On December 30, 2019 a
Party Statement
was filed
involving a dispute between
Maya Jose,
and
Adams M.D. Fred Aka Fraidon Babanejadyanghedjen,
Chlb Llc Dba College Medical Center,
Clinica Sierra Vista Exact Business Form Unknown,
College Medical Center Exact Business Form Unknown,
St. Mary'S Hospital Of Long Beach Exact Business Form Unknown,
Taylor D.O. Bruce B.,
Cruz M.A.Doe 151 Jasmine,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 04/20/2021 10:27 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,Deputy Clerk
Nathaniel J. Friedman, Esq. (SBN: 33135)
NATHANIEL J. FRIEDMAN
A Professional Corporation
8484 Wilshire boulevard, Suite 570
Beverly Hills, CA 90211
(310) 277-2889
Attorney for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
10 GISELLE MAYA, a minor, by JOSE MAYA, ) CASK NO. 19STCV46725
her guardian ad litem,
) (JUDGE KIM)
)
12 Plaintiff, )
) PLAINTIFF'S C.C.P. g 437c(b)
V. ) "SEPARATE STATEMENT" OF
DISPUTED MATERIAL FACTS
14 FRED ADAMS, M.D., AKA FRAIDON )
BABANEJADYANGHEDJEN, JAZMIN )
15 CRUZ, M.A., originally sued as DOE 1; and ) Date of Hearing: May 4 & 6, 2021
DOES 2-500 Time: 8:30 a.m.
) Department: S27
Defendants )
17 )
18
COMES NOW PLAINTIFF, by counsel, and pursuant to the (unconstitutional)
20 requirement of C.C.P. $ 437c(b) under protest, files and serves this "Separate Statement of
21 Disputed Material Facts" in opposition to Defendants Fred Adams, M.D. and Jazmin Cruz,
22 M.A.'s Motions for Summary Judgment, hearing upon which have been noticed for May 4 and 6,
23 2021, at 8:30 a.m., in Dept. S27 of the above-entitled court.
24 DATED: March 25, 2021 NATHANIEL J. FtuEDMAN
A Professional Corporation
25
By
at aniel J. Frie man
Attorney for Plaintiff
7c 'ARATE T T ME T" D P D TE
Document Filed Date
April 20, 2021
Case Filing Date
December 30, 2019
Status
Summary Judgment 05/10/2021
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Electronically FILED by Superior Court of California, County of Los Angeles on 04/20/2021 10:27 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,Deputy Clerk Nathaniel J. Friedman, Esq. (SBN: 33135) NATHANIEL J. FRIEDMAN A Professional Corporation 8484 Wilshire boulevard, Suite 570 Beverly Hills, CA 90211 (310) 277-2889 Attorney for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES 10 GISELLE MAYA, a minor, by JOSE MAYA, ) CASK NO. 19STCV46725 her guardian ad litem, ) (JUDGE KIM) ) 12 Plaintiff, ) ) PLAINTIFF'S C.C.P. g 437c(b) V. ) "SEPARATE STATEMENT" OF DISPUTED MATERIAL FACTS 14 FRED ADAMS, M.D., AKA FRAIDON ) BABANEJADYANGHEDJEN, JAZMIN ) 15 CRUZ, M.A., originally sued as DOE 1; and ) Date of Hearing: May 4 & 6, 2021 DOES 2-500 Time: 8:30 a.m. ) Department: S27 Defendants ) 17 ) 18 COMES NOW PLAINTIFF, by counsel, and pursuant to the (unconstitutional) 20 requirement of C.C.P. $ 437c(b) under protest, files and serves this "Separate Statement of 21 Disputed Material Facts" in opposition to Defendants Fred Adams, M.D. and Jazmin Cruz, 22 M.A.'s Motions for Summary Judgment, hearing upon which have been noticed for May 4 and 6, 23 2021, at 8:30 a.m., in Dept. S27 of the above-entitled court. 24 DATED: March 25, 2021 NATHANIEL J. FtuEDMAN A Professional Corporation 25 By at aniel J. Frie man Attorney for Plaintiff 7c 'ARATE T T ME T" D P D TE