IN THE COURT OF COMMON PLEAS

2 CUYAHOGA COUNTY, OHIO

3

4 THEODORE J. TALLIERE

5 and

6 KATHLEEN TALLIERE

7 and

8 KATHLEEN TALLIERE, as

9 Mother and next friend

10 of LUIGI TALLIERE

11 and

12 JOI GRAY CASE NO. 341951

13 Plaintiffs

14  v

15 PIERRE'S FRENCH ICE

16 CREAM COMPANY

17 Defendants

18

19

20 Deposition of Thomas Romano, M.D.,

21 Ph.D., FACP, FACR

22 Monday, February 8, 1999

23

24

Wheeling, WV V92

81*8
Pittsburgh, PA
Morgantown. WV 1-800-659-2249
Martins Ferry, OH FAX 304-232-9375

2

2 Deposition of Thomas Romano, M.D.,
3 Ph.D., FACP, FACR
4 Monday, February 8, 1999
5
6
7 a witness herein, taken on behalf of the defendant
8 in the above-entitled cause of action pursuant to
9 notice and the Ohio Rules of Civil Procedure by
10 and before Melania D. Streski, Registered
11 Professional Reporter and Commissioner within and
12 for the State of West Virginia at the offices of
13 Streski Reporting & Video Service, 75 12th Street,
14 Wheeling, West Virginia, commencing at 2:15 p.m.
is
16
17
is
19
2 0
21
2 2
2 3
2 4

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1 APPEARANCES:
2
3
4 On behalf of the Plaintiffs:
5 MARK T. GIBBONS, Esquire
6 Weisman, Goldberg & Weisman, Suite 1600, Midland
7 Building, 101 Prospect Avenue, NW, Cleveland,
8 Ohio 44115
9
10
11 On behalf of the Defendants:
12 D. JOHN TRAVIS, Esquire (via
13 telephone)
14 LYNN L MOORE, Esquire
15 Gallagher, Sharp, Fulton & Norman, Seventh Floor,
16 Bulkley Building, 1501 Euclid Avenue, Playhouse
17 square, Cleveland, Ohio 44115-2108
18
19
20
21
2 2
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24

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.................... I N D E X
2 WITNESS EXAMINATION BY  PAGE
3 Thomas Romano Mr. Travis 5
4
5
6
7 E X H I B I T S
8 :  Mrkd  Iden
9 Romano Deposition Exhibit No. I 15 15
10 Romano Deposition Exhibit No. 2 15 15
11 Romano Deposition Exhibit No. 3 15 15
12 Romano Deposition Exhibit No. 4 15 15
13 Romano Deposition Exhibit No. 4A 21 20
14 Romano Deposition Exhibit No. 5 15 16
15 Romano Deposition Exhibit No. 6 15 16
16 Romano Deposition Exhibit No. 7 15 16
17 Romano Deposition Exhibit No. 8 15 16
18 Romano Deposition Exhibit No. 9 15 16
19 Romano Deposition Exhibit No. 10 15 16
20 Romano Deposition Exhibit No. 11 15 17
21 Romano Deposition Exhibit No. 12 15 17
22 Romano Deposition Exhibit No. 13 15 18
23 Romano Deposition Exhibit No. 14 15 18
24

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2 THOMAS J. ROMANO, M.D.,
3 Ph.D., FACP, FACR
4 being first duly sworn, was examined and deposed
5 as follows:
6
7 E X A M I N A T I 0 N
8 BY MR. TRAVIS: 1
9 Q. Doctor, my name is John Travis and I'm
10 conducting this deposition from my office in
11 Cleveland and you are at a court reporter's office
12 in Wheeling, West Virginia; is that correct?
13 A. Yes, sir.
14 Q. And present with you are Lynn Moore on
is behalf of my client, Royal Ice Cream Company, and
16 Mark Gibbons on behalf of the plaintiffs; is that
17 correct?
18 A. Yes. That's right.
19 Q. Doctor, have you brought your file
20 with you?
21 A. Yes. I have four different files, one
22 for each patient.
23 Q. okay.
24 When you have a moment, would you

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1 please give that to Lynn Moore and she can take a
2 look at them and mark them because we'll be
3 referring to them, I'm sure, throughout the
4 deposition.
5 A. Sure.
6 THE WITNESS: If you have no
7 objection.
8 MR. GIBBONS: No, not at all.
9 That's fine.
10 THE WITNESS: These are my
11 patient files and these are the medical records
12 (indicating) that I got in September.
13 MS. MOORE: And you also have
14 some articles.
15 THE WITNESS: Yeah, these are
16 some articles that I Xeroxed.  You can look at
17 them if you want. You're welcome to see them.
18 I'll just put them all in the pile.
19 Q. (By Mr. Travis) Doctor, will you
20 please state your full name for the record?
21 A. My name is Doctor Thomas James Romano.
22 Q. What is your home address, please?
23 A. 30-- that's 3 0-- 30 Greenwood Avenue,
24 here in Wheeling.

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1 Q. How long have you lived at that
2 address?
3 A. 16 and a half years.
4 Q. With whom do you live at that address?
5 A. I live with my wife, Irene, and my two
6 sons, Nicholas and Andrew. My daughter is in
7 college.
8 Q. How old are your'three children,
9 please?
10 A. My daughter, Victoria, is 19. My son,
11 Nicholas, is 18 and my son Andrew will be 17 in
12 two months.
13 Q. What is your date of birth?
14 A. November 26, 1949.
is Q. Place of birth?
16 A. New York City. Manhattan.
17 Q. How long did you remain in New York?
18 A. 30 years.
19 Q. You attended high school in New York,
20 then?
21 A. In the Bronx.
22 Q. What year did you graduate?
23 A. 1968.
24 Q. Which school?

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I A. St. Helena High School in the Bronx.
2 They changed the name of the hi