1(98 787



I THE STATE OF OHIO,
Ss:
2 COUNTY OF SUMMIT.

3

4 IN THE COURT OF COMMON PLEAS

5
Marie Wilkof, et al.,
6
Plaintiffs,)
7
Vs Case No. 91CV072638
8
Plastic & Reconstructive Judge Frank J. Bayer
9 Surgeons, Inc., et al.,

10 Defendants.)

11

12 DEPOSITION OF JOHN H. ROBINSON, M.D.

13 MONDAY, FEBRUARY 22, 1993

14 - - -

15 Deposition of John H. Robinson, M.D., a

16 witness called for examination by the Plaintiffs

17 under the Ohio Rules of Civil Procedure, taken

18 before me, Colleen A. Fox, a Registered Professional

19 Reporter and Notary Public within and for the

20 State of Ohio, pursuant to notice at the offices

21 of John H. Robinson, M.D., 2000 Regency Court,

22 Suite 204, Toledo, Ohio, commencing at 6:00 p.m.,

23 the day and date above set forth.

24 - - -

2 5





Morse, Gantverv & Hodge

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APPEARANCES:
2
On behalf of the Plaintiff:
3 Jed Weisman, Esq.
Weisman, Goldberg, Weisman
4 1600 Midland Building
Cleveland, Ohio 44115
5

6
On behalf of the Defendant:
7 Matthew P. Moriarty, Esq.
Jacobson, Maynard, Tuschman & Kalur
8 1001 Lakeside Avenue, Suite 1600
Cleveland, Ohio 44114
9

10

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12

13

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15

16

17

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21

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Morse, Gantverg & Hodge

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1 John B. Robinson, M.D.,
2 of lawful age, a Witness herein,
3 being first duly sworn,
4 as hereinafter certified, was examined
5 and testified as follows:
6
7 CROSS-EXAMINATION
8 BY MR. WEISMAN:
9 Q. Doctor, just for the record, state your full
10 name, please.
11 A. John Hollis Robinson, middle name,
12 H-0-1-1-i-s.
13 Q. Doctor, as you know, I represent Marie
14 Wilkof in this matter involving Dr. Lehman.
15 A. Yes.
16 Q. And I'm going to be asking you a few
17 questions here this afternoon or evening
18 relative to your review of this matter and
19 your opinions in the matter?
20 A. Yes, sir.
21 Q. If any of my questions I ask are not clear
22 in anyway or you don't understand them,
23 would you ask me to repeat or rephrase them?
24 A. Absolutely.
25 MR. WEISMAN: Okay. I think



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1 the record can show that this is the
2 discovery deposition of Dr.
3 Robinson being taken by agreement of
4 counsel as to the time and place,
5 and waiver as to the formalities of
6 notice, I presume, are waived?
7 MR. MORIARTY: True.
8 Q. okay. Doctor, the address of your
9 professional place is?
10 A. 2000 Regency Court, Suite 204, Toledo, Ohio,
11 4 3 6 2 3 .
12 Q. And how long have you had your office at
13 this location, Doctor?
14 A. Six years.
15 Q. And your residence address?
16 A. 3819 Brookside Road, Toledo, Ohio 43606.
17 Q. And you reside at the Brookside residence
18 with whom?
19 A. My wife.
20 Q. Do you have any children?
21 A. Four, my youngest child resides with us as
22 well.
23 Q. And the other children, I presume, are adult
24 age and out of the home?
25 A. Paying college tuition, I owe a good part to



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1 a few universities around here.
2 Q. University of Michigan included?
3 A. Indiana, Iowa and Kentucky.
4 Q. Do you have a curriculum vitae, Doctor?
5 A. I have one. I don't have it immediately
6 available. I could send it to you, if you
7 wish.
8 Q. If you would, I would appreciate that, then
9 1 won't go through all of that, though, I do
10 want to ask you a few questions about your
11 educational background?
12 A. Sure.
13 Q. Where did you take undergraduate?
14 A. Bethany College at Bethany West Virginia.
15 Q. You graduated undergraduate school when?
16 A. 1 9 6 4 .
17 Q. From there you went onto medical school?
18 A. Jefferson Medical College in Philadelphia.
19 It's now Thomas Jefferson University, they
20 changed names, graduated in 1968.
21 Q. And that would have been with an M.D.?
22 A. Yes, sir.
23 Q. Following medical school, you went on and
24 got some further training?
25 A. I did my general surgery and residency,




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1 internship residency, at St. Louis
2 University Hospital from 1968 to 1972. I
3 then did my plastic reconstructive surgery
4 residency at the Ohio Medical College of
5 Toledo from 1972 to 1974.
6 Q. And have you had any time in the military
7 service?
8 A. No, sir.
9 Q- Okay. From 1974 to the present, have you
10 been out in the private practice?
11 A. Yes, sir.
12 Q. Has that been devoted to the practice of
13 plastic and reconstructive surgery?
14 A. Yes, sir.
15 Q. Now, I note you're in practice by yourself
16 at this time?
17 A. Yes, sir.
18 Q. Previously, had you been in practice with
19 others?
20 A. Yes, sir.  I was initially following my
21 colleagues of residency. I joined the group
22 with whom I trained, titled Northwest Ohio
23 Plastic Surgeons Incorporated, and practiced
24 with that group until 1986, at which time 1
25 went out on my own.




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1 Q- okay. Doctor, just prior to the start of
2 deposition, counsel provided me with copies
3 of various materials that you reviewed both
4 in preparation for this deposi