(07

                                                          t@04-(C)
                        State of Ohio,
                                           ) SS:
               2        County of Cuyahoga.)

               3                             - -  -

               4                 IN THE COURT OF COMMON PLEAS

               5                             - -  -

               6        THE ESTATE OF             )
                        DONALD SCHOCK,            )
               7                                  )
                                 Plaintiff,       )
               8                                  )
                           vs.                    )Case No. 203,296
               9                                  )
                        DILIP NARICHANLA, M.D.,   )
               10                                 )
                                 Defendant.       )
               11

               12
                             DEPOSITION OF JAMES M. LIEBERMAN, M.D.
                                                          1 9 9 2
               13                  Thursday, August 27,

               14                            - -  -

               15            The deposition of JAMES M. LIEBERMAN, M.D.,

               16       a witness, called for examination by the

               17       Plaintiff under the Ohio Rules of Civil

               is       Procedure, taken before me, Diane M. Stevenson, a

               19       Registered Professional Reporter and Notary

               20       Public in and for the state of Ohio, by agreement

               21       of counsel, at the offices of Reminger & Reminger

               22       Co., LPA, The 113 Building, Cleveland, Ohio,

               23       commencing at 6:05 p.m., the day and date above

               24       set forth.

               25                             - - -

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

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              1      APPEARANCES:

              2            On behalf of the Plaintiff:

              3                R. Eric Kennedy, Esq.
                               Weisman, Goldberg & Weisman Co., LPA
              4                1600 midland Building
                               Cleveland, Ohio  44115
              5

              6            On behalf of the Defendant Dr. Narichania:

              7                Robert D. Warner, Esq.
                               Reminger & Reminger Co., LPA
              8                The 113 Building
                               Cleveland, Ohio  44114
              9

              10           On behalf of the Defendants, Dr. Williams,
                            Dr. Bernard, Dr. David, and Reich,
              11             Seidelman & Janicki:

              12               William Bonezzi, Esq.
                               Jacobson, Maynard, Tuschman & Kalur
              13               1001 Lakeside Avenue, Suite 1600
                               Cleveland, Ohio  44114
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                               Diane M. Stevenson, RPR, CM
                                 Morse, Gantverg & Hodge

                                                                     3

              1                  MR. WARNER:        The deposition of

              2        Dr. Lieberman was scheduled on the request of

              3        Mr. Kennedy to depose my expert.

              4            Mr. Bonezzi still has not provided me a

              5        radiological report of his expert.  Apparently,

              6        he indicates that he will at sometime.

              7             At the deposition of Dr. Rollins, my first

              8        expert, I had requested that all of his reports

              9        be provided.  At that time, I waived him

              10       providing the report of his radiologist when he

              11       indicated that he would provide it before

              12       Dr. Lieberman's deposition.

              13            The local rules, in my opinion, require him

              14       to provide  the report before this deposition goes

              15       forward.  I  am willing to do what the other

              16       counsel  wants, but I am going to indicate that I

              17       will object  to his introduction of a radiolo-

              18       gist's  report, and/or another report of another

              19       expert,  unless it is produced before this

              20       deposition goes f