14. During my entire career, no patient has ever died on my table. I have also never been found liable for the death of any patient, or engaged in a "patient surgery accident:  I understand that the Defendants' false statements about this relate to the death of a former patient, Ms. Swarthout. The unfortunate circumstances of her death are confidential and not relevant to this case. However. she neither passed away on my table nor in my operating room or office. She did not even pass away on the day of her surgery with me but rather several days later at a hospital when I was not present. Ms. Swarthout's survivors filed a lawsuit following her death, but as public records show, this lawsuit was settled with no admission of liability.

15. I have never been found liable of medical malpractice. In my more than 15 years of practice, as is very common among plastic surgeons, I have been a defendant in medical malpractice lawsuits. In each of these lawsuits, however, I either defeated the case by defense verdict or the actions were voluntarily dismissed by the plaintiff: mutually resolved with no admission of liability, or remain pending. Each of these civil cases can be found by a case search and are public records so I believe anyone who wishes to obtain information about their status can easily do so online.