On August 10, 2016 a
Motion-Secondary
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.
Preview
LAW OFFICES OF MICHAEL J. LIBMAN, APC
MICHAEL J. LIBMAN (SBN 222353)
ZHANNA SANAMYAN (SBN 337133)
18321 Ventura Boulevard, Suite 700
Tarzana, California 9 1 356
Telephone: (818) 995-7300
Facsimile: (866) 644-6764 F l
mil@libmanlaw. com sgfimg‘g ggu'rST Er: COAL: FORNIA
SA
SAN BERNARD'ZECFfité’}?
GARY BERKOVICH (SBN 19273 1)
A PROFESSIONAL CORPORATION JUL 2 o 2022
14900 Ventura Boulevard, Suite 220
Sherman Oaks, California 91403 W 'Q
Telephone: (818) 465-9505
BY
Facsimile: (818) 358-2829 PAO E ‘
AN Z, DI:
lO Attorneys for Plaintiff, LORI BUSH
ll
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN BERNARDINO
l3
LORI BUSH, an individual; CASE NUMBER: CIVDSI613161
l4
Hon. John M. Pacheco
Plaintiff,
15 Dept: S31
vs.
16
TO
PLAINTIFF’S OPPOSITION
l7
DEFENDANT DIGNITY HEALTH’S
ST. BERNARDINE MEDICAL CENTER, a NOTICE OF MOTION AND MOTION
18 business entity form unknown; DIGNITY FOR JUDGMENT NOTWITHSTANDING
HEALTH, a California Corporation; and THE VERDICT PURSUANT TO CCP.
l9 DOES 1 through 200, inclusive SECTION 629
20 [FILED CONCURRENTLY WITH
Defendants. VVVVVVVVVVVVVVVVVVVVVVV
DECLARATION 0F MICHAEL J.
21 LIBMAN; REQUEST FOR JUDICIAL
NOTICE; EVIDENTIARY OBJECTIONS]
22
23 Date: August 30, 2022
Time: 8:30 a.m.
24
Dpt.: 831
25
26
27
28
TO DEFENDSNT DIGNITY HEALTH’S EX PARTE APPLICATION FOR PLAINTIFF’S OPPOSITION TO
PLAINTIFF’S OPPOSITION
DEFENDANT DIGNITY HEALTH’S NOTICE OF MOTION AND MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT
PURSUANT TO C.C.P. SECTION 629
TO THE HONORABLE COURT, DEFENDANTS AND THEIR RESPECTIVE
ATTORNEYS OF RECORD:
COMES NOW PLAINTIFF LORI BUSH and submits her Opposition to Defendant
DIGNITY HEALTH’s notice of motion and motion for judgment notwithstanding the verdict
(“Moti0n” or “JNOV”) pursuant t0 C.C.P. Section 629.
This Opposition is based upon the grounds that the Motion is untimely, the verdict is
supported by substantial evidence, and entry 0f judgment in favor of defendant notwithstanding
the jury’s verdict would amount to an improper jury nullification and miscarriage ofjustice.
This Opposition is further based upon the complete file and records in this action, the
10 attached Memorandum of Points and Authorities, the Declaration of Michael J. Libman, the
ll attached exhibits, and any and all documentary 0r oral evidence as may be presented at the time
12 of the hearing 0n this Motion.
l3
l4
15
16
DATED: July 19, 2022
By:
W
LAW OFFICES OF MICHAEL
fl.
J.
