On August 10, 2016 a
Motion-Secondary
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
V ORIGINAL
THOMPSON & COLEGATE LLP
3610 Fourteenth Street D
F LE
I
l») P. O. Box 1299 SUPERIOR COURT 0F CALIFORNfi
Riverside, California 92502 COUNTY 0F SAN BERNARDINO
SAN BERNARomo 015mm
Tel: (951) 682-5550
Fax: (951) 781-4012 AUG 2 3 2022
DIANE MAR WIESMANN (SBN 124409) .ua.
dwiesmann@tclaw.net
JUSTIN J. JANZEN (SBN 242556) F’AO AN Z. DEPU 2|
jjanzen@tclaw.net
Attorneys for Defendant/Cross—Complainant,
DIGNITY HEALTH
(erroneously sued and served as ST. BERNARDINE MEDICAL CENTER)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
LORI BUSH, an individual; CASE NO. CIVDSl613161
'«g l'\
Plaintiff, Hon. John M. Pacheco
'Tl
Dept: S3 1
v.
DECLARATION 0F CORYNTHIA
ST. BERNARDINE MEDICAL CENTER, a WINCN IN SUPPORT 0F DEFENDANT
business entity form unknown; DIGNITY DIGNITY HEALTH’S REPLY TO
HEALTH, a California Corporation; and DOES LAINTIFF’S OPPOSITION TO ITS
1 through 200, inclusive, MOTION FOR JUDGMENT
NOTWITHSTANDING THE VERDICT
Defendants. PURSUANT TO CODE OF CIVIL
PROCEDURE SECTION 629
DIGNITY HEALTH,
Cross-Complainaht, TRIAL DATE: 02/14/2022
ACTION FILED: 11/08/2016 (FAC)
v.
DATE: August 30, 2022
TOTAL PROFESSIONAL NETWORK, INC, TIME: 8:30 am.
and ROES 1- 00, inclusive,
l DEPT: S31
Cross-Defendants.
///
///
1
DECLARATION OF CORYNTHIA WINCN
I, CORYNTHIA WINCN, declare as follows:
[J 1. I am a Legal Assistant employed at the law office of Thompson & Colegate LLP,
La.)
attorneys for Defendant/Cross-Complainam, DIGNITY HEALTH, erroneously sued and served as ST.
BERNARDINE MEDICAL CENTER (hereinafter “DIGNITY HEALTH”). I make this declaration in
support of DIGNITY HEALTH’S Reply to Plaintiff‘s opposition to DIGNITY HEALTH’S motion for
judgment notwithstanding the verdict. I have personal knowledge of the facts set forth herein, and if
called upon to testify thereto, I could and would competently do so under oath.
2. On July 6, 2022, I contacted Bosco Legal Services to file DIGNITY HEALTH’S Notice
of Motion and Motion for Judgment Notwithstanding the Verdict with the San Bernardino Superior
Court. They picked up the moving papers that day for filing and thereafter indicated they had
delivered them t0 the Clerk’s Office on that same date.
3. On Friday, July 15, 2022, Bosco Legal Services-returned to me the Court’s Notice of
Return Document rejecting our motion. Since it was 1:21 p.m., I knew that the clerk’s office was
already closed.
4. On Monday, July 18, 2022, I called the San Bernardino Superior Court clerk at 8:15
am. and talked with Paulette. I indicated t0 Paulette that our motion was rejected in error. She looked
into the situation and agreed with me that the Court did make an error. She told me t0 send the
documents back t0 the Court for filing and she would backdate it to July 6, 2022. Immediately after
our phone call, I contacted Bosco Legal Services and indicated to them to please take our motion back
to San Bernardino Superior Court and that Paulette was waiting for it. At 1:45 pm. that day, Bosco
emailed me that our motion was submitted t0 the clerk’s office. .
5. On Wednesday, July 20, 2022, I checked the San Bernardino Superior Court docket
and our motion was still not showing on the docket. I called and talked to a clerk at 10:15 a.m. I
explained our situation and indicated that I needed to speak with Paulette. The clerk took down my
information. Paulette called me back at 10:45 am. indicating that she did in fact file the paperwork
and backdated it July 6, 2022; it just had not been scanned into. the system. She advised me that our
motion would be scanned in by the end 0f the day and, it was.
