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I ANN H. I.ARSON, ESQ. (State Bar No. 176461)
JOHN C. WON, ESQ. (State Bar No. 242743)
2 CRADDICK, CANDLAND J'c CONTI ELECTRONICALLY
A Professional Corporation
3 2420 Camino Ramon, Smte 202 F I L E D
Superior Court of California,
San Ramon, CA 94583-4202 County of San Francisco
4 Telephone: (925) 838-1100
Facsimile: (925) 743-0729 08/27/2019
Clerk of the Court
t E- il:
i
1
e
won',ccclawfirm. corn
BY: SANDRA SCHIRO
Deputy Clerk
6
Attorneys for Defendants,
7 REGENTS OF THE I JNIVERSITY OF
CALIFORNIA, ELEANOR DREY, M.D., and
8 WILLIAM WINKELMAN, M.D.
10
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
12
CHARLOTTE KERNAN and JOSH MOORE, No. CGC-18-564062
13
Plaintiffs
14 DECLARATION OF JOHN C. WON, ESQ.
vs. IN SUPPORT OF MOTION FOR
15 SUMMARY JUDGMENT, OR
RFGENTS OF THE UNIVFRSITY OF ALTERNATIVELY, SUMMARY
16 CALIFORNIA; CITY AND COUNTY OF SAN ADJIJDICATION, BY DEFENDANTS
FRANCISCO; FLFANOR DREY, M.D.; REGENTS OF THK UNIVERSITY OF
17 WILLIAM WINKEI.,MAN, M.D. CALIFORNIA, ELEANOR DREY, M.D.,
AND WILLIAM WINKKLMAN, M.D.
Defendants.
Date: November 15, 2019
19 Time; 9:30 a.m.
Dept. 302
20 Reservation No. 08261115-03
21 Complaint filed: February 2, 2018
Trial date: April 6, 2020
22
23
24 I, JOI IN C. WON, declare as follows:
25 I am an attorney licensed to practice in the State of California and an associate with the law
finn of Craddick, Candland Jr. Conti, attorneys of record for defendants, REGENTS OF THE
UNIVERSITY OF CALIFORNIA, ELEANOR DREY, M.D., and WILI.IAM WINKELMAN, M.D.
If called as a witness, I could competently testify to the following:
I
DECLARATION OF JOHN C. WON, ESQ. IN SUPPORT OF MOTION [...1 BY DEFENDANTS REGENTS OF THE
UNIVERSITY OF CALIFORNIA, ELEANOR DREY, M.D., AND WILLIAM ~LMAN, M.D.
Attached hereto and incorporated by reference herein as exhibits are true and correct copies
of the following documents:
Exhibit "A" Plaintiffs CHARLOTTE KERNAN and JOSH MOORE'S Complaint for
damages, filed February 2, 2018.
Exhibit "B" Notice of Intent, dated November 6, 2017.
Exhibit "C" Plaintiff CHARLOTTE KERNAN Responses to Special Interrogatories, Set
One.
Exhibit "D" Plaintiff JOSH MOORE Responses to Special Interrogatories, Set One.
Exhibit "K" Curriculum Vitae, Dr. James D. Byrne.
Exhibit "F" Excerpts of Zuckerberg San Francisco General Hospital medical records of
10 CHARLOTTE MOORE.
Exhibit "G" Fetal Monitoring Strip dated November 2, 2016.
12 Exhibit "H" Fetal Monitoring Strip dated November 4, 2016.
13 Exhibit "I" Autopsy Report dated November 8, 2016.
14 Exhibit "J" Marin Birth Center medical records.
15 Exhibit "K" Marin Health & Wellness medical records.
16
Executed this 'l(P day of August, California.
17
18
JO C ON
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20
21
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24
25
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2
DECLARATION OF JOHN C. WON, ESQ. IN SUPPORT OF MOTION [...] BY DEFENDANTS REGENTS OF THE
UNIVERSITY OF CALIFORNIA, ELEANOR DREY, M.D., AND WILLIAM WINKELMAN, M.D.
