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     IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     ABRAHAM ACOFF,
                Plaintiff,
          vs                             Case No
     GENERAL MOTORS COMPANY, et al, 03 CV 493150
                 Defendants
     
                        ~ ~ ~ ~ ~
                 Videotaped deposition of
     LAXMINARAYAN C RAO, MD, called for
     examination under the statute, taken before me,
     Denise M Munguia, a Registered Merit Reporter
     and Notary Public in and for the State of Ohio,
     pursuant to notice and stipulations of counsel,
     at Southwest General Health Center, 7255 Old
     
     Oak Boulevard, Middleburg Heights, Ohio, on
     
     Friday, December 12, 2003, at 11:13 o'clock
     
     am
     
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 1   APPEARANCES:
 2   
 3        On behalf of the Plaintiff:
 4              Kelley & Ferraro, LLP, by
 5              JAESON L TAYLOR, ESQ
 6              1901 Penton Media Building
 7              1300 East Ninth Street
 8              Cleveland, Ohio  44114
 9              (216) 575-0777
10   
11        On behalf of the Defendant General Motors
12        Company:
13              Vorys, Sater, Seymour and
14               Pease LLP, by
15              MARGARET DODANE EVERETT, ESQ
16              2100 One Cleveland Center
17              1375 East Ninth Street
18              Cleveland, Ohio  44114-1724
19              (216) 479-6100
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                                                                     3
 1               On behalf of the Defendant
 2              Administrator Bureau of Workers'
 3              Compensation:
 4               State of Ohio Office of the
 5              Attorney General, by
 6                   JEFFREY B DUBER, ESQ
 7                   615 West Superior Avenue,
 8                   11th Floor
 9                   Cleveland, Ohio  44113-1899
10                   (216) 787-3030
11                         ----
12   
13   ALSO PRESENT:
14              Kimberly DiMuzio, CLVS
15                         ---
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 1                    -  -  -  -  -
 2               (Thereupon, Rao Deposition Exhibits
 3               1 through 5 were marked for purposes
 4               of identification)
 5                     -  -  -  -  -
 6               MS EVERETT:  On behalf of the
 7   Defendant General Motors, we would like to
 8   object to Dr Rao testifying today with regard
 9   to anything other than what is contained in his
10   initial report from 1998 which you have
11   identified as Plaintiff's Exhibit 2  We're
12   going to object to any additional testimony or
13   opinions which are not offered in that report
14   and move to strike those opinions and testimony
15   at the time of trial and we're reserving our
16   right to do that on the record at this time,
17   specifically with regard to Dr Rao's addendum
18   which you have marked as Plaintiff's Exhibit 5
19               MR DUBER:  And on behalf of the
20   Defendant Administrator of the Bureau of
21   Workers' Compensation, I would join in that,
22   join in that objection
23               MS EVERETT:  Go ahead
24               MS DiMUZIO:  Okay  Stand by
25               Today is December 12th, 2003  We

                                                                     5
 1   are on the record at 11:13
 2               Court reporter, would you please
 3   swear in the witness?
 4        LAXMINARAYAN C RAO, MD, of lawful age,
 5   called for examination, as provided by the Ohio
 6   Rules of Civil Procedure, being by me first
 7   duly sworn, as hereinafter certified, deposed
 8   and said as follows:
 9       EXAMINATION OF LAXMINARAYAN C RAO, MD
10   BY MR TAYLOR:
11         Q    Good morning, Doctor  Could you
12   please state and spell your last name for the
13   record?
14         A    My name is Laxminarayana C Rao,
15   spelled as L A X M I N A R A Y A N A, C is the
16   middle initial, Rao, R A O, is my last name
17         Q    And what is your profession?
18         A    I'm a physician
19         Q    Okay  I'm handing you what has
20   previously been marked Deposition Exhibit
21   Number 1
22         A    Yes
23         Q    Could you please identify that
24   document for the jury?
25         A    This is a six-page document  It's

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 1   a copy of my curriculum vitae
 2         Q    Okay  And feel free, during the
 3   course of my questioning, to refer to th