On August 10, 2016 a
Party Statement
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
2 13 2017 9 48 AM FROM 666446764 T0 97088586 P 3
CM 1 ld
AT QRtdEY R pAiZTY th9 Gli f A 1 i ORNtY 7Name S ta e Gar curnCcr r r d add mssl FOR COURT USE ONL Y
Michael J Libman Esq SBN 222353 0
l aw Offices of Michaef J Libman APC
18321 Ventura Boulevard Suita 700 Tarzana C 1 91356
B IS 9 7 OQ
SNO t
TELFPNC VE NU J FaxN tonr na Sl iV
A
E MAIL ADC3RESS fOU orat C i TF4 CT
ATTORttiEY FCR Name P c111tIfF LORI BUSN 4 Z IA
SUPERIqFt COURT OF CALIF 7RNlA courarY o SAN BERNAROIN G 1
srrtE rrnoot e ss 24 W Tftird Street
A uNG ooH ss me as above
c T nr nz acooe San Bernardino CA 92415 Y DEPl1TY
SANDRA QRTEG
BRANCHNAME JUS ICe C fl @Y
PLAINTIFFlPETITIOtJER LORI BUSH
oEFENaANTrREs oN NT ST BERNARDINE MEDICAL CENTER ET AL
cn se au r e r
CASE MANAGEMENT S7ATEMENT
CIVDS1613161
Check one UNLEMITED CASE LIMITE CASE
Amount dsmanded Amaunt demanded is 25 000
exceeds 25 OOQ o less
A CASE MANAG MENT CONFERENCE is scheduled as follows
S31 Oiv Room
Date February 22 2017 Time 8 3 a m Dept
Address ot court f ditferenr irom the address adove
Notice of Intent to Appear by Telephone by name Michael J Libman Esq
INSTRUCTIQNS All applicable boxes must be checked and the speciFied information must be provided
1 Pa ty or parties answ erone
a J This statement is submitted by party name Plaintiff LORI BUSH
b This statement is submitted jointty by parties names
2 Comp aint and cross complaint fo be answered by plaintiffs and cross complainarafs only
a The complaint was filed on date 8 10 2016
b The cross complaint if any was filed on date
3 Service to be answered by plainfif s and cross compiainants only
a All pafties named in the complaint and cross complaint have been served have appeared or have been dismissed
b L The foliow ng parties named in the complaint or cross camplaint
1 have not been served specify names and explarn why r ot
Total Professional Network Inc
2 0 have been served but have not appeared and have not been dismissed specify names
3 O have had a default entered against them speci y narnes
c 0 The foilowing additional parties may be added specrfy names n ture of invoiverrtent rn casc arrd date by whicta
they r ay be servedJ
4 Descrtption of case
Type of case in Descrrbe including causes of actio
a 0 complaint cross complaint
Personal injuries with prafessional negligence general negligence and premises liabili y causes of action
Page 1 of 6
c ri u esotco r
r rm aa nea er tandato vUse CASE MANAGEMENT S7ATEMENT tiles5J20 s
J iAcial t mci ef Calilom 3 www couv 3 ca ur
CM t0 jRrV J 21y 1 201 tj
2 13 2017 9 48 AM FROM 666446764 T0 1 97088586 P 4
CM 110
se r ur e R
PLAINTIFFIPETITICNER LORI BUSH
CIVQS1613161
EFENDANTlRESPONDENT ST BERNARDINE M DIGAL CENTER ET AL
4 b Provide a brief statement of the case including any damages fpersonal iitjury damages are sought specify the irrjerry and
damages clarmed including medical expenses to date indicate source and amounfj estrmated future medicat expenses losi
earnirgs to date and est ma ed future tost earnings fequrtabte relret rs sotrght describe the atu e of tha refrsL
Plaintiff was a patient at Oefendant s facility While in Defendant s care past orthopedic surgery due to lack of
proper care and negligence by medical staff as welf as custodial staff Plaintiff fell in Defendant s bathraom
sustaining serious injuries Piaintiff s medical specials to date are in excess of 93 698 OQ Plaintiff will require
future care and treatmenf the exact nature and cost is undetermined ai this time
0 tf more s ace rs needed check this box and attach a page desigrtaied as Attachment 4b
5 Jury or nonjury triai
The party or parties request a jury trial a nonjury triaL tfmore than one party previde the name of each par y
requesting a jur triaiJ
6 Trial date
a Ti e triaf has been set for date
b No trial date has been set This case will ae ready for tr al within 12 mon hs o the date of the filing of the complaint if
not explairt
c Dates on which parties or attorneys will nct 6e available for trial s ecify dafes and explairi reasons tor unavailabifity
