I IN THE COURT OF COMMON PLEAS

2 CUYAHOGA COUNTYr OHIO

3 JACK ALBANO, A0 _N7

4 Plaintiff, 76
JUDGE CORRIGAN
5 _vs- CASE NO. 153043

6 HAMMOND CONSTRUCTION COMPANY,
et al.,
7
Defendants.
8

9 - - - -

10 Deposition of ROD W. DURGIN, Ph.D., taken as

11 if upon cross-examination before M. Sheila

12 Hanlon, a Notary Public within and for the State

13 of Ohio, at the offices of Weisman, Goldberg,

14 Weisman & Kaufman, 1600 Midland Building,

15 Cleveland, Ohio, at 2:30 p.m. on Thursday,

16 February 6, 1992, pursuant to notice and/or

17 stipulations of counsel, on behalf of the

18 Defendants in this cause.

19 - - - -

20
MEHLER & HAGESTROM
21 Court Reporters
1750 Midland Building
22 Cleveland, Ohio 44115
 216.621.4984
23 FAX 621.0050
 800.822.0650
24

25

2

1 APPEARANCES:

2 Eric Kennedy, Esq.
Weisman, Goldberg, Weisman & Kaufman
3 1600 Midland Building
Cleveland, Ohio 44115
4 (216) 781-1111,

5 on behalf of the Plaintiff;

6 Thomas Cabral, Esq.
Gallagher, Sharp, Fulton & Norman
7 Seventh Floor Bulkley Building
Cleveland, Ohio 44115
8 (216) 241-5310,

9 On behalf of the Defendant,
Hammond Construction Company;
10
John Rea, Esq.
11 Meyers, Hentemann, Schneider & Rea
2121 The Superior Building
12 Cleveland, Ohio 44114
(216) 241-3435,
13
On behalf of the Defendant,
14 Salvaggi's.

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2 0

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3
1 ROD W. DURGIN, Ph.D., of lawful age,
2 called by the Defendants for the purpose of
3 cross-examination, as provided by the Rules of
4 Civil Procedure, being by me first duly sworn,
5 as hereinafter certified, deposed and said as
6 follows:
7 CROSS-EXAMINATION OF ROD W. DURGIN, Ph.D.
8 BY MR. CABRAL:
9 Q. Mr. Durgin, can you state your name for the
10 record, please?
11 A. Yes, it's Dr. Rod W. Durgin.
12 Q. Doctor, have you been deposed before?
13 A. Yes, I have.
14 Q. on about how many occasions?
15 A. I have no idea.
16 Q. More than 10?
17 A. More than 10.
18 Q. Well, I imagine you have a pretty good idea how
19 this works. If you don't understand my
20 question, please ask me to restate or repeat
21 it. Sometimes I tend to speak rapidly, if you
22 don't hear me, ask me to repeat it. Otherwise,
23 I will assume you understood the question, and
24 also you have to speak verbally for the court
25 reporterrs sake.
4
1 A. All right.
2 Q. Doctor, I understand you are employed by
3 Vocational Assessments, Inc.?
4 A. That's correct.
5 Q. You are the president of that company?
6 A. Yes, I am.
7 Q. Are you also a principal?
8 A. Yes, I am.
9 Q. Doctor, I would like to go into your education a
10 little bit. Where did you graduate from,
11 undergraduate school?
12 A. Where or when?
13 Q. Where?
14 A. I have a Bachelor's degree from the University
15 of Maine.
16 Q. And when did you obtain that?
1 7 A. 1 9 6 5 .
18 Q. Did you obtain a Master's degree at some point?
19 A. Yes, I have a Master's degree from Western
20 Michigan University in Kalamazoo, Michigan which
21 I obtained in 1970, and then I have a doctorate
22 from the Ohio State University in Columbus, Ohio
23 which I obtained in 1974, and I had post
24 doctorate studies at Purdue University in West
25 Lafayette, Indiana, both in 1990 and 1991 in the
5
1 area of assessment of earnings and health care
2 costs in terms of present day value.
3 Q. In what field was your Bachelor's degree?
4 A. Premed.
5 Q. And your Master's?
6 A. Counseling with a specialty in vocational
7 counseling, and that's the same with the
8 doctorate.
9 Q. Going briefly through your employment history,
10 how long have you worked in the field of
11 vocational assessment?
12 A. Well, I have been in the vocational assessment
13 counseling field for over 20 years, since
14 basically my Master's, whenever that was.
15 Q. Since you obtained your Master's in 1970?
1 6 A. Right.
17 Q. What was the first job you held in this area?
18 A. I was Director of People Personal Services for
19 the Lorain County Joint Vocational School.
20 Actually I built it, five of us started it and
21 put that up in Lorain County. It's the largest
22 of its kind in the state.
23 Q. Are you still involved with that school?
2 4 A. No.
25 Q. How long were you there for?
6
1 A. A little over a year.
2 Q. What were your duties there?
3 A. Director of People Personnel, basically the
4 students, people working with, at that time I
5 think it was 18 or 16 school districts with
6 their kids in terms of helping them make career
7 and vocational choices.
8 Q. At that point did you deal with individuals who
9 had been injured or suffered handicaps?
10 A. Yes, I worked with them in terms of enrolling
11 them in programs at the school if they were
12 interested and things of that nature.
13 Q. Were these people in the school system?
14 A. Yes, they were students.
15 Q. Like high scho