State Of Ohio

County of Richland.
SS:
IN THE COURT OF COMMON PLEAS


CHRISTINE HERRICK,
et al.
Plaintiffs,
vs.
LARRY ZIMMERMAN, DPM,
et al.
Defendants.
Case No. 01—408H


THE. TELEPHONIC DEPOSITION OF JERRY KAPLAN, M.D.
TUESDAY, AUGUST 20, 2002
The deposition of JERRY KAPLAN, M.D.,
called by the Plaintiffs for examination pursuant
to the Ohio Rules of Civil Procedure, taken before
me, the undersigned, Darlene Vance, a Registered
Professional Reporter and Notary Publid within and
for the State of Ohio, taken at the offices of Cady
Reporting Services, Inc., 1225 Illuminating
Building, Cleveland, Ohio, commencing at 9:15 a.rn.
the day and date above set forth.




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1	JERRY KAPLAN, M.D.

2	of lawful age, called by the Plaintiffs for

3	examination pursuant to the Ohio Rules of Civil

4	Procedure, having been first duly sworn, as

5	hereinafter certified, was examined and

6	testified as, follows:

7	EXANINATION OF JERRY KAPLAN, M.D.
	8	BY MR. TRACI:
	9	Q	Doctor, my name is Bob Traci. I represent

10	Christine and Chuck Herrick in this matter.

11	You've been identified as an expert by

12	Dr. Zimmerman's lawyers, as you know.

13	I need you to state your full name and

14	address for us, please.
	15	A	Jerry Kaplan, M.D., 2157 Tomlinson,

16	T-O-M-L-I-N-S-O-N, Avenue, Bronx, New York,

17	10461.
	18	Q	Doctor, is that your residence?
	19	A No.
	20	Q	What is that address, is that youroffice?
	21	A	Yes.
	22	Q	That's your private office where you practice

23	neurology?
	24	A	Right.
	25	Q	And tell me a little bit about your education.




Cady Reporting Services, Inc.

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	1	A	Sure. I went to medical school at the Albert
	2		Einstein College of Medicine, New York. I
	3		started there in 1972, finished in 1975. I did
	4		a medical internship at Albert Einstein College
	5		of Medicine from July 1st, '75 until the end of
	6		June of '76 From July 1, T75 to late June
	7		'79, I was a neurology resident at the Albert
	8		Einstein College of Medicine and Montefiore
	9		Medical Center. From 1979 of July until
	10		today —— 1980, I was a fellow at Albert Einstein
	11		College of Medicine for the next year. From
	12		June of 1980 until August of 1981, I was a
	13		fellow at the Massachusetts General Hospital
	14		Harvard Medical School. I went to college in
	15		clinical neurophysiology ——
F
	16	Q	Neuromuscular diseases?
	17	A	Clinical neurophysiology, EMG, neuromuscular
	18		disease. From August 6, 1981 until July of
	19		1982, I was visiting fellow at Columbia
	20		Presbyterian Medical College in clinical
	21		neurophysiology. In 1981, August, I began as
	22		a professor at Albert Einstein Medical College
	23		and Montefiore Hospital. In 1986 —— that was
	24		prior education. Do you want that or not?
	25	Q	I think that's enough right now, Doctor.




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What is your current position?

A	My current position, I'm in private practice in
neurology. I'm associate professor of
neurology at the Albert Einstein College of
Medicine and Montefiore Medical Center.

Q	Okay. And you're Board certified in neurology?

A	I am.

Q	And since when?

A	I think 1980.

Q	And are you Board certified in any other
specialty?

A	Well, yeah, there was -- more recently neurology
has added a separate subspecialty, they call it
clinical neurophysiology. I have that: I got
that, I believe, in 1996. AndI also have
boards from the American Board of
Electrodiagnostic Medicine. And I honestly
can't tell you when I got thpse. Probably
sometime in the '80s.

Q	Okay. What is neurophysiology versus
iieurology?

A	Neurophysiology is the study of the physiology

——	or function of the nerves, how the nerves
actually function. Doing tests, using equipment
that actually measure responses in different
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	1		parts of the nervous system, either individual
	2		peripheral nerves, peripheral nerves, and
	3		muscles, nerve roots, spinal cord, depending on
	4		the type of test.
	5	Q	And the testing that you're talking ab