1
             IN THE COURT OF COMMON PLEAS
              OF CUYAHOGA COUNTY, OHIO
     
     
     ALONZA C. LUSTER,
                 Plaintiff,
      vs.                          Case No.
     FORD MOTOR COMPANY, et al.,   CV-03-500750
                 Defendants.       JUDGE RUSSO
                        - - - - -
     
                Videotaped deposition of PAUL C.
     VENIZELOS, M.D., called for examination under
     the statute, taken before me, Carina C.
     Meszaros, a Registered Merit Reporter and
     Notary Public in and for the State of Ohio, at
     the offices of Ohio Chest Physicians, Ltd.,
     
     15805 Puritas Avenue, Cleveland, Ohio, on
     
     Wednesday, November 5, 2003, at 2:32 o'clock
     
     p.m.
     
                        - - - - -

                                                                     2
 1   APPEARANCES:
 2   
 3        On behalf of the Plaintiff:
 4              Kelley & Ferraro, L.L.P., by
 5              BRIAN P. WYMAN, ESQ.
 6              1901 Penton Media Building
 7              1300 East 9th Street
 8              Cleveland, Ohio  44114
 9              (216) 376-1950
10   
11        On behalf of the Defendant Ford Motor
12        Company:
13              Radamaker, Matty, McClelland &
14              Greve, by
15              THOMAS F. GREVE, ESQ.
16              Suite 1775
17              55 Public Square
18              Cleveland, Ohio  44113
19              (216) 621-6570
20   
21                         ----
22        ALSO PRESENT:
23              Kurt Henschel, Videographer
24   
25                         ----

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 1                    -  -  -  -  -
 2               (Thereupon, Plaintiff's Deposition
 3               Exhibit 1 through 4 were marked for
 4               purposes of identification.)
 5                    -  -  -  -  -
 6               THE VIDEOGRAPHER:  Today's date is
 7   November 5, 2003.  We are on the record at
 8   2:32.
 9              Would the Notary please swear the
10   witness?
11              PAUL C. VENIZELOS, M.D., of lawful
12   age, called for examination, as provided by the
13   Ohio Rules of Civil Procedure, being by me
14   first duly sworn, as hereinafter certified,
15   deposed and said as follows:
16        EXAMINATION OF PAUL C. VENIZELOS