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Expert Witness : Laxminarayana Rao MD


Case Gladstone Thompson vs. LTV Steel Company, et al.
Testimony Date October 31, 2003
Expert Type Pulmonary
Court State: Ohio County: Cuyahoga
Pages 95
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                                                                     1
               IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     GLADSTONE THOMPSON,
                Plaintiff,        Case No.
                                  CV 03 493152
          vs.
     LTV STEEL COMPANY, et al.,
                Defendants.
     
                        - - - - -
                 Videotaped deposition of
     LAXMINARAYANA C. RAO, M.D., called for
     examination under the statute, taken before me,
     Jill A. Kulewsky, a Court Reporter and Notary
     Public in and for the State of Ohio, by
     agreement of counsel, at the offices of
     
     Pulmonary Medicine Associates, 8255 Old Oak
     
     Boulevard, Middleburg Heights, Ohio, on Friday,
     
     October 31, 2003, at 10:25 o'clock a.m.
     
                        - - - - -

                                                                     2
 1   APPEARANCES:
 2   
 3        On behalf of the Plaintiff:
 4              Kelley & Ferraro, L.L.P., by:
 5               SHAWN M. ACTON, ESQ.
 6               1901 Penton Media Building
 7               Cleveland, Ohio  44114
 8               (216) 575-0777
 9   
10   
11        On behalf of the Defendants:
12              Rademaker, Matty, McClelland &
13              Greve, by:
14               THOMAS GREVE, ESQ.
15               55 Public Square, Suite 1775
16               Cleveland, Ohio  44113
17               (216) 621-6570
18   
19                         ----
20   
21        ALSO PRESENT:
22              Shaun Lewis, Videographer
23                         ----
24   
25   

                                                                     3
 1                    -  -  -  -  -
 2               (Thereupon, Plaintiff's Deposition
 3               Exhibit A, B, C, D, E, F, G, H and I
 4               were marked for purposes of
 5               identification.)
 6                    -  -  -  -  -
 7               MR. ACTON:  This is Shawn Acton on
 8   behalf of the Plaintiff, Mr. Thompson.
 9   Unfortunately I'm at a loss with regard to
10   specific dates because I don't have the entire
11   file on me, but I will tell you a long time ago
12   Plaintiff propounded Discovery upon the
13   Defendant Administrator consisting of Requests
14   for Admissions, First Request for Production of
15   Documents and First Set of -- or Set of
16   Interrog