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Richard W. Lund, SBN 120844
1 PLAGEMAN, LUND & CANNON LLP
One Kaiser Plaza, Suite 1440
2 Oakland, CA 94612 ELECTRONICALLY
Telephone: (510) 899-6100
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Facsimile: (510) 899-6101
F I L E D
Superior Court of California,
County of San Francisco
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Attorneys for Respondent and Successor Trustee 01/06/2020
5 Michael F. Hirner Clerk of the Court
BY: MICHAEL RAYRAY
Deputy Clerk
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF SAN FRANCISCO
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10 In re:
Case No. PTR-19-302798
11 Vishwas Narurkar Trust dated
(TRUST CONTEST) DECLARATION OF
12 January 24, 2019 RICHARD W. LUND IN SUPPORT OF MOTION
BY MICHAEL HIRNER FOR SUMMARY
13 JUDGMENT OR IN THE ALTERNATIVE
SUMMARY ADJUDICATION
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Date: May 20, 2020
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Time: 2:00 p.m.
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Dept: 204
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2305.4
(TRUST CONTEST) DECLARATION OF RICHARD W. LUND RE MOTION FOR SUMMARY JUDGMENT
1 I, Richard W. Lund, declare:
2 1. I am a competent adult resident of the State of California. I have personal knowledge of
3 each and every fact stated in this declaration, and could competently testify thereto if I were
4 called as a witness at trial.
5 2. I am an attorney at law licensed to practice in the State of California. I am a partner at
6 the law firm of Plageman, at Lund & Cannon LLP (the “Firm”), attorneys of record for Michael F.
7 Hirner in the above captioned matters.
8 3. The Firm issued to Queen of the Valley Hospital in Napa, California, a business records
9 subpoena seeking all medical records of Vishwas A. Narurkar (“Vic”) in connection with his
10 hospitalization there in January 2019. Attached as Exhibit 1 is a true and correct copy of a
11 relevant portion of the business records produced by Queen of the Valley Hospital in response
12 to the subpoena, consisting of:
13 • Exhibit 1-A, the Custodian of Records Affidavit from the responding party dated 7-16-
14 2019;
15 • Exhibit 1-B, an “ED Summary Report” dated 4-12-2019; and
16 • Exhibit 1-C, a “History & Physical Report” for service date 1/21/2019.
17 4. Exhibit 1-A establishes that the documents in Exhibit 1 are accurate copies of
18 business records of Queen of the Valley Medical Center, maintained in the ordinary course of
19 business, by authorized persons at or near the time of the events described.
20 5. Exhibit 1-B indicates that Vic arrived at Queen of the Valley medical center on 1-
21 20-2019 at 2318, or 11:18 p.m. that evening.
22 6. Exhibit 1-C indicates that (i) a birthdate for Vic of 1-31-1968 was reported to
23 Queen of the Valley Medical Center; (ii) based on medical chart review, Vic was “without any
24 significant past medical history or any traditional athererosclerotic risk factors” and that “The
25 patient is a dermatologist who is relatively active and free of any significant medical problems.”
26 7. The Firm issued to UCSF Medical Center in San Francisco, California, a
27 business records subpoena seeking all medical records of Vishwas A. Narurkar in connection
28 with his hospitalization there in January 2019. Attached as Exhibit 2 is a true and correct copy
2305.4
DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 2
1 of a relevant portion of the business records produced by UCSF Medical Center in response to
2 the subpoena, consisting of:
3 • Exhibit 2-A, the Declaration of Custodian of Records Affidavit from the responding party
4 dated 6-4-2019;
5 • Exhibit 2-B, bates pages 186-187 from the UCSF production, Stephanie Auffrey, MD,
6 progress notes for date of service 1-23-2019 at 11:24 am;
7 • Exhibit 2-C, bates page 66 from the UCSF production, Raymond Bamvi Fohtung, MD,
8 Consult notes for date of service 1-23-2019 at 4:54 pm;
9 • Exhibit 2-D, bates pages 1155-1156 from the UCSF production, Authorization for
10 Surgery signed by Vic dated 1-24-2019, 12:08 pm;
11 • Exhibit 2-E, bates pages 174-175 from the UCSF production, Jessica Clemtns, NP,
12 Progress Notes for date of service 1-24-2019 at 4:03pm;
13 • Exhibit 2-F, bates pages 50-51 from the UCSF production, Raymond Bamvi Fohtung,
14 MD, Consult notes for date of service 1-24-2019 at 8:07pm;
15 • Exhibit 2-G, bates pages 5-6 from the UCSF production, Discharge Summary by
16 Mallory J. Flynn, PA-C, filed 1-29-2019 at 8:12 pm.
17 8. The medical records excerpted in Exhibit 2 bracket the time period immediately
18 before, between and after the January 23 and 24, 2019 meetings between Vic and his attorneys
19 Cannon and Pankow.
20 9. Exhibit 2-A establishes that the documents in Exhibit 2 are accurate copies of
21 business records of UCSF Medical Center, maintained in the ordinary course of business, by
22 authorized persons at or near the time of the events described.
23 10. Exhibit 2-B shows the Progress Note by Stephanie Auffrey, MD for date of
24 service 1/23/2019 at 11:24am (about 3 hours prior to Jan 23 meeting), stating in relevant part:
25 • “Subjective: No specific complaints. No pain. Asking questions about etiology of cardiac
issues.”
26 • “Constitutional: He is oriented to person, place and time. He appears well-developed
and well nourished. No distress.”
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• “Neurological: He is alert and oriented to person, place and time.”
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2305.4
DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 3
1 11. Exhibit 2-C shows the Consult notes by Raymond Bamvi Fohtung, MD for date of
2 service 1/23/2019 at 4:54 pm (about 90 minutes after Jan 23 meeting), stating in relevant part:
3 • “Subjective: Dr. Narurkar states he is doing well and denies any significant pain.”
• “Physical Exam. Gen: no acute distress”
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12. Exhibit 2-D shows the Authorization for Surgery executed by Vic on 1/24/2019 at
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12:08 pm (about 2.5 hours before Jan 24 meeting), showing that:
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7 • UCSF determined that Vic was in a condition to execute a written consent to his heart
surgery at this time
8 • Signed consent acknowledges Vic received and understood an explanation of the risks
from Dr. Stephanie Auffrey
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10 13. Exhibit 2-E shows the Progress Notes by Jessica Clements, NP, for date of
11 service 1/24/2019 at 4:03 pm (about 1 hour after Jan 24 meeting), stating in relevant part:
12 • “Subjective: Pt denies pain, shortness of breath, and states he is very comfortable at
this time.”
13 • “Constitutional: He is oriented to person, place, and time.”
• “Neurological: He is alert and oriented to person, place and time.”
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15 14. Exhibit 2-F shows the Consult notes by Raymond Bamvi Fohtung, MD for date of
16 service 1/24/2019 at 8:07 pm (about 5 hours after Jan 24 meeting), stating in relevant part:
17
• “Subjective: No major complaints.”
18 • “Physical Exam. Gen: no acute distress”
19 15. Exhibit 2-G shows the Discharge Summary by Mallory J. Flynn, PA-C, filed 1-29-
20 2019 at 8:12 pm, which confirms several of the relevant timeline dates: transfer to UCSF on 1-
21 21-2019, surgery on 1-26-2019, as of 1-29-2019, despite being off sedation for 48 hours, not
22 conscious (i.e., no movement, no cough, no gag and pupils fixed and dilated), family meeting at
23 3 pm on 1-29-2019 where decision made to transfer to comfort care, and Vic pronounced dead
24 at 7:02pm on 1-29-2019.
