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  • ODEH -V- FERNANDEZ Print Medical Malpractice Unlimited  document preview
  • ODEH -V- FERNANDEZ Print Medical Malpractice Unlimited  document preview
  • ODEH -V- FERNANDEZ Print Medical Malpractice Unlimited  document preview
  • ODEH -V- FERNANDEZ Print Medical Malpractice Unlimited  document preview
						
                                

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F I L E D SUPERIOR COURT 0F CALIFORNIA COUNTY 0F SAN BERNARDINO G. Michael Bradbury, DDS SA“ BERNARD” D'STR'CT Rhonda Bradbury 31525 Larga Vista 31525 Larga Vista DEC 0 4 2020 Valley Center CA 92082 Valley Center CA 92082 1‘ 760-751-1 155 760-751-1 155 mike@bhllc.us rhonda@'bhilc.us m Intervenor in pro per Intervenor in pro per 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF SAN BERNARDINO 12 13 UNLIMITED CIVIL CASE Ali Odeh l4 Plaintifi', No. CIVDS 1823772 15 Vs VERIFIED COMPLAINT FOR 16 Lyngadlen Silagan—Fernandez, DDS; Kingsly Dentistry and Ringo Bangalan, 1) FORGERY 17 FRAUD 2) DDS 18 3) FRAUDULENT CONCEALMENT Defendants 4) INTENTIONAL INTERFERENCE 19 WITH PROSPECTIVE ECONOMIC G. Michael Bradbury, DDS, Rhonda ADVANTAGE 20 5) NEGLIGENT INTERFERENCE WITH Bradbury, 21 PROSPECTIVE ECONOMC Intervenors ADVANTAGE 22 Vs. 6) VIOLATION OF CALIFORNIA PENAL CODE 115 23 Ali Odeh; Kat Cohan, 7) DEFAMATION PER SE 8) INTENTIONAL INFLICTION 0F 24 Intervenees EMOTIONAL DISTRESS 25 9) IDENTITY THEFT 10) INTRUSION INTO SECLUSION 26 2'7 28 1 VERIFIED PLEADING BRADBURY COME NOW INTERVENORS G. MICHAEL BRADBURY, DDS AND RHONDA BRADBURY, IN PRO PER, FILING THE PRESENT COMPLAINT AGAINST INTERVENEES ALI ODEH AND KAT COHAN AND STATE THE FOLLOWING. PARTIES 10 Intervenors G. Michael Bradbury, DDS and Rhonda Bradbmy are married individuals residing ll in San Diego County. 12 Intervenee Ali Odeh, Plaintiffin the present matter is an individual residing in Riverside 13 County . Intervenee Kat Cohan is a licensed attorney whose principal place of business is in Los Angeles l4 County. 15 l6 II. COMMON OPERATIVE FACTS Intervenor G. Michael Bradbury (“Mike”) is a semi-retired dentist with oflice in Northern l7 18 San Diego County. He has been in practice for forty~five years. His current practice consists oi 19 approximately one thousand patients. 20 Intervenor Rhonda Bradbury (“Rhonda”) is the omce manager of Mike’s practice. 2l Despite the fact of the semi-rural are in which Mike’s practice is located, he has a constant 22 stream of patients everyday-patients who rely on his expertise, his strong ethical standards, his: 23 compassionate care and the hos overall sterling reputation. 24 In his long and storied career he has never been sued and, conversely, he has not sued himself. 25 The events that occurred to him and the acts committed against him by intervenes Odeh and 26 Cohan are therefore unprecedented in nature for him. 27 28 2 VERIFIED PLEADING BRADBURY