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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, M.D., 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, M.D., 2475 E. 22nd Street,

15	Cleveland, Ohio, at 1:30 p.m. on Thursday,

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


18	Defendants, Gary Rogers, M.D. 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 621.0050
			     800.822.0650
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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, M.D. 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, M.D., of lawful age,
	2		called by the Defendants, Gary Rogers, M.D. 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, M.D.
	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		opinions.to 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