25 16. Attached as Exhibit 3-A is a true and correct copy of the Requests for
26 Admissions Set One (RFA), served by Petitioner on Leela Narurkar (Leela) on July 23, 2019, in
27 the related Trust Petition matter, San Francisco probate court case number PTR-19-302798,
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2305.4
DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 4
1 omitting the voluminous Attachment 2 of the request, which attached copies Vic’s estate
2 planning documents. Attached as Exhibit 3-B is a true and correct copy of Leela Narurkar’s
3 verified response to this RFA, dated September 5, 2019.
4 17. Request 17 of the RFA asked Leela to admit that “At the time of Vic’s death,
5 Leela knew that Vic and Mike Hirner had been together as a couple for approximately 18 years.”
6 Leela’s response to this RFA 17 was: “Deny”. Request 18 of the RFA asked Leela to admit that,
7 “For approximately 18 years prior to Vic’s death, Vic publicly acknowledged that he was in a
8 same-sex couple relationship with Mike Hirner.” Leela’s response to this RFA 18 was:
9 “Responding paarty does not have sufficient personal information on which to admit or deny this
10 request, and on that basis deny.”
11 18. Attached as Exhibit 4-A is a true and correct copy of the Form Interrogatories –
12 General, Set One (Form Interrogatories), served by Petitioner on Leela on July 23, 2019, in the
13 related Trust Petition matter, San Francisco probate court case number PTR-19-302798.
14 Attached as Exhibit 4-B is a true and correct copy of Leela’s verified response to the Form
15 Interrogatories, dated September 5, 2019.
16 19. Form Interrogatory 17.1 asked Leela to state all facts, and identify supporting
17 witnesses and documents, as to any responses to the RFA in Exhibit 3-A and 3-B that were not
18 an unqualified admission, which would include Request 17 and 18 of the RFA. As to Request
19 17 of the RFA, Leela’s Form Interrogatory response was: “b) Responding party did not know the
20 nature and extent of Michael Hirner’s relationship with her son.” As to Request 18 of the RFA,
21 Leela’s Form Interrogatory response was “b) Responding Party has no personal knowledge on
22 which to base a response to this request. Responding party did not know the nature and extent
23 of Michael Hirner’s relationship with her son.”
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2305.4
DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 5
1 I declare under penalty of perjury under the laws of the State of California that the
2 foregoing is true and correct. Executed this 30th day of December, 2019, at Oakland,
3 California.
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T,:,t44...TQA).044.19_
_________________________
5 Richard W. Lund
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2305.4
DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 6
EXHIBIT 1-A
CUSTODIAN OF RECORDS AFFIDAVILi
I THE UNDERSIGNED, AM THE DULY AUTHORIZED CUSTODIAN OF
RECORDS FOR QUEEN OF THE VALLEY HOSPITAL - MEDICAL RECORDS DEPARTMENT
(A) THE RECORDS PERTAINING TO: Vsshwas Narurkar
I
c
3ATE OF BIRTH 1/31/1962
(B) THAT, INCLUDNG THIS CERTIFICATION, ALL RECORDS' CALLED FOR IN THE
ATTACHED SUBlipENA OR AUTHORIZATION ARE IN MY CUSTODY AND HAVE
BEEN RELEASED FOR DOCUMENTATION TO THE DEPOSITION OFFICER
(C)THAT TO THE BEST OF MY KNOWLEDGE, ALL RECORDS WERE PREPARED
IN THE NORMAL COURSE OF BUSINESS BY AUTHORIZED PERSONS AT OR NEAR
THE TIME OF THd ACT, CONDITION OR EVENT
'I
I DECLARE UNDER THE PENALTY OF PERJURY THAT THE FOREGOING IS
TRUE AND CORR1 CT
EXECUTED ON 1 -1G-1cit a19 AT
•
4Sk .\•Lk,
TYPE OR PRINT CUSTODIAN NAME
,DO NOT CHECK ANYTHING BELOW UNLESS NO RECORDS ARE AVAILABLE
CERTIFICATE OF NO: X-RAYS BILLING RECORDS PATHOLOGY OTHER
I
El LOST El DESTROYED 0 MISFILED MISPLACED Ei NEVER TREATED
111.1•1111111C
•
AFFIDAVIT OF PROFESSIONAL PHOTOCOPIER
I DECLARE UNDER PENALTY OF PERJURY THAT IAM AN EMPLOYEE OF ADVANCED MICROSYSTEMS
AND THAT THE RECORDS CALLED FOR IN THE SUBPOENA OR AUTHORIZATION ARE TRLIBC6PIES OF RECORDS
PRODUCED TO ME BY'llHE DUB:ID:FAN OF RECORDS FOR THE FACILITY NAMED ABOVE' AND THAT 'THESE
RECORDS WILL BE'DISTRIBUTED TO THE AUTHORIZED PERSONS OR ENMES.
EXECUTED ON 2019 AT
SIGNED
TYPEolePRINT PtioiocoPiEPSMI PHOTocOPEERS Statannin
[—I The Custodian was recluttted to-sign this certificate at the time of document production
1.-- 1 and refused to sign or generate a simillar document
DATE. ORDER: 429207
EXHIBIT 1-B
DATE: 04/12/19 @ 0038 Northern California EDX *LIVE* PAGE 1
USER: LEEJ002 ED Sunmary Report
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1030 CAROLINA ST
SAN FRANCISCO, CA 94107
415-923-3373
Insurance: Blue Shield PPO PCP: Physician Not On Staff
Neat of Kin: HIRNER,MICHAEL Family Doctor:
Relation: Significant Other Referring:
Phone: 415-722-4862
GENERAV
..
ED Physician: Lopez,Nicholas R, ACT Arrival Date/Time: 01/20/19 - 2318
Practitioner: Triage Date/Tine:
Nurse: Rios,Linda M, RN Date of Birth: 01/31/1968
Stated Complaint: SOB, FIB
ADM Reason For Visit: STEHI, VSD
Chief Complaint: Cardiovascular Priority: 2
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02, 20.19-?2,16 2ime.Jblaug
Isolation Recomaended Standard
Sepsis Screen No Definite Risk
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02/20,1 2326 Zw.Jolene
History Of Present Illness Biba from home with tachycardia, sob, back pain
Illr
No Known Allergies
(NWT MOME-,m
No Active Prescriptions or Reported Meds.
EIGHT
...
......•••••.....
IMIFM1 41f yl
07,7170179 2.716 lomdbleae
Height (Feet) 5
Height (Inches) 10
Height Measurement Method Stated
Weight (Calculated Kilograa) 80.910
EXHIBIT 1-C
Queen of the Valley
1000 Trances Street
Napa, CA 94558
History & Physical Report
Patient Name: NARURKAR,VISHWAS DOB: 01/31/1968
Account #: QV0087805174 Age/Sex: 501M
Unit #: QM02622967 Location: NQMICUS / NQM3410
Admitting Dr: Villalon,Mark L Admit/Service Date: 01/21/19
Ordering Dr:
Dictating Dr: Saman Hayatdavoudi MD
Primary Dr: Physician Not On Staff
Job: 091086 / 4703319 / HBE137917
DATE OF ADMISSION: 01/21/2019
STAT CRITICAL CARE ADMISSION
CHIEF COMPLAINT: The patient with ST elevation myocardial infarction, currently intubated, sedated,
unable to really give a history.This is all per chart review.
