16F
            1   State  of  Ohio,          SS:
            2   County of Lake.
            3                               - - -
            4                  IN THE COURT OF COM(ON PLEAS

            5                               - - -

            6   CATHY J.  PEDERSEN,  at  al.,

            7                  Plaintiffs,

            8         V.                            Case No.  89 CIV 1340
                                                    Judge James Jackson
            9   PAUL  FERRIS,  D.D.S.,

           10                  Defendant.

           11

           12           DEPOSITION OF SANFORD C. FRUMKZR, D.D.S.

           13                   MONDAY, OCTOBER 22, 1990

           14                               - - -

           15         The deposition of SANFORD C. FRUNKER, D.D.S., a

           16   witness, called for examination by the Plaintiffs,

           17   under the Ohio Rules of Civil Procedure, taken before

           18   me, Janet M. Hoffmaster, Registered Professional

           19   Reporter and Notary Public in and for the State of

           20   Ohio, pursuant to agreement of counsel, at the

           21   residence of Sanford C. Frumker, D.D.S., 1731 Wrenford

           22   Road, South Euclid, Ohio, commencing at 8:45 a.m., the

           23   day and date above set forth.

           24                               - - -

           25

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           1   APPEARANCES:

           2
               On behalf of the Plaintiffs:

                    PAUL KAUFMAN, ESQ.
           4        Weisman, Goldberg, Weisman   Kaufman
                    1600 Midland Building
           5        Cleveland,  Ohio  44115

           6
               On behalf of the  Defendant:

                    ROY RULNE, ESQ.
           8        Rominger & Reminger
                    113 St. Clair  Building
           9        Cleveland,  Ohio  44114

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            1                 SKNFORD C. FRUNKER, D.D.S.
            2   a witness, called for examination by the Plaintiffs,
            3   under the Rules, having been first duly sworn, an
            4   hereinafter certified, deposed and said as follows:
            5                       CROSS-EXAMINATION
            6   BY MR.  KAUFMAN:
            7   Q.     Dr. Frumker, for the record, would you state
            8   your full name, please?
            9   A.     Sanford C. Frumker.
           10   Q.     And your occupation  or profession?
           11   A.     Dentist.
           12   Q.     Dr. Frumkor, have you ever given a deposition
           13   before?
           14   A.     Yen.
           15   Q.     So you are somewhat familiar with the procedure
           16   that's involved?
           17   A.     Yes.
           18   Q.     I am going to ask you some questions this
           19   morning, and if at any time I ask you a question   that's
           20   not clear to you, that's garbled, that's
           21   inappropriately framed or whatever, please advise me.
           22          Do not try to answer the question if you don't
           23   understand it, okay?
           24   A.     Yes.
           25   Q.     I will be happy to try to rephrase it, or
                                                                     4
           1    clarify it for you, or we can ask our court reporter to
           2    read it back to you.
           3           If you don't understand the question, don't try
           4    to answer it, okay?
           5    A.     Yen.
           6    Q.     If you give an answer, the court  reporter  is
           7    going to record your answer and we will all assume that
           8    you understood the question.
           9           You also must respond verbally or audibly to the
          10    questions, instead of shaking your head, as  you  are
          11    doing now, because the court reporter can't interpret
          12    nods of the head or shrugs of the shoulders, okay?
          13    A.     Yes.
          14                MR. KAUFMAN:                  The  record
          15           should reflect this in the deposition  of  Dr.
          16           Sanford Frumker taken for purposes of
          17           cross-examination pursuant to the Rules.
          18                The deposition was set up by agreement and
          19           there will be a waiver as to any defect