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IN THE COURT OF COMMON PLEAS
	2	FRANKLIN COUNTY, OHIO
	3	HEATH RYAN WILSON, etc
		et al,
	4
		            Plaintiffs,
	5		JUDGE FAIS
		-vs-	CASE NO 95CVA08-5729
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CHILDREN'S HOSPITAL,
	7	et al,
	8		Defendants
	9		-—




10	Deposition of CARL F ASSEFF, MD, taken as

11	if upon cross-examination before Aneta I Fine,

12	a Registered Merit Reporter and Notary Public

13	within and for the State of Ohio, at the offices

14	of Carl F Asseff, MD, 2475 E 22nd Street,

15	Cleveland, Ohio, at 1:30 pm on Thursday,

16	September 5, 1997, pursuant to notice and/or
	I—
17 stipulations of counsel, on behalf of the


18	Defendants, Gary Rogers, MD and Pediatric

19	ophthalmology Associates, Inc, in this cause

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			MEHLER & HAGESTROM
	22	-	   Court Reporters
			1750 Midland Building
	23		Cleveland, Ohio 44115
			     216 621:4~984
	24		     FAX 6210050
			     8008220650
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Mehier & Hagestrom

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APPEARANCES:

2	James A Marx, Esq
Traci & Marx
3	55 Public Square
Cleveland, Ohio 44113
4	(216) 623-8010,

5	On behalf of the Plaintiffs;

6	William A Davis, Esq
Jacobson, Maynard & Tuschman
7	175 South Third Street, Suite 880
Columbus, Ohio 43215
8	(614) 224-1323,

9	On behalf of the Defendants
Gary Rogers, MD and Pediatric
10	Ophthalmology Associates, Inc;

11	James E Arnold, Esq
Vorys, Sater, Seymour & Pease
12	52 E Gay Street
Columbus, Ohio 43216-1008
13	(614) 464-6400,

14	On behalf of the Defendant
Children's Hospital
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	1			   CAItL F ASSEFF, MD, of lawful age,
	2		called by the Defendants, Gary Rogers, MD and
	3		Pediatric Ophthalmology Associates, Inc for the
	4		purpose of cross-examination, as provided by the
	5		Rules of Civil Procedure, being by me first duly
	6		sworn, as hereinafter certified, deposed and
	7		said as follows:
	8 CROSS-EXAMINATION OF CARL F ASSEFF, MD
	9		BY MR DAVIS:
	10	Q 	Dr 	Asseff, first of all, for the record, state
	11		your name -and a professional address
	12	A-	Carl F Asseff, 2475 East 22nd Street,
	13		Cleveland, Ohio
	14	Q 	Dr 	Asseff, we were just introduced My name is
	15		Bill Davis I represent Dr Gary Rogers in this
	16		case and we're here to take your deposition
	17		today -
	18	-   		- MR DAVIS: By the way, the record
	19	-		should reflect this deposition is being
	20	-		taken pursuant to agreement for purpose of
	21			discovery and that formalities and notice
	22			and service of same are waived
	23	-	 -	       - MR MARX: That's right -
	24			         MR DAVIS: Okay
	25	Q 	We're-here to take your deposition as you've
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	1		been identified as plaintiff's expert witness in
	2		 this case If at any time during the course of
	3		our questions any of the questions are unclear
	4		or don't make sense medically, grammatically,
	5		 logically or otherwise, I'm sure you'll speak up
	6		 and let me know Agreed?
	7	A	Agreed
	8	Q	Very good And secondly, during the course of
	9		 this deposition I'll be asking you whether you
	10		hold any opinions regarding the facts of this
	11		- case and when I do so if I neglect to use all
	12		 the magic words can we have an understanding
	13		 that what I am asking is whether you hold
	14		opinionsto a reasonable medical probability or
	15		 in other words more likely than not Also
	16		agreed?
	17	A	 That's agreed
	18	Q	Very good Doctor, I was provided with an
	19		updated copy of your curriculum vitae just
	20		before we walked into the conference room here
	21		at your offices and i'th not going to bother
	22		marking this as an exhibit but I can just hand
	23		 it to you
	24		      Is this reasonably up-to-date, and if
	25		you'll take a look and just let us know if there
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	1		are any alterations that need to be made to make
	2		it up-to-date
	3	A	That's reasonably up-to-date
	4	Q	Okay Very good And secondly, have you
	5		published in the medical literature?
	6	A	I have but that has not, I haven't published
	7		anything since '72, '73
	8	Q	Okay Because I didn't see any listed in your
	9		CV
	10	A	No My publications have been on glaucoma
	11	Q	In glaucoma Roughly how many publications on
	12		glaucoma?
	13	A	Guesstimate about 12
	14	Q	Okay And this is back in the 70's?
	15	A	Yes, sir
	16	Q	All right And this was either I guess during
	17		your residency or shortly thereafter?
	18	A	It was during the fellowship time when I was in
	19		St Louis and anything I did during that time
	20		was published subsequent to that
	21	Q	I see And what type of fellowship did you take
	22		in St Louis?
	23	A	Glaucoma
	24	Q	Glaucoma, all right Have you taken any
	25		particular training or fellowships in the areas,
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my general
private practice
ittle bit Now,
East 22nd in
this deposition
Huron Road, Mt

include F