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 fi