///
2
DECLARATION OF CORYNTHIA WINCN
Document Filed Date
August 23, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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V ORIGINAL THOMPSON & COLEGATE LLP 3610 Fourteenth Street D F LE I l») P. O. Box 1299 SUPERIOR COURT 0F CALIFORNfi Riverside, California 92502 COUNTY 0F SAN BERNARDINO SAN BERNARomo 015mm Tel: (951) 682-5550 Fax: (951) 781-4012 AUG 2 3 2022 DIANE MAR WIESMANN (SBN 124409) .ua. dwiesmann@tclaw.net JUSTIN J. JANZEN (SBN 242556) F’AO AN Z. DEPU 2| jjanzen@tclaw.net Attorneys for Defendant/Cross—Complainant, DIGNITY HEALTH (erroneously sued and served as ST. BERNARDINE MEDICAL CENTER) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT LORI BUSH, an individual; CASE NO. CIVDSl613161 '«g l'\ Plaintiff, Hon. John M. Pacheco 'Tl Dept: S3 1 v. DECLARATION 0F CORYNTHIA ST. BERNARDINE MEDICAL CENTER, a WINCN IN SUPPORT 0F DEFENDANT business entity form unknown; DIGNITY DIGNITY HEALTH’S REPLY TO HEALTH, a California Corporation; and DOES LAINTIFF’S OPPOSITION TO ITS 1 through 200, inclusive, MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT Defendants. PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 629 DIGNITY HEALTH, Cross-Complainaht, TRIAL DATE: 02/14/2022 ACTION FILED: 11/08/2016 (FAC) v. DATE: August 30, 2022 TOTAL PROFESSIONAL NETWORK, INC, TIME: 8:30 am. and ROES 1- 00, inclusive, l DEPT: S31 Cross-Defendants. /// /// 1 DECLARATION OF CORYNTHIA WINCN I, CORYNTHIA WINCN, declare as follows: [J 1. I am a Legal Assistant employed at the law office of Thompson & Colegate LLP, La.) attorneys for Defendant/Cross-Complainam, DIGNITY HEALTH, erroneously sued and served as ST. BERNARDINE MEDICAL CENTER (hereinafter “DIGNITY HEALTH”). I make this declaration in support of DIGNITY HEALTH’S Reply to Plaintiff‘s opposition to DIGNITY HEALTH’S motion for judgment notwithstanding the verdict. I have personal knowledge of the facts set forth herein, and if called upon to testify thereto, I could and would competently do so under oath. 2. On July 6, 2022, I contacted Bosco Legal Services to file DIGNITY HEALTH’S Notice of Motion and Motion for Judgment Notwithstanding the Verdict with the San Bernardino Superior Court. They picked up the moving papers that day for filing and thereafter indicated they had delivered them t0 the Clerk’s Office on that same date. 3. On Friday, July 15, 2022, Bosco Legal Services-returned to me the Court’s Notice of Return Document rejecting our motion. Since it was 1:21 p.m., I knew that the clerk’s office was already closed. 4. On Monday, July 18, 2022, I called the San Bernardino Superior Court clerk at 8:15 am. and talked with Paulette. I indicated t0 Paulette that our motion was rejected in error. She looked into the situation and agreed with me that the Court did make an error. She told me t0 send the documents back t0 the Court for filing and she would backdate it to July 6, 2022. Immediately after our phone call, I contacted Bosco Legal Services and indicated to them to please take our motion back to San Bernardino Superior Court and that Paulette was waiting for it. At 1:45 pm. that day, Bosco emailed me that our motion was submitted t0 the clerk’s office. . 5. On Wednesday, July 20, 2022, I checked the San Bernardino Superior Court docket and our motion was still not showing on the docket. I called and talked to a clerk at 10:15 a.m. I explained our situation and indicated that I needed to speak with Paulette. The clerk took down my information. Paulette called me back at 10:45 am. indicating that she did in fact file the paperwork and backdated it July 6, 2022; it just had not been scanned into. the system. She advised me that our motion would be scanned in by the end 0f the day and, it was. /// 2 DECLARATION OF CORYNTHIA WINCN