On December 19, 2019 a
Party Discovery
was filed
involving a dispute between
Garcia Alvaro,
and
Bansuan M.D. Rainer,
Bansuan Rainer,
Behavioral Health Services Inc. A California Corp,
Bhs - American Recovery Center,
Bhs - American Recovery Center A Business Form Unknown,
Le M.D. Son,
Le Son,
Nguyen M.D. Tuan D.,
Nguyen Tuan D.,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 02/19/2021 02:01 PM Sherri R. Carter, Executive Officer/Clerk of Court, by G. Moreno,Deputy Clerk
1 MARGARET M. HOLM, State Bar No. 71252
margaret.holm@clydeco.us
2 CHIAYU V. CHANG, State Bar No. 245484
chiayu.chang@clydeco.us
3 CLYDE & CO US LLP
2020 Main Street, Suite 1100
4 Irvine, California 92614
Telephone: (949) 852-8200
5 Facsimile: (949) 567-7850
6 Attorneys for Defendants, BEHAVIORAL HEALTH SERVICES, INC., BHS -
AMERICAN RECOVERY CENTER, RAINER BANSUAN, M.D., SON LE,
7 M.D., and TUAN D. NGUYEN, M.D.
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, POMONA COURTHOUSE
10
11 ALVARO GARCIA, an individual, Case No. 19STCV45995
12 Plaintiff, [Assigned for All Purposes to:
Hon. Gloria White-Brown, Dept. J]
13 v.
DECLARATION OF CHIAYU V. CHANG
14 BEHAVIORAL HEALTH SERVICES, INC., FOR MOTION TO QUASH SUBPOENA
a California Corp.; BHS - AMERICAN FOR THE PRODUCTION OF RECORDS
15 RECOVERY CENTER, a business form FROM THE LOS ANGELES COUNTY
unknown; RAINER BANSUAN, M.D., an DEPARTMENT OF PUBLIC HEALTH
16 individual; SON LE, M.D., an individual; AND FOR $1,960.00 IN SANCTIONS
TUAN D. NGUYEN, M.D., an individual; and AGAINST PLAINTIFF AND
17 DOES 1-100, inclusive, PLAINTIFF'S COUNSEL
18 Defendants. [Filed concurrently with Motion to Quash
Subpoena; Separate Statement and
19 [Proposed] Order]
20 Date: June 9, 2021
Time: 10:00 a.m.
21 Dept.: J
22 [Reservation ID: 545350045834]
23 Action Filed: December 19, 2019
Trial Date: March 8, 2022
24
25 DECLARATION OF CHIAYU V. CHANG
26 I, Chiayu V. Chang, do hereby state and declare as follows:
27 1. I am an attorney licensed to practice law before all courts of the State of California,
28 and a Senior Associate with the firm of Clyde & Co US LLP, counsel of record for Defendants,
5389594v1 1
REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONE
Document Filed Date
February 19, 2021
Case Filing Date
December 19, 2019
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 08/24/2023
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