212017 3l21 2G17 4i4 2017 4110 2Q17 4i20 2017 5I2017 9111 2097 9122i2017 12 712417 12115 2017
1 9 2018 1 30 2017 5i29 2018 615l2017 6i2512418 7 10I2017 3 11J2019 3120l2019
7 Estimated length of trial
The party or artias estimate ihat the trial wifl take check o e
days 7
a specrfy number
b h urs shor causes specify
8 Trial representation fo be answered foreach party
The party ar parties w ll be represented at trial I by the aYorney or party listed in the caption 0 by the followirg
a Attorney
b Firm
c Address
d Telephone number f Fax number
e E mail address g Parly represented
Additional representation is described in P ttachment 8
9 Preference
This case is en itled to pref2rence specify cade secfian
10 Alternaiive dispute resolution ADR
a ADR information package Please note that diffarent ADR process2s are available in different courts and communities read
the ADR in ormation package provided by the court under rule 3 221 for informaBon about the processes available through the
court and community programs in this case
i For parties represented by counsel Counsel has has not provided the ADR information package identified
in rule 3 221 to the client and reviewed ADR options with the client
2 For self represented parties Parfy 0 has 0 has not reviewed the ADR information package identified in rule 3 221
b Referral to judicial arbitration or civii actian mediation if available
1 Q This matter is sub ect to mandatary judicial arbitration under Cnde of Civil Procedure seCtion 1141 11 or to civii action
mediation under Code of Civil F ror dure section 1775 3 because the amount in controversy dass not exceed the
statutory limii
2 Plaintiff elects to refer this case to judiciai arbitratian and agrees to limit recovery to the amount specified in Code o
Civii Pracedure se tion 1141 11
3 This ase is exempt from judical arbitration under rule 3 811 of ths California Rules oF Courtor from civil action
mediation under Code of Ci lii Procedure section 1775 et seq spedfy exemption
Paqe 2 6
of
GASE MANAGEMENT STATEMENT
CM 70 Rev Ju y t 2011j
Document Filed Date
February 14, 2017
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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Preview
2 13 2017 9 48 AM FROM 666446764 T0 97088586 P 3 CM 1 ld AT QRtdEY R pAiZTY th9 Gli f A 1 i ORNtY 7Name S ta e Gar curnCcr r r d add mssl FOR COURT USE ONL Y Michael J Libman Esq SBN 222353 0 l aw Offices of Michaef J Libman APC 18321 Ventura Boulevard Suita 700 Tarzana C 1 91356 B IS 9 7 OQ SNO t TELFPNC VE NU J FaxN tonr na Sl iV A E MAIL ADC3RESS fOU orat C i TF4 CT ATTORttiEY FCR Name P c111tIfF LORI BUSN 4 Z IA SUPERIqFt COURT OF CALIF 7RNlA courarY o SAN BERNAROIN G 1 srrtE rrnoot e ss 24 W Tftird Street A uNG ooH ss me as above c T nr nz acooe San Bernardino CA 92415 Y DEPl1TY SANDRA QRTEG BRANCHNAME JUS ICe C fl @Y PLAINTIFFlPETITIOtJER LORI BUSH oEFENaANTrREs oN NT ST BERNARDINE MEDICAL CENTER ET AL cn se au r e r CASE MANAGEMENT S7ATEMENT CIVDS1613161 Check one UNLEMITED CASE LIMITE CASE Amount dsmanded Amaunt demanded is 25 000 exceeds 25 OOQ o less A CASE MANAG MENT CONFERENCE is scheduled as follows S31 Oiv Room Date February 22 2017 Time 8 3 a m Dept Address ot court f ditferenr irom the address adove Notice of Intent to Appear by Telephone by name Michael J Libman Esq INSTRUCTIQNS All applicable boxes must be checked and the speciFied information must be provided 1 Pa ty or parties answ erone a J This statement is submitted by party name Plaintiff LORI BUSH b This statement is submitted jointty by parties names 2 Comp aint and cross complaint fo be answered by plaintiffs and cross complainarafs only a The complaint was filed on date 8 10 2016 b The cross complaint if any was filed on date 3 Service to be answered by plainfif s and cross compiainants only a All pafties named in the complaint and cross complaint have been served have appeared or have been dismissed b L The foliow ng parties named in the complaint or cross camplaint 1 have not been served specify names and explarn why r ot Total Professional Network Inc 2 0 have been served but have not appeared and have not been dismissed specify