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,  M.D.,           ) Judge Gaul
       10                                  )
                                           )
       11                     Defendant.   )

       12                           - -  -

       13           DEPOSITION OF RICHARD S. ADER, M.D.

       14                 Friday, April lst, 1994

       15                           - -  -

       16        Deposition of Richard S. Ader, M.D., 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 p.m., the day and

       24 date above forth.

       25                           - -  -

                                                               2




            APPEARANCES:
      2
            On  behalf of the Plaintiffs:
      3
                Richard J. Berris, Esq.
      4         Weisman, Goldberg & Weisman Co., L.P.A.
                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

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                                                              3


       2                  RICHARD S. ADER, M.D.
       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