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1 THE STATE OF OHIO,
 SS:
2 COUNTY OF CUYAHOGA.)
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4 IN THE COURT OF COMMON PLEAS
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6 JACK ALBANO,
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Plaintiff,
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VS. Case No. 153043
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HAMMOND CONSTRUCTION, et al., Judge Daniel Corrigan
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11  Defendants.
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13 DEPOSITION OF LINDA ROBINSON
14 WEDNESDAY, FEBRUARY 5th, 1992
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16 Deposition of Linda Robinson, a
17 witness called for examination by the Plaintiff,
18 under the Ohio Rules of Civil Procedure, taken
19 before me, Jill A. Krawetz, a Court Reporter
20 and Notary Public within and for the State of Ohio,
21 pursuant to agreement, at Gallagher, Sharp, Fulton &
22 Norman, Seventh Floor, Bulkley Building, Cleveland,
23 Ohio, commencing at 10:30 a.m., the day and date above
24 set forth.
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APPEARANCES:
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On behalf of the Plaintiff:
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R. Eric Kennedy, Esq.
4 Weisman, Goldberg, Weisman & Kaufman
1600 Midland Building
5 Cleveland, Ohio 44115

6
On behalf of the Defendant Hammond Construction:
7
Thomas Cabral, Esq.
8 Gallagher, Sharp, Fulton & Norman
Seventh Floor, Bulkley Building
9 Cleveland, Ohio 44115

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1 LINDA ROBINSON
2 a witness, called for examination by the Plaintiff
3 herein, being first duly sworn, as hereinafter
4 certified, was examined and testified as follows:
5 CROSS-EXAMINATION
6 BY MR. KENNEDY:
7 Q. My name is Eric Kennedy, and I represent Jack
8 Albano, and I'm going to ask you a few questions
9 about your opinions and your study of Jack
10 Albano, his abilities or non-abilities to become
11 gainfully employed.
12 Have you had your deposition taken
13 before?
1 4 A . Yes .
15 Q. On how many occasions?
16 A. Quite a few. I would say more than ten.
17 Q. Were you requested by Mr. Cabral in this case to
18 do a study and assessment of Jack Albano?
19 A. Yes .
20 Q. Specifically, what were you requested to do?
21 A. Vocational assessment, transferable skills
22 assessment, to determine the feasibility of this
23 gentleman returning to some type of gainful
24 employment.
25 Q. Can you tell me what you reviewed in order to

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1 prepare your report?
2 A. The information that I reviewed consisted of Mr.
3 Durgin's vocational assessment report.
4 MR. CABRAL: That's a copy of Mr.
5 Rea's memo from his associate with respect
6 to some of the depositions.
7 Q. So you reviewed Mr. Durgin's report?
8 A. Uh-huh.
9 Q. Did you review the memorandum done by Mr. Rea's
10 associate with respect to some of the
11 depositions?
12 A. Yes, I did. Additionally, I reviewed the
13 independent medical evaluation and physician
14 report. I think this is by Dr. Wendy Wilson,
15 dated August 9th, 1991.
16 MR. CABRAL: You have various Workers'
17 Comp. records and W-2s in there.
18 Q. Workers' Comp. records?
19 A. Uh-huh.  The W-2s and tax statements.
20 MR. CABRAL: And the lowest estimate,
21 prepared by Mr. Ellerin, is in there.
22 Q. Anything else?
23 A. No, I believe that's all I have.
24 Q. Did you review anything from the time of your
25 report up to today, in addition to what you've

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1 outlined?
2 A. The Workers' Comp. letter dated April 4th, 1988.
3 Q. Whose letter is that?
4 A. This is from Robert Clunen from the Industrial
5 Commission.
6 Q. When did you receive that letter?
7 A. When did I receive it?
8 Q - Yes .
9 N. Yesterday -- no. I'm sorry. I received it
10 January 30th.
11 Q. Of 1991?
12 A. 1 9 9 2 .
13 Q. Can I see that letter?
14 A. Uh-huh.
15 Q. Anything else that you reviewed between the time
16 of your report and today?
17 A. No, that's it.
18 Q. Can you tell me what publications, or sources of
19 information, or computer programs that you
20 utilized in arriving at your opinion?
21 A. Sure. The 1987 edition of the Dictionary of
22 Occupational Titles, the 1988 third --
23 Q. Who publishes that?
24 A. The Department of Labor.
25 Q. From the United States Government?

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1 A Uh-huh.
2 Q. And what else?
3 A. The 1988 third revision of the Classification of
4 Jobs according to worker trait factors.
5 Q. Who publishes that?
6 A. That's all put out by the Department of Labor.
7 Q. What else?
8 A. The 1990 Computerized Labor Market Access
9 published by Elliot and Fitzpatrick.
10 Q. They're the publishers?
11 A. Of the computerized program, yes.
12 Q. What type of information does the computer
13 program provide you with?
14 A. It provides you with Dictionary of Occupational
15 Titles, transferable skills, labor market
16 information regarding job possibilities when you
17 are seeking transferable skills.
18 Q. Job possibilities. I'm probably going to get
19 ahead of myself, but can you ask the computer to
20 give you information about job possibilities in
21 the Cleveland area or the Northeast Ohio area?
2 2 A . Yes .
23 Q. How often is that computer updated with respect
24 to jobs available