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.




CADY REPORTING SERVICES, INC.
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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.

			                                                 4
	1	A	Sure. I went to medical school at the Albert
	2		Eins