HISTORY OF PRESENT ILLNESS: This 50-year-old male without any significant past medical history or
any traditional atherosclerotic risk factors, who presented with upper back discomfort. The patient
currently is intubated and sedated, however, developed respiratory failure. The patient is a dermatologist
who is relatively active and free of any significant medical problems.On January 16, the patient reports
onset of upper back pain and symptoms were intermittent and mild In intensity; however, he was able to
work throughout those next few days and on the 21st, he visited Napa from his native San Francisco,
California and had a massage to try to relieve the symptoms of his back. However, around 9:30 p.m., he
reported onset worsening back pain, malaise, diaphoresis for which 911 was notified. In the ER, he was
found to have a rapid AFib and anterolateral infarct and ST elevation in addition to lateral ST elevation
and inferior ST depressions. The patient was given adenosine 6 mg IV to attempt to restore normal sinus
rhythm, but had no effect. He developed runs of nonsustained V-tech that did not require shock.
Therefore, the patient did go to the cath lab, which revealed delayed presentation of ST elevation
myocardial infarction, status post successful IVUS-guided PCI of the mid distal LAD with insertion of 2
overlapping drug-eluting stents, residual intermediate disease throughout the RI, left circumflex, and right
coronary artery. The patient also had a ventricular septal defect with apical thrombosis.The left
ventricular ejection fraction was 20% to 25% in a hypokinetic pattern consistent with ischemic
cardiomyopathy_ The patient also had elevated left-sided filling pressures and status post successful
MAC with intraaortic balloon pump insertion. The patient also had insertion of a triple lumen catheter via
the right femoral vein, and the patient currently is on a heparin drip as well as eptifibatide drip and the
P2Y12 inhibitor therapy is on hold in anticipation of VSD repair.The patient currently is being evaluated
by UCSF for transfer for further evaluation and management. The patient currently is on dopamine as
well as Levophed. The patient otherwise is unable to give me a review of systems as the patient is
currently intubated. The patient does follow simple commands, however, is unable to give me a review of
systems secondary to the patient's clinical condition.
PAST MEDICAL HISTORY: None.
History & Physical Report Patient Name: NARURKAR,VISHWAS
Report Status: Signed Account #: QV0087805174
Unit #: QM02622967 Dictating Dr: Saman Hayatdavoudi MD
Report #: 0121-0031
Page 1 of 3
EXHIBIT 2-A
LOCATION: VC 01 1ediC4
RECORDS PERTAIN TO: kic r Kgr
DECLARATION OF CUSTODIAN OF RECORDS
(Pursuant to California Evidence Code Section 1561)
I am the duly authorized Custodian of Records and I state that the
records were prepared in the ordinary course of business and that:
all records requested are in my custody and have been released;
records do exist, but none within.the time frame listed In the request;
an records within the time period listed in the request have been destroyed;
a search was performed and no records requested were found. (Please
explain below)
I declare under penalty of perjury that the foregoing is true and
correct under the laws of California.
Executed on C-14 11 9 atCnelti,t)t I tD , California.
•
By:
Name: Vul c&A-k-A- Title: fkA- I t1
Phone Number (A l is' -3 r3- 259/
Records from UCSF Medical Center (Narurkar) 000001
EXHIBIT 2-B
6425 CHRISTIE AVE FL 4 Narurkar, Vishwas
UOaF Medical Center EMERYVILLE CA 94608- MRN: 66513459, DOB: 1/31/1962, Sex: M
UOSF Bei-aloft Chltdren's Hospite 1092 Adm: 1/21/2019, D/C: 1/29/2019
Inpatient Record
Progress.Notes - Encounter Rotei (Zontirtued)
Progress Notes by Jessica Clements, NP at 1/24/2019 4:03 PM (continued) Version 1 of 2
[Endo]
- ISS
Patient and plan discussed with Cardiac Surgery Attending, GEORG MAXIMILLIAN
WIESELTHALER, MD.
Jessica Clements, NP
01/24/19, 4:03 PM
Electronically signed by Jessica Clements, NP at 1/24/2019 4:12 PM
Progress Notes by Stephanie Auffrey, MD at 11231201911:24 AM Version 1 of 1
Author:Stephanie Auffrey, MD Service:
Cardiac Surgery Author Type: Resident
Filed: 1/23/2019 11:27 AM Date of Service: 1123/2019 11:24 AM Status:
Signed
Editor:
Stephanie Auffrey, MD (Resident)
_CARDIAC SURGERY PROGRESS NOTE
ID:
56M with no significant PMH who presented to OSH 1/20 with chest pain and was found to have
STEMI and severe cardiomyopathy (thought secondary to large ischemic event), now s/p PCI and
IABP at OSH, and was transferred to UCSF 1/21 for higher level care.
Admitted: 1/21/2019
24 HOUR EVENTS:
1/23: Plan for OR 1/25. Dc'd Plavix. CRRT -25.
1/22: STAT TEE, Insulin gtt to ISS, CXR with L pulm edema, CRRT -25, extubated, plan for OR next
week. CRRT to even overnight with tachycardia and rising lactate.
1/21: Transferred from Queen of Valley in PM.
SUBJECTIVE:
No specific complaints. No pain. Asking questions about etiology of cardiac issues.
OBJECTIVE:
24-hour Vitals:
ieart Rate: [80-96] 91
*Resp: [17-44] 18
Arterial Line BP (mmHg) : (92-125)/(39-53) 96/39
Printed on 6/4/19 6:32 AM Page 185
Records from UCSF Medical Center (Narurkar) 000186
6425 CHRISTIE AVE FL 4 Narurkar, Vishwas
InSF Medical Center EMERYVILLE CA 94608- MRN: 66513459, DUB: 1/31/1962, Sex: M
1092 Adm: 1/21/2019, D/C: 1/29/2019
BenioliChEaren's Hospital Inpatient Record
Progress Notes - Encoimter Notes(cOntiitued)
Progress Notes by Stephanie Auffrey, MD at 1123/201911:24 AM (continued) Version 1 of 1
F102 (%): [40 %] 40 %
SpO2: [96 %-100 %] 100 %
Physical Exam:
Physical Exam
Constitutional: He is oriented to person, place, and time. He appears well-developed and well-
nourished. No distress.
HENT:
Head: Normocephalic and atraumatic.
Cardiovascular: Normal rate and regular rhythm.
Pulmonary/Chest: Effort normal. No respiratory distress.
Abdominal: Soft. He exhibits no distension.
Left groin soft and without evidence of hematoma.
Musculoskeletal: He exhibits no edema.
Neurological: He is alert and oriented to person, place, and time.
Skin: Skin is warm and dry.
Vitals reviewed.
Admission Weight: 83.8 kg (184 lb 11.9 oz)
'1st Recent Weight: 83.3 kg (183 lb 10.3 oz)
There is no height or weight on file to calculate BMI.
