COURT OF COMMON PLEAS

           2                        SCIOTO COUNTY, OHIO

           3                                 - -  -

           4     WILLIAM NICHOLS, et al.,

           5                    Plaintiffs,

           6            VS.                       CASE WO. 93-CI-193

           7     FAMILY MEDI-CENTER,  et  al.,    JUDGE EVERETT BURTON

           8                    Defendants.

           9                                 - -  -

           10             Deposition of H. MORTON BERTRAM IIIF M,D.,

           11    a witness herein, taken by the Plaintiffs-as upon

           12    crOBs-examination pursuant to the Ohio Rules of

           13    Civil Procedure and pursuant to notice between

           14    counsel as to the time and place, and stipulations

           15    hereinafter set forth, at the offices of Dr. H.

           16    Morton Bertram, 7691 Five Mile Road, Cincinnati,

           17    Ohio, at 5:00 p.m. on Thursday, August 4, 1994,

           18    before Denise Chulik, R.N., a notary public within

           19    and for the  State  of  Ohio.

           20                                - -  -

           21

           2 2

           23                      Cin-Tel Corporation
                                   215 Hast 9th Street
           24                     Cincinnati, Ohio 45202
                                       (513) 621-7723

                                              1
                                    CIN-TEL CORPORATION

            1   APPEARANCES:
                          on behalf of the Plaintiffs:
            2
                                BENITO C.R. ANTOGNOLI, ESQ.
            3                   Weismanr Goldberg & Weisman
                                Company, L.P.A.
            4                   1600 Midland Building
                                Landmark office Towers
            5                   Cleveland, Ohio  44115

            6             On behalf of the Defendants:

            7                   ROBERT E. DEVER, ESQ.
                                325 Masonic Building
            8                   P.o. Box 1384
                                Portsmouth, Ohio  45662
            9

            10                   S T I P U L A T I  0 R S
                                 - - - - - - - - - - - -

            11             It  is stipulated by and between counsel for

            12   the   respective parties that the deposition of H.

            13   MORTON   BERTRAM III, M.D., a witness herein, may be

            14   taken at this time by the Plaintiffs as upon

            is   cross-examination, pursuant to the Ohio Rules of

            16   Civil Procedure and 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 r6porter and transcribed by her out of

            20   the presence of the witness; and that examination

            21   and signature to the transcribed deposition is.

            22   expressly waived.

            23

            2 4


                                               2
                                     CIN-TEL CORPORATION

                                          I N D E X
            2   Witness                                       Cross
            3   H. MORTON BERTRAM III, M.D.
            4        By Mr. Antognoli                          4
            5
            6                          E X H I B I T S
            7                                                Marked
            8    Plaintiffs' Exhibit #1                        5
            9
            10
            11
            12
            13
            14
            15
            16
            17
            18
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            2 0
            21
            2 2
            2 3
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                                              3
                                     CIN-TEL CORPORATION

            1                   H. MORTON BERTRAM III, M.D.r
            2    of lawful age, as having been duly sworn, wad
            3    examined and deposed as follows:
            4                      CROSS-EXAMINATION
            5    BY MR.  ANTOGNOLI:
            6                   Good afternoon, Doctor.  How  are  you?
            7              A    Good.
            8              Q    Before we get started with the
            9    questioning in this case, let me ask  you:  have  you
            10   ever had your deposition taken before?
            11             A    Yes.
            12             Q    Okay; you're somewhat familiar with
            13   the procedure, then.  Let me just remind you of a
            14   few things before we get started, and lay  down  some
            15   ground rules, and then we can get going here.
            16             obviously, i