1 State of Ohio, SS:
2 County of Cuyahoga.
3
4 IN THE COURT OF COMMON PLEAS
5 - - -
6 Rudolph Slezak, et al.,
7 Plaintiffs, Case No. 233611
8 VS. Judge Gaul
9 Michael Kalus, M.D.,
10 Defendant.
11
12 THE DEPOSITION OF THOMAS VROBEL, M.D.
13 TUESDAY, OCTOBER 26, 1993
14 - - -
15 The deposition of THOMAS VROBEL, 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 Professional Reporter and Notary
19 Public in and for the State of Ohio, pursuant to
20 agreement, at Metrohealth Medical Center, Cleveland,
21 Ohio, commencing at 1:30 p.m., the day and date above set
22 forth.
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1 APPEARANCES:

2

3 on behalf of the Plaintiffs:

4 RICHARD BERRIS, ESQ.
Weisman, Goldberg & Weisman
5 1600 Midland Buildin
Cleveland, Ohio 44175
6

7
on behalf of the Defendant:
8
JOSEPH FARCHIONE, ESQ.
9 Jacobson, Maynard, Tuschman & Kalur
1001 Lakeside Avenue
10 Suite 1600
Cleveland, Ohio 44114
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1 THOMAS VROBEL, M.D.
2 a witness, called for examination by the Defendant, under
3 the Rules, having been first duly sworn, as hereinafter
4 certified, deposed and said as follows:
5 CROSS-EXAMINATION
6 BY MR.  FARCHIONE:
7 Q. Doctor, can you state your full name for the
8 record, please?
9 A. Thomas Raymond Vrobel.
10 Q. Dr. Vrobel, my name is Joe Farchione, and I'm the
11 attorney representing Dr. Kalus in the lawsuit
12 brought by Mr. & Mrs. Slezak.
13 It is my understanding that you have reviewed
14 some documents relating to the care and treatment
15 rendered by Dr. Kalus to Mr. Slezak and have
16 reached opinions critical to the care of Dr. Kalus,
17 is that correct?
18 A. That's correct.
19 Q. I'm going to be asking you some questions about
20 those opinions and a little bit about your
21 background.
22 If at any time you don't understand a question
23 that I ask of you or a phrase that I use, please
24 stop me and have me repeat that for you.
25 Can we agree to that?
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1 A. Yes.
2 You understand this is my only opportunity to ask
3 you about your opinions and the basis for those
4 opinions?
5 A. Yes.
6 Q. You have to answer verbally so the court reporter
7 can take it all down.
8 A. Yes.
9 Q. Doctor, can you define standard of care for me?
10 A. Standard of care is the usual and customary
11 procedures performed by competent physicians in the
12 care of a patient.
13 Q. Do you use the term me