On February 24, 2016 a
Stipulation,Agreement
was filed
involving a dispute between
Enriquez, Vicente Guerrero,
and
Koudsi M.D., Nabil,
Koudsi Medical, Inc., A California Corporation,
for Complaint for Medical Malpractice
in the District Court of San Bernardino County.
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1 WALKER MANN LLP
Douglas K Mann State Bar No 157897
2 dmarui walkermann com
Jeffrey A Walker State Bar No 179734
3 iwalker c walkermann com s t C r r t isA
Alyssa S Mortensen State Bar No 309598 ot a 3 d
4 amortensennwalkermann com
10832 Laurel Street Suite 204
5 Rancho Cucamonga California 91730
Telephone 909 989 3200 A
6 Facsimile 909 697 2182 gy
ANT4 I Cv AP 1 tN Dr
Attorneys for Defendant
NABIL KOUDSI MD
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN BERNARDINO CENTRAL DISTRICT
11
12 VICENTE GUERRERO ENRIQUEZ Case No CI DS 1602709
13 Plaintiff Assigned for All Purposes to
Hon Judge Donald Alvarez
14 v
Dept S23
15 NABIL KOUDSI MD KOUDSI MEDICAL STIPULATI N RE PAST ME ICAL
INC a California corporation and DOES 1 SPECIAL DAMAGES AND LI ITING
16 through 100 inclusive PLAINTIFF S RECOVERABL DAMAGES
TO APPLICABLE POLICY LI ITS
17 Defendants
18
19 Complaint Filed 2 24 2016
Trial Date 5 30 2018
20
21 TO ALL PARTIES AND THEIR RESPECTIVE COUNSEL OF RECORD
22 Defendant NABIL KOUDSI MD Plaintiff VICENTE
and GUERRERO RIQUEZ by
23 and through their respective counsel of recard agree as follows
24
In that the parties do not dispute the amount paid by Medi Cal for Plaintiff s al eged expenses
25
associated with the medical care received by Plaintiff following Dr Koudsi s surg ry the parties
26 stipulate that in the Plaintiff is the prevailing party in this
event
action the Court is add the total
27 medical expenses paid Medi Cal
by post trial to a proposed judgment for 154 181 5 No further
28 proof of these damages will be necessary
1
STIPULATION
1008Q7 pOCX 081 181
1
In exchange for this agreement Plaintiff VICENTE GUERRERO ENRIQ EZ agrees to
2 waive
any judgment amount which may the
exceed
1 000 000 00 insurance policy 1 mit afforded to
3 Defendant NABIL KOUDSI MD The parties stipulate that the Court is to con uct a post trial
4 reduction of
any Plaintiff s for damages
verdict to 1 000 OOO QO inclusive of all non economic
5 damages economic damages for past and future medical expense economic dama es for past and
future loss of earnings and
earning capacity costs
Any such reduction pursuant to his stipulation
shall follow any other post trial reductions including a motion to reduce non eco omic damages
g pursuant to Civil Code 3333 2
9
10
11 DATED May 30 2018 WALKER MANN LLP
12
13 d L
By
Douglas K Mann
14 Alyssa S Mortensen
Attorneys for Defendant
15
NABIL KOUD SI MD
16
17 DATED May 30 2018 DAVID H RICKS ASSOCIATES
18
19
gy
20 DAVID H RICKS Esq
Attorneys for Plaintiff
21 VICENTE GUERRERO ENRIQ EZ
22
23
24
25
26
27
28
2
STIPULATION
100807 DOCX1081 18
Document Filed Date
May 30, 2018
Case Filing Date
February 24, 2016
Category
Complaint for Medical Malpractice
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f 1 WALKER MANN LLP Douglas K Mann State Bar No 157897 2 dmarui walkermann com Jeffrey A Walker State Bar No 179734 3 iwalker c walkermann com s t C r r t isA Alyssa S Mortensen State Bar No 309598 ot a 3 d 4 amortensennwalkermann com 10832 Laurel Street Suite 204 5 Rancho Cucamonga California 91730 Telephone 909 989 3200 A 6 Facsimile 909 697 2182 gy ANT4 I Cv AP 1 tN Dr Attorneys for Defendant NABIL KOUDSI MD 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO CENTRAL DISTRICT 11 12 VICENTE GUERRERO ENRIQUEZ Case No CI DS 1602709 13 Plaintiff Assigned for All Purposes to Hon Judge Donald Alvarez 14 v Dept S23 15 NABIL KOUDSI MD KOUDSI MEDICAL STIPULATI N RE PAST ME ICAL INC a California corporation and DOES 1 SPECIAL DAMAGES AND LI ITING 16 through 100 inclusive PLAINTIFF S RECOVERABL DAMAGES TO APPLICABLE POLICY LI ITS 17 Defendants 18 19 Complaint Filed 2 24 2016 Trial Date 5 30 2018 20 21 TO ALL PARTIES AND THEIR RESPECTIVE COUNSEL OF RECORD 22 Defendant NABIL KOUDSI MD Plaintiff VICENTE and GUERRERO RIQUEZ by 23 and through their respective counsel of recard agree as follows 24 In that the parties do not dispute the amount paid by Medi Cal for Plaintiff s al eged expenses 25 associated with the medical care received by Plaintiff following Dr Koudsi s surg ry the parties 26 stipulate that in the Plaintiff is the prevailing party in this event action the Court is add the total 27 medical expenses paid Medi Cal by post trial to a proposed judgment for 154 181 5 No further 28 proof of these damages will be necessary 1 STIPULATION 1008Q7 pOCX 081 181 1 In exchange for this agreement Plaintiff VICENTE GUERRERO ENRIQ EZ agrees to 2 waive any judgment amount which may the exceed 1 000 000 00 insurance policy 1 mit afforded to 3 Defendant NABIL KOUDSI MD The parties stipulate that the Court is to con uct a post trial 4 reduction of any Plaintiff s for damages verdict to 1 000 OOO QO inclusive of all non economic 5 damages economic damages for past and future medical expense economic dama es for past and future loss of earnings and earning capacity costs Any such reduction pursuant to his stipulation shall follow any other post trial reductions including a motion to reduce non eco omic damages g pursuant to Civil Code 3333 2 9 10 11 DATED May 30 2018 WALKER MANN LLP 12 13 d L By Douglas K Mann 14 Alyssa S Mortensen Attorneys for Defendant 15 NABIL KOUD SI MD 16 17 DATED May 30 2018 DAVID H RICKS ASSOCIATES 18 19 gy 20 DAVID H RICKS Esq Attorneys for Plaintiff 21 VICENTE GUERRERO ENRIQ EZ 22 23 24 25 26 27 28 2 STIPULATION 100807 DOCX1081 18