On August 10, 2016 a
Party Statement
was filed
involving a dispute between
Bush, Lori,
Dignity Health, A Califonia Corporation,
and
Dignity Health, A Califonia Corporation,
St. Bernadine Medical Center A Business Entity Unknown,
Total Professional Network, Inc,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
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FILED
SUPERIOR COURT
OUNTY OF SAN BERNARDINO
i MICHAEL J LIBMAN SBN 222353
SAN BERNARDINO DISTFICT
LAW OFFICES OF MICHAEL J LIBMAN APC
Z 18321 Ventura Boulevard Suite 700 MAR 1 9 2018
I arzana California 91356
3 y
Telephone 818 995 7300
p ty
Facsimile 866 644 6764
q
mjl tr libmanla n com
5
GARY BERKOVICfI SBN 192731
A YROP ESSIONAL CORPORATION
14900 Ventura Boulevard Suite 220
Sherman Oaks California 91403
1 elephone S1A 465 9505
K Pacsimile 818 358 282
Attorneys for Plaintiff LO1tI BUSH Q
9
10
11
SUPERIOR COURT OF THE STATE Ol CALIFORNIA
12
FOK THE COUNTY OF SAN BERNARDINO SAN BERNARDI iO DISTRICT
13
14 CASE NO CNDS1613161
LORI I3USH an individual
15 As signeJtolforz lohn 4 Pacheco DeptS3
p gjptiff
16 DECLARATION OF PLAINTIFF LORI
BUSH IN SUPPOR C OF NLAIN 1 INF S
17 OPPOS1T10N TO DEFENDAN I S
ST BERNARDINE MEDICAL CENTER a
business entity form unknown DIGNITY MOTION FOR SUMMARY
18 H ALTH a California Corporation and ADJUDICATION
DO S I through 200 inclusive
I9 FII ED CONCURRENTLY WITH THE MEMORANDUh1
OF POINTS AND AUTHORITIES DECLARATIONS OF
I 0f2llC atttS
7O MICHAEL LII3MAN CARLOS BUSH I SPONSIVE
SEYARATl3 STA1 EV1liN 1 SEY 422A7 E S PA 1 EMEN P
zl ANDREQULSTFORNDiCIA1 NOTICB
DIGNITYHEALTH
ZZ
Cross Complaina it Date Apri12 2018
Time 8 30 a m
23 Dept S31
v
24
Action filed 0811 0 20 1 6
Trial Date None
25
fOTAL PROFESSIONAL NETWORK INC Discovery Cutoff Per CCP
and ROES 1 100 inclusive Motion Cutoff Per CCP
26
Cross Defendants
Z
28
1
DECLAIiATION O LORI USH
1 DECLARA CION OF LORI BUSH
I LORI BUSH declare as follows
z
1 I am the Plaintiff in this mattec I have personal knowledge of the facts set forth
3
4 herein and if called upon as a witness could and would testify competently thereto
2 Between August 19 20I5 and August 25 2015 I stayed in patient at St
5
6 Bernardive EIospital room 474 There was one batl room iu my room I slipped and fell in t ie
bathroom of my room on large amount of water wltich accumulated around the toilet due to the
8 negiigence of and premises liability of Dignity Health I reinjured my back in the fall and am now
9 permanently disabted I was wheeled out of Dignity s hospital in a lot worse shape than I walked
lU in due to Dignity s neglrgcnce in maintenance and use of its premises
ll
3 At the time of my stay I did not see any signs warnings or notices anywhere in the
1Z room or outside the door of the baChroom indicating thxt the baflu ooin was designated for patient
13 use only
4 At uo time did anyone from the Hospital s staff ever informcd me or my husband
14
5 that he was not allowed to use the bathroom inside my room
5 At no time did I obseive anyone Prom DefendanYs nursing staff admonish my
16
t
husband to rePrain from using the bathroom in my room
18
6 I did obsei e my husband use the bathroom in the presence of the hospital s staff
19 member
20 I declare under penalty of perjury under thc laws of the State of California that the
Z
foregoing is true and correct
