On August 10, 2016 a
Party Discovery
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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F
A
Fl
DISC030
ATTORNEYOR PARTY WITHOUT ATTORNEY Name State Barnum6er
andadd2ss FOR COURT USEONLY
Diane Mar JViesmann SB 124409
Thomp son i Colegate LLP
3420 Fourteenth StreLeOtP O Box 299 Riverside CA 92502
1
TELEPHONE NO 7S1 V OZ SSSO FAX NOOptionaq
9S 1 IH1 40 I Z
E MAILADDRESSOptionaq
ATTORNEY FOR Nme DEFENDANT DIGNITY HEALTH
SUPERIOR Cl URT OF CAUFOLRNIA COUNTY OF SAN BERNARDINO
STREETADDRES3 2 F7 W TlLllyd S eet
1
MAILINGADDRESa G4 W Tlllyd S Eet
CITYANDZIPCOD San Bernardino CA 92415
B Nc NAM Justice Center
SHORT TITLE
Bush V Dignity Health
CASE NUMBER
COMMIISSION TO TAKE DEPOSITION OUTSIDE CALIFORNIA
CIVDS 1613161
O ORIDERED BY COURT ISSUED BY THE CLERK OF THE COURT
1 The Superior Gourt of California hereby authorizes the deposition
upon orai examination of identity of deponent
Custodian of Records for Spring Valley Hospital Medical Center 5400 S Rainbow Blvd Las Vegas NV
89118 702 853 3000
2 The depositior is to be takenin state of the United Statesterritory
or insular possession subject to its jurisdiction
Clark Counity Nevada
3 The deposition will be conducted check one
a Under the supervision of aperson who is authorized to administer oaths by the laws of the United States or those of the
place where the examination is to be held and who is not otherwise disqualified under California Code of Civil Procedure
sections2025 320 and 2025 340 b or
b 0 Befc re name ofappointee ROnSin photOCOpy SeTvtCe
who is appointed to administer oaths and to take testimony
4 The documen ts or things to be produced at the time andplace of the deposition are
0 described in Attachment 4 none
5 Additional terrris
required by the foreign jurisdiction to initiate the process are contained in
Attachment 5 Number of pages
attached
6 Under California Code of Civil Procedure section 2026 010 California authorizes that a
commission to take an out of state
deposition maV be issued by the clerfc of the
court orif the foreign jurisdiction requires it
by order of the court
7 The Superior ourt of the State of California hereby requests that process issue in the above referenced place where the
examination is to be he1d requiring the aitendance and enfiorcing the obligations of the deponent to produce documents and
answer questi ms
Date
d J1 Gt 1V 1 1 VlS
I
Judge
OR
Clerk by Deputy
CouK Seal
Page 1 of 1
Formnpprovedtoroptiona use COMMISSION TO TAKE CodeCiv Proc
g2o2s oo n
uRiNo ca gov
oscoso jNeWa arey i zoos DEPOSITION OUTSIDE CALIFORNIA
Bush v I ignity Health
Case No CIVDS 1613161
ATTACHMENT 4
The records to be produced are described as follows
THE RE CORDS REQUESTED ARE regardless of date FOR THE FOLLOWING TYPES OF
RECORI S ANY AND ALL MEDICAL RECORDS DOCUMENTS MEDICAL REPORTS
INCLU ING DOCTORS ENTRIES NURSES CHARTS PROGRESS REPORTS
PHYSICAL THERAPY REGORDS PATHOLOGY REPORTS ALL FILMS ORIGINAL X
RAY FII MS MRI S CT SCANS INCLUDING ANY FILMS IMAGES THAT MAY BE
STOREI DIGITALLY ELECTRONICALLY X RAY REPORTS LAB REPORTS CASE
HISTORY EMERGENCY ROOM RECORDS ADMITTING SHEETS SPECIAL TESTS
INPATIF INT AND OUTPATIENT RECORDS AND ANY SIGN IN SHEETS PERTAINING
TO THE CARE AND TREATMENT DIAGNOSIS PROGNOSIS CONDITION
DISCHARGE ALL BILLINGS STATEMENTS OF ACCOUNTS WRITINGS AND
DOCUM ENTS REFLECTING THE FOLLOWING ANY AND ALL PAYMENT MADE OR
RECEIVED ANY AND ALL CREDITS ADJUSTMENTS WRITE OFFS
RECONCILIATIONS CONTRACT PRICE PAYMENTS OR REDUCTION PAYMENTS BY
ANY HEALTH INSURANCE ENTITY PERSONAL PAYMENTS BY OR TO SAID
PATIEN T FROM ANY SOURCE HMO PPO MEDI CAL MEDIGARE OR CONTRACT
PAYME vTS BY ANY ENTITY CONCERNING SAID PATIENT BILLING LEDGERS
REPORT S DOCUMENTS THAT MAY BE STORED DIGITALLY AND OR
ELECTR ONICALLY INCLUDING ALL PATIENT ORDERS AND PATIENT RESULTS
AND SPIECIFICALLY FOR ANY DISCHARGE ORDERS ALL DETAILED SCREEN
SHOTS JVITHIN ANY COMPUTER SYSTEM IN REFERENCE TO LORI LASHON BUSH
DOB 1 11 1957 SS xxx xxx 1718
