Begins Ends Testimony
6:2 8:19 Dr. Syms’ Schedule

At the deposition of Dr. Mark J. Syms, Ms. Peters, the attorney for the plaintiff, asked Dr. Syms to provide his schedule of times and locations worked. Ms. Syms, Dr. Syms’ attorney, objected to some of Ms. Peters’ questions, stating that they were not specific enough. Ms. Peters clarified that she was asking for Dr. Syms’ schedule of times and locations worked. Ms. Syms stated that Dr. Syms had already provided this information, but that they were still working on getting the specific document that Ms. Peters requested. Ms. Peters stated that she would reserve her objection to keeping the deposition open for testimony regarding Dr. Syms’ schedule.

Ms. Peters’ questions about Dr. Syms’ schedule suggest that she is trying to gather information about Dr. Syms’ whereabouts on a specific date or dates. Ms. Syms’ objections to Ms. Peters’ questions suggest that she believes that Ms. Peters is trying to get information that is not relevant to the case. The fact that Ms. Peters is willing to keep the deposition open suggests that she believes that the information she is seeking is important to her case.

The deposition will continue at a later date, when Ms. Peters and Ms. Syms will continue to discuss Dr. Syms’ schedule. It is possible that Ms. Peters will be able to obtain the specific document that she requested, which would provide her with more detailed information about Dr. Syms’ schedule. If Ms. Peters is able to obtain this information, it could be helpful to her case.

 

8:20 9:17 Dr. Syms’ Certifications, Licenses, and Practice History

At the deposition of Dr. Mark J. Syms, Ms. Peters, the attorney for the plaintiff, asked Dr. Syms about his certifications, licenses, and practice history. Dr. Syms stated that he is board-certified in otolaryngology head and neck surgery and neurotology, and that he is licensed to practice medicine in Arizona and California. Dr. Syms also stated that he practiced medicine in Honolulu, Hawaii for two years after finishing his residency. Dr. Syms denied having any convictions or arrests.

Ms. Peters’ questions about Dr. Syms’ certifications, licenses, and practice history suggest that she is trying to establish Dr. Syms’ expertise and experience as a medical doctor. Dr. Syms’ answers to these questions suggest that he is a qualified and experienced medical doctor who has practiced medicine in multiple states.

The information that Dr. Syms provided about his certifications, licenses, and practice history is likely to be relevant to the case. The plaintiff is alleging that Dr. Syms was negligent in his care of the plaintiff, and the information that Dr. Syms provided about his qualifications and experience may be used to support or refute the plaintiff’s allegations.

 

9:18 12:17 Dr. Syms’ Involvement in Lawsuits

At the deposition of Dr. Mark J. Syms, Ms. Peters, the attorney for the plaintiff, asked Dr. Syms about his involvement in lawsuits. Dr. Syms stated that he has been a witness in one medical malpractice lawsuit and a party in two other lawsuits. In one of the other lawsuits, Dr. Syms was the plaintiff and accused the former chairman of the GOP of making false accusations about him and his wife. In the other lawsuit, Dr. Syms was the defendant and accused of collecting fraudulent signatures for a state Senate candidacy. Dr. Syms stated that he believes the signatures were invalid and that he was not on the ballot.

Ms. Peters’ questions about Dr. Syms’ involvement in lawsuits suggest that she is trying to establish Dr. Syms’ credibility as a witness. Dr. Syms’ answers to these questions suggest that he has been involved in lawsuits in the past, but that he has never been found liable for any wrongdoing.

The information that Dr. Syms provided about his involvement in lawsuits is likely to be relevant to the case. The plaintiff is alleging that Dr. Syms was negligent in his care of the plaintiff, and the information that Dr. Syms provided about his involvement in lawsuits may be used to support or refute the plaintiff’s allegations.

He was a witness in one medical malpractice lawsuit, a plaintiff in one lawsuit against the former chairman of the GOP, and a defendant in one lawsuit about fraudulent signature collection. Dr. Syms was not found liable for any wrongdoing in any of these lawsuits.

 

12:18 13:14 Dr. Syms’ Preparation for Deposition

At the deposition of Dr. Mark J. Syms, Ms. Peters, the attorney for the plaintiff, asked Dr. Syms about his preparation for the deposition. Dr. Syms stated that he spoke to his counsel for about 10 minutes yesterday afternoon and that he has looked at all of the discovery. Dr. Syms did not specify any specific documents that he looked at in preparation for the deposition.

