1   STATE OF 0 H I 0
           2                         SS:
           3   COUNTY OF CUYAHOGA
           4
           5
           6   KATHERINE G. KELL, et al.,         )
           7                 Plaintiff ,          )
           8       VS.                            ) No. 249409
           9   REICH, SEIDELMANN Sc JANICKI CO.,
         10    et al.,
         11                  Defendants.
         12
         13
         14
         15             The deposition of RICHARD M. GORE, M.D.,
         16    taken in the above-entitled cause, before GAIL H.
         17    JACOBS, a Notary public within and for the County
         18    of Cook, State of Illinois, and a Certified
         19    Shorthand Reporter of said state, at Evanston
         20    Hospital, 2650 Ridge Avenue, Evanston, Illinois, on
         21    the 21st day of December, A.D. 1994, at 10:30 A.M.
         2 2
         2 3
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                            rwoffe, croientsig and @.tio@tzi, -qna.
                                                                   2

           1   PRESENT%
           2        WEISMAN, GOLDBERG & WEISMAN,
           3        (1600 Midland Building,
           4        Landmark Office Tower,
           5        Cleveland, Ohio 44115), by:
           6        MR. RICHARD J. BERRIS,
           7            appeared on behalf of the Plaintiff;
           8        JACOBSON, MAYNARD, TUSCHMAN & KALUR,
           9        (1001 Lakeside Avenue,
         10         Cleveland, Ohio 44114-1192), by:
         11         MR. DALE L. KWARCIANY,
         12             appeared on behalf of
         13             D.efendants Alan Easton, M.D., and
         14             Reich, Seidelmann & Janicki Co.
         15
         16
         17
         18
         19
         2 0
         21    REPORTED BY:  GAIL H. JACOBS, C.S.R. No. 84-2814
         2 2
         2 3
         2 4

                             qvoffe, @o!izntrv            -one.
                                                                   3

           1                  (WHEREUPON, the witness was duly
           2                  sworn.)
           3                  RICHARD M. GORE, M.D.,
           4   called as a witness herein, baving been first duly
           5   sworn, was examined and testified aB follows:
           6                       EXAMINATION
           7   BY MR.  KWARCIANY:
           8        Q.     Doctor, how old are you?
           9        A.     41.
         10         Q.     You provided me with a copy of your
         11    curriculum  vitae.  Is it reasonably accurate and up
         12    to date?
         13         A.     Yes, it is.
         14         Q-     Are there any major changes or
         15    alterations that you are aware of that would update
         16    it   further?
         17         A.     No.
         18         Q.     Do you subspecialize in the field of
         19    radiology?
         20         A.     Abdominal imaging.
         21         Q.     What does that include?
         22         A.     That includes body CT of chest, abdomen,
         23    and pelvis.  It also includes doing barium studies,
         24    magnetic resonance imaging of the chest and

                             @offe, cRo@Fig and @.uo@tzi, -Ona.
                                                                  4

           1   abdomen, and also ultrasound primarily of the
           2   abdomen.
           3        Q.     Under whom did you train?
           4        A.     I trained at Northwestern University
           5   Medical Center for my residency under Lee F.
           6   Rogers, who was the program director.  I did a
           7   fellowship in abdominal imaging at the University
           8   of California San Francisco under Alexander
           9   Margulis and Henry Goldberg.
         10         Q.     How many x-ray films do you personally
         11    read in a week?
         12         A.     In a week -- I could more easily give
         13    you a yearly statistic.
         14         Q.     Fair enough.
         15         A.     About 9,000 to 10,000 a year.
         16         Q.     Is that just you alone, or does that
         17    include your supervision over residents.>
         18         A.     That would include supervision of
         19    residents aB well.
         20         Q.     Can you give me a breakdown as to those
         21    9,000 to 10,000 filmb what percentage are plain
         22    chest  films?
         23         A.     Plain chest films I would say about a
         24    quarter, 25 percent.

                             @offr, @o@Fig and            Yna.
                                   egic -qaiwis  1

                                                                   5

           1               Is Your Practice hospital based?
           2        A.     Yes, it is.
           3        Q.     Do you have any sort of