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  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
  • SHEINAGH VILLANUEVA VS. UBER TECHNOLOGIES, INC. ET AL PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED document preview
						
                                

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ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 03/06/2020 Clerk of the Court BY: RONNIE OTERO Deputy Clerk AGNES M. GROGAN, R.N., B.S. 4186 Racquet Club Drive Huntington Beach, CA 92649 714-840-1777 PROFESSIONAL EXPERIENCE 10/09-present GROGAN & ASSOCIATES, Huntington Beach, CA Position: Legal Nurse Consultant and sole proprietor. Areas of activity:Review and summary of medical records and assessment of damages/liability; perform medical billreviews for appropriate, accurate and usual/customary charges; defense medical exam monitoring, Experienced in elder abuse, personal injury, professional negligence, product liability and fraud investigation.. 1992 – 10/09 V/G ASSOCIATES, Westminster and Huntington Beach, CA Position: Partner in multi-specialty forensic consulting firm. Responsibilities: Review and summary of medical records and assessment of damages/liability; perform medical bill reviews; conduct audits related to organizational compliance and/or medical fraud investigation; perform peer review literature searches; provide medical expert referral, defense medical exam monitoring, deposition assistance, trial preparation to include trial notebooks, demonstrative evidence and medical tutoring; present educational seminars. Experienced in elder abuse, personal injury, professional negligence, and product liability. 1998 - 1999 CATHOLIC HEALTHCARE WEST, Oakland, CA Position: Legal Nurse Consultant. Conduct medical-legal investigations for claims against CHW facilities; assist in obtaining expert medical opinions; submit reports detailing findings. 1997 - 1998 ARCA, Concord, CA Position: Risk Control Consultant. Responsibilities: Review variance reports for risk exposure; conduct investigations; submit reports detailing findings. 1993 - 1994 CORVEL, Orange, CA. Position: Medical & Hospital Bill Auditor, Legal Nurse Consultant Responsibilities: Review and adjust Workers’ Compensation medical and hospital bills, evaluate medical records for case management and utilization review recommendations, summarize and analyze medical records for insurance adjusters and physicians 1986 - 1992 GROGAN & ASSOCIATES, Running Springs, CA Position: Owner of medical-legal and bill audit consulting firm. Responsibilities: Review and summarize medical records for attorneys, literature searches, locate and consult with medical experts. Verify accuracy of hospital and physician charges. Provide seminars and educational workshops to hospitals and medical personnel on concurrent audit process. 1990 INLAND MEDICAL CENTER, Pomona, CA Position: Director of Patient Services Responsibilities: Institute and revise policies/procedures relating to patient care. Supervise nursing personnel. Provide direct patient care in ambulatory and urgent care setting. Review billings and medical records for appropriateness and accuracy of charges. SAN DIMAS COMMUNITY HOSPITAL, San Dimas, CA 1987 - 1993 Position: Staff Nurse - Emergency Room, Medical-Surgical; Relief Supervisor 1988 - 1990 Position: Patient Accounts Auditor 1983 - 1985 Position: Staff Nurse - Medical-Surgical, Maternity, Pediatric, Recovery Room, ICU-CCU 1972 - 1978 Position: Inservice Education Coordinator. Quality Care Evaluation Coordinator October 2019 LUDWIG CIBELLI, JR., M.D., Lake Arrowhead, CA 1985 - 1986 Position: Office Nurse 1979 – 1983 Position: Office Nurse 1970 - 1972 POMONA VALLEY COMMUNITY HOSPITAL, Pomona, CA Position: Staff Nurse Labor and Delivery, Medical, Orthopedics. Inservice Education Instructor. 