I/O last 2 completed shifts plus current shift:
In: 3642.59 [P.O.:110; I.V.:3107.59; NG/GT:20; IV Piggyback:405]
Out: 4140 [Urine:265; Drains/NG:100; Other:3775]
Medications:
Continuous Infusions:
• amiodarone 0.5 mg/min (01/23/19 1100)
• dextrose
• dextrose 5 % and 0.2 % sodium Stopped (01/22/19 0800)
chloride
• dextrose 5 % and 0.45 % sodium 10 mUhr (01/23/19 1100)
chloride
• DOPamine 4 mcg/kg/min (01/23/19 1100)
• heparin flush for iabp pump 3 Units/hr (01/23/19 1100)
• heparin 19 Units/kg/hr (01/23/19 1100)
• norEPINEPHrine 0.04 mcg/kg/min (01/23/19 1117)
• pureflow 2,000 mUhr (01/23/19 0627)
Scheduled Meds:
• sodium chloride 3 mL Intravenous Q8H SCH
flush
• aspirin 81 mg Per OG Tube Daily (AM)
Printed on 6/4/19 6:32 AM Page 186
Records from UCSF Medical Center (Narurkar) 000187
EXHIBIT 2-C
6425 CHRISTIE AVE FL 4 Narurkar, Vishwas
UCSF Medical Center EMERYVILLE CA 94608- rviRN: 66513459, DOB: 1/31/1962, Sex: M
1092 Adm: 1/21/2019, D/C: 1/29/2019
Selloff ChiNren's Hospit Inpatient Record
Consults Encounter•Notes (continued)
Consults by Raymond Bamvi Fohtung, MD at 1/23/2019 4:54 PM (continued) Version 2 of 2
PGY5 I Cardiology Fellow
Electronically signed by Francesca Nesta Delling, MD at 1/24/2019 12:05 PM
Consults by Raymond Bamvi Fohtung, MD at 1/23/2019 4:54 PM Version 1 of 2
Author Raymond Bamvi Fohtung, MD Service:
Cardiology Author Type: Resident
1/23/2019 5:12 PM
Filed: Date of Service:
1/2312019 4:54 PM Status. Cosign Needed
Editor: Raymond Bamvi Fohtung, MD (Resident)
Related Notes: Addendum by Raymond Bamvi Fohtung, MD (Resident) filed at 1/23/2019 5:13 PM
Cosign Required: Yes
CARDIOLOGY CONSULT FOLLOW-UP NOTE
24 Hour Course
- Extubated.
- on levo 0.06 and dobamine 4. Lactate stable around 2.5. SVO2 stable in the 50s.
- Having some NSVT last night. Given some calcium and fluid removal with dialysis stopped with
some improvement in NSVT.
- CVP 13-16. UOP 170 cc. Drains 100 cc. Dialysis 3.4L. Net negative 500 cc.
- Balloon pump in place. Augmented diastolic 85. MAPs in 60s.
Subjective
- Dr. Narurkar states he is doing well and denies any significant pain.
Vitals
Heart Rate: [86-96] 86
*Resp: [17-34] 22
Arterial Line BP (mmHg) : (92-125)/(38-53) 106/41
Most Recent Weight: 83.3 kg (183 lb 10.3 oz)
Admission Weight: 83.8 kg (184 lb 11.9 oz)
Physical Exam
Gen: no acute distress
HENT: clear oropharynx, moist mucous membranes. Nasal cannular in place.
Eyes: movements intact
Neck: supple, JVP difficult to appreciate with patient laying flat. Does not appear significantly
elevated
CV: normal rate, regular rhythm. Mechanical sound of balloon pump. No rubs, or gallops
Pulm: Limited. Coarse throughout. No wheezes, rales, or rhonchi
Abd: soft, non-tender, non-distended, normal bowel sounds
Ext: warm, well perfused, no clubbing, or edema
Intake/Output Summary (Last 24 hours) at 01/23/19 1654
Last data filed at 01/23/19 1631
Printed on 6/4/19 6:32 AM Page 66
Records from UCSF Medical Center (Narurkar) 000067
EXHIBIT 2-D
6425 CHRISTIE AVE FL 4 Narurkar, Vishwas
UO3F Medical Center EMERYVILLE CA 94608- MRN: 66513459, DOB: 1/31/1962, Sex: M
1-rtn Ben off Children's Hospital 1092 Adm: 1/21/2019, D/C: 1/29/2019
Inpatient Record
UCI3F Medical Center UNT N.PMER
- maims
Ui Benloff Children's Hospital Ihruillariashwtt
HAS: 621388551 005: 101556796
• AUTHORIZATION FOR SURGERY,
SPECIAL DIAGNOSTIC OR THERAPEUTIC
PROCEDURE, BLOOD TRANSFUSION AND
. DOS: 1191/1881 (60 yrt)M Adm Dec 1,2112019
11111111111111101111111111111
ADMINISTRATION OF ANESTHETICS (Page 1 of 2) LOCATDI Orr
1. I authorize cieter inlieseA44".aier M.D., and associates to
3 velx..e.1
perform the following operation(s) or procedure(s): c arorme.a.
I understandthe
t.svrai F•PA4
edical Cehter is a teaching institutio
atinligelaaociates or
assistants involved in the operation(s) or procedure(s) may include residents, fellows, medical
students or other allied healthcare professionals. I authorize that such associates or assistants
may perform or observe portions of the operation(s) or procedure(s) under the direction of the
physician(s) identified in paragraph 1 above. That physician may be out of the operating or pro-
cedural room for some of the surgical tasks done by the associates and assistants if the physi-
cian(s) identified in paragraph 1 determines it is safe to do so.
2. I authorize the administration of anesthesia and/or sedation as may be considered necessary
or advisable. I have been advised that there are certain risks associated with anesthetics that
may Include allergic reactions, and/or drug intolerances, and dental, mouth or throat damage,
discomfort or soreness. I understand that the explanations that I have received may not be
exhaustive or all-inclusive and that other more remote risks may be involved.
3. I authorize the use of pathology and radiology services if necessary. I understand that any
tissue removed will be disposed of at the discretion of the hospital pathologist or designee. I
authorize the pathologist to retain, preserve, use or dispose of any tissues, organs, bones,
bodily fluid or medical devices that may be removed during the operation(s) or procedure(s). I
understand that such specimens may be used for research, as permitted by federal and state
law. I understand that I have no property ownership or interest in such specimens or data
derived from these specimens and no right or entitlement in any research or research project
using or derived from the specimens.
My tissue:
❑ may be used In medical research
0 may not be used in medical research
4. The nature and purpose of the procedure or operation, the likelihood of benefits, risks, compli-
cations and side effects of the procedure or operatidn and its alternatives, possible alternative
methods of treatment (including the risks related to not receiving the operation or procedure)
a and potential problems tiltattinet occur during recuperation have been explained to me by
a Doctor . My consent is given with the understanding that
any operation br procedure involveAisks and hazards some of which can be serious and pos-
sibly fatal. I understand that risks may vary depending on the operation or procedure for which
I am consenting. I am aware that the practice of medicine and surgery is not an exact science
0; and no guarantee has been made as to the results or cure. I understand that the explanations
that I have received may not be exhaustive or all-inclusive and that other more remote risks
may be involved.
AUTHORIZATION FOR SURGERY OR SPECIAL
DIAGNOSTIC OR THERAPEUTIC PROCEDURE (Page 1 of 2)
Printed on 614/19 6:35 AM Page 1154
Records from UCSF Medical Center (Narurkar) 001155
6425 CHRISTIE AVE FL 4 Narurkar, Vishwas
UO3F Medical Center EMERYVILLE CA 94608- MRN: 66513459, DOB: 1/31/1962, Sex: M
1092 Adm: 1/21/2019, D/C: 1/29/2019
U eenioff Chlidrents HospW In•atient Record
U0aF Medical Center
C MAN: Sighseg
NSF Benloff Children's Hospital 4 Nonobr,Ifidwie
UMW CU: 101565788
Dale: 1/21f2019
DON: 1131'1968 NO yo) N
AUTHORIZATION FOR SURGERY,
SPECIAL DIAGNOSTIC OR THERAPEUTIC 111111111111111111111111111
PROCEDURE, BLOOD TRANSFUSION AND
ADMINISTRATION OF ANESTHETICS (Page 2 of 2) 1.0.1100 ORE
5. Transfusion: (strike out if not applicable); My doctor has discussed with me that there Is a
reasonable possibility that a transfusion of blood or blood products may be necessary. I have
received a copy of the transfusion information form describing my transfusion options (unless
I have a life-threatening emergency or medical contraindications). My doctor has discussed the
risks, benefits and alternatives of the transfusion of blood and blood products with me. I have
also learned about the option of pro-donating my own blood and have had the opportunity to
discuss this matter with my doctor.
