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	1	IN THE COURT OF COMMON PLEAS
	2	. CUYAHOGA COUNTY, OHIO
	3		GARY GRABEL,
	4	Plaintiff,
			JUDGE GAUL
	5	-vs-	CASE NO. 383110
	6	.	ASHIS RAKHIT, M.D., et al.,
	7		              Defendants.
	8
	9		     ~osiflon5C}ThTRcK '~KATZMANThCb
	10		taken as if upon direct examination before Judith
	11		A. Gage, a Registered Merit Reporter and Notary
	12,		~ub1ic within and for the State of Ohio, at the
	13		offices of Weston, Hurd, Fallon, Paisley &
	14		Howley, 2500 Terminal Tower, Cleveland, Ohio, at
	15		4:00 p.m. on Tuesday, September 12, 2000,
	16		pursuant to notice and/or stipulations of
	17		counsel, on behalf of the Defendant in this
	18		cause.

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	20	MEHLER & HAGESTROM
		 Court Reporters
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		     CLEVELAND	      AKRON
	22	1750 Midland Building	1015 Key Building
		Cleveland, Ohio 44115	Akron, Ohio 44308
	23	    216.621.4984	   330.535.7300
		    FAX 621.0050	   FAX 535.0050
	24	    800.822.0650	   800.562.7100

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APPEARANCES:
	2	Robert V. Traci, Esq.
		Traci & Marx
	3	1550 Illuminating Building
		Cleveland, Ohio 44113
	4	(216) 623-8010,
	5	On behalf of the Plaintiff;

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		Ronald Rispo, Esq.
	7	Weston, Hurd, Fallon, Paisley & Rowley
		2500 Terminal Tower
	8	Cleveland, Ohio 44113
		(216) 241-6602,
	9
		    On behalf of the Defendant.
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	RICHARD K: KATZMAN, M.D., of lawful age,
called by the Defendant for the purpose ~f direct
examination, as provided by the Rules of Civil
Procedure, being by me first duly sworn, as
hereinafter certified, deposed and said as
follows:

DIRECT EXAMINATION OF RICHARD K. KATZMAN, M.D.

BY MR. RISPO

Q.	Dr. Katzman, thank you for coming down this
afternoon.

For the record, I would like to introduce
myself.
	I am representing Dr. Ashis Rakhit, who
is a defendant in this matter, and I have a
number of questions to ask of you concerning your
consultations, which I think is the best way of
describing your inVolvement in this case.

If at any time during the course of the

proceedings the question is not clear, please do
not answer, have me repeat it, rephrase it, or
have it read back.
Are we in agreement on that?
Q.	For the record, doctor, would you state your full



A.	Richard K. Katzman, M.D.
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A.	Yes.
name?
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Q.	And how old are you, doctor?

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	A.	69.
	2	Q.	And what is your area of medical specialty?
	3	A.	Cardiology and internal medicine.
	4	Q.	And are you Board certified?
		A.	I'm Board certified in internal medicine, but not
	6		in cardiology.
	7	Q.	And in internal medicine only?
	8	A.	Yes.
	9	Q.	And are you currently engaged in the services of
	10		any specific employer? Are you consulting? Are
	11		you in independent practice?
	12	A.	Both.
	13	Q.	All three? Okay
	14		    And where do you maintain your independent
	15		practice?
	16	A.	At Parkway Medical Building, 3609 Park East,
	17		Beachwood, Ohio, 44122.
	18	Q.	Do you see private patients there?
	19	A.	I see consultations, only consultations at that
	20		place.
		Q.	Do you see private patients elsewhere?
	22	A.	I am working for the Veterans' Administration at
	23		the VA part-time.
	24	Q.	And do you see patients for the Veterans'
	25		Administration?

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	1	A.	Yes.
	2	Q.	And what percentage of your time is spent in
	3		seeing patients for the Veterans' Administration?
	4	A.	About half.
	5	Q.	And is the rest taken up with consultations?
	6	A.	Yes.
	7	Q.	And for whom do you consult?
	8	A.	I consult for the -- let's see. Rehabilitation
	9	.	Services -- disability and termination section of
	10		the State of Ohio for the performance of
	11		disability consultations for people applying for
	12		either Social Security disability or for 551.
	13		I'm a consultant to the Public Employees
	14		Retirement System, the State Teachers' Retirement
	15		System, the School Employees Retirement System,
	16		the police and fire, Ohio Police and Fire
	17		Disability and Retirement System.
	18		    I'm a consultant for the United States
	19		Department of Labor Coal Workers Disability.
	20		                MR. TRACI: Didyou say "co" or
	21		      "coal"?
	22		                THE WITNESS: Coal, c-o~-a-l.
	23		                MR. TRACI: I'm sorry.
	24	A.	And I don't know if I left anything out.
	25	Q.	Well, that is certainly sufficient.

	1	A.	I formerly was a, worked on the appeals, the
	2		Bureau of Appeals hearings and appeals for
	3		disputed Social Security cases and I had to leave
	4		that when I went to MetroHealth Medical Center in
	5		1992.
	6	Q.	Are you still attached to Metro?
	7	A.	No, I'm not. No, 11m not but yes, I am. 11m not
	8		working there full-time. I'm teach