1969- 1970 PRESBYTERIAN INTERCOMMUNITY HOSPITAL, Whittier, CA Position: Staff Nurse Labor and Delivery, Medical, Gynecology FORMAL EDUCATION 1994 Bachelor of Science in Business Administration, California Coast University, Santa Ana, CA 1969 Associate in Arts, Mt. San Antonio Junior College, Walnut, CA Licensure as R.N. 1956 - 1958 St. Luke’s School of Nursing, Marquette, MI 1956 - 1957 Northern Michigan College of Education, Marquette, MI CURRENT PROFESSIONAL AFFILIATIONS Association of Medical Auditor Specialists, 2005-present American Association of Legal Nurse Consultants; 1989-2011; 2014-present; Founding Member 1989. Education Committee 1992, 1993 American Association of Professional Coders, 2014-present PAST PROFESSIONAL AFFILIATIONS International Association of Forensic Nurses; Chairperson Geriatric Council 1994, 1995 American Trial Lawyers Association California Trial Lawyers Association California Advocates for Nursing Home Reform National Citizens’ Coalition for Nursing Home Reform American Association of Legal Nurse Consultants, Orange County Chapter 1989 - 2011; Founding Member, Secretary 1992, President 1993, 2003 PRESENTATIONS 2019 “Supporting Medical Damages in a CRPS Case”, American Associations for Justice, San Diego, CA 2015 “Role of Legal Nurse in Personal Injury Litigation” – presented to attorneys from Nationwide Insurance, Glendale, CA 2014 Presentations (2) to attorneys and adjusters from Farmer’s Insurance, San Bernardino, CA and Ontario, CA 2012 Webinar presentation “Bill Review in Litigation:, presented to Western Regional Legal Nurse Consultants, CA. 2011 “LNC’s Role in Personal Injury Litigation” – presented to American Association of Legal Nurse Consultants, Orange County Chapter, Irvine, CA 2009 “Ethical Considerations in LNC Practice” – presented to American Association of Legal Nurse Consultants, Orange County Chapter, Irvine, CA “Software Tools for the LNC” – presented to American Association of Legal Nurse Consultants, Orange County Chapter, Irvine, CA 2008 “How Medical Bill Review Can Enhance Your Practice” – presented to American Association of Legal Nurse Consultants, Los Angeles Chapter , Pasadena, CA [Type text] 2007 “A Little Knowledge – Tips on Checking Medical Bills” – presented to San Diego South County Bar Association, San Diego, CA “Bill Review in the Litigation Process”, presented to San Diego North County Bar Association, Vista, CA “Transition: Nurse Auditor to Legal Nurse Auditor”, presented to American Association of Medical Auditors, Williamsburg, VA. “LNC & Bill Review – A $ucce$$ful Combination”, presented to American Assocation of Legal Nurse Consultants, Laguna Woods, CA and San Diego CA 2005 “BillReview: Value in Litigation”, one-hour teleconference presented to Wyoming Trial Laywers. 2005 “An Introduction to Legal Nurse Consulting”, presented at annual seminar of American Assocaiton of Legal Nurse Consultants, Anaheim, CA. 2004 “Report Writing”, presented to American Association of Legal Nurse Consultants, Buena Park, CA. 2003 “Medical Bill Review for the Legal Nurse Consultant,” an 8-hour course at University of California-Riverside. 2002 “Medical Bill Review for the Legal Nurse Consultant,” an 8-hour course at University of California-Riverside “Health Care And Insurance Industries and Legal Nurse Consultants,” a 6-hour course at University of California-Riverside. 2001 “Physician Small Office Practice Medicare Compliance”, presented to SCPIE, Los Angeles, CA 2000 “Flags of Fraud: Billing Issues”, presented to American Association of Legal Nurse Consultants, St. Louis, MO. “Medical Bill Review for the Legal Nurse Consultant,” an 8-hour course at University of California-Riverside. “Health Care and Insurance Industries and Legal Nurse Consultants,” a 6-hour course at University of California-Riverside, 1999 "Recognizing Fraud in the Medical Records and Bills," presented to Northern Claims Conference, Oakland, CA. "Recognizing Fraud in the Medical Records and Bills," presented to Sedgwick, Detert, Moran firm. "Legal Aspects of Documentation", presented to Community Hospital of San Bernardino & St. Bernardine Medical Center personnel, San Bernardino, CA 1998 "Recognizing Medical Fraud in Records and Bills", presented to Florida Medicare Peer Review Board, Tampa, FL "Recognizing Potential Fraud in Medical Bills",presented to San Bernardino County Bar Association, San Bernardino, CA "Legal Aspects of Documentation", presented to St. Bernardine Medical Center personnel, San Bernardino, CA "Medical Research on the Internet", presented to Orange County Chapter of Legal Nurse Consultants, Orange, CA. [Type text] 1998 "Orthopedic Basics", presented to Nationwide Insurance/Northwest Insurance/Oregon Mutual, Portland, OR. 1997 "Orthopedic Basics", presented to St. Paul Insurance, Brea, CA