State of Ohio,
) SS:
2 County of Cuyahoga.)

3

4 IN THE COURT OF COMMON PLEA S

5 - - -

6 MARY DUCKWORTH, etc.,
et al.,
7
Plaintiffs,
8
 vs. Case No. 226,873
9
LUTHERAN MEDICAL CENTER,)
10 et al., Judge Patricia Cleary

11 Defendants.

12 - - -

13 DEPOSITION OF JEFFREY R. CRASS, M.D.
Monday, February 15, 1993
14

15

16 The deposition of JEFFREY R. CRASS, M.D., a

17 witness, called for examination by the Plaintiffs

18 under the Ohio Rules of Civil Procedure, taken

19 before me, Diane M. Stevenson, a Registered

20 Professional Reporter and Notary Public in and

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

22 at the offices of Arter & Hadden, 1100 Huntington

23 Building, Cleveland, Ohio, commencing at 9:15

24 a.m., the day and date above set forth.

25 - - -

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

2

1 APPEARANCES.,

2 On behalf of the Plaintiffs:

3 Richard Berris, Esq.
Weisman, Goldberg & Weisman Co., LPA
4 1600 Midland Building
Cleveland, Ohio 44115
5

6 On behalf of the Defendant
Lutheran Medical Center:
7
Thomas H. Allison, Esq.
8 Arter & Hadden
1100 Huntington Building
9 Cleveland, Ohio 44115

10
On behalf of the Defendants Dr. Pelini
11 and Acute Care Specialists, Inc.:

12 Thomas Terry, Esq.
Jaobson, Maynard, Tuschman & Kalur
13 1001 Lakeside Avenue, Suite 1600
Cleveland, Ohio 44114
14

15 On behalf of the Defendants Dr. Oza
and Dr. Kapoor:
16
Beth Sebaugh, Esq.
17 Quandt, Giffels & Buck
800 Leader Building
18 Cleveland, Ohio 44114

1 9
On behalf of the Defendants Dr. Lontoc
2 0 and Medical Center Radiologists:

21 Donald Moracz, Esq.
Reminger & Reminger Co., LPA
22 The 113 Building
Cleveland, Ohio 44114
23

24

25

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

3

1 JEFFREY R. CRASS, M.D.

2 A witness, called for examination by the

3 Plaintiffs, 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.  BERRIS:

8 Q. State your full name, please.

9 A. Jeffrey Robert Crass.

10 Q. You are a physician, correct?

11 A. That is correct.

12 MR. BERRIS: Have I been provided

13 a copy of the doctor's CV?

14 MR. ALLISON: No, you haven't. if

15 you would like one, I would be happy to provide

16 one to you.

17 Q. Just for the record, if you will outline your

18 medical training and post-graduate education.

19 A. Sure. I went to medical school at Temple

20 University in Philidelphia, did internship in

21 general surgery at University of Minnesota, and

22 residency, followed by fellowship, in that same

23 institution.

24 Post-residency employment started at the

25 University of Chicago, where I was on the staff

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

4

1 for a little over a year, came back to the

2 University of Minnesota, where I was chief of the

3 chest section from then, which was, I guess, '83

4 through to 187.

5 Q. Let me stop you there. When you say chief of the

6 head section-

7 A . Chest .

8 Q. You did say chest. What do you mean by chief of

9 the chest section?

10 A. I was the primary radiologist responsible for

11 teaching chest radiology, organizing the

12 procedures and policies regarding chest

13 radiography at the University of Minnesota, read

1 4 most of the chest f ilms or the highest percentage

15 of chest films there. I am not sure where to go

16 beyond that.

17 Q. You don't get involved in oncology, specifically,

18 radiation oncology?

19 A. No, not therapy.

20 Q. Go ahead with your background now.

21 A. Okay. Following Minnesota, after chairmanship

22 changed, I went to the State University of New

23 York at Stony Brook, and came to Cleveland

24 MetroHealth Medical Center in 1988 where I am

25 Chief of Body Imaging, head of the residency

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

5

1 program, and Associate Professor of Radiology and

2 Reproductive Biology at Case Western Reserve

3 University.

4 Q. When were you first contacted about this case?

5 A. November, I think, of this past year.

6 Q. Who contacted you?

7 A. Mr. Allison.

8 Q. Have you had dealings with Mr. Allison in the

9 past?

10 A. He had shown me films from, I think, one previous

11 case.

12 Q. Have you had dealings with Mr. Treu in the past?

13 A. No.

14 Q. Have you ever met Mr. Treu?

is A. Not to my knowledge.

16 MR. ALLISON: This morning.

17 Chris.

18 THE WITNESS: oh, okay, this

19 morning.

20 Q. With Mr. Treu this morning I take it you reviewed

21 the case, discussed this case, before the

22 deposition?

23 A. Yes.

24 Q. With Mr. Treu and Mr. Allison?

25 A. That is correct.

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

1 Q. Was anybody else present?

2 A. No.

3 Q. Have you ever discussed this case with anybody

4 other than--any lawyer other than Mr. Allison or

5 Mr. Treu?

6 A. No.

7 Q. Have you ever discussed the case with anybody

8 other