2 THE STATE OF OHIO,
SS:
3 COUNTY OF CUYAHOGZ-@.)

4
IN THE COURT OF COMMON PLEAS
5
KEITH E. JONES,
6

7 Plaintiff,

8 VS. Case No. 90952

9 BEN D. ORTEGA, M.D. , et al , Robert M. Lawther

10
Defendants.
11

12
DEPOSITION OF DR.  RUSSELL W. HARDY
13
WEDNESDAY, NOVEMBER 5, 1986
14

15
Deposition of Russell W. Hardy, a
16
witness called for examination by the Plaintiff
17
under the Ohio Rules of civil Procedure, taken
18
before me, Richard G. DelMonico, a Registered
19
Professional Reporter and Notary Public within
20
and for the State of Ohio, pursuant to notice,
21
at The Cleveland Clinic, Cleveland, Ohio,
22
commencing at 1:30 p.m. the day and date
23
above set forth.
24

25

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2 APPEAR AN CES

3 On beh al f of th e Pl ai nt i f f

4 FRED WEISMAN, ESQ. and
JED WEISMAN, ESQ.
5 Weisman, Goldberg & Weisman
540 Leader Building
6 Cleveland, Ohio 4 4 1 1 4

7
On behalf of the Defendant
8 Dr. Ortega:

9 JEROME S. KALUR, ESQ.
Jacobson, Maynard, Tuschman & Kalur Co.
10 200 Erieview Plaza
Cleveland, Ohio 4 4 1 1 4
11

12 on behalf of the Defendant
Bethandale Corp.
13
MATTHEW J. HATCHADORIAN, ESQ.
14 Vorys, Sater, Seymour and Pease
2100 One Cleveland Center
15 1375 East 9th Street
Cleveland, Ohio 4 4 1 1 4 - 1 7 2 4
16

17 On behalf of the Defendant
Huron Road Hospital:
18
JAMES L. MALONE, ESQ.
19 Reminger & Reminger
113 St. Clair
20 Cleveland, Ohio 44114

21

22

23

24

25

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2 MR. FRED WEISMAN: The record
3 should show this deposition is taken by
4 agreement between counsel for each and
5 all of the parties to this law suit.
6 There is a waiver with respect to any
7 possible defect, I take it, in
8 connection with service or notice.
9 MR. KALUR: That's correct.
10 MR. FRED WEISMAN: Everybody
11 agreeable?
12 MR. HATCHADORIAN: Agreed.
13 MR. MALONE: Yes.
14
15 RUSSELL W. HARDY, M.D.
16 of lawful age, called as a witness by the Plaintiff
17 pursuant to the Ohio Rules of Civil Procedure,
18 being by me first duly sworn, as hereinafter
19 certified, deposed and said as follows:
20 DIRECT EXAMINATION
21 BY MR. FRED WEISMAN:
22 Q. State your name and your residence address,
23 doctor, and your professional address, please?
24 A. Russell Willis Hardy, 16628 Aldersyde
25 Drive, Shaker Heights, Ohio. The prof essional
4
1 address is Cleveland Clinic, Cleveland, Ohio.

2 Q - Your speciality I know is neurosurgery.

3 How long have you been a physician and how long

4 have you been in the neurosurgical field?

5 A. II ve been a phy si ci an since 1 96 5 and 1

6