and Wm. Chopak Law firm "Chiropractic and Physical Therapy Regulations", presented to St. Paul Insurance, Brea, CA "Recognizing Fraud in the Medical Records and Medical Bills", presented to St. Paul Insurance, Brea, CA “Medical Fraud Investigation” presented in San Francisco, CA 1996 “Medical Fraud Investigation” presented in Orlando, FL; Philadelphia, PA, Chicago, IL, Las Vegas, NV, and San Antonio, TX “Report Writing in the Personal Injury Case” presented to Orange County of Legal Nurse Consultants, Orange, CA. “Medical Fraud Investigation: The Nurse’s Role” presented to Nationwide Insurance Case Managers, Columbus, OH “Legal Nurse Consultant’s Role in Discouraging Frivolous Lawsuits”, KIEV Radio Interview, Glendale, CA 1995 “Forensic Medical Fraud Investigation: “Investigative Process of the Medical Records and Medical Bills”, Aegis Institute, Queen Mary, Long Beach, CA “Elder Abuse: The Silent Suffering” Orange County Bar Association, Elder Law Section, Orange, CA; Encino CA 1994 “Elder Abuse: The Silent Suffering” California Advocates for Nursing Home Reform, Sacramento, CA; Costa Mesa, CA “Bill Review - Its Place in the Litigation Process”, Orange County and Los Angeles Chapters of American Association for Legal Nurse Consultants, Anaheim, CA “Bill Review - An Effective Marketing Tool for the LNC”, American Association for Legal Nurse Consultants, Fifth Annual National Conference, Houston, TX 1993 “Nurse Auditors and the Challenge of Change”, Medical Auditor’s Association of California, Buena Park, CA “Introduction to Legal Nurse Consulting”, Aegis Network, Inc., Dana Point, CA 1991 - 1993 “Hospital Bill Auditing”: A 2-day seminar for hospital personnel on elements of effective bill auditing from hospital and insurance viewpoints. Introduction of auditor participation in quality assurance and risk management processes 1989 - 1990 “RECOUR$E”: A 1-day seminar presented nationwide to hospital personnel on topics of revenue enhancement, risk management and quality assurance participation through audit process PUBLICATIONS “Medical Bill Review: An Often Untapped Source of Information,” OCTLA – The Gavel, Winter 2009 Nursing Malpractice, Third Edition, contributing author for chapter on Significance of Healthcare Fraud in Nursing, Lawyers & Judges Publishing Company, January 2007 Medical-Legal Aspects of Medical Records, contributing author for chapter on Medical Billing and Coding, for Lawyers & Judges Publishing Company, January 2006 “Understanding the Impact of Medical Billing on Your Case”, C.A.A.L.A. Advocate – publication, Spring 2005 Legal Nurse Consulting: Principles and Practice, contributing author for chapter on Medical Bill Review, 1997; 2003 revised (newly titled Health Care Claims Analysis) [Type text] “Medical Bill Review - A Tool in Cost-Effective Claims Management”, Claims Magazine, March 1996 “Geriatric Council Update: Focus on Existing Elder Abuse Legislation”, International Association of Forensic Nurses, July 1995 “What’s the Difference?” - Role comparison of paralegal, physician and Legal Nurse Consultant in medical-legal arena; Inland Empire Claims Association Newsletter October 1993 and San Bernardino County Bar Association BULLETIN, January 1994 “Utilization of the Nurse Auditor in the Quality Assurance and Risk Management Processes”, thesis for Bachelor of Science degree, 1993 CONTINUING EDUCATION 2018 Orthopedic Nursing: Caring for Patients with Musculoskeletal Disorders, Western Schools, West Bridgewater, MA 2016 Care of Patients Prescribed Opiods for Treatment of Pain; Deasling with the Angry Patient or Family Member; Chronic Pain; Therapeutic Doses of Humor; Pain Management; Pharmacology: Mental Health Medications: Health Information Technology for Nurses; Hooked: Drug Abuse in America; Elder Care; Elite Continuing Education 2015 Neuropsychological Persepctives on Mild Traumatic Brain Injury, American Association of Legal Nurse Consultants, Webinar Beyond the Policy and Procedure, Chronic Pain: Evaluation and Management, Professional Nursing Documentation, RN.com 2014 Elbow Injuries and Fractures; Legal Issues Related to complementary and Alternative Medicine; Getting to the Heart of Back and Shoulder Pain; Noninvasive Monitoring of End-Tidal Carbon Dioxide in the Emergency Department; Shaken Baby Syndrome; Management