The patient
Preview
Richard W. Lund, SBN 120844 1 PLAGEMAN, LUND & CANNON LLP One Kaiser Plaza, Suite 1440 2 Oakland, CA 94612 ELECTRONICALLY Telephone: (510) 899-6100 3 Facsimile: (510) 899-6101 F I L E D Superior Court of California, County of San Francisco 4 Attorneys for Respondent and Successor Trustee 01/06/2020 5 Michael F. Hirner Clerk of the Court BY: MICHAEL RAYRAY Deputy Clerk 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SAN FRANCISCO 9 10 In re: Case No. PTR-19-302798 11 Vishwas Narurkar Trust dated (TRUST CONTEST) DECLARATION OF 12 January 24, 2019 RICHARD W. LUND IN SUPPORT OF MOTION BY MICHAEL HIRNER FOR SUMMARY 13 JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION 14 Date: May 20, 2020 15 Time: 2:00 p.m. 16 Dept: 204 17 18 19 20 21 22 23 24 25 26 27 28 2305.4 (TRUST CONTEST) DECLARATION OF RICHARD W. LUND RE MOTION FOR SUMMARY JUDGMENT 1 I, Richard W. Lund, declare: 2 1. I am a competent adult resident of the State of California. I have personal knowledge of 3 each and every fact stated in this declaration, and could competently testify thereto if I were 4 called as a witness at trial. 5 2. I am an attorney at law licensed to practice in the State of California. I am a partner at 6 the law firm of Plageman, at Lund & Cannon LLP (the “Firm”), attorneys of record for Michael F. 7 Hirner in the above captioned matters. 8 3. The Firm issued to Queen of the Valley Hospital in Napa, California, a business records 9 subpoena seeking all medical records of Vishwas A. Narurkar (“Vic”) in connection with his 10 hospitalization there in January 2019. Attached as Exhibit 1 is a true and correct copy of a 11 relevant portion of the business records produced by Queen of the Valley Hospital in response 12 to the subpoena, consisting of: 13 • Exhibit 1-A, the Custodian of Records Affidavit from the responding party dated 7-16- 14 2019; 15 • Exhibit 1-B, an “ED Summary Report” dated 4-12-2019; and 16 • Exhibit 1-C, a “History & Physical Report” for service date 1/21/2019. 17 4. Exhibit 1-A establishes that the documents in Exhibit 1 are accurate copies of 18 business records of Queen of the Valley Medical Center, maintained in the ordinary course of 19 business, by authorized persons at or near the time of the events described. 20 5. Exhibit 1-B indicates that Vic arrived at Queen of the Valley medical center on 1- 21 20-2019 at 2318, or 11:18 p.m. that evening. 22 6. Exhibit 1-C indicates that (i) a birthdate for Vic of 1-31-1968 was reported to 23 Queen of the Valley Medical Center; (ii) based on medical chart review, Vic was “without any 24 significant past medical history or any traditional athererosclerotic risk factors” and that “The 25 patient is a dermatologist who is relatively active and free of any significant medical problems.” 26 7. The Firm issued to UCSF Medical Center in San Francisco, California, a 27 business records subpoena seeking all medical records of Vishwas A. Narurkar in connection 28 with his hospitalization there in January 2019. Attached as Exhibit 2 is a true and correct copy 2305.4 DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 2 1 of a relevant portion of the business records produced by UCSF Medical Center in response to 2 the subpoena, consisting of: 3 • Exhibit 2-A, the Declaration of Custodian of Records Affidavit from the responding party 4 dated 6-4-2019; 5 • Exhibit 2-B, bates pages 186-187 from the UCSF production, Stephanie Auffrey, MD, 6 progress notes for date of service 1-23-2019 at 11:24 am; 7 • Exhibit 2-C, bates page 66 from the UCSF production, Raymond Bamvi Fohtung, MD, 8 Consult notes for date of service 1-23-2019 at 4:54 pm; 9 • Exhibit 2-D, bates pages 1155-1156 from the UCSF production, Authorization for 10 Surgery signed by Vic dated 1-24-2019, 12:08 pm; 11 • Exhibit 2-E, bates pages 174-175 from the UCSF production, Jessica Clemtns, NP, 12 Progress Notes for date of service 1-24-2019 at 4:03pm; 13 • Exhibit 2-F, bates pages 50-51 from the UCSF production, Raymond Bamvi Fohtung, 14 MD, Consult notes for date of service 1-24-2019 at 8:07pm; 15 • Exhibit 2-G, bates pages 5-6 from the UCSF production, Discharge Summary by 16 Mallory J. Flynn, PA-C, filed 1-29-2019 at 8:12 pm. 17 8. The medical records excerpted in Exhibit 2 bracket the time period immediately 18 before, between and after the January 23 and 24, 2019 meetings between Vic and his attorneys 19 Cannon and Pankow. 20 9. Exhibit 2-A establishes that the documents in Exhibit 2 are accurate copies of 21 business records of UCSF Medical Center, maintained in the ordinary course of business, by 22 authorized persons at or near the time of the events described. 23 10. Exhibit 2-B shows the Progress Note by Stephanie Auffrey, MD for date of 24 service 1/23/2019 at 11:24am (about 3 hours prior to Jan 23 meeting), stating in relevant part: 25 • “Subjective: No specific complaints. No pain. Asking questions about etiology of cardiac issues.” 26 • “Constitutional: He is oriented to person, place and time. He appears well-developed and well nourished. No distress.” 27 • “Neurological: He is alert and oriented to person, place and time.” 28 2305.4 DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 3 1 11. Exhibit 2-C shows the Consult notes by Raymond Bamvi Fohtung, MD for date of 2 service 1/23/2019 at 4:54 pm (about 90 minutes after Jan 23 meeting), stating in relevant part: 3 • “Subjective: Dr. Narurkar states he is doing well and denies any significant pain.” • “Physical Exam. Gen: no acute distress” 4 12. Exhibit 2-D shows the Authorization for Surgery executed by Vic on 1/24/2019 at 5 12:08 pm (about 2.5 hours before Jan 24 meeting), showing that: 6 7 • UCSF determined that Vic was in a condition to execute a written consent to his heart surgery at this time 8 • Signed consent acknowledges Vic received and understood an explanation of the risks from Dr. Stephanie Auffrey 9 10 13. Exhibit 2-E shows the Progress Notes by Jessica Clements, NP, for date of 11 service 1/24/2019 at 4:03 pm (about 1 hour after Jan 24 meeting), stating in relevant part: 12 • “Subjective: Pt denies pain, shortness of breath, and states he is very comfortable at this time.” 13 • “Constitutional: He is oriented to person, place, and time.” • “Neurological: He is alert and oriented to person, place and time.” 14 15 14. Exhibit 2-F shows the Consult notes by Raymond Bamvi Fohtung, MD for date of 16 service 1/24/2019 at 8:07 pm (about 5 hours after Jan 24 meeting), stating in relevant part: 17 • “Subjective: No major complaints.” 18 • “Physical Exam. Gen: no acute distress” 19 15. Exhibit 2-G shows the Discharge Summary by Mallory J. Flynn, PA-C, filed 1-29- 20 2019 at 8:12 pm, which confirms several of the relevant timeline dates: transfer to UCSF on 1- 21 21-2019, surgery on 1-26-2019, as of 1-29-2019, despite being off sedation for 48 hours, not 22 conscious (i.e., no movement, no cough, no gag and pupils fixed and dilated), family meeting at 23 3 pm on 1-29-2019 where decision made to transfer to comfort care, and Vic pronounced dead 24 at 7:02pm on 1-29-2019. 