On August 10, 2016 a
Motion,Ex Parte
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
t THOMPSON COLEGATE LLP
3610 Fourteer th Street SUPERI4R COU r
COUN7Y uqN FORNIA
2 P O Box 129 SAN R na qa
ARDINO
p DISTRICT
Riverside Ca ifornia 92502
3 Tel 951 68 5550
Fax 951 781 4012
JAN p 3 Zp g
4
DIANE MAR WIESMANN SBN 124409
5 dwiesmann@tcla v net RE INA CHANEZ EPUTy
MAXINE M MORISAKI SBN 134361
6 mmorisaki@tclaw net
7 Attorneys for efendant Cross Complainant DIGNITY HEALTH erroneously sued and
served as ST I3ERNARDINE MEDICAL CENTER
8
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT
1
t2
LORI BUSH in individual CASE NO CIVDS 1613161
13
Plaintiff JUDGE Hon John M Pacheco
14 Dept S31
v
15 DECLARATION OF MAXINE M
ST BERNARf INE MEDICAL CENTER a MORISAHI IN SUPPORT OF MOTION
16 business entity form unknown DIGNITY TO COMPEL PLAINTIFF S DEPOSITION
HEALTH a C lifornia Corporation and DOES 1
17 through 200 inclusive
Filed concurrently with Notice of Motion
and Motion to Compel Deposition of
18 Defendants Plaintiff Proposed Order
19 Date February 6 2018
DIGNITY HE LTH Time 8 30 a m
20 Dept S31
Cross Complainant
21
v
22
TOTAL PROFESSIONAL NETWORK INC TRIAL DATE 04 30 2018
23 and ROES 1 1 J0 inclusive ACTION FILED 11 08 2016 FAC
24 Cross Defendants
25
26
2 I MAXINE M MORISAKI declare as follows I
28 1 I am an Associate of the law firm of Thompson Colegate LLP attorneys of record
1
DECLARATION OF MAXINE M MORISAKI IN SUPPORT OF MOTION TO COMPEL PLAINTIFF S
DEPOSITION
1
herein for Defendant Cross Complainant DIGNITY HEALTH erroneously sued and served as ST
2 BERNARDINE MEDICAL CENTER hereinafter DEFENDANT
also
I have been duly
3 admitted to practice law in the State of California I make this declaration in support of Motion to
4 Compel Plaintiff s Deposition with request for monetary sanctions or in the alternative an
5
evidentiary sanction If called upon I could and would competently testify hereto
6 2 has to depose Plaintiff LORI BUSH hereinafter also
My office attempted
7 PLAINTIFF a total of five 5 times The fifth time is set for January 16 2018 I am filing this
8 motion to compel in the event the deposition is once again and on short notice cancelled My office
9
will take the instant motion off calendar in the event PLAINTIFF submits to her properly noticed
1o
deposition on January 16 2018
11 3 The initial notice of deposition of PLANITIFF was
by my office on June 16 2017 I
12
purposely set it out six 6 weeks because I wanted PLAINTIFF S further responses to discovery
13 which were then
pending after meet and confer attempts It was cancelled at the last minute
14 Subsequent notices were initiated by TPN and
my office has joined them TPN This is because
15 PLAINTIFF objected to the distance to travel to Riverside and TPN s counsel s office is located in
16 the San Fernando Please see true and correct copies of the
the same geographic area of Valley
17 deposition PLAINTIFF
notices and s objections
noting that they occur essentially at the last
18 possible moment allowable per the Code
19
20 6 16 17 DEFENDANT S notice of 7 27 17 which was six 6 weeks out Exhibit 1
21 7 19 17 PLAINTIFF S objection that PLAINTIFF and her attorney are not available Exhibit
22 2
23 8 9 17 TPN notice ofdeposition of PLAINTIFF set for 8 28 17 Exhibit 3
24 8 10 17 DEFENDANT S joinder in the notice ofdeposition Exhibit 4
25 8 23 17 PLAINTIFF S objection and PLAINTIFF and her attorney are not available Exhibit
26 ccs
27 8 24 17 TPN notice ofcontinued deposition ofPLAINTIFF for 10 3 17 Exhibit 6
28 8 28 17 DEFENDANT S joinder in the notice of deposition Exhibit 7
2 I
DECLARATION OF MAXINE M MORISAKI IN SUPPORT OF MOTION TO COMPEL PLAINTIFF S
DEPOSITION I
Document Filed Date