of Acute Agitation in the Emergency Department; Osteoporosis, Fragility Fractures and Associated Surgieries; Feeding the Person with Late-State Alzheimer’s Disease; Animal-assisted Therapy: Paws with a Cause; ED Violence: Ocupational Hazard?, Lippincott Williams & Wilkins CE Department, New York, NY 2014 Howell and Corenbaum Decision Effects on Damages, American Association of Legal Nurse Consultants, San Diego, CA Navigating the Challenges and Reaping the Rewards of Working with Interprofessional Teams: All About Herniated Discs – Anatomy & Pathology;Liability Lessons for LNCs; Expert Reviews of Pressure Ulcer/Wound Care Cases: A Systemic Approach: The Intersection of Science and Law; Medical Cannabis and Health Care; Demystifying Medical Records – Advocating for Your Client; Trends & Implications of Negligent Credentialing; Product Liability Trends & Court Rulings: Ipacting the LNC Practice; Life Care Planner as Expert Witness: Who do you trust?; LNC Role in Deposition Prep of Expert Witnesses; American Association of Legal Nurse Consultants, Denver, CO 2012 Rape in the Acute Care Facility, Western Regional Legal Nurse Consultants; Orange Co., CA The LNC, The Electronic Medical Record and New Technology, Western Regional Legal Nurse Consultants, Orange Co, CA 2011 Fall into Success, Research Techniques, Case of the Lettuce Patch Murder, Demonstrative Evidence, Missed CVA Diagnosis in the ED, Expert Witnessing: Direct and Cross Examination, When Pressure Rises and Results in Litigation, Poiont of view: Working up the case, Finessing your Writing Skills, News in Health Care Regulation, 7 Steps to Building your LNC Practice, American Association Legal Nurse Consultants, Massachusetts. Traumatic Brain Injury, American Association Legal Nurse Consultants, San Diego, CA. [Type text] 2010 From File to Trial, American Association Legal Nurse Consultants, Orange Co., CA Advanced Directives: Litigation and Legislation, American Association Legal Nurse Consultants, Orange Co., CA Spinal Impairments – Diagnosis and Treatment; presented by Dr. Jeffrey Gross, American Association Legal Nurse Consultants, Orange Co., CA Case of Too Many Complaints, LNC and The Accident Recnstructionist; Technology in the Courtroom; Welcome to the Emergency Room: Have a Seat and Call Your Lawyer; Criminal Prosecution of Healthcare Providers: Implications for Nurse Attorneys and Legal Nurse Consultants; Wound Care Litigation:An Analysis of Real-world Defense and Plaintiff Cases; Proving Medical Causation in Product Liability Cases; End-of-Life Care and Decision Making in Dementia; Medicare Compliance: What the LNC Needs to Know; Integrating Healthcare Reimbursement with LNC Work Including LCPs, Damage Determinations and Fraud Examination; Negligence in Home Healthcare; American Association of Legal Nurse Consultants, Pittsburgh, PA. 2009 Elder Law Face-Off-Why the Other Side is Just Wrong; Managing the Assisted Living Case; What Legal Nurse Consultants Need to Know About How Jurors Make Decisions; E-Discovery and the Electronic Medical Record; Complex Regional Pain Syndrome; Developing Partnership with Elder Abuse Litigation Team; Proficient LNC Use of Technology and Data Management/ New Challenges in Wound Care Litigation; American Association of Legal Nurse Consultants, Phoenix, AZ Falls are a Risky Business, American Association of Legal Nurse Consultants, Orange Co, , CA. 2008 Critical Thinking:Managing Stress; Acute and Chronic Pain: Assessment and Management; Forensic Evidence Collection for Nurses; Medication Safety: Assuring Safe Outcomes; Professional Communication and Documentation: Safe, Effective and Legal; Fall Assessment and Prevention; RN, San Diego, CA. 2007 Revolution: Health Care, Gamma Knife, Leadership & Conflict Resolutions; Observation: Challenges of Coverage & Compliance; America Association of Medical Audit Specialists, Williamsburg, VA 2006 Interventional Radiology and Cardiology; Billing for Supplies and More; Complementary & Alternative Therapy; Ostomy Care; American Association of Medical Audit Specialists, Houston, TX 2005 “Neurosurgical Issues”, American Association of Legal Nurse Consultants, Orange Co, CA. Role of Nutrition in Litigation and Clinical Outcome; Back Pain, Distinguishing Fact from Fiction; Neurological Electrodiagnostic Testing; Drug Product