1 The State of Ohio,
SS:
2 County of Lake

3 - - - - -

4 IN THE COURT OF COMKON PLZAS


6 ROY W ROGERS, ET AL,

7
Plaintiffs,
8
Came Number 96CV000514
9
JOSEPHINE M SASU,
10
Defendant
11

12
DEPOSITION OF DAVID L UHRICH, PhD
13 Friday, September 13, 1996

14 - - - - -

15 Deposition of DAVID L UHRICH, PhD, called by the

16 Plaintiffs for examination under the Ohio Rules of Civil

17 Procedure, taken before me, the undersigned, Kathleen

18 Grandillo, Registered Professional Reporter, a Notary

19 Public in and for the State of Ohio, pursuant to agreement

20 of counsel, at the residence of David L Uhrich, PhD,

21 5754 Caranor Road, Kent, Ohio, commencing at 10:15 am,

22 the day and date above set forth

23 CORSILLO GRANDILLO
COURT REPORTERS
24 950 Citizens Building
Cleveland, Ohio 44114
25 216-523-1700

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1 APPEARANCES:

2 On Behalf of the Plaintiffs:

3 Mitchell A Weisman, Esquire
Weisman, Goldberg & Weisman
4 1600 Midland Building
Cleveland, Ohio 44115
5
On Behalf of the Defendant-
6
Robert J Foulds, Require
7 Dyson, Scbmidlin & Foulds
5843 Mayfield Road
8 Cleveland, Ohio 44124

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10 ALSO PRESENTt

11 Mr & Mrs Roy W Rogers, Plaintiffs

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13

14

is

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1 DAVID L UHRICH, PhD

2 called by the Plaintiffs for examination under the Ohio

3 Rules of Civil Procedure, after having been first duly

4 sworn, as hereinafter certified, was examined and testified

5 as follows:



7 EXAMINATION

8 - - - - -

9 BY MR WEISMAN:

10 Q Please tell us your name for the record

11 A it is David L Uhrich, U-h-r-i-c-h

12 Q Do you happen to have a current CV or resume?

13 A Yes

14 Q That will save about ten minutes, probably Thank

15 you

16 Okay, thanks We may as well mark this I'll just

17 write 1 on there  I'll put E-x-h for exhibit

18 Could you identify for the record what that document

19 is?

20 A Yes, it is my academic CV

21 0 And that's how many pages?

22 A Nine

23 0 Is it essentially accurate and current?

24 A Yes Academically, yes

25 Q When you say academically, are there things that you


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1 would like to include in your resume that are not included

2 here?

3 A Well, it just does not include anything in accident

4 reconstruction in terms of the number of cases I have

5 worked on or the number of times I have testified, which is

6 probably what you are interested in

7 Q As far as your writings and so forth, though, most of

8 that is included in here?

9 A All of it, yeah

10 Q Now, this deposition was set up sometime ago and we

11 switched it from a trial deposition to a discovery

12 deposition?

13 A Yen

14 0 And, just to clarify, we were also scheduled to come

15 here yesterday; were you aware of that?

16 A Yes

17 0 And that one we cancelled?

18 A Yes

19 0 Do you know when that deposition was scheduled, the

20 deposition for yesterday?

21 A It was recently, but I don't know when I forgot

22 when

23 You don't know?

24 As far as the exact date, I know when I was told 1

25 was wondering when you were told You don't recall when


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1 you were

2 A No

3 0 -- asked to

4 A Just last week or this week, I don't recall which

5 Q You reviewed the police report in this case; is that

6 true?

7 A Yes

8 0 Do you know the police officer who did this

9 investigation?

10 A No

11 Q Now, based on the review of the police report alone,

12 just looking at the police report, is there any evidence of

13 excessive speed that you found on the part of either of the

14 drivers?

is MR FOULDS: Show an objection -- and

16 1 am just going to put the objection on once

17 and then we can move along -- that this is

is the discovery deposition of an expert that's

19 being conducted pursuant to the Civil Rules,

20 and my understanding of the rule that

21 governs this proceeding is that Mr Weisman

22 is entitled to inquire of Dr Uhrich what

23 materials he has reviewed in connection with

24 this matter, what opinions he has formed

25 with regard to this matter and what opinions


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1 he has related to, in this case, the

2 Defendant in this matter, and that that's as

3 far as the deposition is permitted to go

4 MR WEISMAN: Okay

5 A What do you mean by excessive? Exceeding the speed

6 limit?

7 Q Yes

8 A With the report by itself, no

9 Q Okay

10 A You need the photographs as well to determine that

11 Q Okay

12 So you are saying with the police photographs and the

13 police report, just those two item , you can determine

14 speed?

15 A Well, I had to go to the accident scene and measure

16