NOON & PRATT - VENTURA  CERTIFIED ORIGINAL

                            SUPERIOR COURT OF THE STATE OF OHIO
            2                   FOR THE COUNTY OF CUYAHOGA
            3
            4
            5     KEITH JONES,
            6                  Plaintiff,
            7            VS.                          No.  9 0 9 5 2
            8     BEN ORTEGA, M.D., et al,
            9                  Defendant.
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          13             Deposition of SIDNEY W. GROSS, M.D., taken on
          14             behalf of the Defendant, Ben Ortega, M.D., at
          15             330 Alta Avenue, Santa Monica, California,
          16             90402, commencing at 9:40 A.M., Friday,
          17             September 9, 1988, before Irma Coronel, CSR No.
          18             7976, Notary Public, pursuant to Agreement.
          19
          2 0
          21                                   NOON & PRATT - VENTURA
          22                               CERTIFIED SHORTHAND REPORTERS
          23                               5720 RALSTON STREET, SUITE 305
          24                                  VENTURA, CALIFORNIA 93003
          25                                       (805) 644-6646
                                 NOON & PRATT - VENTURA                   2
            1    APPEARANCES OF COUNSEL:
            2
            3           FOR THE PLAINTLFF:
            4
            5                 WEISMAN, GOLDBERG, WEISMAN
            6                 & KAUFMAN CO., L.P.A.
            7                 BY:  FRED WEISMAN, ESQ.
            8                 540 Leader Building
            9                 Suite 540
          10                  Cleveland, Ohio 44114
          11
          12            FOR THE DEFENDANT:
          13
          14                  JACOBSON, MAYNARD, TUSCHMAN & KALUR
          15                  BY:  JEROME S. KALUR, ESQ.
          16                  100 Erieview Tower - 14th Floor
          17                  Cleveland, Ohio 44113
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                                  NOON & PRATT - VENTURA                    3
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           3                              I N D E X
           4
           5      Friday, September 9, 1988
           6
           7      WITNESS                                      EXAMINATION
           8
           9      SIDNEY W. GROSS, M.D.
          10
          11                   By Mr. Kalur                        4
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          17                              - - - - -
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                                  NOON & PRATT - VENTURA                   4
            1            MR. KALUR:  The record should reflect that this
            2    deposition is being taken for  purposes  of  discovery,
            3    and it is being taken by agreement of counsel.
            4
            5                     SIDNEY W. GROSS, M.D.,
            6      having been first duly sworn, tebtified as follows:
            7
            8                           EXAMINATION
            9    BY  MR.  KALUR:
          10             Q     Would you state your full name, sir?
          11             A     Sidney W. GROBS, G R 0 S S.
          12             Q     Dr. Gross, Mr. Weisman has informed me
          13     that your fee charge is $300 per hour.  Is that
          14     correct?
          15             A     That's correct.
          16             Q     And he's also advised me that you'd like
          17     to be paid in advance.  Is that also correct?
          18             A     No. At the time  of  the  deposition.  In
          19     other words, when you're finished.  After all, in
          20     advance we don't know how long you're  going  to  take.
          21             Q     All right.  I've already drawn a check for
          22     $300, so you can anticipate for how long  I'd  like  to
          23     stay.
          24             A     One hour.  Okay.
          25             Q     I've got a plane to catch, but I certainly
                                  NOON & PRATT - VENTURA                  5
           1     don't want you to shorten your answers.
           2             A    Shall do.
           3             Q    Would you tell us, just for purposes of
           4     the record, what your address is here?
           5             A    330 Alta Avenue, Santa Monica 90402.
           6             Q    What is your age, Dr. Gross?
           7             A    I was 84 years old on August 28th.
           8             Q    Okay.  Do you still perform  surgery  at  the
           9     standpoint of using a scalpel and cutting?