1
              IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     EDWARD SOVINE,
                Plaintiff,
          vs                         Case No
     FORD MOTOR COMPANY,              489948
                Defendants
     
                      - - - - -
                 Videotaped deposition of PRASADARAO
     G KONDAPALLI, MD, called for examination
     under the statute, taken before me, Claudine
     Kelly, a Registered Professional Reporter and
     Notary Public in and for the State of Ohio,
     
     pursuant to notice and stipulations of counsel,
     
     at the offices of Prasadarao G Kondapalli,
     
     MD, 18660 Bagley Road, Cleveland, Ohio, on
     
     Friday, October, 2003, at 1:30 pm
     
                      - - - - -

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

                                                                     3
 1               MR MORRISON:  We are on the
 2   record
 3               PRASADARAO G KONDAPALLI, MD, of
 4   lawful age, called for examination, as provided
 5   by the Ohio Rules of Civil Procedure, being by
 6   me first duly sworn, as hereinafter certified,
 7   deposed and said as follows:
 8    EXAMINATION OF PRASADARAO G KONDAPALLI, MD
 9   BY MR FROST:
10         Q    Doctor, would you introduce
11   yourself to the jury, please
12         A    My name is Prasadarao G
13   Kondapalli  I'm a physician practicing
14   pulmonary medicine and also critical care
15         Q    All right  Doctor, could you
16   describe your academic and professional
17   background for the jury, please
18         A    I am trained in pulmonary medicine
19   here in Cleveland City Hospital, what used to
20   be Metro hospital  And then practicing in the
21   west side of the Cleveland since 1980
22         Q    Okay  And, Doctor, when did you
23   first become licensed to practice medicine in
24   Ohio?
25         A    1978

                                                                     4
 1         Q    And could you tell the jury what
 2   board certification means?
 3         A    Board certification is given by the
 4   American Board of Internal Medicine and the
 5   have one for internal medicine  Then they have
 6   also pulmonary medicine  They have also
 7   critical care medicine  And on all those three
 8   boards I have, I am certified
 9         Q    Okay  When did you first become
10   board certified in internal medicine?
11         A    I think it is 1978
12         Q    Okay  And, Doctor, just very
13   briefly could you tell the jury what internal
14   medicine involves?
15         A    Internal medicine involves the
16   diagnosis and the treatment of medical
17   conditions of the medical diseases of various
18   kinds of various systems
19         Q    Okay  And another term that you
20   mentioned was pulmonary medicine  When did you
21   first become board certified in pulmonary
22   medicine?
23         A    1980 I was board certified in
24   pulmonary medicine
25         Q    And could you briefly tell the jury

                                                                     5
 1   what pulmonary medicine involves?
 2         A    Pulmonary medicine involves the
 3   treatment and diagnosis of the diseases and the
 4   conditions that affects the lungs
 5         Q    Okay  And the --
 6         A    And also other chest disease, chest
 7   disorders which can affect
 8         Q    Okay  And you also mentioned
 9   another area in which you were board certified
10   that was called critical care medicine, is that
11   correct?
12         A    Right
13         Q    Could you tell the jury, well,
14   first of all, when did you become board
15   certified in critical care medicine?
16         A    1987
17         Q    Okay  And what does critical care
18   medicine involve?
19         A    Critical care medicine involves the
20   diseases which effect the -- diseases effect
21   which critical care, intensive care and
22   management of the