IN THE COURT OF COMMON PLEAS

        2                     MAHONING COUNTY, OHIO    2 @ - @@

        3                      CASE NO. 86-CV-1547           3S-  3@
        4

        5   WILLIAM GITSCHIER,

        6                   Plaintiff,
                                                  DEPOSITION OF
        7        versus
                                              MARIO F. MENDEZ,  M.D.
        8   JOHN AGNONE, et al.,

        9                   Defendants.

      10

      11

      12

      13              DEPOSITION OF MARIO F. MENDEZ, M.D., a Witness

      14    herein, called by the Defendants  for  Cross-Examination

      is    pursuant to the Ohio Rules of Civil Procedure, taken

      16    before me, the undersigned, Linda J. Ruffing, a

      17    Stenographic Reporter and Notary Public in and  for  the

      18    State of Ohio, at the offices of Mario F. Mendez, M.D.,

      19    University Hospitals of Cleveland, Cleveland,  Ohio,  on

      20    Friday, the 10th day of July, 1987, at 11:15 a.m.

      21

      22                          - - - - - - -

      2 3

      2 4
 It
      2 5


                              HILL COURT REPORTERS

                                                                      2



            APPEARANCES:

       2

       3         On Behalf of the Plaintiff:

       4              Eric Kennedy, Attorney at Law
                      540 Leader Building
       5              Cleveland, Ohio  44114

       6

       7         On Behalf of the Defendants:

                      David L. Herbert, Attorney at Law
                      4574 Stephen Circle, N.W.
       9              Canton, Ohio  44718

      10

      11         Also Present:

      12              Judy Hoechst

      13

      14

      15

      16

      17

      is

      19

      20

      21

      22

      23

      24

      25


                              HILL COURT REPORTERS

                                                                       3

       1                         MR. HERBERT: Let the  record  reflect
       2         we're here pursuant to agreement of counsel for  the
       3         purposes of taking a discovery deposition as to  Dr.
       4         Mario F. Mendez at University Hospitals of Cleveland.
       5         Is that correct Mr. Kennedy?
       6                         MR. KENNEDY:  Yes.
       7                          - - - - - - -
       8    WHEREUPON,
       9                      MARIO F. MENDEZ, M.D.,
      10         who, after being first duly sworn, testified as
      11         follows:
      12                        CROSS-EXAMINATION
      13    BY MR.  HERBERT:
      14         Doctor, my name is David Herbert.  I represent two
      15         physicians in this cause of action, a Dr. George
      16         Georgopoulos and Dr. John Agnone.  I'm going  to  ask
      17         you some questions.    If there's anything in the
      is         course of my questioning that you don't  understand,
      19         stop me, tell me that you don't understand or tell me
      20         you'd like it explained further, and I'll attempt  to
      21         do that.  I will also give you an opportunity, if you
      22         want, to add any material to the answers you give  to
      23         the questions that I ask.  But answer, if  you  would,
      24         the questions that I put to you.
      25                         For the record, would you state  your
      -1
                              HILL COURT REPORTERS
                                                                       4

        1        name?
        2   A.   Mario F. Mendez.
        3   Q.   And what is your profession?
        4   A.   I'm a physician.
        5   Q.   How long have you been so licensed?
        6   A.   Since 1974, thirteen years as of June.  Actually I
        7        have a license from California since 1975 and a
        8        license in Ohio since 1986.
        9   Q.   All right.  So you're licensed in California and
      10         Ohio?
      11    A.   Yes.
      12    Q.   You've been licensed in Ohio for about --
      13    A.   I have an inactive license in Rhode Island.
      14         And how long have you been licensed in Ohio, since
      15         what month?
      16    A.   What month?
      17    Q-   Yes.
      18    A.   I believe January of 1986.
      19         So you've been licensed about eighteen months here in
      20         this state?
      21    A.   Yes.
      22         And in California before that for thirteen years;
      23         correct?
      24    A.   I believe my license in California is dated
      2 5
                              HILL COURT REPORTERS
                                                                       5

        1   Q.   Okay.  Where did you go to medical school?
        2   A.   The University of Texas, Medical