Party Discovery: LORI BUSH -V- ST BERNADINE MEDICAL CENTER Print

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                                1    THOMPSON           COLEGATE LLP
      3610 Fourteenth Street
 2    P O Box 1299
      Riverside California 92502                                      S P
                                                                          R oR            E
 3    Tel   951 682 5550                                                   v y      U T OF
                                                                      ANBERN
      Fax   951   781 4012                                                          pg
                                                                                         0c ARDNp      A

 4
                                                                                                oivrsipN
      DIANE MAR WIESMANN               SBN 124409                              UN    3
 5    dwiesmann@tclaw net
                                                                                         2017
      MAXINE M MORISAKI               SBN 134361
 6                                                                         7
      mmorisaki@tclaw net



 7    Attorneys for Defendant
      DIGNITY HEALTH erroneously sued and served as
 s    ST BERNARDINE MEDICAL CENTER

 9



 p                           SUPERIOR COURT OF THE STATE OF CALIFORNIA


1 t            FOR THE COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT


12



13    LORI BUSH     an   individual                     CASE NO CIVDS 1613161


 4                   Plaintiff                          JUDGE    Hon John M Pacheco
                                                        Dept     S31
15    v

                                                        REVISED MODIFIED ORDER
16    ST BERNARDINE MEDICAL CENTER a                    PURSUANT TO COURT S RULING ON
      business entity form unknown DIGNITY              SUBMITTED MA           TER
17    HEALTH a California Corporation and DOES 1
      through 200 inclusive                             Date   Apri118 2017
18                                                      Time    8 30 a m
                     Defendants                         Dept    S31
19



20    DIGNITY HEALTH
                                                        TRIAL DATE              NONE
21                   Cross Complainant                  ACTION FILED            11 08 2016 FAC


22    v




23    TOTAL PROFESSIONAL NETWORK INC
      and ROES 1 100 inclusive
24

                     Cross Defendants
25



26



27



28




                                                    1
       MODIFIED ORDER ON MOTIONS TO COMPEL FURTHER RESPONSE BY DEFENDANT DIGN TY HEALTH
i




                                   1




     1   I        On April 18 2017          at   8 30   a m     in Department S31 of the above entitled Court the Motion

    2    to Compel Further Response to Form and Special Interrogatories Set One against Plaintiff of

    3
         Defendant DIGNITY HEALTH erroneously sued and served as ST BERNARDINE MEDICAL
    4    CENTER and the Motion to Compel Further Response to Request for Production of Documents Set

    5    One against Plaintiff of that same defendant came on regularly for hearing before the above entitled
    6
         Court At the hearing the Court issued its tentative ruling
     7
                  Having considered the moving papers including declarations and exhibits opposition and
     8                                                                 the Court took the matter                      On April
         reply   papers   and after
                                        hearing   oral argument                                    under submission



     9   24 2017 the court served its Ruling on Submitted Matter which included that moving party prepare

    10   Modified Orders

    11                                                         MODIFIED ORDER


    l2   FORM AND SPECIAL INTERROGATORIES

    13            Form Interro atory No 4 1 The court will overrule objections and grant the motion

    14            Form    Interro          v     No   6 5      The court will inquire if a further response specifically

    15
         identifying from which records responsive information can be deduced would be sufficient and if so
    16   the court will grant the motion in part on that basis


                  Form Interro                          12 2    12 3   12 5   12 5         12 7    The court will overrule the
                                           y Nos
    17                                 a                                             and



    18                                 the motion
         objections and       grant                     Bush has not demonstrated attorney client privilege and attorney

    19
         work product privilege apply

    2o            S   ecial   Interro       v No 9 The court will overrule objections and grant the motion as to any

    21   unprivileged information

    22            Special Interro atory No 14 The court will overrule objections and grant the motion as to

    23   information on the medical providers from whom she obtained services and the total charges

    24                        Interro
                      ecial
                                               y No 15 The court will sustain objection on the grounds of vagueness

    25
         and compound and deny the motion
    26                ecial   Interro          v No 16 The court will sustain objection based on Britt v Superior Court

    27       1978 20 Cal 3d 844 and grant the motion in part as to full and complete information on medical

    28   providers for 3 years prior to the incident up to the present as it pertains to the types of injuries

                                                                          2
             MODIFIED ORDER ON MOTIONS TO COMPEL FURTHER RESPONSE BY DEFENDANT DIGNITY HEALTH