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         1               IN THE COURT OF COMMON PLEAS
         2                 OF CUYAHOGA COUNTY, OHIO
         3    RUDOLPH SLEZAK, et  al.,:
         4           Plaintiffs       :
         5          VS.               : Case No. 233611
         6    MICHAEL KALUS, M.D.     :
         7           Defendant        :
         8                    - - - - -
         9        DEPOSITION OF JOHN P. CONOMY, M.D., J.D.
        10                THURSDAY, APRIL 7, 1994
        11
        12           The deposition of JOHN P. CONOMY, M.D.,
        13    J.D., the Witness herein, called by counsel on
        14    behalf of the Defendant for examination under the
        15    statute, taken before me, Vivian L. Gordon, a
        16    Registered Professional Reporter and Notary Public
        17    in and for the State of Ohio, pursuant to
        18    agreement of counsel, at the offices of Weisman,
        19    Goldberg & Weisman, 1600 Midland Building,
        20    Cleveland, Ohio, commencing at 9:30 o'clock a.m.
        21    on the day and date above set forth.
        22                     - - - - -
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                             Vivian Gordon, RPR-CM
                            MORSE, GANTVERG & HODGE

                                                                2

         1   APPEARANCES:
         2       on behalf of the Plaintiff
         3              Weisman, Goldberg & Weisman, by
         4              RICHARD J. BERRIS, ESQ.
         5              1600 Midland Building
         6              Cleveland, Ohio  44115
         7              781-1111
         8       on behalf of the Defendant
         9              Jacobson, Maynard, Tuschman & Kalur, by
        10              STEVEN J. HUPP, ESQ.
        11              1001 Lakeside Avenue Suite 1600
        12              Cleveland, Ohio  44115
        13              736-8600
        14                     - - - - -
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                             Vivian Gordon, RPR-CM
                            MORSE, GANTVERG & HODGE

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          1           JOHN P. CONOMY, M.D., J.D., a witness
          2    herein, called for examination, as provided by the
          3    Ohio Rules of Civil Procedure, being by me first
          4    duly sworn, as  hereinafter  certified,  was  deposed
          5    and said as follows:
          6        EXAMINATION OF JOHN P. CONOMY, M.D., J.D.
          7    BY-MR.  HUPP:
          8    Q.     Good morning.  Could  you  please  state  your
          9    name for the record.
        10     A.     My name is John Conomy.
        11     Q.     Doctor, my name is Steve Hupp and I
        12     represent Dr. Kalus in this case.
        13            I will be asking you  a  series  of  questions
        14     today.  If you don't understand any of my
        15     questions at any point in time, just please tell
        16     me and I'll attempt to rephrase the question.
        17            Can we agree to that?
        18     A.     Yes.
        19     Q.     Do you have a copy of your CV today?
        20     A.     I  don't.
        21                    MR. BERRIS:  I don't know if I
        22            have one.  I will get you one.
        23                    MR. HUPP:  No problem.
        24     Q.     Have you done any training in cardiology?
        25     A.     During the course of medical house

                               Vivian Gordon, RPR-CM
                              MORSE, GANTVERG & HODGE

                                                                 4

          1   officership, yes, but I am not a specialist, nor
          2   do I hold myself out to be one in that field.
          3                     - - - - -
          4           (Thereupon, CONOMY Deposition
          5           Exhibits 1 and 2 were markld for
          6           purposes of identification.)
          7                     - - - - -
          8   Q.      We have marked Exhibits 1 and 2 already.
          9   Could you please tell me what Exhibits 1 and 2
        10    are?
        11    A.      Exhibit 2 is the report of an independent
        12    neurologic examination that I performed on Mr.
        13    Rudolph Slezak on the 15th of December, 1993.
        14    Q.      What is Exhibit 1?
        15    A.      Exhibit Number I is a summary of that
        16    report  and medical records, which I received from
        17    Mr. Berris.
        18    Q.      Have you written any other reports in this
        19    case?
        20    A.      No, I have not.
        21    Q.