On August 10, 2016 a
Hearing
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
q i p
MICIIAEL J LIBMAN SBN 222353
THE LAW OFFICES OF M C IAEL J LIBMAlV
2 F I L E D
18321 Ventura 13oulevard Suite 700 SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
3 Tarzana CallfOt rila 9 3S6
SAN BERNARDINO DISTRICT
Telephone 818 995 7300
4
Facsimile 866 644 6764 SEP 2 9 2017
rrrilCa2 l ibmanluw cam
s
BY 1
GARY BERKUVICI I SBN 192731 ANtvE PERRY EPUTY
6
i A PROFESSIONA CORPORATION
14900 Ventura oulevard Suite 220
Sherman Oaks California 91403
Telephone 818 465 9505
Facsiinile 818 358 2829
i
Attorneys for Plaintiff LORI BUSH
io
11 SUPERIOR COURT OF THE STATE OF CALlFO12NIA
l FOR THE COiTNTY OF SAN BERNARDINO SAN BERNARDINO DISTR CT
is
LORI BUSI I an indivicival CASE NO ClVDS16T3161
4 1
1
Plaintiff Judge Ho John M Pacheco
ly
vs Dept S31
6
NOTICE UF MOTION AND MOTIUN TO
1
ST BERNARDINE 1 IEDICAL CENTER a
COMPEL FURTHER RESPONSES TO
business entity form unknown DIGNITY
8 DEMAND FOR PRODUCTION OF
NEALTI t a California Corpqration and DOCUMENTS SET TWO
DOES 1 tl rough 200 inclusive
19 PROPOUNDED ON DEFENDANT
DIGNITY HEALTI 1ViEMORANDUM
0
Defendants OF POINTS AND AUTH012IT1ES WITH
1
REQUEST FOR MONETAIZY
SANCTIONS OF 4 085 00 SEPARATE
z
STATEEMNT OF ITEMS REQUIRING
FURTHCR RESPONSE DECLAR ITION
23 OF MICHAEL J LIBMAN PROPOSIEll
2
ORDER THEREON
25
DATE Nc vember 7 2017
T1ME 8 30 a m
26
DEPT S31
2 J
z
1
NOTICE OF MOTION AND MOTION TO COMPEI FUR I HEIt RESI ONSE TO DEMAND FOR
PRODUGTION OF UOCUMF NTS SET 2 MEMO Or P A DECL OF MICHAGL J LIBMAN ETC
t
1
TO DErENDANT AND ITS COUNSEti OF RECORD
2
PL AS TAKE NOTICE that on the date time and place set forth above at the abov
3
entitled Court or as soon thereafter as counsel may be heard Plaintiff LORT BUSH l ere nafCe
also PLAINTIFF will moye the Court for an orcier
compelling Defendant DIGNI
HEALTH to provide further answers without objections to Plaintif s Demand for Production o
6
Documents Set Two as more specifically identified herein and to pay to Plaintiff one
sancti ns iilcluding reasonable atto ney s fees and costs
totaling 4 085 00 incurred in tli
preparation filing and hearing of this motion
9
This motion is made pursuant to Gode of Civil P1 acedure 2031 010 2031 220
2031 230 and 2031 310 n the gr unds that the information requested is relevant to the sul jec
11
matter of this Iitigatioil is property discoverable and is not privileged Additional that th
interrogatories comply with the C ode of Civil Procedure by designating Defendant as fh
13
Responding Party and that the Defenclant is obligated to respond to the discovery Defendant
1 4
objections stated in response are improper and justify the production of further responses withou
1s
objection Plaintiff has engaged in mtiltiple meet and confer tele hone discus sions meet an
16 confer correspondence and still has not received supplemental responses
Accordingly
1
Defendant seeks monetary sanctions including attorney s fees and costs
totaling 4 085 0
1 8 against Defendauf its Code
ind attorney of r ecord pursuant to of Civrl Proc 2023 010
2023 020 and 2030 030
o
T11is inotion will be based upon this Notice the pleadings records and files herein tti
21
Memorancium of Points and Authorities and Declaratioii of Michael J Libman served and file
z2
herewith and upon such other and further oral and docttmentary evidence as may be presented a
23
the hearing of this motion
24
DATED Septem6er 29 2017 LAW OFFICLS ICHAEL J LIBMAN APC
a
6
By
IVII HA EL J LIBMAN
Attorneys for LORi BUSH
2
2
NOTICE OF N10TION AND MOTION 1 O COMPELFUI2THER RESPONSE TO DEMAND FOR
YRODUCTION OF DOCUMENTS SET 2 IVIEMO OF P A DECL OF MICHAEL J LIBMAN ETC
Document Filed Date
September 29, 2017