Document Filed Date
March 02, 2018
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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F A Fl DISC030 ATTORNEYOR PARTY WITHOUT ATTORNEY Name State Barnum6er andadd2ss FOR COURT USEONLY Diane Mar JViesmann SB 124409 Thomp son i Colegate LLP 3420 Fourteenth StreLeOtP O Box 299 Riverside CA 92502 1 TELEPHONE NO 7S1 V OZ SSSO FAX NOOptionaq 9S 1 IH1 40 I Z E MAILADDRESSOptionaq ATTORNEY FOR Nme DEFENDANT DIGNITY HEALTH SUPERIOR Cl URT OF CAUFOLRNIA COUNTY OF SAN BERNARDINO STREETADDRES3 2 F7 W TlLllyd S eet 1 MAILINGADDRESa G4 W Tlllyd S Eet CITYANDZIPCOD San Bernardino CA 92415 B Nc NAM Justice Center SHORT TITLE Bush V Dignity Health CASE NUMBER COMMIISSION TO TAKE DEPOSITION OUTSIDE CALIFORNIA CIVDS 1613161 O ORIDERED BY COURT ISSUED BY THE CLERK OF THE COURT 1 The Superior Gourt of California hereby authorizes the deposition upon orai examination of identity of deponent Custodian of Records for Spring Valley Hospital Medical Center 5400 S Rainbow Blvd Las Vegas NV 89118 702 853 3000 2 The depositior is to be takenin state of the United Statesterritory or insular possession subject to its jurisdiction Clark Counity Nevada 3 The deposition will be conducted check one a Under the supervision of aperson who is authorized to administer oaths by the laws of the United States or those of the place where the examination is to be held and who is not otherwise disqualified under California Code of Civil Procedure sections2025 320 and 2025 340 b or b 0 Befc re name ofappointee ROnSin photOCOpy SeTvtCe who is appointed to administer oaths and to take testimony 4 The documen ts or things to be produced at the time andplace of the deposition are 0 described in Attachment 4 none 5 Additional terrris required by the foreign jurisdiction to initiate the process are contained in Attachment 5 Number of pages attached 6 Under California Code of Civil Procedure section 2026 010 California authorizes that a commission to take an out of state deposition maV be issued by the clerfc of the court orif the foreign jurisdiction requires it by order of the court 7 The Superior ourt of the State of California hereby requests that process issue in the above referenced place where the examination is to be he1d requiring the aitendance and enfiorcing the obligations of the deponent to produce documents and answer questi ms Date d J1 Gt 1V 1 1 VlS I Judge OR Clerk by Deputy CouK Seal Page 1 of 1 Formnpprovedtoroptiona use COMMISSION TO TAKE CodeCiv Proc g2o2s oo n uRiNo ca gov oscoso jNeWa arey i zoos DEPOSITION OUTSIDE CALIFORNIA Bush v I ignity Health Case No CIVDS 1613161 ATTACHMENT 4 The records to be produced are described as follows THE RE CORDS REQUESTED ARE regardless of date FOR THE FOLLOWING TYPES OF RECORI S ANY AND ALL MEDICAL RECORDS DOCUMENTS MEDICAL REPORTS INCLU ING DOCTORS ENTRIES NURSES CHARTS PROGRESS REPORTS PHYSICAL THERAPY REGORDS PATHOLOGY REPORTS ALL FILMS ORIGINAL X RAY FII MS MRI S CT SCANS INCLUDING ANY FILMS IMAGES THAT MAY BE STOREI DIGITALLY ELECTRONICALLY X RAY REPORTS LAB REPORTS CASE HISTORY EMERGENCY ROOM RECORDS ADMITTING SHEETS SPECIAL TESTS INPATIF INT AND OUTPATIENT RECORDS AND ANY SIGN IN SHEETS PERTAINING TO THE CARE AND TREATMENT DIAGNOSIS PROGNOSIS CONDITION DISCHARGE ALL BILLINGS STATEMENTS OF ACCOUNTS WRITINGS AND DOCUM ENTS REFLECTING THE FOLLOWING ANY AND ALL PAYMENT MADE OR RECEIVED ANY AND ALL CREDITS ADJUSTMENTS WRITE OFFS RECONCILIATIONS CONTRACT PRICE PAYMENTS OR REDUCTION PAYMENTS BY ANY HEALTH INSURANCE ENTITY PERSONAL PAYMENTS BY OR TO SAID PATIEN T FROM ANY SOURCE HMO PPO MEDI CAL MEDIGARE OR CONTRACT PAYME vTS BY ANY ENTITY CONCERNING SAID PATIENT BILLING LEDGERS REPORT S DOCUMENTS THAT MAY BE STORED DIGITALLY AND OR ELECTR ONICALLY INCLUDING ALL PATIENT ORDERS AND PATIENT RESULTS AND SPIECIFICALLY FOR ANY DISCHARGE ORDERS ALL DETAILED SCREEN SHOTS JVITHIN ANY COMPUTER SYSTEM IN REFERENCE TO LORI LASHON BUSH DOB 1 11 1957 SS xxx xxx 1718