names 3 O have had a default entered against them speci y narnes c 0 The foilowing additional parties may be added specrfy names n ture of invoiverrtent rn casc arrd date by whicta they r ay be servedJ 4 Descrtption of case Type of case in Descrrbe including causes of actio a 0 complaint cross complaint Personal injuries with prafessional negligence general negligence and premises liabili y causes of action Page 1 of 6 c ri u esotco r r rm aa nea er tandato vUse CASE MANAGEMENT S7ATEMENT tiles5J20 s J iAcial t mci ef Calilom 3 www couv 3 ca ur CM t0 jRrV J 21y 1 201 tj 2 13 2017 9 48 AM FROM 666446764 T0 1 97088586 P 4 CM 110 se r ur e R PLAINTIFFIPETITICNER LORI BUSH CIVQS1613161 EFENDANTlRESPONDENT ST BERNARDINE M DIGAL CENTER ET AL 4 b Provide a brief statement of the case including any damages fpersonal iitjury damages are sought specify the irrjerry and damages clarmed including medical expenses to date indicate source and amounfj estrmated future medicat expenses losi earnirgs to date and est ma ed future tost earnings fequrtabte relret rs sotrght describe the atu e of tha refrsL Plaintiff was a patient at Oefendant s facility While in Defendant s care past orthopedic surgery due to lack of proper care and negligence by medical staff as welf as custodial staff Plaintiff fell in Defendant s bathraom sustaining serious injuries Piaintiff s medical specials to date are in excess of 93 698 OQ Plaintiff will require future care and treatmenf the exact nature and cost is undetermined ai this time 0 tf more s ace rs needed check this box and attach a page desigrtaied as Attachment 4b 5 Jury or nonjury triai The party or parties request a jury trial a nonjury triaL tfmore than one party previde the name of each par y requesting a jur triaiJ 6 Trial date a Ti e triaf has been set for date b No trial date has been set This case will ae ready for tr al within 12 mon hs o the date of the filing of the complaint if not explairt c Dates on which parties or attorneys will nct 6e available for trial s ecify dafes and explairi reasons tor unavailabifity 212017 3l21 2G17 4i4 2017 4110 2Q17 4i20 2017 5I2017 9111 2097 9122i2017 12 712417 12115 2017 1 9 2018 1 30 2017 5i29 2018 615l2017 6i2512418 7 10I2017 3 11J2019 3120l2019 7 Estimated length of trial The party or artias estimate ihat the trial wifl take check o e days 7 a specrfy number b h urs shor causes specify 8 Trial representation fo be answered foreach party The party ar parties w ll be represented at trial I by the aYorney or party listed in the caption 0 by the followirg a Attorney b Firm c Address d Telephone number f Fax number e E mail address g Parly represented Additional representation is described in P ttachment 8 9 Preference This case is en itled to pref2rence specify cade secfian 10 Alternaiive dispute resolution ADR a ADR information package Please note that diffarent ADR process2s are available in different courts and communities read the ADR in ormation package provided by the court under rule 3 221 for informaBon about the processes available through the court and community programs in this case i For parties represented by counsel Counsel has has not provided the ADR information package identified in rule 3 221 to the client and reviewed ADR options with the client 2 For self represented parties Parfy 0 has 0 has not reviewed the ADR information package identified in rule 3 221 b Referral to judicial arbitration or civii actian mediation if available 1 Q This matter is sub ect to mandatary judicial arbitration under Cnde of Civil Procedure seCtion 1141 11 or to civii action mediation under Code of Civil F ror dure section 1775 3 because the amount in controversy dass not exceed the statutory limii 2 Plaintiff elects to refer this case to judiciai arbitratian and agrees to limit recovery to the amount specified in Code o Civii Pracedure se tion 1141 11 3 This ase is exempt from judical arbitration under rule 3 811 of ths California Rules oF Courtor from civil action mediation under Code of Ci lii Procedure section 1775 et seq spedfy exemption Paqe 2 6 of GASE MANAGEMENT STATEMENT CM 70 Rev Ju y t 2011j