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
SUPERIQR COURT OF C ALIFORNIA
COUN7Y OF SAN BFRNARDINO
t THOMPSON COLEGAT LLP SAN 6EF NARDINU DISTfiICT
3610 Fourteenth Street
2 P O Box 1299 OCT 0 7 2016
Riverside California 92502
3 Tel 951 682 5550
Y
Fax 951 781 4012
CHRIuTI DE UTY
4
DIANE MAR WIESMANN SBN 124409
5 dwiesmann@tclaw net
MAXINE M MORISAKI SBN 134361
mmorisaki@tclaw net
7 Attorneys for Defendant DIGNITY HEALTH erroneously sued and served as
ST BERNARDINE MEDICAL CENTER
s
9
SUPERIOR COURT OP THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT
11
12
LORI BUSH an individual CASE NO CIVDS1613161
13
Plaintiff Hon John M Pacheco
t4 Dept S31
v
t5 NOTICE OF MOTION AND MOTION TO
ST BERNARDINE MEDICAL C NTER a STRIKE PORTIONS OF PLAINTIFF S
16 business entity Form unknown DIGNITY COMPLAINT MEMORANDUM OF
HEALTH a California Corporation and DOES 1 POINTS AND AUTHORITIES IN
t7 through 200 inclusive SUPPORT THEREOF
18 Defendants Date November 22 2016
Time 8 30 a m
t9 Dept S31
20 TRIAL DATE NONE
ACTION FILED 08 10 2016
21
22
23 TO PLAINTIFF AND TO HER ATTORNGYS OP RECORD HEREIN
Z4 PLEASE TAKE NOTICE that on November 22 2016 at 8 30 a m or as soon thereafrer as
ZS the matter may be heard in Department S31 of the above entitled Court located at 247 W Third
z6 Street San Bernardino California 92415 Defendant DIGNITY HEALTH erroneously sued and
27 served as ST BERNARDINE MEDICAL CENTER hereinafter DefendanP will move to strike
Zg the following portions of plaintiffls complaint
1
NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF PLAINTIFPS COMPLAINT MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT
THEREOF
1 Page 7 line 7 to page 8 line 9 paragraphs 26 33 the entire cause of action for
2 premises liability
3 2 Page 8 line ll to page 9 line 9 paragraphs 33 38 the entire cause of action for
4 negligence
5 9 Page 9 line 24 paragraph 11 of the prayer fJor such other and further relief
6 as the court may deem just and proper
7
The grounds for the motion pursuant to Code Civ Proa 435 et seq are that the complaint
8 contains irrelevant and improper matters including matters that are not drawn or filed in
9 conformity with the laws of this state Code Civ Proc 436
lo The motion will be based on this Notice the Memorandum of Points and Authorities filed
I 1 herewith the records and pleadings on file herein and on such other evidence as may be presented at
12 or before the hearing in this matter
t3 DATED SeptemberG 2016 THOMPSON COLEGATE LLP
14
I5
gy
DIANE M R WI SMANN
16
MAXINE MORISAKI
Attorneys for Defendant
DIGNITY HEALTH erroneously sued and
served as ST BERNARDINE MEDICAL
g
CENTER
l9
20
2
22
23
24
25
26
27
28
Z
NOTICE OF MOTION AND MOTION I O S CRIKE PORTIONS OF PLAINTIFPS COMPLAINT MGMORANDUM OF POINTS AND AUT HORI fIG51N SUPPORT
THF REOF
Document Filed Date
October 07, 2016
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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SUPERIQR COURT OF C ALIFORNIA COUN7Y OF SAN BFRNARDINO t THOMPSON COLEGAT LLP SAN 6EF NARDINU DISTfiICT 3610 Fourteenth Street 2 P O Box 1299 OCT 0 7 2016 Riverside California 92502 3 Tel 951 682 5550 Y Fax 951 781 4012 CHRIuTI DE UTY 4 DIANE MAR WIESMANN SBN 124409 5 dwiesmann@tclaw net MAXINE M MORISAKI SBN 134361 mmorisaki@tclaw net 7 Attorneys for Defendant DIGNITY HEALTH erroneously sued and served as ST BERNARDINE MEDICAL CENTER s 9 SUPERIOR COURT OP THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT 11 12 LORI BUSH an individual CASE NO CIVDS1613161 13 Plaintiff Hon John M Pacheco t4 Dept S31 v t5 NOTICE OF MOTION AND MOTION TO ST BERNARDINE MEDICAL C NTER a STRIKE PORTIONS OF PLAINTIFF S 16 business entity Form unknown DIGNITY COMPLAINT MEMORANDUM OF HEALTH a California Corporation and DOES 1 POINTS AND AUTHORITIES IN t7 through 200 inclusive SUPPORT THEREOF 18 Defendants Date November 22 2016 Time 8 30 a m t9 Dept S31 20 TRIAL DATE NONE ACTION FILED 08 10 2016 21 22 23 TO PLAINTIFF AND TO HER ATTORNGYS OP RECORD HEREIN Z4 PLEASE TAKE NOTICE that on November 22 2016 at 8 30 a m or as soon thereafrer as ZS the matter may be heard in Department S31 of the above entitled Court located at 247 W Third z6 Street San Bernardino California 92415 Defendant DIGNITY HEALTH erroneously sued and 27 served as ST BERNARDINE MEDICAL CENTER hereinafter DefendanP will move to strike Zg the following portions of plaintiffls complaint 1 NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF PLAINTIFPS COMPLAINT MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF 1 Page 7 line 7 to page 8 line 9 paragraphs 26 33 the entire cause of action for 2 premises liability 3 2 Page 8 line ll to page 9 line 9 paragraphs 33 38 the entire cause of action for 4 negligence 5 9 Page 9 line 24 paragraph 11 of the prayer fJor such other and further relief 6 as the court may deem just and proper 7 The grounds for the motion pursuant to Code Civ Proa 435 et seq are that the complaint 8 contains irrelevant and improper matters including matters that are not drawn or filed in 9 conformity with the laws of this state Code Civ Proc 436 lo The motion will be based on this Notice the Memorandum of Points and Authorities filed I 1 herewith the records and pleadings on file herein and on such other evidence as may be presented at 12 or before the hearing in this matter t3 DATED SeptemberG 2016 THOMPSON COLEGATE LLP 14 I5 gy DIANE M R WI SMANN 16 MAXINE MORISAKI Attorneys for Defendant DIGNITY HEALTH erroneously sued and served as ST BERNARDINE MEDICAL g CENTER l9 20 2 22 23 24 25 26 27 28 Z NOTICE OF MOTION AND MOTION I O S CRIKE PORTIONS OF PLAINTIFPS COMPLAINT MGMORANDUM OF POINTS AND AUT HORI fIG51N SUPPORT THF REOF