Ms. Peters’ questions about Dr. Syms’ preparation for the deposition suggest that she is trying to establish whether Dr. Syms has had a fair opportunity to prepare for the deposition and whether he is aware of the allegations that the plaintiff is making against him. Dr. Syms’ answers to these questions suggest that he has had a fair opportunity to prepare for the deposition and that he is aware of the allegations that the plaintiff is making against him.

Dr. Syms spoke to his counsel for about 10 minutes the previous afternoon and that he has looked at all of the discovery in preparation for his deposition. Dr. Syms did not specify any specific documents that he looked at.

 

13:15 19:6 Dr. Syms’ Income and Business

Ms. Peters asked Dr. Syms about his income and business. Dr. Syms stated that he is paid a salary by Arizona Ear Center, which is the same entity as Arizona Hearing Center. He did not know his exact income from Arizona Ear Center in 2020, but he believes it was around $23,221. Dr. Syms also stated that he has other sources of income, but he does not know how much he earned from them in 2020.

Dr. Syms stated that business in 2022 was “okay, but nothing wonderful,” and that business in 2023 is the same. He attributed the slow business to the economic uncertainty and the high deductibles for commercial insurance.

Ms. Peters’ questions about Dr. Syms’ income and business suggest that she is trying to establish Dr. Syms’ financial motive. Dr. Syms’ answers to these questions suggest that he is not motivated by money, but that he is passionate about his work.

In summary, Dr. Syms is paid a salary by Arizona Ear Center, which is the same entity as Arizona Hearing Center. He does not know his exact income from Arizona Ear Center in 2020, but he believes it was around $23,221. Dr. Syms also stated that he has other sources of income, but he does not know how much he earned from them in 2020. Business in 2022 and 2023 was “okay, but nothing wonderful,” and Dr. Syms attributed the slow business to the economic uncertainty and the high deductibles for commercial insurance.

19:7 21:16 Dr. Syms’ income and business, and his discussions with Kory Castro about his wife Laura

Ms. Peters asked Dr. Syms about his income and business. Dr. Syms stated that he is paid a salary by Arizona Ear Center, which is the same entity as Arizona Hearing Center. He did not know his exact income from Arizona Ear Center in 2020, but he believes it was around $23,221. Dr. Syms also stated that he has other sources of income, but he does not know how much he earned from them in 2020.

Business in 2022 and 2023 was “okay, but nothing wonderful,” and Dr. Syms attributed the slow business to the economic uncertainty and the high deductibles for commercial insurance.

Ms. Peters also asked Dr. Syms about his discussions with Kory Castro about his wife Laura. Dr. Syms stated that he had several discussions with Kory about Laura, including discussions about her residency, her exposure to COVID-19, and her fellowship in Phoenix. Dr. Syms stated that he never had any discussions with Laura directly.

Dr. Syms’ income and business have been relatively stable in recent years, but he has been affected by the economic uncertainty and the high deductibles for commercial insurance. Dr. Syms also had several discussions with Kory Castro about his wife Laura, but he never had any discussions with Laura directly.

21:17 23:22 Relevant Information About Laura Castro

Ms. Peters asked Dr. Syms what relevant information he believes Laura Castro has related to his claims.

Dr. Syms stated that he thinks they already covered the deposition materials in Laura Castro’s deposition.

Ms. Peters asked why Dr. Syms deposed Laura Castro.

Dr. Syms stated that he did not depose her, but that she was deposed on his behalf because she is a named defendant in the lawsuit.

Ms. Peters asked if Dr. Syms believes Laura Castro has any relevant information about the lawsuit.

Dr. Syms stated that whatever information was discussed at the deposition is a fair accounting.

Ms. Peters asked if Dr. Syms can identify any specific information that he believes Laura Castro has that is relevant to the lawsuit.

Dr. Syms stated that he has not reviewed the transcript of the deposition and does not recollect the specifics.

Ms. Peters asked if Dr. Syms was at Laura Castro’s deposition.

Dr. Syms stated that he was.

Ms. Peters asked if Dr. Syms can explain why he decided to take Laura Castro’s deposition.

Dr. Syms stated that he is not sure what Ms. Peters is asking.

Ms. Peters asked if Dr. Syms can think of any relevant information that Laura Castro has that would explain why he decided to take her deposition.

Dr. Syms stated that he did not take Laura Castro’s deposition and that he cannot recollect any relevant information from her deposition.

Dr. Syms does not seem to be able to identify any specific information that Laura Castro has that is relevant to the lawsuit. However, he did depose her, so it is possible that there is some relevant information in the transcript of her deposition.

 

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At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, The LegalPen will be able to prepare the legal document within the shortest time possible. You can send us your quick enquiry ( here )