25 16. Attached as Exhibit 3-A is a true and correct copy of the Requests for 26 Admissions Set One (RFA), served by Petitioner on Leela Narurkar (Leela) on July 23, 2019, in 27 the related Trust Petition matter, San Francisco probate court case number PTR-19-302798, 28 2305.4 DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 4 1 omitting the voluminous Attachment 2 of the request, which attached copies Vic’s estate 2 planning documents. Attached as Exhibit 3-B is a true and correct copy of Leela Narurkar’s 3 verified response to this RFA, dated September 5, 2019. 4 17. Request 17 of the RFA asked Leela to admit that “At the time of Vic’s death, 5 Leela knew that Vic and Mike Hirner had been together as a couple for approximately 18 years.” 6 Leela’s response to this RFA 17 was: “Deny”. Request 18 of the RFA asked Leela to admit that, 7 “For approximately 18 years prior to Vic’s death, Vic publicly acknowledged that he was in a 8 same-sex couple relationship with Mike Hirner.” Leela’s response to this RFA 18 was: 9 “Responding paarty does not have sufficient personal information on which to admit or deny this 10 request, and on that basis deny.” 11 18. Attached as Exhibit 4-A is a true and correct copy of the Form Interrogatories – 12 General, Set One (Form Interrogatories), served by Petitioner on Leela on July 23, 2019, in the 13 related Trust Petition matter, San Francisco probate court case number PTR-19-302798. 14 Attached as Exhibit 4-B is a true and correct copy of Leela’s verified response to the Form 15 Interrogatories, dated September 5, 2019. 16 19. Form Interrogatory 17.1 asked Leela to state all facts, and identify supporting 17 witnesses and documents, as to any responses to the RFA in Exhibit 3-A and 3-B that were not 18 an unqualified admission, which would include Request 17 and 18 of the RFA. As to Request 19 17 of the RFA, Leela’s Form Interrogatory response was: “b) Responding party did not know the 20 nature and extent of Michael Hirner’s relationship with her son.” As to Request 18 of the RFA, 21 Leela’s Form Interrogatory response was “b) Responding Party has no personal knowledge on 22 which to base a response to this request. Responding party did not know the nature and extent 23 of Michael Hirner’s relationship with her son.” 24 /// 25 /// 26 /// 27 /// 28 /// 2305.4 DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 5 1 I declare under penalty of perjury under the laws of the State of California that the 2 foregoing is true and correct. Executed this 30th day of December, 2019, at Oakland, 3 California. 4 T,:,t44...TQA).044.19_ _________________________ 5 Richard W. Lund 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2305.4 DECLARATION OF RICHARD W. LUND IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT PAGE 6 EXHIBIT 1-A CUSTODIAN OF RECORDS AFFIDAVILi I THE UNDERSIGNED, AM THE DULY AUTHORIZED CUSTODIAN OF RECORDS FOR QUEEN OF THE VALLEY HOSPITAL - MEDICAL RECORDS DEPARTMENT (A) THE RECORDS PERTAINING TO: Vsshwas Narurkar I c 3ATE OF BIRTH 1/31/1962 (B) THAT, INCLUDNG THIS CERTIFICATION, ALL RECORDS' CALLED FOR IN THE ATTACHED SUBlipENA OR AUTHORIZATION ARE IN MY CUSTODY AND HAVE BEEN RELEASED FOR DOCUMENTATION TO THE DEPOSITION OFFICER (C)THAT TO THE BEST OF MY KNOWLEDGE, ALL RECORDS WERE PREPARED IN THE NORMAL COURSE OF BUSINESS BY AUTHORIZED PERSONS AT OR NEAR THE TIME OF THd ACT, CONDITION OR EVENT 'I I DECLARE UNDER THE PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORR1 CT EXECUTED ON 1 -1G-1cit a19 AT • 4Sk .\•Lk, TYPE OR PRINT CUSTODIAN NAME ,DO NOT CHECK ANYTHING BELOW UNLESS NO RECORDS ARE AVAILABLE CERTIFICATE OF NO: X-RAYS BILLING RECORDS PATHOLOGY OTHER I El LOST El DESTROYED 0 MISFILED MISPLACED Ei NEVER TREATED 111.1•1111111C • AFFIDAVIT OF PROFESSIONAL PHOTOCOPIER I DECLARE UNDER PENALTY OF PERJURY THAT IAM AN EMPLOYEE OF ADVANCED MICROSYSTEMS AND THAT THE RECORDS CALLED FOR IN THE SUBPOENA OR AUTHORIZATION ARE TRLIBC6PIES OF RECORDS PRODUCED TO ME BY'llHE DUB:ID:FAN OF RECORDS FOR THE FACILITY NAMED ABOVE' AND THAT 'THESE RECORDS WILL BE'DISTRIBUTED TO THE AUTHORIZED PERSONS OR ENMES. EXECUTED ON 2019 AT SIGNED TYPEolePRINT PtioiocoPiEPSMI PHOTocOPEERS Statannin [—I The Custodian was recluttted to-sign this certificate at the time of document production 1.-- 1 and refused to sign or generate a simillar document DATE. ORDER: 429207 EXHIBIT 1-B DATE: 04/12/19 @ 0038 Northern California EDX *LIVE* PAGE 1 USER: LEEJ002 ED Sunmary Report ....... MI= ... ,..... Ariarimi • ^ .. itA ....... ..prIBREMOILICig 1030 CAROLINA ST SAN FRANCISCO, CA 94107 415-923-3373 Insurance: Blue Shield PPO PCP: Physician Not On Staff Neat of Kin: HIRNER,MICHAEL Family Doctor: Relation: Significant Other Referring: Phone: 415-722-4862 GENERAV .. ED Physician: Lopez,Nicholas R, ACT Arrival Date/Time: 01/20/19 - 2318 Practitioner: Triage Date/Tine: Nurse: Rios,Linda M, RN Date of Birth: 01/31/1968 Stated Complaint: SOB, FIB ADM Reason For Visit: STEHI, VSD Chief Complaint: Cardiovascular Priority: 2 ..• MEL .1...1..... 02, 20.19-?2,16 2ime.Jblaug Isolation Recomaended Standard Sepsis Screen No Definite Risk . ....... . EIVUUUMftl klitiNWalb ......... ....... ..... ........!' 02/20,1 2326 Zw.Jolene History Of Present Illness Biba from home with tachycardia, sob, back pain Illr No Known Allergies (NWT MOME-,m No Active Prescriptions or Reported Meds. EIGHT ... ......•••••..... IMIFM1 41f yl 07,7170179 2.716 lomdbleae Height (Feet) 5 Height (Inches) 10 Height Measurement Method Stated Weight (Calculated Kilograa) 80.910 EXHIBIT 1-C Queen of the Valley 1000 Trances Street Napa, CA 94558 History & Physical Report Patient Name: NARURKAR,VISHWAS DOB: 01/31/1968 Account #: QV0087805174 Age/Sex: 501M Unit #: QM02622967 Location: NQMICUS / NQM3410 Admitting Dr: Villalon,Mark L Admit/Service Date: 01/21/19 Ordering Dr: Dictating Dr: Saman Hayatdavoudi MD Primary Dr: Physician Not On Staff Job: 091086 / 4703319 / HBE137917 DATE OF ADMISSION: 01/21/2019 STAT CRITICAL CARE ADMISSION CHIEF COMPLAINT: The patient with ST elevation myocardial infarction, currently intubated, sedated, unable to really give a history.This is all per chart review. HISTORY OF PRESENT ILLNESS: This 50-year-old male without any significant past medical history or any traditional atherosclerotic risk factors, who presented with upper back discomfort. The patient currently is intubated and sedated, however, developed respiratory failure. The patient is a dermatologist who is relatively active and free of any significant medical problems.On