a 0

                State of Ohio,

       2        County of Lorain.

       3
                           IN THE COURT OF CONMON PLEAS
       4

       5
                CAROL L. FREDERICK, etc.,
       6
                          Plaintiff,
       7                                     Case No.
                     VS.                     94 CV 112,225
       8
                THE OBERLIN CLINIC, INC.,
       9        et al.,

       10                 Defendants.

       11

       12          CONTINUED DEPOSITION OF JEFFREY NORRIS, M.D.
                               Tuesday, May 14, 1996
       13

       14

       15            The continued deposition of JEFFREY MORRIS,

       16       M.D., a witness, called for examination by the

       17       Defendants under the Ohio Rules of Civil

       18       Procedure, taken before me, Diane M. Stevenson, a

       19       Registered Professional Reporter and Notary

       20       Public in and for the state of Ohio, by agreement

       21       of counsel, at the office of Jeffrey Morris,

       22       M.D., 23250 Mercantile Road, Beachwood, Ohio,

       23       commencing at 4:40 p.m., the day and date above

       24       set  forth.

       25                              - - -



                          Diane M. Stevenson, RPR, CM
                            Morse, Gantverg & Hodge

                                                                      I

                                                           8 2
       1                MR. CHAMBERLAIN:       Before we begin,
       2       I would like to make a statement on the record,
       3       and it is for Mr. Foerstner's benefit, and to
       4       confirm our earlier conversation.
       5            This is a continuation of Dr. Morris's
       6       deposition.  The questions on the liability and
       7       what Dr. Morris finds to be deviations of the
       8       standard of care have been completely outlined.
       9            And, Jim, you and I have talked about the
       10      fact that I will be objecting throughout  the
       11      course of the deposition to any rehash of that
       12      area in any specific detail, because I think it
       13      has been covered, and by someone from your
       14      o f f i c e .
       15           I understand you are a new lawyer, but this
       16      it is still your same firm, same party  being
       17      represented.  On that basis, I think you have had
       18      that bite at the apple.
       19           But as far as the second report on  what
       20      injury was proximately caused by the malpractice,
       21      I don't have a problem with that.  That is what
       22      we are here for.
       23                MR. FOERSTNER:       okay.  Well, as I
       24      told you on the phone, Hank, my interest here is
       25      going to be based primarily on proximate cause

                        Diane M. Stevenson, RPR, CM
                          Morse, Gantvera & Hodge

                                                            8 3
       1       issues and damages.
       2            You can object.  I mean, it is certainly
       3       your right to object.  I am going to ask the
       4       questions.  I don't think you can tell the doctor
       5       not to answer any questions if they don't square
       6       with your idea of what is a proper question or
       7       not a proper question based upon the prior
       8       depositions.
       9            So I will respect your objections and let
       10      the Judge rule on the admissibility, or
       11      otherwise.
       12                MR. CHAMBERLAIN:        Sorry, Doctor,
       13      you had to go through this, but this is
       14      unfortunately lawyer's legalese that we have to
       15      hassle over.
       16                THE WITNESS:       No problem.
       17                          - - -
       18
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                        Diane M. Stevenson, RPR, CM
                           Morse, Gantvarg & Hodge

                                                           8 4
       1                     JEFFREY MORRIS, M.D.
       2       A witness, recalled for further examination by
       3       the Defendants, under the Rules, having been
       4       first duly sworn, as hereinafter certified, was
       5       examined and testified as follows:
       6                  CONTINUED CROSS-EXAMINATION
       7       BY MR.  FOERSTMER:
       8 Q.    Dr. Morris, my name is James Foerstner.  We  just
       9       met informally.  I am a new counsel on this case.
       10      Lisa Baer was the prior counsel.  You  apparently
       11      met her in the past.
       12 A.   Yes.
       13 Q.   You have had a de