EXHIBIT A
EXHIBIT A
PLD-Pl-001
Y QR pARTY WITHOUT ATTORNEY IName. Sf ln 8
fnumber and nddmncl FOR COURT USE
RLOTTE KERNAN and JOSH MOORE
Panorama Drive
Francisco, CA 94131
NENO (415) 936 — 6449 FAXNoiopbnnnfi
DRESS (Opffonnll
YFORim.mei In prOpria perSOna
ytJDPPD
loRGQURTDFGALIFQRNIA,coUNTVDF san Francisco
sTREETADDREBB 400 ttcAllister Street Q'fl 2018
MAILING ADDRESS PP8
cITYANDzlp DDDESan Francisco, CA 9 4 1 02
Oj: THE COUKT
BRANCH NAME Ejuly.
PLAINTIFF: Charlotte Kernan
DEFENDANT,'Regents Df the Univernrty of california, city and county
of Sae 2'tanciecc, Sieanot Drey, M.D. Niliram Nickelmao, M.D.
El DoEs 1 yo 1nn
COMPLAINT-Personal Injury, Property Damage, Wrongful Death
~ AMENDED (hfumber)i
Type (check all that apply):
~~ NIOTOR VEHICLE
Property Damage
Qg
~
OTHER (specify)i
Wrongful Death
Medical Nealigence
~ Personal Injury ~ Other Damages (specify)i
Jurisdiction (check all that apply)i CASE NUMBER
C3 ACTION IS A LIMITED CIVIL CASE
Amount demanded ~
~
does not exceed $ 10,000
exceeds $ 10,000, but does not exceed $ 25,000
Q'J ACTION IS AN UNLIMITED CIVIL CASE (exceeds $ 25,000)
~~ ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
~ from unlimited to limited
plaintiff(name ornames)i Charlotte Kernan and Josh tuloore
alleges causes of action againstdefendant(nsms ornames)i Regenta of the Univetnity of California, City aod
County of San Francisco, Eleanor Drey, M.D., William Winkelman, M.D., Does l to 100
2. This pleading, including attachments and exhibits, consists of the following number of pages:
3. Each plaintiff named above is a competen( adult
a. ~ except plaintiff (nsms):
~ a corporation qualified to do business in California
(1)
~
(2)~ an unincorporated entity (describe)i
a public entity (describe):
~
(3)
(4) a minor
~ ~ an adult
for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(5)~
(a)
(b)~ other (specify)i
other(specffy)i
b. ~ except plaintiff (name)i
~ a corporatian qualified to do business in California
(1)
(2)~
~
an unincorporated entity (describe)i
a public entity (descrtbs)i
(3)
(4)~ a minor
~ ~ an adult
for wham a guardian or conservator of the estate or a guardian ad litem has been appointed
~
(5)
(e)
(b)~ other (specify)i
other (specify)i
~ Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Pne I 13
Fofm
1
AFP'dion oobmwf Uw r,—.
deelcouncfotColdofnn
Jl« IL'OMPLAINT-Personal Injury, Property cnd nfcwlpfmwde.tn2312
www cond Iio
caen
2MTILj ()IER)IA[ (RRIII'"
Jnn"*N I,
PI.D-PI-SOI iRn
Damage, Wrongful Death Kernan, Charlotte
PLD-PI-001(2
SHORT TITLE: CASE NUMSER
Kernan v. University of California-San Francisco
Ft rot CAUSE OF ACT(ON- General Negligence Page g
(number)
ATTACHMENT TO ~ Complaint ~ Cross-Complaint
(tfse s separate cause of action form for each cause of action.)
GN-1. Plaintiff(name): Charlotte Kernan, Josh Moore
slleges that defendant (name):Regents of the IIniversity of California, City and County
of Sen Francisco, Eleanor Dray, W.D., William Winkelman, W.D.
(lsd Does 3 to 1IIB
was the legal(proximate) cause of damages to plaintiff.
By the followingacts or omissions to act, defendant
negligently caused the damage to plaintiff
on(rats): On or about November 1), 2016
at(place): San Francisco General Hospital, San Francisco, California
(dsscripiion of reasons for Iisbiiity):
Plaintiff is informed and believes and thereon alleges that at
all times relevant herein, each of the defendants was the
agent, employee, servant and joint venturer of each of the
remaining defendants and that in doing the things hereaftez
alleged, was acting within the course, scope and authority of
such agency, employment and joint venture, and with the
consent and permission of each of the other defendants.
On oz about November 4, 2016, Charlotte Kernan was admitted to
San Francisco General Hospital for an External Cephalic
Version (RECVM). The ECV procedure was intended to rotate the
position of plaintiff's healthy
first" fetus, which presented in a
breech fashion, to a "head position. The ECV procedure
was performed by Eleanor Drey, M.D. and assisted by William
Winkelman, M.D..
