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         1   State of  Ohio,          SS:
         2   County of Lake.
         3                             - - -
         4                 IN THE COURT OF COMMON PLEAS

         6   CATHY J. PEDERSEN, et  al.,

         7                 Plaintiffs,

         8        V.                           Case No.  89 CIV 1340
                                               Judge James W. Jackson
         9   PAUL FERRIS, D.D.S.,

        10                 Defendant.

        11

        12           DEPOSITION OF ROBERT L. HARTER, D.D.S.

        13                  TUESDAY, OCTOBER 9, 1990

        14                             - - -

        15        The deposition of ROBERT L. HARTER,  D.D.S.,  a

        16   witness, called for examination by  the  Plaintiffs,

        17
             under the Ohio Rules of Civil Procedure, taken before

        18   me, Janet M. Hoffmaster, Registered Professional

        19   Reporter and Notary Public in and for the  State  of

        20   Ohio, pursuant to agreement of counsel, at the offices

        21   of Reminger & Reminger, 113 St. Clair Building,

        22   Cleveland, Ohio, commencing at 3:15 p.m., the day and

        23   date above set forth.

        24                             - - -

        25

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          1  APPEARANCES:


             On behalf of the Plaintiffs:

                  PAUL KAUFMAN, ESQ.
          4       Weisman, Goldberg, Weisman & Kaufman
                  1600 Midland Building
          5       Cleveland,  Ohio  44115

          6
             On behalf of the  Defendant:

                  ROY HULME, ESQ.
          8       Peminger & Reminger
                  113 st.  Clair  Building
          9       Cleveland,  Ohio  44114

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                                                                     3

                              ROBERT L. HARTER, D.D.S.
           2    a witness, called for examination by the Plaintiffs,
           3    under the Rules, having been first duly sworn, as
           4    hereinafter certified, deposed and said as follows:
           5                      CROSS-EXAMINATION
           6    BY MR.  KAUFMAN:
           7    Q.   Doctor, would you state your full name for the
           8    record?
           9    A.   Robert Lawrence Harter.
        10      Q-   And you are a dentist?
        11      A.   That's correct.
        12      Q-   And, Dr. Harter, you're business address is
        13      14701 Detroit Avenue in Lakewood?
        14      A.   Yes.
        15      Q-   Is that correct?
        16      A.   M-hm.
        17      Q.   Do you have any other offices besides that one?
        18      A.   No, I do not.
        19      Q.   You mentioned before we began that you're in
        20      practice with your son?
        21      A.   That's correct.
        22      Q.   What is your son's name?
        23      A.   Christopher.
        24      Q-   Are you in practice with any other dentists
        25      besides your son Christopher?
                                                                   4

          1    A.    No, I'm not.
          2    Q.    What is your age, sir?
          3    A.    Fifty-nine.
          4          You can tell us.
          5    A.    Got to be careful here.
          6    Q-    Your residence address?
          7    A.    31506 Carlton Drive, C-A-R-L-T-0-N.  That's Bay
          8    Village.  Zip is 44140.
          9          Have you ever been involved in a deposition
        10     proceeding before?
        11     A.    Yes, I have.
        12     Q.    Approximately how many times?
        13     A.    Probably about three or four.
        14           Have you ever testified in court?
        15     A.    Yes, once.
        16     Q.    From your testimony, then, I will assume that
        17     you are at least somewhat familiar with the procedure?
        18     A.    Yes, I am.
        19     Q-    I am going to ask you some questions this
        20     afternoon and if at any time I ask you a question that
        21     is not clear to you, please tell me, and I will attempt
        22     to rephrase it or clarify it for you, or we can even
        23     have our court reporter read it back to you.
        24     A.    Okay.
        25           If you don't understand the question, don't try
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           1    to answer it.
           2    A.   Okay.   I understand.
           3    Q.   If you give a response the young lady is going
           4    to take down