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Expert Witness : Laxminarayana Rao MD, FCCP


Case James Dexter vs. Baker Material Handling
Testimony Date September 12, 2003
Expert Type Pulmonary
Court State: Ohio County: Cuyahoga
Pages 108
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                                                                     1
               IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     JAMES DEXTER,
                Plaintiff,
          vs.                         Case No.
     BAKER MATERIAL HANDLING,         CV 03 491810
                Defendant.
     
                        ~ ~ ~ ~ ~
                 Videotape deposition of
     LAXMINARAYANA C. RAO, M.D., F.C.C.P., 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 the offices of Laxminarayana C.
     
     Rao, M.D., F.C.C.P., 7255 Old Oak Boulevard,
     
     Middleburg Heights, Ohio, on Friday, September
     
     12, 2003, at 11:37 o'clock a.m.
     
                        ~ ~ ~ ~ ~

                                                                     2
 1   APPEARANCES:
 2   
 3        On behalf of the Plaintiff:
 4              Kelley & Ferraro, L.L.P., by
 5              LORI A. LUKA, 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:
12              Ross, Brittain & Schonberg Co.,
13              L.P.A., by
14              THOMAS R. WYATT, ESQ.
15               DAVID T. ANDREWS, ESQ.
16              6000 Freedom Square Drive,
17              Suite 540
18              Cleveland, Ohio  44131-2547
19              (216) 447-1551
20                         ----
21   
22   ALSO PRESENT:
23              Shaun R. Lewis, Videographer
24                         ----
25   

                                                                     3
 1               MR. WYATT:  I'd just like to go on
 2   the record and object to any reference to the
 3   reports, B reading or any other findings of
 4   Dr. Phillip H. Lucas in that he will not
 5   testify in this matter and we are going to
 6   prepare a motion in limine to support that
 7   argument, but at the very least at the outset
 8   we're going to object to that.
 9               And also -- well, let's see what
10   else happens.  Just note an objection to that
11   and we'll move on.
12          (Discussion had off the record.)
13               MR. LEWIS:  We are on the rec