January 16, the patient reports onset of upper back pain and symptoms were intermittent and mild In intensity; however, he was able to work throughout those next few days and on the 21st, he visited Napa from his native San Francisco, California and had a massage to try to relieve the symptoms of his back. However, around 9:30 p.m., he reported onset worsening back pain, malaise, diaphoresis for which 911 was notified. In the ER, he was found to have a rapid AFib and anterolateral infarct and ST elevation in addition to lateral ST elevation and inferior ST depressions. The patient was given adenosine 6 mg IV to attempt to restore normal sinus rhythm, but had no effect. He developed runs of nonsustained V-tech that did not require shock. Therefore, the patient did go to the cath lab, which revealed delayed presentation of ST elevation myocardial infarction, status post successful IVUS-guided PCI of the mid distal LAD with insertion of 2 overlapping drug-eluting stents, residual intermediate disease throughout the RI, left circumflex, and right coronary artery. The patient also had a ventricular septal defect with apical thrombosis.The left ventricular ejection fraction was 20% to 25% in a hypokinetic pattern consistent with ischemic cardiomyopathy_ The patient also had elevated left-sided filling pressures and status post successful MAC with intraaortic balloon pump insertion. The patient also had insertion of a triple lumen catheter via the right femoral vein, and the patient currently is on a heparin drip as well as eptifibatide drip and the P2Y12 inhibitor therapy is on hold in anticipation of VSD repair.The patient currently is being evaluated by UCSF for transfer for further evaluation and management. The patient currently is on dopamine as well as Levophed. The patient otherwise is unable to give me a review of systems as the patient is currently intubated. The patient does follow simple commands, however, is unable to give me a review of systems secondary to the patient's clinical condition. PAST MEDICAL HISTORY: None. History & Physical Report Patient Name: NARURKAR,VISHWAS Report Status: Signed Account #: QV0087805174 Unit #: QM02622967 Dictating Dr: Saman Hayatdavoudi MD Report #: 0121-0031 Page 1 of 3 EXHIBIT 2-A LOCATION: VC 01 1ediC4 RECORDS PERTAIN TO: kic r Kgr DECLARATION OF CUSTODIAN OF RECORDS (Pursuant to California Evidence Code Section 1561) I am the duly authorized Custodian of Records and I state that the records were prepared in the ordinary course of business and that: all records requested are in my custody and have been released; records do exist, but none within.the time frame listed In the request; an records within the time period listed in the request have been destroyed; a search was performed and no records requested were found. (Please explain below) I declare under penalty of perjury that the foregoing is true and correct under the laws of California. Executed on C-14 11 9 atCnelti,t)t I tD , California. • By: Name: Vul c&A-k-A- Title: fkA- I t1 Phone Number (A l is' -3 r3- 259/ Records from UCSF Medical Center (Narurkar) 000001 EXHIBIT 2-B 6425 CHRISTIE AVE FL 4 Narurkar, Vishwas UOaF Medical Center EMERYVILLE CA 94608- MRN: 66513459, DOB: 1/31/1962, Sex: M UOSF Bei-aloft Chltdren's Hospite 1092 Adm: 1/21/2019, D/C: 1/29/2019 Inpatient Record Progress.Notes - Encounter Rotei (Zontirtued) Progress Notes by Jessica Clements, NP at 1/24/2019 4:03 PM (continued) Version 1 of 2 [Endo] - ISS Patient and plan discussed with Cardiac Surgery Attending, GEORG MAXIMILLIAN WIESELTHALER, MD. Jessica Clements, NP 01/24/19, 4:03 PM Electronically signed by Jessica Clements, NP at 1/24/2019 4:12 PM Progress Notes by Stephanie Auffrey, MD at 11231201911:24 AM Version 1 of 1 Author:Stephanie Auffrey, MD Service: Cardiac Surgery Author Type: Resident Filed: 1/23/2019 11:27 AM Date of Service: 1123/2019 11:24 AM Status: Signed Editor: Stephanie Auffrey, MD (Resident) _CARDIAC SURGERY PROGRESS NOTE ID: 56M with no significant PMH who presented to OSH 1/20 with chest pain and was found to have STEMI and severe cardiomyopathy (thought secondary to large ischemic event), now s/p PCI and IABP at OSH, and was transferred to UCSF 1/21 for higher level care. Admitted: 1/21/2019 24 HOUR EVENTS: 1/23: Plan for OR 1/25. Dc'd Plavix. CRRT -25. 1/22: STAT TEE, Insulin gtt to ISS, CXR with L pulm edema, CRRT -25, extubated, plan for OR next week. CRRT to even overnight with tachycardia and rising lactate. 1/21: Transferred from Queen of Valley in PM. SUBJECTIVE: No specific complaints. No pain. Asking questions about etiology of cardiac issues. OBJECTIVE: 24-hour Vitals: ieart Rate: [80-96] 91 *Resp: [17-44] 18 Arterial Line BP (mmHg) : (92-125)/(39-53) 96/39 Printed on 6/4/19 6:32 AM Page 185 Records from UCSF Medical Center (Narurkar) 000186 6425 CHRISTIE AVE FL 4 Narurkar, Vishwas InSF Medical Center EMERYVILLE CA 94608- MRN: 66513459, DUB: 1/31/1962, Sex: M 1092 Adm: 1/21/2019, D/C: 1/29/2019 BenioliChEaren's Hospital Inpatient Record Progress Notes - Encoimter Notes(cOntiitued) Progress Notes by Stephanie Auffrey, MD at 1123/201911:24 AM (continued) Version 1 of 1 F102 (%): [40 %] 40 % SpO2: [96 %-100 %] 100 % Physical Exam: Physical Exam Constitutional: He is oriented to person, place, and time. He appears well-developed and well- nourished. No distress. HENT: Head: Normocephalic and atraumatic. Cardiovascular: Normal rate and regular rhythm. Pulmonary/Chest: Effort normal. No respiratory distress. Abdominal: Soft. He exhibits no distension. Left groin soft and without evidence of hematoma. Musculoskeletal: He exhibits no edema. Neurological: He is alert and oriented to person, place, and time. Skin: Skin is warm and dry. Vitals reviewed. Admission Weight: 83.8 kg (184 lb 11.9 oz) '1st Recent Weight: 83.3 kg (183 lb 10.3 oz) There is no height or weight on file to calculate BMI. I/O last 2 completed shifts plus current shift: In: 3642.59 [P.O.:110; I.V.:3107.59; NG/GT:20; IV Piggyback:405] Out: 4140 [Urine:265; Drains/NG:100; Other:3775] Medications: Continuous Infusions: • amiodarone 0.5 mg/min (01/23/19 1100) • dextrose • dextrose 5 % and 0.2 % sodium Stopped (01/22/19 0800) chloride • dextrose 5 % and 0.45 % sodium 10 mUhr (01/23/19 1100) chloride • DOPamine 4 mcg/kg/min (01/23/19 1100) • heparin flush for iabp pump 3 Units/hr (01/23/19 1100) • heparin 19 Units/kg/hr (01/23/19 1100) • norEPINEPHrine 0.04 mcg/kg/min (01/23/19 1117) • pureflow 2,000 mUhr (01/23/19 0627) Scheduled Meds: • sodium chloride 3 mL Intravenous Q8H SCH flush • aspirin 81 mg Per OG Tube Daily (AM) Printed on 6/4/19 6:32 AM Page 186 Records from UCSF Medical Center (Narurkar) 000187 EXHIBIT 2-C 6425 CHRISTIE AVE FL 4 Narurkar, Vishwas UCSF Medical Center EMERYVILLE CA 94608- rviRN: 66513459, DOB: 1/31/1962, Sex: M 1092 