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


            4                IN THE COURT OF COMMON PLEAS

            s                             - -  -

            6  Sharon A. Walden, et al.,          )
                                                  )
            7                     Plaintiffs,     )
                                                  )  Case No. 277480
            8          VS.                        )
                                                  )  Judge Gaughan
            9  Family  Dental Centers, et al.,    )
                                                  )
          10                      Defendants.     )

          12            DEPOSITION OF PETER BAMBAKIDIS, M.D.
          13                   TUESDAY, AUGUST 13, 1996
          14                              - -  -
          is   The deposition of Peter Bambakidis, M.D., a witness
          16   herein, called by the Plaintiffs for examination
          17   under the Ohio Rules of Civil Procedure, taken
          18   before me, Ivy J. Gantverg, Registered Professional
          19   Reporter and Notary Public in and for the State of
          20   Ohio, by agreement of counsel and without further
          21   notice or other legal formalities, at 18099 Lorain
          22   Avenue, Cleveland, Ohio, commencing at 5:00 p.m., on
          23   the day and date above set forth.
          24
          25
          1   APPEARANCES:

          2   On behalf of the Plaintiffs:

          3          Fred Weisman, Esq.
                     Weisman, Goldberg & Weisman
          4          1600 Midland Building
                     Cleveland, Ohio   44115
          5
              On behalf of Defendants Mark Florman, D.D.S.
          6      and Michael Florman, D.D.S.:

          7          Richard J. Rymond, Esq.
                     Reminger & Reminger
          8          113 St. Clair Building
                     Cleveland, Ohio  44114
          9
              On behalf of Defendant Family Dental Centers:
         10
                     (No Appearance)
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           1                   PETER BAMBAKIDIS, M.D.
           2   a witness, called by the plaintiffs for examination
           3   under the Rules, having been first duly sworn, as
           4   hereinafter certified, was deposed and said as
           5   follows:
           6                      CROSS EXAMINATION
           7   BY MR.  WEISMAN:
           8   Q.      State your name, sir?
           9   A.      Peter Bambakidis, B-A-M-B-A-K-I-D-I-S.
         10    Q.      And what is your address, please?
         11    A.      18099 Lorain Avenue, Suite 225, Cleveland,
         12    Ohio.
         13    Q.      And your profession?
         14    A.      I am a physician, more specifically a
         15    neurologist.
         16    Q.      Doctor, I am going to ask you questions about
         17    particularly your examination of Sharon Walden.
         18            I take it, or I will just ask you, have you
         19    been deposed previously?
         20    A.      Yes, I have.
         21    Q.      And on how many occasions, would you say?
         22    A.      I would estimate on perhaps ten to twelve
         23    occasions.
         24    Q.      And under those circumstances, were you
         25    examining on behalf of the plaintiff, the one who
          1   was injured, or the defendant, or both?
          2   A.     To my recollection, on one occasion I gave a
          3   deposition consequent to an independent medical
          4   examination for the defense in the case of an
          s   accident, not in the case of medical malpractice.
          6          on another occasion, I also did a deposition
          7   with regard to -- in this case a patient of mine had
          8   filed a medical malpractice suit against another
          9   physician, and I testified as a treating physician --
         10   Q.     Okay.
         11   A.     -- at the request of the plaintiff, the
         12   patient.
         13          And on one other occasion, I have testified
         14   as a treating physician for a patient with regard to
         15   an accident, not medical malpractice.
         16          And in one other one, one recent one, this
         17   was in a role of an expert witness in a medical
         18   malpractice case testifying for the defense, but I
         19   did not examine that patient, rather reviewed the
         20   case.
         21   Q.     Well, in any event, essentially you
         22   understand the procedure, and that is that questions
         23   are put to you