l@ist@ I 1
                                                                  C) CA

              1State of Ohio,     )   SS:                  AUG 24 199b
              2County of Cuyahoga. )                      KELLER & CURTIN
                                                            CC), L.P. A.
              3                         - - -
              4             IN THE COURT OF COMMON PLEAS
              5                          - - -
              6Laura Miller,
              7               Plaintiff,          Case No. 255950
              8    VS.                            Judge McMonagle
              9Timothy  O'Neill,
              10              Defendant.
              11
              12          THE DEPOSITION OF MELVIN SHAFRON, M.D.
              13              WEDNESDAY, DECEMBER 14, 1994
              14                         - - -
              15    The deposition of MELVIN SHAFRON, M.D., a witness,
              16 called for examination by the Defendant, under the Ohio
              17 RUles of Civil Procedure, taken before me, Michelle R.
              18 Hordinski, Registered ProfeBSional Reporter and Notary
              19 Public in and for the State of Ohio, pursuant to
              20 agreement, at the offices of Melvin Shafron, M.D., 26900
              21 Cedar Road, Beachwood, Ohio, commencing at 5:00 p.m., the
              22 day and date above set forth.
              23
              24                          - - -
              25

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              1APPEARANCES:

              2

              3on behalf of the Plaintiff:

              4HENRY CHAMBERLAIN, ESQ.
              Weisman, Golberg & Weisman
              51600 Midland Building
              Cleveland, Ohio  44113
              6

              7
              on behalf of the Defendant:

              8
              WALTER KROHNGOLD, ESQ.
              9Keller & Curtin
              330  Hanna Building
              10 Cleveland, Ohio  44115

              11

              12

              13

              14 ALSO PRESENT:  Thomas Sheehan, Esq.
                             Scott Morrison, Videographer

              15

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                                                                    3



             1                  MELVIN SHAFRON, M.D.
             2           called for examination by the Defendant, under
             3           having been first duly sworn, as hereinafter
             4                ed and said as follows:
             5                       PROCEEDINGS
             6              MR.',,,KROHNGOLD:                       let
             7              the record reflect that this iE
             8              deposition    Dr. Melvin Sha    n which Is
             9              being taken pursuant to notyce and that it
             10             is my understanding, Mr. 9@amberlain, that
             11             the statutory and pioceoural formalities of
             12             notice, service, and     filing  of  this
             13             deposition will be @@ivedx is that correct?
             14             MR. CHAMBERLAIN:                That's
             15             correct.
             16             MR. KROHNGOLD@                  Thlis
             17             deposition is being taken upon  direct
             18             examination in order to preserve the
             19             doctor'  testimony for use at the tim@@\of
             20             the tris@ of this action brought  by  LauI

                                                                    r
             21             m       gainst my client,  Timothy  O'Nei 11.
             22             T        on has case number 255950 before the
             23             H        e Judge Tim McMonagle in the
             24                       County Court of  Common  Pleas.
             25                   DIRECT EXAMINATION
                                                                  4



             1  BY MR. KROHNGOLD:
             2  Q.   Doctor, would you please state your full name?
             3  A.   Melvin Shafron.
             4  Q.   What is your current professional address?
             5  A.   26900 Cedar Road, Beachwood, Ohio.
             6  Q.   Are we at that address today?
             7  A.   Yes.
             8  Q.   Doctor, what is your profession?
             9  A.   I'm a neurosurgeon, or a neurological surgeon.
             10 Q.   When were you first licensed to practice in the
             11      State of Ohio?
             12 A.   1957.
             13 Q.   Are you currently licensed