1  THE STATE OF  OHIO,  )
                               )  SS:
       2  COUNTY  OF  CUYAHOGA)

       3                            - -  -

       4                IN THE COURT OF COMMON PLEAS

       5                            - -  -

       6  RUDOLPH SLEZAK, et al,          )
                                           )
       7                                   )
                               Plaintiffs, )
       8                                   )
                       VS                 ) Case No 233611
       9                                   )
          MICHAEL  KALUS,  MD,           ) Judge Gaul
       10                                  )
                                           )
       11                     Defendant   )

       12                           - -  -

       13           DEPOSITION OF RICHARD S ADER, MD

       14                 Friday, April lst, 1994

       15                           - -  -

       16        Deposition of Richard S Ader, MD, a witness

       17 herein, called for examination by the Plaintiffs,

       18 under the Ohio Rules of Civil Procedure, taken

       19 before me, Jill A Krawetz, a Court Reporter and

       20 Notary Public within and for the State of Ohio,

       21 pursuant to notice, at Southwest Cardiology

       22 Associates, Inc, 18660 Bagley Road, Middleburg

       23 Heights, Ohio, cominencing at 3:00 pm, the day and

       24 date above forth

       25                           - -  -

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            APPEARANCES:
      2
            On  behalf of the Plaintiffs:
      3
                Richard J Berris, Esq
      4         Weisman, Goldberg & Weisman Co, LPA
                1600 Midland Building
      5         Cleveland, Ohio  44115

      6
            on  behalf of the Defendant:
      7
                Steven Hupp, Esq
      8         Jacobson, Maynard, Tuschman & Kalur
                1001 Lakeside Avenue, Suite 1600
      9         Cleveland, Ohio  44114

      10

      11

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      13

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      2 0

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      2 2

      2 3

      24

      2 5

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       2                  RICHARD S ADER, MD
       3  a witness herein, called for examination by the
       4  Plaintiffs, being first duly sworn, as hereinafter
       5  certified, was examined and testified as follows:
       6                    CROSS-EXAMINATION
       7        BY MR  BERRIS:
       8  Q    State your full name, please?
       9  A    Richard Steven Ader
       10 Q    And you're a physician, correct?
       11 A    Yes
       12 Q    Cardiology is your specialty area?
       13 A    Yes
       14                 MR BERRIS:  Steve, you indicated
       15            you'll send me a copy of the doctor's CV?
       16                 MR HUPP:  Yes, we'll fax it Monday,
       17            or deliver it for sure
       18 Q    Where did you attend medical school?
       19 A    Case Western Reserve
       20 Q    Graduated when?
       21 A    1975
       22 Q    And you went on and did a residency after that?
       23 A    Yes
       24 Q    Where?
       25 A    University Hospitals of Cleveland
                                                               4

       1  Q    And completed your residency when?
       2  A    1978
       3  Q    Cardiology residency or internal medicine?
       4  A    Internal medicine
       5  Q    And after the completion of your residency, what
       6        did you do?
       7  A    Cardiology fellowship
       8  Q    Where?
       9  A    University of California, San Francisco
       10 Q    And completed that?
       11 A    1980
       12 Q    That was a three-year --
       13 A    Two
       14 Q    Two years, 178 to 180?
       15 A    Yes
       16 Q    What did you do then?
       17 A    Started private practice
       18 Q    Here, in Cleveland?
       19 A    Yes
       20 Q    And with what group?
       21 A    Solo
       22 Q    Solo?
       23 A    Yes
       24 Q    How long did you remain solo?
       25 A    Nine years
                                                              5

       1  Q    where did you practice?
       2  A    St Vincent's Charity Hospital, Parma Community,
       3        Southwest General, and Deaconess
       4  Q    And you joined a group in 189?
       5  A    No, I took on partners
       6  Q-    Took on partners?
       7  A    (Nodding head)
       8  Q    You're the founding member of Southwest
       9        Cardiology Associates, Inc?
       10 A    Yes
       11 Q    What