Maria Syms, Esq. (#023019)
2627 North Third Street, Suite 201
Phoenix, AZ 85004
602-430-0472
symsaz@gmail.com
Attorney for Plaintiffs
Mark J. Syms, Arizona Ear Center, PC
dba Arizona Hearing Center

SUPERIOR COURT OF ARIZONA
IN MARICOPA COUNTY

MARK J. SYMS, ARIZONA EAR
CENTER, PC DBA ARIZONA HEARING
CENTER,
Plaintiffs
vs.
KORY CASTRO, LARA CASTRO, JOHN
AND JANE DOES 1-10, DOE
COMPANIES A-Z.,
Defendants

Case No. CV2021-019035

PLAINTIFF’S REQUEST FOR
PRODUCTION OF DOCUMENTS

PROPOUNDING PARTY: Plaintiffs Mark J. Syms, Arizona Ear Center, PC dba
Arizona

Hearing Center (hereinafter “Plaintiff”)

RESPONDING PARTY: Defendants Kory and Laura Castro (hereinafter “Defendants”)
SET NO.: One

Pursuant to Rule 26 and 34 of the Arizona Rules of Civil Procedure, Plaintiff requests
that Defendant Kory and Laura Castro (“Defendants”) produces the requested documents for
inspection and copying within thirty (30) days of service of this request at the address of said
Plaintiff.

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_____________________________________________________________________________________________

REQUEST FOR PRODUCTION OF DOCUMENTS

INSTRUCTIONS

1. Your written response shall state for each item, that inspection-related activities
will be permitted as requested unless the request is refused. In that event, the reasons for
refusal shall be stated. If the refusal relates to part of an item, that part shall be specified.
2. In accordance, the documents shall be produced in a logical and reasonable
manner, or you shall organize and label them to correspond with the categories in the request.
3. These requests shall encompass all items within your possession, custody, or
control.
4. These requests are continuing in character to require you to promptly amend or
supplement your response if you obtain further material information.
5. If in responding to these requests, you encounter any ambiguity in construing
any request, instruction, or definition, set forth the matter deemed ambiguous in the
construction used in responding.

DEFINITIONS

6. As used in these requests, the following terms are to be interpreted per these
definitions:
a) The term "person" includes any individual, joint-stock company, unincorporated
association, or society, municipal or other corporation, state, which agencies or political
subdivisions, and court or any other governmental entity.
b) The terms "you" or "your" include the person(s) to whom these requests are addressed,
and all that person's agents, representatives or attorneys.
c) In accordance, the terms, "document" or "documents" includes all writings, drawings,
graphs, charts, photographs, recordings, and any other data computations from which
information can be obtained, translated, if necessary, by (you) into a reasonably usable
form.
d) “Communication(s)”: The term “communication(s)” as used herein means any written or
oral contact, formal or informal, at any time or place, and under any circumstances

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_____________________________________________________________________________________________

REQUEST FOR PRODUCTION OF DOCUMENTS

whatsoever, whereby information of any nature was transmitted and transferred. It
includes, but is not limited to, meetings, telephone conversations, discussions, reports,
executive summaries, briefings, and oral requests for information. It includes, but is not
limited to, letters, notes, notices, pleadings and other legal filings, memoranda,
advertisements, post cards, and telegrams.
REQUESTS

REQUEST FOR PRODUCTION NO. 1:
All documents identified by you in response to each and every interrogatory in Plaintiff’s
First Set of Interrogatories.
RESPONSE:

REQUEST FOR PRODUCTION NO. 2:
All documents or data compilations that are in your possession, custody or control that you
may use to support your defenses.
RESPONSE:

REQUEST FOR PRODUCTION NO. 3:
All records (electronic documents, paper-based documents, audio recordings, police
dispatches, or video surveillance) in your possession, custody, or control relating to the
Plaintiff’s allegation(s) in the Complaint.
RESPONSE:

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_____________________________________________________________________________________________

REQUEST FOR PRODUCTION OF DOCUMENTS

REQUEST FOR PRODUCTION NO. 4:
Copies of any and all photographs, videotapes, moving pictures or any other audio or video
recording, diaries, logs, notes, calendars, letters, memoranda or any other document which
in any way support, detract from or are relevant to any of the issues in this matter.
RESPONSE:

REQUEST FOR PRODUCTION NO. 5:
Any notes, log or diary you or anyone else have ever made regarding this matter.
RESPONSE:

REQUEST FOR PRODUCTION NO. 6:
Copies of all periodicals, literature or textbooks which you contend support your theories in
this case.
RESPONSE:

REQUEST FOR PRODUCTION NO. 7:
All written reports of all potential witnesses with whom you or your attorneys have
consulted.

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_____________________________________________________________________________________________

REQUEST FOR PRODUCTION OF DOCUMENTS

RESPONSE:

REQUEST FOR PRODUCTION NO. 8:
The most recent resume or curriculum vitae of each expert whom you expect to call as an
expert witness at trial.
RESPONSE:

REQUEST FOR PRODUCTION NO. 9:
All notes, diagrams, photographs, or other documents prepared or reviewed in connection
with their assignment in this case by each person whom you expect to call as an expert
witness at trial.
RESPONSE:

REQUEST FOR PRODUCTION NO. 10:
All drafts, working papers or documents generated by each witness whom you intend to call
as an expert at trial in connection with the opinions and subjects on which the witness is
expected to testify.
RESPONSE:

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REQUEST FOR PRODUCTION OF DOCUMENTS

REQUEST FOR PRODUCTION NO. 11:
Each publication or paper that was written or worked on by each witness whom you intend
to call as an expert witness at trial, and which refers or relates to the opinions and subjects
on which the witness is expected to testify.
RESPONSE:

REQUEST FOR PRODUCTION NO. 12:
All correspondence between Kory Castro and Sonova concerning purchase and financing.
RESPONSE:

REQUEST FOR PRODUCTION NO. 13:
All correspondence and communications between Kory Castro and Beltone – its employees,
representatives, officers, managers , including without limitation Mike Halloran and Jon
Pomerantz regarding hearing aid dispensaries in Arizona.
RESPONSE:

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REQUEST FOR PRODUCTION OF DOCUMENTS

REQUEST FOR PRODUCTION NO. 14:
All correspondence and communications between Kory Castro and Audigy – its employees,
representatives, officers, managers , including without limitation Kim Gilmore, Sam Haney
and Cassie Schultz.

RESPONSE:

REQUEST FOR PRODUCTION NO. 15:
All correspondence and communications between Kory Castro and Randy McCall regarding
the potential acquisition of his hearing aid dispensary.
RESPONSE:

Dated: ____________

___________________________
Maria Syms, Esq.
2627 North Third Street, Suite 201
Phoenix, Arizona 85004
symsaz@gmail.com
Attorney for Plaintiffs

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REQUEST FOR PRODUCTION OF DOCUMENTS
CERTIFICATE OF SERVICE

I hereby certify a copy of the foregoing has been served upon the Defendants’ counsel via
[STATE MEANS OF SERVICE] to the following address on record on this [ENTER
DATE].

Kristy L. Peters
Carlos B. Gutierrez
LITTLER MENDELSON, P.C.
Attorneys for Defendants

Dated: ____________

___________________________
Maria Syms, Esq.
2627 North Third Street, Suite 201
Phoenix, Arizona 85004
symsaz@gmail.com
Attorney for Plaintiffs

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