At all times herein, Defendants Drey and Winkelman employed by
defendant Regents of the University of San Francisco as
medical physicians and all acts and omissions alleged herein
were done in the course and scope of their employment..
Defendants Drey and Winkelman, and Does 1-100, performed the
ECV negligently and caused the death of plaintiff's daughter.
The defendants'erformance of the ECV and the death of the
child was in breach of the professional standard of care.
Plaintiff Moore was in the operating room and observed t: he
procedure.
As consequence of the negligent acts and omissions of the
defendants, and each of them, plaintiff Charlotte Kernan
suffered damages as alleged hereinabove.
Pgefof 1
Fo rm Appro ed for Dpi oner Dec CAUSE OF ACTION- General Negligence cmleofc promo
J dier f 0 unoil
f Calrfomie
PLD.Pf-egf (2) (Rer. Janume 1. 2007I
~oI 12512
onm(ongou
LJ ESSENTIAl FORMS'" Kernan, Charlotte
4.
SHORT TITLE:
3
~
. U 'tf
Plaintiff (name)r
f C I'f '
3
is doing business under the fictitious name (specify):
7
CASE NUMBER
and has complied with the fictitious business name laws.
5. Each defendant named above is a natural person
a. gg except defendant (name):
University of California
c. ~ except defendant (name)f
(1) ~
~ a business organization, form unknown
a corporation
(1) ~
~ a business organization, form unknown
a corporation
(2)
(3) ~ an unincorporated entity(describe)r
(2)
(3) ~ an unincorporated entity (describe)r
(4) ~State
a public entity (describe):
of California University
(4) ~ a public entity (descn'be)r
(5) ~ other (specify): (5) ~ other (specify)r
b. Qg except defendant(name):
City and County of San Francisco
d. ~ except defendant (name):
(1) ~
~ a business organization, form unknown
a corporation
(1) ~
~ a business organization, form unknown
a corporation
(2)
(3) ~ an unincorporated entity(describe):
(2)
(3) ~ an unincorporated entity(descnbe)f
(4) QQ a public entity (descnbe):
a charter municipality
(4) ~ a publicentity(descnbe)r
(5) ~ other (specify): (5) ~ other (specify):
6.
~ Information about additional defendants who are not natural persons is contained in Attachment 5.
The true names of defendants sued as Does are unknown to plaintiff.
a. Qg Doe defendants(specify Doe numbers): 1-qA were lhe agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [Q Doe defendants(specify Doe numirers);q1 -1 AA are persons whose capacities are unknown to
plaintiff.
T. ~ Defendants who are joined under Code of Civil Procedure section 382 are (names)f
8, This courl is the proper court because
a.
b.
~ at least one defendant now resides in its jurisdictional area.
QJ the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c.
d.
~
~
injury to person or damage to personal properiy occurred in its jurisdictional area.
other (specify)'.
9. ~~
a.
Plaintiff is required to comply with a claims statute, and
has complied with applicable claims statutes, or
b.~ is excused from complying because (specify)r
PCIPPIJJUI IRU
3U tr I,2lxirl CORRPLAINT-Personal Injury, Property PB2IB
Damage, Wrongful Death Kernan, Charlotte
LJ EIIIRI'IAI fllRAII"
PLD-PI-001
SHORT TITLE: CASENUMBER
Kernan v. University of California-San Francisco
10, The following causes of action are attached and the statements above apply to each (eacb comp(atnt must have one or more
causes of action attached):
a.
b,
~
Qg
Motor Vehicle
General Negligence
c.
d.
~
~
Tort
intentional
Products Liability
e.
f.
~
~
Premises Liability
Other (specify):
11. Plaintiff has suffered
a.
b.
~
~ wage loss
loss of use of property
c.
d.
~
~
hospital and medical expenses
general damage
e.
f.
~
~ properly damage
loss of earning capacity
g. ~ other damage (specify):
12. ~~
e.
The damages claimed for wrongtul death and lhe relationships of plaintiff to the deceased are
listed in Attachment 12.
b. ~ as follows:
13. The relief sought in this complaint is within the jurisdiction of this court.
13L plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. (1) QQ compensatory damages
(2) C3 punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) Qg according to proof
{2)~ in the amount of: $
15. ~ The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers).
