Preview
CV-2020-02-0578 ROWLANDS, MARY MARGARET 04/20/2022 11:55:53 AM DEPO Page 1 of 6
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
MICHAEL A. RENNE, as Guardian of ) Case No. CV-2020-02-0578
the Estate of LEVI LEON PATTERSON, )
a minor, and OLIVIA PATTERSON, ) Judge Mary Margaret Rowlands
Individually, )
Plaintiffs, ) PLAINTIFFS’ AMENDED NOTICE OF
) VIDEOTAPED DEPOSITION
v. )
)
SUMMA HEALTH d/b/a SUMMA )
HEALTH SYSTEM – AKRON )
CAMPUS, CHERYL JOHNSON, M.D., )
ASHLEY L. BALLESTER, M.D., )
MEREDITH BELLAMY, D.O., and )
SUMMA PHYSICIANS, INC. d/b/a )
SUMMA MEDICAL GROUP, )
)
Defendants. )
)
TO: Cheryl Johnson, M.D.
c/o Gregory T. Rossi, Esq.
Hanna Campbell & Powell, LLP
3737 Embassy Parkway
Suite 100
Akron, Ohio 44333
grossi@hcplaw.net
Comes now the Plaintiff, by and through counsel, and gives notice that the deposition of
Cheryl Johnson, M.D. will be taken on the 22nd day of April, 2022 beginning at 10:00 A.M.
EST. All parties will be attending remotely via Zoom as well as the court reporter and
videographer. The deposition will be recorded by video by the court reporter using Zoom’s
recording function, which will be considered the official video copy for the record. The official
video recording by the court reporter will “Pin” the screen of the deponent so that the video
recording will remain stationary at all times on the witness. However, if documents are shared
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 04/20/2022 11:55:53 AM DEPO Page 2 of 6
electronically, it will be side-by-side with the witness so that the witness can always be seen on
the recording.
The deponent will be sworn in remotely and the parties waive any objection that the
remote swearing in of the deponent is invalid. The deponent must present a valid ID for the court
reporter to verify her identity. All attorneys must be on a separate device with video so that their
faces can be seen at all times. The deponent will pan their video around the room before the
deposition starts so that everyone attending remotely can see the room setup, if anyone else is in
the room, etc.
Once the deposition starts, the deponent is to have their device positioned so their camera
shows them from the waist up and it must stay that way with the exception of viewing any
exhibits. The deponent will not have on a mask. The private 1-on-1 chat feature will be disabled
by the court reporter, who will be the Host of the meeting. As the deponent’s counsel will be in
the same room with the deponent, they must be distanced by 6 feet and be on a separate device as
the deponent so that counsel’s face can be seen at all times. The deponent will confirm that they
do not have any other devices near them and that her cell phone is either in her pocket or on the
floor under her chair.
This deposition is being taken pursuant to Rules 26 and 30 of the Ohio Rules of Civil
Procedure and will continue from time to time and place to place until completed.
DUCES TECUM
The deponent is requested to produce the following, electronically, no less than 24 hours
prior to the start of the deposition:
1. A current curriculum vitae.
2. Any and all written reports you have prepared in this case;
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 04/20/2022 11:55:53 AM DEPO Page 3 of 6
3. Any and all notes prepared by you, or for you, and any and all information
upon which you relied to formulate your opinions;
4. All invoices for services performed for any work related to this case;
5. A list of all documents records etc. you have reviewed in connection with
this case;
6. A list of all cases you have reviewed or in which you have acted as an
expert including the case name, party for which you reviewed or testified,
an the attorney who retained you;
7. Any literature you have reviewed in connection with this case regardless
of whether you plan to rely on it at trial.
8. Any other documents or evidence you intend to use at the trial of this case.
This the 20th day of April, 2022.
By: _____________________
GRANT & EISENHOFER P.A.
Lisa B. Weinstein *
IL State Bar No. 6290253
Edward J. Aucoin, Jr. *
IL State Bar No. 6236645
Kimberly M. Brancato *
IL State Bar No. 6317505
30 N. LaSalle St., Suite 2350
Chicago, IL 60602
(312) 610-5350
lweinstein@gelaw.com
eaucoin@gelaw.com
kbrancato@gelaw.com
*Pro Hac Vice admission
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 04/20/2022 11:55:53 AM DEPO Page 4 of 6
And
Pamela Pantages, Esq. (0046840)
Nurenberg Paris Heller & McCarthy, LPA
600 Superior Avenue East, Suite 1200
Cleveland, Ohio 44114
(216) 621-2300
ppantages@nphm.com
Attorneys for Plaintiffs
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 04/20/2022 11:55:53 AM DEPO Page 5 of 6
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
MICHAEL A. RENNE, as Guardian of ) Case No. CV-2020-02-0578
the Estate of LEVI LEON PATTERSON, )
a minor, and OLIVIA PATTERSON, ) Judge Mary Margaret Rowlands
Individually, )
) PLAINTIFFS’ AMENDED NOTICE OF
Plaintiffs, ) VIDEOTAPED DEPOSITION
)
v. )
)
SUMMA HEALTH d/b/a SUMMA )
HEALTH SYSTEM – AKRON )
CAMPUS, CHERYL JOHNSON, M.D., )
ASHLEY L. BALLESTER, M.D., )
MEREDITH BELLAMY, D.O., and )
SUMMA PHYSICIANS, INC. d/b/a )
SUMMA MEDICAL GROUP, )
)
Defendants. )
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have served the foregoing Plaintiffs’ Videotaped Notice of
Deposition of Cheryl Johnson, M.D., by submitting a copy thereof, via electronic mail, addressed
as follows:
Gregory T. Rossi, Esq. (0047595)
Rocco D. Potenza, Esq. (0059577)
Carol N. Tran, Esq. (0089192)
HANNA, CAMPBELL & POWELL, LLP
3737 Embassy Parkway
Suite 100
Akron, Ohio 44333
Phone: (330) 670-7300
grossi@hcplaw.net
rpotenza@hcplaw.net
ctran@hcplaw.net
Attorneys for the Defendants, Summa Health System, Summa Health, Summa Physicians,
Inc., Cheryl Johnson, M.D., Ashley L. Ballester, M.D. and Meredith Bellamy, D.O.
This the 20th day of April, 2022.
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 04/20/2022 11:55:53 AM DEPO Page 6 of 6
By: _____________________
GRANT & EISENHOFER P.A.
Lisa B. Weinstein *
IL State Bar No. 6290253
Edward J. Aucoin, Jr. *
IL State Bar No. 6236645
Kimberly M. Brancato *
IL State Bar No. 6317505
30 N. LaSalle St., Suite 2350
Chicago, IL 60602
(312) 610-5350
lweinstein@gelaw.com
eaucoin@gelaw.com
kbrancato@gelaw.com
*Pro Hac Vice admission
And
Pamela Pantages, Esq. (0046840)
Nurenberg Paris Heller & McCarthy, LPA
600 Superior Avenue East, Suite 1200
Cleveland, Ohio 44114
(216) 621-2300
ppantages@nphm.com
Attorneys for Plaintiffs
Sandra Kurt, Summit County Clerk of Courts