state of Ohio,
        2
           County of Cuyahoga.

        3                           - - -

        4
                           IN THE COURT OF COMMON



        6
           RICHARD GROFF, et al,
        7
                       Plaintiffs,
        8                              Case No. 81-
                VS.
        9                              Judge Mcliona
           JEAN RYAN,
        10

                       Defendant.



        12
                          DEPOSITION OF JAVIEFFLOPEZ, M.D.

        13
                           THURSDAY, OCTOBER 31, 1985

        14


        15
           The deposition of Javier Lopez, M.D., a witness called for

        16
           examination by the plaintiffs under the Ohio Rules of Civil

        17 Procedure taken before me, Diane M. Stevenson a Registered

        18
           Professional Reporter and Notary Public in and for the  State


        19
           of Ohio, pursuant to notice. at the offices of


        20 Javier Lopez, M.D., 5156 Broadway Cleveland, Ohio,


        21 coimencing at 1:30 P.M., the dav and date above set forth.


        22


        23


        24


        25

       1

                                                              2


 APPEARANCES:

       2  on behalf of the Plaintiffs:

       3     Howard  Mishkind.,Esq.
             Weisman, Goldberg, Weisman   Kaufman
       4     540 Leader Building
             Cleveland, Ohio  44114
       5
          on behalf of the Defendant:
       6                            00
             Gerald L. Jeppe,  Esq.
       7     Meyers, Hentemann, Schneider & Rea
             2121 Superior Building
       8     Cleveland, Ohio  44114

       9                             - - -
       10

       11

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       17

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                                                               3


                           MR. MISHKIND:         Let the record
       2
                   reflect that the plaintiffs are taking the
       3
                   deposition of Dr. Javier Lopez for the purposes of
       4
                   perpetuating the doctor's testimony to be used
       5
                   at trial in the case of Richard Groff, et al, versus
       6
                   Jean Ryan, and that the deposition is being taken
       7
                   pursuant to notice.
       8
                           Any defects that may exist in notice or
       9
                   service I presume are wai-ved, Mr. ieppe?
       10
                           MR. JEPPE:            That's correct.
       11

       12

       13                     JAVIER  LOPEZ,  M.D.

          a witness called for examination by the plaintiffs under

       14
          the Rules, havinq been first duly sworn, as hereinafter

       15
          certified.,was examined and testified as follows:

       16
                             DIRECT EXAMINATION

       17
          BY MR.  MISHKIND:

       18
          O.       State your name for the record.

       19 A.       bly name is  JavierLopez,  M.D.

       20 O.       Your professional address?

       21 A.       5158 Broadway.  That is in Cleveland.

       22 OL       Doctor, do you have any area that you specialize in?

       23 A.       I do speciall:ze in general surgery.

       24 0        Do you understand that your testimony is going to

       25 be read  to the ladies and gentlemen of the jury that will be

                                                                         4


           hearing this case?

       2
           A.        I do.

       3
                     Would you tell us a little bit about your medical

       4
           background, where you went to medical school?

           A.        I went to medical school in Colombia, South America.

       6             UDon graduation I came to the United States, to

       7
           Cleveland.

       8             Ifinished my five years of surgical training here.

       9   I spent a year in the VA Hospital as a surgeon in Fargo,

       10  North Dakota.

       11            Then I returned back to Cleveland where   I started

       12  practice, and I have been in practice since then.

       13            what year did you start practice in Cleveland?

       14  A.        I started practice in 1965, July.

       15            When were you first licensed to practice your

       16  orofession, Doctor?

       17  A.        I started in 1963.

       18  QL        In what states are you licensed?

       19  A.        I am licensed in Ohio and Virginia.

       20  0.