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                                                                     1
               IN THE COURT OF COMMON PLEAS
                 OF CUYAHOGA COUNTY, OHIO
     
     
     RICHARD D. NICHOLSON,
                 Plaintiff,
           vs.                           Case No.
     FORD MOTOR COMPANY, et al.,         474760
                 Defendants.
     
     
                         ~ ~ ~ ~ ~
                 Videotaped and video conference 
     deposition of JAY S. THOMPSON, M.D., called for 
     examination under the statute, taken before me, 
     Nancy L. Molnar, 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 ******** Reporting 
     Services, 1301 East Ninth Street, Suite 2500, 
     Cleveland, Ohio, on Thursday, February 20, 2003 
     at 12:00 o'clock p.m.
                         ~ ~ ~ ~ ~
     
     

                                                                     2
 1   APPEARANCES:
 2   
 3         On behalf of the Plaintiff:
 4               Kelley & Ferraro, by
 5               ROBERT A. MARCIS, ESQ.
 6               1300 East Ninth Street
 7               Cleveland, Ohio  44114
 8               (216) 575-0777
 9   
10         On behalf of the Defendants:
11               Rademaker, Matty, McClelland & 
12               Greve, by
13               KIRK R. HENRIKSON, ESQ.
14               55 Public Square, Suite 1775
15               Cleveland, Ohio  44113
16               (216) 621-6570
17                      ~ ~ ~ ~ ~
18   
19   ALSO PRESENT: (Via teleconference)
20               Mr. Patrick VonAhn, Videographer   
21                      ~ ~ ~ ~ ~
22   
23   
24   
25   

                                                                     3
 1               (Whereupon, the following is off 
 2   videotape.)
 3               MR. MARCIS:  Bob Marcis, on behalf 
 4   of the Plaintiff, Mr. Nicholson, we object to 
 5   the use of Dr. Thompson.  His report was 
 6   provided to us by fax on February 18.  The 
 7   actual report is dated February 18.  Trial for 
 8   this matter is set February 27.  
 9               The first time we've ever received 
10   a report, approximately a week before trial.  
11   We would object to his testimony going forward 
12   at all.  We have a -- well, I'll let Kirk 
13   respond to that then I'll respond to him.
14