All paragraphs
Date: January 31, 2018
Cjj)LILLftflF RRRNAN *TIrl .TARP tAARR
nYPEOR PRINT NAME I iSIGNATURE OF(IIAINTIFF One(TTORNye)
PLO-PIO01 iRee 33003IT I, 200TI COMPLAINT-Personal Injury, Property Pg 3M3
Damage, Wrongful Death Charlotte
I e FORM%'"
jest(RTIAI Kernan,
EXHIBIT B
EXHIBIT B
Charlotte Ker'nan
215 Panorama Drive
San Francisco, CA 94131
(415) 936-6449
November 6, 2017
Dr. William Winkelman, M.D.
Pliscilla Chan aud Mark Zuckerberg San Francisco General Hospital and Trauma Center
1001 Potrero Ave, Ward 6D, San Francisco, CA 94110
San Francisco, CA 94110
Re; Your Patient: Ms. Charlotte'Kernan
Date of Birth: 01/2g/19g5
Medical Record //: 06021535
Date of Loss: 11/07/2016
Rc; Medical Malpractice Notice Letter
Ms, Chariotte Keman and
Zhckerberg San Francisco General Hospital,
Eleanor Drey, M,D.,
William Winkelman, M,D,,
iuan Vargas, M,D„
Sara Netvmann, M,D,,
Rebecca Jackson, M.D., Chief, and
Margaret Hutchison, CMN
Dear Dr. William Winkelrnan,
Pursuant to California Code of Civil Procedure ("CCP"), sections 364, 365, you are hereby given
notice that Charlotte Kernan intends to comznence a lawsuit agamst you for damages brought on
by your professional malpractice, as you failed to provide treatment that mct the appropriate
"medical standard of care" under the circumstances, which resulted in the induction of labor and
delivery of the demised fetus of Charlotte Keman and J'oshua Moore on November 7, 2016.
The treatment provided by the named physicians, midwives and/or other health care
pmfessionals was neghgent, in many areas, resulting in care that feil below the accepted standard
of practice in the industry, and caused injury and des1h to Ms. Kcrnan's f72g term baby. Medical
malpractice also occurred when an error or mistake was made by a medical professional resulting
in the hatm and/or death and other associated damages and injuries.
12-14-2017 20170094911 SR20171214000090
Though roost of the time we can expect to receive quality care I'rom medical professionals,
situations do arise where negligence occurs and mistakes happen. Some, examples in the present
instance hrclude:
- Failure to administer medications properly
- Failure to prescribe the con cot medication/dose
—
Failure to diagnose a medical condition
— Misdiagnosis.of 0 medical condition
—
Anesthesia erroi s
- Surgical errors
- Failure to order/follow up on lab tests
- Pre-Birth injuries
ln March, 2016, your patient, Charlotte Keman, upon discovering that she was pregnant in
Thailand, presented to Zuckerberg San Francisco General Hospital ("ZSFGH") to confirm her
pregnancy, Qn May 10, 2016, she presented for a 12 week scan which showed her baby
measuring within normal patameters. She was scheduled for regular visits with her midwife,
Margaret Hutchison. She had appointments every 5 weeks (which included bloods, screenings,
heart tone and measurements), She had a 20 week scan on June 23, 2016 and the baby was
identified as a girl, all measurements were within normal parameters,
Ms. Keman spoke with her lvlidwife Margaret about the options of delivering out of hospital, of
which she was supportive and suggested Sar. Francisco Birth Center ("SF") and Marin City Birth
Center ('tMC"), SF was full for Ms. Kernan's due date, thereby causing her to present to MC.
Her last appointment with Midwife Hutchison at ZSFGH was on Scptentber 23, 2016.
At 33 weeks, she transferred her care to MC, where she was assigned to midwife, Kiki Jordan,
who upon admittuig her at her first appomtment, was able to locate her fetus in a head-dawn
positioii.
At week 35, Midwife Kiki was unable to confidently feel Ms, Kernan's fetus*s head in the
desired position and agreed to check agaiu the following week, before taking any action. The
following week she was unable again to feel the fetus's head and feltsure thatthe fetus was in a
breech position.
Midwife KRi suggested that they look f'r a physician to perform an External Cephalic Version
("ECV*'). The followiug week, on October 21, 2016, Ms. Kernan was registered for an
ultrasound at IJCSF Medical Center to confirm the breech position. Once confirmed, Midwife
Kiki inovcd to locate a physician who would help.