Executed thi day of vlarch 2018 at Tarzana California
22
23
A l c L
ZQ LOR BUSH
25
26
27
28
1
DECLARATION OF LORI BUSfi
Document Filed Date
March 19, 2018
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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FILED SUPERIOR COURT OUNTY OF SAN BERNARDINO i MICHAEL J LIBMAN SBN 222353 SAN BERNARDINO DISTFICT LAW OFFICES OF MICHAEL J LIBMAN APC Z 18321 Ventura Boulevard Suite 700 MAR 1 9 2018 I arzana California 91356 3 y Telephone 818 995 7300 p ty Facsimile 866 644 6764 q mjl tr libmanla n com 5 GARY BERKOVICfI SBN 192731 A YROP ESSIONAL CORPORATION 14900 Ventura Boulevard Suite 220 Sherman Oaks California 91403 1 elephone S1A 465 9505 K Pacsimile 818 358 282 Attorneys for Plaintiff LO1tI BUSH Q 9 10 11 SUPERIOR COURT OF THE STATE Ol CALIFORNIA 12 FOK THE COUNTY OF SAN BERNARDINO SAN BERNARDI iO DISTRICT 13 14 CASE NO CNDS1613161 LORI I3USH an individual 15 As signeJtolforz lohn 4 Pacheco DeptS3 p gjptiff 16 DECLARATION OF PLAINTIFF LORI BUSH IN SUPPOR C OF NLAIN 1 INF S 17 OPPOS1T10N TO DEFENDAN I S ST BERNARDINE MEDICAL CENTER a business entity form unknown DIGNITY MOTION FOR SUMMARY 18 H ALTH a California Corporation and ADJUDICATION DO S I through 200 inclusive I9 FII ED CONCURRENTLY WITH THE MEMORANDUh1 OF POINTS AND AUTHORITIES DECLARATIONS OF I 0f2llC atttS 7O MICHAEL LII3MAN CARLOS BUSH I SPONSIVE SEYARATl3 STA1 EV1liN 1 SEY 422A7 E S PA 1 EMEN P zl ANDREQULSTFORNDiCIA1 NOTICB DIGNITYHEALTH ZZ Cross Complaina it Date Apri12 2018 Time 8 30 a m 23 Dept S31 v 24 Action filed 0811 0 20 1 6 Trial Date None 25 fOTAL PROFESSIONAL NETWORK INC Discovery Cutoff Per CCP and ROES 1 100 inclusive Motion Cutoff Per CCP 26 Cross Defendants Z 28 1 DECLAIiATION O LORI USH 1 DECLARA CION OF LORI BUSH I LORI BUSH declare as follows z 1 I am the Plaintiff in this mattec I have personal knowledge of the facts set forth 3 4 herein and if called upon as a witness could and would testify competently thereto 2 Between August 19 20I5 and August 25 2015 I stayed in patient at St 5 6 Bernardive EIospital room 474 There was one batl room iu my room I slipped and fell in t ie bathroom of my room on large amount of water wltich accumulated around the toilet due to the 8 negiigence of and premises liability of Dignity Health I reinjured my back in the fall and am now 9 permanently disabted I was wheeled out of Dignity s hospital in a lot worse shape than I walked lU in due to Dignity s neglrgcnce in maintenance and use of its premises ll 3 At the time of my stay I did not see any signs warnings or notices anywhere in the 1Z room or outside the door of the baChroom indicating thxt the baflu ooin was designated for patient 13 use only 4 At uo time did anyone from the Hospital s staff ever informcd me or my husband 14 5 that he was not allowed to use the bathroom inside my room 5 At no time did I obseive anyone Prom DefendanYs nursing staff admonish my 16 t husband to rePrain from using the bathroom in my room 18 6 I did obsei e my husband use the bathroom in the presence of the hospital s staff 19 member 20 I declare under penalty of perjury under thc laws of the State of California that the Z foregoing is true and correct Executed thi day of vlarch 2018 at Tarzana California 22 23 A l c L ZQ LOR BUSH 25 26 27 28 1 DECLARATION OF LORI BUSfi