COURT OF COMMON PLEAS

                               SCIOTO COUNTY, OHIO
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           4  WILLIAM NICHOLS, et al.,


                        Plaintiffs,
           5                                   CASE NO. 93-cj-193

           6     VS.


           7  FAMILY MEDI-CENTER, et al.,



           8            DefendantS.



           9                       depOSition Of R. MORTON BERTRAM,

           io            videotaped



           11   III, M.D., an expert witness herein, taken by the



           12   defendants as upon direct examination pursuant to



           13   the Ohio RUles of Civil Procedure and pursuant to



           14   agreement between counsel as to the time and place,



           15   and stipulations hereinafter set forth, at the



           16   offices of H. Morton Bertram, III, M.D., 7663 Five



           17   Mile Road, Cincinnati, Ohio, at 12:17 P.M. on



           18   Wednesday, August 13, 1997, before Steven W. Varney,



           19   CLVS, videographer, and Cynthia L. Varney, a notary



           20   public within and for the State of Ohio.



           21                           - - -




           22                     Cin-Tel Corporation

                                      813 Broadway


           23                  Cincinnati, Ohio  45202

                                     (513) 621-7723


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                                          I

                                   CIN-TEL CORPORATION

           1 APPEARANCES:

           2         O,, behalf of the Plaintiffs:

                           BENITO ANTOGNOLI, ESQ-       c)., L.P.A.
           3               Weisman  Goldberg & Weism,n C
                           1600 Mi@land BUilding
           4               Cleveland, Ohio  44115

           5          on behalf of the DefendantS:

           6               ROBERT E. DEVER, ISQ-
                           Bannon  Howland & Dever
                           325 Ma onic Building
                           portsmouth, Ohio  45662


           9

           10              S

                      It is stipulated by and between Counsel fo'r
           11

           12   the respective parties that the depOSition Of H.


           13   MORTON BERTRAM, III, M.D., an expert witness herein,


           14   Tnay be taken at this time by the delendants as upon


           is   direct examination, pursuant to the Ohio Rules Of


           16   civil Procedure arid pursuant to agreement between


           17   counsel as to the time and place; that the


           18   deposition may be taken in stenotypy by the notary


           19   public-court reporter and transcribed by her out Of


           20   the presence of the witness; and that review of the


           21   videotape and examination and signature to the


           22   transcribed deposition are expressly waived.


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                                  CIN-TEL CORPORATION

                                    I N D F X
           1                                DII'alt Cro_ss  Redirecl-

           2  WitnesS

           3  H. MORTON BERTRAM, III, M.D.     4                so

           4    By Mr. Dever

           5    By Mr. AntOgnOli                       20

           6

           7               (No exhibits were identified.)

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                                           3

                                    CIN-TEL CORPORATION

                          THE VIDEOGRAPHER:  This is the

                      estimony of Dr- I,_ Morton Bertram, III, in
          2          t

          3          the matter of william Nichols, et al.,

          4          versus Family Medi-Center, et al.  The case

          5          number is 93-CI-193.  The date is August 13,

          6          1997.

          7               Madam court reporter, would you swear

          8           in the witness, please.

          9               ii. MORTON BERTRAM  III  M.D.

          10  of lawful age, as having been duly sworn, was

          11  examined and testified as follows:

          12                   DIRECT EXAMINATION

          13  BY MR.  DEVER--

          14          Q    Dr. Bertram, as you know, my name is

          is  Bob Dever, and I  represent the defendants in this

          16   case.  For the record, first of all, would you give

          17   the jury a history of your education and your

          18   experience as a physician.  You are a medical

          19   doctor; right?

          20           A    That's correct, medical doctor.