technician 25 Jon Jastromb, Videotape Technician Computer Transcription - Wanous Reporting Service I N D E X 2 WITNESSt GARY I KATZ, MD 3 Page 4 Examination by Mr Davies 3 5 Examination by Mr Berrie 34 6 Re-examination by Mr Davies 53 7 9 10 11 12 13 14 15 17 18 19 20 21 22 23 24 25 Computer Transcription Wanous Reporting Service 3 1 MR DAVIESt This is the 2 ueposition of Dr Gary 1 Katz, taken on the 3 afternoon of March 6 199jr pursuant to notice 4 is there any question about the adequacy of the 5 notice, Mr Berris? 6 MR BERRIS! No 7 MR DAVIESs And may we 8 agree that the formalities of filing can be 9 waived? 10 MR BERRIS: Yes 11 MR DAVIESt would you swear 12 the witness, please 13 - - - - - 14 GARY I KATZt MD 15 of lawful age, called by the Defendant for examination 16 pqrsuanL to the Ohio Rules of Civil Procedure, having 17 been first duly swornr as hereinafter certified, was is examined and testified as follows: 19 20 EXAMINATION OF GARY I KATZ; MD 21 BY MR DAVIES; 22 0 Tell us your name, please 23 A Gary Katz 24 0 What is your profession or occupation? 25 A Orthopedic surgeon Computer Transcription - Wanous Reporting Service 4 I Q Could you tell us your professional address, 2 please 3 A May Medical Building 4 0 And what city is that? 5 A University Heights 6 Q You said you were an orthopedic surgeon, is that 7 a specialty dealing with the bones and joints? 8 A Yes 9 Q How did you train to be an orthopedic surgeon? 10 A After graduation from medicai school in 1961, I 11 did a five-year residency in orthopedic surgery 12 and I finished in 1966 13 Q What was your medical school? 14 A Ohio State 15 0 And where did you do your residencies? 16 A Mt Sinai Hospital in Clevelanas and University 17 of Indiana 18 112 Are you licensed to practice medicine in Ohio? 19 A Yes 20 Q Are you what is called board certified? 21 A Yes 2 2 How does one become board certified in 23 orthopedic surgery? 24 A At that time, when you finished your training 2 5 program# two years later you took an Computer Transcription - Wanous Reporting Service 5 1 examination, if you passed that# you were board 2 certified 3 0 Do you pracLice here in the Cleveland area? 4 A Yes 5 0 Do you practice at particular hospitals? 6 A Yes 7 Q What are those hospitals? 8 A Huron Road# Hillcrest and Bedford 9 Q In the course of your practice, do you teach 10 other doctors? 11 A Yes 12 0 What kind of doctors do you teach? 13 A AT this time, general surgery residents 14 0 Do you have a subspecialty in the field of 15 orthopedic surgery? 16 A I practice general orthopedics 17 Q This would include broken bonest arthritist what is else? 19 A You got trauma and deformities of the bones and 20 joints 21 Q In the course of your practice, do you do hip 2 2 replacement surgery? 23 A Yes 24 0 How frequently do you do hip replacement 25 surgery? Computer Transcription - WanOQ2 Reporting Service - - - - - - - - - - - - - - - --- - - - - - - 6 I A A few a month 2 0 Is it a major part of your practice? 3 A No 4 0 Do you know Dr Victor Goldberg? 5 A Yes 6 Q Do you refer cases to him from time to time? 7 A I have, yes 8 0 Under what circumstances do you refer cases to 9 Dr Goldberg? 10 A The cases I've referred to him were very complex 11 casesf both involving implants of the hips or 12 knees 13 0 Is he a specialist in -- or subspecialist in 14 that field? 15 A Yes 16 Q When you do hips i
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