4th“ [E-Signature]
LIBMAN, APC
l7 MICHAEL J. LIBMAN
Attorneys for Plaintiff LORI BUSH
18
l9
20
21
22
23
24
25
26
27
28
2
TO DEFENDSNT DIGNITY HEALTH’S EX PARTE APPLICATION FOR PLAINTIFF’S OPPOSITION TO
PLAINTIFF‘S OPPOSITION
DEFENDANT DIGNITY HEALTH’S NOTICE OF MOTION AND MOTION FOR JUDGMENT NOTWITHSTANDTNG THE VERDICT
PURSUANT TO C.C.P. SECTION 629
Document Filed Date
July 20, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
LAW OFFICES OF MICHAEL J. LIBMAN, APC MICHAEL J. LIBMAN (SBN 222353) ZHANNA SANAMYAN (SBN 337133) 18321 Ventura Boulevard, Suite 700 Tarzana, California 9 1 356 Telephone: (818) 995-7300 Facsimile: (866) 644-6764 F l mil@libmanlaw. com sgfimg‘g ggu'rST Er: COAL: FORNIA SA SAN BERNARD'ZECFfité’}? GARY BERKOVICH (SBN 19273 1) A PROFESSIONAL CORPORATION JUL 2 o 2022 14900 Ventura Boulevard, Suite 220 Sherman Oaks, California 91403 W 'Q Telephone: (818) 465-9505 BY Facsimile: (818) 358-2829 PAO E ‘ AN Z, DI: lO Attorneys for Plaintiff, LORI BUSH ll SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF SAN BERNARDINO l3 LORI BUSH, an individual; CASE NUMBER: CIVDSI613161 l4 Hon. John M. Pacheco Plaintiff, 15 Dept: S31 vs. 16 TO PLAINTIFF’S OPPOSITION l7 DEFENDANT DIGNITY HEALTH’S ST. BERNARDINE MEDICAL CENTER, a NOTICE OF MOTION AND MOTION 18 business entity form unknown; DIGNITY FOR JUDGMENT NOTWITHSTANDING HEALTH, a California Corporation; and THE VERDICT PURSUANT TO CCP. l9 DOES 1 through 200, inclusive SECTION 629 20 [FILED CONCURRENTLY WITH Defendants. VVVVVVVVVVVVVVVVVVVVVVV DECLARATION 0F MICHAEL J. 21 LIBMAN; REQUEST FOR JUDICIAL NOTICE; EVIDENTIARY OBJECTIONS] 22 23 Date: August 30, 2022 Time: 8:30 a.m. 24 Dpt.: 831 25 26 27 28 TO DEFENDSNT DIGNITY HEALTH’S EX PARTE APPLICATION FOR PLAINTIFF’S OPPOSITION TO PLAINTIFF’S OPPOSITION DEFENDANT DIGNITY HEALTH’S NOTICE OF MOTION AND MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT PURSUANT TO C.C.P. SECTION 629 TO THE HONORABLE COURT, DEFENDANTS AND THEIR RESPECTIVE ATTORNEYS OF RECORD: COMES NOW PLAINTIFF LORI BUSH and submits her Opposition to Defendant DIGNITY HEALTH’s notice of motion and motion for judgment notwithstanding the verdict (“Moti0n” or “JNOV”) pursuant t0 C.C.P. Section 629. This Opposition is based upon the grounds that the Motion is untimely, the verdict is supported by substantial evidence, and entry 0f judgment in favor of defendant notwithstanding the jury’s verdict would amount to an improper jury nullification and miscarriage ofjustice. This Opposition is further based upon the complete file and records in this action, the 10 attached Memorandum of Points and Authorities, the Declaration of Michael J. Libman, the ll attached exhibits, and any and all documentary 0r oral evidence as may be presented at the time 12 of the hearing 0n this Motion. l3 l4 15 16 DATED: July 19, 2022 By: W LAW OFFICES OF MICHAEL fl. J. 4th“ [E-Signature] LIBMAN, APC l7 MICHAEL J. LIBMAN Attorneys for Plaintiff LORI BUSH 18 l9 20 21 22 23 24 25 26 27 28 2 TO DEFENDSNT DIGNITY HEALTH’S EX PARTE APPLICATION FOR PLAINTIFF’S OPPOSITION TO PLAINTIFF‘S OPPOSITION DEFENDANT DIGNITY HEALTH’S NOTICE OF MOTION AND MOTION FOR JUDGMENT NOTWITHSTANDTNG THE VERDICT PURSUANT TO C.C.P. SECTION 629