Midwife Kiki spoke to Dr, Juan Vargas, at Zuckerberg San Francisco General Hospital, who told
her that they could perform this procedure and Ms. Kernan was registered for an FCV procedure
on November 2, 2016.
The medical professionals breached the standard of care, which required. them to use the same
degree of knowledge, skiU, and ability as an ordinarily careful professional would exercise under
similar circumstances, ultimately resulting in Ms. Kernan's 39 1/7 week female fetus to be found
without cardiac activity and delivered by vaginal delivery following intrauterine fetal demise,
2017009490 5820171114005393
certain risks
When Ms, Kcrnan presented to the hospital, she was informed that there werc
complications, preznature labor„
involved with an ECV procedure, which were stated to be: cord
placental abruption.
natural birth
Ms. Kernan indicated to the Doctors that she was a prime candidate for a healthy,
and that she wanted to avoid surgery wherever possible and that she did not
want to put her child
Ms. Keman was
at any risk and that she wanted to give her the best chance to be born naturally,
50's'0 successful
advised that approximately 6 ECVs per week were performed at ZSFGH, with a
turn rate, No risk of death or damage to her baby was ever mentioned.
The ECV pmcedure was initially attempted, without an epidural, in a room in the labor ward by
Drs. William Winkehnsn and Sara Newmann and was unsuccessful. At that point, Ms, Kernan
scheduled C-section the
was given an ultimatum — to try again in 2 days or come in for a
following day.
to do. She
Ms. K.ernan was unsatisfied with her options, she felt rushed and was unsure what
asked if she could wait and asked if she couki go home and wait a little while as
her baby was
allow her to go home
not yet 411 weeks. She was told that she could not, and that they would not
and wait for labor or hope that the baby turns around, She was told again that her options were
was a prime
to try again or go for a C-section. She once again stated to the Doctors that she
possible. She
candidate for a healthy, natural bhth and that she wanted to avoid surgery where
the
re-stated that she did not want to put her child at any risk and that she wanted to give
would be
baby the best chance to be born naturally, It was decided that a second ECV attempt
pursued. Ms. K.ernan went home to rest and presented at ZSFGH on 11/114/lb. She was
informed that the head of the department, Dr, Eleanor Dray, was going to attend and that she was
"very good*'ith 0 track record in successful turns. Ms, Kernan felt reassmed,
Ms. Kernan was then taken into an operating theater and given a spinal epidural, There
procedure,
were numerous people in the theater, The Doctors began the procedure. During the
feel a massive pressure
Ms, Kernan was unable to feel the Doctors pushing on her belly, but did
Kernan's partner, Joshua
and pain in her chest, but was reassured that this was normal. Ms.
Moore, 1vas sitting at her head, holding her hand and focusing on talking her through
the
procedure.
Dr. Dray was standing to the left of Ms. Kernan's partner. Ms. Keman
noticed, although
she could not feel nor sce hcr belly {the table was tilted so that her feetwere higher than her
procedure, it looked
head), that she could scc Dr. Drcy, From hcr angle, at one point during the
as though Dr. Drcy was performing CPR {hard, sharp, jerking movements) on herbdly area, so
and pulled them up for
much so that Dr, Dray's scrub pants started to fall down and a nurse game
Dr. Drcy, Ms, Kernan's fetus'eart rate was monitored throughout, there
was a small dip in
her heart rate, it came back up, which reassured everyone,
it appeared that they were
Dr. William Winkelman was assisting Dr. Drey, In thc beginning,
and ruled the
moving the baby together, but at some point Dr. Drey took over completely
procedure successR1.
and seen as a
There was some excitement around the procedure; being that it was a difficult turn
great success. One of the nurses, Nurse Tia, who had been with Ms. Keman, before and during
that Dr. Drey had to
the procedure, remarked to Ms. Kernan what a tough turn it had been and
"really get in therel",
Z017009490 5810171314005393
Thereafter, Ms, Kernan was transferred to a room and she and hcr baby were monitored for 40
minutes. She was told that the baby was happy and healthy and that shc co~ld go home once the
epidural had worn off and she was able to walk herselt'to thc bathroom. Ms. Kernan was not
given any instnictions to count any kicks nor track movements. At approximately 4;00 p,m, Ms,
Keman was released from the hospital.
That evening Ms. Kernan felt seine movement. The following morning, on Saturday November
6, 2016, Ms, Kernan proceeded to go about her day. While running crt ands (around 11;00 a.m,)
she noticed that she wasn't sure if she had felt any movement that morning. She. asked her friend
(a roidwife from the UK), who had come to stay with her and Joshua, to have a
listen ivhen she
got home, She was unable to track a heartbeat.
