On December 19, 2019 a
Motion-Secondary
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 03/17/2020 03:49 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk
1 Andrew L. Ellis, Esq. State Bar# 167091
ELLIS LAW CORPORATION
2 2230 E. MAPLE A VE.
EL SEGUNDO, CA 90245
3 Telephone: (310) 641-3335
4
Attorney for Plaintiff
5 ALVARO GARCIA
File # 209924
6
SUPERIOR COURT OF THE STATE OF CALIFORNIA
7
IN THE COUNTY OF LOS ANGELES
8
9 ALVARO GARCIA, an individual CASE NO.: 19STCV45995
10 Plaintiff,
OPPOSITION TO DEMURRER
11
vs.
12 BEHAVIORAL HEALTH SERVICES,
INC.,a California Corp.; BHS-AMERICAN
13 RECOVERY CENTER, a business form
unknown; RAINER BANSUAN, M.D., an
14 individual; SON LE, M.D., an individual,
TUAN D. NGUYEN, M.D., an individual;
15 and DOES 1-100, inclusive
16
17
Defendants.
18
TO ALL PARTIES HEREIN AND TO THEIR RESPECTIVE ATTORNEYS OF
19
RECORD:
20
Plaintiff Alvaro Garcia hereby opposes Defendants' Demurrer to Plaintiffs Complaint.
21
This opposition is based on the fact that Plaintiffs' Complaint sufficiently pleads facts to allege
22
Plaintiffs First, Second, Fourth and Fifth causes of action. Based thereon, Plaintiff Alvaro
23
Garcia submits that Defendant's demurrer should be overruled in its entirety.
24
25 Dated: March 17, 2020
26
27 :Anewf:Ell!s
Alyson T. Marchiondo
28 Attorneys for Plaintiff
OPPOSITION TO DEMURRER
Document Filed Date
March 17, 2020
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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