January 03, 2018
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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t THOMPSON COLEGATE LLP 3610 Fourteer th Street SUPERI4R COU r COUN7Y uqN FORNIA 2 P O Box 129 SAN R na qa ARDINO p DISTRICT Riverside Ca ifornia 92502 3 Tel 951 68 5550 Fax 951 781 4012 JAN p 3 Zp g 4 DIANE MAR WIESMANN SBN 124409 5 dwiesmann@tcla v net RE INA CHANEZ EPUTy MAXINE M MORISAKI SBN 134361 6 mmorisaki@tclaw net 7 Attorneys for efendant Cross Complainant DIGNITY HEALTH erroneously sued and served as ST I3ERNARDINE MEDICAL CENTER 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT 1 t2 LORI BUSH in individual CASE NO CIVDS 1613161 13 Plaintiff JUDGE Hon John M Pacheco 14 Dept S31 v 15 DECLARATION OF MAXINE M ST BERNARf INE MEDICAL CENTER a MORISAHI IN SUPPORT OF MOTION 16 business entity form unknown DIGNITY TO COMPEL PLAINTIFF S DEPOSITION HEALTH a C lifornia Corporation and DOES 1 17 through 200 inclusive Filed concurrently with Notice of Motion and Motion to Compel Deposition of 18 Defendants Plaintiff Proposed Order 19 Date February 6 2018 DIGNITY HE LTH Time 8 30 a m 20 Dept S31 Cross Complainant 21 v 22 TOTAL PROFESSIONAL NETWORK INC TRIAL DATE 04 30 2018 23 and ROES 1 1 J0 inclusive ACTION FILED 11 08 2016 FAC 24 Cross Defendants 25 26 2 I MAXINE M MORISAKI declare as follows I 28 1 I am an Associate of the law firm of Thompson Colegate LLP attorneys of record 1 DECLARATION OF MAXINE M MORISAKI IN SUPPORT OF MOTION TO COMPEL PLAINTIFF S DEPOSITION 1 herein for Defendant Cross Complainant DIGNITY HEALTH erroneously sued and served as ST 2 BERNARDINE MEDICAL CENTER hereinafter DEFENDANT also I have been duly 3 admitted to practice law in the State of California I make this declaration in support of Motion to 4 Compel Plaintiff s Deposition with request for monetary sanctions or in the alternative an 5 evidentiary sanction If called upon I could and would competently testify hereto 6 2 has to depose Plaintiff LORI BUSH hereinafter also My office attempted 7 PLAINTIFF a total of five 5 times The fifth time is set for January 16 2018 I am filing this 8 motion to compel in the event the deposition is once again and on short notice cancelled My office 9 will take the instant motion off calendar in the event PLAINTIFF submits to her properly noticed 1o deposition on January 16 2018 11 3 The initial notice of deposition of PLANITIFF was by my office on June 16 2017 I 12 purposely set it out six 6 weeks because I wanted PLAINTIFF S further responses to discovery 13 which were then pending after meet and confer attempts It was cancelled at the last minute 14 Subsequent notices were initiated by TPN and my office has joined them TPN This is because 15 PLAINTIFF objected to the distance to travel to Riverside and TPN s counsel s office is located in 16 the San Fernando Please see true and correct copies of the the same geographic area of Valley 17 deposition PLAINTIFF notices and s objections noting that they occur essentially at the last 18 possible moment allowable per the Code 19 20 6 16 17 DEFENDANT S notice of 7 27 17 which was six 6 weeks out Exhibit 1 21 7 19 17 PLAINTIFF S objection that PLAINTIFF and her attorney are not available Exhibit 22 2 23 8 9 17 TPN notice ofdeposition of PLAINTIFF set for 8 28 17 Exhibit 3 24 8 10 17 DEFENDANT S joinder in the notice ofdeposition Exhibit 4 25 8 23 17 PLAINTIFF S objection and PLAINTIFF and her attorney are not available Exhibit 26 ccs 27 8 24 17 TPN notice ofcontinued deposition ofPLAINTIFF for 10 3 17 Exhibit 6 28 8 28 17 DEFENDANT S joinder in the notice of deposition Exhibit 7 2 I DECLARATION OF MAXINE M MORISAKI IN SUPPORT OF MOTION TO COMPEL PLAINTIFF S DEPOSITION I