Ms. Kernan then called the hospital and was told her to come in. She went to the hospital, and
was initially seen by a nurse„who was unable to find a heartbeat and, at that point, brought in a
portable ultrasound machine. Dr Rel&ecca Jackson came to do an ultrasound and was assisted by
Dr William Winkelman, Charlotte Kernan was informed that her baby had died.
Ms, Kernan was given several options; go home & wait for labor, go home to grieve then oame
back at a later time or remain at the hospital and begin the process of labor. Ms, Keman chose to
stay at the hospital and begin labor. Ms, Kemsh and Joshua Moore's 39 2/7 week female fetus
was found without cardiac activity and was delivered by vaginal delivery following intrauterine.
1'etal demise on Monday morning November 7„2017 at 12.20 a.m.
Vpon dehvery, Dr Juan Verges came to spoke with Ms, Kernan, firstly to express his
condolences and secondly to inform her that immediately, upon first sight of her baby and
placenta, he, could scc no cause of death nor indicators. He asked if the parents would like an
autopsy performed, to which they said yes. He stated that hc would be happy to go through the
report at a date in the future when they felt ready.
An Autopsy Report, with a Provisional Autopsy Diagnosis, with a signout date of November 9,
2016 was issued. A Firial Diagnosis following review of all pathology slides, with a signout date
of December 14, 2016, was issued by Patrick Devine, MD, PhD and Rebecca Wolksy MD.
Charlotte Kernan and Joshua Moore believe that the health care providers named above and
herein had a duty to treat Ms. Kernan and her intrauterine fernale fetus with the degree cf skill,
knowledge, and care that other doctors in similar circumstances would use and that they violated
that duty.
Your failure to exercise reasonable medical care resulted in an unnecessary delay of treatment.
,
As Ms. Keman's gynecologist and health care providers, it was incumbent upon you to recognize
symptoms requiring fruther testing and treatment. You failed to do so. Your failure resulted in
Ms. Kernan's loss ofher and Mr. Moore's 39 2/7 female fetus, who was delivered by vaginal
delivery following fetal demise, Through proofs, Ms. Kernan will demonstrate that excessive
force was used during the procedure by Dr. Drey and that caused the demise of her baby.
Further, a brain autopsy should have been perforined, due to the fart that a "sensitizing
event" (an aggressive ECV) was performed fess than 24hrs prior to death.
As a direct and proximate result of your actions and omissions Ms. Keman and her partner,
Joshua Moore, have suffered damages including, hut not limited to:
Loss of life
Medical bills
Z017009490 5820171214005393
Present and future medical costs
Lost wages
Emotional distress
Loss of consortium
Fain and suffering
this letter to your
Ms, Kernan seeks compensation representing the above damages. Please give
insurance company immediately. If for any reason we do not hear from you or a representative
of
letter, we will commence
your insurance company within thirty (30) days of your receipt of this
legal action.
Yours truly,
Charlotte Kernan
2017009490 5830171314005393
'|11a-7017
EXHIBIT C
ANN H. LARSON (State Bar No. 176461)
JOHN C. WON (State Bar No. 242743)
CRADDICK, CANDLAND & CONTI
A Professional Corporation
2420 Camino Ramon, Suite 202
San Ramon, CA 94583-4202
Telephone: (925) 838-1100
Facsimile: (925) 743-0729
F.-mail: alarson@ccclawfirm.corn
Attorneys for Defendants,
REGENTS OF THE UNIVERSITY OF
CALIFORNIA, ELEANOR DREY, M.D.,
and WILLIAM WINKELMAN, M.D.
10 IN THE SUPFRIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNI'Y OF SAN FRANCISCO
12 CHARLOTTE KERNAN and JOSH No. CGC-18-564062
MOORE,
13
Plaintiffs, SPECIAL INTERROGATORIES,
14 SET NO. ONK
vs.
15
REGENTS OF THE UNIVERSITY OF
16 CALIFORNIA; CITY AND COUNTY OF
SAN FRANCISCO; ELFANOR DREY,
17 M.D4 WILLIAM WINKELMA'N, M.D.„
18 Defendants.
19
20 PROPOUNDING PARTY: Defendant, REGENTS OF THE UNIVERSITY OF C