Liability & Vicarious Liability of Healthcare Providers and Hospitals; American Association of Legal Nurse Consultants, Anaheim, CA 2004 Domestic Violence Strangulation: Coordinating Dispatch, Police, Medical, Prosecution & Advocacy Responses, Battered Women’s Justice Project, San Diego, CA. Civil Litigation and the LNC; The Courtroom as a Theater; Criminal Litigation and the Legal Nurse Consultant; Problems in Shaken Baby Syndrome Litigation; American Association of Legal Nurse Consultants, Orange Co., CA.. Investigating, Recognizing & Interviewing Techniques Related to Child Abuse; American Association of Legal Nurse Consultants, Orange Co., CA. 2003 “Just the Facts – Reviewing a Case for Merit”; American Association of Legal Nurse Consultants, Orange Co, CA. Developing and Presenting Technical Demonstrative Evidence; Preparing the Nurse for Deposition Testimony; Elder Mistreatment; Dealing with the Difficult Pain Patient; Fraud and Abuse: Opportunities for the LNC; American Association of Legal Nurse Consultants, Philadelphia, PA 2002 Legal Nurse in Criminal Arena, American Association of Legal Nurse Consultants, Orange Co, CA. 17th Annual Skin and Wound Care Symposium, Dallas, Texas [Type text] California Elder Abuse Litigation; Professional Education Systems Institute; Costa Mesa, CA, 2001 Wound Care Standards; Acute and Chronic Pain Management: Defining Standards of Care; Fact Witnessing; Product Liability Torts; American Association of Legal Nurse Consultants, Denver, CO. Molds: Current Trends in Litigation; American Association of Legal Nurses Consultants, Orange, CA 2000 LiabilityAssociated with Acts of Nonphysician-Licensed Practitioners; Role of the LNC in Nursing Home Negligence; Writing for Lawyers; Cancer Diagnosis: Delay, Nondiagnosis, Misdiagnosis and Managed Care Roadblocks; Fraud & Abuse; Forensic Psychiatric Evaluation of Trauma Claims, American Association of Legal Nurse Consultants, St. Louis, MO. California Nursing Home Negligence, Professional Education Systems, Inc., San Jose, CA 1999 Loss Prevention in the Perioperative Environment, Catholic Healthcare West & Daughters of Charity, San Diego, CA Managed Care and Its Impact on Healthcare Organizations and Systems of Health Care, Putting a Halt to Medicare Fraud and Abuse, Ethical and Legal Issues in Genetic Testing, Deposition and Trial Questions: Using Special Interrogatories, Legal Issues for Staff Nurses, Forensic Document Investigative Techniques, Elder Abuse Litigation,Causation Issues: Brain-Damaged Baby Cases, National Conference, American Association of Legal Nurse Consultants, Reno, NV 1998 Managed Care or Managed Chaos, American Association of Legal Nurse Consultants, Long Beach, CA Pharmaceutical Liability, American Association of Legal Nurse Consultants, Orange, CA Investigating for Fraud in Low Speed Rear Impact Collisions; Biomechanics of Injury in Low Speed Rear Impact Collisions. SATAI, Laughlin, NV Issues in Litigation Involving Older Adults; Understanding Hospital Accountability; ERISA: Linchpin of the Managed Care; Senate Bill 386: The Right to Sue any Managed Care Facility that 'Affects Quality of Care'; Managed Care Liability Issues; Focus Groups and Mock Trials. National Conference, American Association of Legal Nurse Consultants, Dallas, TX. [Type text] Agnes M. Grogan, RN Fee Schedule Taxpayer ID 27-1200464 PROFESSIONAL RATES FOR LEGAL NURSE CONSULTANT Medical Record Review/Summary/Analysis ........... $200.00/Hour Medical Bill Review............................................. $200.00/Hour Attendance only at Mediation/Arbitration/Trial ........ $200.00/Hour Expert Testimony- Deposition/Arbitration/Trial ....... $400.00/Hour Minimum one hour fee for testimony; also minimum one hour fee if canceled in less than 24 hours from scheduled appearance Miscellaneous Requests ...................................... $200.00/Hour RETAINER Standard .................................................................. $800.00 Note: Retainers may be waived at discretion of consultant. MISCELLANEOUS CHARGES Travel Time ............................................ Standard Hourly Rate Parking fees, telephone, postage, meals, airfare, car rental, lodging, etc ................................................................ at cost Effective for new assignments January 1, 2020