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(JOB)
1 State of Ohio,
SS:
2 County of Lorain
3 - - -
4 IN THE COURT OF COMMON PLEAS
5 - - -
6 Carol L Frederick, etc,
7 Plaintiff,
Case No 94 CV 112225
8 VS
Judge McGough
9 The Oberlin Clinic, Inc,
et al,
10
Defendants
11
12
13 DEPOSITION OF JEFFREY MORRIS, MD
14 MONDAY, FEBRUARY 19, 1996
15
16 The deposition of Teffrey Morris, MD, a witness
17 herein, called by the Defendants for examination
18 under the Ohio Rules of Civil Procedure, taken
19 before me, Ivy J Gantverg, Registered Professional
20 Reporter and Notary Public in and for the State of
21 Ohio, by agreement of counsel and without further
22 notice or other legal formalities, at 23250
23 Mercantile Road, Beachwood, Ohio, commencing at 2:40
24 pm, on the day and date above set forth
25
MNRAR rA@Rr@ k MnnrR
1 APPEARANCES:
2 on behalf of the Plaintiff:
3 Herlry Chamberlain, Esq
Weisman, Goldberg & Weisman
4 1600 Midland Building
Cleveland, Ohio 44115
5
on behalf of Defendants The Oberlin Clinic, Inc
6 and Antonio Rosario, MD:
7 Elizabeth E Baer, Esq
Cheryl A O'Brien, Esq
8 Jacobson, Maynard, Tuschman Kalur
1001 Lakeside Avenue - Suite 1600
9 Cleveland, Ohio 44114
10
11
12
13
14
15
16
17
18
19
20
21
2 2
2 3
24
25
MNRRR, r@ANTW@Rr NOT)RR
1 (Thereupon, Defendants' Exhibits 1
2 through 3 (Morris) were marked for
3 identification)
4 JEFFREY MORRIS, MD
5 a witness herein, called by the defendants for
6 examination under the Rules, having been first duly
7 sworn, as hereinafter certified, was deposed and
a said as follows:
9 CROSS EXAMINATION
10 BY MS BAER:
11 Q I take it that you have had your deposition
12 taken before It looks like you have the routine
13 down pat
14 A Right
15 Q Doctor, we met a few minutes ago I am Lisa
16 Baer, and I am one of the attorneys here for
17 Dr Rosario
18 If you have been deposed before, then I
19 probably don't need to do much explaining
20 Verbalize your answers so the court reporter
21 can take them down If you don't understand
22 something, I will clarify, or start over if we need
23 to; fair enough?
24 A Fair enough
25 Q I guess first thihgs first
mngqp, r-,hm"7ppr- r T4c)ncp
- 4
1 The information you have here is a file that
2 you have for Shanon Maurer?
3 A That is correct, records only
4 Q Okay
5 Actually, let me just take a quick look
6 A Sure
7 (Thereupon, the documents were handed
8 to Ms Baer)
9 MR CHAMBERLAIN: There is a
10 deposition in there, too
11 BY MS BAER:
12 Q I see you caught one of the typos that I was
13 going to ask you about Actually, there is a
14 second, but I will get to that
15 A There may be, yes
16 Q Is this the current CV (indicating)?
17 A Yes
18 Q Do you have a copy that I could take with me?
19 A I do I will provide as many copies as you
20 want, as well as one for the stenographer, because
21 some of the
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