1(o878Z
1 State of Ohio,
) SS:
2 County of Cuyahoga.)

3

4 IN THE COURT OF COMMON PLEAS

5

6 THE ESTATE OF
DONALD SHOCK,
7
Plaintiff,
8
vs. Case No. 203,296
9
DILIP NARICHANIA, M.D.
10
Defendant.

12
DEPOSITION OF DAVID ROLLINS, M.D.
13 Wednesday, August 12, 1992

14 - - -

15 The deposition of DAVID ROLLINS, M.D., a

16 witness, called for examination by the Plaintiff

17 under the Ohio Rules of Civil Procedure, taken

18 before me, Diane M. Stevenson, a Registered

19 Professional Reporter and Notary Public in and

20 for the state of Ohio, by agreement of counsel,

21 at the offices of David Rollins, M.D., 26250

22 Euclid Avenue, Euclid, Ohio, commencing at 2:40

23 p.m., the day and date above set forth.

24 - - -

25

Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

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1 APPEARANCES:

2 On behalf of the Plaintiff:

3 R. Eric Kennedy, Esq.
Ben Antognoli, Esq.
4 Weisman, goldberg & Weisman Co., LPA
1600 Midland Building
5 Cleveland, Ohio 44115

6
On behalf of the Defendant Narichania, M.D.:
7
Robert Warner, Esq.
8 Reminger & Reminger Co., LPA
The 113 Building
9 Cleveland, Ohio 44114

10
On behalf of the Defendants Reich,
11 Seidelman & Janicki and Drs.  Williams,
Walter, Bernard and David:
12
Ellen H. Hirshman, Esq.
13 Jacobson, maynard, Tuschman & Kalur
1001 Lakeside Avenue - Suite 1600
14 Cleveland, Ohio 44114

15 - - -

16

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Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

3

1 DAVID ROLLINS, M.D.

2 A witness, called for examination by the

3 Plaintiff, under the Rules, having been first

4 duly sworn, as hereinafter certified, was

5 examined and testified as follows:

6 CROSS-EXAMINATION

7 BY MR. KENNEDY:

8 Q. Doctor, would you please state your full name.

9 A. David Rollins.

10 Q. And your professional address.

11 A. 26250 Euclid Avenue, in Euclid.

12 Q. Doctor, have you had your deposition taken

13 before?

1 4 A . Yes, sir.

15 Q. on how many occasions?

16 A. 8, 10, 12.

17 Q. If I ask you a question that is inarticulate for

is some reason--there may be a lot of reasons why it

19 might be--you are not sure you understand the

20 question, don't answer the question, and I will

21 attempt to rephrase it so that you do.

22 Can we agree that you will only answer the

23 questions that you certainly understand?

24 A. Yes.

25 Q. If you are not certain that you hear the

Diane M. Stevenson, RPR, CM
Morse, Gantverg & Hodge

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1 question, again, don't answer it. I will repeat

2 it s