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, MD, 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
     
     pm
     
                        - - - - -

                                                                     2
 1   APPEARANCES:
 2   
 3        On behalf of the Plaintiff:
 4              Kelley & Ferraro, LLP, 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                         ----

                                                                     3
 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, MD, 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, MD
17   BY MR WYMAN:
18         Q    Good afternoon, Doctor  My name is
19   Brian Wyman  I know we've met before  I
20   represent the Plaintiff in this case, Alonzo
21   Luster, in his case against Ford Motor Company,
22   and we do have a few questions for you today
23               Before we begin, could you please
24   state your name for the record?
25         A    Paul Venizelos

                                                                     4
 1         Q    Now, Doctor, I'm going to hand you
 2   what's been previously marked as Plaintiff's
 3   Exhibit 4, and could you identify that to the
 4   jury?
 5         A    It's my curriculum vitae
 6         Q    Now, Doctor, could you give us a
 7   brief description of your educational
 8   background starting with college?
 9         A    Yes  I -- from 1968 to 1972, I
10   attended Northwestern University and received a
11   bachelor's of arts in chemistry  From there
12   went to Ohio State School of Medicine from 1972
13   to 1975 where I received the medical -- medical
14   doctor's degree
15              Went from there to the Cleveland
16   area and did an internship and residency at
17   Cleveland -- then called "Cleveland
18   Metropolitan General Hospital" affiliated with
19   Case Western Reserve's University School of
20   Medicine, and did an internship and residency
21   in internal medicine there  Then went back to
22   the Chicago area in -- in 1978 and did a
23   two-year pulmonary disease fellowship at the
24   University of Illinois at Chicago
25         Q    Now, Doctor, are you licensed to

                                                                     5
 1   practice medicine in the State of Ohio?
 2         A    Yes
 3         Q    And how long have you been licensed
 4   to practice medicine in Ohio?
 5         A    Since 1975
 6         Q    And are you a member of any
 7   professional organizations?
 8         A    Yes  Member of the American
 9   Thoracic Society, the American College of Chest
10   Physicians, and the American Academy of Sleep
11   Medicine
12         Q    And, in addition, Doctor, have you
13   authored any kind of articles pertaining to
14   lung diseases or conditions?
15         A    Yes, I have
16         Q    And what were some of the topics of
17   those articles?
18         A    Most of that research was done in
19   Chicago at Department of Env