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1 The State of Ohio,
2 County of Summit. SS:
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4 IN THE COURT OF COMMON PLEAS
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6 MARIE V. WILKOF, et al.,
7 Plaintiffs, Case No.
8 VS. CV91072638
9 PLASTIC & RECONSTRUCTIVE Judge Maureen
10 SURGEONS, INC., et al., O'Connor
11 Defendants.
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13 Videotaped deposition of
14 JOHN H. ROBINSON, M.D., a witness herein,
15 called by the Defendants as if upon direct
16 examination, and taken before Maureen
17 Povinelli, RPR-CM, a Notary Public within
18 and for the State of Ohio, pursuant to
19 agreement of counsel, and pursuant to the
20 further stipulations of counsel herein
21 contained, on Monday, the 12th day of
22 April, 1993, at 5:30 p.m., at 2000 Regency
23 Court, Suite 204, Toledo, Ohio.
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1 APPEARANCES:
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3 On behalf of the Plaintiffs:
4 Weisman, Goldberg & Weisman, by:
5 JED WEISMAN, ESQ.
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7 On behalf of the Defendants:
8 Jacobson, Maynard, Tuschman & Kalur,
9 by:
10 MATTHEW P. MORIARTY, ESQ.
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2 PROCEEDINGS
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4 MR. MORIARTY: We are here
5 preparing to take the videotaped
6 deposition of Dr. Robinson for trial
7 purposes, and before we swear the
8 witness, I just want to reiterate a
9 stipulation that Mr. Weisman and I
10 have agreed on, and that is that Dr.
11 Robinson is a Board certified plastic
12 surgeon who is qualified to testify
13 as an expert witness in this case.
14 Is that right, Mr. Weisman?
is MR. WEISMAN: That is
16 correct.
17 MR. MORIARTY: Okay. You
18 can swear Dr. Robinson in, please.
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20 JOHN E. ROBINSON, M.D., of
21 lawful age, having been first duly
22 sworn, as hereinafter certified, was
23 examined and testified as follows:
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1 DIRECT EXAMINATION
2 BY MR. MORIARTY:
3 Q Could you tell the ladies and
4 gentlemen of the jury your full name?
5 A John Hollis Robinson.
6 Q And you are a plastic surgeon, Sir?
7 A I am a plastic reconstructive surgeon,
8 yes, air.
9 Q And how old are you?
10 A 50 years old.
11 Q Could you tell the jury where you
12 graduated from medical school and what
13 year that was?
14 A I graduated from Thomas Jefferson
15 University in Philadelphia in 19 and 68.
16 Q And you did a general surgery
17 residency after medical school?
18 A Yes, Sir. I did my general surgery
19 training at St. Louis University Hospital
20 from 1968 until 1972.
21 Q And after that, you did a plastic
22 surgery residency?
23 A Yes, Sir.  My plastic surgery
24 residency was at the Medical College of
25 Ohio at Toledo from 1972 to 1974.

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I Q And have you been a plastic surgeon
2 practicing in private practice in the
3 Toledo area since 1974?
4 A That's correct.
5 Q And you are Board certified?
6 A That is correct.
7 Q And do you have some teaching
8 responsibilities at the hospitals and the
9 medical school here in Toledo?
10 A Yes, sir.  I am a clinical assistant
11 professor at the Medical College of Ohio
12 at Toledo, teaching plastic surgical
13 residents.
14 Q Now, is that classroom teaching or is
15 that teaching in the operating room and on
16 the floor seeing patients?
17 A Both.
18 Q And as part of your practice, do you
19 perform facelifts?
20 A Yes, sir.
21 Q And the blepharoplasty procedure?
22 A Yes, sir.
23 Q And the brow lift procedure?
24 A Yes, sir.
25 Q At my request, did you review the

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I medical records from this case, the
2 deposition transcripts and the photographs
3 of Marie Wilkof?
4 A Yes, I did.
5 Q And generally speaking, Doctor -- I'll
6 get into the details in a minute -- but
7 generally, based on all of that material,
8 do you have an opinion to a reasonable
9 degree of medical probability as to
10 whether Dr. Lehman and his partner, Dr.
11 Tantri complied with the acceptable
12 standards of care expected of them as
13 plastic surgeons when they were --
1 4 Nj- : j @ec t i@qo n .
@@S MA@
15 Q -- treating Mrs. Wilkof?
16 A Yes, I do have an opinion within a
17 reasonable degree of medical certainty and
18 yes, I believe the records show t