COURT OF COMMON PLEAS

           2                        SCIOTO COUNTY, OHIO

           3                                -  -  -

           4     WILLIAM NICHOLS, et al.,

           5                    PlaintiffB,

           6            vs.                       CASE NO. 93-CI-193

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

           8                    Defendants.

           9                                -  -  -

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

         11      a witnees herein, taken by the Plaintiffs aB upon

         12      cross-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 East 9th Street
         24                       Cincinnati, Ohio 45202
                                      (513) 621-7723

                                              1
                                    CIN-TEL CORPORATION        ORIGINAL

            1   APPEARANCES:
                          on behalf of the Plaintiffs:
            2
                                BENITO C.R. ANTOGUOLI, ESQ.
            3                   Weisman, 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
                                PortBMOUth, Ohio  45662
            9

            10                   S T I P U L A T I 0 N 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 ao upon

            15   cross-examination, pursuant to the Ohio Rules of

            16   Civil Procedure and pursuant to agreement between

            17   counbel as to the time and place; that the

            18   depOBition 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 examination

            21   and signature to the transcribed deposition is

            22   expressly waived.

            23                             - - -

            24


                                               2
                                     CIN-TEL CORPORATION

           1                            I N D E X
           2    WitneBS                                     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
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           2 0
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           2 2
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                                             3
                                   CIN-TEL CORPORATION

           I                    H. MORTON BERTRAM III, M.D.,
           2     of lawful age, as having been duly sworn, waa
           3     examined and depOBed aB fOllOWB:
           4                       CROSS-EXAMINATION
           5     BY MR.  ANTOGNOLI:
           6               Q    Good afternoon, Doctor.  How  are  you?
           7               A    Good.
           8               Q    Before we get started with the
           9     quebtioning in thib 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 juot remind you of a
          14     few thingb before we get started, and lay  down  some
          15     ground rules, and then we can get going here.
          16               Obviously, if I ask you a quebtion and  you
          17