Adm: 1/21/2019, D/C: 1/29/2019 Selloff ChiNren's Hospit Inpatient Record Consults Encounter•Notes (continued) Consults by Raymond Bamvi Fohtung, MD at 1/23/2019 4:54 PM (continued) Version 2 of 2 PGY5 I Cardiology Fellow Electronically signed by Francesca Nesta Delling, MD at 1/24/2019 12:05 PM Consults by Raymond Bamvi Fohtung, MD at 1/23/2019 4:54 PM Version 1 of 2 Author Raymond Bamvi Fohtung, MD Service: Cardiology Author Type: Resident 1/23/2019 5:12 PM Filed: Date of Service: 1/2312019 4:54 PM Status. Cosign Needed Editor: Raymond Bamvi Fohtung, MD (Resident) Related Notes: Addendum by Raymond Bamvi Fohtung, MD (Resident) filed at 1/23/2019 5:13 PM Cosign Required: Yes CARDIOLOGY CONSULT FOLLOW-UP NOTE 24 Hour Course - Extubated. - on levo 0.06 and dobamine 4. Lactate stable around 2.5. SVO2 stable in the 50s. - Having some NSVT last night. Given some calcium and fluid removal with dialysis stopped with some improvement in NSVT. - CVP 13-16. UOP 170 cc. Drains 100 cc. Dialysis 3.4L. Net negative 500 cc. - Balloon pump in place. Augmented diastolic 85. MAPs in 60s. Subjective - Dr. Narurkar states he is doing well and denies any significant pain. Vitals Heart Rate: [86-96] 86 *Resp: [17-34] 22 Arterial Line BP (mmHg) : (92-125)/(38-53) 106/41 Most Recent Weight: 83.3 kg (183 lb 10.3 oz) Admission Weight: 83.8 kg (184 lb 11.9 oz) Physical Exam Gen: no acute distress HENT: clear oropharynx, moist mucous membranes. Nasal cannular in place. Eyes: movements intact Neck: supple, JVP difficult to appreciate with patient laying flat. Does not appear significantly elevated CV: normal rate, regular rhythm. Mechanical sound of balloon pump. No rubs, or gallops Pulm: Limited. Coarse throughout. No wheezes, rales, or rhonchi Abd: soft, non-tender, non-distended, normal bowel sounds Ext: warm, well perfused, no clubbing, or edema Intake/Output Summary (Last 24 hours) at 01/23/19 1654 Last data filed at 01/23/19 1631 Printed on 6/4/19 6:32 AM Page 66 Records from UCSF Medical Center (Narurkar) 000067 EXHIBIT 2-D 6425 CHRISTIE AVE FL 4 Narurkar, Vishwas UO3F Medical Center EMERYVILLE CA 94608- MRN: 66513459, DOB: 1/31/1962, Sex: M 1-rtn Ben off Children's Hospital 1092 Adm: 1/21/2019, D/C: 1/29/2019 Inpatient Record UCI3F Medical Center UNT N.PMER - maims Ui Benloff Children's Hospital Ihruillariashwtt HAS: 621388551 005: 101556796 • AUTHORIZATION FOR SURGERY, SPECIAL DIAGNOSTIC OR THERAPEUTIC PROCEDURE, BLOOD TRANSFUSION AND . DOS: 1191/1881 (60 yrt)M Adm Dec 1,2112019 11111111111111101111111111111 ADMINISTRATION OF ANESTHETICS (Page 1 of 2) LOCATDI Orr 1. I authorize cieter inlieseA44".aier M.D., and associates to 3 velx..e.1 perform the following operation(s) or procedure(s): c arorme.a. I understandthe t.svrai F•PA4 edical Cehter is a teaching institutio atinligelaaociates or assistants involved in the operation(s) or procedure(s) may include residents, fellows, medical students or other allied healthcare professionals. I authorize that such associates or assistants may perform or observe portions of the operation(s) or procedure(s) under the direction of the physician(s) identified in paragraph 1 above. That physician may be out of the operating or pro- cedural room for some of the surgical tasks done by the associates and assistants if the physi- cian(s) identified in paragraph 1 determines it is safe to do so. 2. I authorize the administration of anesthesia and/or sedation as may be considered necessary or advisable. I have been advised that there are certain risks associated with anesthetics that may Include allergic reactions, and/or drug intolerances, and dental, mouth or throat damage, discomfort or soreness. I understand that the explanations that I have received may not be exhaustive or all-inclusive and that other more remote risks may be involved. 3. I authorize the use of pathology and radiology services if necessary. I understand that any tissue removed will be disposed of at the discretion of the hospital pathologist or designee. I authorize the pathologist to retain, preserve, use or dispose of any tissues, organs, bones, bodily fluid or medical devices that may be removed during the operation(s) or procedure(s). I understand that such specimens may be used for research, as permitted by federal and state law. I understand that I have no property ownership or interest in such specimens or data derived from these specimens and no right or entitlement in any research or research project using or derived from the specimens. My tissue: ❑ may be used In medical research 0 may not be used in medical research 4. The nature and purpose of the procedure or operation, the likelihood of benefits, risks, compli- cations and side effects of the procedure or operatidn and its alternatives, possible alternative methods of treatment (including the risks related to not receiving the operation or procedure) a and potential problems tiltattinet occur during recuperation have been explained to me by a Doctor . My consent is given with the understanding that any operation br procedure involveAisks and hazards some of which can be serious and pos- sibly fatal. I understand that risks may vary depending on the operation or procedure for which I am consenting. I am aware that the practice of medicine and surgery is not an exact science 0; and no guarantee has been made as to the results or cure. I understand that the explanations that I have received may not be exhaustive or all-inclusive and that other more remote risks may be involved. AUTHORIZATION FOR SURGERY OR SPECIAL DIAGNOSTIC OR THERAPEUTIC PROCEDURE (Page 1 of 2) Printed on 614/19 6:35 AM Page 1154 Records from UCSF Medical Center (Narurkar) 001155 6425 CHRISTIE AVE FL 4 Narurkar, Vishwas UO3F Medical Center EMERYVILLE CA 94608- MRN: 66513459, DOB: 1/31/1962, Sex: M 1092 Adm: 1/21/2019, D/C: 1/29/2019 U eenioff Chlidrents HospW In•atient Record U0aF Medical Center C MAN: Sighseg NSF Benloff Children's Hospital 4 Nonobr,Ifidwie UMW CU: 101565788 Dale: 1/21f2019 DON: 1131'1968 NO yo) N AUTHORIZATION FOR SURGERY, SPECIAL DIAGNOSTIC OR THERAPEUTIC 111111111111111111111111111 PROCEDURE, BLOOD TRANSFUSION AND ADMINISTRATION OF ANESTHETICS (Page 2 of 2) 1.0.1100 ORE 5. Transfusion: (strike out if not applicable); My doctor has discussed with me that there Is a reasonable possibility that a transfusion of blood or blood products may be necessary. I have received a copy of the transfusion information form describing my transfusion options (unless I have a life-threatening emergency or medical contraindications). My doctor has discussed the risks, benefits and alternatives of the transfusion of blood and blood products with me. I have also learned about the option of pro-donating my own blood and have had the opportunity to discuss this matter with my doctor. The patient