DCR-3003 (415) 777-1190 - Ventura County Star

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FAITRO v. SHAMAAN IHSAN NAJIB SHAMAAN, M.D. 12/20/2011 09:58:55 1 MS. CARLSON: Good morning. Sandra Carlson on 09:58:55 2 behalf of defendant Simi Valley Hospital. 09:58:57 3 MS. THOMASSON: Christie Thomasson for Michael 09:58:57 4 Drucker, M.D. 09:58:57 5 MR. ROBERTSON: Alex Robertson for plaintiffs. 09:58:57 6 MR. WALKER: And John Walker for the plaintiffs. 09:59:22 7 Shall we swear the witness? 09:59:22 8 09:59:22 9 IHSAN NAJIB SHAMAAN, M.D., 09:59:22 10 having been duly sworn, was examined and 09:59:22 11 testified as follows: 12 09:59:22 13 BY MR. WALKER: E X A M I N A T I O N 09:59:22 14 Q Dr. Shamaan, have you ever had your deposition 09:59:24 15 taken before? 09:59:25 16 A Yes. 09:59:26 17 Q I'm going to repeat a couple of things just so 09:59:29 18 we have a clear record here. Do you understand that you 09:59:32 19 are under oath to tell the truth today? 09:59:35 20 A Correct. 09:59:36 21 Q And that's under penalty of perjury; do you 09:59:38 22 understand that? 09:59:38 23 A I understand. 09:59:39 24 Q What do you understand the word to mean that 09:59:41 25 you are under penalty of perjury? (818) 706-3749 www.DCRLitigationServices.com (800) DCR-3003 (415) 777-1190 (805) 497-0046 21
FAITRO v. SHAMAAN IHSAN NAJIB SHAMAAN, M.D. 12/20/2011 09:59:45 1 A If I lie I could go to jail. 09:59:48 2 Q Is there any reason why you feel that you 09:59:50 3 cannot give your truthful, best, honest answers today? 09:59:54 4 A Correct. 09:59:55 5 Q Is that your intent to do that? 09:59:56 6 A Yes. 09:59:57 7 Q Are you under the influence of any kind of 09:59:59 8 medications today that would affect your abilities to 10:00:01 9 understand the questions or to give your best testimony? 10:00:03 10 A I take medications for high blood pressure and 10:00:06 11 diabetes, but they will not affect my memory or my 10:00:11 12 ability to answer questions or alertness. 10:00:15 13 Q Do you have any pressing engagements or 10:00:17 14 anything that's occurring outside of this room that would 10:00:20 15 affect your abilities to give your best, accurate 10:00:22 16 testimony today; in other words, things that you are 10:00:24 17 worried about or disturbed about that are distracting you 10:00:24 18 from understanding the questions and giving your best 10:00:29 19 testimony? 10:00:29 20 A No. 10:00:34 21 Q Doctor, we've come here to talk about a case 10:00:37 22 that I understand you are involved in with Laura Faitro. 10:00:41 23 And is there anything that strikes you as being important 10:00:47 24 concerning Ms. Faitro and the case? 10:00:57 25 MR. DE HERAS: Objection, vague and ambiguous. (818) 706-3749 www.DCRLitigationServices.com (800) DCR-3003 (415) 777-1190 (805) 497-0046 22
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REPORTER'S CERTIFICATE I, Debra Lyn
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DCR-3003 (415) 777-1190 - Ventura County Star

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