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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q i p MICIIAEL J LIBMAN SBN 222353 THE LAW OFFICES OF M C IAEL J LIBMAlV 2 F I L E D 18321 Ventura 13oulevard Suite 700 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO 3 Tarzana CallfOt rila 9 3S6 SAN BERNARDINO DISTRICT Telephone 818 995 7300 4 Facsimile 866 644 6764 SEP 2 9 2017 rrrilCa2 l ibmanluw cam s BY 1 GARY BERKUVICI I SBN 192731 ANtvE PERRY EPUTY 6 i A PROFESSIONA CORPORATION 14900 Ventura oulevard Suite 220 Sherman Oaks California 91403 Telephone 818 465 9505 Facsiinile 818 358 2829 i Attorneys for Plaintiff LORI BUSH io 11 SUPERIOR COURT OF THE STATE OF CALlFO12NIA l FOR THE COiTNTY OF SAN BERNARDINO SAN BERNARDINO DISTR CT is LORI BUSI I an indivicival CASE NO ClVDS16T3161 4 1 1 Plaintiff Judge Ho John M Pacheco ly vs Dept S31 6 NOTICE UF MOTION AND MOTIUN TO 1 ST BERNARDINE 1 IEDICAL CENTER a COMPEL FURTHER RESPONSES TO business entity form unknown DIGNITY 8 DEMAND FOR PRODUCTION OF NEALTI t a California Corpqration and DOCUMENTS SET TWO DOES 1 tl rough 200 inclusive 19 PROPOUNDED ON DEFENDANT DIGNITY HEALTI 1ViEMORANDUM 0 Defendants OF POINTS AND AUTH012IT1ES WITH 1 REQUEST FOR MONETAIZY SANCTIONS OF 4 085 00 SEPARATE z STATEEMNT OF ITEMS REQUIRING FURTHCR RESPONSE DECLAR ITION 23 OF MICHAEL J LIBMAN PROPOSIEll 2 ORDER THEREON 25 DATE Nc vember 7 2017 T1ME 8 30 a m 26 DEPT S31 2 J z 1 NOTICE OF MOTION AND MOTION TO COMPEI FUR I HEIt RESI ONSE TO DEMAND FOR PRODUGTION OF UOCUMF NTS SET 2 MEMO Or P A DECL OF MICHAGL J LIBMAN ETC t 1 TO DErENDANT AND ITS COUNSEti OF RECORD 2 PL AS TAKE NOTICE that on the date time and place set forth above at the abov 3 entitled Court or as soon thereafter as counsel may be heard Plaintiff LORT BUSH l ere nafCe also PLAINTIFF will moye the Court for an orcier compelling Defendant DIGNI HEALTH to provide further answers without objections to Plaintif s Demand for Production o 6 Documents Set Two as more specifically identified herein and to pay to Plaintiff one sancti ns iilcluding reasonable atto ney s fees and costs totaling 4 085 00 incurred in tli preparation filing and hearing of this motion 9 This motion is made pursuant to Gode of Civil P1 acedure 2031 010 2031 220 2031 230 and 2031 310 n the gr unds that the information requested is relevant to the sul jec 11 matter of this Iitigatioil is property discoverable and is not privileged Additional that th interrogatories comply with the C ode of Civil Procedure by designating Defendant as fh 13 Responding Party and that the Defenclant is obligated to respond to the discovery Defendant 1 4 objections stated in response are improper and justify the production of further responses withou 1s objection Plaintiff has engaged in mtiltiple meet and confer tele hone discus sions meet an 16 confer correspondence and still has not received supplemental responses Accordingly 1 Defendant seeks monetary sanctions including attorney s fees and costs totaling 4 085 0 1 8 against Defendauf its Code ind attorney of r ecord pursuant to of Civrl Proc 2023 010 2023 020 and 2030 030 o T11is inotion will be based upon this Notice the pleadings records and files herein tti 21 Memorancium of Points and Authorities and Declaratioii of Michael J Libman served and file z2 herewith and upon such other and further oral and docttmentary evidence as may be presented a 23 the hearing of this motion 24 DATED Septem6er 29 2017 LAW OFFICLS ICHAEL J LIBMAN APC a 6 By IVII HA EL J LIBMAN Attorneys for LORi BUSH 2 2 NOTICE OF N10TION AND MOTION 1 O COMPELFUI2THER RESPONSE TO DEMAND FOR YRODUCTION OF DOCUMENTS SET 2 IVIEMO OF P A DECL OF MICHAEL J LIBMAN ETC